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Report Reference: UC10547.05
November 2015
Review of the Potential Health Effects of
Smart Water Meter Systems Used in the
Thames Water Region
RESTRICTION: This report has the following limited distribution:
External: Thames Water
Any enquiries relating to this report should be referred to the Project Manager at the
following address:
WRc plc,
Frankland Road, Blagrove,
Swindon, Wiltshire, SN5 8YF
Telephone: + 44 (0) 1793 865000
Website: www.wrcplc.co.uk
Follow Us:
WRc is an Independent Centre
of Excellence for Innovation and
Growth. We bring a shared
purpose of discovering and
delivering new and exciting
solutions that enable our clients
to meet the challenges of the
future. We operate across the
Water, Environment, Gas, Waste
and Resources sectors.
Document History
Version
number
Purpose Issued by Quality Checks
Approved by
Date
V1.0 Draft report issued to client for comment. Rowena Gee, Project Manager Carmen Snowdon 30/01/15
V2.0 Second draft report issued to client. Rowena Gee, Project Manager Carmen Snowdon 22/05/15
V3.0 Final report issued to client Rowena Gee, Project Manager Carmen Snowdon 01/10/15
V4.0 Final report re-issued to client with minor amendments Rowena Gee, Project Manager Mark Kowalski 14/10/15
V5.0 Final report re-issued to client with minor amendment Rowena Gee, Project Manager Rowena Gee 11/11/15
© WRc plc 2015 The contents of this document are subject to copyright and all rights are reserved. No part of this document may be reproduced, stored in a retrieval system or transmitted, in any form or by any means electronic, mechanical, photocopying, recording or otherwise, without the prior written consent of WRc plc.
This document has been produced by WRc plc.
Review of the Potential Health Effects of Smart
Water Meter Systems Used in the Thames Water
Region
Authors:
Andy Godley
Senior Consultant
Customer Engagement
Date: November 2015
Report Reference: UC10547.05
Leon Rockett
Senior Toxicologist
Catchment Management
Project Manager: Rowena Gee
Project No.: 16188-2
Paul Rumsby
Principal Toxicologist
Catchment Management
Client: Thames Water
Client Manager: Martin Hall
Rowena Gee
Project Manager
Catchment Management
Contents
Glossary ................................................................................................................................... 1
Summary .................................................................................................................................. 3
1. Introduction .................................................................................................................. 4
2. Smart Meter Systems .................................................................................................. 6
2.1 Introduction .................................................................................................................. 6
2.2 Homerider .................................................................................................................... 6
2.3 FlexNet ........................................................................................................................ 7
2.4 RF emissions ............................................................................................................... 8
2.5 Meter locations .......................................................................................................... 10
3. Comparison of RF Emissions from Smart Meters with Other Sources ..................... 11
3.1 Introduction ................................................................................................................ 11
3.2 Previous studies ........................................................................................................ 11
3.3 Exposure Estimates from Smart Meters ................................................................... 13
4. Human Health Review .............................................................................................. 27
4.1 Introduction ................................................................................................................ 27
4.2 Guideline values ........................................................................................................ 29
4.3 Report of the Independent Advisory Group on Non-Ionising Radiation .................... 31
4.4 Evaluation by the International Agency for Research on Cancer ............................. 33
4.5 Verschaeve (2012) .................................................................................................... 35
4.6 European Commission Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR) (2015) ............................................................... 35
4.7 Specific Reviews of Smart Meters ............................................................................ 35
4.8 Summary ................................................................................................................... 38
5. Conclusions ............................................................................................................... 40
References ............................................................................................................................. 42
Appendices
Appendix A Regulatory Conformance Requirements ................................................. 44
List of Tables
Table 2.1 Homerider system radiated power levels .................................................. 9
Table 2.2 Operating frequencies and power for FlexNet system .............................. 9
Table 2.3 Duration and occurrence of transmissions from FlexNet ........................ 10
Table 3.1 Level of exposure from electrical devices that emit RF energy ...................................................................................................... 12
Table 3.2 Level of exposure from electrical devices that emit RF energy (EPRI, 2011) ................................................................................ 12
Table 3.3 Calculated potential exposure to RF energy from the Homerider system components ............................................................... 15
Table 3.4 Calculated potential exposure to RF energy from FlexNet smart meters ............................................................................................ 17
Table 3.5 Comparison of crude and refined exposure estimates for the Homerider system ................................................................................... 21
Table 3.6 Calculated duty cycles for the FlexNet system ....................................... 22
Table 3.7 Comparison of crude and refined exposure estimates for the FlexNet system in fixed network mode.................................................... 23
Table 3.8 Comparison of crude and refined exposure estimates for the FlexNet system in AMR mode ................................................................. 23
Table 4.1 Reference Levels applicable to the Homerider and FlexNet systems ................................................................................................... 30
Table 4.2 Comparison of Reference Levels with exposure estimates .................... 30
List of Figures
Figure 2.1 How to recognise the Homerider System .................................................. 7
Figure 2.2 Overview of the FlexNet fixed network solution ........................................ 7
Figure 2.3 How to recognise the FlexNet system; meter and LCE ............................ 8
Figure 3.1 Level of exposure to RF from Homerider transmitters compared with other common household devices .................................. 16
Figure 3.2 Level of exposure to RF from FlexNet system components compared with other common household devices .................................. 19
Figure 3.3 Comparison of calculated exposure from Homerider smart meter transmitters with and without consideration of duty cycle and reflected exposure ................................................................... 21
Figure 3.4 Comparison of crude and refined exposure estimates from FlexNet SWM Low Power Radio ............................................................. 24
Figure 3.5 Comparison of crude and refined exposure estimates from FlexNet LCE Low Power Radio ............................................................... 24
Figure 3.6 Comparison of crude and refined exposure estimates from FlexNet LCE Wide-Area Radio ................................................................ 25
Figure 3.7 Comparison of crude and refined exposure estimates from FlexNet radio base station ....................................................................... 25
Figure 4.1 Risk assessment process ........................................................................ 27
Thames Water
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© WRc plc 2015 1
Glossary
AGNIR UK independent Advisory Group on Non-ionising Radiation
AMR Automatic Meter Reading
ARPANSA Australian Radiation Protection and Nuclear Safety Agency
CCST California Council on Science and Technology
COMAR Committee on Man and Radiation
DoC Declaration of Conformity
Duty Cycle The fraction of time a smart meter is transmitting, i.e. a duty cycle of 100% would
be equivalent to continuous transmission; a 1% duty cycle would be equivalent to
transmitting for 1% per 24 hours (14.4 minutes/day)
EEG Electroencephalography; a test used to detect abnormalities related to electrical
activity of the brain
EMR Electromagnetic Radiation
EPRI US Electric Power and Research Institute
ERC European Research Council
EU European Union
FCC US Federal Communications Commission
HPA Health Protection Agency; former name for Public Health England
IARC International Agency for Research on Cancer
ICNIRP International Commission on Non-Ionizing Radiation Protection
IEEE Institute of Electrical and Electronic Engineers
ISM Industrial, Scientific and Medical (ISM) radio bands are portions of the radio
spectrum reserved internationally for industrial, scientific and medical purposes
other than telecommunications
LCE Local Communication Equipment
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MPE Maximum Permissible Exposure; the highest power or energy density (measured
in W/cm2 or J/cm
2) of radiation that is considered „safe‟; used to limit average
exposure over a given time period
NCET National Centre for Environmental Toxicology; part of the independent research
consultancy, WRc
PG&E Pacific Gas and Electric Company
PHE Public Health England
R&TTE Directive The European Radio equipment and Telecommunications Terminal Equipment
Directive
RF Radio Frequency; radiation (part of the EM spectrum) in the range of
approximately 3 kHz to 300 GHz, which corresponds to the frequency of radio
waves and the alternating currents which carry radio signals
SAR Specific Absorption Rate; measures the rate of energy absorption and is
expressed as watts (W) per kilogram (kg) of body mass
SWM Smart Water Meter
TETRA Terrestrial Trunked Radio, formerly known as Trans-European Trunked Radio: a
professional mobile radio and two-way transceiver (colloquially known as a walkie
talkie) specification. TETRA was specifically designed for use by government
agencies, emergency services, for public safety networks, rail transport staff for
train radios, transport services and the military.
WHO World Health Organization
WOE Weight-Of-Evidence; the process of considering the strengths and weaknesses of
various pieces of information in reaching and supporting a conclusion
Thames Water
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Summary
Thames Water is deploying smart water meters over much of its region and wishes to be
proactive in addressing any customer concerns about perceived health effects from exposure
to radio frequency1 (RF) electromagnetic radiation (EMR) from these devices. Such perceived
health concerns have existed for several years in relation to smart meters generally.
This report, from specialists at the National Centre for Environmental Toxicology (NCET),
addresses these concerns by comparing prolonged exposure from smart water meters in
close proximity with RF emissions from other common household equipment, and with
international guideline limit levels (see Section 4.2) established for the protection of human
health. The comparison is based on the specific systems being deployed by Thames Water -
the Homerider system and the FlexNet system. The conclusions of recent authoritative
reviews on research studies on the effects of RF exposure on biological systems and human
health are also summarised.
The main effects of EMR on biological systems depend on both the power and frequency of
the emissions and the distance from the source. For the lower frequencies of EMR applicable
to smart meters (RF), the damage to cells and also to many ordinary materials under such
conditions is determined mainly by heating effects, and thus by the radiation power. There are
also heath concerns relating to low frequency pulsing effects produced by some radio
systems such as DECT cordless telephones (phones). However, neither the Homerider nor
the FlexNet systems produce such a pulsing effect.
This review concludes that emissions from smart meters are similar to, or much less than,
emissions from other household equipment. Levels of exposure are less than that which
would be expected from Wi-Fi devices, and are significantly lower than the levels of exposure
that may be expected from standing close to a microwave oven or using a mobile phone
(handsets). Even assuming very close proximity to smart meters for extended periods,
exposure is still well below the guideline limit levels set by international authoritative bodies
(see Section 4) for the protection of human health. When the very short signal durations of the
smart meters are taken into account, estimated levels of exposure are lower still. It is
therefore reasonable to conclude that levels of exposure to RF from smart meter devices
would represent a very small fraction of the total daily exposure that an individual may be
expected to receive.
Toxicologists within NCET have used the weight of scientific evidence (WOE) approach to
evaluate the numerous studies investigating the potential effects of RF exposure on human
health, mainly from mobile phones. Overall, it can be concluded that there is no evidence that
the use of smart meters would have any adverse effects on human health, particularly so for
the low levels of exposure involved in the Thames Water smart meter deployments.
1 The part of the electromagnetic spectrum up to 300 GHz.
Thames Water
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© WRc plc 2015 4
1. Introduction
Thames Water has a programme to install smart water meters across its region over the next
15 years. This began in 2011 and in autumn 2015 moves into a second phase of deployment.
This second phase rollout is the first smart water metering deployment in the UK to use fixed
network infrastructure on a large scale, allowing more frequent collection of water meter
readings. The programme is as follows:
From 2011 to summer 2015 – deployment of approximately 300,000 smart water
meters using the Homerider system in automatic meter reading (AMR) mode. These
meters will be read using walk-by or drive-by methods;
Autumn 2015 onwards – deployment of smart water meters using the FlexNet system.
Data collection will be made using walk-by and drive-by AMR technology and also by
fixed network as the communication technology is rolled out across the Thames Water
region over the next 15 years.
Smart meter deployments around the world, and the publicity around the GB energy smart
meter programme in particular, have given rise to concerns about possible health effects.
Thames Water wishes to be proactive in addressing such concerns, both in the interests of its
customers and to meet the objectives of the smart metering strategy in managing demand.
In order to address these concerns, Thames Water has asked specialists from the National
Centre for Environmental Toxicology, part of the independent research consultants, WRc, to
prepare a technical review of potential health issues from exposure to RF emissions from
smart water meters, with specific reference to the two systems Thames Water will be using.
This report considers the issues in two parts:
1. Evidence for RF exposure levels from smart meters in general is reviewed and levels of
exposure from prolonged use in close proximity are compared with RF emissions from
other household equipment; and
2. A review of the human health implications of RF exposure.
The report includes the international standards set for RF exposure for the frequencies used
by smart meters. There have been many studies, both in humans and using experimental
systems, investigating the possible effects on biological systems and human health. It is
beyond the scope of this report to review all these studies individually, but there have been
recent authoritative reviews by the UK independent Advisory Group on Non-ionising Radiation
(AGNIR) published by the Health Protection Agency, now Public Health England (PHE), and
the International Agency for Research on Cancer (IARC). The conclusions of these in-depth
reviews are summarised. Most of the studies are concerned with RF exposure from mobile
Thames Water
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© WRc plc 2015 5
phone use which, as will be shown, is generally very much greater than exposure from smart
meters. Therefore these studies generally constitute much more extreme exposure to RF than
would be observed for smart meters.
In several cases throughout this report, the phrase „worst-case‟ has been used to describe a
situation. This phrase is commonly used in risk assessment to describe a situation where
assumptions surrounding that situation have been made, which may be considered extreme,
with the intention of ensuring the protection of the most vulnerable human populations or that
protection still ensues if unlikely extreme exposure does occur. This may be reflected in this
report in assumptions regarding the level and duration of exposure to RF from smart meters.
For example, exposure has been calculated at specific distances from the transmitter, which
are worst-case. As the exposure will decrease in proportion to the square of the distance from
the transmitter, the actual exposure would be significantly reduced as the person moves away
from the transmitter. Therefore, if it is considered unlikely that smart meters will produce
adverse health effects in these „worst-case scenarios‟, it becomes even more unlikely that
adverse health effects will be observed following more realistic exposure.
Thames Water
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2. Smart Meter Systems
2.1 Introduction
Thames Water will have three smart meter arrangements running concurrently in different
parts of their region. The operation of the three arrangements is described below:
Homerider system in AMR mode;
FlexNet system in fixed network mode;
FlexNet system in AMR mode.
Both the Homerider and FlexNet systems, in common with other radio equipment placed on
the European Union market, must comply with relevant European Directives and Standards;
these provide a regulatory framework with essential requirements concerning user health,
safety, electromagnetic compatibility and radio spectrum usage. Related conformance
requirements are listed in Appendix A.
2.2 Homerider
The Homerider system, shown in Figure 2.1, will be used as a walk-by and drive-by system.
In this system, a battery powered radio transmitter is attached to the water meter. For most of
the time, the transmitter is not sending data. The receiver, which is either carried by a meter
reader walking his round (walk-by) or in a vehicle (drive-by), sends out a signal instructing all
the meter transmitters within range to transmit their readings. When the meter transmitter
receives this instruction it returns the reading to be recorded by the receiver.
Typically reading rounds are scheduled to be 6 monthly in residential areas and monthly or
quarterly for larger commercial customers.
Thames Water
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Figure 2.1 How to recognise the Homerider System
2.3 FlexNet
In the FlexNet system, the meter (SWM) incorporates a low power short range radio that
transmits to its associated Local Communication Equipment (LCE). This is located very close
to the meter itself; typically the meter and the LCE are less than 500 mm apart and each
meter has its own LCE. The LCE then transmits over a long range, up to 3 km, to a radio base
station. Each radio base station will receive data from many LCEs, as shown in Figure 2.2.
Figure 2.2 Overview of the FlexNet fixed network solution
Communications between the base station and the LCE, and the LCE and the meter are two
way.
For areas where there is no coverage from a radio base station at the time of meter
installation, the system can operate in an AMR (walk-by or drive-by) mode. In this mode, the
LCE is inactive for most of the time, but the meter transmits a reading every 15 seconds. This
is collected by a meter reader walking or driving past the meter with the required receiver.
When a base station comes on line within range of the LCE it will automatically switch over to
SWM LCE Radio base
station
Thames Water
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© WRc plc 2015 8
operate as part of the fixed network. There will be some installations where an LCE is not
fitted and these meters will remain in AMR mode.
A photograph of the FlexNet system is shown in Figure 2.3.
Figure 2.3 How to recognise the FlexNet system; meter and LCE
2.4 RF emissions
2.4.1 Homerider
The Homerider system will operate in the 868 MHz unlicensed ISM2 band with radiated power
levels as shown in Table 2.1.
As stated in Section 2.2, the Homerider will only transmit when requested by a receiver
passing by in close proximity. For residential properties this is once every six months. The
typical duration of the transmission is 1.6 seconds.
2 The industrial, scientific and medical (ISM) radio bands are portions of the radio spectrum reserved
internationally for industrial, scientific and medical purposes other than telecommunications.
Thames Water
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© WRc plc 2015 9
Table 2.1 Homerider system radiated power levels
Device1
Minimum EIRP
Maximum EIRP
mW dBm mW dBm
Meter 10 10 25 14
1. Radiated power levels
3 obtained from Homerider‟s data sheets, expressed as both milliwatts (mW)
and as the power ratio in decibels (dB) referenced to one mW. The values are rounded to the nearest
whole number.
2.4.2 FlexNet
The operating frequencies and power levels for the FlexNet components are shown in Table
2.2.
Table 2.2 Operating frequencies and power for FlexNet system
FlexNet component Frequency Power (mW) Power dBm EIRP
SWM Low Power Radio 433 MHz 10 10
LCE Low Power Radio 433 MHz 10 10
LCE Wide-Area Radio 412 MHz 316 25
Radio base station 423 MHz 50,119 47
The FlexNet system can be operated in different modes to provide greater flexibility in data
collection, these will be AMR and Fixed Network (AMI mode).
In fixed network mode, the default setting will be for hourly readings (i.e. every 60 minutes),
although a small number of commercial meters will be read at 15 minute intervals. Therefore,
within this report, occurrence of transmission every 15 minutes is assumed, in order to
provide the most conservative (i.e. extreme) estimates of exposure.
This system can also be operated in AMR mode for areas not yet covered by a radio base
station. Whilst the frequency and power levels are the same in each mode, the occurrence
and duration of the transmissions varies as shown in Table 2.3.
3 Radiated power is the product of the power supplied to an antenna and the gain of that antenna
compared with some standard antenna. Effective isotropic radiated power (EIRP) is the effective
radiated power referred to a theoretical isotropic radiator (which radiates equally in all directions).
Effective radiated power (ERP) is referred to a half-wave antenna. A half-wave dipole antenna in free
space exhibits a gain in its direction of maximum radiation of 2.15dB over a theoretical isotropic
radiator.
Thames Water
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© WRc plc 2015 10
FlexNet will also be using three different meters – the 640, the iPERL and the Meistream
Plus. The meters differ in operating principle but have the same radio characteristics.
Table 2.3 Duration and occurrence of transmissions from FlexNet
FlexNet component Duration of
transmission (ms) Occurrence of transmission
Fixed network (15 minute sample rate)
SWM Low Power Radio 11 ms Every 15 minutes
LCE Low Power Radio
(LCE to SWM) <11 ms
Very infrequently when SWM
is reconfigured*
LCE Wide-Area Radio
(LCE to base station) 107 ms 24/day
Radio base station 166 ms 167/hour
AMR mode
SWM Low Power Radio <3 ms Every 15 seconds
LCE Wide-Area Radio
(where installed) 107 ms Occasional – typically 1/day
* Assumed to be once per day.
2.5 Meter locations
For both systems, meters will be located either internally (e.g. under the kitchen sink) or
externally in boundary boxes, usually in the public highway (footpath). It is expected that
approximately 65% of installations across the Thames region will be external. The boundary
box lids will be plastic and therefore effectively transparent to radio waves.
In external installations for the Homerider system, the meter transmitter will be located in the
base of the boundary box. Anyone in the immediate vicinity of a boundary box will be exposed
to power levels significantly less than those shown in Table 2.1 because of propagation
losses, i.e. due to distance4 and attenuation through the surrounding ground. It is likely that
the power levels directly above the boundary box will also be significantly attenuated because
of the antenna vertical radiation pattern.
In external installations for the FlexNet system, the meter transmitter will be at the base of the
boundary box and the LCE will be just beneath the lid. Therefore, the propagation losses will
be less from the LCE than from the meter.
4 For example, the Free Space Path Loss (FSPL) over 1 m at 868 MHz = ~31 dB
Thames Water
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© WRc plc 2015 11
3. Comparison of RF Emissions from Smart Meters with Other Sources
3.1 Introduction
There are many sources of RF energy to which an individual may be exposed every day,
including mobile phones, smartphones tablets, computers etc. using 2G, 3G and 4G
telephone networks, DECT cordless phones, Bluetooth and Wi-Fi devices, microwave ovens
and more. Many of these devices, which are mostly readily accepted within the home, operate
at frequencies close to those used by smart meters but produce emissions at higher power
levels and for significantly longer periods. Therefore, a comparison of the measured exposure
to these devices with estimates of prolonged exposure in close proximity to the Homerider
and FlexNet system components can provide a context for assessing the health risks.
3.2 Previous studies
A number of studies have been carried out, comparing emissions from smart meters with
those from other sources. Two such representative studies are discussed below.
3.2.1 Pacific Gas and Electric Company (PG&E) Review
The Pacific Gas and Electric Company (PG&E) in the USA has published measurement data
for the levels of exposure from smart meters compared with other common devices found in
the home (PG&E, 2013). These exposure values, expressed as „relative power density‟ in
microwatts per square centimetre, are presented in Table 3.1. The results are from a study by
Richard Tell Associates, Inc., a scientific consulting business focused on electromagnetic field
exposure assessment, compliance with applicable standards and regulations on radio
frequency and power frequency fields.
The data indicate that at a distance of approximately 30 cm from an electricity smart meter,
the level of exposure is similar to, but less than the exposure from a microwave oven at a
distance of 1 metre, and is substantially less than the exposure from a mobile phone held next
to the head.
Thames Water
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Table 3.1 Level of exposure from electrical devices that emit RF energy
Device Relative power density
(µW/cm²)
Gas SmartMeter™ at a distance of 1 foot (~31 cm) 0.00166
Electricity SmartMeter™ at a distance of 10 feet (~3 metres) 0.1
Electricity SmartMeter™ at a distance of 1 foot (~31 cm) 8.8
Microwave oven at a distance of 1 metre 10
Wi-Fi LAN/access points/routers, laptop computers, (maximum
~1 metre for laptops, 2 - 5 metres for access points) 10 - 20
Mobile phone (at head) 30 – 10 000
Mobile radio (Walkie-Talkie) (at head) 500 – 42 000
3.2.2 Electric Power and Research Review
A review by the US Electric Power and Research Institute (EPRI) in 2011 compared the level
of exposure to a smart meter (operating at frequencies of 900 and 2400 MHz with common
sources of radio frequency energy (EPRI, 2011a). This review provides significantly more
detail on the conditions of exposure to each of these sources, however, a similar pattern is
observed in the relative levels of exposure between smart meters and other devices.
Table 3.2 Level of exposure from electrical devices that emit RF energy
(EPRI, 2011)
Device Frequency
(MHz) Details
Exposure level
(µW/cm²)
Smart meter at a
distance of 3 feet
(~91 cm)
900 and 2400 During transmission.
Localised but non-
uniform spatial
characteristic
0.1 (250 mW, 1% duty
cycle5)
2 (1W, 5% duty cycle)
Smart meter at a
distance of 10 feet
(~3 metres)
900 and 2400 During transmission.
Localised but non-
uniform spatial
characteristic
0.009 (250 mW,
1% duty cycle)
0.2 (1W, 5% duty cycle)
5 A duty cycle is the fraction of time a smart meter is transmitting, i.e. a duty cycle of 100% would be
equivalent to continuous transmission; a 1% duty cycle would be equivalent to transmitting for 1%
per 24 hours (14.4 minutes/day).
Thames Water
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© WRc plc 2015 13
Device Frequency
(MHz) Details
Exposure level
(µW/cm²)
Mobile phone
(at head)
900 and 1800 During call.
Highly localised spatial
characteristic
1000-5000
Mobile phone base
station
900 and 1800 Constant transmission.
Relatively uniform spatial
characteristic
0.005-2
Microwave oven at a
distance of 2 inches
(~5 cm)
2450 During use.
Localised but non-
uniform spatial
characteristic
~5000
Microwave oven at a
distance of 2 feet
(~61 cm)
2450 During use.
Localised but non-
uniform spatial
characteristic
50-200
Wi-Fi wireless routers
and similar home
devices at a distance
of 3 feet (~91 cm)
2400-5000 Constant use.
Localised but non-
uniform spatial
characteristic
0.2-1 (router)
0.005-0.2 (PC adapter)
Radio and television
broadcasts (significant
distance from the
source in most cases)
Wide spectrum Constant transmission.
Relatively uniform spatial
characteristic
1 (highest 1% of
population)
0.005 (50% of
population)
3.3 Exposure Estimates from Smart Meters
The following sections detail the exposure estimates from the two smart meter systems
employed by Thames Water. The initial estimates, henceforth referred to as “Crude Exposure
Estimates” are based on the assumption that the smart meter is in continuous operation. As
such, these values significantly over-estimate „real‟ exposure, where smart meters are only in
operation for a fraction of the day. More realistic estimates are provided in Section 3.3.2,
henceforth referred to as “Refined Exposure Estimates”. These values take into account the
amount of time the smart meter is in operation throughout the day (the „duty cycle‟), as well as
any reflected exposure that may occur as a result of RF emission „bouncing‟ off solid ground.
3.3.1 Calculation of Exposure from Smart Meters (Crude Exposure Estimates)
According to EPRI (EPRI, 2011b), a conservative estimate of the potential exposure to radio
frequency energy from a smart meter can be calculated by the following formula:
Thames Water
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© WRc plc 2015 14
Where:
S is the estimated exposure (mW/cm²)
EIRP is the maximum power radiated by a theoretical isotropic antenna (mW)
R is the distance from the transmitter antenna (cm)
It should be noted that EPRI (EPRI, 2011b) reported that this formula produced calculations of
exposure 2-3 times greater than levels of exposure measured from the use of smart meters.
Therefore, values derived using this approach will represent significant over-estimates of
exposure to the systems in use by Thames Water.
The Homerider System
The Homerider smart meter transmitter operates in the 868 MHz band, close to frequencies
used by other smart meter devices described above and devices that are likely to already be
present in the home such as mobile phones.
The Homerider smart meter transmitter has a power output of 25 mW EIRP; therefore,
assuming distances of 30 and 100 cm, calculations of potential exposure to radio frequency
energy are as shown in Table 3.3.
As stated above, this formula produced calculations of exposure 2-3 times greater than levels
of exposure measured from the use of smart meters. Therefore, the values shown in Table
3.3 are likely to represent significant over-estimates of exposure to the Homerider system.
Additionally, the Homerider smart meter transmitter used in walk-by and drive-by mode only
transmits for approximately 1.6 seconds when it is woken up by the receiver, typically once a
month or once a quarter for larger commercial customers and once every 6 months for
household customers. For household customers, this is equivalent to a duty cycle of 0.002%6
for days when the meter is being read. Therefore, by considering this to be a continuous
exposure would be a highly conservative worst-case scenario.
6 There are 60 seconds in a minute, 60 minutes in an hour and 24 hours in a day. Therefore, there are
a total of 86 400 seconds in a day. 1.6 seconds per day accounts for 0.002% of the total number of
seconds per day (i.e.
)
Thames Water
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Table 3.3 Calculated potential exposure to RF energy from the Homerider system
components
Homerider device Distance from smart
meter (cm)
Calculated potential exposure
(µW/cm²)7
Meter transmitter 30 2.2
Meter transmitter 100 0.2
A comparison of these data with the levels of exposure from the conservative calculations of
exposure to the Homerider smart meter transmitter and other devices reported in the literature
is presented in Figure 3.1 (note that the scale on this graph is logarithmic).
The conservative calculations for exposure levels from the Homerider components are shown
in green, measured values from other smart meter devices are represented in red and other
RF devices to which a member of the public may be exposed are represented in blue.
As shown in Figure 3.1, even assuming extreme conditions, levels of exposure to RF from the
Homerider transmitters are similar to those from other smart meters. Levels of exposure are
also less than that which would be expected from Wi-Fi routers, and are significantly lower
than the levels of exposure that may be expected by standing next to a microwave oven or
using a mobile phone.
7 Calculated using the formula:
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Figure 3.1 Level of exposure to RF from Homerider transmitters compared with other common household devices
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The FlexNet systems
The FlexNet smart meter transmitter operates at frequencies of 412 and 433 MHz.
The smart meter transmitter and the LCE each have a power output of 10 mW and 25 dBm
(calculated to be 316 mW, assuming no gain); therefore, assuming distances of 30 and
100 cm, calculations of potential exposure to radio frequency energy are as shown in Table
3.4.
Similarly, the FlexNet radio base station has a power output of 47 dBm. The information
provided indicates that these base stations will be installed on towers of similar height to
mobile phone masts. Mobile phone masts can generally be installed at a height of up to
15 metres without planning permission, therefore, it has been assumed in this report that the
radio base station will also be installed at a height of 15 metres. An assumption of a 2 m tall
adult and a base station that is primarily transmitting downwards represents a worst-case
scenario of a distance of 13 metres from the head. Calculations of potential exposure to radio
frequency energy from the base station are also provided in Table 3.4.
As stated above, this formula produced calculations of exposure 2-3 times greater than levels
of exposure measured from the use of smart meters. Therefore, the values shown in the table
are likely to represent significant over-estimates of exposure to the FlexNet system.
Additionally, the FlexNet system will only be transmitting for several milliseconds throughout
the day (see Table 3.6). Therefore, by considering this to be a continuous exposure would be
a highly conservative worst-case scenario.
Table 3.4 Calculated potential exposure to RF energy from FlexNet smart meters
FlexNet device
Distance from smart
meter or base station
(cm)
Calculated
potential exposure
(µW/cm²)8
SWM Low Power Radio 30 0.88
SWM Low Power Radio 100 0.08
LCE Low Power Radio 30 0.88
LCE Low Power Radio 100 0.08
LCE Wide-Area Radio 30 28
LCE Wide-Area Radio 100 2.5
Radio base station 13000 0.02
8 Calculated using the formula:
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A comparison of these data with the levels of exposure from the conservative calculations of
exposure to the FlexNet system and other devices reported in the literature is presented in
Figure 3.3 (note that the scale on this graph is logarithmic).
The conservative calculations for exposure levels from the FlexNet system are shown in
green, measured values from other smart meter devices are represented in red and other RF
devices to which a member of the public may be exposed are represented in blue.
As shown in Figure 3.2, even assuming extreme conditions, levels of exposure to RF from the
FlexNet smart meters are similar to those from other smart meters, although levels from the
LCE Wide-Area Radio are closer to those of Wi-Fi routers and the minimum power density of
mobile phones.
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Figure 3.2 Level of exposure to RF from FlexNet system components compared with other common household devices
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3.3.2 Consideration of duration of exposure and reflected exposure (Refined Exposure Estimates)
In 2010, EPRI also published a review (EPRI, 2010) of a specific smart meter that included
consideration of the duty cycle and reflected exposure using the following formula:
Where:
S is the estimated exposure (W/m²)
Pt is the maximum transmitter output power (W)
Gmax is the maximum possible antenna gain (dimensionless)
δ is the duty cycle of the transmitter
Γ is a factor accounting for possible in-phase ground reflections. A value of 60% has been
recommended by the FCC, which is equivalent to an enhancement factor of (1.6)² or 2.56
R is the distance from the transmitter (m)
The Homerider system
Application of this formula to the Homerider smart meter transmitter, under the conditions
stated above, results in the calculated exposure levels shown in Table 3.5 and Figure 3.3.
Consideration of these additional factors results in significant reductions in the level of
exposure due to the very short duty cycles for the smart meter. As such, it is reasonable to
conclude that levels of exposure to RF from smart meter devices would represent a small
fraction of the total daily exposure to RF that an individual may be expected to receive.
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Table 3.5 Comparison of crude and refined exposure estimates for the Homerider
system
Homerider device Distance from smart
meter (cm)
Crude exposure
estimate (µW/cm²)
Refined exposure
estimate (µW/cm²)910
Meter transmitter 30 2.2 0.006
Meter transmitter 100 0.2 0.0005
Figure 3.3 Comparison of calculated exposure from Homerider smart meter
transmitters with and without consideration of duty cycle and reflected exposure
The FlexNet system
The calculated duty cycles for each of the FlexNet components in their various operational
modes are provided in Table 3.6. It should be noted that it is intended that this system will
operate in AMR mode.
Application of the formula described above to the FlexNet system (and assuming no gain, as
none is reported in the provided documentation) results in the calculated exposure levels
9 Estimate considers duty cycle of the system and reflected exposure.
10 Calculated using the formula:
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shown in Figure 3.4, Figure 3.5, Figure 3.6 and Figure 3.7. Consideration of these additional
factors results in significant reductions in the level of exposure due to the very short duty
cycles for both the smart meter and the base station. As such, it is reasonable to conclude
that levels of exposure to RF from smart meter devices would represent a small fraction of the
total daily exposure to RF that an individual may be expected to receive.
Table 3.6 Calculated duty cycles for the FlexNet system
FlexNet
component
Duration of
transmission
(ms)
Occurrence of
transmission
Daily
transmission
time (s)
Duty cycle
(%)11
Fixed network (15 minute sample rate)
SWM Low Power
Radio 11 ms Every 15 minutes 1.1 0.001
LCE Low Power
Radio
(LCE to SWM)
<11 ms
Very infrequently
when SWM is
reconfigured*
0.011 0.00001
LCE Wide-Area
Radio
(LCE to base
station)
107 ms 24/day 2.6 0.003
Radio base
station
166 ms 167/hour 665 0.77
AMR mode
SWM Low Power
Radio <3 ms Every 15 seconds 17.3 0.02
LCE Wide-Area
Radio
(where installed)
107 ms Occasional –
typically 1/day 0.107 0.0001
* Assumed to be once per day.
11
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Table 3.7 Comparison of crude and refined exposure estimates for the FlexNet
system in fixed network mode
FlexNet device
Distance from
smart meter or
base station (cm)
Crude exposure
estimate (µW/cm²)
Refined exposure
estimate12
(µW/cm²)
SWM Low Power Radio 30 0.88 0.002
SWM Low Power Radio 100 0.08 0.0002
LCE Low Power Radio 30 0.88 0.00002
LCE Low Power Radio 100 0.08 0.000002
LCE Wide-Area Radio 30 28 0.21
LCE Wide-Area Radio 100 2.5 0.02
Radio base station 200 0.02 0.000005
Table 3.8 Comparison of crude and refined exposure estimates for the FlexNet
system in AMR mode
FlexNet device
Distance from
smart meter or
base station (cm)
Crude exposure
estimate (µW/cm²)
Refined exposure
estimate13
(µW/cm²)
SWM Low Power Radio 30 0.88 0.045
SWM Low Power Radio 100 0.08 0.004
LCE Low Power Radio 30 0.88 -
LCE Low Power Radio 100 0.08 -
LCE Wide-Area Radio 30 28 0.007
LCE Wide-Area Radio 100 2.5 0.0006
Radio base station 200 0.02 0.000005
12 Estimate considers duty cycle of the system and reflected exposure.
13 Estimate considers duty cycle of the system and reflected exposure.
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Figure 3.4 Comparison of crude and refined exposure estimates from FlexNet SWM
Low Power Radio
Figure 3.5 Comparison of crude and refined exposure estimates from FlexNet LCE
Low Power Radio
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Figure 3.6 Comparison of crude and refined exposure estimates from FlexNet LCE
Wide-Area Radio
Figure 3.7 Comparison of crude and refined exposure estimates from FlexNet radio
base station
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3.3.3 Pulsing effects
In addition to the thermal effects of EMR, some interest groups have expressed concerns
about the biological effects of very low-frequency pulsing produced by some radio systems,
suggesting that TETRA professional mobile radio may produce adverse health effects, both
as a result of the frequency of operation and from these pulsing effects. However, there is no
strong evidence to support these conclusions.
Cordless phones based on the DECT standard are now widely used in the home. DECT is
based on Time Division Duplex (TDD) and Time Division Multiple Access (TDMA) with 10 RF
carriers in the 1880-1900 MHz band, with peak power of 250 mW. During use, DECT devices
emit 400 µs bursts every 10 ms, resulting in an average power of 10 mW, which is
approximately 10 times smaller than the emissions from a mobile telephone. Whilst not
making a call, DECT devices transmit 80 µs pulses every 10 ms, resulting in an average
power of 2 Mw (HPA, 2012). Maximum electric field strengths are reported to be
approximately 1% of the ICNIRP reference level at a distance of 1 metre and 0.01% of the
reference level in far-field conditions (HPA, 2012).
Emissions from the smart meters are much simpler, consisting of infrequent, single short
transmissions. As a result, there is no equivalent pulsing effect for these systems.
3.3.4 Summary
There are many sources of RF energy to which an individual may be exposed every day,
including mobile phones, microwave ovens, Wi-Fi devices and cordless phones. Many of
these operate on similar frequencies to smart meters but with significantly higher power
and/or for a much longer duration.
Highly conservative calculations of exposure to RF from the smart meter systems have been
made, which have been compared with measured levels of RF exposure from other smart
meter devices and other RF-emitting devices that may be found in the home.
Even assuming unrealistic or extreme conditions with prolonged exposure in close proximity
to the smart meter, levels of exposure to RF from the both the Homerider and the FlexNet
smart meter transmitters and FlexNet base station are similar to those from other smart
meters. Levels of exposure are less than that which would be expected from Wi-Fi devices,
and are significantly lower than the levels of exposure that may be expected from standing
close to a microwave oven or using a mobile phone. When the very short signal durations of
the smart meters are taken into account, estimated levels of exposure are even lower.
It is therefore reasonable to conclude that levels of exposure to RF from smart meter devices
would represent a very small fraction of the total daily exposure that an individual may be
expected to receive.
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4. Human Health Review
4.1 Introduction
4.1.1 Risk Assessment
The risk assessment process used by the toxicologists in the NCET team to conduct the
human health review of smart meters is composed of several stages as illustrated in Figure
4.1 and described below.
Figure 4.1 Risk assessment process
Hazard Identification and Characterisation
These stages involve the identification of the hazard posed by potentially toxic materials, be
they chemical or radiation, etc. This is usually defined in terms of its target organ toxicity,
together with the amount needed to cause that hazard, i.e. the dose response.
There have been many 100s of studies in cells, experimental animals and humans, which
have investigated the potential hazard which might be posed by RF.
Exposure Assessment
This stage involves an actual, or often estimated, exposure of a receptor, in this case a
human adult or perhaps child or infant (including a determination of which is most susceptible)
to the hazardous material.
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Risk Characterisation
This stage involves the comparison of a level of exposure which would potentially have no
harmful effect on human health (derived from hazard characterisation; a „safe‟ level) with the
estimated or actual exposure concentration. In the case of RF, these „safe‟ levels are
guidelines which have been derived by the International Commission on Non-Ionizing
Radiation Protection (ICNIRP) and the US Federal Communications Commission (FCC), and
are described below. Exposure, either measured or estimated, above the „safe‟ level would
lead to concern about human health from that level of exposure.
4.1.2 Scientific Method for Reviewing Studies
There have been a large number of studies on the human health effects of RF, from cellular
systems (in vitro assays) to large-scale epidemiological studies looking at the effects of
instruments and processes emitting RF on the health of the public and workers. These studies
involve the examination of different health endpoints and a range of different RF exposures.
This being the case, it is not valid to reach conclusions on possible effects from the results of
single studies. The scientific weight-of-evidence (WOE) approach is used here to examine the
quality and results of all the studies in a particular field and if they point to a consistent effect,
this will be accepted by the scientific community.
Particularly since the use of cellular mobile phones became widespread, there have been
many 100s of studies measuring exposure to RF in all types of biological systems. It is
beyond the scope of this report to assess the results of all these studies. Therefore, it is
appropriate to locate reviews by authoritative bodies which are current and represent the
situation in the UK.
In April 2012 the UK Health Protection Agency‟s (HPA), now Public Health England (PHE)
Radiation, Chemical and Environmental Hazards Division published a review entitled Health
Effects from Radiofrequency Electromagnetic Fields (HPA, 2012). This was an updated
review building on one first published in 2003 and was the Report of the Independent
Advisory Group on Non-Ionising Radiation (AGNIR), which consisted of eight experts whose
knowledge covered all aspects of human health, together with ancillary staff.
This report, being the most recent relevant review by independent UK experts, forms the
basis for assessing the effects of RF on human health. The report covered all sources of RF
exposure including broadcasting, industrial applications and wireless telecommunications
(including smart meters). As smart metering is a relatively new technology, there are few
direct studies; however, there have been a number of reviews and these will be considered.
As has been shown previously, radiation emitted from mobile phones is at a similar frequency
to smart meters but with much longer exposure times and a much shorter distance (next to
the head), and so the human health studies on mobile phones and their RF, might be
considered a worst-case scenario for smart meter exposure.
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The International Agency for Research on Cancer (IARC) is an organisation located in France
and part of the World Health Organization (WHO) which has also recently reviewed RF and
assessed its potential for carcinogenicity and associated toxicities (IARC, 2013). Its review of
the evidence for toxicity is also summarised in this report.
The recent review by Verschaeve (2012) brought together the results of 33 reviews of the
literature published between 2009 and 2011.
4.2 Guideline values
4.2.1 International Commission on Non-Ionizing Radiation Protection
In 1998, the International Commission on Non-Ionizing Radiation Protection (ICNIRP)
developed guidelines for limiting exposure to electromagnetic, electric and magnetic fields up
to 300 GHz (ICNIRP, 1998). These guidelines were intended to provide protection against
adverse health effects, considering all the studies conducted on biological systems, exposed
human populations and dosimetry of electric and magnetic fields. The specific absorption rate
(SAR) measures the rate of energy absorption and is expressed as watts (W) per kilogram
(kg) of body mass. The guidelines set Basic Restrictions for the assumed SAR at the specific
emission frequency and the maximum (received) power density permissible. The more recent
studies were reviewed in 2010 and the guidelines restated (ICNIRP, 2009). These guidelines
are the “central pillar of advice on RF field exposure from the HPA” (HPA, 2012). They are
also recognised internationally and are more precautionary than the FCC values outlined
below. Therefore, these are the most appropriate guidelines to use when assessing the safety
of smart meters in the UK.
ICNIRP set Basic Restrictions for general health exposure and these must not be exceeded to
ensure compliance for frequencies up to 10 GHz.
The restriction that provides adequate protection for occupational exposure:
Whole body average Specific Absorption Rate (SAR): 0.4 W/kg
An addition safety factor of 5 has been introduced for exposure of the general public:
Whole body average Specific Absorption Rate (SAR): 0.08 W/kg
ICNIRP have also used these basic restrictions together with mathematical modelling and
experimental data to derive Reference Levels to provide practical exposure assessment to
determine whether Basic Restrictions are likely to be exceeded.
For exposure to workers and the general public, these Reference Levels are given as power
levels (equivalent plane wave power densities). According to the ICNIRP Guidelines, the
Reference Level for general public exposure is ƒ/200 (ƒ is frequency between
400-2000 MHz).
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Therefore, for RF emitted from devices operating at 868 MHz (including the Homerider) and
412-433 MHz (the FlexNet system), the Reference Levels for general public exposure, as
derived from the Guidelines, are as shown in Table 4.1.
Table 4.1 Reference Levels applicable to the Homerider and FlexNet systems
Component Frequency
(MHz)
Derivation of
Reference Level
Reference Level
W/m2 µW/cm
2
Homerider system 868 868/200 4.34 434
FlexNet system
SWM and LCE
Low Power Radio 433 433/200 2.12 212
LCE Wide-Area
Radio 412 412/200 2.06 206
Radio base station 423 423/200 2.12 212
The Reference Levels in Table 4.1 are guideline Reference Levels, and if power densities are
exceeded then further investigation can be instigated to demonstrate compliances with Basic
Restrictions. Comparison of these Reference Levels with the estimated power densities
(exposure estimates) derived from scenarios of use, as shown in Table 3.5 (Homerider),
Table 3.7 (FlexNet system in fixed network mode) and Table 3.8 (FlexNet system in AMR
mode), indicates that all levels of exposure are below the Reference Levels. This is
highlighted by Table 4.2 which shows that even the most conservative of the estimates (crude
exposure estimates, assuming a distance of 30 cm) indicate exposure below the Reference
Levels. The refined exposure estimates, accounting for duration of exposure and reflected
exposure, are even further below these Levels.
Table 4.2 Comparison of Reference Levels with exposure estimates
Component Reference Level
(µW/cm2)
Exposure estimate
(µW/cm²)14
Homerider system 434 2.2
FlexNet system
SWM and LCE Low Power Radio 212 0.88
LCE Wide-Area Radio 206 28
Radio base station 212 0.02
14 Based on the crude exposure estimates (not accounting for duration of exposure and reflected
exposure), calculated assuming distances of 30 cm, as the most conservative scenario.
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4.2.2 US Federal Communications Commission
The other main guidelines for the health effects of human exposure to RF are those first
established by the US Federal Communications Commission (FCC) in 1985 to limit human
exposure and protect against the thermal effects of absorbed RF emissions. These guidelines
were modified in 1996 and they are still in place. The guidelines also use two measures to
assess the effects of exposure to RF emissions. They are based on a threshold of 4 W/kg and
account for the thermal effects on health of heating body tissue. The adverse effect
considered by FCC at RF levels similar to those emitted by smart meters, was behavioural
disruption in experimental animals (including non-human primates).
The FCC limit is considered to be sufficiently protective of the health threshold of 4 W/kg
outlined above.
Specific Absorption Rate (SAR): 1.6 W/kg
The equivalent value to the Power Density set by ICNIRP (see above) is the Maximum
Permissible Exposure (MPE) which limits average exposure over a given time period (usually
30 minutes for general exposure) from a device and is often used for exposure to stationary
devices and where the human is more than 20 cm away.
These US guidelines are less stringent than those derived by ICNIRP which are international
and used in the UK. They are mentioned here for completeness and because they are used in
some of the studies described in this section.
4.3 Report of the Independent Advisory Group on Non-Ionising Radiation
This comprehensive review (HPA, 2012) considers the large numbers (many 100s) and wide
range of studies investigating the possible health effects of RF EMR. This study is an update
of a review which was published in 2003. The more recent studies have improved in quality
and attempt to reproduce and confirm earlier observations. The review is divided into a
number of chapters and demonstrates the wide-ranging types of studies and different
toxicological endpoints and outcomes. The conclusions of each section are summarised
below.
4.3.1 Cellular Studies
This chapter considered the interaction of RF with living tissue, investigated using in vitro cell
systems. There are a large number of studies using a range of cell types and endpoints and
the main problem is the lack of consistent results and the independent replication of
observations. As regards effects that could be linked to carcinogenesis, the evidence for a
possible direct effect of RF are not convincing; for example, there appears to be no increase
in cell proliferation, and evidence for a genotoxic effect (damage to genetic information) is
weak.
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In conclusion, there are no consistent effects on cell systems that indicate adverse effects of
RF below international guidelines.
4.3.2 Animal Studies
This chapter assessed the studies of RF effects on various tissues in experimental animals.
Animal studies have been useful in investigating possible health effects of the RF produced
by mobile phones. Again, there is no clear evidence of any effects below the guideline values,
although some subtle changes have been observed, often following single, acute exposure.
Effects on the brain and nervous systems have not shown any consistent effects by weak RF,
although the report suggests that further studies on the behaviour and development of young
animals would be interesting as there have been suggestions of improvements in learning.
Recent large-scale animal carcinogenicity studies conclude that long-term RF exposure does
not promote any kind of cancer. There are no adverse effects on immunology or haematology.
4.3.3 Cognitive Effects in Humans
This chapter considered the acute cognitive and neurophysiological effects of mobile phone
signals. Studies on cognitive function and performance in humans do not suggest an effect of
RF exposure from mobile phones or base stations. The results of neurophysiological studies
are inconsistent. The majority of recent studies have suggested an effect of RF fields on brain
function but the participant numbers and the difficulties in measuring the exposure to RF
makes their significance unclear. Further larger investigations are also required before the
changes in alpha band EEG seen in some experiments during and after RF exposure can be
considered convincing evidence. Studies in children do not support the idea that they are any
more susceptible to RF than adults, although again better quality evidence is required before
a firm conclusion can be drawn.
4.3.4 Symptoms in Humans
There has been a substantial amount of research into symptoms in humans and exposure to
RF fields. In the general population, the most common adverse effects attributed to RF are
acute subjective symptoms such as headache, fatigue and nausea. The type of symptoms,
speed of onset and type of electromagnetic field are very heterogeneous. However, it appears
that the sensitivity to RF reported by a small percentage of the population can be associated
with a poor quality of life. The overall evidence from the numerous studies suggests that no
causal link exists for short-term exposures.
There were problems in assessing exposure in the earlier longer-term studies due to self-
reporting or distance from base stations. These have been overcome by the use of personal
exposure meters and their use has typically shown no association between exposure and the
presence of symptoms. A possible association with behavioural disorders in children has
been observed but the results have not yet been replicated.
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4.3.5 Other (Non-Cancer) Effects in Humans
Possible effects on reproductive function such as spontaneous abortion, congenital
malformations, sperm quality and male and female sexual function and fertility are unproven
as there are few studies which use poor methodology. For example, none of the one positive
and three negative results from studies on potential effects on spontaneous abortion give
convincing evidence due to poor methodology.
There is no substantial evidence for an adverse effect on cardiovascular function.
4.3.6 Cancer in Humans
Studies of occupational exposure to RF and those of residence near radio and TV
transmitters do not indicate that RF exposure from these sources causes cancer. This review
suggests that the overall results of epidemiological studies do not indicate that the use of
mobile phones causes brain tumours or any other type of cancer, nor do they suggest that
causation is likely. There is considerable evidence of no observed effects within the first 10
years of use and to a lesser extent within 15 years, with only limited information on the risk of
childhood cancers. The conclusions from this review are stronger than those in the IARC
report which is summarised below.
4.4 Evaluation by the International Agency for Research on Cancer
The International Agency for Research on Cancer (IARC) evaluation was that there is „limited
evidence in humans for the carcinogenicity of RF‟ with positive associations observed
between exposure to RF from wireless phones, and gliomas and acoustic neuromas. There
was also limited evidence in experimental animals for the carcinogenicity of RF. The overall
evaluation was that radiofrequency electromagnetic fields are possibly carcinogenic to
humans (Group 2B) (IARC, 2013).
The following comments were made after publication of the evaluation:
Dr Jonathan Samet (University of Southern California, USA), overall Chairman of the Working
Group, indicated that ‘the evidence, while still accumulating, is strong enough to support a
conclusion and the 2B classification. The conclusion means that there could be some risk,
and therefore we need to keep a close watch for a link between cell phones and cancer risk.‟
IARC Director Christopher Wild stated: ‘Given the potential consequences for public health of
this classification and findings ‘it is important that additional research be conducted into the
long‐term, heavy use of mobile phones. Pending the availability of such information, it is
important to take pragmatic measures to reduce exposure such as hands‐free devices or
texting.’
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IARC classifies substances and some processes into the following Groups. At present, only
one substance, caprolactam, has enough evidence to be listed in Group 4.
Group 1: The agent is carcinogenic to humans
Group 2A: The agent is probably carcinogenic to humans
Group 2B: The agent is possibly carcinogenic to humans
Group 3: The agent is not classifiable as to its carcinogenicity to humans
Group 4: The agent is probably not carcinogenic to humans.
To put this classification into context, there is a range of different substances and processes
in Group 2B including: acetaldehyde, bitumen, coffee, gasoline, lead and talc-based body
powders, and occupational processes such as printing, dry cleaning and welding fumes.
While IARC reviewed several 100s of studies, the limited evidence for carcinogenicity in
humans comes mainly from the INTERPHONE study, a very large, multicentre study, together
with a smaller case-control Swedish study. The INTERPHONE study found an association
between gliomas and acoustic neuromas and mobile phone use, specifically in the group with
the highest 10% of call time, with subjects who used their phones on the same side of the
head as the tumour, and whose tumours were located in the temporal lobe (the area of the
head most exposed to RF when mobile phones are used). Similar results were found with
cordless phones in Sweden and this study showed a dose-response with cumulative call time.
A small Japanese study also observed an association of acoustic neuroma with mobile phone
use (IARC, 2013).
This association, which the IARC review considered could possibly be causal and which is
their main evidence for its Group 2B classification, appears to be closely linked to high
cumulative call use of a mobile phone, with that use being in close contact with the side of the
head. Neither the exposure in terms of time nor the proximity of the RF appears relevant to
the use of smart meters.
A number of long-term cancer bioassays had been conducted in mice and rats. There were a
number of negative results, with positive results seen when there was co-exposure of RF with
known carcinogens, mainly with RF at a higher frequency (1966 and 2450 MHz) than used in
smart meters (IARC, 2013).
The rest of the review of in vivo and in vitro investigations indicated some weak evidence for
genotoxicity but none for mutagenicity, with some evidence for changes in cellular processes
(IARC, 2013).
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4.5 Verschaeve (2012)
This publication briefly reviewed the conclusions of 33 reports from all around the world
including: ICNIRP, IARC, WHO, the European Union and many of its members, USA,
Canada, Australia and Latin America, and also assessed the expertise of the authors, the
methodology used and the quality of the report according to 10 criteria. The vast majority of
the reports expressed the same opinion which this publication considered not surprising as
they were reviewing the same data and some of the experts were on more than one review.
The main variant came from the BIOINITIATIVE Report (2007-2010) which concluded that
exposure to electromagnetic fields was a significant risk to human health and suggested limits
much lower than currently applied around the world. However, this report was not considered
independent and appeared to stress „alarming‟ studies and was rated only 3/10 for quality,
much lower than the other 30+ reports.
The conclusion of this review was that the vast majority of expert group opinions ‟did not
consider that there is a demonstrated health risk from RF-exposure from mobile phones and
other wireless communication devices. Because of remaining uncertainties, especially with
respect to long-term exposures, some caution is still expressed.‟
4.6 European Commission Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR) (2015)
SCENIHR have recently published an opinion on Potential health effects of exposure to
electromagnetic fields. This report was published too late to be fully reviewed here and these
statements are taken from the conclusions drawn. This report outlines recent studies on EMF
including RF with the work overwhelmingly on mobile phone use. The overall conclusions are
in line with other reviews. Epidemiological studies do not show an increased risk of brain
tumours or any other malignant diseases including childhood cancer. There is a lack of
evidence that mobile phone RF affects cognitive function. Double-blind and other studies on
symptoms attributed by some people to both short and long-term exposure to EMF (and
which can seriously impair quality of life) have not been causally linked RF exposure. The
conclusion is that there are no adverse effects on reproduction and development from RF
fields at non-thermal exposure levels, i.e. levels below the ICNIRP values outlined above in
this review.
4.7 Specific Reviews of Smart Meters
There have been a few reviews considering the health effects of RF exposure from smart
meters. Unlike the studies based mainly on the use of mobile phones and the observation of
potential adverse health effects, these reviews are based on the RF exposure from the use of
smart meters and comparison with the guideline values derived by FCC and ICNIRP. These
reviews have also been considered in section 2.
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4.7.1 Review by California Council on Science and Technology
The most detailed review on the health effects of RF in smart meters was carried out by an
independent panel of scientists for the California Council on Science and Technology (CCST)
and entitled Health impacts of radio frequency exposure from smart meters (CCST, 2011). In
the absence of specific health-based studies on smart meters, its remit was to: firstly, see
whether US FCC standards for smart meters were adequate for protection of the public,
taking into account current exposure levels to RF; and secondly, whether additional
technology-specific standards were needed for smart meters and other devices commonly
found in the home, to protect public health.
The review identified two types of RF effects: thermal and non-thermal. Thermal effects have
been extensively studied and are largely understood, while non-thermal effects are not well-
defined.
The report states that smart meters operate at low power in the RF portion of the
electromagnetic spectrum and that at these levels, RF emissions are unlikely to produce
thermal effects. Scientific consensus (including WHO) is that body temperature must increase
by at least 1°C to have any biological impact. The only effect seen in the power/frequency
range of smart meters is a disruption in animal feeding behaviour at an energy level of 4 W/kg
(the energy absorption rate, SAR is measured in watts per kg body mass) with a rise in body
temperature of 1°C. The exposure levels from smart meters, even at close range, is far below
this threshold. The FCC limit is 1.6 W/kg giving a significant safety factor against the SAR
threshold of effect of 4 W/kg.
Suggested non-thermal effects include non-specific symptoms such as fatigue, headache and
irritability and even cancer, but these findings have not been scientifically established and any
mechanisms for such effects remain unclear. The report suggests that available data strongly
suggest that if there are any effects of RF absorption on human health, “such effects are not
so profound as to be easily discernible”.
The FCC guidelines are based on protection against thermal effects although their staff state
that their exposure limits provide adequate protection from all known adverse effects, thermal
or athermal in origin.
4.7.2 Report by the Electric Power Research Institute
A report was produced in December 2010 by the Electric Power Research Institute (EPRI)
entitled An Investigation of Radiofrequency Fields Associated with the Itron Smart Meter
(EPRI, 2010). The report outlined data collated from the operation of two types of smart
meters currently being used in California.
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Again this was not a review of the studies conducted on potential human health effects of RF
but compared actual RF levels in the laboratory, and residential scenarios and estimated
models with the FCC Maximum Permitted Exposure (MPE) limit as outlined previously.
The frequency of smart meters used in this study was 902-928 MHz and the FCC MPE used
was 601 µW/cm2. The results indicated that the RF field generated by the smart meter was
well below the limit for all scenarios. For a distance of one foot (approximately 0.3 m),
exposure from the smart meter would not exceed 0.8% and the cell relay (the „gateway
device‟) not more than 0.2% of the MPE. At the more realistic distance of ten feet, the
corresponding values would be 0.008% and 0.002%, respectively. Even if, at one foot, the cell
duty was 100% (i.e. the meter transmitting continuously), the resulting exposure was still less
than the MPE. For the occupants of a home equipped with a smart meter, the interior RF
fields might be expected to be at least 10 times less due to the directional properties of the
meter.
The report concluded that, regardless of the duty cycles involved, typical exposures resulting
from the operation of smart meters were very low and complied with scientifically-based
human exposure limits by a wide margin.
4.7.3 Study by the State Government of Victoria, Australia
A small similar measurement study of RF fields emitted by smart meters was conducted for
the State Government of Victoria, Australia (Zombolas, 2012) using a number of occupational
sites and dwellings. The results were compared to the Australian Radiation Protection and
Nuclear Safety Agency (ARPANSA) Draft Radiation Protection Standard: Limits for Electric
and Magnetic Fields. This standard is identical to the ICNIRP standard and slightly less than
the FCC limits. The results showed that even with the worst-case duty cycle and possible
reflections, the RF emissions from the smart meters were less than 1% of the limit. The report
also concluded that exposure to RF was likely to be significantly less than other common
household appliances such as baby monitors and vacuum cleaners.
4.7.4 Review by the Vermont Department of Health, USA
As part of a review by the US Vermont Department of Health (2012), actual measurements
were made of active smart meters and these verify that they emitted only a small fraction of
the RF emitted from a wireless phone, even at very close proximity to the meter, and the RF
was well below the regulatory limits set by FCC. The report gives an example of
measurements, taken directly in contact with a smart meter on an external wall of a residence,
which ranged from 50-140 µW/cm2 compared to the US FCC maximum permissible of
610 µW/cm2 for a member of the public. Measurements at distances of three feet or more
from the smart meter were at or near background.
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After reviewing the scientific literature, the Vermont Department of Health concluded that the
current regulatory standards for RF from smart meters were sufficient to protect human
health.
4.7.5 IEEE Committee on Man and Radiation, COMAR Technical Information Statement (2013)
The Institute of Electrical and Electronic Engineers (IEEE) Committee on Man and Radiation
(COMAR) produced a Technical Information Statement to describe smart meter technology
and the levels of RF emissions from these meters, in relation to US and international RF
safety limits, together with comparison of levels from other sources (IEEE, 2013). They
indicated that smart meters transmit at the same frequency ranges as Wi-Fi, many cordless
phones, remote controlled light switches, some baby monitors and other wireless-enabled
appliances. They concluded that smart meters signals were typically lower than those from
other RF emitting devices in the home. They quoted evidence that RF energy from a smart
meter was below the background level from operation of a laptop computer, energy leaking
from the door seals of an operating microwave and a Wi-Fi controlled power outlet and home
thermostat, and that the main European home RF exposure was likely to be from use of a
mobile phone. In both of these examples, all the RF exposure measured in the home was a
fraction of the relevant safety limits.
From both the RF exposure relative to national and international safety limits and
consideration of the health reviews on RF, IEEE COMAR concluded that RF from smart
meters should be considered safe.
4.8 Summary
The main guidelines developed for limiting exposure to electromagnetic, electric and magnetic
fields are those set by the International Commission on Non-Ionizing Radiation Protection
(ICNIRP) and these are the “central pillar of advice on RF field exposure from the HPA” (UK
Health Protection Agency, now PHE, Public Health England, 2012). They are used in the UK
as „safe‟ limits against which to compare potential exposure from radiofrequency emissions in
general.
There have been hundreds of studies on the human health effects of RF (particularly since
the widespread use of mobile phones) using many methods from cellular systems (in vitro
assays) to large-scale epidemiological studies. The scientific community uses a weight-of-
evidence approach to assess studies and reach a conclusion about a consistent effect. Such
studies have been recently assess by the independent Advisory Group on Non-Ionising
Radiation (AGNIP; on behalf of the Health Protection Agency), and the World Health
Organization‟s International Agency for Research on Cancer (IARC).
AGNIP reviewed all the data that have accumulated over the years and concluded that
problems in estimating RF exposure levels and conflicting results meant that firm evidence of
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either adverse or no effect has been difficult to obtain. However, the results at present
suggest that there appears to be some slight biological effect caused by thermal heating from
RF. The AGNIR review concluded that there is no firm evidence of adverse effects of RF
below the international guidelines set by ICNIRP and FCC.
The recent IARC review led to a classification of Group 2B as “Possibly carcinogenic to
humans” and this was mainly due to evidence of an association between the very highest
mobile phone use and some brain tumours, which were present on the same side of the head
as that used for mobile phone calls, i.e. very close contact. These studies suffered from lack
of confirmed exposure, which was usually estimated from personal recall over a number of
years.
There have been few studies so far on the specific use of smart meters but these have
concluded that RF exposure is low and well below the international guidelines set for the
protection of human health.
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5. Conclusions
Even assuming very close proximity to smart meters for extended periods, the exposure is still
well below the guideline limit levels set by international authoritative bodies (see Section 4.2)
for the protection of human health. Two studies carried out in the US, which compared
emissions from smart meters with those from other sources, have been discussed. The smart
meters which were the subject of these studies operate on similar frequencies but with
significantly higher radiated power levels compared with the Homerider and FlexNet systems.
There have been hundreds of studies both in humans and using experimental systems
investigating the possible effects on biological systems and human health. These have been
recently reviewed by authoritative, independent bodies, AGNIR in the UK (see Section 4.3)
and IARC part of WHO (see Section 4.4). The weight-of-evidence approach adopted by the
scientific community (and used by National Centre for Environmental Toxicology (NCET)
experts) requires that, for an effect to be confirmed, there is a replication of an observed effect
in a number of different independent studies, preferably in a number of different systems.
Problems in estimating RF exposure levels and conflicting results has meant that firm
evidence of either adverse or no effect has been difficult to obtain. The results at present
suggest that there appears to be some slight biological effect caused by thermal heating from
RF. The AGNIR review concludes that there is no firm evidence of adverse effects of RF
below the international guidelines. The recent IARC classification of Group 2B as “Possibly
carcinogenic to humans” was mainly due to evidence of an association between very high
mobile phone use and some brain tumours, which were present on the same side of the head
as that used for mobile phone calls, i.e. close contact. These studies also suffered from lack
of confirmed exposure, which was usually estimated from personal recall over a number of
years.
Both the thermal effects and the possible carcinogenicity are not relevant to exposure from
RF emitted by smart meters: the RF would not raise body temperature sufficiently; and, the
brain tumours appear specific to the extremely close proximity and intense use of mobile
phones.
Even in worst-case scenarios, the RF emitted by mobile telephones is still well-below the
international guidelines (see Section 4.2) set for the protection of human health. The power
density of RF emitted by smart meters is lower or similar to that emitted by other common
household products. When the very short signal durations of smart meters are taken into
account, estimated levels of exposure to RF from smart meters are lower still. It is therefore
reasonable to conclude that levels of exposure to RF from smart meter devices would
represent a very small fraction of the total daily exposure that an individual may be expected
to receive.
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NCET has used the scientific weight-of-evidence (WOE) approach to evaluate the numerous
studies investigating the potential effects on human health of RF exposure, mainly from
mobile phones. The overall conclusion is that there is no evidence that the use of smart
meters would have any adverse effects on human health, particularly so for the low levels of
exposure involved in the Homerider and FlexNet deployments.
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References
CCST (2011) Health impacts of radio frequency exposure from smart meters. California Council on
Science and Technology.
EPRI (2010) An investigation of Radiofrequency Fields Associated with the Itron Smart Meter. 2010
Technical Report. Electric Power Research Institute, California, USA.
EPRI (2011a) Radio-Frequency Exposure Levels from Smart Meters: A Case Study of One Model.
February 2011. Electric Power Research Institute, California, USA.
EPRI (2011b) Characterization of Radiofrequency Emissions from Two Models of Wireless Smart
meters. 2011 Technical Report. Electric Power Research Institute, California, USA.
HPA (2012) Health Effects from Radiofrequency Electromagnetic Fields. Report of the independent
Advisory Group on Non-Ionising Radiation (AGNIR). Document of the Health Protection Agency,
Radiation, Chemical and Environmental Hazards.
IARC (2013) Non-ionizing radiation, part 2: radiofrequency electromagnetic fields. Vol. 102 IARC
monographs on the evaluation of carcinogenic risks to humans. International Agency for Research on
Cancer, World Health Organization.
IEEE (2013) Committe4e on Man and Radiation. COMAR Technical Information Statement.
Radiofrequency Safety and Utility Smart Meters. Institute of Electrical and Electronic Engineers.
Available from: http://ewh.ieee.org/soc/embs/comar/COMAR%20Smart%20Meter%20TIS%20(9-25-
2013).pdf
ICNIRP (1998) ICNIRP Guidelines for limiting exposure to time-varying electric, magnetic and
electromagnetic fields (up to 300 GHz). Health Physics 74, 494-522. International Commission on Non-
ionizing Radiation Protection.
ICNIRP (2009) ICNIRP Statement on the “Guidelines for limiting exposure to time-varying electric,
magnetic and electromagnetic fields (up to 300 GHz)”. Health Physics 97, 257-258. International
Commission on Non-ionizing Radiation Protection.
PG&E (2013) Understanding Radio Frequency (RF). Pacific Gas & Electric. Available from
http://www.pge.com/safety/systemworks/rf/
Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR) (2015) An Opinion on
Potential health effects of exposure to electromagnetic fields. European Commission. Available at
http://ec.europa.eu/health/scientific_committees/emerging/docs/scenihr_o_041.pdf
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Vermont Department of Health (2012) Radio Frequency Radiation and Health: Smart Meters. Available
from:
http://healthvermont.gov/pubs/ph_assessments/radio_frequency_radiation_and_health_smart_meters.p
df
Verschaeve, L. (2012) Evaluations of International Expert Group Reports on the Biological Effects of
Radiofrequency Fields, Wireless Communications and Networks - Recent Advances, Dr. Ali Eksim
(Ed.), ISBN: 978-953-51-0189-5, InTech, DOI: 10.5772/37762. Available from:
http://www.intechopen.com/books/wireless-communications-and-networks-recent-
advances/evaluations-of-international-expert-group-reports-on-the-biological-effects-of-radiofrequency-
fields
Zombolas, C. (2012) Study on electromagnetic fields from smart meters prepared for Department of
Primary Industries, State Government of Victoria, Australia. Metering International, Issue 2, 82-84.
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Appendix A Regulatory Conformance Requirements
A1 Introduction
Manufacturers and suppliers of Radio and Telecommunications Terminal Equipment wishing
to place their products in the European Union market must demonstrate compliance with the
protection requirements of the R&TTE Directive by providing:
A Technical Construction File (TCF);
A Declaration of Conformity (DoC) that shows how compliance is achieved; and
CE Marking to indicate compliance.
A2 Homerider Systems Declaration of Conformity
Homerider Systems‟ Declaration of Conformity and sales literature claim compliance with the
following directives and standards:
1999/05/EC (R&TTE Directive)
2004/108/EC (EMC Directive)
EN 300 220-1 V2.3.1
EN 300 220-2 V2.3.1
EN 301 489-1 V1.8.1
EN 301 489-3 V1.4.1
EN 301 489-7 V1.3.1
Radio ISM 868MHz: REC70-03E
EN 50371:2002; Recommendation 1999/519/EC (NB This Standard has now been
superseded by BS EN 62479:2010. Assessment of the compliance of low power
electronic and electrical equipment with the basic restrictions related to human
exposure to electromagnetic fields (10 MHz to 300 GHz)
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These directives and standards are summarised below.
A3 FlexNet
The conformities for the various components of the FlexNet system are shown in
Standard or Directive SWM
640
SWM
iPERL
LCE
Smartpoint
R&TTE Directive 1999/5/EC Y Y Y
EN 300 113-2 V1.5.1 Y
ETSI EN 300 220-1 V2.4.1 Y
ETSI EN 300 220-2 V2.4.1 Y Y Y
EN 301 489-1 V1.9.2 Y Y Y
EN 301 489-3 V1.4.1 Y Y
EN 301 489-5 V1.3.1 Y
A4 Summary of Directives and Standards
R&TTE Directive The European Radio equipment and Telecommunications Terminal
Equipment (R&TTE) Directive (1999/5/EC) covers all radio equipment and all equipment
intended to be connected to public telecommunications networks.
The R&TTE Directive relies for its operation on Harmonized Standards defined by the
recognized European Standards Organizations; these Harmonized Standards define technical
characteristics which can be used to meet the essential requirements of the Directive. The
essential requirements, which are applicable to all apparatus, cover: health and safety,
electromagnetic compatibility (EMC), radio spectrum matters, and other aspects.
Health and safety is addressed by Article 3(1)(a): the protection of the health and the safety of
the user and any other person, including the objectives with respect to safety requirements
contained in the Low Voltage Directive (LVD) – Directive 2006/95/EC24, but with no voltage
limit applying. This essential requirement ensures also that equipment is constructed in such
a way that, when it is used as intended, the limits for human exposure to electromagnetic
fields are respected.
EMC Directive In the UK the EMC Directive has been transposed as: The Electromagnetic
Compatibility Regulations 2006, Statutory instrument (SI) of 20/01/2007, SI 2006 No. 3418.
ETSI EN 300 220-1 V2.3.1 (2009-04) ElectroMagnetic Compatibility and Radio Spectrum
Matters (ERM); Short Range Devices (SRD); Radio equipment to be used in the 25 MHz to
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1 000 MHz frequency range with power levels ranging up to 500 mW; Part 1: Technical
characteristics and test methods.
ETSI EN 300 220-2 V2.3.1 (2009-12) Electromagnetic compatibility and Radio spectrum
Matters ERM); Short Range Devices (SRD); Radio equipment to be used in the 25 MHz to 1
000 MHz frequency range with power levels ranging up to 500 mW; Part 2: Harmonized EN
covering essential requirements under article 3.2 of the R&TTE Directive.
ETSI EN 301 489-1 V1.8.1 (2008-04) Electromagnetic compatibility and Radio spectrum
Matters (ERM); ElectroMagnetic Compatibility (EMC) standard for radio equipment and
services; Part 1: Common technical requirements.
ETSI EN 301 489-3 V1.4.1 (2002-04) Electromagnetic compatibility and Radio spectrum
Matters (ERM); ElectroMagnetic Compatibility (EMC) standard for radio equipment and
services; Part 3: Specific conditions for Short-Range Devices (SRD) operating on frequencies
between 9 kHz and 40 GHz.
ETSI EN 301 489-5 V1.3.1 (2002-08) Electromagnetic compatibility and Radio spectrum
Matters (ERM); ElectroMagnetic Compatibility (EMC) standard for radio equipment and
services; Part 5: Specific Conditions for private land mobile radio (PMR) and ancillary
equipment (speech and non-speech).
ETSI EN 301 489-7 V1.3.1 (2005-11) Electromagnetic compatibility and Radio spectrum
Matters (ERM); ElectroMagnetic Compatibility (EMC) standard for radio equipment and
services; Part 7: Specific conditions for mobile and portable radio and ancillary equipment of
digital cellular radio telecommunications systems (GSM and DCS).
BS EN 50371:2002 Generic standard to demonstrate the compliance of low power electronic
and electrical apparatus with the basic restrictions related to human exposure to
electromagnetic fields (10 MHz - 300 GHz). General public. (NB This standard has been
superseded by BS EN 62479:2010 Assessment of the compliance of low power electronic
and electrical equipment with the basic restrictions related to human exposure to
electromagnetic fields (10 MHz to 300 GHz) which provides additional routes to
demonstrating conformance.
ERC Recommendation 70-03 This Recommendation sets out the general position on
common spectrum allocations for Short Range Devices (SRDs) for countries within the CEPT.
It is also intended that it can be used as a reference document by the CEPT member
countries when preparing their national regulations in order to keep in line with the provisions
of the R&TTE Directive.
EN 50371:2002 has been replaced by EN 62479:2010. The standard EN 62479:2010:
Assessment of the compliance of low power electronic and electrical equipment with the basic
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restrictions related to human exposure to electromagnetic fields (10 MHz to 300 GHz) is listed
in the Official Journal of the European Union as a Harmonized Standard under the R&TTE
directive. For a Self-Declaration of Compliance, the manufacturer must have an Assessment
Report for this standard in the TCF for his product. The Scope of the standard is a simple
conformity assessment method for low-power electronic and electrical equipment to an
exposure limit relevant to electromagnetic fields (EMF). It specially addresses the SAR
compliance for devices with a power less than 20 mW.
ETSI EN 300 113-2 V1.5.1 Electromagnetic compatibility and Radio spectrum Matters (ERM);
Land mobile service; Radio equipment intended for the transmission of data (and/or speech)
using constant or non-constant envelope modulation and having an antenna connector; Part
2: Harmonized EN covering essential requirements of Article 3.2 of the R&TTE Directive.