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Radiation protection and the Directorate of Radiation Control in South Africa

Radiation protection and the Directorate of Radiation Control in South Africa

Mr Leon du Toit from the Directorate of Radiation Control of the Department of Health in South Africa is frequently quoted by the mobile industry & Council officials as saying that “local and other authorities, in considering the environmental impact of any particular base station, do not need to and should not attempt, from a public health point of view, to set any restrictions with respect to parameters such as height of the mast, distance to the mast, and duration of exposure.” DRC – Leon du Toit’s letter

However in this study published in 2012 the SA Journal of Radiology the authors note that “the DRC [Directorate of Radiation Control] is not a juristic person and has no locus standi or legal capacity to take decisions, issue licences, determine conditions or function on its own. The common idea that the DRC is the ‘regulatory authority’ is not only wrong, but also without legal foundation.”

Although the study considers the negligence of the DRC with respect to ionising radiation, there are useful parallels in the way they fail to adequately protect the public from the effects of non-ionising radiation as well.

Radiation protection and the safe use of X-ray equipment: Laws, regulations and responsibilities

Background: South Africa’s regulatory framework for electromagnetic medical devices has come under considerable criticism. Here it is reviewed in terms of how it has given form to protective measures against ionising radiation. The Hazardous Substances Act provides for effective protection against radiation, but has been undermined by poor administration and uncertainty about regulations and licensing conditions. The legal weight of enforcing licensing conditions through a website without proper consultation with all parties concerned is questionable and ineffective…

Charles P Herbst, PhD (Department of Medical Physics, University of the Free State, Bloemfontein)
Gerhard H Fick, DCL (Department of Private Law, University of the Free State)
Corresponding author: C Herbst (




Detailed Submission to DoC&DT re 5G Masts

Cut and paste everything in the block under this into your email. Then copy  ONE OR TWO of the numbered points (or however many you choose just NOT ALL OF THEM) and copy them into your email and if possible, try to add in your own words. This is because Government hates form letters and tends to disregard them.


Email to:

The Acting Director-General, Department of Communications and Digital
For attention: Mr. A Wiltz, Chief Director, Telecommunications and IT Policy; Cell: 0837140126 (Mr. L Motlatla)


When the ‘advancement as a country in the 4th Industrial Revolution’ becomes a danger to the health of people and environment.

I hereby object to the above policy and policy direction based on the following grounds:


We look forward to your prompt response to this legitimate concern and hereby call for a moratorium on the roll-out of 5G and using the Precautionary Principle until Government has conducted independent (not funded by industry with vested interests) studies to prove its safety) and that an effective safety, monitoring and regulation policy has been establish.

Signed: SA Citizen

NUMBERED POINTS – REMEMBER TO only copy and paste some points not all of them and also you will then need to remove the paragraph numbers in your email submission.

The erection of cell masts in close proximity to where we live, work and play, violates our Section 24 constitutional right to:

  1. An environment that is not harmful to their health or well-being. The untested 5G technology has been proven by science that the radiation from cell masts is harmful to our health.  (See here for scientific reports:
  2. To have the environment protected, for the benefit of present and future generations, through reasonable legislative and other measures that—
    (i) prevent pollution and ecological degradation;
    (ii) promote conservation; and
    (iii) secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.

Regarding these points (i)(ii) and (iii)  under (2) above, the roll-out of 5G technology will:

(i) rather than prevent ecological degradation 5g technology in fact enhances it because it will be inescapable to all life on earth; there is no ‘opting out’ or getting away from it; (A 2018 study published in Annals of Telecommunications found increased RF-EMF exposure from small cell LTE networks in two urban cities in France and the Netherlands. Researchers measured the RF-EMF from LTE (Long-Term Evolution) MC (macro cells meaning large cell towers) and SC networks (low-powered small cell base stations)  and found that the small cell networks increased the radio emissions from base stations (called downlink) by a factor of 7–46  while decreasing the radio emissions from user equipment exposure (called ) by a factor of 5–17. So while the devices themselves could emit less radiation, the cell antennas will increase the levels from cell antennas (Mazloum et al., 2019). This study shows the increased exposures would be involuntary. We can turn our phones off, but we cannot turn off the antennas in the neighborhood.)

(ii) again 5G technology destroys conservation of trees, birds etc., rather than conserve it; See here for the results of a symposium regarding the effects of 5G on  Birds, Bees, and Humanity.

(iii) As shown but the somewhat reckless and certainly unbalanced manner in which the Government is rolling out 5G technology without our consultation or consent, Government is clearly more in favour of developing the profits of the telecoms companies, rather than protecting to our health and safety.

Other Factors for Opposing the Current Role-Out of 5G

  • It has never been tested and proven safe, the erection of its technology violates twelve international codes and policies including :
    The Nuremberg Code (1947)applies to all experiments on humans, thus including the deployment of 5G with new, higher RF radiation exposure that has not been pre-market tested for safety. “The voluntary consent of the human subject is absolutely essential” (art. 1). Exposure to 5G will be involuntary. “No experiment should be conducted, where there is an a priori reason to believe that death or disabling injury will occur” (art. 5). The findings of over 10,000 scientific studies and the voices of hundreds of international organizations representing hundreds of thousands of members who have suffered disabling injury and been displaced from their homes by already-existing wireless telecommunications facilities, are “a priori reasons to believe that death or disabling injury will occur”.
  1. There is no effective legislative procedure in place to guide, monitor or redress 5G electro-magnetic radiation. South Africa adheres to the ICNIRP  guidelines which the independent scientific research shows is inadequate and ineffectual; (See A 2020 European Parliament Briefing on the “Effects of 5G wireless communication on human health” reiterates the issues with measurements and also comments on how radiation limits are outdated stating in this summary, “The EU’s current provisions on exposure to wireless signals, the Council Recommendation on the limitation of exposure of the general public to electromagnetic fields (0 Hz to 300 GHz), is now 20 years old, and thus does not take the specific technical characteristics of 5G into account” (Karaboytcheva, 2020).
  2. Studies show that radiofrequency (RF) radiation in the frequency range of 30 kHz-300 GHz (the range for 5G) is classified as a ‘possible’ human carcinogen, Group 2B, by the International Agency for Research on Cancer (IARC) since 2011.The above evidence has since then been strengthened by further research; thus, RF radiation may now be classified as a human carcinogen, Group 1. In spite of this, microwave radiations are expanding with increasing personal and ambient exposure. One contributing factor is that the majority of countries rely on guidelines formulated by the International Commission on Non-Ionizing Radiation Protection (ICNIRP), a private German non-governmental organization. ICNIRP relies on the evaluation only of thermal (heating) effects from RF radiation, thereby excluding a large body of published science demonstrating the detrimental effects caused by non-thermal radiation.
  3. 5G will add significantly to the current electro-magnetic radiation we already have from mobile phone masts, mobile phones, Wi-Fi, wearable devices, smart meters, and other ‘smart’ devices. (See A 2018 multi-country study published in Environment International measured RF in several countries. It found that cell phone tower radiation is the dominant contributor to RF exposure in most outdoor areas; exposure in urban areas was higher and that exposure has drastically increased. As an example, the measurements the researchers took in Los Angeles, USA were 70 times higher than the US EPA estimate 40 years ago (Sagar et al., 2018). and another study of how rapidly RF is increasing from wireless antennas, a 2014 published study from Environmental Research looked at RF in three European cities and found in just one year (between  April 2011 and March 2012) that the total RF-EMF exposure levels in all outdoor areas in combination increased by 57.1%  in Basel, by 20.1% in Ghent and by 38.2% in Brussels. “Exposure increase was most consistently observed in outdoor areas due to emissions from mobile phone base stations” (Urbinello et al., 2014).
  4. There has been NO public hearings or consent which is problematic and is thus what Robert F Kennedy (Jr) calls: The Global Human Experiment Without Consent.
  5. The consequence of Government inaction could be serious and irreversible damage. We just don’t know how damaging the technology is. The latency period asbestosis for example is officially 5 to 10 years, although often it takes 40 or more years from first exposure before the disease is diagnosed.




The public needs to be properly informed of the potentially harmful effects of radio-frequency waves (RF) and their role in cancer and other serious medical conditions as reported in the following studies and reports:

  1. Radio-frequency radiation has been designated as a Group 2b carcinogen in 2011 by the International Agency for Research on Cancer based on increased incidence of certain types of brain tumours in heavier users of mobile phones was not communicated to the public.
  2. A ten year $30 million dollar study from the National Toxicology Program (NTP) funded by the U.S. government, which analyzed the effect of mobile phone radiation concluded ‘clear evidence’ of carcinogenesis.
  3. The highly esteemed Ramazzini Institute corroborated these findings above by demonstrating the same types of tumours in response to much lower intensity base station type exposures. Together, these two very large scale animal studies confirm the human epidemiological data already demonstrating carcinogenesis and as a result multiple independent experts and teams of experts have made clear that RF should now be designated as a Group 1 ‘known human carcinogen’
  4. Effect of Ultra High Frequency Mobile Phone Radiation on Human Health : This paper describes the risk of mutation and sexual trauma and infertility in masculine sexual cell by mobile phone radiations:
  5. The results of this study and International Commission of Non Ionization Radiation Protection (ICNIRP) reports showed the people who spend more than 50 minutes a day using a cell phone could have early dementia or other thermal damage due to the burning of glucose in the brain.



Request to DoC&DT for an extension for public participation

The Acting Director-General, Department of Communications and Digital Technologies
For attention: Mr. A Wiltz, Chief Director, Telecommunications and IT Policy; Cell: 0837140126 (Mr. L Motlatla)


Due to the current circumstances of the lockdown, we request an extension for the public participation process for the above policy for a further 30 days until the end of SEPTEMBER 2020.

This is to allow for a wider exposure to the general public so that they can be adequately informed of their rights regarding the roll-out of this technology.

Your prompt attention to this would be appreciated.

Kindly respond by no later than 15 August 2020

Yours sincerely

Member of the Public.





Interested persons are invited to provide written comments on the proposed policy

and policy direction, within 30 working days of the date of publication, addressed

to –



Resources for Medical/Health Practitioners

Physicians for Safe Technology
Digital and wireless devices have provided many benefits, however, we are now realizing that the rapid adoption of this novel technology has not been accompanied by adequate regulation, monitoring or safety precautions.

Widespread use of digital media and near constant exposure to wireless devices has caused increasing concern among scientists, health care professionals, psychologists, educators and the public who are now considering this is not only a public health issue but a looming public health crisis. (11,108) It appears that we are at the same point of emerging science similar to early recognition of health impacts associated with tobacco, asbestos, coal dust and lead. (119) These concerns are amplified by industry proposals for a massive expansion of wireless infrastructure and connectivity.
Read More

The Collaborative on Health and the Environment Working Group on Electromagnetic Fields

The Collaborative has a Working Group on Electromagnetic Fields (EMF) of more than 250 health professionals, scientists, and concerned individuals. This group has a listserve for the purpose of sharing new research and policy ideas and discussion and you can sign up to receive updates. Additionally the CHE-EMF Working Group hosts teleconferences featuring leading researchers speaking to topics related to EMF science and health impacts. You can listen to their recorded conferences in electromagnetic radiation. We highly recommend that you join the EMF listserve to stay updated on the science.

Appeal to Halt 5G by Doctors for the Environment
Telecommunications companies worldwide, with the support of governments, are poised within the next two years to roll out the fifth-generation wireless network (5G). This is set to deliver what is acknowledged to be unprecedented societal change on a global scale. We will have “smart” homes, “smart” businesses, “smart” highways, “smart” cities and self-driving cars. Virtually everything we own and buy, from refrigerators and washing machines to milk cartons, hairbrushes and infants’ diapers, will contain antennas and microchips and will be connected wirelessly to the Internet. Every person on Earth will have instant access to super-high-speed, low- latency wireless communications from any point on the planet, even in rainforests, mid-ocean and the Antarctic.

What is not widely acknowledged is that this will also result in unprecedented environmental change on a global scale. The planned density of radio frequency transmitters is impossible to envisage. In addition to millions of new 5G base stations on Earth and 20,000 new satellites in space, 200 billion transmitting objects, according to estimates, will be part of the Internet of Things by 2020, and one trillion objects a few years later. Commercial 5G at lower frequencies and slower speeds was deployed in Qatar, Finland and Estonia in mid-2018. The rollout of 5G at extremely high (millimetre wave) frequencies is planned to begin at the end of 2018.

Despite widespread denial, the evidence that radio frequency (RF) radiation is harmful to life is already overwhelming. The accumulated clinical evidence of sick and injured human beings, experimental evidence of damage to DNA, cells and organ systems in a wide variety of plants and animals, and epidemiological evidence that the major diseases of modern civilization—cancer, heart disease and diabetes—are in large part caused by electromagnetic pollution, forms a literature base of well over 10,000 peer-reviewed studies.
Read More

Doctors for the Environment
The main purpose of ISDE is to help defend our environment both locally and globally to prevent numerous illnesses, ensure the necessary conditions for health, and improve the quality of life. In order to safeguard the health of our own generation and of future ones, we must care for the environment.
ISDE was established as a tool for educating and updating physicians and the general public, and stimulating awareness and initiatives by public and private bodies, in particular governmental agencies.
The Association intends to reach out to all, as fellow citizens of the world.
Learn more


Dr Mercola on 5G

Dr. Joseph Mercola’s latest book — ‘EMF*D’ — introduces the reader to the concept that electronic and wireless technology emits frequencies in the form of dirty electricity and microwave radiation that can harm your health.

This book comes at an interesting time when governments around the world are racing to roll out 5G wireless technology, without any testing of the biological and health effects of long-term exposure … It is no longer enough for us to eat organic, drink purified water, inhale fresh air, exercise, and get plenty of sleep to stay healthy. We must also minimize our exposure to the harmful effects of electromagnetic pollution. Learn how to reduce your exposure and how to repair EMF-related damage by reading Dr. Mercola’s book, ‘EMF*D’. You won’t be disappointed!”
∼ Dr. Magda Havas, Ph.D., physicist at Trent University, Peterborough, Can

Taken from EHTrust website:

Physicians’ Health Initiative for Radiation and Environment

Founded by Dr. Erica Mallery-Blythe, Physicians’ Health Initiative for Radiation and Environment (PHIRE) is an independent association of medical doctors and associated specialists assembled for the purposes of improving education regarding health effects of non-ionising radiation. We collate research produced globally on this issue, share and critique it and also conduct our own research.

We use the resulting knowledge to help educate ourselves and others, improve best practice guidance, and facilitate protection and support of vulnerable groups.

The Oceania Radiofrequency Science Advisory Association
The Oceania Radiofrequency Science Advisory Association (ORSAA) Database is a searchable database on peer-reviewed scientific studies and articles on bioeffect research of electromagnetic fields. The database is designed to enable detailed independent searches invaluable to researchers and scientists. It requires some training on how to use it most effectively.

Electromagnetic Radiation Safety
Dr.  Joel Moskowitz Director and Principal Investigator, Center for Family and Community Health at the University of California Berkeley School of Public Health maintains the excellent blog on current news and research on electromagnetic fields.

Lennart Hardell’s Blog
Dr.  Hardell is the internationally respected scientist on cell phone radiation and cancer.  He worked on Agent Orange in the 80s calling it out to be a cancer risk.  He and Michael Carlberg have worked on the issue of wireless exposure and cancer risk for the last decade extensively publishing in the field.

Dariusz Leszczynski’s scientific blog: Between a Rock and A Hard Place
Dariusz Leszczynski PhD was an invited expert to the WHO IARC’s EMF working group in 2011. His research group studied regulation of cellular stress response and used high-throughput screening methods of transcriptomics and proteomics to identify genes and proteins affected by mobile phone radiation. His blog contains links to his lectures and powerpoint presentations.

Bioinitiative 2012
An extensive report authored by international scientists published in the field of EMF’s calling for the reform of outdated safety standards due to the mounting evidence of health effects from electromagnetic fields (1479 pages of scientific evidence). Note:

  • Research Abstracts: These are invaluable sets of abstracts (data-based to be searchable) covering the RFR scientific literature, as well as collections of scientific abstracts on free radical damage (from both RFR and ELF) and a set specific to electrosensitivity.  They cover the research published between 1990-2014.
  • Color Charts at Exposure Levels: These invaluable charts detail the published science showing biological effects at different exposure levels. We highly recommend that you take the time to review them.

Microwave News
Microwave News is the go-to news source since January 1981 reporting on non-ionizing Radiation that covers the entire non-ionizing electromagnetic spectrum, with emphasis on mobile phones and power lines, as well as radar and broadcast towers. In addition, they cover medical applications of different types of fields and radiation, as well as the ability of various species to navigate using the Earth’s magnetic field. Their EMF-EMR Web Directory lists hundreds of Web sites. Highly recommended for researchers and scientists.

For over 20 years Powerwatch has researched and presented the science to the public. This informative website maintains a library of research articles and regularly reviews new research studies on electromagnetic fields.

BabySafe Project
More than one hundred physicians, scientists and public health professionals from around the world have joined together to express their concern about the risk that wireless radiation poses to pregnancy and to urge pregnant women to limit their exposures.  Watch the press confeerence, read their joint statement, watch their video and download health resources for pregnant women.

Grassroots Environmental
An excellent resource on wireless radiation, fracking, artificial turf and chemical exposures.  “The mission of Grassroots Environmental Education is to inform the public about the health risks of common environmental exposures and to empower individuals to act as catalysts for change in their own communities. We strive to accomplish this using science-driven arguments for clean air, clean water and a safe food supply, and for stricter regulation of chemical toxins. We believe that positive and lasting change is best accomplished through grassroots initiatives.”

Environment and Human Health
EHH is made up of doctors, public health professionals and policy experts committed to the reduction of environmental health risks to individuals. They prepared the Cell Phone Report that summarizes the science on cell phones. You can download the report off the website link at their site and read their other reports on environmental health issues.

EMF Portal
This extensive literature database from Aachen University summarizes systematically scientific research data on the effects of electromagnetic fields (EMF) and has an inventory of 22,305 publications and 5,456 summaries of individual scientific studies. The EMF-Portal is a project of the femu working group of the Institute and Out-patient Clinic of Occupational Medicine of the University Hospital RWTH Aachen. All information is made available in both English and German.
A research, education and advocacy organization working nationally and internationally to present the risks of electromagnetic fields from wireless technologies clearly and to empower citizens, governments, health professionals and media to become constructively engaged in creating safer lifestyles, communities and natural environments.

Manhattan Neighbors for Safer Telecommunications
“Our mission is to bring awareness to the harmful physical and mental health effects of cell phones, Wi-Fi, wireless computer equipment, portable phones, excessive screen time, too early technology use, wireless utility equipment and neighborhood cell towers and antennas.”


Please check out these two Facebook groups focused on wireless health issues: Campaign for Radiation Free SchoolsCampaign for Safer Phones
Also our South African page: Safe Technology4SA

Website of Magda Havas
Magda Havas is Associate Professor of Environmental & Resource Studies at Trent University where she teaches and does research on the biological effects of environmental contaminants. Her website provides a wealth of information on electromagnetic fields.

Canadians 4 Safe Technology
Canadians for Safe Technology is headed up by the former Canadian Microsoft President Frank Clegg. Canadians 4 Safe Technology is a not-for-profit, volunteer-based coalition of parents, citizens and experts whose mission is to educate and inform Canadians and their policy makers about the dangers of the exposures to unsafe levels of radiation from technology and to work with all levels of government to create healthier communities for children and families from coast to coast.

Citizens for Safe Technology
Citizens for Safe Technology Society is a not-for-profit educational society made up of Canadian and U.S. parents, grandparents, teachers, business professionals, physicians, scientists, politicians and lawyers.

California Brain Tumor Association
The California Brain Tumor Association educates individuals and communities about environmental health risks related to brain tumors and develops and promotes constructive policy changes that rely on our research and input from relevant experts.

Radiation Research Trust
The EM Radiation Research Trust is an independent body. The aim of the organisation is to provide the facts about electro-magnetic radiation and our health to the public and the media.

Antenna Search
Ever wonder how many cell towers are nearby? Just type in any US address and get the towers and antennas within a 4 mile radius.

Open Signal
This website looks up the strength of the wireless signal for any address in the US.

The International EMF Alliance
IEMFA is the International Electromagnetic Fields Alliance, supported by an independent and growing global body of empirically-based scientific experts on living processes, with a multilevel, multidisciplinary health focus.

EMFacts Consultancy
EMFacts Consultancy, founded in 1994 by Don Maisch, has produced a wide range of reports and papers dealing with various health issues related to human exposure to Electromagnetic Radiation. This website was established in 1997 as an independent source of information on the possible health and safety issues arising from human exposure to Electromagnetic Energy (EME).

EMR Australia
EMR Australia is dedicated to creating EMR-safe living and working environments. We offer a unique blend of technical expertise, knowledge about the effects of electromagnetic radiation and concern for people’s welfare.

Manhattan Neighbors for Safer Telecommunications wants New York City to be a global leader on wireless safety. Our mission is to bring awareness to the harmful physical and mental health effects of cell phones, Wi-Fi, wireless computer equipment, portable phones, excessive screen time, too early technology use, wireless utility equipment and neighborhood cell towers and antennas.
The International EMF Scientist Appeal serves as a credible and influential voice from EMF (electromagnetic field) scientists who are urgently calling upon the United Nations and its sub-organizations, the WHO and UNEP, and all U.N. Member States, for greater health protection on EMF exposure.

5G EMF Dangers Arthur Firstenberg

South African resources

Safe Technology4SA website