Criticism of the philosophy for development of standards for non-ionizing radiation

The new recommendations of WHO and EC for legislation in Europe and other countries concerning non-ionizing radiation (NIR) health and safety include exposure limits that are very debatable. ICNIRP Guidelines propose exposure limits for electromagnetic fields in the frequency range up to 300 GHz based on short-term exposures and on thermal effects. The new EC proposal for optical and laser safety legislation includes classification of sources of radiation—both lasers and other optical sources, but not requirements for the methodology of classification. On the other hand, many new requirements have been set by the WHO publication “Model Legislation for EMF Protection” concerning the responsibilities in the field of EMF health and safety. Many specialists in the field of developing exposure limits have positions very far away from the proposed of the ICNIRP Guidelines philosophy. The results are different approaches in developing standards and exposure limits, and differences more than 100 times in maximal permissible levels. We, the Bulgarian Program Committee on NIR, try to organize working groups and discuss different philosophy for developing exposure limits for more than 10 years. This paper exposes our position in this area.