Lin's commentary is misleading and inaccurate on important topics. First, it misrepresents the IEEE C95.1-2019 2 and ICNIRP (2020) limits 3. Second, it fails to distinguish between biological effects and health hazards, with several examples incorrectly presented. Third, his critique of World Health Organization (WHO) sponsored systematic reviews (SRs) relies on selected criticisms without evaluating their objectivity and substance. Consequently, his commentary lacks an adequate basis for its conclusions.1. Referring to Table 1 1, Lin states "the exposure limits allow tissue temperature rises in the human head, limbs, and torso to as high as 5°C." This statement is incorrect because 5°C is the threshold for adverse effects on the body surface for 6 -300 GHz local exposures; the exposure limits will not allow a temperature increase to 5°C, although Lin explained there are safety or reduction factors of 2 and 10 near the end of the paragraph, and called them marginal. ICNIRP has limits of 2 °C for head and torso tissues and 5 °C for limbs for local exposures below 6 GHz; above 6 GHz, the absorbed power density limits in columns 8, 10 are for all body surface tissues, not separated as Local head-torso and Local limbs as in Table 1. The averaging area for 30-300 GHz is 1 cm 2 and not 2 cm 2 . The exposure limits in W/m 2 are stated correctly in the text but the units are listed incorrectly as W/cm 2). Harmonization of limits and frequency ranges was an important part of the process as long as justified based on scientific reasoning.3. Lin argues that the microwave auditory effect is adverse but occurs at exposure levels allowed by guidelines. The IEEE C95.1-2019 standard 2 and ICNIRP (2020) guidelines 3 explicitly state that the limits are designed to protect against adverse health effects, identified as "established" adverse health effects (IEEE) 2 and "substantiated" adverse health effects" (ICNIRP, 2020) 3 of exposures to electric fields, magnetic fields, and electromagnetic fields. They were not set on the basis of speculative hazards or biological data that are unrelated to health. Both standards have evaluated and explicitly excluded this effect. The IEEE C95.1-2019 standard 2 states "The phenomenon of RF hearing in humans is a wellestablished biological effect with no known adverse health consequence. The RF-induced sounds are similar to other common sounds." ICNIRP 2020 also does not include limits for auditory effects for similar reasons 3.RF radiation is questionable " and "are flawed and are not applicable to long-term, low-levels exposures." While that is his opinion and shared by others, his cited support consists of one review "(18)" and 7 opinion pieces "(17-22, 33)". IEEE C95.1-2019 in Section 1.3.1 rebuts these opinions:The literature review also evaluated the possibility of adverse health effects associated with chronic low-level exposure. For exposures to electric, magnetic, and electromagnetic fields at frequencies between 0 Hz and 300 GHz, the following two conclusions were reached: a) The weight-of-evidence provides no credible indication of adverse effects caused by chronic exposures below levels specified in this standard. b) No biophysical mechanisms have been scientifically validated that would link chronic exposures below levels specified in this standard to adverse health effects 2.ICNIRP has similarly addressed this issue in its guideline 3 and ICNIRP 2020 Q none reported consistent, confirmed health effects at levels below IEEE and ICNIRP exposure limits https://sagroups.ieee.org/ices/expert-reviews/.6. Lin criticizes some of the 12 recent systematic reviews (SR) of various RF/health issues supported by the World Health Organization 6 that "appear to be biased with strong conviction of nothing but heat to worry about with RF microwave radiation" 7891011. This misrepresents actual conclusions of the reviews; they are more detailed and cannot be summarized as stated. Rather than dismissing non-thermal effects reviewed, conclusions focused on the poor overall quality of the studies reviewed, which prevented drawing conclusions with high confidence. Several SRs provided detailed recommendations for improved follow-up research to address these weaknesses. Evaluation of this complex scientific literature includes consideration of risk of bias, quality of study design, possible study-selection bias, and certainty of evidence. These complex issues cannot be adequately addressed in commentaries by Lin or us, and await more comprehensive multidisciplinary assessments of SRs, all commentaries, and more publications in planned reports by scientific and health agencies including the WHO Task Group in the upcoming EHC Monograph of RF fields, and by the International Agency for Research on Cancer (IARC).
Bailey et al. (Thu,) studied this question.