Using Law and Advocacy to Win Accommodations for Clients with Electromagnetic Hypersensitivity (EHS): Part 1

  • February 06, 2021
  • David McRobert

Using Law and Advocacy to win Accommodations for Clients with Electromagnetic Hypersensitivity (EHS): Part 1 [1], [2]

By David McRobert[3]


This is part 1 of a two-part series on using law and advocacy to win accommodations for clients suffering from electromagnetic hypersensitivity (EHS) associated with use of wireless technologies including routers and cell phones.


Electromagnetic hypersensitivity (EHS) is explicitly recognized as a disability in many nations. However, individuals with EHS who make disability claims often are not accommodated by employers or service providers and tend to have limited success in the legal system. This paper provides an analysis of legal protections available in Canada for those living with EHS, and discusses the relationship between law, scientific advances, and the role of metapolicy in developing preventative policies that protect vulnerable persons and overall populations. The paper deals with, amongst other things, the role played by medical professionals in providing accommodation for EHS.

Recognizing and validating EHS is challenging for a number of reasons. Electromagnetic fields (EMF) and electromagnetic radiation (EMR) are odourless and invisible and there are numerous sources of in homes, workplaces, and public spaces. Thus, professional electromagnetic surveys are typically needed to identify sources of EMF and EMR. Industry experts and some medical specialists have argued that EHS cannot be diagnosed using traditional physiological techniques due to psychological factors, the range of non-specific symptoms, and a resemblance of symptoms to those associated with illnesses such as multiple chemical sensitivities (MCS). Consequently, there is a great deal of skepticism towards EHS, especially amongst industry-employed professionals, engineers and scientists, as well as many medical experts, judges and lawyers. These factors often present problems for the Canadian courts and tribunals when considering medical evidence on EHS. Establishing proof of a workplace-related triggering exposure is a key difficulty in EHS cases due to variations in reaction severity - even between several EHS-impacted employees - and because symptoms tend not to cease when the workplace source is removed.

Many of the frustrations that EHS advocates experience with legal and policy systems are related to metapolicies, particularly related to prevention of health impacts and requisite standards of evidence. For instance, Health Canada’s official position is that there is no scientific evidence connecting EMF exposure to the symptoms attributed to EHS, raising the question of whether this stance is truly reflective of evidence. Telecommunications companies seeking to expand markets for new devices and 5G technology have also shaped current EMF/EHS meta-policy, resulting in growing levels of EMFs in public and shared spaces.

Part 2 of this series will examine the challenges facing lawyers and experts associated with addressing alleged injury caused by EHS and other toxic substances through tort lawsuits. Lawyers, experts, and their clients face several legal challenges including: 1) identifying pathways, 2) calibrating dosages, 3) difficult diagnoses due to long latency periods, and 4) a duty on potential plaintiffs of workplace or health insurance claimants to mitigate harm. Many EHS tort cases are addressed through insurance programs when available. Some cases involving workplace exposures are also submitted to the Ontario Workers Safety and Insurance Board (WSIB), which has consistently refused to recognize EHS claims as legitimate disabilities.  Accommodations for EHS claimants are typically achieved through government legislation that protects the rights of individuals with ongoing disabilities and/or health impacts. These accommodations can raise conflicts due to competing rights, making creativity and a willingness to compromise essential in the development process. The Accessibility for Ontarians with Disabilities Act (AODA) was expected to significantly advance accessibility in Ontario. However, it is unclear whether any of the committees created through the AODA are examining accessibility standards for individuals suffering from EHS or similar conditions. The good news is that in several cases, organizations, public utility providers, landlords, and workplaces have been adopting a range of measures and accommodations for EHS-sensitive individuals. The bad news is that these individuals often have to make persistent efforts to obtain these modest accommodations. 

In the absence of constitutional amendments, mirror laws can address the regulatory and jurisdictional gaps that arise in the Canadian context and mitigate harms related to EMF/EMR, though this would have to be developed on the basis of sound meta-policies. Practical accommodation options that consider competing rights can be used in the short-term. In the long run, development of well thought-out EMF/EMR metapolicies and related laws and policies preventing EHS would be an excellent place to start.

Introduction to Part 1

A growing number of residents in many developed nations are adversely affected by electromagnetic radiation (EMR), electromagnetic fields (EMFs) and related phenomena. While some individuals report mild to moderate symptoms and mitigate the effects by avoiding the fields and radiation sources as best they can, others are so severely affected that they cease work and change their entire lifestyle.[4] This illness is referred to as “electromagnetic hypersensitivity” or EHS and now is explicitly recognized as a disability in many nations.

The World Health Organization[5] defines EHS as “...a phenomenon where individuals experience adverse health effects while using or being in the vicinity of devices emanating electric, magnetic, or electromagnetic fields (EMFs)… This reputed sensitivity to EMF has been generally termed “electromagnetic hypersensitivity” or EHS.”

The symptoms most commonly experienced include, “dermatological symptoms (redness, tingling, and burning sensations) as well as neurasthenic and vegetative symptoms (fatigue, tiredness, concentration difficulties, dizziness, nausea, heart palpitation, and digestive disturbances). The collection of symptoms is not part of any recognized syndrome.”[6]

Many individuals and potential clients are suffering from EHS—they come to lawyers with evidence of harm, and allege employers or service providers have failed to accommodate their disabilities by reducing electromagnetic field (EMF) exposure. Their success in having laws and the legal system address their concerns tends to be limited, even when they have ample financial resources. There also tends to be a degree of skepticism about EHS, especially amongst engineers and scientists employed by industry, many medical experts, and many judges and lawyers. These potential clients and their advocates working in the medical, health and legal fields find they must battle for institutional recognition of EMF disability rights and challenge the power of industries and government agencies who attempt to downplay the potential risks to the public posed by new and existing wireless technologies.

EMF and electromagnetic radiation (EMR) sources are numerous but typically include cell towers, wireless equipment, and personal devices such as cell phones, tablets, and laptops.

Electric and magnetic fields also are generated by household wiring, lighting, and electrical appliances such as microwave ovens, hair dryers, and toasters. Other common sources include computer monitors, photocopiers, fax machines, and fluorescent lights. Power lines and electric tools also emit EMFs. Some medical applications of EMFs include short-wave diathermy and magnetic resonance imaging (MRI). Electrical currents and fields also arise as “stray voltage” from inadequate grounding of buried cables and wiring. Patients and litigants also suggest that wind turbines cause EHS. While historical exposures were generally several orders of magnitude under the limits in internationally accepted standards there is growing evidence that more recent chronic exposures sometimes exceed them.[7]

Nonetheless, technological “fixes” and providing accommodations can be simple and effective in certain circumstances. Professional electromagnetic surveys can identify sources of lower frequencies such as power lines, improperly wired circuits (e.g. with ground return), and fluorescent lights, as well as sources of higher frequencies, such as computers, or the “internet of things”. Wireless systems can be replaced with wired ones, returning organizations to configurations typical in homes and workplaces in the 1990s and 2000s.

Addressing the health impacts of EMFs or radiation present challenges, as they cannot be seen and have no odour. This often presents problems for the courts and tribunals as procedural and substantive rights related to traditional disabilities such as mobility, visual and hearing impairments continue to evolve in developed nations.[8]

Accordingly, the Canadian courts and tribunals are struggling with medical evidence on EHS and other sensitivities. Experts retained by industries involved in causing EMFs often argue that EHS has a large psychological component and resembles multiple chemical sensitivities (MCS), a disorder associated with environmental exposures to chemicals. Moreover, for the past 15 to 20 years many government regulators and industry officials have argued that both EHS and MCS are characterized by a range of non-specific symptoms that cannot be independently verified using traditional toxicological or physiological techniques.[9]

In contrast, the courts regularly award damage for mould in real estate cases because reductions in property value can be quantified using accepted techniques that have been developed by real estate and property appraisal experts since about 1900. At the same time, the courts struggle with making damage awards to litigants on the basis that moulds can synergistically help to cause Multiple Chemical Sensitivities (MCS) and/or Environmental Sensitivities (ES) or depression, despite strong evidence that biochemical mechanisms of mycotoxins can spur MCS and ES.[10]

Yet, despite institutional reluctance to recognize the health effects of EMFs and EMR, there are many signs of severe implications of electromagnetic fields. These include:

-Biological effects can be measured at radiation levels thousands of times below current standards; and

-Electromagnetic “smog” levels increasing rapidly (orders of magnitude more coming with 5G technology).

The extent of EMF in the city of Salt Lake City in surveys undertaken in 2010s is represented in Figure 1. This figure shows the results of modeling of electromagnetic fields in Salt Lake City and illustrates peaks from telecommunications point sources and reflections.[11]

Law, Science, and Metapolicy

Communities and researchers pushing back against regulators and arguing that EMFs and EMR are sources of serious health impacts are at the edge of paradigm shifts in both law and science, carrying out novel science, exploring new biochemical and biological phenomena and connections, and advocating for new ideas.

Law and science share common features: both claim authority over evidence and conclusions; both claim a monopoly over what counts as “rational”; both claim what counts to be a credible witness. “Normal” science and law are seemingly decentralized, yet both activities are subject to financial forces and particular values and biases despite varying claims of degrees of objectivity by their practitioners.

Unlike law reform processes or court decision making, science is largely independently verifiable by replication or re-examination of original data and flawed decision-making is open to self-correction. Fundamental laws of nature are immutable (though our understanding improves over time), whereas court decisions and laws are human-made, mutable and even reversible at the stroke of a pen.

Both science and law strive to function on the basis of core principles such as accountability and transparency but law reform and court decision-making processes are more vulnerable to ideological pressures because of the constant interaction between political, social and legal systems. Consequently, law reform can fail to achieve its intended objectives.

Some key roles of the courts and tribunals[12] include: 1) to deconstruct experts and limit abuse of science by powerful actors such as corporations and government agencies; 2) to educate the public through civic education about reasonable behaviour; and 3) to redress wrongs and address some of the problems inherent in government decision-making systems by permitting judicial reviews by the courts which can overturn decisions. At the same time, it is important to bear in mind that the courts cannot offer miracle cures and difficult and complex cases often result in bad court precedents.

Differences between law and science include that law strives for closure, while science advances through hypothesis testing as argued by Sir Karl Popper and others.[13] Fact-finding in law is designed to persuade in short-term, but this is not so in science. Litigation and law reform are often based on narratives created by lawyers and public relations (PR) experts, while science advances through new evidence that can usher in paradigm shifts.[14]














Figure 1: This figure shows the results of modeling of electromagnetic fields in Salt Lake City and illustrates peaks from telecommunications point sources and reflections.

Legal rules often are not ‘scientific’ because the courts and regulators have to take into account uncertainty and conflicting evidence. One key consideration is that law relies on the concept of precedent. Precedent seeks to provide residents, business and property owners, financial investors and other organizations with reassurance about the stability of rules in legal decisions on property, contracts and torts and security and confidence about our legal and political system. As such, the legal system is loyal to concepts of equity and justice in ways that can seem counterfactual and illogical (and even seemingly unethical), while striving to be consistent with historical patterns.

In essence, our legal and government decision-making systems tend to be based on “metapolicies”. Metapolicies can be defined as policies on how to make policies.[15]

Metapolicies underpin laws and policies

When activists and advocates for law reform criticize or challenge particular laws or policies, it often is because they disagree with overarching metapolicies shaping those laws and policies. Reliance on science and evidence and long-term prevention goals must inform the core metapolicies underpinning laws on EMF to prevent EHS illnesses. For example, those advocates wishing to change a specific policy or address a regulatory challenge such as the use of wireless devices and WiFi in hospitals, arguably have to deconstruct the metapolicies and values underlying the current policies and practices.

Many of the frustrations that EHS advocates experience with Canadian legal and policy systems are related to incomplete and dated metapolicies that do not seem to be based on scientific evidence and the core values of prevention of health impacts and diseases such as cancer. For instance, Canada’s current metapolicy governing health care emphasizes expenditures on treatment to the detriment of investments in preventative care and education. Prevention and lifestyle change must become the metapolicy for health care in the long run because treatment is extremely expensive. Currently, both prevention and treatment must occur simultaneously. In the past 50 years, there have been numerous efforts to shift the policy framework for the health care system to place more emphasis on prevention and less on treatment.[16] One of the first concerted policy efforts was the report prepared for then-federal Health Minister Marc Lalonde.[17] (“Lalonde report”) This Report was prepared in 1973 by a former deputy minister asked to draft an overarching policy on health care for Canada which stressed the importance of prevention. The report, and subsequent reports, have noted that implementing prevention also is challenging because the overall health care system faces significant funding constraints, limited access to educational resources to retrain existing professionals, communication barriers and other challenges.

With respect the specific health threats posed by EMR/EMF and the causes of EHS, the effective Canadian policy (and by default Canada’s metapolicy) was articulated by Health Canada[18] in 2009:

‘The causes of these symptoms are unclear. There are suggestions that they might arise from environmental factors unrelated to EMFs (e.g. "flicker" from fluorescent lights or glare and other visual problems with computer monitors). Other possible factors include poor indoor air quality, stress in the workplace or living environment, or pre-existing medical conditions.’

Similarly, a 2010 Health Canada fact sheet on EMFs called “It’s Your Health”[19] reviews some of the studies and evidence relating to the concerns about exposure to EMFs and concludes that: “Health Canada does not consider guidelines for the Canadian public necessary because the scientific evidence is not strong enough to conclude that exposures cause health problems for the public.”[20]

In summary, Health Canada’s official position is that there is no scientific evidence the symptoms attributed to EHS are actually caused by exposure to EMFs. Moreover, even though the links between EMF radiation and cancer has been studied extensively, Health Canada claims that there is no scientific basis for claims that RF radiation causes cancer.[21]

In contrast, the International Agency for Research on Cancer (IARC, the independent global authority) determined in 2011 that EMF radiation is a Group 2B, possible human carcinogen.[22] In 2019, IARC outlined recent strong findings including human epidemiology plus two multi-million-dollar animal studies, and announced that re-evaluation is a high priority.[23] The only large Canadian cell phone cancer study, published in 2017, found that compared with those who were not regular users, the risk of glioma, a malignant type of brain cancer, was doubled with 558 hours talking on cell phones held to the head.[24] Similarly, in the past decade families who make claims for glioma brain cancers and deaths are being compensated by courts and tribunals in Italy, France and elsewhere and some European insurance companies have expressed serious concern about the risks associated with future EMF liability.[25] As noted below, many insurers (including workplace agencies such as the Ontario WSIB) in Canada and other common law jurisdictions (e.g. USA, UK) are refusing to cover claims of harms from EMF exposures and EHS.

While some advocates for greater regulation of EMR sources would argue Health Canada’s position is evidence of “regulatory capture”, industry and government officials insist that their approach adequately protects human health. These statements are reflective of an obvious skepticism towards EHS, indicating a lack of belief that low dose frequencies are the cause EHS and simultaneous confidence that the standards set out by Health Canada in Safety Code 6[26] (SC6) are sufficient. An important critical question to raise is whether Health Canada’s position is in fact fully reflective of available scientific evidence.  In 2015, Dr. Meg Sears wrote and edited a paper published by Canadians for Safe Technology (C4ST) on more than 150 low-exposure studies, below SC6.  The C4ST report showed significant biological effects, published within a narrow window of time, that were not referenced by Health Canada (HC) or the Royal Society of Canada (RSC) in evaluating SC6.  The C4ST report also identified a number of references in the RSC and HC reports, including many from other periods, and others that did not critically analyze  significant effects associated with EMF and EMR.[27]

Critics argue that current EMF/EHS metapolicy has been shaped by transnational post-industrial capitalism, supercharged by corporations like Apple, Samsung and Huawei that are seeking to expand markets for new devices and 5G technology. This results in growing levels of electromagnetic phenomena, and the popularization of Wi-Fi access in public and shared spaces (e.g. the strong interest in expanding wireless technology into public spaces such as parks, allegedly to promote economic development and tourism).

Differences Between Law and Policy

Public laws, such as those passed by legislatures on employment standards, occupational health and safety (OHS) and health protection, have a vital role to play in ensuring government regulations, policies and practices prevent or reduce the risk of regulatory capture.

Public and administrative laws often are intended to address problems in the private law system such as the expense of litigation and the desire to provide access to justice. They usually provide remedies through tribunals, which are supposed to be more accessible and economical. Moreover, modern laws enacted by legislatures are based on concepts such as natural justice and fairness. 

In contrast to laws which are enacted by legislatures in typically lengthy procedures, policies and programs can be changed more easily; however, they also can be incorporated by reference, which gives them legal status. Policies and programs, which usually are based on an overarching metapolicy, are not binding on courts, tribunals, or other decision makers unless they are “incorporated by reference.” For example, an ISO standard on equipment or procedures may be referenced in a regulation or even a public law. It is important to understand that most Canadian Human Rights Commission (CHRC) policies are only legal policies, rather than public law.


How can we promote law and policy reform on EHS problems? We must start to build a social consensus through advocacy, research and education. Education will be essential. We must come to a common understanding that sensitivities arise from EMF and EMR, in order best to prevent and to treat conditions such as EHS. If our efforts and demands are seen as reasonable and carefully formulated, the courts and legislatures will respond.  There are other precedents that are instructive e.g. the work by Mothers Against Drunk Driving (MADD) on intoxicated vehicle driving, Pay Equity, LGBTQ rights, etc.

By questioning Health Canada’s Safety Code 6 and cell tower siting processes, communities and activists send a strong message both to ISSD and to the telecommunications companies.

Resistance to cell tower applications also engages citizens who otherwise care little about politics and alerts local and senior government politicians of the need to heed their concerns. Municipal and resident resistance to cell towers encourages industry to withdraw applications and Industry Canada to reject towers application. Hopefully, Industry Canada will become more receptive to the concerns of local communities in making its final decisions, even though it is not constitutionally bound to do so.

In the short term, EHS sufferers and their lawyers also need to consider how to develop practical options on accommodations that are not perceived as completely trumping other interests such as the desire for access to the internet.[28]

In the long run, development of well thought-out EHS metapolicies would be an excellent place to start. These metapolicies need to be developed using transparent and accountable processes that engage experts, afflicted persons and others. Conversely, poor, untraceable or incoherent processes often can result in the development of highly questionable laws and policies that lack social licence.


[1] This paper is not legal advice and only provides general information about how the legal system can be used. Individuals suffering from EHS and patients seeking specific legal advice should contact the lawyer referral service for their respective Law Society or the appropriate organization in their jurisdiction and retain a lawyer. The author gratefully acknowledges the work of Dr. Meg Sears, Chairperson of Prevent Cancer Now, past and current clients and Canadian medical researchers in preparing this presentation.

[2] As published in: Riina Bray MD and David Fancy PhD (eds.), Clinical Practice Guidelines for Electromagnetic Hypersensitivity (EHS) - Proceedings from a Symposium on the Impacts of Wireless Technology on Health. Based on Presentations made at Women’s College Hospital  held on May 30, 2019; Published by the Environmental Health Clinic, Women’s College Hospital, University of Toronto, Canada, January 2021. Link to Proceedings:

[3] The author is an environmental lawyer based in southern Ontario, and retired Adjunct Professor. He was pro-bono counsel on the Board of the Wireless Radiation Safety Council of Canada from 2011 to 2013. He has worked with numerous clients on a range of wireless radiation safety, air pollution, water pollution and chemical sensitivity issues. David served for sixteen years as In-House Counsel and Senior Policy Advisor at the Environmental Commissioner of Ontario. David has a B.Sc. in Biology and a Master’s in Environmental Studies on Biological Conservation. He graduated from Osgoode Hall Law School, undertook graduate law studies and was admitted to the Ontario Bar in 1990. David taught law to undergraduate and graduate students at York University, Osgoode Hall Law School, the University of Toronto and Humber College between 1987 and 2011. He has published dozens of books, journal articles and articles. Book titles include Risky Business: A Guide to the Use, Handling and Transportation of Asbestos (2012) and My Municipal Recycling System Made Me Fat and Sick (2012).

[4] Dr. Margaret Sears, “The Medical Perspective on Environmental Sensitivities,” Report prepared for the Canadian Human Rights Commission, May 2007. › sites › default › files › envsensitivity_en

[5] World Health Organization, Electromagnetic fields and public health: Electromagnetic hypersensitivity, Backgrounder, December 2005.

6 WHO, ibid.

[7] See, for example, some of the papers and presentations made at the conference on EHS and EMF at Women’s College Hospital on 30 May 2019, Endnote 2.

[8] Lisa Vanhala, Making Rights a Reality?: Disability Rights Activists and Legal Mobilization. Cambridge Disability Law and Policy Series (2011). Cambridge University Press. ISBN 9781107000872

[9] According to Dr. Meg Sears, scientific thinking and regulator attitudes in Ontario about MCS and EHS took a progressive leap forward when the Ontario government established an MCS task force. Sears reports she has worked on presentations about MCS with EHAQ recently and this work has resulted in more positive views about EHS science as well.  Personal Communication to author, Dr. Meg Sears, 10 Jan. 2020.

[10] It has been estimated by environmental health experts that 3-5% of Canadians have been diagnosed with Environmental Sensitivities. People with this condition become extremely sick with even slight exposures to the everyday chemicals such as fabric softeners and flame retardants and pesticides. In 2007, Sears estimated that 3% of Canadians were affected by ES: See Dr. Margaret Sears, “The Medical Perspective on Environmental Sensitivities,” Report prepared for the Canadian Human Rights Commission, May 2007. › sites › default › files › envsensitivity_en; Personal Communication, Dr. Meg Sears, Prevent Cancer Now, May 2019.

[11] Note that this modelling work was undertaken in the early 2010s. Levels would be much higher now, and are projected to increase significantly in the coming years as 5G infrastructure is implemented.

[12] Relevant administrative tribunals and adjudicators include: the Canadian Human Rights Commission, Human Rights Tribunal of Ontario (HRTO), Workers Safety and Insurance Board (WSIB), Ontario Landlord and Tenant Board (OLTB), Environmental Review Tribunal (ERT), Ontario Ministry of Labour – OHSA. Other Canadian Tribunals include: provincial and federal Worker Compensation agencies, Landlord and Tenant Board, Employment, Federal Dept. of Labour, arbitrators, mediators, and special commissioners or appointees. There are also agencies also like Canada Revenue, which make decisions that have a bearing, such as providing access to funds if you have a disability.

[13] See, for example, M. Wilkinson, Testing the null hypothesis: the forgotten legacy of Karl Popper?, J Sports Sci. 2013;31(9):919-20. doi: 10.1080/02640414.2012.753636. Epub 2012 Dec 19.  As explained in the abstract for the paper, “[t]esting of the null hypothesis is a fundamental aspect of the scientific method and has its basis in the falsification theory of Karl Popper. Null hypothesis testing makes use of deductive reasoning to ensure that the truth of conclusions is irrefutable. In contrast, attempting to demonstrate the new facts on the basis of testing the experimental or research hypothesis makes use of inductive reasoning and is prone to the problem of the Uniformity of Nature assumption described by David Hume in the eighteenth century. Despite this issue and the well documented solution provided by Popper's falsification theory, the majority of publications are still written such that they suggest the research hypothesis is being tested. This is contrary to accepted scientific convention and possibly highlights a poor understanding of the application of conventional significance-based data analysis approaches.” Research on health policy should be driven by conjecture and attempted falsification such that it is always the null hypothesis that is tested. The write up of our EMF and EHS research studies should make it clear that we are indeed testing the null hypothesis and conforming to the established and accepted philosophical conventions of the scientific method.

[14] Thomas Kuhn, The Structure of Scientific Revolutions, 1962.

[15] Yehezkel Dror, Social Science Metapolicy: Some Concepts and Applications. Santa Monica, CA: RAND Corporation, 1970. Also available in print form. As such, they deal with: (1) the characteristics of policymaking systems (structure, process patterns, personnel, inputs, and stipulated outputs); and, (2) master policies (strategies, overall goals, basic assumptions, conceptual frameworks, policy instruments, and similar inter-policy directives). One of the main utilities of the concept of metapolicy is to stimulate research, study, contemplation, design, and analysis focusing explicitly on the metapolicy level. Metapolicies also can provide a framework that sets out to define the range of compliance documents (e.g. regulations, policies, procedures, protocols) and establishes a classification system which groups them (e.g. financial, information technology). In addition, metapolicy should identify and describe the processes by which the compliance documents are developed, reviewed and made available to stakeholders.

[16] See Dr. Bruce Lanphear, Prevention Paradox: Why We are Failing to Prevent Disease (2018). 10 Jan. 2020; See also: How many Canadians will be diagnosed with diabetes between 2007 and 2017? Assessing population risk, D.G.Manuel DG, L. Rosella, M. Tuna M, C. Bennett, June 2010.; retrieved 10 Jan. 2020.

[17] Government of Canada, A New Perspective on the Health of Canadians: a Working Document (“the Lalonde report’).  Ottawa: Ministry of Supply and Services, 1974. The final report was presented in the House of Commons on April 1, 1974.

[18] Health Canada, Environmental and Workplace Health: Electromagnetic Hypersensitivity (2009). Date Modified: 2009-01-22

[19] Health Canada, It’s Your Health (2010; updated in 2011). › pdf › iyh-vsv › prod › monit-eng

[20] Ibid.

[21] Health Canada, Understanding Safety Code 6: Health Canada's radiofrequency exposure guidelines: Safety Code 6 is one of a series of safety codes that provides radiation protection guidance for radiation emitting devices. Retrieved 26 Oct. 2020. The Health Canada fact sheet states: “[m]ost research does not support a link between radiofrequency EMF and cancer,” citing 2011 IARC report. The fact sheet was updated In October 2020 to also clarify that there is no connection between EMF and COVID-19. This was a response to the burning of cell towers in France, the UK and Quebec by anti-cell tower activists who asserted a link between EMF and COVID-19.

[22] International Agency for Research on Cancer (IARC), Non-ionizing Radiation, Part 2: Radiofrequency Electromagnetic Fields, IARC Monographs on the Evaluation of Carcinogenic Risks to Humans (2011). Volume 102, IARC.  This conclusion was based in part on evidence showing an increased risk for glioma, a malignant type of brain cancer, associated with wireless phone use.

[23] IARC Monographs on the Identification of Carcinogenic Hazards to Humans Report of the Advisory Group to Recommend Priorities for the IARC Monographs during 2020–2024 (2019);

[24] F. Momoli, J. Siemiatycki et. al., Probabilistic Multiple-Bias Modeling Applied to the Canadian Data From the Interphone Study of Mobile Phone Use and Risk of Glioma, Meningioma,  Acoustic Neuroma, and Parotid Gland Tumors, Am J Epidemiol. 2017 Oct 1; 186(7): 885–893. Published online 2017 May 23. doi: 10.1093/aje/kwx157;

[25]  Swiss Reinsurance, SONAR — Emerging Risk Insights (June 2013). fe339fc9941c/SONAR_+Emerging_risk_insights_from_Swiss_Re.pdf  According to the report the ‘unforeseen consequences of electromagnetic fields’ could result in a flood of insurance claims that would translate into significant liability losses for the industry. The report considers the risk of increased insurance claims about electromagnetic field, or EMF-related health risks to be ‘high’.

[26] Health Canada, Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range from 3 kHz to 300 GHz: Safety Code 6 (2009). HC Pub.: 091029; See also: Canadians for Safe Technology (C4ST), What is Safety Code 6?; Retrieved: 10 Jan. 2020. Safety Code 6 was developed and approved by Health Canada in 1970s and originally was intended to ensure the protection of federal employees and visitors to federal buildings. Its purpose is to establish safety limits for human exposure to radiofrequency (RF) electromagnetic energy in the frequency range from 3 kHz to 300 GHz. This is the energy given off all wireless electronic devices including, but not limited to, cell and portable phones, baby monitors, smart meters, wireless appliances, Wi-Fi and cell phone towers. These guidelines may also be adopted by the provinces, industry or other interested parties. It has been adjusted to include Wi-Fi, smart phones, smart meters and cell phone towers and has not had any major revisions in the last 30 years.

[27] Canadians for Safe Technology (C4ST), References of over 200 scientific studies and six (6) reviews reporting potential harm at non-thermal (not heating) levels of radiofrequency/microwave radiation that are below Safety Code 6 (2015), March 5th, 2017.

[28] Frank M.Clegg, Margaret Sears, Margaret Friesen,Theodora Scarato, Rob Metzinger, Cindy Lee Russell, Alex Stadtner, Anthony B.Miller,  Building science and radiofrequency Radiation: What makes smart and healthy buildings (Aug. 2019).


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