by: Sharon Noble

Ms. Sheila Fraser
Auditor General of Canada
Office of the Auditor General of Canada
240 Sparks Street
Ottawa, Ontario K1A 0G6

Re: Conflict of Interest -- Health Canada

Dear Ms. Fraser,

It was with great interest I learned that your Office has alleged conflict of interest in several departments of Government. One concerns a consultant who worked on a strategy for greenhouse emissions and later worked for organizations that received grants from the program.

In June, 2008, I and my husband submitted a petition (#255) to your Office alleging conflict of interest in Health Canada. It included many examples of scientists either having received funding from or being affiliated with telecommunications industries. Some of these scientists are responsible for determining the safety of devices sold by these industries or the electromagnetic radiation (EMR) emitted by these devices. Others are "experts" whose research is used by Health Canada’s scientists as bases for decisions. I provided many examples of Health Canada scientists refusing to consider independent studies by credible scientists which demonstrate that EMR can and does contribute to major health problems.

One, Dr. James McNamee , research scientist, Consumer & Clinical Radiation Protection Bureau, Health Canada, is the new EMR specialist on the editorial board of Radiation Research. He has published three negative papers on microwave genotoxicity in Radiation Research. McNamee also has written a review paper with Moulder on cell phones and cancer. Vijayalaxmi, McNamee and Maria Scarfi, an Italian researcher, are authors on 14 of the 42 negative genotox papers. Ten of their 14 negative papers were published in Radiation Research. (Microwave News, July 31, 2006)

Dr. McNamee is on the Board of Directors for the Bioelectromagnetics Society, with his term ending 2008. ( This Society’s newsletter is funded by Motorola, and its editor is Dr. Mays Swicord, director of EMR research for Motorola. (Microwave News, July 2004)

In reply to my request for examples of what Health Canada considers credible studies showing that there are no adverse health effects from non-thermal RF radiation, on March 17, 2008, Dr. McNamee sent me the following list:

a) Krewski D, Glickman BW, Habas RW, Habbick B, Lotz WG, Mandeville R, Prato FS, Salem T. Weaver DF. Recent advances in research on radiofrequency fields and health: 2001-2003. J Toxicol Environ Health B Crit Rev. 10:287-318 (2007)

b) Valberg PA, van Deventer TE, Repacholi MH. Workgroup report: base stations and wireless networks-radiofrequency (RF) exposures and health consequences. EnvironHealth Perspect. 115:416-424 (2007)

c) Moulder JE, Foster KR, Erdreich LS, McNamee JP. Mobile phones, mobile phone base stations and cancer: a review. Int J Radiat Biol. 81:189-203 (2005)

d) Vijayalaxmi, Obe G. Controversial cytogenic observations in mammalian somatic cells exposed to radiofrequency exposure. Radiat Res. 162:481-496 (2004)

e) Ahlbom A, Green A, Kheifets L., Savitz D, Swerdlow A; ICNIRP. Epidemiology of health effects of radiofrequency exposure. Enviro Health Perspect. 112:1741-1754 (2004)

I decided to apply Dr. McNamee's "vigilant surveillance" to the quality and integrity of some of his sources:

a) D. Krewski is Director of the R. Samuel McLaughlin Centre for Population Risk Assessment, University of Ottawa.. According to CBC's Marketplace, Nov. 25, 2003, the Canadian Wireless and Telecommunication Association (CWTA),a cell phone industry lobby group along with its members invested $1 million to help establish the R. Samuel McLaughlin Centre for Population Health Risk Assessment at the University of Ottawa, where Dr. Krewski is doing his cellphone research. The head of the CWTA, Peter Barnes, told CBC that the million dollars his lobby group gave to Krewski's centre has no strings attached.

Dr. Krewski also holds the position of Chair of the scientific advisory group of the Wireless Information Research Centre (WIRC). According to CBC News, Nov. 25, 2003, the WIRC is funded by the Canadian Wireless and Telecommunication Association.

Another of his positions is that of Director of IARC, the Canadian Interphone Study. Canada is the only country of the 13 participants that accepts funding from the telecommunications industry. "Krewski has about $1million to fund his part of the IARC research, most of it came from the Canadian Wireless and Telecommunications Association, the cellphone industry lobby group." (CBC News, Nov. 25, 2003)

According to the University of Ottawa Gazette, May 10, 2001, "The Canadian project has received a grant from the Canadian Wireless Telecommunications Association (CWTA), which is being administered through the university-industry partnership program of the Canadian Institutes for Health Research (CIHR). CIHR is expected to fund half, with the CWTA funding the remainder. "Industry has a responsibility to contribute to health research on their products, to address questions about potential health risks associated with wireless telecommunications," he says. "The university-industry partnership program that CIHR has set up is exactly designed for this purpose."

In addition, "Roger Poirier, the man who negotiated the million dollar deal, is a consultant on the big cellphone study for IARC," as reported by CBC News, Nov. 25, 2003.

The World Health Organization (WHO), according to many observers, is closely associated with the industries they are supposed to be researching. According the WHO 2005 Annual Report, Krewski acted as the Principal Investigator in the epidemiological study of cellular telephones and head and neck cancer which was funded by CIHR and CWTA, with the databases created and coordinated by the McLaughlin Centre.

In the same WHO Report is documentation that Dr. Krewski, along with R. Habash and M. Repacholi, was the principal investigator for the study on Electromagnetic Fields and Health which was funded by the CWTA and CIHR ($850,000).

b) John Moulder is an industry consultant, and, according to Microwave News, July 31, 2006, "has a lucrative consulting practice on EMFs and health. Over the years, Moulder has earned hundreds of thousands of dollars disputing the existence of adverse EMF health effects, even those accepted by most other members of the EMF community."

He has worked for Radiation Research since the early 1990s and is now senior editor of it. "Over the last 16 years, only one positive paper on microwave genotoxicity has appeared in Radiation Research.... 80% of the negative papers (17 out of 21) published in Radiation Research were paid for by either industry or the U.S. Air Force."

Microwave News is "meticulously researched and thoroughly documented." Time Magazine, July 30, 1990

" the most authoritative journal on ELF fields and health." Fortune Magazine, Dec. 31, 1990

"the world's most authoritative source on EMF health risks." Washington Journalism Review, Jan/Feb 1991

c) Obe G. Vijayalaxmi, together with Moulder and some colleagues from Washington University and the U.S. Air Force had published a review paper that dismissed any possible connection between cell phones and cancer. This was published in Radiation Research. After Moulder had moved up to senior editor in 2001, he recruited Vijayalaxmi of the University of Texas in San Antonio to join the Radiation Research editorial board. Vijayalaxmi is the lead author on seven of the negative microwave-genotox papers. All were funded by the U.S. Air Force, Motorola or a combination of the two. (Microwave News, July 31, 2006)

Dr. Vijayalaxmi is treasurer for the Bioelectromagnetics Society, and will be until 2010.

Many surveys confirm that money-source influences results of research. One done by Harvard University Medical School was reported in the New York Times, June 10, 2008. In another one, Dr. Henry Lai in 2006, reported on 326 studies on EMR, finding that where the results were of no biological harm, 72% were industry funded. Of those showing biological harm, only 33% received industry funding. Yet Health Canada replied to my charges with, "The fact that some studies are either directly or indirectly funded, in whole or in part, from the wireless industry or any other sources does not constitute a valid reason to dismiss these research findings outright."

Dr. James McNamee of Health Canada supports the use of industry-funded research, arguing that the number of studies which show no biological harm outnumber those showing harm. Therefore, using the "weight of evidence" argument, he supports the current stance.

Ms. Fraser, please explain to me how this evidence, and more which I could provide, does not warrant an investigation into conflict of interest. Is our health not as important as natural resources? For years, experts have questioned Health Canada’s competence and independence, yet it continues to fail to fulfill its mandate of protecting Canadians. It is well past the time for you and your office to investigate why Health Canada appears to be working for the corporations rather than the citizens of Canada.

Yours truly,
Sharon Noble