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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

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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

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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.

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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

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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

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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

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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

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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.

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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

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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.

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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.

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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

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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.

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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.

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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

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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.

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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).

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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:

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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.

)

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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.