Respondent Code Comment # Document Line # Comment Type Submitted Text ICNIRP Response
1 1 Main 39-40 Technical EMC related to the electrical equipment has been mentioned but not for implanted metal (induction heating). Please clarify this is the scope of ICNIRP guidelines. Proposed change: Please add the sentence if this is within the scope of the ICNIRP guidelines. This is now specified.
1 2 Main 396-424 Editorial a) The limit of SA  (specific absorption) was considered as a footnote of the table in the ICNIRP 1998. No new finding has been mentioned after 1998; at least not cited as a rationale. This section may be more suitable to move the note of ICNIRP as a new basic restricion.  a) This section may be more suitable to move the note of ICNIRP rather the new basic restricion.
b) Please add explanation so that the product safety community can adopt the metric easily.
Although more science would certainly be useful, there is sufficient understanding to warrant the addition of this basic restriction. Further explanation has been provided in guidelines and Apendix A. Compliance issues are beyond the scope of the guidelines document.
1 3 Main 386-390 Technical The averaging area was changed from 4 cm^2 to 1 cm^2 abruptly at 30 GHz. In the ICNIRP 1998, the notation of the beam was listed in the note of the corresponding table (in addition to 20 cm^2 averaging area, additional limit for 1 cm^2 beam was given). Please clarify the rational for this abruput change or redefine so as to keep the continuity at 30 GHz. This is clarified in Apendix A. Greater continuity is now provided at 30 GHz.
1 4 Appendix A 156 Editorial
Physical quantities and symbols are listed in Table 1. It is not clear whether those quantities are scalar or vector quantities.  Usually bold font indicates vector quantity. Those vector quantities are often used for the magnitude of the vector quantities in the text.  In contrast magnitude of vector is correctly described in Appendix A. Revise the symbols in the guidelines in accordance with Appendix A
The font used for vector/scalar values has now been clarified, and used consistently through the documents.
1 5 Main 156 Editorial The symbol for transmitted energy density Htr is confusing. The symbol H is used for the fundamental quantity of magnetic field strength in this guideline and others. Use a differnt symbol for transmitted energy density other than H.  This has now been changed to 'U' (and 'transmitted' changed to 'absorbed').
1 6 Main 32 Editorial It is mentioned that the guideline is not applicable to volunteer research participants. However, it would be very helpful if the guideline provides relevant information for criteria in ethical review for volunteer studies. Tabulate the operational threshold for convenience in the decision of cases that are outside the scope of the guideline. Volunteer studies should not be restricted by this guideline. Operational threshold will provide useful information for ethical review. Biological effects associated with exposure at the occupationalupational basic restrictions is now provided. This provides an upper level of exposure that would normally be used within human research environments, which should be useful for ethics boards.
1 7 Main all General Operational threshold is a new concept that forms the rationale of restrictions  in these guidelines. The evaluation of operational threshold values are fundamental for this guideline. More stress should be put on the operational thresholds  in the guidelines. A list of operational thresholds should be tabulated in parallel with basic restrictions and reference levels.        A list of dosimetric exposure quantites corresponding to the operational threshold is also necessary.           The exposure guidelines are set based on the harm.  Harm caused by electroiomagnetic field exposures is not clear, however. Even though the harm is unclear, the EMF exposures are restricted. This situation makes people fear from EMF more than reality. It should be helpful to be clarified  what harm is to be protected by the guidelines.   We believe that there is currently sufficient clarification of the operational adverse health effect thresholds. The justification for using these is provided in the guidelines, and we believe that this approach is appropriate as a conservative measure.
1 8 Main 395 General A transmitted power density of 200 W/m2 is determined as the exposure value corresponding to the operational threshold >6GHz. At a glance the value itself does not seem relevant as the threshold of warmth sensation is about this value. Sensation is not an adverse health effect according to the treatment of microwave hearing. So the value is apparently too conservative. However, it is understood that harm could occur at this threshold value in consideration of focused exposures. This level is not based on sensation, but on an exposure level corresponding to an operational adverse health effect threshold (which we acknowledge is conservative). This is described in the guidelines.
1 9 Appendix A Table 3.1 and Ref Technical The dielectric properties listed in Table 3.1 are referred from not only the reference (Sasaki et al., 2017) but also another reference as follows;
Sasaki K, Wake K and Watanabe S 2014a Measurement of the dielectric properties of the epidermis and dermis at frequencies from 0.5 GHz to 110 GHz Phys. Med. Biol. 59 4739–47.
This has been amended as suggested.
2 1 Main All General ​Recommend including a definitions section. 

​Highly recommend use of restricted environment and unrestricted environment versus public and occupational which are non-operational and not conducive to clarifying definition. While terms are Gly defined when introduced it would be beneficial if a definitions section was included for immediate reference while reading following sections to avoid having to search for the initial definition
The main terms have been defined more clearly, but we decided that a separate section was not necessary.   Terminology regarding occupationalupational exposure has been considered, but we decided to retain the terminology given that this terminology is what is commonly used.
2 2 Main 84 General Healthy is not defined.  Delete word “healthy. Are electromagnetic engineers prohibited who have diabetes, atrical flutter, visual impairments etc? In this context thermoregulatory capability would have to be assessed and a criteria set. Please refer to the WHO definition and the instantiation of the definition in Apendix B for clarification of what is meant by 'healthy'. In this example, we have removed the term and provided some of the key functions that are important in occupationalupational exposure situations.
2 3 Main 85 General Controlled conditions should be defined.  Controlled conditions: Environments where access is restricted by a safety program consisting of an organized system of policies, procedures, practices and plans designed to help ensure compliance with exposure limits associated with electric, magnetic, and electromagnetic fields, contact voltage, and contact and induced currents. Individuals exposed under controlled conditions associated with their occupational duties, shall be trained to be aware of potential radiofrequency EMF risks and to employ appropriate harm-mitigation measures, and who have the capacity for such awareness and harm-mitigation response; it is not sufficient for a person to merely be a worker.   IEEE C95.1 and IEEE C95.1TM-2345 define the occupational limits as „“restricted environment: An environment in which exposure can result in exceeding the unrestricted environment (lower tier)“ Exceeding the unrestricted environment  safety program initiation level requires implementation of a safety program.  Safety program:  An organized system of policies, procedures, practices and plans designed to help ensure compliance with exposure limits associated with electric, magnetic, and electromagnetic fields, contact voltage, and contact and induced currents.  NOTE—A safety program typically includes awareness training, implementation of protective measures such as signage and the use of personal protective equipment (PPE), incident response, periodic evaluation of program effectiveness, and assigned responsibilities for implementing the program similar to the elements described in IEEE Std C95.7.  This has now been clarified further, incorporating some but not other of these suggestions. 
2 4 Main 84 General The use of the term “Occupational“ is undefined and confusing. Individuals permitted access to the restricted/controlled environment have been trained on the safety program requirements to be aware of potential radiofrequency EMF risks and to employ appropriate harm-mitigation.
Access to the controlled environment should not be limited to EMF occupational individuals.  Anyone who meets the safety program guidelines should be allowed access, for example transient passage through controlled spaces.
Terminology regarding occupationalupational exposure has been considered, but we decided to retain the terminology given that this is commonly used.
2 5 Main 88 General ​The statement that it is not sufficient for a person to merely be a worker means only EMF trained workers will be allowed access.
Delete “it is not sufficient for a person to merely be a worker“. The statement that “it is not sufficient for a person to merely be a worker“ means only EMF trained workers will be allowed access.  The key point should be not occupation but rather individual’s safety program status. Anyone who has been trained on the safety program applicable to the environment and systems should be allowed access regardless of occupational status.  Necessary for passage through environment. Further an individual trained on safety program procedures should be able to have access for many ;erasons including work not related to electrical engineering.
The ICNIRP definition requires that a person is not only trained, but also a worker, and so we have not changed this.
2 6 Main 93-94 General It is important to state that the safety programs prevent greater risk, however, the use of occupational is problematic and limiting.
Individuals allowed access to restricted environments are not deemed to be at greater risk than the G public in unrestricted environments, providing that appropriate screening and training is provided to account for all known risks.
Setting dicotomy of public and occupational is too broad and is insufficiently defined.
As noted by this person, the guidelines state that there is no increase in risk associated with occupationalupational exposure. Other comments noted.
2 7 Main 103-105 Not Given Stating it is unnecessary to take additional precautionary measures is important and welcome and supported. No change requested.
2 8 Main Table 1 General ​Radiant exposure in Joules per square meter is not clear  Htr is not known.
​Transmitted energy density (also termed incident energy density J/m2 ).
Radiant is inappropriate term
This has been amended as suggested.
2 9 Main 189 Technical Low-level effects refer to very low, possibly unmeasurable, thermal events. Non-thermal is incorrect as any energy deposition will result in molecular activation and thermal events even if micro. Delete non-thermal. It is anachronistic.
For the purpose of determining thresholds, evidence of adverse health effects arising from all exposures is considered, including those referred to as ‘low-level’ and including those where mechanisms have not yet been elucidated.
The literature review conducted for IEEE Std C95.1-2005 includes studies conducted under many different exposure conditions, some using levels of RF energy too low to produce significant heating in animal or in vitro test systems (herein referred to as “low-level” exposures rather than “non-thermal” exposures),
This now refers to what people 'refer to as' non-thermal. This avoids inaccuracies, but provides important information to the reader.
2 10 Main 213-215 Editorial Run on repetitious (too many protects)
Restrictions designed to protect against smaller temperature elevations will also be protective in vivo.
Editorial. No change in meaning. Note that the use of italics is not universally accepted.  “Increasingly, the trend is to dispense with italics. Most publishers and style guides instruct authors not to use italics for such phrases. Both Springer and Elsevier, for example, insist on setting "in vitro," "in vivo," and "in situ" in normal, or Roman, font, and so does the Chicago Manual of Style and Scientific Style and Format. The Oxford Dictionary for Scientific Writers and Editors insists that in vivo and in vitro should be set in italics.“ Editage Insights.
This comment has been considered in the rewriting of the guidelines.
2 11 Main 226-228 General ​Why is ICNIRP basing EMF RF exposure limits on lower non-EMF RF thermal limits that impair health?
Delete “Where there is good reason to expect health impairment at temperatures lower than those shown to impair health via radiofrequency EMF exposure, ICNIRP uses those lower temperatures to base limits on“. Additionally, do not use non-EMF data when there is no EMF effect.
This guideline is supposed to be EMF RF thermally based. Including other mechanisms for elevation of temperature such as fever or pharmaceutically induced temperature rise or any non-EMF agent iis inappropriate. This conflicts with lines 267-271“It is important to note that even though body core temperature increases at the operational adverse health effect threshold (+ 1°C) can result in significant physiological changes, this can be part of the body’s normal thermoregulatory response and within the normal physiological range, and thus does not in itself represent an adverse health effect.“ Also lines 431-436  “The present guidelines restrict radiofrequency EMF to levels that do not cause any known health effect, using relationships between exposure and tissue heating, as well as exposure and health more  Gly, to do so. Although the guidelines protect against significant temperature rise due to  EMF power deposition within tissue, they do not limit other sources of heat (i.e. that are not due to radiofrequency EMF)“
We do not believe that this approach is problematic. We have now tried to make the logic clearer so as to avoid any misunderstanding.
2 12 Main 286 Editorial Be consistent throughout document.  Heat and thermal are used interchangably.
Easier for the thermal energy to transfer
 
This has been amended accordingly.
2 13 Main 594 and 607 Editorial Use 6 minutes as in line 594 of Table 2 not <360 seconds as in line 607 Table 3. Consistency.  See also Table 6 5 This has been amended as suggested.
2 14 Main 622 General How do you average over an undefined unit “less than 6 minutes“? This has been amended as suggested.
2 15 Main 743, Table 7 Editorial IL2  is not defined and should not be squared. One is conjecture that the sub L refers to limb. If so it should be defined as such and included in Table 1.
Use I for current not IL and in Note 1. Use I not  IL2.
This has been amended as suggested.
2 16 Main Table 7 Technical Values for grasp versus touch should be included. The values in Table 7 are induced current values not contact current values
Refer to frequency dependent Table 14 IEEE C95.1  note this standard has passed all levels of voting and further changes will not occur.
IEEE Table 14 - see Sheet IEEE Table 14

Additional tests of human perception of RF current suggest that thresholds rise with stimulation frequency from 3 MHz to 20 MHz. Rogers, S. J. 1981 The report by Rogers lacks peer-review to qualify as a definitive reference. Responses to contact current have been reported in the peer-reviewed literature at frequencies up to 3 MHz (reviewed in Kavet et al. [2014]. Further research is needed to clarify this subject.  

​Reductions in allowed contact current in ICNIRP 1998 and 2013/35/EU from 100 mA to 40 mA were determined to introduce major impacts on safe operations in the military setting during HF transmissions which were essential. 40 mA requirement would have forced entire deck of ships to be cleared of personeel presenting a new more significant hazard. The operational experiences showed no health or safety impacts had been reported over decades of operations. Obtained derogations from Directive 2013/35/EU. NATO and DoD adopted C95.1-2345TM2014.
1. We believe that the distinction between grasp and touch threshold values is not appropriate given the limited data underpinning these values. These have not been provided. 2. The reference to Rogers has been removed. 3. The justification for the values cited has been provided in the text. Operational issues should now be easier given that reference level restrictions have now been removed for contact currents.
2 17 Main 759 Technical Contact currents are not a field per se.  The RF field induces a current in a metalic object usually an elongated structure which can transfer the current to a person with contact.
EMF RF exposure due to contact currents is indirect. The field induces a charge in a conducting object, typically an elongated metalic structure. Contact with the charged object conducts the current to the person.
There is no field in the object.
This has been amended as suggested.
2 18 Main 768 General The position of not providing limits for contact currents is not prudent.  While the literature is sparse, there are reports that support estabishing environmental safety guidance particularly for individuals who have the greatest opportunity to have contact with charged structures.
Refer to Rogers report. There is sufficient data to be analyzed to develop interim guidance
The text describes the reasons why only basic restrictions and Guidance (but not refernce levels) are provided to protect against contact currents.
2 19 Main 56-61 General Operational level needs to be better defined. Also while “substantiated effect” (line 52) is considered important evidence used for exposure restrictions (line 50-51) operational thresholds and levels are used extensively.

Where no such threshold could be explicitly obtained from the radiofrequency health literature, or where evidence that is  independent from the radiofrequency health literature has (indirectly) shown that harm can occur at levels lower than the ‘EMF-derived threshold’, ICNIRP set an ‘operational threshold’. 

​ These are based on more-G knowledge of the relation between the primary effect of exposure (e.g. heating) and health effect (e.g. pain), to provide an operational level with which to derive restriction values in order to attain an appropriate level of protection
This has now been clarified further.
2 20 Main Not Given General The continuing practice to set an “occupational“ exposure level (reduction factor of 10) and then arbitrarily place another factor of 5 resulting in a reduction factor of 50 for the “public“ seems backwards and unscientific.  If the “public“ value was first established for all individuals (everyone) and then, for the reasons given, the “occupational“ was set as a relaxed value because the safety program requirements are met it would be more rational.
A reduction factor of 50 provides for mitigation of risks for the public who have not been trained on applicable safety programs. Prior to gaining access to restricted/occupational/controlled environments safety program training must be completed. Safety program implimentation   Occupationally-exposed individuals are not deemed to be at greater risk than the G public, providing that appropriate screening and training is provided to account for all known risks. They must be trained to be aware of potential radiofrequency EMF risks and to employ appropriate harm-mitigation measures, and who have the capacity for such awareness and harm-mitigation response.
Workers frequently question why the exposure levels they are allowed are not as protective as the public. Additionally, the arbitrariness of the the additional factor or 5 is questioned. Note all workers become public for an average 16 hours a day. Setting a firm exposure limit for all with justifable rationale for relaxing the limit for workers is appropriate and explanatory.
1. This perspective has been considered, but we have kept the original method. 2/ The text now clarifies that occupationalupational exposure does not result in greater risk than that for the general public.
3 1 Appendix A 622-625 General In my investigations (presented at BioEM 2018, Piran-Portoroz, Slovenia; see reference [1]) with an anatomically more realistic skin modeling for children, -segmented as a thinner layer compared to those of adults, I found for the 5 year old girl "Roberta" an maximum exceeding of 48.3% of the whole-body SAR (gen.pub.). For the standard-segmentation type of the skin derived from values for adults (-as done for the whole Virtual Population v1.0) the maximum exceeding found for "Roberta" was 36.7% (gen.pub.). Therefore a adapted thinner skin layer for children pushes up the whole-body SAR by additionally +11.6%, compared to (a typical) skin layer thickness with values taken from adults.
/supplement in line 625: after "...whole body average SAR.": The effect of an enhanced (and anatomically more realistic ) thinner skin layer for children (compared to the previous taken from adults) in the segmentation process was investigated by Überbacher et al. (2018) [1]. For the 5 year old girl "Roberta" the author reported for a thinner modeled skin an exceeding of the gen.pub. limits of 48.3%, instead of 36.7% for the former standard-thickness derived from adults (that was applied to the entire Virtual Population v1.0). This finding with an additional impact of +11.6% leads to the conclusion, that former presented SAR values for children (e.g. Bakker et al.,2010) have to be revised, and in a first step an additional uncertainty (in direction to higher whole-body SAR values) due to the restricted segmentation accuracy of the skin is recommended. [1] Überbacher R, Cecil S. Influence of Anatomical Skin Thickness of Children on the Whole-Body SAR for Future 5G-Frequencies. BioEM-2018, Piran-Portoroz, Slovenia, (June 25 - 29), Abstract Book pp. 406-409, 2018.
Difference in the anatomical accuracy of segmentation of the skin; impact on the whole-body SAR.
1. This has been taken into account. 2. The issue of WBA SARs for small children has been considered and described in detail in the revised guidelines. 3/ The skin thickness depends on the body parts as reported extensively. For human body models with constant skin thickness, the power absorption may be maximal at a specific frequency. However, this will not happen in the real world (as skin thickness is variable). As stated in Apendix A, the restrictions are not based on such unrealistic conditions.
4 1 Main All General Overall, the draft RF Guidelines rely heavily on a limited field of physics and mostly ignore biology. ICNIRP is still maintaining (incorrectly) that only thermal effects are harmful. This approach supposes that the field of classical  thermodynamics is the only field of science that is relevant to understanding the effects of microwave radiation on humans, animals and plants, and that no other area of science has a valuable persepctive or important evidence to contribute. This approach completely ignores the significant vast body of emperical evidence from well conducted in vivo and in vitro experiements that find significant biological effects with health implications, which occur in the absence of heating.  Approximately 70% of the RF peer reviewed research evaluated and categorsied in the Oceania Radiofrequency Scientific Advisory Association’s (ORSAA) database show statistically significant biological effects, with the clear majority of these bio-effects occuring at non thermal exposure levels (Leach and Weller, 2017; Leach, Weller, and Redmane, 2018). Many of the biological effects are most definitely linked to potential harm and include:
• Oxidative stress
• DNA damage
• Altered voltage-gated ion channels
• Cell damage/disrucption to basic functions (i.e. macromolecular damage, altered gene expression, altered protein confromation
• Blood Brain Barrier (BBB) breaches
• Circadian/ultraradian rhythm disruption
• Increased inflammation
• Neoplasia/cancer/tumours
• Neurodegeneration These effects are detailed in the screenshot of the ORSAA database summary page, generated by using a filter applied to peer
reviewed scientific papers specifically covering microwave frequencies, comprising approximately 2000 papers (see figure in sheet Weller Figures).
Oxidative stress is a significant outcome in close to 90% of papers which have investigated this endpoint (Bandara & Weller, 2017) . It should also be noted that the assays used to verify oxidative stress/free radical production provide direct evidence of oxidative damge to cellular constitutents and include:
•Lipid Peroxidation of fatty acid moieties of cell membranes and other biological tissue components
•DNA Base Damage - oxidative DNA damage plays crucial roles in the pathogenesis of numerous diseases including cancer (Guo, Wang & Yu, et. al, 2016).
• Protein Oxidation
Reactive Oxygen Species have the capacity to damage DNA directly and may explain why a significant number of studies looking at the genotioxic potential of RF exposure find direct evidence of increased DNA damage from RF exposure (Ruediger, 2009).
Weller Figure 1,2.
It is very important when performing a systematic review that one takes into consideration the source of funding for both “effect“ and “no effect“ papers. ORSAA’s data analysis has revealed that for many bio-effect endpoints that “no effect“ outcomes are predominantly associated with funding from industry, government communication regulatory authorities and the military. In
contrast, institutional funded research is predominantly finding statistically significant biological effects as shown below. Our findings further support previously published evidence of funding bias in RF health research (Huss et al 2007).
Weller Figures 3, 4
Altogether, the categorised research from the ORSAA database presented above speaks loudly and clearly. The thermal-effects only paradigm is outdated and unwarranted. In order to pursue the evidence in a scientific manner, ORSAA recommends that ICNIRP conduct a thorough investigation of the scientific evidence, by engaging with truly independent scientists who are neither connected to, nor manitain close relations with, industry, military or government agencies. ICNIRP should also include scientists in its membership who have diverse expertise and view points rather that the current “echo chamber“ as discussed by Professor Dariusz Leszczynski in his presentation https://betweenrockandhardplace.files.wordpress.com/2017/02/leszczynski-reykjavik-lecture-feb-2017.pdf. It is also vitally important to include a large range of diverse expertise in the review process, most importantly and including but not limited to biomedical experts such as toxicologists, biochemists, physiologists, microbiologists,as well as medical experts such as neurologists, endocrinologists,  immunologists,  oncologists,and cardiologists, because RF has the capability to affect all tissue types and organs that make up an organism as well as cellular processes and metabolic pathways. It is only when we have all these
specialist qualifications looking at the research collectively can we begin to improve our understanding. It is concerning that ICNIRP‘s membership does not include any scientists from countries that have scientific, yet more biologically protective RF standards e.g., Russia and China. Some of ICNIRP‘s members have clear relationships with the power industry (EPRI), telecommunications companies (MMF, GSM Association UK, French Telecom, Nokia etc.) and military. Therfore, conflicts of interest cannot be ruled out. Confirmation bias is obvious, particularly in reference to sensitive individuals who are suggested to be suffering nocebo effects based on flawed and poorly conducted provocation studies (for further detail refer to response to Appendix B).
Another cause for concern is that the draft guidelines appear to neglect the possible consequences to the wider environment, with no regard for effects on insects, birds or plants. Wildlife are not trained in radiation protection nor do they recongnize unsafe zones
that may be fenced off to keep humans out because radiation levels may exceed limits e.g.areas directly in front of a cell tower transmitter.
ORSAA submits that ICNIRP, in order to fulfill its international obligations to humanity and the greater environment, needs to address the limitations and concerns raised above.
References
Bandara P, & Weller S. (2017). Biological Effects of Low-intensity Radiofrequency Electromagnetic Radiation – Time for a Paradigm Shift in Regulation of Public Exposure.
Guo, C., Li, X., Wang, R., Yu, J., Ye, M., Mao, L., ... & Zheng, S. (2016). Association between oxidative DNA damage and risk of colorectal cancer: sensitive determination of urinary 8-hydroxy-2′-deoxyguanosine by UPLC-MS/MS analysis. Scientific reports, 6, 32581 https://www.nature.com/articles/srep32581
Leach, V. & Weller, S. (2017). Radio Frequency Exposure Risk Assessment and Communication: Critique of ARPANSA TR-164 Report. Do we have a problem?
Leach, V.Weller,S. & Redmayne, M. (2018). A novel database of bio-effects from non-ionizing radiation
Ruediger, H. W. (2009). Genotoxic effects of radiofrequency electromagnetic fields. Pathophysiology, 16(2), 89-102.
1. That the guidelines consider and protect against 'all' effects, and not only thermally mediated effects, has been clarified in the revised document. 2. The comment does not provide evidence that there are adverse health effects that are not protected against by the guidelines.
4 2 Main 18 General Please clarify what ICNIRP defines as “best science currently available“ Reference is made to some of the features that constitute good science in the document. A more precise definition is not within the scope of the guidelines.
4 3 Main 24 General ICNIRP claims the draft guidelines aim to provide protection for all people. If this is the case, we need to make clear what consideration ICNIRP has given to the elderly, pregnant women, children and the infirm, and to those who may be deemed to be more sensitive than the average population. Such sub-groups do exist, as is evidenced when looking at pain sensitivity, pollution
sensitivity, chemical sensitivity and even photo (light) sensitivity.
ICNIRP needs to be clear on how it is protecting vulnerable people as well as more sensitive sub-groups. Disappointingly it appears that ICNIRP is of the belief that its draft guidelines will protect all people. This is a position that appears to have changed from its previous stance outlined in the ICNIRP 2002 philosophy statement where it adivsed under “People being protected” (p 545) “Different groups in a population may have differences in their ability to tolerate a particular NIR exposure. For example, children, the elderly, and some chronically ill people might have a lower tolerance for one or more forms of NIR exposure than the rest of the
population. Under such circumstances, it may be useful or necessary to develop separate guideline levels for different groups within the G population…”
“Some guidelines may still not provide adequate protection for certain sensitive individuals nor for normal individuals exposed concomitantly to other agents, which may exacerbate the effect of the NIR exposure, an example being individuals with photosensitivity. Where such situations have been identified, appropriate specific advice should be developed….”
“ICNIRP distinguishes occupational and public exposures in G terms. When applying the guidelines to specific situations, it is ICNIRP’s opinion that the relevant authorities in each country should decide on whether occupational or G public guideline
levels are to be applied.…”
“Environmental conditions may also influence the effect of whole-body exposure to optical or RF radiation. Seriously ill patients might be considered as more vulnerable when exposed to NIR, but ICNIRP guidelines do not consider these potential vulnerabilities….”
The World Health Organisation also has the following statement on RF Guidelines. “What guidelines cannot account for...” “…Guidelines are set for the average population and cannot directly address the requirements of a minority of potentially more sensitive people…” Source: http://www.who.int/peh-emf/about/WhatisEMF/en/index4.html
1. Further detail has been provided in Apendix B regarding IEI-EMF individuals. We have clarified that all subgroups are protected against, but a full review of this issue is beyond the scope of the guidelines documents. 2. No evidence is provided to show that there is evidence of such sensitivities.
4 4 Main 45-48 General ICNIRP claims to have identified published research papers, evaluated them, presumably identified biological effects that result from RF exposure and then established whether these effects are harmful. A number of questions arise from these claims:
1. Where is the list of papers that were evaluated?
2. What were the biological effects that were identified and which biological effects were noted but deemed to be harmless?
3. Who performed the evaluation to determine whether an effect is harmful and what are their qualifications?
4. On what basis was an effect deemed to be harmful or not?
5. What is ICNIRPs definition of “sufficient scientific quality”?
6. What proportion of the studies evaluated could be considered chronic long-term exposures and how many were short-term or single acute exposures?
Insert your proposed change.
Today, the majority of RF research is not useful for determining long term health implications because:
1) studies have not been specifically designed to look for health outcomes; and
2) while we have an excellent body of experimental studies (in vivo/in vitro), there is a clear lack of controlled clinical studies investigating the role of RF-EMR exposure in human diseases. There should be more in vivo studies invovling more long-term
exposures as we currently have most studies conducted with short-term exposure, which are not representative of typical exposures experienced in a person’s lifetime. The graph below depicts a breakdown of exposure durations for a set of RF papers contained within the ORSAA database. The sample size was 978 papers (in vivo and in vitro only). Within the sample, 87% of the papers could be classified as short-term exposures and so are unliklely to provide any detailed insight into “substantiated“ health effects. However, biological effects are noted, and their implications for health can be predicted if they are sustained based on their “known“ role in disease pathways. Toxocologists and medical specialists could facilitate this understanding. Figure 5
Please note that the detail that is asked of ICNIRP is beyond the scope of the guidelines documents, and that this has been stated in Apendix B.
4 5 Main 54 Technical “adverse health effect threshold“ - Specific details are missing regarding the bioeffects and the specific levels determining effects.
Appendix B is quite weak and underwhelming as it appears to disregard a large number of bio-effects that would most likely have health implications, and which occur at exposures well below the levels permitted by ICNIRP draft Guidelines.
From a historical perspective, in the 1970’s the US Naval Medical Research Institute (1971) and the US Defence Intelligence Agency, (DIA, 1976) performed literature reviews and identified the following bio-effects, many of which have serious implications for long
term health and wellbeing:
¡ Changes in physiologic function including but not limited to changes in the oxidative processes in tissues and organs, alterations in sensitivity to light, sound, and olfactory stimuli, electrocardiographic (EKG) changes
¡ Central Nervous System effects including headache, insomnia, restlessness etc.
¡ Autonomic Nervous System effects including neuro-vegetative disorders (altered heart rhythm), fatigue, stimulation of parasympathetic nervous system (Bradycardia)
¡ Changes in circadian rhythms – we have knowledge from investigations into the health of shift workers that circadian rhythm disruption has long term health implications. Over time, working night shifts increases your risk of heart disease, diabetes and cancer.
While a number of these effects listed above may not be considered immediately harmful per se, they can definitely be considered as nuisance effects and if sustained can have far reaching health and wellbeing implications. Given the wide-ranging scope of wireless infrastructure deployment into our environment, the quality of life and productivity of large numbers of people worldwide are threatened.
DIA specifically found:
¡ “Animal experiments reported in open literature have demonstrated the use of low level microwave signals to produce death by heart seizure or by neurological pathologies resulting from breaching of the blood-brain barrier.” (page viii)
¡ “Personnel exposed to microwave radiation below thermal levels experience more neurological, cardiovascular, and haemodynamic disturbances than do their unexposed counterparts.” (page 6)
¡ “Subjects (military personnel) exposed to microwave exhibited a variety of neurasthenic disorders against a background of angiodystonia (abnormal changes in the tonicity of the blood vessels). The most common subjective complaints were
headache, fatigue, perspiring, dizziness, menstrual disorders, irritability, agitation, tension, drowsiness, sleeplessness, depression, anxiety, forgetfulness and lack of concentration.” (page 8) Many of these listed effects will impact a person’s
quality of life and so it is important that serious efforts are taken to reduce or avoid their development.
¡ “Another possibility is alteration of the permeability of the blood-brain barrier. This could allow neurotoxins in the blood to cross. As a result, an individual could develop severe neuropathological symptoms, either die, or become seriously impaired
neurologically.” (page 26) When we look at more recent accumulated evidence in the ORSAA database (see Field Search Summary Table in #1 above) we see the same or similar biological effects appearing. The question to ICNIRP is ‘why are these findings being collectively ignored?’ Could ICNRRP’s approach be best explained by US DIA’s statements of why adopting stricter safety guidelines were a problem in the 1970’s:
¡ “If the more advanced nations of the West are strict in the enforcement of stringent exposure standards, there could be unfavourable effects on industrial output and military functions.” (page vii)
¡ “Recognition of the .01mW/cm2 standard (stringent safety regulations) could also limit the application of new electronic technology by making the commercial exploitation of some products unattractive because of increased costs imposed by the need for additional safeguards.” (page 24)
Insert your proposed change.
Explain the context of your comment.
¡ Psychological Disorders including depression, anxiety, sleepiness, insomnia, mood changes, increased fatiguability, chest pain etc.
¡ Blood Disorders including hemolysis, increased blood glucose and could have a role in raising the risk of diabetes, increased cholesterol increasing risks of cardiovascular disease, increased blood histamine content increasing the risk of allergies
¡ Vascular Disorders
¡ Metabolic Disorders – including glycosuria (glucose in urine),
¡ Gastrointestinal disorders
¡ Genetic and chromosomal changes that lead to chromosomal aberrations, mutations, somatic alterations and neoplastic diseases (tumors)
1/ A description has been provided about the thresholds used and why they were used. We believe that these have an appropriate level of detail. 2/ We do not agree that the evaluation has missed evidence of adverse health effects.
4 6 Main 63 Technical Reduction Factors applied by ICNIRP are not scientifically based and appear to be only relevant to heating effects because they do not provide biological protection to a range of bio-effects clearly demonstrated in the scientific literature (e.g. oxidative stress causing different forms of cellular damage including DNA, and membrane damage leading to functional impairment such as neurological and metabolic effects ) that are associated with disease outcomes and are occuring at athermal/non-thermal exposure levels. Oxidative stress plays a major part in the development of chronic and degenerative disease such as cancer, arthritis, autoimmune disorders, cardiovascular and neurodegenerative diseases as well as aging (Halliwell and Gutteridge, 2015); Pham-Huy, He, & Pham-Huy 2008). The aforementioned diseases are a significant problem today in developed nations, is ever increasing and parallels the deployment of wireless technology in our society. Given that oxidative stress features in the clear majority of papers that investigate this endpoint, it would seem ICNIRP is negligent in its lack of acknowledgement of this bio-effect and its implications to health and well being.
References
Halliwell, B., & Gutteridge, J. M. (2015). Free radicals in biology and medicine. Oxford University Press, USA.
Pham-Huy, L. A., He, H., & Pham-Huy, C. (2008). Free radicals, antioxidants in disease and health. International journal of biomedical science: IJBS, 4(2), 89. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3614697/
ORSAA requests that ICNIRP address the issue of oxidative stress induced by low-intesity RF-EMR and explain why it has been omitted as a health concern.
Note that the guidelines protect against adverse health effects, and not biological effects - the reduction factors thus relate to adverse health and not biological effects. Where there is evidence that a biological effect results in harm, then ICNIRP treats it as a health effect and restricts exposure to remove the hazard.
4 7 Main 84 Technical The Draft Guidlines indicate that “Occupationally-exposed individuals are defined as healthy adults....“ There appears to be no consideration for those individuals whose health maybe compromised by varying degrees – a person‘s health status can easily change as a result of infection, stress or many other temporary ailments. Of course there is another concern. It is assumed that the information provided to occupationally exposed individuals about the possible risks are accurate. One can assume that these individuals would be relying on the advice provided by ICNIRP and the RF Guidelines, which are clearly questionable based on the improved awarenss of the science and subsequent concern that have been raised in this document. As such, the risks could be underestimated and precautionary/protective measures taken by occupationally exposed individuals could be severely inadequate for their protection.
Unfortunately, looking for established evidence of harm is not a recognized risk management best practice. Risk Management is not about requiring established evidence of harm. Risk Management is about recognising the potential for harm and if there is evidence for potential harm , taking precautionary measures.
What is quite obvious today is the distinct lack of public awareness of the real risks associated with radiofrequency exposure –wireless devices operating within RF Guidelines are assumed to be completely safe irrespective of how frequent or how long they are used for. It is also critically important to understand that the research being evaluated by ICNIRP and other scientific committees, are in most cases, not designed to answer the question of whether there are possibly multiple downstream health effects arising out of the observed biological effects, including those in the second and subsequent exposed generations. This is because experiments are typically performed with controlled exposures that are:
1. Not representative of typical real-life exposures situations 2. Often performed with simulated signals that lack the signal variation that occurs with real wireless devices 3. Typically short-term acute exposures 4. Rarely investigating synergistic effects with other environmental/manmade toxins 5. In nearly all cases not looking at the possibility of both additive effects (exposure to multiple different frequencies simultaneously) or accumulative effects (damage to cells and organs over a long period of time).
It is also problematic that bio-effects routinely found in well-conducted studies are not being addressed by health bodies for their potential to cause harm.
Recommendation: All ICNIRP members read “Late lessons from early warnings report”
https://www.eea.europa.eu/publications/environmental_issue_report_2001_22
https://www.eea.europa.eu/publications/late-lessons-2
The scientific elites have also been slowly losing public support. This is in part because of the growing number of instances of misplaced certainty about the absence of harm, which has delayed preventive actions to reduce risks to human health, despite
evidence to the contrary. (Late lessons learned from early warnings, European Environmental Agency, 2013).
ORSAA recommends ICNIRP adjust its methodology for evaluating the science to include recognition of potential risks associated with non-thermal bioeffects. Looking for established "evidence of harm“ while ignoring clear evidence of nonthermal biological
effects is counter to best practice, especially considering the number of people being exposed to potential harm 24x7 without informed consent. ICNIRP should follow the recommended precautionary approach adopted by the ICRP which incorporates as low
as reasonably achievable (ALARA). ICNIRP needs to ensure that an ethical foundation is applied to non-ionising radiation protection that includes the following tenants:
¡ Reasonableness and tolerability
¡ Transparency and accountability
¡ Impartiallity and independence
¡ Commitment to public and environmental safety
The mantra – “no established evidence of harm” has been widely used to give the public a false sense of security and is not acceptable, given that the weight of scientific evidence at present clearly indicates health risks. The uniformed public bears the consequences of these undisclosed risks.
The guidelines take into account the variability of health statuses in occupationalupationally exposure individuals - this is described in the narrative. In terms of this instance, we have removed the term 'healthy' and replaced it with examples of factors that are important for ensuring safety for occupationalupational exposure.
4 8 Main 98-105 General A conservative approach is claimed to have been taken yet ICNIRP draft RF Guidelines are several orders of magnitude higher (more permissive) than scientifically based RF standards adopted by other countries in order to prevent at least some non-thermal effects  (Russia, China, Poland etc.). Precautionary aspects that have been included such as reduction factors do not protect against a range of biological effects that are potentially harmful.
Insert your proposed change.
Unfortunately, ICNIRP does not see the need for further precautionary measures yet various tumours (schwannoma, glioma and other neoplasms) have been associated with RF exposure levels that are signfincantly lower than what is permitted by ICNIRP guidelines in both epidemiological and animal studies (Hardell, CERENAT, NTP, Ramazzini).  ICNIRP must seriously take on board the  opinions of independent scientists.
https://ntp.niehs.nih.gov/ntp/about_ntp/trpanel/2018/march/actions20180328_508.pdf
https://www.icnirp.org/cms/upload/publications/ICNIRPnote2018.pdf
The ICNIRP guidelines have been based on science, rather than on other standards. However, where such standards are based on science, that science has been considered in the guidelines.
4 9 Main 161-164 General ICNIRP claims it has primarily used major international reviews of the literature on radiofrequency EMF and health, but has only mentioned two in this paragraph – WHO 2014 and SCENIHR 2015. This  presents a number of significant problems:
The WHO EHC technical document did not move past the the draft phase, and the researchers who performed the RF-EMF literature review as part of Environmental Health Criteria (EHC) were predominantly ICNIRP members. This appears to be a blatant conflict of interest because those who are responsible for setting the RF Guidelines are the same ones trying to assess if those guidelines are adequately protective.
ORSAA notes with interest that the Ethics Board of the Karolinska Insittue, Sweden had in 2008 determined that ICNIRP may have a conflict of interest. When ICNIRP members consult health authorities (such as WHO), regarding health risks of EMR, that Conflict of Interest should be declared (Karolinska Institute diary number: 3753-2008-609, 2008). However, no statement of such conflict of interest appears to have been made by ICNIRP members when working with the WHO.
ORSAA performed a ‘two degrees of separation‘ to review the relationships between the original EHC scientists performing the review, their qualifications, who funded their research and the how their research findings stack up with the ratio of  “effect“ vs “no effects“ seen in the ORSAA database. The results showed that:
• There was no representation from countries that have RF Standards significantly lower than what ICNIRP has adopted for its basic restrictions. This suggests that WHO and/or ICNIRP had employed biased selection criteria when establishing the EHC group.
• EHC expert panel composition appeared to be over represented by "No Effect" scientists particularly in the core group. A small number of token “Effect” researchers were included in the mix. This stacking of “no effect” scientists in the EHC is not representative of what the balance of evidence is showing.
• There was a clear lack of representation from countries that are finding significant amount of effects versus no effects, which is very concerning particularly when the majority have adopted RF standards that are significantly more restrictive (90 – 100 times or lower) than those advised by ICNIRP; e.g., China, Russia, Turkey and Iran.
• A number of experts, including the EHC core group, appear to have conflicts of interest and are members of ICNIRP.
• ICNIRP is an NGO with no public accountability and promotes the least protective exposure guidelines, globally.
• Most members of the group have performed research (predominantly “no effect” studies) sponsored directly by the industries and/or military that generate anthropometric EMF e.g., Electrical Power consortiums (such as EPRI) and Telecommunications companies such as Motorola, Nokia, French Telecom, Telecom Italia Mobile etc. as well as industry groups or associations (GSM Association, Mobile Manufacturers Forum, Cellular Telecommunications & Internet Association) and the US Airforce.
ICNIRP claims it has primarily used major international reviews of the literature on radiofrequency EMF and health, but has only mentioned two in this paragraph – WHO 2014 and SCENIHR 2015. This  presents a number of significant problems:
The WHO EHC technical document did not move past the the draft phase, and the researchers who performed the RF-EMF literature review as part of Environmental Health Criteria (EHC) were predominantly ICNIRP members. This appears to be a blatant conflict of interest because those who are responsible for setting the RF Guidelines are the same ones trying to assess if those guidelines are adequately protective.
ORSAA notes with interest that the Ethics Board of the Karolinska Insittue, Sweden had in 2008 determined that ICNIRP may have a conflict of interest. When ICNIRP members consult health authorities (such as WHO), regarding health risks of EMR, that Conflict of Interest should be declared (Karolinska Institute diary number: 3753-2008-609, 2008). However, no statement of such conflict of interest appears to have been made by ICNIRP members when working with the WHO.
ORSAA performed a ‘two degrees of separation‘ to review the relationships between the original EHC scientists performing the review, their qualifications, who funded their research and the how their research findings stack up with the ratio of  “effect“ vs “no effects“ seen in the ORSAA database. The results showed that:
• There was no representation from countries that have RF Standards significantly lower than what ICNIRP has adopted for its basic restrictions. This suggests that WHO and/or ICNIRP had employed biased selection criteria when establishing the EHC group.
• EHC expert panel composition appeared to be over represented by "No Effect" scientists particularly in the core group. A small number of token “Effect” researchers were included in the mix. This stacking of “no effect” scientists in the EHC is not representative of what the balance of evidence is showing.
• There was a clear lack of representation from countries that are finding significant amount of effects versus no effects, which is very concerning particularly when the majority have adopted RF standards that are significantly more restrictive (90 – 100 times or lower) than those advised by ICNIRP; e.g., China, Russia, Turkey and Iran.
• A number of experts, including the EHC core group, appear to have conflicts of interest and are members of ICNIRP.
• ICNIRP is an NGO with no public accountability and promotes the least protective exposure guidelines, globally.
• Most members of the group have performed research (predominantly “no effect” studies) sponsored directly by the industries and/or military that generate anthropometric EMF e.g., Electrical Power consortiums (such as EPRI) and Telecommunications companies such as Motorola, Nokia, French Telecom, Telecom Italia Mobile etc. as well as industry groups or associations (GSM Association, Mobile Manufacturers Forum, Cellular Telecommunications & Internet Association) and the US Airforce.
• It was abundantly clear that there were gaps in EHC specialist expertise and research experience and so it is questionable whether the reviewers could accurately interpret all potential health effects associated with bio-effects being found in the RF literature.
• Some of the researchers in the EHC group are known to cherry pick their data to support their "no evidence" or "no association" conclusions - particularly in relation to mobile phone usage and brain tumour studies.
• A number of the same "no effect" scientists appear to have been involved in multiple review panels and expert advisory committees over the last 10 years (ICNIRP, AGNIR, SCENIHR, SSI).
• The composition of the EHC tasked with reviewing the literature on RF bio-effects is not representative of the diverse opinions held in the wider scientific community.
The SCENIHR working group has also been criticised for:
• using the wrong methodology for evaluating potential harm,
• having scientists as part of the reveiw panel that appear to have conflicts of interest,
• being biased,
• a lack independence and impartiality.
See https://www.stralskyddsstiftelsen.se/wp-content/uploads/2015/09/Annex_1_SCENIHR_Experts_2015.pdf and https://www.researchgate.net/publication/287791372_Comments_on_SCENIHR_Opinion_on_potential_health_effects_of_exposure_to_electromagnetic_fields_Bioelectromagnetics_36480-484_2015] 

In summary, various working groups such as AGNIR, SCENIHR and ICNIRP appear to be relying on each other‘s inaccurate assessments, ignoring evidence contrary to their position, thereby perpetuating confirmation bias and groupthink. Moreover, such repetition gives a false impression of consensus amongst a large group of international scientists, when in fact, the number of members in these groups is a fraction of the total number of scientists involved in RF-EMR research.
We believe that, even though a draft, the WHO Environmental Health Criteria Public Consultation Document represents the most comprehensive review in this area to date. However, further reviews have now been added to the consideration in Apendix B.
4 10 Main 168-169 Technical ICNIRP’s claim that “EMF can affect the body via three primary biological effects“ is overly simplistic and incomplete. To make such a statement sugests a possible lack of expertise within the ICNIRP team. EMF can impact any organ systems due to interference with basic biological functions at the cellular level such as interference with voltage gated ion channels and signal transduction pathways which in turn can lead to systemic disregulation:
1. Immune system: EMF can cause immune system dysfunction; i.e,  overactive, underactive and auto immune conditions. EMFs can cause calcium flux changes which in turn can result in mast cell degranulation releasing histamine, implicated in allergic reactions. There has been clear evidence of exacerbation of allergic reactions in sensitised people as demonstrated in double-blind provocation studies (Kimata 2002, 2005; see https://www.ncbi.nlm.nih.gov/pubmed/15876318, https://www.ncbi.nlm.nih.gov/pubmed/12795649)
2. Endocrine system: EMF can cause endocrine dysregulation via above mentioned biological effects leading to circadian rhythm disruption etc. Research shows that biochemical actions induced by EMR exposures lead to adverse changes in hormones essential in male and female reproduction:
a. Testosterone level decreases (e.g., Qin, Zhang and Cao et al. 2014)
b. Luteinising hormone (LSH) levels increased (e.g., Ozguner, Koyu and Cesur, et al, 2005)
c. Follicle-stimulating hormone (FSH) level increased (e.g., Sepehrimanesh, Saeb, and Nazifi et al., 2014)
d. Estrogen level changes (e.g., Yüksel, Nazıroğlu and Özkaya, 2016)
e. Progesterone level changes (e.g., Nakamura, Matsuzaki and Hatta et al., 2003)
f. Prolactin levels decreased (e.g., Eskander, Estefan and Abd-Rabou, 2012)
g. Corticosterone level increases (Corticosterone is a main glucocorticoid, involved in regulation of energy, immune reactions, and stress responses) (e.g., Ragy, 2015)
h. Adrenaline and Noradrenaline levels (catecholamine) change and is more dramatic with length of exposure (e.g., Megha, Deshmukh and Ravi et al., 2015)
i. Thyroid hormone levels change (TSH, T3, T4) (e.g., Bergamaschi, Magrini and Ales et al., 2004)
j. Adrenocorticotropic hormone (ACTH) levels decreased (e.g., Eskander, Estefan and Abd-Rabou, 2012)
k. Melatonin level decreases (e.g., Burch, Reif, and Noonan et. al, 2002).
3. Cardiovascular system: EMF causes changes to HRV as well as vascular disturbances  (Bandara, & Weller, 2017).
4. Central nervous system: EEG changes provide direct evidence that EMF affects brain waves. The mechanism is yet to be fully explored and the implications not fully known. Long-term exposure to microwaves leads to impairment of cognitive function due to neurotransmitter disruption (Zhao, 2012). RF-EMF influences monoamine neurotransmitter levels and their key regulating enzymes (Megha, 2015). Many studies looking at learning and spatial memory deficiencies also find neurotransmitter profiles changed (Shtemberg, 2000; Zhao, 2012, Maaroufi, 2014; Qin 2014; Wang 2015 etc.). Neurotransmitters GABA, dopamine, serotonin, norepinephrine (noradrenaline), epinephrine (adrenaline), glutamate, acetylcholine levels are all impacted by RF exposures.
5. Peripheral nervous system: Dysaesthesia associated with C nerve fibre changes (Hocking 2002), whereby neurotransmitter effects also feature.
6. Hepatic system: oxidative stress, lipid peroxidation, structural/morphological changes, AST and ALT activity changes.
7. Renal system: glomerular damage, dilatation of Bowman's capsule, large spaces between tubules, tubular damage, and oxidative stress.
8. Haematological system: increased haemolysis, micronuclei induction, oxidative protein damage, lipid profile and cholesterol level changes, haemoglobin structural changes, decreasing values of RBCs, WBCs, platelets, and haemoglobin.
There are a vast array of biological effects that if widespread can also impact the body (see field search summary table in comment #1 above).

References
Bergamaschi, A., Magrini, A., Ales, G., Coppeta, L., & Somma, G. (2004). Are thyroid dysfunctions related to stress or microwave exposure (900 MHz)?. International journal of immunopathology and pharmacology, 17(2_suppl), 31-36.
Burch, J. B., Reif, J. S., Noonan, C. W., Ichinose, T., Bachand, A. M., Koleber, T. L., & Yost, M. G. (2002). Melatonin metabolite excretion among cellular telephone users. International Journal of Radiation Biology, 78(11), 1029-1036.
Eskander, E. F., Estefan, S. F., & Abd-Rabou, A. A. (2012). How does long term exposure to base stations and mobile phones affect human hormone profiles?. Clinical biochemistry, 45(1-2), 157-161.
Megha, K., Deshmukh, P. S., Ravi, A. K., Tripathi, A. K., Abegaonkar, M. P., & Banerjee, B. D. (2015). Effect of low-intensity microwave radiation on monoamine neurotransmitters and their key regulating enzymes in rat brain. Cell biochemistry and biophysics, 73(1), 93-100
Nakamura, H., Matsuzaki, I., Hatta, K., Nobukuni, Y., Kambayashi, Y., & Ogino, K. (2003). Nonthermal effects of mobile-phone frequency microwaves on uteroplacental functions in pregnant rats. Reproductive Toxicology, 17(3), 321-326.
Ozguner, M., Koyu, A., Cesur, G., Ural, M., Ozguner, F., Gokcimen, A., & Delibas, N. (2005). Biological and morphological effects on the reproductive organ of rats after exposure to electromagnetic field. Saudi medical journal, 26(3), 405-410.
Qin, F., Zhang, J., Cao, H., Guo, W., Chen, L., Shen, O., ... & Tong, J. (2014). Circadian alterations of reproductive functional markers in male rats exposed to 1800 MHz radiofrequency field. Chronobiology international, 31(1), 123-133.
Ragy, M. M. (2015). Effect of exposure and withdrawal of 900-MHz-electromagnetic waves on brain, kidney and liver oxidative stress and some biochemical parameters in male rats. Electromagnetic biology and medicine, 34(4), 279-284.
Sepehrimanesh, M., Saeb, M., Nazifi, S., Kazemipour, N., Jelodar, G., & Saeb, S. (2014). Impact of 900 MHz electromagnetic field exposure on main male reproductive hormone levels: a Rattus norvegicus model. International journal of biometeorology, 58(7), 1657-1663.
Yüksel, M., Nazıroğlu, M., & Özkaya, M. O. (2016). Long-term exposure to electromagnetic radiation from mobile phones and Wi-Fi devices decreases plasma prolactin, progesterone, and estrogen levels but increases uterine oxidative stress in pregnant rats and their offspring. Endocrine, 52(2), 352-362.
We do not agree that science has shown that there are additional primary biological mechanisms (and no evidence of this has been provided here).
4 11 Main 189-190 Technical ICNIRP claims that it has considered evidence of adverse effects at ‘low-level‘ and ‘non-thermal‘ exposure. Yet when one looks at a number of studies in the ORSAA database for oxidative stress (OS) and DNA damage one finds exposure levels in the conducted experiments that are well below the current draft RF Guideline reference levels:
Oxidative stress: see Kumari, 2012; Burlaka, 2013; Deshmukh, 2013; Maaroufi,  2014; Gurier, 2014;  Ghazizadeh, 2014; Djordjevic  2015; Hussein, 2016). The ORSAA database contains many more studies (>50) with SAR ranges from .15 W/Kg to 0.000003 W/Kg.
DNA Damage:  see Burlaka, 2013; Deshmukh, 2013; Sekeroglu, 2013; Tsybulin, 2013; , 2013; Furtado-Filho, 2014; Megha, 2015; Gustavino, 2016). There are many more examples in the ORSAA database.
ORSAA requests that ICNIRP identify and document the non-thermal effects it has considered, and provide justification of why it does not see a range of biological effects such as oxidative stress and DNA damage as a threat to health
We believe that what is stated in the documents is accurate in this regard, and so no changes have been made.
4 12 Main 216-244 General ICNIRP has provided a high level of detail of the mechaisms of thermal action and the draft RF Guidelines go to great lengths towards preventing harmful heating effects. However, thermal effects and the mechanism of action are now well known. Sadly, there is very little discussion of non-thermal effects, despite lines 189-190 suggesting that they have been considered.
ORSAA requests that ICNIRP provide more details of the non-thermal effects that were considered and to explain why DNA damage and oxidative stress that are occuring at significantly lower exposure levels than ICNIRP reference levels are not considered to be relevant to health.
Mechanisms for non-thermal bio-effects such as oxidative stress are also absent despite plausible mechanisms being discussed; e.g.,  Barnes et al. (2016).
The guidelines text clearly clarifies that all effects, regardless of mechanism, have been considered.
4 13 Appendix B all General A  biased review with a lack of attention to important detail that misrepresents the available evidence. Evidence of potential and real harm is being routinely dismissed by ICNIRP via a list of generic statements claiming “methodological limitations“ of the studies (in at least 15 instances) or lacking “dosimetry” information, or “other short comings” or “the results have not been replicated in independent studies”. In all cases these throw away statements:
1) Have not identified which papers have resulted in the purported shortcomings, nor justified what the specific shortcomings or methodological limitations are;
2) Have not identified which papers lack dosimetry information and what signal source (simuated or real) was used. Some of these  papers may relate to epidemiological studies looking at cell towers or even cell phone use. Even though there may be no useful and specific details of exposure levels for setting appropriate limits for safety purposes, the RF sources in such  epidemiological studies will most likely be operating well within currently permitted levels, and yet effects are still being observed.  This suggests that the current guidelines are obsolete and are not fully protective.
3) Have not identified how many studies available in the literature claiming to be replications yet showing null results are true attempts at replication. Neither has ICNIRP discussed whether the attempted replicated study was funded by industry. The reader has not been not informed as to the existence of replicated studies that do reproduce the same result. Two examples are Tillman (2010) and Lerchl (2015). Both studies found RF acting as a tumour promotor. ICNIRP dismisess this finding with a statement claiming no obvious dose response relationship (see later). However, Tillman performed an earlier study in 2006 and found that RF was not acting as a tumour promotor. This earlier research was funded by the telecommunications industry (GSM Association, UK/Ireland Mobile Manufacturers Forum (MMF)). Funding source appears to matter, suggesting that much of the research funded by industry (whereby the majority find no significant effects) is potentially unreliable and a source of uncertainty.
4) Have not advised the reader that many independent studies, although not exact replications of prior studies, have found the same bio-effect outcomes, thereby providing converging evidence for such outcomes. In many cases, the balance of evidence supports their findings; e.g. oxidative stress, DNA damage, behavioral changes etc.
5) Have not provided justification as to why other more stringent and scientifically based RF Standards, such as those adopted by Russia and China are incorrect while those adopted by ICNIRP are correct.

The shortcomings mentioned above undermine ICNIRP’s credibility and create a level of distrust within the international research community. ICNIRP has failed to acknowledge or address such concerns as those raised by more than 200 well respected international scientists (see EMF appeal by 244 EMF scientists, Aug 2018: www.emfscientist.org).
ORSAA recommends that ICNIRP make clear the specifc papers that have made findings identified as troublesome along with their specific methodological deficiencies. A holistic approach to evaluating the evidence needs to be taken, and more importantly, a risk determination needs to be made along with probabilities around possible disease outcomes. Such risk determinations need to be conducted by those with appropriate qualifications.
To wait until established evidence of harm is found would mean that the risk has already materialised. Given the size of the population exposed such an approach is negligent.
Lack of impartiality and dismissal of important findings that challenge the validity the draft RF Guidelines.
These comments have been considered.
4 14 Appendix B 15-16 General Refer to comment #9 above for Guidelines.
ORSAA  recommends  ICNIRP remove that the reference to WHO as the EHC work was not completed and may never be published.
Lack of impartiality, evidence of confirmation bias and conflicts of interest.
ICNIRP does not agree with these accusations, and no evidence is provided in support of them.
4 15 Appendix B 17 General ICNIRP claims the WHO technical document was an “independent review“.
ORSAA recommends that ICNIRP  remove this claim
This claim is clearly contestable for the reasons covered in comment #9 above for Guidelines. The majority of the EHC review group were ICNIRP members. The EHC did not include any representation from countries that have adopted RF Standards that are more restrictive.
Independent' here refers to independence from vested interests. ICNIRP acknowledges that some of its commissioners were involved in the WHO Environmental Health Criteria.
4 16 Appendix B 19 General SCENIHR has also been accused of evaluating the science using the wrong methodology (Carpenter, Hardell, Sage, 2015).  ICNIRP does not agree that such an accusation is appropriate.
4 17 Appendix B 25-27 General ICNIRP also considered research published subsequent to that included in the WHO and SCENIHR reviews in the development of the current guidelines.
 ORSAA recommends that ICNIRP provide a list of papers reviewed for transparency and specify who the reviewers were for these studies.
 Without this necessary information it cannot be validated as to whether all the latest available research was considered or whether important papers were missed.
As described above in response to this author, this is beyond the scope of the guidelines documents.
4 18 Appendix B 47 Technical
“ICNIRP bases its guidelines on substantiated adverse health effects“. ORSAA does not consider this apprach to be reasonable, due the following limitations:
1. Risk management is not about waiting for a risk to materialise before taking action.
2. The clear majority of studies are based on short–term acute exposures.  This is equivalent to looking to establish cancer as a health effect after someone has smoked a single cigarette, or after smoking one packet of cigarettes over a month.
3. Animals are sacrificed to evaluate changes, so any long-term developmental effects cannot be observed. All that the results of such studies can reveal is that an acute exposure is unlikely to cause disease; however, they are unable to deterine whether chronic exposures are harmless.
4. Most sudies are not designed to look at health outcomes.
5. Very limited controlled experiments on humans and none that are long term have been conducted.
Many experiments (see ORSAA database) are showing biological effects, some of which have been associated with disease pathways; e.g., oxidative stress. Some diseases take many years to manifest.
There are indicators that ICNIRP does not appear to take seriously nor include:
1. Increase in neoplasms: animal studies and human epidemiological studies;
2. Leukemia, breast cancer, brain tunours, salivery gland malignancy;
3. DNA damage: in vitro, in vivo and epidemiological studies
4. Oxidative stress –  In vitro, In vivo and epidemiological studies;
5. Inflammation;
6. Tumour promotion and initiation.
Some of the above biological effects, if sustained for many years, can lead to disease.
When looking at clinical studies and historical studies on humans, there are clear signs that physical and mental health is impacted by long term chronic exposures. The DIA highlighted this in their paper. The key points are given below:
¡ “Personnel exposed to microwave radiation below thermal levels experience more neurological, cardiovascular, and haemodynamic disturbances than do their unexposed counterparts.” (page 6)
¡ “Subjects exposed to microwave exhibited a variety of neurasthenic disorders against a background of angiodystonia (abnormal changes in the tonicity of the blood vessels). The most common subjective complaints were headache, fatigue, perspiring, dizziness, menstrual disorders, irritability, agitation, tension, drowsiness, sleeplessness, depression, anxiety, forgetfulness and lack of concentration.” (page 8)
Most of the “disorders” listed will definitely impact well-being. Many of the symptoms described match what is being claimed by members of the public today as occurring as a result of exposure to Wi-Fi, mobile phones, smart meters and cell towers. Unfortunately, ICNIRP and government radiation protection agencies are intimating that such symptoms are due to a “nocebo effect”.
ICNIRP has provided its justification for adopting this position, and believes that it is very sensible to do so. The reasons that the respondant has provided for the contrary position have been noted.
4 19 Appendix B 67-69 General ORSAA recommends that ICNIRP provide specific examples of those more rigorous studies that are have failed to show effects. It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have now added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
4 20 Appendix B 75 Technical Spatial memory has also been shown to be impacted within animal experiments, which fairly consistently show reduced exploratory activity in exposed animals compared to the controls.  This has been considered, but there is no evidence that this change results in an adverse health effect.
4 21 Appendix B 88 General Please provide examples of alternative explanations to support the statement “alternative explanations for observed effects are plausible” The wording has been changed to emphasise the lack of demonstration that these endpoints are related to radiofrequency EMF exposure.
4 22 Appendix B 90 Technical There is evidence that RF alters neurotransmitter levels in animal studies and human epidemiological studies.
¡ Hippocampus injured by long-term exposure to microwaves leads to impairment of cognitive function due to neurotransmitter disruption (Zhao 2012)
¡ Microwaves influences monoamine neurotransmitter levels and their key regulating enzymes (Megha 2015)
¡ Impacts brain, heart and digestive system
¡ Many studies looking at learning and spatial memory deficiencies also find neurotransmitter profiles changed (Shtemberg 2000, Zhao 2012, Maaroufi 2014, Qin 2014, Wang, 2015 etc.)
¡ Key neurotransmitters are all impacted by RF:
¡ GABA (e.g., Qiao,  Peng, Yan, et al., 2014)
¡ Dopamine (e.g., Ezz, Khadrawy, Ahmed et al., 2013)
¡ Serotonin (e.g., Li, Peng and Wang, et al., 2015)
¡ Norepinephrine (noradrenaline) (e.g., Megha, Deshmukh and Ravi et al., 2015).
¡ Epinephrine (adrenaline) (e.g., Kulkybaev and Pospelov, 2000)
¡ Glutamate (e.g., Noor, Mohammed and Ahmed et al., 2011)
¡ Acetylcholine (e.g., Testylier, Tonduli and Malabiau et al., 2002).
Imbalances of these key neurotransmitters can lead to the following:
¡ GABA imbalances: anxiety, restless mind, inner tension and excitability, tinnitus, blurred vision, chest discomfort, irritability and oversensitivity;
¡ Dopamine imbalances: depression, fatigue, learning disorders, Attention Deficit Disorder (ADD), irritability and outbursts and easily distracted;
¡  Serotonin imbalances: migraines/headaches, rapid heart rate/irregular heart-beat, tremor, strong sugar cravings, insomnia, fatigue, depression and reduced emotional control;
¡ Acetylcholine imbalances: learning disabilities, memory lapses, diminished comprehension, slowed mental responsiveness and Attention Deficit Disorder (ADD).
Many of the symptoms described above fit the profile of those who complain of suffering microwave sickness and/or electromangentic hypersensitivity. Many of the symptoms above are also becoming common in modern society.
For example, a real-life exposure condition is detailed below (Buchner 2011):
¡ A long-term study conducted in Germany to investigate the influence of base station RF emissions on neurotransmitters under true-to-life conditions;
¡ 24 out of 60 participants were exposed to a power density of < 60 µW/m², 20 participants to 60 - 100 µW/m², and 16 participants to more than 100 µW/m²;
¡ The levels of stress hormones adrenaline and noradrenaline grew significantly during the first 6 months after starting the GSM base station;
¡ The levels of the precursor substance dopamine substantially decreased in this time period;
¡ The initial condition was not restored even after 1.5 years;
¡ The effects showed a dose-effect relationship even though exposures were situated well under public exposure limit values.

References
Ezz, H. A., Khadrawy, Y. A., Ahmed, N. A., Radwan, N. M., & El Bakry, M. M. (2013). The effect of pulsed electromagnetic radiation from mobile phone on the levels of monoamine neurotransmitters in four different areas of rat brain. Eur Rev Med Pharmacol Sci, 17(13), 1782-1788.
Kulkybaev, G. A., & Pospelov, N. I. (2000). Changes in gastric electric activity and serum catecholamine level under the influence of electromagnetic microwaves (experimental studies). Meditsina truda i promyshlennaia ekologiia, (5), 8-11.
Li, H. J., Peng, R. Y., Wang, C. Z., Qiao, S. M., Yong, Z., Gao, Y. B., ... & Li, Z. (2015). Alterations of cognitive function and 5-HT system in rats after long term microwave exposure. Physiology & behavior, 140, 236-246.
Megha, K., Deshmukh, P. S., Ravi, A. K., Tripathi, A. K., Abegaonkar, M. P., & Banerjee, B. D. (2015). Effect of low-intensity microwave radiation on monoamine neurotransmitters and their key regulating enzymes in rat brain. Cell biochemistry and biophysics, 73(1), 93-100.
Noor, N. A., Mohammed, H. S., Ahmed, N. A., & Radwan, N. M. (2011). Variations in amino acid neurotransmitters in some brain areas of adult and young male albino rats due to exposure to mobile phone radiation. Eur Rev Med Pharmacol Sci, 15(7), 729-742.
Qiao, S., Peng, R., Yan, H., Gao, Y., Wang, C., Wang, S., ... & Su, Z. (2014). Reduction of phosphorylated synapsin I (ser-553) leads to spatial memory impairment by attenuating GABA release after microwave exposure in Wistar rats. PloS one, 9(4), e95503.
Testylier, G., Tonduli, L., Malabiau, R., & Debouzy, J. C. (2002). Effects of exposure to low level radiofrequency fields on acetylcholine release in hippocampus of freely moving rats. Bioelectromagnetics: Journal of the Bioelectromagnetics Society, The Society for Physical Regulation in Biology and Medicine, The European Bioelectromagnetics Association, 23(4), 249-255.

There are indeed reports of effects, but these do not represent substantiated reports of adverse effects on health. 
4 23 Appendix B 98-99 Technical ORSAA recommends that ICNIRP consider the issue of electromagnetic hypersensitivity (EHS) more seriously. EHS is primarily a medical and biophysics issue that requires investigation by medical doctors as well as psychologists trained in psychophysics and physicists trained in biophysics. Objective tests performed by Hocking et al. 2001, 2002, 2003 clearly show neurological changes (c-nerve fibres). Belpomme et al. 2015 has identified plausible biomarkers. Heuser 2017 has identified functional differences in fMRI scans between healthy individuals and those who are EHS. Further medical research is required with central sensitisation syndrome and kindling effects as possible avenues for investigation.
When it comes to research on EHS, there are a number of serious issues with existing studies:
¡ Many studies are not designed to demonstrate causation i.e. survey based studies, subjective tests etc.
¡ Most studies look at short term, one off, acute exposures, rather than the required longitudinal studies.
¡ Many provocation studies are subjective and do not include objective biological and/or neurological tests.
¡ There is limited research looking at genetic differences, metabolic disorders, biological, neurological and immunologic responses between sensitive and non-sensitive people.
¡ Very few clinical studies investigate RF-occupational worker’s health versus a less exposed population.
¡ There has been very limited biological and controlled exposure testing on humans.
¡ People who have health problems are excluded from tests. Therefore, it is difficult to determine whether people whose health is compromised are especially vulnerable to everyday RF-exposures.
Provocation studies are not the gold standard for investigating EHS, because most provocation studies suffer design, methodological and statistical deficiencies. Some examples include:
¡ Provocation studies are unreliable in that the participants often respond according to their beliefs about the conditions, or expectations about the outcomes;
¡ Not representing real life exposure situations because studies focus on a single or narrow frequency range, power level and often lack signal variability;
¡ Symptoms may not be tracked for long enough and may vary between test subjects by type, onset time, intensity and duration;
¡ The way in which the symptoms are recorded and the method for constructing a numerical differential score can introduce bias;
¡ Environments are not always controlled; e.g.,  EMR leakage within the testing environment (i.e. other power sources, fluorescent lights) or even from the test device;
¡ Other confounders are not considered; e.g., many EHS people have been found to be also sensitive to odours and noise (not controlled);
¡ Subjective tests are often not supplemented with useful objective tests (HRV, blood and urine chemistry changes, skin voltage, nerve conductivity, fMRI etc.);
¡ Provocation studies do not always identify and test genuine EHS sufferers separately (pooling of data tends to wash out potential findings);
¡ Provocation studies can be affected by memory recall issues when comparing feelings to past exposures.

The material provided does not demonstrate any weaknesses in the conclusions reached in Apendix B, or the restrictions more generally. No changes have been made.
4 24 Appendix B 101 Technical When it comes to the suggestion of nocebo effects this psychological paradigm is unproven and speculative. Nocebo is not likely to be responsible for the initial EHS development but may certainly exacerbate the situation once RF is identified as the source of complaint, as suggested by Dieudonne (2016). The suggestion of EHS being of nocebo origin ignores clinical study findings and biological effects that can be associated with many symptoms; e.g., the experiences of EHS sufferers can be tied to changes in neurotransmitters. To continue pushing nocebo and purposefully exclude EMR as a likely cause is both dangerous, disingenuous and harmful to EHS sufferers who may end up being treated inappropriately using psychiatric models and methods. Further evidence has now been provided to justify these conclusions.
4 25 Appendix B 113-115 Technical Epidemiological studies are not designed to provide causation.
ICNIRP to correct their statement
 Epidemiological studies are not controlled, nor do they investigate the mechanism of harm so it is impossible to demonstrate causation. At best they can only provide “a possible association“ between RF exposure and an endpoint being investigated.
No comment on the guidelines appears to have been made here.
4 26 Appendix B 297-298 Technical Immune system RF bio-effects have been clearly related to health. Immunology expertise is required to correctly interpret the implications to health. Below are some example papers showing RF effects on the immune system:
¡ Inflammation:
¡ Interleukin 1 beta (IL-1β) levels increased (Eser, 2012; Megha, 2012)
¡ Tumour necrosis factor alpha (TNF-α) levels increased (Megha, 2012)
¡ Neuroinflammation (Bouji, 2012)
¡ Changes in Cytokine profile (Gapeev, 2010)
¡ Lymphocyte percentage and total white blood cell counts changes:
¡ IgM and IgG levels significantly changed (Yuan, 2004; El-Gohary, 2017)
¡ Pancytosis (an increase in RBCs, WBCs, and platelets) (Otitoloju, 2012)
¡ Leukocyte cell surface antigens (CD antigens) expression changes
¡ Skin disorders/dermatitis (Johansson, 2001):
¡ Migration of mast cells towards the uppermost dermis
¡ Mast cell degranulation
¡ Histamine release
¡ Autoimmune changes (Grigoriev, 2010*)
¡ Supressed phagocytic activity of neutrophils (Kolomytseva, 2002)
¡ Increased allergies and asthma (Saravanamuttu, 2016)
*Replicated Soviet studies conducted between 1974 and 1991 that showed immunological effects.
Immune system effects are key bio-effects that were used to establish the Soviet RF Standard. 
We believe that what is stated in the documents is accurate in this regard, and so no changes have been made.
4 27 Appendix B 320-322 Technical The basis on which ICNIRP claims there is no strong evidence for an association between EMF and sperm quality is questionable. ORSAA has identified more than 80 papers from in vitro, in vivo and human epidemiology studies that show a strong association  between EMF and sperm quality attributes (see the ORSAA database). For example, the cohort study by Zhang (2016), epidemiological studies looking at at radar exposures and fertility (Ding, 2004; Ye, 2007; Yan, 2007), and long term and short term exposure studies showing:
¡ Defective and degenerative testicular function;
¡ Increased oxidative stress;
¡ Atrophy of the seminiferous tubules;
¡ Degenerative changes in the epithelium of the testes;
¡ Reduction of serum testosterone levels;
¡ Reduction in the number of sertoli cells;  
¡ Malformed sperm;
¡ Reduced sperm count and quality;
¡ Reduced sperm viability;
¡ Reduced sperm motility;
¡ Increased sperm DNA damage.  SEE FIgure 6

Many of the above parameters are associated directly with exposure duration.
We believe that what is stated in the documents is accurate in this regard, and so no changes have been made.
4 28 Appendix B 342 Technical There are numerous studies showing a non linear dose response relationship. Linear relationships are a simplification. In contrast, biological systems are complex with amplification and feedback mechanisms. Research is suggesting frequency and intensity windows exist and that higher power does not necessarily mean a larger effect. To dismiss evidence because it does not follow a linear dose response is an engieering approach that is inadequte for describing biological systems. A linear response is not required to demonstrate adverse health effects within the guidelines methodology.
4 29 Appendix B 379 Technical A regular user in the Interphone study was defined as someone who hardly used the phone i.e. at least one call on their cell phone each week for at least 6 months. This classification is not an accurate reflection of regular usage today. No comment on the guidelines appears to have been made here.
4 30 Appendix B 390-392 General If ICNIRP is looking for increases in cancer incidences aross a large number of countries in order to establish a trend, the doubling in brain tumour rates over the last 20-25 years in the UK, the Netherlands and Denmark (see graph below) should be sufficient.
ICNIRP should reconsider its position given the converging evidence that is available today.
Explain the context of your comment.

Brain tumour incidence rates has been considered by ICNIRP in the guidelines derivation.
5 1 Main 156 General It is unfortunate that the symbol for magnetic field strength, H, and the symbol for radiant exposure, Htr, are so similar.  This can lead to confusion in later parts of the document.

These Guidelines must be used,  interpreted and understood by the users.  It needs to be clear and concise.   The term Htr could easily be confused with the magnetic field at, or very near to, a transmitter.
This has now been changed to 'U' (and 'transmitted' changed to 'absorbed').
5 2 Main 156 Technical „Radiant Exposure“ is the radiant energy received at a surface.  It is not a transmitted quantity (although a relationship can be calculated).
Use a term other than „Transmitted Energy Density“ throughout the document.  Possibly „Received Energy Density“ might be more applicable.
This exposure is about the energy received at a body not the energy transmitted by a source.
This terminology has now been amended.
5 3 Main 156 Technical See above, in relation to „Transmitted power density“
Use a term other than „Transmitted Power Density“  throughout the document.   Possibly „Received Power Density“ might be more applicable.
This exposure is about the power received at a body not the power transmitted by a source.

This comment has been repeated and is not addressed again.
5 4 Main 437 Editorial „ACGIH 2017“ is not referenced although „ACGIH 2018“ appears in the references.
Check reference and text for validity and applicability.
This has been amended as suggested.
5 5 Main 441-445 Technical The note is very wide ranging.  It takes no account of the scenario, for example, when a pregnant woman is operating a machine and there is a very localised limb exposure at worker levels but where the torso (and thus the fetus) is exposed below G public levels and cannot be greater due to positional constraints.
Change:
“Note that for the basic restrictions described below, a pregnant woman is treated as a member of the G public. This is because recent modelling suggests that for both whole body and local exposure scenarios, exposure of the mother at the occupational basic restrictions can lead to fetal exposures that exceed the G public basic restrictions.”
To:
“Note that for the basic restrictions described below, the fetus in a pregnant woman is treated as a member of the G public. Recent modelling suggests that exposure of the torso of the mother at the occupational basic restrictions can lead to fetal exposures that exceed the G public basic restrictions.”

Women, including pregnant women, are important members of the workforce.  They should be allowed to continue to work at their normal jobs while pregnant as far as is possible; provided the health of the fetus and mother is protected.
It could have significant social consequencies because in the early stages or pregnancy a mother may not realise she is pregnant; however the text indicates her exposure should be below G Public levels.  This could lead to a scenario where all sexually active women over a wide age range are prohibited from some types of work because they might become pregnant.

The issue of the pregnant woman has now been elaborated on in Apendix A and provides consideration of different scenarios.
5 6 Main 509-511 Also Table 2 Table 3  and Note 4 under table 3 Technical The concepts and equations for the basic restrictions for exposures of less than 6 minutes are complex and the text in lines 509-511 further complicates the issue.
Example 1:  Consider a continuous exposure which is due to a 500MHz square wave pulse train with a mark space ratio of 10%.  The text says that the <6 minute thresholds apply to any group or subgroup of pulses.  The exposure due to a single pulse is over 2 microseconds and line 509 says the time period „t“ is the duration in seconds of a single pulse so the limit for <1s applies from Table 3. The total „on“ time in the 6 minutes is 36 seconds so the summed exposure duration would make the 1<t<360s equation apply from Table 3. But the overall exposure continues over the full 6 minutes and the exposure interval is not less than 6 minutes so Table 2 applies.  If all of these have to be separately assessed to determine the worst case level/limit scenario, this will become a very complex and expensive process.
Example 2:  An RFID signal with a 860MHz fundamental which has a variable envelope time but with a maximum of 4 seconds envelope which is followed by a short break of less than 1s and the pulse envelope repeats.   This also poerates continuously.  Previously it was possible to assume the 860MHz operated continuously (ie no envelope break) as this gave a worse case over the 6 minutes.  With the new Table 3 it may be necessary to assess each single envelope to determine the exposure against the limits.

Neither of these types of signal consists of the short sharp spike type signals it appears this section is designed to protect against.  It needs to be clearer.
This section has been rewritten, and the equations improved to account for such issues.
5 7 Main 682 & Table 4 Technical If a 10MHz CW exposure is considered there appears to be a significant discontinuity between the reference levels in this document and the ones from the 2010 LF Guidelines.  It is appreciated that this limit is with H2 and E2 averaged over 30 minutes but for a CW signal the RMS average would not elate to that discontinuity.

There is likely to be a need to explain the difference.
The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
5 8 Main 709 Editorial  There is a misprint:  „(66-30 GHz)“ makes no sense  This has been amended as suggested.
6 1 Main 118-119 Not Given The field inside the body depends on many more parameters.
„on the EMF source properties (size, distance, frequency, modulation, field intensity and polarization), on the size of the body, as well as on the physical properties and spatial distribution of the tissues within the body.“
It is better to include as many parameters determining the field distribution as possible.
Additional parameters have been added.
6 2 Main 129 Editorial dialectric
dielectric
Typo
This has been amended as suggested.
6 3 Main 156 Technical In the third column of Table 1, line 10, the entry is „radiant exposure“, instead of the units.
Change to „joule per square meter“
Consistency
This has been amended as suggested.
6 4 Main 231 Technical „health effects are primarily related to absolute temperature: “This is true for whole body exposure. In the case of local exposure, tissue damage is dependent on temperature and time at that temperature. This is why the CEM43oC concept was introduced and is mentioned in line 319, further below.
„related to absolute temperature and the time at this temperature“.
Consistency.
There is currently no evidence that the duration is relevant at the temperatures relevant to the guidelines, and so this has been left as it is. 
6 5 Main 272-275 Editorial „human adults“: It is important to mention whether these were resting human adults.
„resting human adults“
Consistency
This has now been defined.
6 6 Main 319-320 Editorial „Yarmolenko et al. 2011“ is missing from the reference list.

This has been amended as suggested.
6 7 Main 479 Editorial „a SAR of“
„an SAR of“
Typo
We treat 'SAR' as though it was a word, rather than 3 separate letters, which makes 'a' appropriate here.
6 8 Main 482-487 Technical „A reduction factor of 2“
Please, justify better the selection of reduction factors and explain how uncertainty was taken into account for deriving them.
The need for the reduction factor is clear and discussed at several points in the document. However, the value of 2 is not explained in detail. Was it derived quantitatively by following a rigorous uncertainty analysis procedure, or is it an educated guess? Moreover, it is different than the reduction factor for whole body exposure. The fact that „the associated health effect is less serious medically“ for local exposure should not play a role in the derivation of the reduction factors. The procedure for deriving these numbers should be self-consistent and uniform throughout the guidelines. Any deviations should be adequately justified in a scientific way.
1/ Further justification for the difference between local and whole body RFs has been added. 2/ There is not sufficient data to enable an adequate uncertainty analysis, and so the RFs are based on expert judgement.
6 9 Main 675-677 Technical „a smaller temperature rise“
Give a value (or percentage) and the respective reference.
This is a „sensitive“ issue, because it relates to children, and a significant one because it has an impact on the decision of not changing the reference levels. The statement here reads like a hypothesis/assertion. It would better to give a  value for the expected temperature rise with respect to adults, or a reference to support the statement. 
We now explicitly state that the temperature rise in the child would be less than that of the adult at the basic restriction.
6 10 Main 709 Editorial „(66-30 GHz)“
„(6-30 GHz)“
Typo
This has been amended as suggested.
6 11 Appendix A 171-172 Technical „As described above, power absorption is confined within the surface tissues at frequencies above 6 GHz. This may lead to thermoregulatory response initiation time being reduced.“
Remove the sentence.
What is the biological rationale for this? Is there a reference to support it? At the surface of the body (skin) there are numerous heat receptors sending signals to the hypothalamus.
This has been amended to avoid the inaccuracy.
6 12 Appendix A 341 Editorial „°C kg W-1“
„°C kg W-1“
Typo
This has been amended as suggested.
6 13 Appendix A 672 Technical „internationally standardized child models“
Remove the whole sentence.
These are scaled voxel models of Janapese children. (a) They are not globally valid; (b) they are not models of real children but scaled down from adult Japanese models; and (c) they should not be considered „standardized“: Who did standardize them and when? (i.e.: Is there an international standard document describing them? By which standardization organization?)
These are specified by ICRP. This information (and an updated reference) has now been added to the text.
6 14 Appendix B 25-27 Technical „To complement the WHO and SCENIHR reviews, ICNIRP also considered  research published subsequent to that included in the WHO and SCENIHR reviews in the development of the current guidelines.“
Insert ctu-off date for pulications taken into consideration.
We thank ICNIRP for acknowledging the work performed by SCENIHR (now SCHEER). For reasons of consistency/transparency, it is suggested that ICNIRP clearly states a cut-off date for the literature that it has considered in the process of developing the guidelines.
The cut-off date has now been added. The citation has been corrected.
6 15 Appendix B 27-29 Technical „In order to provide an indication of ICNIRP’s evaluation process, overviews of the literature and conclusions that ICNIRP reached, as well as a limited number of examples, are provided.“
Elaborate further.
Are the inclusion/exclusion criteria for the studies of the peer-reviewed literature that have been considered during the risk assessment process itemised somewhere? Will ICNIRP issue a detailed report on the evlauation of the studies and the list of those that have been considered in the risk assessment process?
It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
6 16 Main 16 General „This publication replaces the radiofrequency part of the 1998 guidelines (ICNIRP 1998);“
Elaborate further.
An abstract with the changes that have been made to the previous guidelines would be most useful.

ICNIRP is preparing a separate document to outline the differences between ICNIRP 1998 and the present guidelines.
6 17 Appendix B 346-406 Technical SCHEER notes the striking difference between this evaluation of the NTP-studies and the conclusions of the NTP peer review by external experts which  concluded that the NTP studies were well designed, and that the results demonstrated that RFR were carcinogenic to the heart (schwannomas) and brain (gliomas) of male rats. This section also does not explain the concordance between high quality animal data (NTP studies, Falcioni studies) and human data with regard to the occurrence of specific tumours such as schwannoma’s and brain glioma’s The guidance also does not explain how the local SAR levels, considered to be more relevant than whole body exposures, applied in the NTP-studies compare to the local SARs ICNIRP-guideline values.   
It is recommended to re-evaluate the NTP- and Falcioni studies as well as the significance of the findings in the light of the available human data, taking into consideration the NTP peer review.
ICNIRP has now published a critique (Health Physics, 2019) that explores these issues in more detail. This is cited in the revised document.
7 1 Main 47 General The WHO definition of health is used. This definition includes mental/social wellbeing and in the context of EMF it can be interpreted  that “worrying” about the presence of EMF might be a health effect.
Please delete the footnote stating that the WHO definition is used.
The WHO definition is accurate, and is appropriate in that if EMF causes the worry, then it would be within scope of the guidelines, but as there is no evidence that the EMF is relevant to the worry, as a matter of fact it falls outside the scope. We have thus not changed this.
7 2 Main 122-127 Technical The generation of heat due EMF interaction with either charged and/or polarized molecules is briefly explained in this section. However in the corresponding Annex AA the different contributions of charge (conductive) and polarization (dielectric) is not addressed.
Please add a formula for the dielectric and conductive properties of the conductance quantity in Annex AA  (eg. Introduce effective conductivity σ_eff=σ+ωε_0 ε^'')
The guidelines documents are not meant to replicate related text books, but to highlight the most saliant features of the guidelines. We do not believe that this detail is sufficiently important to include.
7 3 Main 156 Technical It is not clear why some of the quantities are given in bold (E, H, Seq, Htr, Str and Sinc). Further in Annex AA only E,H, and J are given in bold which leads to the assumption, that bold is used to indicate vectorial character of quantities. However, Htr, Str and Sinc are scalar values.
Please explain the usage of bold letters in the text. If it is due to vectors, only apply bold to E and H
The font used for vector/scalar values has now been clarified, and used consistently through the documents.
7 4 Main 156 Technical Incident energy density (Hinc) is missing in the table
Please add Hinc
The tables have been completely rewritten, and this issue resolved.
7 5 Main 156 General Using the letter “H“ for both magnetic field and energy density quantities (Hinc and Htr) might be confusing
Please use another letter for energy densities (eg. U)
This has now been changed to 'U' (and 'transmitted' changed to 'absorbed').
7 6 Main 266-271 General ICNIRP aims at adopting the OAHT that corresponds to ACGIH 2017 (+1 °C of “normothermia”,cf l. 261) However according to the footnote 2 normothermia means that no active thermoregulatory processes are engaged by the body. This is in conflict with the statements made in l. 269-l.271
Please resolve this discrepancy
Note that within this range, there can be or not be active thermoregulatory processes (i.e. it can be normotheric or hyperthermic). That is, it is within the range, but is not identical with it. We have reworded this for clarity.
7 7 Main 290 General „infrared radiation” is a more accurate term than just “infrared”
Please add „radiation„ after „infrared“
This has been amended as suggested.
7 8 Main 292 General See comment 8 Note that this is comment 8.
7 9 Main 366-370 General Citation missing
Please cite relevant work
Dosimetry detail is provided in Apendix A.
7 10 Main 380-383 Technical This statement is not very precise. What does “most of the power” mean? According to table 3.1 the penetration depth (86% absorbed power) at 6GHz is 8.1 mm. This does not fit to skin thicknesses as used in numerical simulations (eg. 1mm)
 Please give a more sound justification (eg. Best compromise of constant heating factors for SAR or TPD) or change the transition frequency
 Kanezaki, A., Hirata, A., Watanabe, S., & Shirai, H. (2009). Effects of dielectric permittivities on skin heating due to millimeter wave exposure. Biomedical engineering online, 8(1), 20
This is clarified in Apendix A.
7 11 Main 390-391 Technical What does sufficient mean?
Please specify (and cite) the maximum error introduced by the step function for averaging
The general logic is now described in more detail in Apendix A. There is not a paper that we are aware of that provides the specification for the respondant's particular question.
7 12 Main 411 Technical Below 1s there is a fixed value for SA although the sqrt(t)-rule should be valid below 1s as well! To our knowledge, applying sqrt(t-1) is not based on scientific results.
Please apply sqrt(t) rule instead of sqrt(t-1) with constant values below 1s or give a reasonable explanation for choosing the 1s limit
Foster, Kenneth R., Marvin C. Ziskin, and Quirino Balzano. "Thermal modeling for the next generation of radiofrequency exposure limits: Commentary." Health physics 113.1 (2017): 41-53
This formula and explanation have now been amended.
7 13 Main 415-418 Technical Citation needed
Please cite relevant literature
Dosimetry detail is provided in Apendix A.
7 14 Main 423-424 Editorial Adiabatic absorption of 5kJ/m2 may lead to temperature elevation of more than 10 K in the worst case scenario. Therefore it is not conservative at all!
Please lower the values below 1s by applying the sqrt(t) rule (instead the sqrt(t-1) with constant values below 1s). Otherwise lower the values below 1 s to maximally 2kJ/m2 and give a reasonable explanation for choosing the 1s limit
For details See my comment 41 regarding Annex A
This formula and explanation have now been amended to account for this.
7 15 Main 442 Editorial The pregnant woman is treated as a member of the G population even though she is currently working. This  should be made clear in the sentence
Please Add:… and occupational limits are not to be used for her
This has now been clarified in numerous places within the documents.
7 16 Main 508 Technical Below 1s there is a fixed value for SA although the sqrt(t)-rule should be valid below 1s as well! To our knowledge, applying Sqrt(t-1) is not based on scientific results.
Please apply sqrt(t) rule instead a sqrt(t-1) with constant values below 1s or give a reasonable explanation for choosing the 1s limit
 Foster, Kenneth R., Marvin C. Ziskin, and Quirino Balzano. "Thermal modeling for the next generation of radiofrequency exposure limits: Commentary." Health physics 113.1 (2017): 41-53
This formula and explanation have now been amended to account for this.
7 17 Main 518 Technical Below 1s there is a fixed value for SA although the sqrt(t)-rule should be valid below 1s as well! To my knowledge, applying Sqrt(t-1) is not based on scientific results.
 Please apply sqrt(t) rule instead a sqrt(t-1) with constant values below 1s or give a reasonable explanation for choosing the 1s limit
 Foster, Kenneth R., Marvin C. Ziskin, and Quirino Balzano. "Thermal modeling for the next generation of radiofrequency exposure limits: Commentary." Health physics 113.1 (2017): 41-53
This comment has been repeated and is not addressed again.
7 18 Main 520 Technical Below 1s there is a fixed value for SA although the sqrt(t)-rule should be valid below 1s as well! To my knowledge, applying Sqrt(t-1) is not based on scientific results.
 Please apply sqrt(t) rule instead a sqrt(t-1) with constant values below 1s or give a reasonable explanation for choosing the 1s limit
Foster, Kenneth R., Marvin C. Ziskin, and Quirino Balzano. "Thermal modeling for the next generation of radiofrequency exposure limits: Commentary." Health physics 113.1 (2017): 41-53
This comment has been repeated and is not addressed again.
7 19 Main 541 Technical Below 1s there is a fixed value for SA although the sqrt(t)-rule should be valid below 1s as well! To my knowledge, applying Sqrt(t-1) is not based on scientific results.
 Please apply sqrt(t) rule instead a sqrt(t-1) with constant values below 1s or give a reasonable explanation for choosing the 1s limit
 Foster, Kenneth R., Marvin C. Ziskin, and Quirino Balzano. "Thermal modeling for the next generation of radiofrequency exposure limits: Commentary." Health physics 113.1 (2017): 41-53
This comment has been repeated and is not addressed again.
7 20 Main 548 Technical Below 1s there is a fixed value for SA although the sqrt(t)-rule should be valid below 1s as well! To my knowledge, applying Sqrt(t-1) is not based on scientific results.
 Please apply sqrt(t) rule instead a sqrt(t-1) with constant values below 1s or give a reasonable explanation for choosing the 1s limit
 Foster, Kenneth R., Marvin C. Ziskin, and Quirino Balzano. "Thermal modeling for the next generation of radiofrequency exposure limits: Commentary." Health physics 113.1 (2017): 41-53
This comment has been repeated and is not addressed again.
7 21 Main 552 Technical Below 1s there is a fixed value for SA although the sqrt(t)-rule should be valid below 1s as well! To my knowledge, applying Sqrt(t-1) is not based on scientific results.
 Please apply sqrt(t) rule instead a sqrt(t-1) with constant values below 1s or give a reasonable explanation for choosing the 1s limit
 Foster, Kenneth R., Marvin C. Ziskin, and Quirino Balzano. "Thermal modeling for the next generation of radiofrequency exposure limits: Commentary." Health physics 113.1 (2017): 41-53
This comment has been repeated and is not addressed again.
7 22 Main 597 Technical Point 5 seems not to be relevant for table 1 as there is no incident plane wave power density listed in table 2
Please delete point 5
The tables have been completely rewritten, and this issue resolved.
7 23 Main 601 Technical Table 3: Below 1s there is a fixed value for SA although the sqrt(t)-rule should be valid below 1s as well! To my knowledge, applying Sqrt(t-1) is not based on scientific results. For the transmitted energy density, the underlying limit of 5kJ/m2 is not conservative (see comment 41).
For SA and Htr please apply sqrt(t) rule instead a sqrt(t-1) with constant values below 1s or give a reasonable explanation for choosing the 1s limit. Htr values should be drastically reduced  (at least by a factor of 2.5)
 Foster, Kenneth R., Marvin C. Ziskin, and Quirino Balzano. "Thermal modeling for the next generation of radiofrequency exposure limits: Commentary." Health physics 113.1 (2017): 41-53
This formula and explanation have now been amended to account for this.
7 24 Main 610 General Regarding the whole reference level section: Plotting the curves would make it way easier to get an overview over the levels
Please add figures displaying graphs of the reference levels
Reference level figures have now been provided for a limited number of situations (it is not feasible to show all permutations).
7 25 Main 615-618 General Although the reason why being within reference levels does not necessarily protect from exceeding basic restrictions is well and  understandable explained in lines 650-679 and Annex A it induces more G problems in the concept. The new approach reduces the importance of the G meaning of basic restrictions. As you state that only basic restriction or reference level has to be met you “allow” higher basic restrictions for special situations. This “means” that the basic restrictions varies with body size and posture.  
Just a comment, no proposed change
Noted.
7 26 Main 697-711 General Table 5, the minus in the exponent is barely visible. It looks like f^0.177  instead of f^-0.177
Please revise the table with the reference levels
The tables have been completely rewritten, and this issue resolved.
7 27 Main 697-711 General Table 5, note : It is quite inconvenient to look up values  in different tables
Please add the corresponding values in table 5
The tables have been completely rewritten, and this issue resolved.
7 28 Main 718-738 General Table 6, the minus in the exponent is barely visible. It looks like f^0.177  instead of f^-0.177
Please revise the formula
This has been amended as suggested.
7 29 Main 718-738 General Table 6, the minus in the exponent is barely visible. It looks like f^0.177  instead of f^-0.177
Please revise the formula
This has been amended as suggested.
7 30 Main 718-738 Technical To my knowledge, applying Sqrt(t-1) is not based on scientific results. For the transmitted energy density, the underlying limit of 5kJ/m2 is not conservative (see comment 41).
Please apply sqrt(t) rule (instead of the sqrt(t-1) with constant values below 1s) or give a reasonable explanation for choosing the 1s limit. Htr values should be drastically reduced  (at least by a factor of 2.5)
 Foster, Kenneth R., Marvin C. Ziskin, and Quirino Balzano. "Thermal modeling for the next generation of radiofrequency exposure limits: Commentary." Health physics 113.1 (2017): 41-53 
These formulas have been revised to account for these and other issues.
7 31 Appendix A 47 General Introducing an effective conductivity consisting of conductive and dielectric part would be helpful here because it would fit to the introduction in the main text
Please add a formula that explains the quantity conductivity
See my comment #2
We have improved the corresponding explanation for clarity.
7 32 Appendix A 75 Technical The penetration depths given are inconsistent with the values given in table 3.1
Please revise the values
This has been amended as suggested.
7 33 Appendix A 106 Technical This is not necessarily true for array antennas
Just a comment, no proposed change
Noted.
7 34 Appendix A 225-232 Editorial This statement is incomplete, since eg. the applied power and exposure time are not reported (stationary conditions?).
Please add the relevant parameters
Please note that this is not intended to be a complete description, but to convey the main issues considered in the dosimetry underpinning the guidelines.
7 35 Appendix A 328-331 General This statement requires a citation
Please cite relevant literature
Please note that we have not provided complete referencing here, but have focused on the main issues underpinning the dosimetry.
7 36 Appendix A 359 Technical Transmitted power density does not depend on depth! The formula given is not consistent with equation 2.9 (l. 80).  Most likely SAR is meant here.
Please change formula accordingly (eg. SAR(z)=…)
This has been amended as suggested.
7 37 Appendix A 388-391 Technical The error introduced by the step function has to be addressed in order to justify the decision for using it.
Please change the part accordingly
The perspective has been noted. The step function for 4cm^2 has been removed.
7 38 Appendix A 443-448 Technical Formula based on unpublished work and “empirical equations” without any further explanation are not reasonable to the reader
Please add a more detailed explanation
Full citation is now provided.
7 39 Appendix A 449-450 Technical Below 1s there is a fixed value for SA although the sqrt(t)-rule should be valid below 1s as well! To my knowledge, applying Sqrt(t-1) is not based on scientific results.
Apply sqrt(t) rule instead a sqrt(t-1) with constant values below 1s or give a reasonable explanation for choosing the 1s limit
 Foster, Kenneth R., Marvin C. Ziskin, and Quirino Balzano. "Thermal modeling for the next generation of radiofrequency exposure limits: Commentary." Health physics 113.1 (2017): 41-53 
This formula and explanation have now been amended to account for this.
7 40 Appendix A 462 General According to the text SA is not required below 400MHz.  This is based on unpublished (and not peer reviewed) work only.
Please add a more detailed justification or specify the SA limits below 400 MHz as well
The published paper has now been cited.
7 41 Appendix A 492-502 Technical   No comment given.
7 42 Appendix A 561-563 General Why is that?
Please explain more detailed or cite relevant work
Further explanation has now been provided.
7 43 Main 761 Technical The Formula is too simple as it only applies to the homogenous case. The different possible pathways of the current through tissue with different conductivity results in different current densities. The text doesn’t explain if this is considered by using the “effective section area”
Please add an explanation for „effective section area“ and discuss how the different conductivities are incorporated in this evaluation
This phrase has now been removed.
7 44 Appendix A 803-805 Technical It is stated, that the time function for Htr are more conservative than for the time function of SA. This actually seems not to be the case
 Please apply the sqrt(t) rule instead of the sqrt(t-1) rule and apply this rule for times below 1s. Reduce the limit for Htr at least by a factor of 2.5

This is noted, and we have revised the time function in the new version accordingly.
7 45 Appendix A 809-813 General Citation needed
Please cite relevant work
It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text.
7 46 Appendix B 1-410 General Inadequate citations. There are whole paragraphs without any citation (eg p2.1 p.4 p.5 and p.7). It is not possible for the reader to check the statements made by ICNIRP.  It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
7 47 Appendix B 41-46 General ICNIRP states that “it is important to consider research across a range of study types in order to arrive at useful conclusions concerning the relation between radiofrequency EMF exposure and adverse health effects”. However, the discussion seems to be “biased” towards studies showing no effect. Annex B insufficiently explains why certain studies showing effects are not taken into account. The argument that studies showing effect are inconsistent with other findings also applies to the studies that show no effect. For the reader it is important to understand why specific studies showing no effect have not been considered for setting guidelines.
Please expand the discussion and explain why studies have been not taken into account.
As described in the text, Apendix B provides an indication of the conclusions of the review, and is not designed to provide full explanation of the decisions made. Based on the public consultation process, key areas of interest have now been described and referenced more fully. The reader will need to consult the reviews that are referenced for further information.
8 1 Main 523 Technical  “either 4 cm2 (>6 to 30 GHz) or 1 cm2 (>30 to 300 GHz)”
 Decrease the averaging area.
Recent publications (Neufeld and Kuster, 2018; Neufeld et al, 2018) show that this averaging area is too large for narrow beams, as those expected in 5G technology, allowing the temperature at the surface of the body to increase considerably.  We do agree with the notion that the power density averaging area should decrease with increasing frequency. However, a step function at 30 GHz makes compliance testing very difficult. Therefore, we recommend a reduction of the averaging area as a function. Please note that the function is also a function of the limit.  
It can be calculated that a beam with a Gaussian profile of 1 mm width, normally incident on the skin, can induce a surface temperature rise of 3.9°C instead of the 1°C produced by a plane wave with the same incident power density averaged over 4 cm^2. The temperature rise can become even higher, if a lower perfusion rate is assumed, since the 102 ml/min/kg perfusion rate assumed in the document is rather high: the energy is absorbed superficially on the skin in non-perfused layers, therefore a three-fold lower effective perfusion rate would be more reasonable. Then, in the above example the localized temperature rise would be about 4.1°C (i.e., 5 % higher).
References:
Neufeld et al. 2018. Discussion on consistent spatial and time averaging restrictions within the electromagnetic exposure safety framework. Bioelectromagnetics. Submitted.
Neufeld and Kuster, „Systematic derivation of safety limits for time varying 5G radiofrequency exposure based on analytical models and thermal dose,“ Health Physics, Sept. 2018.
Neufeld et al., "Theoretical and Numerical Assessment of Maximally Allowable Power-Density Averaging Area for Conservative Electromagnetic Exposure Assessment Above GHz," Bioelectromagnetics. Submitted.
The cited literature has been considered, but as argued in the guidelines, we beieve that the spatial averaging is appropriate for health protection.
8 2 Main 553 Technical  „less than 1 second“
 Introduce a limit to the maximum energy density per pulse.
Introducing a constant energy density below 1 s allows for ultrashort pulses to deliver high amounts of energy and increase the temperature considerably. It is recommended to introduce a limit to the maximum energy density per pulse, taking into account the work of Neufeld et al.
Reference:
Neufeld et al., “Discussion on consistent spatial and time averaging restrictions within the electromagnetic exposure safety framework,” Bioelectromagnetics. 2018. Submitted.
This has been amended as suggested.
8 3 Main 156 Editorial In the third column of Table 1, line 10, the entry is „radiant exposure“, instead of the units.
Change to „joule per square meter“
Consistency
The tables have been completely rewritten, and this issue resolved.
8 4 Main 596 Technical  „square“
 Change the shape of the surface for the averaging of the incident power density for frequencies above 6 GHz from a square to a circle of the same area. On non-planar evaluation surfaces, the shape of the averaging area would then be determined by intersecting it with a sphere with its center at the evaluation point and a radius that maintains the averaging area.
Defining the averaging area as a square leads to problems with reproducibility, because the square is not rotationally symmetric. A square requires the definition of the orientation of its edges around its surface normal. This definition is arbitrary and will lead to ambiguities when assessing compliance in practical situations. Furthermore, a square does not conform to a non-planar surface. The definition that we propose is free of these problems. Despite the problem of definition, a sphere intersection will also substantially reduce the effort required for compliance testing.
We do not believe that there is sufficient requirement to change this to a circle (although it is clearly another good option).
8 5 Appendix A 79 Technical  “power and energy densities”
„power density“
 Equation 2.9 is the averaged power density, not the energy density.
This has been amended as suggested.
8 6 Appendix A 94 Technical  „absolute strength of the Poynting vector“
 „modulus of the complex Poynting vector“
 Change to technically correct wording 
This has been amended as suggested.
8 7 Appendix A 733-736   Technical  “Recent research has shown that the normal angle results in the maximum transmitted power density (greatest absorption) and is used for calculating the reference levels (Li et al., 2018).”
 This statement is incorrect and should be replaced by the conclusions from the publication by Samaras et al. (see below).
 The angle that corresponds to maximum transmittance at TM mode cannot correspond to normal incidence. This reference cannot be used to support the incorrect assumption that normal incidence is the worst case. The Li 2018 presentation is not published in a peer-reviewed journal, and the paper by Samaras et al comes to a different conclusion.
Reference:
Samaras and Kuster. 2018. Power transmitted to the body as a function of angle of incidence and polarization at frequencies >6GHz and its relevance for standardization. Bioelectromagnetics. Submitted.     
This has now been clarified more adequately.
8 8 Main 122 Editorial „polarized molecules“
„polar molecules“
“polarized” means that something caused the substance to acquire polarity. Water is a polar molecule meaning that its polarity is inherent, not acquired.
This has been amended as suggested.
8 9 Main 71 Editorial „These quantities cannot be easily measured“
„These quantities may be difficult to evaluate“
Induced quantities, such as SAR, have become relatively easy to evaluate. This the reason for changing to “may be difficult”. Also, changed “measure” to “evaluate” as a more G term, as numerical methods are well used and standardized.
We have kept this description as it is to emphasise that it is more difficult to measure SAR than field strength.
8 10 Main 89 Editorial „which may include particularly vulnerable groups or individuals“
„which includes particularly vulnerable groups or individuals “
 “G public” includes everyone, so “may include” is incorrect.
Note that your statement would only be true if there in fact vulnerable people (in terms of EMF of the magnitude considered), but there is no evidence of this.
8 11 Main 156 Technical „Htr
“U
tr
It is confusing to use H for energy density and magnetic field. Use a different symbol (e.g., U). It should be a scalar, not a vector (i.e., not bold).
This has now been changed to 'U' (and 'transmitted' changed to 'absorbed').
8 12 Main 429 General „To be compliant with the present guidelines, exposure cannot exceed any of the restrictions described below, nor those for the 100 kHz – 10 MHz range of the ICNIRP (2010) low frequency guidelines“
Please specify which limits to apply where there are differences between ICNIRP 2018 and ICNIRP 2010. The limits should be consistent and in one single standard.  Also replace “cannot” with “must not”.
Reference levels in ICNIRP 2018 and 2010 are different in some cases. 
The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
8 13 Main 590 Technical Headings of Tables 2 and 3, and Tables 5 and 6, are misleading.
Delete ">= 6 minutes" and "< 6 minutes" from the headings.
The two sets of limits should always apply together. The SA and energy density restrictions are limiting when transmitting short pulses, and the SAR and power density restrictions are limiting when transmitting continuous signals, but both sets of limits apply regardless of the type of signal. This should be made clear in the text also.
The tables have been completely rewritten, and this issue resolved.
8 14 Main 813 Technical „Simultaneous exposure to multiple frequency fields”
Add guidance if a person is exposed simultaneously to signals that fall under both > 6 minutes and < 6 minutes.
There is no guidance if a person is exposed simultaneously to signals that fall under both > 6 minutes and < 6 minutes.
This has now been added.
8 15 Main 140 Technical „10-g cubical mass“
Add guidance on what to do if the body surface is not flat.
A cube does not conform to a non-flat surface, resulting in air in the volume or tissue that is not considered. IEC 62704-1 includes considerations on what to do about this problem.  Adapting the surface of the cube to the curved SAM shell is common practice in compliance testing standards. However, problems still remain dealing with the lack of rotational symmetry of a cube. A better approach is to use a sphere whose center is at the point of interest and radius is set such that 10 g is included. This would be a hemisphere for a point on a flat surface.
This issue is outside the scope of the guidelines, and will need to be considered in technical (product safety) standards.
8 16 Main 374 Technical „From 6 to 10 GHz there may still be significant absorption in the subcutaneous tissue. “
Extend the frequency range for SAR as a basic restriction to 10 GHz.
 The above statement supports the need to extend the frequency range of SAR as a basic restriction to 10 GHz. Furthermore, the paper of Carrasco et al. (see below) outlines the problems with using power density in the reactive near field and supports extending SAR to 10 GHz.  IEC draft 62209-1528 has already included procedures, sources and validation for frequencies from 6 – 10 GHz. The work of Pfeifer et al and Pokovic et al (see below) demonstrate that SAR measurements are achievable within reasonable uncertainty bounds at these frequencies.
References:
Pfeifer et al., “Total field reconstruction in the near field using pseudo-vector E-field measurements,” IEEE Transactions on Electromagnetic Compatibility, June 2018.
K. Pokovic et al., "Methods and Instrumentation for Reliable Experimental SAR Assessment at 6 – 10 GHz," BioEM Meeting, Hangzhou China, 2017.
Carrasco et al., "Exposure assessment of portable wireless devices above 6 GHz," Radiation Protection Dosimetry, October 2018.
This notion was considered, but 6 GHz was thought to be preferable.
8 17 Main 481 Editorial „(5 C in Type-1 tissue and 2 C in Type-2 tissue)“
“(2 C in Type-2 tissue)”
This section talks about the Head and Torso only.
As described in the text, the Head and Torso region contains both Type 1 and Type 2 tissue. This has not been amended.
8 18 Main 522 Editorial „200 W m-2
Keep on same line
This is broken across 2 lines.
This has been amended as suggested.
8 19 Main 715 Technical „no reference levels are provided for reactive near-field exposure conditions within this frequency range “
Add reference levels for near-field exposure, or extend SAR as a basic restriction above 6 GHz. An alternative is to recommend compliance testing based on transmitted power.
Exposure to reactive near fields is likely to be common for 5G devices and the basic restrictions may be difficult to measure. This is supported by the paper of Carrasco et al (see below). Currently there are no measurement systems available that measure the transmitted power density. This makes it very difficult to demonstrate compliance with EM exposure. It is also important to point out that the incident power density flux crossing the surface is not always conservative as a proxy for transmitted power (see Samaras et al. 2018).
References:
Samaras and Kuster, “Power transmitted to the body as a function of angle of incidence and polarization at frequencies > 6 GHz and its relevance for standardization.” Bioelectromagnetics. 2018. Submitted.
Carrasco et al., "Exposure assessment of portable wireless devices above 6 GHz," Radiation Protection Dosimetry, October 2018.
Further justification for the set of rules relating to near-field conditions has now been added. Your concerns are noted.
8 20 Main 156 Editorial „Seq, Sinc, Htr, Str
Use scalar rather than vector quantities.
The limits are defined as scalar values, so the symbols should also be scalars (without bold)
The font used for vector/scalar values has now been clarified, and used consistently through the documents.
8
21 Appendix A  171-172 Technical „As described above, power absorption is confined within the surface tissues at frequencies above 6 GHz. This may lead to thermoregulatory response initiation time being reduced.“
Remove the sentence.
No reference is provided to support this statement. In addition, it is in contradiction with the work of Christ et al (see below). At the surface of the body (skin) there are numerous heat receptors sending signals to the hypothalamus. Reference: Christ et al., “RFInduced Temperature Increase in a Stratified Model of the Skin for Plane-Wave Exposure at 6 to 100 GHz.” Bioelectromagnetics. 2018. Submitted.
Note that your comment is consistent with what was said in the consultation document. However, the wording has been changed to make it clearer anyway.
8 22 Appendix A  672 Technical „Conversely, the only study using the internationally standardized child models shows only a modest increase of 15 % at most (Nagaoka et al., 2008). “
Remove the sentence.
These are scaled voxel models of Japanese children, i.e., (a) they are not models of real children but scaled down from adult Japanese models; (b) they are not globally valid; and (c) they should not be considered „standardized“ unless there is an international standard document describing who standardized them, how, and when.
Further clarification of this is provided in the revised guidelines.
8 23 Appendix A  412 Technical The Sasaki study is an important paper. Latest studies taking into considerations detailed skin properties, showed that simplifications result in insufficient conclusions. The most important one is that the layered model considered did not take into account the epidermis structure, i.e., did not differentiate between stratum corneum and viable epidermis. This is important, as it increases power transmission at higher frequencies (stratum corneum acts as a matching layer). The thermal parameters used in the Sasaki study Gly yield a lower temperature increase than the ones in published databases. These different parameters (and using fat instead of muscle as terminating layer) explain the remaining differences to Sasaki even without the stratum corneum and with mixed thermal boundaries instead of the adiabatic ones.
Consider newer results about the heating factor, taking into account more detailed models.
It can be shown that at frequencies above 15 GHz, the stratum corneum (SC) acts as an impedance matching layer for the incident electromagnetic fields. Considerably increased transmission of the energy can be observed for thick layers of the SC (0.36 – 0.70 mm), which occur in the palms. The worst-case heat conversion factor for normal incidence occurs at 60 GHz for a thick SC and is 0.04 K/(W/m^2).
References:
Christ et al. 2018. RF-Induced Temperature Increase in a Stratified Model of the Skin for Plane-Wave Exposure at 6 to 100 GHz. Bioelectromagnetics. Submitted.
Samaras and Kuster. 2018. Power transmitted to the body as a function of angle of incidence and polarization at frequencies > 6GHz and its relevance for standardization. Bioelectromagnetics. Submitted.
Although computationally possible, there is currently no evidence that this is an issue in realistic human exposure scenarios. In terms of obliquely incident power density, we have now commented on this in the revised version.
8 24 Appendix A 415 Technical This may not be so conservative after all, considering the limitations of the study by Sasaki et al (2017) and the ambiguity about the transmitted power density at oblique incidence, especially for TM polarization.
Consider newer results about the heating factor, taking into account more detailed models.
Conservativeness of reference levels.
See response to 8.23 above.
8 25 Main 156 Technical Missing references
The following references should be added to the guidelines (manuscripts available on request):
Neufeld and Kuster, ”Systematic derivation of safety limits for time varying 5G radiofrequency exposure based on analytical models and thermal dose,“ Health Physics, Sept. 2018.
Christ et al., “RF-Induced Temperature Increase in a Stratified Model of the Skin for Plane-Wave Exposure at 6 to 100 GHz.” Bioelectromagnetics. 2018. Submitted.
Samaras and Kuster, “Power transmitted to the body as a function of angle of incidence and polarization at frequencies > 6 GHz and its relevance for standardization.” Bioelectromagnetics. 2018. Submitted.
Neufeld et al., “Discussion on consistent spatial and time averaging restrictions within the electromagnetic exposure safety framework,” Bioelectromagnetics. 2018. Submitted.
Pfeifer et al., “Total field reconstruction in the near field using pseudo-vector E-field measurements,” IEEE Transactions on Electromagnetic Compatibility, June 2018.
Pokovic et al., "Methods and Instrumentation for Reliable Experimental SAR Assessment at 6 – 10 GHz," BioEM Meeting, Hangzhou China, 2017.
Carrasco et al., "Exposure assessment of portable wireless devices above 6 GHz," Radiation Protection Dosimetry, October 2018.
Neufeld et al., "Theoretical and Numerical Assessment of Maximally Allowable Power-Density Averaging Area for Conservative Electromagnetic Exposure Assessment Above GHz," Bioelectromagnetics. Submitted.
References were added where relevant.
9 1 Main 595 Technical The change from averaging the SAR over a contiguous region to a 10 g cube is a significant step backwards, when the dosimetry should be moving forwards. A cube, as opposed to a contiguous (connected) region, is a very poor way to represent localised SAR, particularly at higher frequencies when absorption is more surface based. I imagine the change has been made purely because averaging over a cube is easier to do, regardless of accuracy.
Average over 10 g contiguous region. The averaging volume should be kept the same as ICNIRP 1998
Reasons for using a cube are provided in Apendix A. Note that the cube provides a better estimate of temperature rise, and the issue of higher frequencies is accounted for with the use of absorbed power density.
10 1 Main 84-88 Technical Only two groups of people are considered, we would prefer three groups: occupational as defined in the text, G public as defined and vulnerable people’s group.
Insert your proposed change.
 Insert vulnerable persons to account for schools (pupils and students), hospitals and health care places (illness bring fragility to any type of radiations), old people who have lower thermoregulation capacities, and rural places where people may be exposed but have no means to protect themselves. This would also put a constrain to physical location of some equipements near these places. 
This comment has been repeated and is not addressed again.
10 2 Main 95 General A pregnant woman is vulnerable and should be place in the third group The rationale for the treatment of a pregnant woman has been described in Apendix A.
10 3 Main 112-117 Technical The phrasing is not clear regarding power and energy definition
As the field propagates away from a source, it transfers power (in watt or power per unit of surface) from its source to a receiving object. When the said power is applied  during a time t the receiving object absorbs an equivalent energy (in joule which is power x time).
The phrasing of this definition is important for the remainder of the text. It is the application oft he power during time that brings heat and allows for changes and consequences in the body.
This comment has been repeated and is not addressed again.
10 4 Main 119-120 Technical There is a need of clearly stating that EMF is composed of electric and magnetic field. Not only electric field E This comment has been repeated and is not addressed again.
10 5 Main 125 Technical The effect of induced electric field on electrons and molecules may lead to oxidyzation. This phenomenon is known to cause certain health problems but not mentioned here. In particular, in appendix B, impacts on calcium ion dynamics have been mentioned.   Even if there is currently no evidence, it should be mentioned either here or in Appendix B. Another possible effect on blood is mentioned in the article of M. Havas (see comment 13 below). This needs tob e discussed as prolonged exposure has some damaging affects.  The guidelines consider adverse health effects, rather than biological effects (unless shown to result in adverse health effects). This is described in the text.
10 6 Main 156 Technical Assumed tissue density and average body density are not mentioned in the table nor is the conductivity. (see also line 357-364).
Insert your proposed change.
Tissue mass is considered for dosimetric specification. But tissue/body part density varies depending on which part is considered. Bones are different from skin, cells etc. And the EMF propages through different media.
This is clarified in Apendix A.
10 7 Main 284-285 Technical Eyes are sensitive as they mainly contain water. Even if EMF does not penetrate, it can induce eye dryness because of superficial dryness caused by heat. This should be revisited in the text.  This is considered in Apendix B.
10 8 Main 371 Technical There is a need of reassessing this sentence. When a high frequency reaches the body, it is predominantly absorbed by superficial tissues. However, it can go deaper by being attenuated and with lower frequencies.  As such other effects could  be found such as nerve excitation for lower frequencies transmitted by attenuation effect. The studies mentioned do not go further but it should be clearly said that this is a possibility that has not been investigated.  We do not believe that the intent of the sentence is affected by the comment made here and so have not changed the text.
10 9 Main 458-466 Technical On the risk factor, please include vulnerable people.
Insert your proposed change.
By including vulnerable people, it will force emf equipment to be put away from these people/places.
This comment has been repeated and is not addressed again.
10 10 Main 502 Technical Why 400 MHz instead of 100 Mhz as stated in the concerned range of frequency
Replace 400 by 100
This is clarified in Apendix A.
10 11 Main 532 – 532 and 552 Technical There is need of clarifying that  transmitted energy as average transmitted power over time. For example for G public 20 W/m2 over 2s gives 40W/m2. However using the other formula for energy gives something much above the 40W/m2 (in KJ/m2).  (see also comment 3).  Discrepancies between the different restrictions have now been removed.
10 12 Main 681-718 Technical Best to put frequency f in the same units in all Tables otherwise it is confusing to have it in MHz and after in GHz. Choose GHz as it is most used We believe that it is easier to read as it currently is.
10 13 Main 866 Technical Additional reference
Magda Havas, Radiation from wireless technology affects the blood, the heart and the autonomic nervous systems. Rev. Environ. Healt 2013; 28(2-3): 75-84.
Magda Havas,  Electromagnetic Hypersensitivity: Biological Effects of Dirty Electricity with Emphasis on Diabetes and Multiple Sclerosis. Electromagnetic Biology and Medicine, 25: 259–268, 2006
In these articles, vulnerable persons such as pupils are cited and also effect on the blood and nervous system. Also effects of health such as diabete.
We have noted these references.
10 14 Appendix A 69-70 Technical It is assumed that tissue has the same density as water which is not true as the dry part of a tissue is not negligable; Water is is Gly assumed be around 70-80% of the body.  Noted.
10 15 Appendix A 80 Technical Please correct the equation: the correct writing is given below.
Str=1/A ∬_A▒(∫▒ρ(x,y,z)SAR(x,y,z)dz)  dxdy, where  SAR(x,y,z)   and  ρ(x,y,z) are  the SAR and the density of a point (element of body)  located at cubic coordinates x,y,z. 
This has been amended as suggested.
10 16 Main Not Given General Several studies seem to have methodological problems. It might interesting to help the scientist in setting what is acceptable in terms of methodology. This issue is very important for human being and ist environnement and is worth this exercice.  This is beyond the scope of the guidelines.
11 1 Main All General We would like to thank and congratulate ICNIRP on providing these proposals for updated guidelines, as well as for seeking input through this consultation process as part of their development. The inclusion of appendices with details of the dosimetry and health rationales for the guidelines is particularly welcome, and provides for increased transparency over the previous guidelines
Timing is a key consideration for the updated guidelines and, while there is no evidence of harm resulting from people not being protected by the current guidelines, there are an increasing number of questions being raised by new dosimetry studies that need to be addressed. Moreover, the imminent widespread use of mm-wave frequencies makes it especially important to update and provide improved justification for the guidelines at those frequencies.
We encourage ICNIRP to address the comments from this consultation carefully and to proceed with the publication of updated guidelines.
The guidelines are needed
No response required.
11 2 Main All General Referencing and providing support for the decisions/rationale in the guidelines is a difficult area to strike a balance with. As explained in the documents, the main supporting health reviews are those by WHO and SCENIHR, such that there is no need to replicate those reviews in the document, but there still needs to be a robust and largely self-contained narrative in the guidelines themselves. This narrative is largely in place but it may still be helpful to look again at the places where important aspects of the guidelines and appendices seem to be supported by just one reference.
ICNIRP should consider including more references or supporting explanation at various points in the document. See specific comments for the details
Based on particular requests during the public consultation, we have indeed added additional references for key areas. However, we are not able to provide a formal treatment of the evaluation process and so must refer the interested reader to the cited review documents (which are now more extensive).
11 3 Main All General It may be helpful to those who have to consider adopting the new guidelines (and moving away from earlier ones), if a short document summarising the changes to the restrictions, and the reasons for those changes, is provided. Possibly, that could be in a tabular format.
Consider issuing an accompanying document to explain/justify the changes succinctly
We are working on providing that as a standalone document to be released at the same time as the guidelines.
11 4 Main All General As an international guidelines document it would be helpful for ICNIRP to be consistent in its use of units and in particular to use SI units and prefixes as this is the internationally agreed standard system for science. For example the SI "mm" should be used in preference to the non-SI "cm". Similarly it would be helpful to readers to be consistent in the use of unit symbols, rather than a mix of units expressed as symbols and words.
Replace "cm" with "mm" or "m" throughout. Replace "degrees centigrade" (non-standard unit) with "°C". Replace ²Ohm² with "W". If units are written in full, it should be noted that all except Celsius are written in lower case.
To improve consistency and clarity all units should be expressed according to the internationally agreed scientific convention, the Système International d'Unités (SI).
The documents have been amended accordingly (except where, in a few instances, we believed that non-SI terms would make it easier for the non-expert to understand).
11 5 Main 17 General There is potential for confusion in applying the reference levels in the overlapping frequency regions of the low and high frequency guidelines.
Insert additional advice on application of the reference levels in the 100 kHz – 10 MHz region, for example state that both sets of guidelines are to be applied one after another.
The overlapping reference levels are based on different metrics and therefore differ substantially. In practice it is not clear which reference level to use in this frequency range.
The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
11 6 Main 35 Editorial Suggestion of word change.
Replace "treats" with the word "considers".
The word "treats" inplies that ICNIRP is applying a treatment. 
We have retained the word 'treats', as it has a more active connotation than 'considers', and is very commonly used independent of the sense of medical 'treatment'.
11 7 Main 104 General The term "additional precautionary measures" is potentially confusing.
Suggest change term to "further reduction factors".
This will avoid the misinterpretation of the term precautionary measures , which is poorly defined and therefore subject to different meanings, depending on context. 
We agree with your point, and have reworded this so as to make it clear that 'precautionary measures' are not needed, rather than to say that ICNIRP has used precautionary measures. This allows us to comment on something that people are interested in (and may be looking for in the guidelines), without suggesting that our conservative steps are equivvalent to them.
11 8 Main 117 Technical Missing RF – body interaction phenomenon.
Include the term "absorption".
Apart from other phenonmenons such as reflection and transmission, the EMF is also absorbed, hence it seems necessary to include this effect.
This has been amended as suggested.
11 9 Main 129 Editorial Spelling.
Change "dialectric" to  "dielectric"
This has been amended as suggested.
11 10 Main 133-138  Technical The text, whilst not technically incorrect, is misleading. It gives the impression that there is a breakpoint in absorption characteristics around 6 GHz. In fact penetration depth changes gradually over a wide range of frequencies, as discussed in Appendix A, and 6 GHz is selected as an arbitrary breakpoint for the purposes of setting guidelines. This should be clearly stated. In addition, greater justification should be provided for the selection of 6 GHz as the breakpoint frequency used in the guidance. The frequency selected has not been too critical in the past as there have been few uses in the vicinity of this frequency. However, new technologies, such as 5G will result in widespread use of similar devices operating both below and above 6 GHz, so it is important to be clear on this issue. (See also comment at lines 380-383).
Include a clear statement that 6 GHz is selected for the purposes of convenience, rather than a reflection of any underlying frequency-specific change in absorption characteristics. In addition, include some justification for the selection of 6 GHz, rather than say 5 GHz or 10 GHz.
Appendix A. 
This has been amended as suggested, and further information provided in Apendix A.
11 11 Main 156 Technical The symbol for the quantity of transmitted energy density (Htr) could be confused with a quantity relating to magnetic field strength.
Consider using a different symbol.
It is understood that in the optical part of the electromagnetic spectrum radiant exposure is given the symbol H, however this link need not be preserved in the RF part of the spectrum, and indeed may cause confusion in the new guidelines. It is suggested that transmitted energy density should be given an alternative symbol.
This has now been changed to 'U' (and 'transmitted' changed to 'absorbed').
11 12 Main 164 Editorial Make referencing styles consistent. SCENIHR is not spelt out, but WHO is at the moment.
Write sentence as "review from the World Health Organization that will be released as a Technical Document in the near future (WHO, 2014) and by the European Commission’s Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR, 2015)." Also change format of reference at 991 to become "WHO (2014) ..."
As per comment. 
This has been amended as suggested.
11 13 Main 184-187  Editorial The sentence is long and difficult to follow.
Suggest that it is broken into shorter sentences. 
We believe it is best as one sentence and so have not changed this.
11 14 Main 194,203,292,302, 391 General There are several points in the guidelines where important principles and decisions are supported by only one reference
Add more references or explain why the provided reference is considered to be sufficiently authoritative on its own
See G comment about the need to support and justify the guidelines as robustly as possible based on the evidence that is available
To do this fully would require the equivvalent of a textbook for each section. As described in the document, only a summary is provided here, with further details given in the appendices.
11 15 Main 200 Editorial Suggest adding reference to Appendix B.
Use the words "also see Appendix B" in the brackets.
To avoid saying this repetitively, this is stated early on in the document where the structure of the document is described.
11 16 Main 201-215  General Membrane permeabilisation requires extremely strong internal field strengths that are well in excess of those that would cause thermal effects. It could never be a limiting factor and there is therefore no need to consider it in the guidelines document.
Delete this section from the guidelines document. If it is necessary to discuss it at all, it should be restricted to Appendix B.
Appendix B. 
This is provided for completeness (we acknowledge your point).
11 17 Main 256 Editorial Suggested word change.
"readily" should be replaced with "rapidly".
This sentence has been removed completely.
11 18 Main 350-353  General It is not necessary to describe reversible male infertility as insufficient to impair health. Exposures of sufficient magnitude to induce reversible impairment of male fertility are most likely to occur in an occupational setting. Occupational exposures are likely to be repeated on a regular basis. Hence, whilst the effect of a single exposure may be reversible given sufficient recovery time, repeated occupational exposures would not allow time for recovery and the effect would be a decrease in male fertility that would persist throughout the employment. Male infertility is a recognised adverse health effect.
The persistent reduction in male fertility that would result from repeated occupational exposures should be recognised and the proposed guidelines revised to prevent this. 
We agree, but there is no evidence that chronic exposures result in meaningful reductions in male fertility. If they had been, then we agree that the guidelines would need to incorporate this.
11 19 Main 380-383  Technical It may be helpful to provide this explanation of the rationale for choosing 6 GHz as a break-point earlier in the document, e.g. around lines 133-138.
Consider overall organization of the narrative around selection of the 6 GHz break-point throughout the document. Cross-referencing at lines 133-138 to lines 380 to 383 may help
This is clarified in Apendix A.
11 20 Main 394 Editorial Improve precision of text
Change "value" to "threshold" (to which the margin will be applied later on for basic restrictions/reference levels).
Note that this is a value that is used to represent the threshold (rather than being the threshold), and so we have not changed the terminology.
11 21 Main 397, 400  Technical The phrase "some types of exposure" should be given further explanation perhaps by means of example. The same comment applies at Line 400.  This is meant to indicate the variability of the situation, rather than to explain the sources of variability (and so has been kept as it is).
11 22 Main 436 Editorial Suggested change for the word "relation".
Replace with "relationship".
Better use of English. 
As 'relation' tends to infer not only a link, but a particular pattern of linkage, this has been retained.
11 23 Main 442-445 General It would be helpful here to provide supporting references .  It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text.
11 24 Main 455 Editorial Text adjustment.
Suggest using another word for "modification", or expansion of what this means.
The word "modification" is unclear and the sentence regarding modification of blood perfusion needs clarification.  It probably refers to changes in vasculature affecting blood flow. 
This has been changed to make it clear that this does not refer to a particular form of mediation, but rather refers to anything that 'changes' blood flow and sweating.
11 25 Main 468-470  General The text makes an important assertion that should be ideally be backed-up with evidence.
Provide more explanation and/or references as to justify why these two aspects of uncertainty are considered to have reduced
This would need a detailed description of a number of studies, which is beyond the scope of the guidelines.
11 26 Main 522-526 Editorial This is a long and complicated sentence
Consider breaking-up the sentence to make the text easier to understand
This is a specification, and we believe needs to be kept as one sentence.
11 27 Main 537 General Change "value" to "threshold". Sometimes it seems "threshold" is referred as "value" or 'level' or "limit". "Threshold" is when the health effect is observed and no margins have been applied (e.g. factor of 2 and 10 for occupational and public respectively), while exposure limit values refer to basic restrictions and thus when a margin has already been applied. If this is the case then suggest using the same word throughout Note that the exposure level is not meant to be the threshold, but rather is an exposure level set to avoid the adverse health effect threshold being exceeded. Thus we use 'level' to refer to the exposure, and 'threshold' to refer to the health effect. However, the terms were not always used consistently and so have been amended.
11 28 Main 564 Editorial Repetition of text.
Removal of repeated text.
Duplicated text in lines 582-585.
This has been amended as suggested.
11 29 Main 567-569  Technical The suggestion that workers should be provided with a means of verifying their core body temperature is inappropriate. This implies risk control at the individual level and as a matter of personal responsibility. This is contrary to accepted principles of risk mitigation, which require an established hierarchy of risk control measures to be implemented, with priority clearly given to collective protection over individual protection.
Remove the suggestion of workers verifying core body temperature and replace with recommendation for employers to undertake a proper risk assesment that accounts for all other factors that can affect core body temperature, followed by implementation of appropriate and effective risk mitigation
This is a recommendation from ACGIH 2017, and does not replace the need for an appropriate risk assessment and risk training. We believe it is prudent to ask for this.
11 30 Main 597 Technical The equivalent incident plane wave power density has been mentioned above but there hasn't been any explanation about what is meant by "equivalent". Is it assumed that the reader knows? This has now been defined.
11 31 Main 610 General It is noted that the new reference levels have been relaxed in the 100 kHz to 20 MHz range when comparing with those in the 1998 guidelines.
Include a clear statement to explain why the levels are now more relaxed in this range.
For instance does this result from changes in the basic restrictions and/or refinements in the dosimetric models? Has dosimetric uncertainty reduced so that smaller reduction factors can be accommodated now in developing the reference levels?
This is clarified in Apendix A.
11 32 Main 623-625 General It would be helpful to provide supporting references It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
11 33 Main 643 Editorial Word addition.
Add the word "distances" after "as a rough guide".
This section has been rewritten to improve clarity.
11 34 Main 648-649 General Clarify what is meant by "the compliance community".
Change "compliance community" to "technical standards bodies and users". 
This has been amended as suggested.
11 35 Main 656 General How small are the differences?
Delete "small" and clarify meaning.
Small is subjective, the request is to explain what judgements are being made here more clearly. Does it even matter whether the difference is small or large if there is no health effect?
This has been amended as suggested.
11 36 Main 664-667  General It would be helpful to provide references here.  It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
11 37 Main 675-678 General Repetition from previous paragraph(lines 656 to 660).
Bring the text together and avoid repetition.
This section has been rewritten to improve clarity.
11 38 Main 683-695  Technical The footnotes to table 4 are confusing. Note 3 indicates that for frequencies up to 2 GHz it is only necessary to demonstrate compliance with one reference level. Note # then clarifies that for freqencies up to 400 MHz for reactive and radiative near field exposures it will be necessary to demonstrate compliance with the reference levels for both E- and H-fields. In practice, almost all occupational exposures that are assessed are likely to occur in the reactive and radiative near fields, but it is likely that the requirement will be widely misunderstood with assessment made against only one reference level.
The footnotes should be redrafted to make the requirements for near field assessments much clearer. 
The tables have been completely rewritten, and this issue resolved.
11 39 Main 752 Editorial Additional words are required.
Insert "such as those that are".
Additional words required. 
This has been amended as suggested.
11 40 Main 899 Editorial Line space required.
Insert line between references. 
This has been amended as suggested.
11 41 Appendix A 38 Editorial r is actually a vector and the increment should be a volume
E_ave = sqrt( 1/V int_V{ |E(x,y,z)|^2 }dx*dy*dz)
This has been amended as suggested.
11 42 Appendix A 65 Technical "Weight" is the incorrect technical term.
Replace "weight" with "mass" here and elsewhere in the three documents.
Nothing is gained in terms of clarity by using the wrong term.
This has been amended as suggested.
11 43 Appendix A 67-70 Editorial It is not actually divided by 10 grams but by the weight of a 2.15^3 cm^3 cube of tissue, so wording above perhaps should be along the lines of:
"SAR10g is defined as the total power absorbed in a 10 g cubic volume divided by its mass: [...]
Note the denominator is not exactly equal to 10g, as a 10 g volume [...] defined as [..]." 
This has been amended as suggested.
11 44 Appendix A 76 Editorial "0.4 mm at 6 GHz" is inconsistent with Table 3.1 which says penetration depth is 0.23mm at 300 GHz.
"0.2 mm at 6 GHz".
This has been amended as suggested.
11 45 Appendix A 85 Technical Shouldn't the RHS of this equation be a closed surface integral if we are using Poynting vector? The equation is correct. The human body is very lossy in higher frequencies where the APD is applied. Assuming this condition (lossy material), the closed surface integration becomes the limited surface integration. This is also discussed in [Appendix B of  [Li, 2019]].
11 46 Appendix A 87 Editorial "with the normal direction of the integral area 𝐴" is confusing.
"with its direction normal to the integral area".
This has been revised as suggested.
11 47 Appendix A 95 Technical Aren't E and H here the unperturbed fields and the ones in Eqn 2.10 the perturbed/internal ones? If this is the case then maybe best to specify this? This has been checked and we are happy with the text as written.
11 48 Appendix A 99 Editorial The main document should refer to this appendix when first mentioning the equivalent incident power density. The main document does refer to Apendix A, but not each time it uses information from Apendix A. This is to avoid having to reference Apendix A too often.
11 49 Appendix A 102 Editorial It  would be useful to have some of the information from p.18 mentioned here.
Add the sentence of p 18 here:
"The reflection coefficient is derived from the electrical properties of the surface tissues, shape of the body surface, incident angle and polarization.” (line 732).
This has been revised as suggested.
11 50 Appendix A 113 Editorial Superfluous words.
Delete "at the".
Remove otherwise sentence doesn’t make sense.
This sentence has been removed completely.
11 51 Appendix A 164-165 Editorial Revision of wording.
Write as"...naked body exposed to a plane wave at 65 ..."
Otherwise current sentence doesn’t make sense.
This has been amended as suggested.
11 52 Appendix A 207 Technical Clause after semicolon seems to be about metabolic heat output, not imposed SAR.
Write as "...adult; greater metabolic heat output is required to ...".
This has been amended to improve clarity.
11 53 Appendix A 243 Editorial "pregnant woman" should be "pregnant worker". As this is not a definition, either phrase is appropriate.
11 54 Appendix A 250 Editorial Improve grammar.
Replace "occupation" with "occupational".
Amend as per comment.
This has been amended as suggested.
11 55 Appendix A 266 General Suggested word change.
Replace "sweating" with "physiological state".
Sweating alone may not be responsible, maybe better to say physiological state to include conditions of increased heart rate etc. 
This has been amended as suggested.
11 56 Appendix A 280 Editorial Improve grammar.
Replace "are" with "is" at beginning of line.
Amend as per comment.
This has been amended as suggested.
11 57 Appendix A 312, 370 Editorial Suggest using abbrevation.
Replace gram with g.
For consistenty with other areas of the document.
This has been amended as suggested.
11 58 Appendix A 341 Editorial "(i.e. 0.1 [°C kg W-1] x 2 [W] = 0.2 [°C])" should be
"(i.e. 0.1 [°C kg W-1] x 2 [W/kg] = 0.2 [°C])"
This has been amended as suggested.
11 59 Appendix A 359 Editorial Wouldn't z rather than x be consistent with the definition at the beginning of the document? This has been revised as suggested.
11 60 Appendix A 370 Technical Wrong unit.
Change "mm" to "cm" after "2.15".
To align with rest of document and the need for 10 g averaging mass.
This has been amended as suggested.
11 61 Appendix A 391 Editorial "30-300 GHz"
">30 GHz"
Suggested change.

This has been amended as suggested.
11 62 Appendix A 420 Technical Address confused meaning.
Replace first instance of "exposure" with "heating".
Intended meaning of sentence not entirely clear. Make this change, if appropriate.
This has been amended as suggested.
11 63 Appendix A 426 Editorial Suggested change for consistency.
Change "6 minute"  to "6-minute". Search document and amend any other instances (e.g. lines 460, 480, 488).
Amend as per comment.
This has been amended as suggested.
11 64 Appendix A 444 Technical Is the fact that the head was "Japanese" relevant? If so, please explain why, or
Delete "Japanese".
The ethnic/racial background of the voxel phantoms used is not Gly provided in the document.
Reference to 'Japanese' has been removed.
11 65 Appendix A 445 Technical Meaning of "dispersive" not clear in this context.
Not able to suggest change as Kodera reference not published yet.
Reconsider wording.
This has been changed to 'variable'. Kodera et al is now published, and cited in Apendix A.
11 66 Appendix A 446 General The guidelines here are relying on unpublished data (Kodera), which presents a challenge to reviewers of the guidelines.Consider carefully here and elsewhere, whether the references provide sufficient support. The published paper has now been cited.
11 67 Appendix A 456 General For a document that may be used for a decade or more, it is best not to use the word "recent" to describe studies.
Delete "recent" here. Check for other instances elsewhere in the document and amend similarly.
The study will not be "recent" for very long, in the context of the guidelines themselves.
Recent' has been removed.
11 68 Appendix A 456 Editorial Grammatical change.
Change "show" to "shows".
Amend as per comment.
This has been amended as suggested.
11 69 Appendix A 457 Technical Syntax problem as one cannot protect a temperature elevation.
Possibly write as "... temperature elevation in Type-2 tissue (i.e. the brain) is kept below 1 degree C by complying with the SA restriction for the skin ...".
Suggested amendment, but need to consider intended meaning of sentence.
This has been amended as suggested.
11 70 Appendix A 460 Technical Why specify "cumulative"?
Remove "cumulative".
This has been amended as suggested.
11 71 Appendix A 460 Editorial Is "basic restriction" missing after the word "SAR"? This has been amended as suggested.
11 72 Appendix A 471 Editorial Avoid use of "significant" in this context.
Suggest replacing "not significant" with "is negligible".

This has been changed to account for this.
11 73 Appendix A 490 Editorial Is "basic restriction" missing after the word "transmitted energy density"? This has been amended as suggested.
11 74 Appendix A 522 Editorial Improve grammar.
Insert "a" before "uniform".
Amend as per comment.
This has been amended as suggested.
11 75 Appendix A 532 Editorial Suggestion to use symbol.
Replace ohm with symbol Ω.
To make consistent with other areas of the guidelines.
This has been amended as suggested.
11 76 Appendix A 538 & 539 Editorial Improve grammar.
Write as " ...characteristics as a plane wave, which Gly appears far away from radiation sources, and if there is no reflecting object to ...".
Amend as per comment.
This section has been completely rewritten and now avoids this issue.
11 77 Appendix A 544 Editorial Additional letter required.
Change "dimension" to "dimensions".
Use of English.
This has been amended as suggested.
11 78 Appendix A 554 Technical Paragraph should consider the measurement situation where the wave impedance is < 377 ohm.
Append the following sentence to paragraph "Conversely, if the H-field is dominant (E/H < 377 ohm), only the H-field reference level needs to be met".
It would be useful to explain the situation for making measurements around inductive sources.
Further clarification is outside the scope of the guidelines, and will need to be considered in technical (product safety) standards.
11 79 Appendix A 564 to 568 Technical Modelling by Dimbylow showed that, with a person stood on a conducting ground plane and exposed to a plane wave of field strength equal to the reference level in the 1998 guidelines, the localised SAR in the ankle could be exceeded for frequencies between 20 and 60 MHz. Thus, the limb current reference level had to be complied with in addition to the field strength reference levels in this frequency range to be sure the guidelines were complied with. However, a contiguous averaging mass was used in the work, rather than the cubic mass used in these updated guidelines. Nevertheless, it would be a good idea to check very carefully whether the change in averaging mass specification has removed the need to consider limb current if  the E & H reference levels are complied with.
Check carefully – spreadsheets and graphs based on the Dimbylow data can be provided, if requested.
As you noted, Dimbylow's data is the SAR averaged over contiguous tissue, which increases the value by more than 1.5 times. Further, a recent study has shown that it is compliant for local SAR in the grounded condition. 
11 80 Appendix A 574 Editorial Improve grammar.
Write "whole body" as "whole-body" here. Search and make changes elsewhere in the document to ensure consistency.
Amend as per comment.
This has been amended as suggested.
11 81 Appendix A 574 Editorial Improve grammar.
Write "...to the plane wave" as "...to plane waves...".
This has been amended as suggested.
11 82 Appendix A 583-585 Technical Same question as at lines 564 to 568 about conservativeness of E/H reference levels over ankle SAR between 20-60 MHz.
Check carefully.
This comment has been repeated and is not addressed again.
11 83 Appendix A 602 Editorial Improve grammar.
Write "... at the field strength of reference level..." as "...to a field strength equal to the reference level..."
Amend as per comment.
This has been amended as suggested.
11 84 Appendix A 613 Editorial Avoid the word "recent" for the reason explained earlier.
Delete "recent".
Amend as per comment.
This has been removed in most cases (but here it is a relative statement where we believe it is appropriate to retain)
11 85 Appendix A 635 Technical Use correct quantity.
Change "weight" to "mass". Also change at lines 642 and 643.
Mass is the correct term.
This has been amended as suggested.
11 86 Appendix A 636 Technical Use correct quantity.
Write as "...SAR in low body mass index (BMI) adults can ...".
BMI is the correct term.
This has been amended as suggested.
11 87 Appendix A 640 General Suggested revision of wording.
Change "her/her" to "the".
Amend as per comment.
This has been amended as suggested.
11 88 Appendix A 642 Editorial Improve grammar.
Delete "the" before "pregnant" and insert commas at the beginning and end of the following clause: "whose mass is heavier".
Amend as per comment.
This has been amended as suggested.
11 89 Appendix A 646 Editorial Improve grammar.
Write as "...the same as, or lower than, that of the non-pregnant...".
Amend as per comment.
This has been amended as suggested.
11 90 Appendix A 648 Editorial Suggestion of word change.
Replace "women" with "woman".
Better use of English.
This has been amended as suggested.
11 91 Appendix A 650 Editorial Improve grammar.
Insert "for" before "the mother".
Amend as per comment.
This has been amended as suggested.
11 92 Appendix A 651 Editorial Additional letter required.
Change "trimester" to "trimesters".
Better use of English.
This has been amended to improve clarity.
11 93 Appendix A 670 Editorial There was also a mention of 45%.
Replace 40% with 45%.
This has been amended as suggested.
11 94 Appendix A 672 Technical What are the "internationally standardized child models"?
Provide a reference or explain where these can be found.
Amend as per comment.
These are specified by ICRP. This information (and an updated reference) has now been added to the text.
11 95 Appendix A 677 Technical Unclear –"dry" repeated when one instance should probably be "wet".
Change one instance of "dry" to "wet".
Amend as per comment.
This has been amended to improve clarity.
11 96 Appendix A 681 Editorial Improve grammar.
Change "3 year" to "3-year". Check for similar instances elsewhere and amend.
Amend as per comment.
This has been amended as suggested.
11 97 Appendix A 682 Editorial Improve grammar.
Insert "that" before "in an adult female".
Amend as per comment.
This has been amended to account for this.
11 98 Appendix A 690 Editorial Reference usage.
Include both references in full.
References listed incorrectly.
This has been amended as suggested.
11 99 Appendix A 691 Technical Unclear to use dB here when percent is Gly used in the document. Readers may be less familiar with dB than %.
Write in percentage terms rather than dB.
Simplify to give %, not dB.
This has been amended as suggested.
11 100 Appendix A 693 Editorial Improve grammar.
Insert "at" before "other frequencies".
Amend as per comment.
This has been amended to account for this.
11 101 Appendix A 706 Editorial It would be helpful to give a cross reference here to Equation 3.2.
End sentence "... deeper regions (see Eqn 3.2).".
Amend as per comment.
This has been amended as suggested.
11 102 Appendix A 716 Technical Use correct terminology.
Insert "area" after "surface".
Amend as per comment.
This has been amended as suggested.
11 103 Appendix A 732-737 Technical Confusing text – line 734 states that maximum transmittance is USUALLY at  normal incidence, whereas line 736 seems to remove the "USUALLY" caveat. What is correct?
Needs clarification. Also need to check earlier mention of Brewster angle at line 113 and ensure consistency/clarity of with this text
Check and update text.
This has been checked and amended accordingly.
11 104 Appendix A 753 Editorial Improve grammar – inappropriate use of optical radiation terminology.
Change "focuses" to "concentrates", or "flows preferentially".
As per comment.
This has been amended to account for this.
11 105 Appendix A 762 Technical Need to define J as current density. This has been amended as suggested.
11 106 Appendix B 98 Editorial Word replacement.
Replace "relation" with "relationship".
Use of English.
We view 'relation' as appropriate here, as it refers to not only whether there is a relationship, but also what such a relation may look like. We have thus not changed this.
11 107 Appendix B 142 Editorial Re-ordering of sentence.
Alter to read "functions such as".
Use of English.
This has been amended as suggested.
11 108 Appendix B 161-176 Editorial Suggest text to be amended and moved. 
Paragraph should be moved from Section 2.3 to Section 3.
Text is currently in a section on other brain physiology and related functions but it would be better placed within the auditory, vestibular and ocular function section since it is about the eye.
Also, the section from 168-173 needs to be re-worded.  A suggestion might be...However, rabbits can be a good model for damage to superficial structures of the eye (e.g., give example) at higher frequencies (30-300 GHz), due to the shape of the facial structure.  The baseline temperature of the anterior portion of the eye (including the cornea) is relatively low (compared with the posterior portion of the eye that would be exposed at lower frequencies), very high exposure levels are required to cause harm superficially.
We acknowledge that this research could also be included within Section 3, but we believe it is more useful here. This section has been reworded for clarity.
11 109 Appendix B 162 Editorial Additional letter required.
Change "cataract" to "cataracts".
Use of English.
This has been amended as suggested.
11 110 Appendix B 164 Editorial Suggestion to use symbol.
Replace "degrees centigrade" with"oC".
To make consistent with other areas of the guidelines.
This has been amended as suggested.
11 111 Appendix B 177-180 General The possibility of eye damage, particuarly cataracts, from thermal exposures of the eyes has been long accepted and ophthalmic examination is part (often the only significant part) of most medical examinations following potential overexposure. If ICNIRP is proposing to change its advice in this area then there needs to be clear and unambiguous evidence presented in support of the change, including an explanation of why previous advice is now thought to have been incorrect.
Provide clear and unambiguous evidence to justify why ophthalmic injury is now thought to be unlikely and an explanation of why previous advice is now thought to be incorrect.
As described in Apendix B, there is no evidence that RF EMF causes cataracts in relevant exposure scenarios. We will consider providing further advice (outside of the guidelines), but do not believe that a critique of previous protection positions is appropriate within the present guidelines.
11 112 Appendix B 178 Editorial Suggested sentence adjustment.
Alter sentence to read "impair human health".
Use of English.
This has been amended as suggested.
11 113 Appendix B 183 Editorial Suggested sentence adjustment.
Sentence to read... pathology of "the auditory, vestibular and ocular systems".
The current wording of "these" systems is ambiguous.
This has been amended as suggested.
11 114 Appendix B 189-194 Technical The evidence for a threshold for the microwave hearing effect is presented so that it implies that the auditory effect is barely audible and consequently not significant. This is incorrect. By definition the threshold for the effect constitute the point at which it is barely audible, but this does not mean it can be assumed that exposure at higher pulse energies would similarly be barely audible. In fact there is considerable anecdotal evidence from exposure of military personnel that the effect is clearly audible even in the presence of other noise, such as strong winds. Such effects can cause annoyance and distraction.
The text should be amended to distinguish between threshold data and the magnitude of the effect that will occur in typical occupational settings.
Please note that the guidelines do not treat sensory effects as adverse health effects, unless they can be shown to result in adverse health effects. This has not been shown and so they have not been included within the guidelines. We acknowledge that evaluation of this needs to account for super-threshold effects, which we have considered.
11 115 Appendix B 238 Editorial Suggested sentence adjustment.
Suggested wording might be..."autophagy in the absence of apoptosis in neurons", rather than "which was not accompanied by apoptosis".
Use of English.
This has been amended as suggested.
11 116 Appendix B 242-243 Editorial Suggested text adjustment.
Add "s" to the end of the disease names,so change to Alzheimer’s disease, dementias, and Parkinson’s disease.
Accepted use of disease terminology.
This has been amended as suggested.
11 117 Appendix B 245 Editorial Suggested text adjustment.
Rather than "Results for multiple sclerosis", it is technically "Risks for....".
Clarification of words.
This has been amended to address the error. Note though that 'risks' has not been added, as the risk becomes relevant only when there is a hazard.
11 118 Appendix B 252 Editorial Suggested text adjustment.
Change "too much heat" to  "an increased temperature".
Use of English.
This has been amended as suggested.
11 119 Appendix B 279 Editorial Suggested text adjustment.
Remove "thus their thermoregulatory systems"  and adjust sentence to read ...humans are more-efficient thermoregulators than rodents, and can deal effectively with "increased temperature resulting from" higher exposure levels than rodents. Taberski et al. (2014) reported that in hamsters, no body core temperature elevation is seen at 4 W kg-1, with the only detectable health effect being a reduction in food intake (which is consistent with "observations of" reduced eating in humans when warmer). However the last word "warmer" needs clarification as it is not clear whether you mean enviromental temperature or body core temperature.
Clarification.
This has been amended as suggested.
11 120 Appendix B 346-367 General Emphasis on NTP study and Falcioni 2018 study.
Perhaps less discussion on the NTP and Falcioni studies, and draw in other animal literature as a balance. 
There seems to be too much emphasis on the NTP and Falcioni studies given the recent ICNIRP note on recent animal carcinogenesis studies, and draw in other animal literature as a balance. In addition, the focus of the discussion is around cardiac schwannoma but there is no mention of glioma.
This has been redrafted to provide greater balance. However, we do believe that, given their recency and strong claims, it is useful to emphasise these studies.
12 1 Appendix B 192-194 General Microwave hearing effect may not be harmful to health but it is irritating. It may not be a problem in a working environment but may be in a living environment where G public can be exposed to pulsed microwave radiation for 24 hours per day. Long-term exposure to pulsed microwave radiation which evokes irritating microwave hearing effect in a living environment may indirectly cause harmful health effects. At least it impairs the quality of life.
Proposed change: Set restrictions for pulsed microwave radiation for G public to prevent microwave hearing effect.
There is no evidence that the microwave hearing effect can result in health effects (e.g. through annoyance), and so a limit has not been given.
12 2 Main 766-768 General No strict limits for contact currents are given in this draft. However, reference levels were given for contact currents up to 110 MHz in the ICNIRP 1998 guidelines and up to 10 MHz in the 2010 ICNIRP guidelines.  Thus, there is a contradiction of the reference levels for contact currents in the frequency range from 100 kHz to 10 MHz between this draft and the ICNIRP 2010 guidelines.
Proposed change
Add reference levels for contact currents up to 110 MHz or update the ICNIRP 2010 guidelines in the next revision by removing the reference levels above 100 kHz.
The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete), and thus remove the contradiction.
12 3 Main 34-38 General Cosmetic procedures utilize RF energy which is transferred into tissue through direct contact or an air gap between the electrode and the skin. There is an urgent need for guidelines applicable for these procedures since this is one of the few applications of EMF that may cause instant adverse effects on the G public. It is unclear if RF currents transferred through galvanic contact are within the scope of the draft. In our opinion, the scope of the draft should be addressed to all cosmetic procedures utilizing RF energy, since the biological effects of the RF energy are the same regardless of the way the energy is transferred into tissue.
Proposed change
Cosmetic procedures utilize RF currents and EMFs. 
We do not believe that there is sufficient control over cosmetic procedures (unless provided under medical guidance), and so they have remained out of scope.
12 4 Appendix B 408-409 General The Health Risk Assessment Literature is rather G and lacks relevant references. The Appendix would be more informative and easier to read with the relevant references.
Proposed change
Add relevant references, at least review articles and reports.
It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
12 5 Appendix A 370 Editorial The side length of a 10 gram mass cube is 2.15 cm and not 2.15 mm.
Proposed change
As a result, the local SAR averaged over a 10 gram mass with side length of 2.15 cm is no longer …
This has been amended as suggested.
12 6 Main 156 Technical The unit of transmitted energy density is joule per square meter (Jm-2) and not radiant exposure (Jm-2).
Proposed change
Replace ´radiant exposure (Jm-2)´ with joule per square meter (Jm-2)  in Table 1. 
This has been amended.
12 7 Main 687 Technical The foot notes of Table 4 are ambiguous.
Proposed change
In foot note #3 replace ´For frequencies up to 2 GHz‘ with For frequencies above 400 MHz up to 2 GHz.
The tables have been completely rewritten, and this issue resolved.
12 8 Main 711 Editorial ´- - -´ is not used in Table 5
Proposed change
Delete foot note #5.
The tables have been completely rewritten, and this issue resolved.
13 1 Main 118-119 Technical „This results in complex patterns of fields inside the body that are heavily dependent on the EMF source and frequency, as well as on the physical properties and dimensions of the body.”
„ This results in complex patterns of fields inside the body that are heavily dependent on the EMF source properties (size of the transmitter elements, distance from the source, frequency, field intensity, modulation, and polarization), on the body size and shape and inclination of the surface, as well as on the physical properties and spatial distribution of the tissues within the body.“
It is better to specify as many parameters determining the field distribution as possible.
Additional parameters have been added.
13 2 Main 129 Editorial dialectric dielectric Typo This has been amended as suggested.
13 3 Main 156 Editorial In the third column of Table 1, line 10, the entry is „radiant exposure“, instead of the units. Change to „joule per square meter“
Consistency
The tables have been completely rewritten, and this issue resolved.
13 4 Main 231 Technical „health effects are primarily related to absolute temperature“
„health effects are related to absolute temperature and the duration of temperature exposure“
The statement in the document is true for whole body exposure. In the case of local exposure, tissue damage is dependent on temperature and time at that temperature. This is why the CEM43°C concept was introduced and is mentioned in line 319, further below. The concept is also needed to determine the peak-to-average and appropriate averaging time (see Neufeld and Kuster 2018).
Reference:
Neufeld and Kuster, „Systematic derivation of safety limits for time varying 5G radiofrequency exposure based on analytical models and thermal dose,“ Health Physics, Sept. 2018.
This comment has been repeated and is not addressed again.
13 5 Main 272-275 Editorial „human adults“
„resting human adults“
It is important to mention whether these were resting human adults
This comment has been repeated and is not addressed again.
13 6 Main 319-320 Editorial „Yarmolenko et al. 2011“ is missing from the reference list. Insert reference in the reference list.
Consistency
This comment has been repeated and is not addressed again.
13 7 Main 482-487 Technical “A reduction factor of 2” Justify better the selection of reduction factors and explain how uncertainty was taken into account for deriving them.
The need for the reduction factor is clear and discussed at several points in the document. However, the value of 2 is not documented in detail. Was it derived quantitatively by following a rigorous uncertainty analysis procedure, or is it an educated guess? Moreover, it is different than the reduction factor of whole body exposure. The fact that „the associated health effect is less serious medically“ for local exposure should not play a role in the derivation of the reduction factors. The procedure for deriving these numbers should be self-consistent and uniform throughout the guidelines. Any deviations should be adequately (and in a scientific way) justified
This comment has been repeated and is not addressed again.
13 8 Main 675-677 Technical „a smaller temperature rise“
Give a value (or percentage) and the respective reference.
This is a sensitive issue, because it relates to children, and a significant one because it has an impact on the decision of not changing the reference levels. The statement here reads like a hypothesis/assertion. It would better to give a value for the expected temperature rise with respect to adults, or a reference to support the statement
This comment has been repeated and is not addressed again.
13 9 Appendix A 171-172 Technical „As described above, power absorption is confined within the surface tissues at frequencies above 6 GHz. This may lead to thermoregulatory response initiation time being reduced.“
Remove the sentence.
No reference is provided to support this statement. In addition, it is in contradiction with the work of Christ et al (see below). At the surface of the body (skin) there are numerous heat receptors sending signals to the hypothalamus. Reference: Christ et al., “RF- Induced Temperature Increase in a Stratified Model of the Skin for Plane-Wave Exposure at 6 to 100 GHz.” Bioelectromagnetics. 2018. Submitted.
This comment has been repeated and is not addressed again.
13 10 Appendix A 341 Editorial „°C kg W-1“
„°C kg W-1“
Typo
This comment has been repeated and is not addressed again.
13 11 Appendix A 672 Technical „Conversely, the only study using the internationally standardized child models shows only a modest increase of 15 % at most (Nagaoka et al., 2008). “
Remove the sentence.
This comment has been repeated and is not addressed again.
13 12 Appendix B 27-29 Technical „In order to provide an indication of ICNIRP’s evaluation process, overviews of the literature and conclusions that ICNIRP reached, as well as a limited number of examples, are provided.“
Elaborate further.
Are the inclusion/exclusion criteria for the studies of the peer-reviewed literature that have been considered during the risk assessment process itemized somewhere? Will ICNIRP issue a detailed report on the evaluation of the studies and the list of those that have been considered in the risk assessment process?
This comment has been repeated and is not addressed again.
13 13 Main 16 General „This publication replaces the radiofrequency part of the 1998 guidelines (ICNIRP 1998);“ Elaborate further.
An abstract outlining the changes that have been made to the previous guidelines is important.
This comment has been repeated and is not addressed again.
13 14 Main 523 Technical 4 cm2 up to 30 GHz with a step function at 30 GHz to 1 cm2
Decrease the averaging area.
Recent publications (Neufeld and Kuster, 2018; Neufeld et al, 2018) show that this averaging area is too large for narrow beams, as those expected in 5G technology, allowing the temperature at the surface of the body to increase considerably. We do agree with the notion that the power density averaging area should decrease with increasing frequency. However, a step function at 30 GHz makes compliance testing very difficult. Therefore, we recommend a reduction of the averaging area as a function. Please note that the function is also a function of the limit.
It can be calculated that a beam with a Gaussian profile of 1 mm width, normally incident on the skin, can induce a surface temperature rise of 3.9°C instead of the 1°C produced by a plane wave with the same incident power density averaged over 4 cm^2. The temperature rise can become even higher, if a lower perfusion rate is assumed, since the 102 ml/min/kg perfusion rate assumed in the document is rather high: the energy is absorbed superficially on the skin in non-perfused layers, therefore a three-fold lower effective perfusion rate would be more reasonable. Then, in the above example the localized temperature rise would be about 4.1°C (i.e., 5 % higher).
References:
Neufeld et al. 2018. Discussion on consistent spatial and time averaging restrictions within the electromagnetic exposure safety framework. Bioelectromagnetics. Submitted.
Neufeld and Kuster, „Systematic derivation of safety limits for time varying 5G radiofrequency exposure based on analytical models and thermal dose,“ Health Physics, Sept. 2018.
Neufeld et al., "Theoretical and Numerical Assessment of Maximally Allowable Power-Density Averaging Area for Conservative Electromagnetic Exposure Assessment Above GHz," Bioelectromagnetics. Submitted.
This comment has been repeated and is not addressed again.
13 15 Main 553 Technical „less than 1 second“
Introduce a limit to the maximum energy density per pulse.
Introducing a constant energy density below 1 s allows for ultrashort pulses to deliver high amounts of energy and increase the temperature considerably. It is recommended to introduce a limit to the maximum energy density per pulse, taking into account the work of Neufeld et al.
Reference:
Neufeld et al., “Discussion on consistent spatial and time averaging restrictions within the electromagnetic exposure safety framework,” Bioelectromagnetics. 2018. Submitted.
This comment has been repeated and is not addressed again.
13 16 Main 596 Technical „square“
Change the shape of the surface for the averaging of the incident power density for frequencies above 6 GHz from a square to a circle of the same area. On non-planar evaluation surfaces, the shape of the averaging area would then be determined by intersecting it with a sphere with its center at the evaluation point and a radius that maintains the averaging area.
Defining the averaging area as a square leads to problems with reproducibility, because the square is not rotationally symmetric. A square requires the definition of the orientation of its edges around its surface normal. This definition is arbitrary and will lead to ambiguities when assessing compliance in practical situations. Furthermore, a square does not conform to a non-planar surface. The definition that we propose is free of these problems. Despite the problem of definition, a sphere intersection will also substantially reduce the effort required for compliance testing.
This comment has been repeated and is not addressed again.
13 17 Appendix A 79 Technical „power and energy densities“
„power density“
Equation 2.9 is the averaged power density, not energy density.
This comment has been repeated and is not addressed again.
13 18 Appendix A 94 Technical „absolute strength of the Poynting vector“
„modulus of the complex Poynting vector“ Change to technically correct wording
This comment has been repeated and is not addressed again.
13 19 Appendix A 412 Technical The Sasaki study is an important paper. Latest studies taking into considerations detailed skin properties, showed that simplifications result in insufficient conclusions. The most important one is that the layered model considered did not take into account the epidermis structure, i.e., did not differentiate between stratum corneum and viable epidermis. This is important, as it increases power transmission at higher frequencies (stratum corneum acts as a matching layer). The thermal parameters used in the Sasaki study Gly yield a lower temperature increase than the ones in published databases. These different parameters (and using fat instead of muscle as terminating layer) explain the remaining differences to Sasaki even without the stratum corneum and with mixed thermal boundaries instead of the adiabatic ones.
Consider newer results about the heating factor, taking into account more detailed models.
It can be shown that at frequencies above 15 GHz, the stratum corneum (SC) acts as an impedance matching layer for the incident electromagnetic fields. Considerably increased transmission of the energy can be observed for thick layers of the SC
(0.36 – 0.70 mm), which occur in the palms. The worst-case heat conversion factor for normal incidence occurs at 60 GHz for a thick SC and is 0.04 K/(W/m^2).
References:
Christ et al. 2018. RF-Induced Temperature Increase in a Stratified Model of the Skin for Plane-Wave Exposure at 6 to 100 GHz. Bioelectromagnetics. Submitted.
Samaras and Kuster. 2018. Power transmitted to the body as a function of angle of incidence and polarization at frequencies > 6GHz and its relevance for standardization. Bioelectromagnetics. Submitted.
This comment has been repeated and is not addressed again.
13 20 Appendix A 415 Technical This may not be so conservative after all, considering the limitations of the study by Sasaki et al (2017) and the ambiguity about the transmitted power density at oblique incidence, especially for TM polarization.
Consider newer results about the heating factor, taking into account more detailed models. Conservativeness of reference levels.
This comment has been repeated and is not addressed again.
13 21 Appendix A 733-736 Technical “Recent research has shown that the normal angle results in the maximum transmitted power density (greatest absorption) and is used for calculating the reference levels (Li et al., 2018).”
This statement is incorrect and should be replaced by the conclusions from the publication by Samaras et al. (see below).
The angle that corresponds to maximum transmittance at TM mode cannot correspond to normal incidence. This reference cannot be used to support the incorrect assumption that normal incidence is the worst case. The Li 2018 presentation is not published in a peer-reviewed journal, and the paper by Samaras et al comes to a different conclusion. Reference: Samaras and Kuster. 2018. Power transmitted to the body as a function of angle of incidence and polarization at frequencies >6GHz and its relevance for standardization. Bioelectromagnetics. Submitted.
This comment has been repeated and is not addressed again.
13 22 Main 122 Editorial „polarized molecules“
„polar molecules“
“polarized” means that something caused the substance to acquire polarity. Water is a polar molecule meaning that its polarity is inherent, not acquired.
This comment has been repeated and is not addressed again.
13 23 Main 71 Editorial „These quantities cannot be easily measured“
„These quantities may be difficult to evaluate“
Induced quantities, such as SAR, have become relatively easy to evaluate. This the reason for changing to “may be difficult”. Also, changed “measure” to “evaluate” as a more G term, as numerical methods are well used and standardized.
This comment has been repeated and is not addressed again.
13 24 Main 89 Editorial „which may include particularly vulnerable groups or individuals“
„which includes particularly vulnerable groups or individuals “
“G public” includes everyone, so “may include” is incorrect.
This comment has been repeated and is not addressed again.
13 25 Main 156 Technical „Htr“
“Utr”
It is confusing to use H for energy density and magnetic field. Use a different symbol (e.g., U). It should be a scalar, not a vector (i.e., not bold).
This has now been changed to 'U' (and 'transmitted' changed to 'absorbed').
13 26 Main 429 General „To be compliant with the present guidelines, exposure cannot exceed any of the restrictions described below, nor those for the 100 kHz – 10 MHz range of the ICNIRP (2010) low frequency guidelines“
Please specify which limits to apply where there are differences between ICNIRP 2018 and ICNIRP 2010. The limits should be consistent and in one single standard. Also replace “cannot” with “must not”.
Reference levels in ICNIRP 2018 and 2010 are different in some cases.
This comment has been repeated and is not addressed again.
13 27 Main 590 Technical Headings of Tables 2 and 3, and Tables 5 and 6, are misleading. Delete ">= 6 minutes" and "< 6 minutes" from the headings.
The two sets of limits should always apply together. The SA and energy density restrictions are limiting when transmitting short pulses, and the SAR and power density restrictions are limiting when transmitting continuous signals, but both sets of limits apply regardless of the type of signal. This should be made clear in the text also.
This comment has been repeated and is not addressed again.
13 28 Main 813 Technical „Simultaneous exposure to multiple frequency fields”
Add guidance if a person is exposed simultaneously to signals that fall under both > 6 minutes and < 6 minutes.
There is no guidance if a person is exposed simultaneously to signals that fall under both > 6 minutes and < 6 minutes.
This comment has been repeated and is not addressed again.
13 29 Main 140 Technical „10-g cubical mass“
Add guidance on what to do if the body surface is not flat.
A cube does not conform to a non-flat surface, resulting in air in the volume or tissue that is not considered. IEC 62704-1 includes considerations on what to do about this problem. Adapting the surface of the cube to the curved SAM shell is common practice in compliance testing standards. However, problems still remain dealing with the lack of rotational symmetry of a cube. A better approach is to use a sphere whose center is at the point of interest and radius is set such that 10 g is included. This would be a hemisphere for a point on a flat surface.
This comment has been repeated and is not addressed again.
13 30 Main 374 Technical „From 6 to 10 GHz there may still be significant absorption in the subcutaneous tissue. “ Extend the frequency range for SAR as a basic restriction to 10 GHz.
The above statement supports the need to extend the frequency range of SAR as a basic restriction to 10 GHz. Furthermore, the paper of Carrasco et al. (see below) outlines the problems with using power density in the reactive near field and supports extending
SAR to 10 GHz. IEC draft 62209-1528 has already included procedures, sources and validation for frequencies from 6 – 10 GHz. The work of Pfeifer et al and Pokovic et al (see below) demonstrate that SAR measurements are achievable within reasonable uncertainty bounds at these frequencies.
References:
Pfeifer et al., “Total field reconstruction in the near field using pseudo-vector E-field measurements,” IEEE Transactions on Electromagnetic Compatibility, June 2018.
K. Pokovic et al., "Methods and Instrumentation for Reliable Experimental SAR Assessment at 6 – 10 GHz," BioEM Meeting, Hangzhou China, 2017.
Carrasco et al., "Exposure assessment of portable wireless devices above 6 GHz," Radiation Protection Dosimetry, October 2018.
This comment has been repeated and is not addressed again.
13 31 Main 481 Editorial „(5 C in Type-1 tissue and 2 C in Type-2 tissue)“ “(2 C in Type-2 tissue)”
This section talks about the Head and Torso only.
This comment has been repeated and is not addressed again.
13 32 Main 522 Editorial „200 W m-2 “
Keep on same line
This is broken across 2 lines.
This comment has been repeated and is not addressed again.
13 33 Main 715 Technical „no reference levels are provided for reactive near-field exposure conditions within this frequency range “
Add reference levels for near-field exposure, or extend SAR as a basic restriction above 6 GHz. An alternative is to recommend compliance testing based on transmitted power.
Exposure to reactive near fields is likely to be common for 5G devices and the basic restrictions may be difficult to measure. This is supported by the paper of Carrasco et al (see below). Currently there are no measurement systems available that measure the transmitted power density. This makes it very difficult to demonstrate compliance with EM exposure. It is also important to point out that the incident power density flux crossing the surface is not always conservative as a proxy for transmitted power (see Samaras et al. 2018).
References:
Samaras and Kuster, “Power transmitted to the body as a function of angle of incidence and polarization at frequencies > 6 GHz and its relevance for standardization.” Bioelectromagnetics. 2018. Submitted.
Carrasco et al., "Exposure assessment of portable wireless devices above 6 GHz," Radiation Protection Dosimetry, October 2018.
This comment has been repeated and is not addressed again.
13 34 Main 156 Editorial „Seq, Sinc, Htr, Str“
Use scalar rather than vector quantities.
The limits are defined as scalar values, so the symbols should also be scalars (without bold)
This has been amended as suggested.
13 35 Main 156 Technical Missing references: The following references should be added to the guidelines (manuscripts attached in an email sent to R. Croft on October 8th as the file was not accepted by the system because of its size):
Neufeld and Kuster, ”Systematic derivation of safety limits for time varying 5G radiofrequency exposure based on analytical models and thermal dose,“ Health Physics, Sept. 2018.
Christ et al., “RF-Induced Temperature Increase in a Stratified Model of the Skin for Plane-Wave Exposure at 6 to 100 GHz.” Bioelectromagnetics. 2018. Submitted.
Samaras and Kuster, “Power transmitted to the body as a function of angle of incidence and polarization at frequencies > 6 GHz and its relevance for standardization.” Bioelectromagnetics. 2018. Submitted.
Neufeld et al., “Discussion on consistent spatial and time averaging restrictions within the electromagnetic exposure safety framework,” Bioelectromagnetics. 2018. Submitted.
Pfeifer et al., “Total field reconstruction in the near field using pseudo-vector E-field measurements,” IEEE Transactions on Electromagnetic Compatibility, June 2018.
Pokovic et al., "Methods and Instrumentation for Reliable Experimental SAR Assessment at 6 – 10 GHz," BioEM Meeting, Hangzhou China, 2017.
Carrasco et al., "Exposure assessment of portable wireless devices above 6 GHz," Radiation Protection Dosimetry, October 2018. Neufeld et al., "Theoretical and Numerical Assessment of Maximally Allowable Power-Density Averaging Area for Conservative Electromagnetic Exposure Assessment Above GHz," Bioelectromagnetics. Submitted.
This comment has been repeated and is not addressed again.
14 1 Main 711 Editorial There is no cell with „---„ in Table 5.
You can delete this line.
None.
The tables have been completely rewritten, and this issue resolved.
15 1 Main 14-15 General Please specify : “protection of humans …” from what, and how (what is the method of ICNIRP) ?
Extend the sentence:… (thereafter radiofrequency), from Gly acknowledged adverse effects by limiting the exposure below scientifically established and Gly accepted thresholds. Without scientifically established threshold in a particular field of research (e.g. radiofrequency exposure associated cancer) no exposure limit can be set.  
The proposed insert  increases transparency, it informs the reader already at the beginning what to expect and what NOT to expect. 
The methods and scope have been described in the documents.
15 2 Main 24 Editorial „against known adverse health effects” . raises the question , Known to whom ?
Please consider: Against scientifically established and Gly accepted adverse health effects
known is a subjective term, it conveys that ICNIRP is UN-scientific 
This is described in the main document. No change required.
15 3 Main 103-15 General „ICNIRP considers …. precautionary .measures unnecessary.” 
This sentence reads like ordered and delivered. It undermines INCNIRPs standing in the public.
Omit whole sentence
The claimed “sufficiently conservative“ derivation of limits may be fine for cases with little uncertainty in knowledge.
In other situations (with substantial uncertainties) conservative approaches and margins of 100, and 1000 fold are common practice. 
The rationale for this approach is provided in the documents, and we believe is appropriate.
15 4 Main 351 Editorial Referring to: “However, there is currently no evidence that such effects are sufficient to impair health” “no evidence” is used in an exceptional context. Others will see evidence, therefore the statement not comprehensible.
Omit the sentence. Alternatively define evidence as used here
The statement can be easily falsified, by any piece of evidence. A reduced spermfunction is not a health effect, therefore the statement is correct, but sounds “over-smart” and cynical. 
The meaning has been described in the text.
15 5 Appendix B 31-32 General Why ICNIRP ignores  risk management tools  other than threshold definition and limit setting? Typical risk management strategies in situations with uncertainties are strategies like “prudent avoidance”, ALARA (As Low As Reasonable Achievable), ALATA (As Low as technically Achieveable)  
Please consider: This research feeds in the determination of thresholds for adverse human health effects and for organisational strategies to lower possible risks.  
ICNIRPs continuous arguing for „no evidence“, where others see plenty of evidence. This feeds rumours that ICNIRPs protects radiofrequency more than exposed humans. As result “Nocebo effects” occur as unspecific stress reaction in persons, who already lost trust in ICNIRPs judgements.
Where there are advantages of risk management strategies, ICNIRP has used them (e.g. in terms of occupationalupational exposures).
15 6 Appendix B 64 Editorial The sentence is incomplete, please insert at the end “exposure”.
Result: …report an association with radiofrequency EMF exposure.
to leave as it is: it is unscientific, and meaningless 
Exposure' has been added as suggested.
15 7 Appendix B 69 Editorial If you mention studies, please cite them and give the reader a chance to comprehend the argument. 
…. cognitve domains (cite the work you have in mind). 
Be scientific
It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
15 8 Appendix B 72-74 Editorial A very specific publication here is cited in details  without citation
Please insert reference
Please stay with scientific standards  , 
The citation has been added as suggested.
15 9 Appendix B 78 Editorial Sentence starts with „However, …. “It is unfair to discuss a scientific report without telling the specific report 
Please insert a reference after the sentence
to make this discussion comprehensible.
It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
15 10 Appendix B 82-85, 98, 100, 102, 105, 106, ... and many more places  Editorial Without references any discussion is not scientific reporting but preaching,   
Please provide the reference as it is standard for science based reports
without basic scientific standards the ICNIRP guidelines run down to the level of the business of a religious sect.  
The scope and procedures of this document has been described. For further information, please see the reviews cited.
15 11 Appendix B 101 General … “belief about exposure ….  - Nocebo effect, …. 
Please acknowledge that reported effects can be real, but without knowledge on the threshold are not within the scope of ICNIRP. 
Discussing effects without treshold as „no evidence“ (in various places of the ICNIRP document) may be correct from ICNIRPs point of view only. It is inacceptable for persons expecting protection. Therefore the (ICNIRPs) strategy produces nocebo effects. i.e. stress with unspecific symptoms. It is scientifically naive to insinuate or expect that unspecific stress symptoms (nocebo symptoms) can be substantiated under laboratory conditions.
There is no evidence that the effect is any more than nocebo, and so it would not be appropriate to suggest otherwise.
15 12 Appendix B 295 General Referring to : There is currently no evidence that such reported effects, if real, are relevant.    
Omit:  , if real,
it adds nothing to the argument, and provides evidence that ICNIRP is un-scientific, it is lead by believes and not by scientific evidence. How do you make the distinction to question this reports “if real” and not question all the others? .
This clarifies that the argument is based on the premise that there is a hazard, rather than to suggest that there is a hazard, which is important so as not to mislead the reader.
15 13 Appendix B 321 General Referring to : …. do not provide strong evidence ….
???
How does ICNIRP distinguish between 1)  no evidence, and 2) not provide strong evidence? Please explain   
The methods have been described within the documents.
15 14 Appendix B 329 General I am surprized ICNIRP even cares about the Cancer Issue, which would require other than ICNIRPs protection strategies.   
Omit the complete section, it is completely out of scope of ICNIRPs “first threshold - then protection” philosophy. 
There are Gly accepted strategies how to deal with Cancer issues like prudent avoidance, ALARA, ALATA. The ICNIRP philosophy  “protection-when threshold is established” just creates stress for those not willing to wait for a threshold be found. Therefore with this section ICNIRP achieves nothing for the protection of exposed persons, other than trigger and enhance nocebo like reactions.
In addition it creates stress for the ICNIRP itself, as it triggers and enforces argumentations - that can be considered obsessive - to describe as “not real”  what is perceived as real possibility by a growing number of professionals and lay persons.   
Cancer is an important issue that ICNIRP cannot ignore. It has been retained within the guidelines accordingly.
16 1 Main 20-21 General We recommend that ICNIRP consider regular (annual is suggested) statements that guidelines remain valid. A less-technical summary would also be helpful for policy makers wanting to understand the ICNIRP update process and outcomes. This should be published with the final Guidelines. For examples, see the European Commission approach: https://ec.europa.eu/health/scientific_committees/policy/opinions_plain_language_en
Add: ICNIRP will annually confirm that the guidelines remain valid.
For the 1998 guidelines, statements that they remain valid were made only in 2009 and 2017. In an area with constant new research it may not be clear to all stakeholders that the limits remain valid.
An appropriately informed consideration of the guidelines requires a large amount of work that could not be completed within this time frame. ICNIRP monitors the literature, and where there is need, such statements are made.
16 2 Main 44 Editorial Consistency of language is important for understanding by stakeholders. We suggest use of ‚adverse‘ as used at line 24 throughout. ... known harmful adverse health effects change to  ... known adverse health effects
Clarity
This has been amended as suggested.
16 3 Main 55 Editorial Add adverse
 cause the adverse health effect
Clarity
This has been amended as suggested.
16 4 Main 61 Editorial Add adverse
 cause the adverse health effect
Clarity
This has been amended as suggested.
16 5 Main 79 Technical It is difficult to prove ‚worst-case exposure conditions‘ so we propose an alternative description
 ...under actual maximum exposure conditions‘
Clarity
We agree that this is difficult, but we think that the suggestion is equally difficult. We have provided qualification to this to address this issue.
16 6 Main 96 Editorial The Guidelines do not explicitly state that the public limits apply 24x7x365.
The public exposure limits in these guidelines  for human exposure to RF-EMF are designed to provide protection for all age groups, including children, on a continuous (24 hours a day/seven days a week whole of life) basis.
 Clarity. Wording based on Health Canada fact sheet.
The main document now states that it provides protection for both short-term and long-term exposure, for all people.
16 7 Main 135 Editorial  specific absorption rate differs from 1998 terminology
Specific energy absorption rate (SAR).
Consistency
We have amended this to that of 1998 for consistency (and accuracy).
16 8 Main 152 Technical    The equivalent incident power density (Seq) does not appear to be defined.
 Provide a definition.
Clarity
This has now been defined.
16 9 Main 156 Editorial    The quantities in Table 1 are defined in Appendix A and it would helpful if this was indicated. It would also be helpful for a Glossary to be developed similar to the 1998 guidelines. .
 Add: (Note: See Appendix A for the definitions of these quantities).
Clarity
Reference to Apendix A has now been made at the beginning of the 'quantities' section. Coupled with better definition of the quantities in Table 1, we believe that this is now sufficient without a glossary.
16 10 Main 156 Editorial Frequency is denoted by f but this symbol is not used in the Tables.
Use f symbol in the tables.
Consistency
This has been amended as suggested.
16 11 Main 156 Editorial Hinc should be added to Table 3.
Add H
inc to the Table.
Consistency
The tables have been completely rewritten, and this issue resolved.
16 12 Main 190 Technical     Add new sentence on modulation to address scientific discussion about whether modulation is significant.
  Based on SCENIHR 2015 add: ‘Several interaction mechanisms are well established and these enable extrapolation of scientific results to establish limit values for the entire frequency range regardless of signal modulations.‘
 There has been scientific discusson about whether modulation is important to the possibility of adverse health effects (Juutilainen et al., 2011; Balzano et al, 2008; Davis et al, 2010; Kowalczuk et al., 2010; Foster et al, 2004 ). It was addressd by SCENIHR (2015):

‚Several interaction mechanisms are well established. These enable extrapolation of scientific results to the entire frequency range and wide-band health risk assessment. They have been used to formulate guidelines limiting exposures to EMF in the entirefrequency range from static fields to 300GHz. A number of studies proposed other candidate mechanisms. However, none that operates in humans at levels of exposure found in the everyday environment has been firmly identified and experimentally validated nor do they enable concluding on potential health risks at other exposure conditions both with regard to amplitude and/or frequency’

It would be helpful to stakeholders to have ICNIRP comment on the topic. Other relevant references:

Review of possible modulation-dependent biological effects of radiofrequency fields, Juutilainen, et al., Bioelectromagnetics, 32(7):511–534, October 2011
The brain is not a radio receiver for wireless phone signals: Human tissue does not demodulate a modulated radiofrequency carrier, Davis, et al., Comptes Rendus Physique, 11(9-10):585-591, November-December 2010
Absence of nonlinear responses in cells and tissues exposed to RF energy at mobile phone frequencies using a doubly resonant cavity, Kowalczuk, et al., Bioelectromagnetics, 31(7):556-565, Oct 2010
A doubly resonant cavity for detection of RF demodulation by living cells, Balzano, et al., Bioelectromagnetics, 29(2):81 - 91, February 2008
Biological Effects of Radiofrequency Fields: Does Modulation Matter?, Foster, et al., Radiation Research, 162(2):219–225, August 2004
The wording of the document is now clear in that it accounts for 'all' exposure within scope. We will comment on pulsed signals in a companion document providing further explanation of the guidelines.
16 13 Main 260 Editorial     Reference is made to ACGIH, 2017 but the Reference list includes only ACGIH, 2018a and ACGIH, 2018b..
 Correct the reference.
Clarity
This has been amended as suggested.
16 14 Main 319 Editorial    Reference missing  Yarmolenko et al. 2011.
 Insert reference.
Consistency
This has been amended as suggested.
16 15 Main 365 Technical     It is not clear whether this phrase ‚ ICNIRP assumes actual exposures (such as from radio-communications sources)‘ refers to the sources or the signals produced by such sources. .
 Clarify the meaning.
Clarity
Further clarification has been added.
16 16 Main 429 and 617 Editorial The sentence in line 429 states “To be compliant with the present guidelines, exposure cannot exceed any of the retrictions described below....”however line 617 states “For the purpose of these guidelines, compliance is demonstrated if either the relevant reference levels or basic restrictions are complied with....”.
 Clarify the meaning.
Clarity
This has been amended as suggested.
16 17 Main 432 Editorial Insert adverse.
do not cause any known adverse health effect...
Clarity
This has been amended as suggested.
16 18 Main 434-437 Technical Many countries using these guidelines have warm climates. It would be helpful if ICNIRP provided additional commentary on the extent to which the guidelines have considered the influence of climate in settig both the public and worker limits.
Clarify the relevance of climate factors for worker and public exposures.
Moore et al, 2017 provides some data for worker exposures.
(Effect of adverse environmental conditions and protective clothing on temperature rise in a human body exposed to radiofrequency electromagnetic fields, Moore, et al., Bioelectromagnetics, 38(5):356-363, July 2017)
How variability in environmental conditions is accounted for in the guidelines is now described in the text.
16 19 Main 437 Editorial Reference is made to ACGIH, 2017 but the Reference list includes only ACGIH, 2018a and ACGIH, 2018b.
Correct the reference.
Clarity
This has been amended as suggested.
16 20 Main 643-646 Technical Discussion of near-field/far-field regions should be amended for consistency with ITU publications and recent research. The present text is more appropriate to antenna pattern formation than field impedance. “D“ should be the maximum linear dimension of the anntena. 
  The conventional approach is that the reactive near-field extends to about λ m, the reactive-radiating near-field extends to about 3λ, the radiating near-field extends from 3λ to about 2D2/λ m and the radiating far-field begins at 2D2/λ m. The radiating near-field region only exists if the maximum linear dimension D of the antenna is large compared with the wavelength λ. However, recent research suggests that reactive near-field boundary may be smaller (Colombi et al., 2018).
 See section 6.3 in ITU-T K.61 (2008) and RF Energy Absorption by Biological Tissues in Close Proximity to mmW 5G Wireless Equipment, Colombi, et al., IEEE Access:1-1, 5 January 2018. 
This has been amended as suggested.
16 21 Main 655 Editorial   Insert adversely.
 To adversely affect health.
Clarity
This has been amended as suggested.
16 22 Main 657 Editorial   Insert adversely.
  adversely impact on health .
Clarity
This has been amended as suggested.
16 23 Main 670 Editorial    Insert adversely .
  not adversely impact on health .
Clarity
This has been amended as suggested.
16 24 Main 697 Editorial      Two Equations in Table 5 have a negative sign (-) before the number 0.177, however the text font makes it difficult to see the “-“ from the “f”.
  Distinguish the “f” and the “-“ .
Clarity
This has been amended as suggested.
16 25 Main 709 Editorial    Note 4 says 66-30 GHz, should be 6 -30 GHz .
 6-30 GHz.
Correction
This has been amended as suggested.
16
26 Main 720 Editorial  Two Equations in Table 6 have a negative sign (-) before the number 0.177, however the text font makes it difficult to see the “-“ from the “f”.
  Distinguish the “f” and the “-“.
Clarity
This has been amended as suggested.
16 27 Main 770 Editorial Add the frequency range .
  source in the frequency range 100 kHz -110 MHz..
Clarity
This has been amended as suggested.
16 28 Main 818-822 General     It is difficult to demonstrate ‚worst-case‘ so alternative wording suggested. Delete final pair of words that seem unneccesary .
  The below reference level summation formulae assume highest exposure conditions among the fields from multiple sources. As a result, typical exposure situations may in practice require less restrictive exposure levels than indicated by the formulae for the reference levels (but would require compliance to be demonstrated with basic restrictions demonstrate this).
Clarity
This has been amended to improve clarity.
16 29 Appendix A 17 Editorial  Insert thresolds. Abbreviation not used in the Guidelines. .
  operational adverse health effects thresholds (OAHETs).
 Missing word. Add  abbreviation to the Guidelines. 
This has been amended as suggested.
16 30 Appendix A 50 Technical    The term „adiabatic“ refers to the lack of energy transfer from an object to its surroundings. This does not account for energy transfer within the object (where there is thermal conduction) and so the term „adiabatic“ is not relavant to equation 2.4..
  Replace „Under the adiabatic condition where no heat diffusion occurs ...“ with „Under the situation where heat conduction is not significant ...“
Clarity.
This has now been addressed, with the error removed.
16 31 Appendix A 53 Technical  SAR should be calculated at the instant that energy is input to the system. .
  Replace equation 2.4 with „SAR = c dT/dt | t=0“ (Note: In the formatting of this equation the d’s are partial d’s and t=0 is subscript).
This is an equation that is often used improperly and leads to large errors in estimation of SAR. It should be emphasised that the calculation be done at t=0 (that is, by looking at the initial slope of T with time). In the calculation of SAR, many researchers use this equation and look at temperature rise over say two minutes when it should be performed within no more than the first few seconds. SAR can easily be underestimated by a factor of two or more when the equation is used improperly for animal tissue
As adiabatic conditions were assumed, the equation was correct . However, please note that the condition has now been specificed differently in the revised version, where it says that "Under conditions where heat loss due to processes such as conduction is not significant, SAR and temperature elevation are directly related as follows;"
16 32 Appendix A 250 Technical   The statement „‘normothermic‘ range“ has not been specified. . .
   ICNIRP should add the temperature range at which normothermia applies. .
 Guidance to the reader is desired to understand the operational adverse threshold for core body temperature. As an example, if normothermia is defined as the range 36.5 degC to 37.5 degC (an example range), then the statement at line 260-261 “to keep the body core temperature within +1 degC of normothermia” implies that the body core temperature could rise to 38.5 degC. Is this a correct interpretation of ICNIRP’s intent?
Note that this is not referred to in Apendix A, but rather in the main document. Further clarificaiton is now provided in the main document.
16 33 Appendix A 336 Editorial ...worst case.
 ... highest exposure condition....
 Alternative wording that may be better understood.
This has been amended to improve clarity.
16 34 Appendix A 347 Editorial  ...worst case.
 ... highest exposure condition....
 Alternative wording that may be better understood.
This has been amended to improve clarity.
16 35 Appendix A 522 Editorial  ...worst case.
 ... highest exposure condition....
 Alternative wording that may be better understood.
This has been amended to improve clarity.
16 36 Appendix A 631 Editorial   ...worst case.
 ... highest exposure condition....
 Alternative wording that may be better understood.
This has been amended to improve clarity.
16 37 Appendix A 677 Editorial   dry skin and the dry skin reported in the de-fact database (Gabriel, 1996)...
   ...dry skin and the dry skin (Gabriel, 1996)....
Clarity
This has been amended to improve clarity.
16 38 Main 646-649 General   Edit to this text. .
Delete the latter “input from the compliance community is required to determine which of these field types is most appropriate for a given exposure...
 The community has only developed assessment methods according to information from relevant industries.
This issue is too complex to be specified in advance using these guidelines, and so Standards bodies will be needed for such detailed considerations.
16 39 Main 375-379 Technical  “However, as the maximum and thus worst-case temperature elevation from >6 to 300 GHz is close to the skin, exposure that will restrict temperature elevation to below the operational adverse health effect threshold for Type-1 tissue (5 °C) will also restrict temperature elevation to below the Type-2 tissue threshold (2 °C).”
This sentence does not adequately explain why it is sufficint to consider only the 5 °C increase in Type-1 tissue.
 Additional details including numerical data and references should be added.
Clarity
This is clarified in Apendix A.
16 40 Main 827 Editorial   Add ‚should be‘.
    And local SAR and transmitted power density values should be added according to ..
Correction
This has been amended as suggested.
16 41 Appendix A 250 Editorial  ““Occupation whole body exposure” should be “occupational ...”..
   “Occupational whole body exposure...“
Correction
This has been amended as suggested.
16 42 Appendix A 370 Editorial  “ Side length of 2.15 mm” should be “... 2.15 cm”..
    Side length of 2.15 cm...”
Clarity
This has been amended as suggested.
17 1 Main All General It is alarming to see that those involved in preparing the new ICNIRP draft guidelines have stuck to the old approach of regarding heat and shock related damage from sufficient power intensity over a short period as the only cause of health effects.
There is a vast body of independently replicated, quality research evidence indicating biological effects induced by exposures with very much lower intensities than relevant to heat damage. Many of these are known to be able to lead to diseases (see example below). The non-ionising radiation limits need to be set on the basis of levels known to cause bio-effects, as for ionising radiation. 
The evidence available indicates that the proposed document needs to be completly overhauled using a new approach
The full range of quality evidence of research over the last 20 years needs to be considered in addition to earlier research.
A new approach is needed that prevents bio-effects after exposures at observed extremely low intensities when these effects are known to lead to ill-health Gly and/or specific diseases.
The guidelines protect against all adverse health effects identified by science. No evidence is provided in support of the alternate view.
17 2 Main 54-55 General „Adverse health effect thresholds“ is a naive approach to a complex process that leads up to most disease/ adverse health conditions. Clearly it is not acceptable to overlook bio-effects which are known to be able to lead to  disease/ adverse health conditions. An example is the induced production of reactive oxygen species and oxidative stress. There are many possible citations but this abstract will suffice: „This review aims to cover experimental data on oxidative effects of low-intensity radiofrequency radiation (RFR) in living cells. Analysis of the currently available peer-reviewed scientific literature reveals molecular effects induced by low-intensity RFR in living cells; this includes significant activation of key pathways generating reactive oxygen species (ROS), activation of peroxidation, oxidative damage of DNA and changes in the activity of antioxidant enzymes. It indicates that among 100 currently available peer-reviewed studies dealing with oxidative effects of low-intensity RFR, in G, 93 confirmed that RFR induces oxidative effects in biological systems. A wide pathogenic potential of the induced ROS and their involvement in cell signaling pathways explains a range of biological/health effects of low-intensity RFR, which include both cancer and non-cancer pathologies. In conclusion, our analysis demonstrates that low-intensity RFR is an expressive oxidative agent for living cells with a high pathogenic potential and that the oxidative stress induced by RFR exposure should be recognized as one of the primary mechanisms of the biological activity of this kind of radiation” (Yakymenko I, et al.: Oxidative mechanisms of biological activity of low-intensity radiofrequency radiation. Electromagnetic Biology and Medicine 2016, 35(2):186-202)
ROS and resulting oxidative stress are linked to several diseases including some cancers and Alzheimers (e.g. Poprac Pet al: Targeting Free Radicals in Oxidative Stress-Related Human Diseases. Trends in Pharmacological Sciences 2017, 38(7):592-607.)
This is just one of many possible bio-effect examples.
Insert your proposed change.
Context: The importance of acknowledging effects of extremely low exposures
Any bioeffects that have been shown to result in adverse health effects have been used in the guidelines to derive restrictions.
17 3 Main Title   296-297 Technical The proposed range of frequencies for the guidelines is not scientifically supportable, even by thermal standards. One should not set guidelines  using the thermal threshold approach  for frequency ranges that have had no research on their effects on body core temperature.
(100 kHz to 6 GHz)
Separate guidelines should be prepared for mm wave exposures. The thermal core temperature research won’t be necessary providing the aim is to prevent the bio-effects and health effects of much lower exposures, which should apply to both environmental exposures and those resulting from transmitting devices which are frequently used against the body 
It is not clear what the argument is for these assertions, and so we are not able to evaluate their relative worth.
17 4 Main 321-344 Editorial Lines 338-340 are presented in the reverse order from the passage before and after
Put the passage in the same order (type  1 then type 2)
The mis-ordering is misleading, but the greater picture is that the guidelines are not safe
This has not been changed as we believe it reads better as it is.
17 5 Main 327 General The eyes are some of the most vulnerable tissues if one is using a thermal approach
Insert your proposed change.
New technologies often put the tranmitter very close to the eyes. Eyes need a more, not less, stringent approach
The GLDs provide protection for the eyes as well, as is stated in the documents.
17 6 Main  And 467 Technical How were factors of 10 and 50 selected? The meeting at Wollongong in 2014 revealed there had not been a scientific basis for this. One needs to be given. This represents an expert judgement taking into account all the conservative steps incorporated into deriving the restrictions. No science is available to specify a particular set of conservative steps in such a derivation.
17 7 Main 479-501 Technical What is the scientific basis for the reduction factors of only 2 and 10 for head, torso and limb exposures? This represents an expert judgement taking into account all the conservative steps incorporated into deriving the restrictions. No science is available to specify a particular set of conservative steps in such a derivation.
17 8 Main Pp14-18 Technical The basic restrictions and reference levels are many times too high to achieve the main objective
Insert your proposed change.
 Context: The importance of permitted exposures being low enough that they do not trigger  bio-effects when said effects are known to lead to disease or ill-health Gly
Where RF-induced bioeffects cause harm, then these are protected against, but when there is no evidence of this, then they are not the subject of restrictions.
17 9 Appendix B 92-138 General The typical short-term exposure method used for evaluating EHS (IEI_EMF) is equivalent to asking participants in an allergy study whether there is a high pollen count after a few minutes outside. Some react quickly and others don’t, or are only react to certain pollens.
However, subjective research approaches are becoming less necessary. Objectively measured bio-effects, also being health effects in several cases, in those who are electrohypersensitive have been published. Research is still limited but includes:
• Belpomme D, et al: Reliable disease biomarkers characterizing and identifying electrohypersensitivity and multiple chemical sensitivity as two etiopathogenic aspects of a unique pathological disorder. Reviews on Environmental Health 2015, 30(4):251-271. Wjpse , who concluded that test indicated, “Inflammation-related hyper-histaminemia, oxidative stress, autoimmune response, temporal lobe capsulothalamic hypoperfusion and Blood Brain Barrier opening, and a deficit in melatonin metabolic availability, suggesting a risk of chronic neurodegenerative disease”.
• de Luca C, et al: Metabolic and genetic screening of electromagnetic hypersensitive subjects as a feasible tool for diagnostics and intervention. Mediators of Inflammation 2014, who tested 153 electrohypersensitivity, 147 multiple chemical sensitivity, and 132 Control participants. Diagnosis involved metabolic pro-oxidant / pro-inflammatory tests for alterations in blood, and selected genetic tests. Results found:
-   Distinctively increased plasma coenzyme-Q 10 oxidation ratio
-   Significantly altered distribution-versus-control of the CYP2C19*1/*2SNP variants
-   Combined presence of genotype Genotype (null)GSTT1 + (null)GSTM1 variants
o confers 9.7 times higher risk of EHS than other GSTM1 GSTT1 combinations

This is not to deny that there may also be those with a psychological response to non-transmitting antennae.
.
Insert your proposed change.
 Context: The importance of permitted exposures being low enough to avoid effects of extremely low „non-thermal“ exposures when said effects are known to lead to disease or ill-health Gly
We do not agree with the author's view and so have not amended the text.
17 10 Appendix B All pages General The review is very poorly referenced with many claims not given a citation and therefore unable to be checked.
Insert your proposed change.
 Context: The academic process of reviewing literature 
It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
17 11 Appendix B 15-25 General Despite the sentence in line 21 starting with ‘accordingly’, the WHO 2014 review which has been used is not the one referred to in line 15.
Remove reference to the upcoming WHO review.
Context: Material reviewed
This has been amended as suggested.
17 12 Appendix B 47-54 General Limiting a review of the literature principally to 2 reviews is entirely unsatisfactory, especially in a field with thousands of publications in the peer reviewed literature. If the current situation is to be assessed through reviewing reviews, then I believe this needs a wide representation and should at least include those with a low proportion of reviewers who appear in other review panels, and few overlapping aspects other than expertise in the subject, as this will most likely cover a broader range of the literature and confirm whether or not a broader range of reviewers reach the same conclusions.
To  this end, certain chapters of the BioInitiative Report (2007, 2012) could be included. This very extensive document (1557 pages), presented chapters each prepared by individual experts (called sections in the document) on an area of their speciality. Each drew their own conclusions, many of which were subsequently published as peer-reviewed papers in a special issue of Pathophysiology 2009. These papers, and more recent studies by these authors, would be well-included in the review as a beginning step to a more representative review and to bring a better balance. Other reviews by authors other than those involved with WHO and SCENIHR should also be included.
Insert your proposed change.
 Context: The importance of reviewing a representative balance of the literature. 
It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
17 13 Appendix B Line 329 onwards:section 9 General Cancer/tumours. The claim of ‘no substantiated evidence’ acts as a block to scientific progress when given with no/thin explanation, little reasoning, or (in many cases) citation of the studies referred to both here and in most other sections of Appendix B
Necessary changes are extensive and should be intrinsic to the review process
 Context: The importance of a robust review process
It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
17 14 Appendix B Line 364 to 367 General The NTP and Ramanizzi studies have been commented on by a peer review panel and other specialists in this field with starkly different conclusions than those provided here.
 Context: The importance of an unbiased review process by a panel which includes specialists in the relevant fields and who are qualified to comment.
As described in Apendix B, please see ICNIRP 2019 for further details about the limitations of those studies.
17 15 Appendix B Line 406 General The Precautionary Principle as stated in 1998 the Wingspread statement says, "When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.” This means that we should not wait until cause and effect relationships are fully established – at that point the action would no longer be precautionary.
With respect to tumours, “indications of an increased risk in high- and long-term users from Interphone and other studies are of concern. There are now more than 4 billion people, including children, using mobile phones. Even a small risk at the individual level could eventually result in a considerable number of tumours and become an important public-health issue”  (Cardis E, Sadetzki S: Indications of possible brain-tumour risk in mobile-phone studies: should we be concerned? Occupational and Environmental Medicine 2011, 68(3):169-171).
It is high time to put a precautionary approach to exposure standards in place now. With regard to exposure from hand held devices, “many public health practitioners have moved from the theoretical level (adoption of the precautionary principle) to an active phase of introducing regulations, with specific emphasis to various populations” (Sagi OI, Sadetski S: Determining health policy for sensible mobile phone use: current world status. Harefuah 2011, 150(3):216-220, 306).
Context: The appropriateness of putting the precautionary principle in place now bearing in mind indications in research to date.
Given the strong knowledge relating to RF-EMF exposure and health, the precautionay principle is not appropriate here and so has not been invoked.
18 1 Main 20 General Since the updating process of the guidelines is defined as to be periodical, the updating period should be indicated as well as should be indicated the typology of advances in research that could trigger an updating process of the guidelines, before the updating period It is not possible to specify such triggers a priori, and so no such specification has been provided.
18 2 Main 27 Editorial ……. directly on tissue, ……  This has been amended for clarity.
18 3 Main 27 Technical ….. rather than via an intermediate object. This has been amended for clarity.
18 4 Main 30-31 General The rationale why carers and comforters are not covered by exposure limits need to be indicated as well as the reasons why they are not considered as people exposed for professional reasons. These are specified as people who are exposed for medical purposes, with the reason for this given in the text.
18 5 Main 43-45 General The guidelines can establish limits to known adverse effect at the time of preparation of the guidelines. The aim of the guidelines is to specify safe exposure levels, regardless of time.
18 6 Main 48-50 Editorial Consider bulleting the conditions This has been considered, but we have kept the text as a narrative.
18 7 Main 88 Technical Carers and comforters, as defined here, are not general public nor occupationally exposed individuals and that is in contrast with lines 30-31 (see comment 4) We cannot see any inconsistency between the two sections and so have not amended them.
18 8 Main 111 General Remove the word „rapidly“ This has been amended as suggested.
18 9 Main 113 Editorial Remove the words „from its source“ This has been amended for clarity.
18 10 Main 119-121 Technical Even inside an exposed body there are both E and H fields This is consistent with what is written.
18 11 Main 590-591 Technical The caption of table 2 refers to electric, magnetic and electromagnetic fields while columns show SAR and Str The tables have been amended completion and this issue resolved.
18 12 Main 601-602 Technical The caption of table 3 refers to electric, magnetic and electromagnetic fields while columns show Local SA and Local Htr  The tables have been amended completion and this issue resolved.
18 13 Main 645-646 Technical Could be not so simple to define a diameter on the base of the antenna shape  We agree that there complexities involved with this.
18 14 Main 697-699 Technical  The caption of table 5 refers to electric, magnetic and electromagnetic fields while column shows Incident plane wave power density   The tables have been amended completion and this issue resolved.
18 15 Main 718-719 Technical  The caption of table 6 refers to electric, magnetic and electromagnetic fields while column shows Incident plane wave energy density   The tables have been amended completion and this issue resolved.
18 16 Main Whole document General In any part of the Guidelines wideband signals are mentioned nor mentioned how to apply guidelines for signals whose power is spread over a frequency band that could be not negligible with respect to the center frequency. All RF signal needs to be accounted for. This is now clearer given the greater detail provided in Section 5.3, which explains how different components of one or more RF signals need to be summated.
18 17 Main 720 Editorial Table 6, Occupational 6 – 300 GHz, a „[„ is missing This has been amended as suggested.
18 18 Main 720 Technical Table 6, the minus sign at power is not intelligible The tables have been amended completion and this issue resolved.
18 19 Main NA Technical A paragraph devoted to definitions is needed. Quantities like incident plane wave energy density and equivalent incident plane wave energy density or incident plane wave power density and equivalent incident plane wave power density need definition for a correct use of the guidelines These have now been defined more clearly.
18 20 Main NA Technical In all the tables where levels are defined as formulas depending on frequency, time or any other quantity, it should be indicated clearly that formulas are only for the determination of the numeric value of the limit and disregarding the physical dimensions of the quantities We believe that the amended wording conveys this intention with sufficient clarity.
18 21 Main 697 Technical Table 5. Note 2 makes use of 6min time average period, but it refers to Table 4 where the time average period is 30 mins, so creating confusion. The tables have been amended completion and this issue resolved.
18 22 Main 711 Technical Table 5, note 5: not applicable in the context of the table The tables have been amended completion and this issue resolved.
18 23 Main Table 3 to Table 6 Technical Tables make reference to each other. This is not helpful for clarity, so creating confusion and misinterpretations. The tables have been amended completion and this issue resolved.
18 24 Main 627-630 Technical Numbers and symbols are used as a method for distinguishing notes for far field or near field regions. Since notes are integral part of the relevant exposure limit, a clear indication of the application field would help in univocally identifying conditions. We have not provided such specification. The reasons for not doing so are given in the revised text.
18 25 Main 685 - 686 Technical Table 4, Note 2: average over the whole body implicates a field sampling over a volume containing the body that should be defined in dimensions, since the Std Dev in human body dimensions could be large. Field sampling depends also on the frequency so the guidelines should address this point since it has a deep impact on assessment of the reference levels Assessment issues are outside the scope of the guidelines and will need to be determined by technocal standards bodies.
18 26 Main 693-695 Technical Table 4, Note *:
for the sake of clarity, since E-field (in radiative region) or both E and H fields (in non-radiative region) must be measured, reference levels for both electric field and magnetic field should be provided also for frequencies over 2 GHz.
Note that those rules were relevant to f < 400 MHz. However, the wording has now changed to make it clearer that E and H are not directly relevant to refernce levels for frequencies > 2 GHz.
18 27 Main 682 Technical Table 4: the table should be consistent with basic restrictions assessment in the upper two frequency ranges that should be 400 MHz – 6 GHz and 6 GHz – 300 GHz respectively  The tables have been amended completion and this issue resolved.
18 28 Main Table 3 and Table 6 Technical It is not clear the context - in terms of time dependence of exposure and type of sources - where to apply the tables. The guidelines should not leave any space to interpretation or lacks in definitions and applicability of reference levels. As an example: a periodic pulse source with a duty cycle time of 10s out of 360s falls in the conditions covered by Table 3 or 6?  This has now been clarified by specifying that all restrictions must be adhered to (i.e. all relevant tables must be considered).
18 29 Main Table 4 and Table 5 Technical Table 5 is a complement to Table 4. What are the reasons to have 2 tables for the same quantity? That creates a lot of confusion and misinterpretation. The tables have been amended completion and this issue resolved.
18 30 Main Whole 5.1 and 5.2 paragraphs Technical A deep and strong revision is required in order to increase clarity, to avoid misinterpretations, to define quantities left undefined, to clarify the context of application and to cover all aspects (frequency bands, sources definition, context of application, lack of reference levels) This has been conducted and we believe it is now much clearer.
19 1 Main 117, 138, 142, 146, 156, 373, 380, 394, 420, 521, 522, 533, 535, 537, 540, 545, 827, 831, 854, 859  Editorial The term transmitted could easily be confused with incident because of the common usage of transmitted to mean energy from the source, i.e. transmitter.
Replace transmitted with absorbed. Line 138 indicates transmitted power density is the power absorbed per unit area. Stick with the usage of absorbed.
Also replace Htr and Str with an alternate such as Habs and Sabs.
Readability
This has now been changed to 'U' (and 'transmitted' changed to 'absorbed').
19 2 Main 145, 156, 420, 533, 537, 720,  725, 726, 734, 854, 859 Editorial Transmitted energy density (Htr) and incident plane wave energy density (Hinc) are new terms to exposure guideliens and should be rethought and possibly repalced. 

These terms are time averaged power density and could be easily be represented by that terminology.

For a reference level Hinc is challenging as it will only be assessed by measureing and averaging Seq. There is no mechanism to measure Hinc directly.

Also it is cofusing to have two important terms represented by the letter H.

A simple method could be applied that indicates that the time averaged power density is the restriction unit and the notation of a macron could be used: S ̅.

Appropriate modifications to the formulas in table 3 and 6 would have to be made to accommodate this change.

As a practitioner of RF exposure assessment it would be good to have terms that are measurable and don’t expand the nomenclature without adding value.
These issues have been considered. Absorbed energy density (U) is now used instead of Hinc. Tables have been updated accordingly.
19 3 Appendix A 98-100 Editorial Seq is not well defined. Modifying the follwoing in Appendix A could resolve this…
S
inc = EH
As it is typical to measure only the E or H field, the equivalent incident power density is defined as;
S
eq = E2/Zo = H2Zo
where Z
o is the characteristic impedance of free space, i.e., 377 Ω.
This has been rewritten to improve clarity. However, some of the suggested specification is beyond the scope of the guidelines and will need to be considered in technical standards.
19 4 Main 645-646 Editorial Diameter is not the G term, only being appripriate for circular aperture antennas. In most instances this equation uses the term dimension.
D and λ refer to maximum antenna dimension and wavelength respectively,
Common usage and more G application
This has been amended as suggested.
20 1 Main  Table 1 Editorial In Table 1, the quantity “incident energy density” was omitted.
An additional row should be inserted to the table to include this quantity (Hinc).
Reference levels (RL) are provided for incident energy density, therefore, this quantity needs to be included in Table 1.
The tables have been completely rewritten, and this issue resolved.
20 2 Main 243 Technical The expression “same absorbed radiofrequency power” might be misleading to the reader.
It would be advisable to change “power” with”energy”: “same absorbed radiofrequency energy”.
The two exposure scenarios concerning“steady-state temperature elevations” and “brief temperature elevations” are related to different incident power densities that lead to different absorbed powers. It is the amount of briefly absorbed energy that cannot rapidly dissipate through thermal processes which is of importance in this matter. In this draft guidelines, basic restrictions for brief exposures are based on quantities related to energy: specific absorption and transmitted energy density.
This has been amended as suggested.
20 3 Main Table 4 Technical Below 1.5 MHz, the frequency-dependent RL values for E-field are large. At 100 kHz, the occupational RL is extremely large: 12.2 kV/m. That is much larger than the RL for nerve stimulation in the 3 kHz - 10 MHz frequency band that is 170 V/m (ICNIRP 2010).
Below 10 MHz, RL for E-field should not exceed about 850 V/m rms. Therefore, I propose to change the E-field RL function below 20 MHz from 1220/f  to 272/ f1/2 , i.e. 272/sqrt(f). This function gives the following values at 100 kHz, 1 MHz and 20 MHz, respectively: 860 V/m, 272 V/m and 61 V/m. Therefore, the target of not exceeding 850 V/m is well accomplished and the value at 20 MHz remains unchanged (61 V/m).
The large RL values for the E-field below 1 MHz, especially downwards 100 KHz do not fit to the RL values and philosophy of the low-frequency ICNIRP guidelines from 2010. ICNIRP recommended that the low-frequency restrictions be regarded as “instantaneous values which should not be time averaged”. Moreover, considering a reduction factor of 5 for occupational exposure was used to set basic restriction for nerve stimulation, we may conclude that thermal RL for E-field in the 100 kHz - 10 MHz frequency band should not exceed by more than 5 times the RL for nerve stimulation, i.e. 850 V/m.
The derivation of restrictions has been based on the logic described in the guidelines, rather than the 2010 LF guidelines. However, the reasons for the changes to the refernce levels have now been clarified in Apendix A, and the nerve stimulation restrictions from 2010 added to the present guidelines.
20 4 Main Table 4 Technical Same as in the case above of the RL for occupational exposure, the E-field RL for G public at frequencies below 1 MHz are very large. At 100 kHz, the G public RL is 5.6 kV/m which is much larger than the RL for nerve stimulation in the 3 kHz - 10 MHz frequency band of 83 V/m (ICNIRP 2010).
In the case of G public, considering an additional reduction factor of 2, the RL for E-field should not exceed about 425 V/m rms. Therefore, I propose to change the E-field RL function below 20 MHz from 560/f  to 125/ f1/2 , i.e. 125/sqrt(f). This function gives the following values at 100 kHz, 1 MHz and 20 MHz, respectively: 395 V/m, 125 V/m and 28 V/m. Therefore, the target of not exceeding 425 V/m is well accomplished and the value at 20 MHz remains unchanged (28 V/m).
The reasons for the proposed change are similar to the ones presented for occupational exposure. Large RL values for the E-field below 1 MHz do not fit to the RL values and philosophy of the low-frequency ICNIRP guidelines from 2010. Considering the additional reduction factor of 2 for the G public, we may conclude that thermal RL for E-field in the 100 kHz - 10 MHz frequency band should not exceed 425 V/m.
See 20.3.
20 5 Main 688 Editorial The mention “… reference levels; only one is required” needs some clarification.
Proposed text: “… reference levels; only one is required, except for near field conditions as specified below.”
Working with various partners like practitioners in the domains of EMF measurement, occupational health and safety, as well as risk management showed the need of clear and complete mentions in a note in order to help good practice.
This has now been rewritten to improve clarity.
20
6 Main 694 - 695 Editorial The mention “…; no reference level is provided for reactive near-field exposure conditions” needs a little clarification.
Proposed text: “…; no reference level is provided for reactive near-field exposure conditions, where compliance with basic restrictions needs to be assessed.”
Experience with practitioners in the domains of EMF measurement, occupational health and safety, as well as risk management showed that clearly mentioning the steps to be done helps good practice.
Further clarification is now provided in the main document tables and Apendix A.
20 7 Main Table 5 Technical Not clear why in Table 6 that specifies RL only for incident power density, the first frequency range starts with 100 kHz. The note 2 for that row redirects to Table 4 where incident power density got values only for frequencies higher than 30 MHz.
The first frequency range should be changed from 100 kHz - 400 MHz to 30 - 400 MHz. Alternatively, if besides the RL for incident power density, the use of the RL for E-field and H-field from Table 4 is intended, this should be clearly mentioned in note 2.
The proposed change is meant to make the Table 5 clearer to reader and to avoid confusions.
The tables have been completely rewritten, and this issue resolved.
20 8 Main Table 5 Technical For frequencies between 400 MHz - 6 GHz, note 3 of Table 5 directs to Table 6 where RL are specified only for incident energy density. But the header of Table 5 specifies RL only for incident power density and not for incident energy density.
To meet the values of 10 W/m2 at 400 MHz and 200 W/m2 at 6 GHz, I propose the following function to specify RL for incident power density between 400 MHz - 6 GHz: 27.5f1.1 , i.e.  27.5*f^1.1
To meet the values of 10 W/m2 at 400 MHz and 200 W/m2 at 6 GHz, I propose the following function to specify RL for incident power density between 400 MHz - 6 GHz: 27.5f1.1 , i.e.  27.5*f^1.1 in the case of occupational exposure. For the G public, proposed function is 5.5f1.1 , i.e. 5.5*f^1.1 that meets the values of 2 W/m2 at 400 MHz and 40 W/m2 at 6 GHz as required by RLs from adjacent frequency ranges.
The tables have been completely rewritten, and this issue resolved.
20 9 Main 709 Editorial Current text: 66-30 GHz
To change to : 6-30 GHz
Typing mistake
This has been amended as suggested.
20 10 Main 724 Editorial Current text: “(the 6 minute average reference levels described in Table 5 are to be used)”
 Question: Is it “Table 4”, actually?
It seems that Table 4 describes the needed  RL.
The tables have been completely rewritten, and this issue resolved.
20 11 Appendix A Line number Editorial Current text: “between dry skin and dry skin”
To change to: “between dry skin and wet skin”
Typo
This has been amended as suggested.
20 12 Appendix A 771 Editorial  Current text: “reference levels at 100 mA and 20 mA”
To change to: “reference levels at 100 mA and 45 mA”
Typo
This has been amended as suggested.
20 13 Appendix B 192 - 194 Technical Current text: “There is no evidence that the microwave hearing effect can affect health, and so the present Guidelines do not provide a restriction to specifically account for microwave hearing.”
Question: Why not making the distinction between health and sensory effects and using the related restrictions as the Directive 2013/35/EC does? A sensory effect restriction may be exceeded if the health effects restrictions are not exceeded.
Maybe keeping providing a restriction in terms of peak SA for hearing effect, together with setting a reference level for peak Hinc would help occupational risk assessors and managers to implement the right measures ?
Please note that the guidelines do not treat sensory effects as adverse health effects, unless they can be shown to result in adverse health effects. The logic underpinning this has been described in the text.
21 1 Main 24 Technical The term "known adverse health effect", although generally used by experts, should be explained by specifying two examples and term “known” should be replaced by “established”.     "established adverse health effects like hyperthermia or tissue burn due to RF-overexposure.     The meaning of adverse health effects should be explained to prevent unnecessary inquiries about what ICNIRP Guidelines aim to prevent.
“Established” refers to high quality internationally accepted research results.   
This is described more clearly in the revision. 'Established' is not used as it has the connotation of 'accepted' rather than scientifically justified.
21 2 Main 25 General The proposed statement that all “known adverse health effects from [...] both short- and long-term“ are mitigated is misleading. Long-term health effects are only discussed in Appendix B (and then classified as not substantiated).
However, their possible existence may not be excluded. Some of the rich research in this area must be acknowledged in the main document of the guidelines instead of having this in the Appendix B. It is not sufficient to just cite SCENIHR and WHO opinions without proper discussion and “hide” citations and a few phrases in the appendix.     Incorporate part of the text of Appendix B or include an explicit reference to Appendix B:
Please add sentence at line 26: A detailed review of the existing literature including an assessment whether the results are substantiated or not is given in Appendix B.     The main document must be comprehensive in means that long term effects are considered by these guidelines, but as literature provides no substantiated effects, separate basic restrictions to protect against long term effects are not given
It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
21 3 Main  line 27 General What about implants? It is not specified if the guidelines are applicable for persons with metallic implants.     Please add: “[...] intermediate objects, i.e. active and passive body worn and/ or implanted medical devices are outside of the scope of these guidelines.”     Scope of the document must be clear. To prevent unnecessary inquiries a clearly expressed scope is preferred. The scope has now been clarified.
21 4 Main 26 Editorial Grammar 
Either "EMF","EMFs", or “EMF fields” should be used consistently in the text.
"EMF" should be used if another word follows, i.e. "EMF xyz" (e.g. EMF exposure)
"EMFs" should be used if another word precedes EMF, i.e. "xyz  EMF" (e.g. radiofrequency EMFs).     consistent wording throughout entire document and appendices
This has been amended as suggested.
21 5 Main 30-38 Technical Medical procedures are beyond the scope of these guidelines AND cosmetic procedures exclude non-medical aesthetic procedures.   line 34: Cosmetic and non-medical aesthetic procedures may also utilize radiofrequency EMFs. ICNIRP [...] as a result of cosmetic or non-medical aesthetic treatments as subject to these guidelines. Scope of the document must be clear. To prevent unnecessary inquiries a clearly expressed scope is preferred.    The current expression excludes aesthetic appliances utilizing EMF without an intended medical purpose. That non-medically-supervised cosmetic procedures are outside scope has now been clarified.
21 6 Main 41 Editorial Insert a space between ISO and 14117 This has been amended as suggested.
21 7 Main 48-53 Technical Inclusion and exclusion of scientific evidence is not fully understood, especially when change of paradigms are based on unpublished literature or pros and cons are not summarized comprehensibly, i. e. appendix A, line 446& 577, or appendix B line 150.     Please describe exclusion and inclusion of scientific evidence more clearly and in particular how it is applicable to these guidelines.    Stating of how something is supposed to be done does not necessarily result in doing so eventually. It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
21 8 Main 44, 159, 161, and entire document Technical The difference between "harmful effects" and "adverse (health) effects" should be explained. In case of no differences, please use “adverse health effects”. Please specify “harm” and “adverse health” and use terms consistently. consistent wording throughout entire document and appendices
This has now been clarified.
21 9 Main 65 Technical Add for clarification      Please add: ”[...] variability in the population (e.g. age, gender), variance […]”  This has been amended as suggested.
21 10 Main 66 Technical Please add: “[...] environmental factors (e.g. air temperature, humidity, clothing), dosimetric uncertainty […]" This has been amended as suggested.
21 11 Main 95-96 General We welcome the statements regarding the protection of fetus.  Please specify protective aims for the respective gestational ages. Additional specifications may prevent uncertainties in applying these guidelines. No further protective measures are deemed necessary (beyond adherence to the restrictions) and so have not been added.
21 12 Main 128-130 Technical Reference to the frequency range for nerve stimulation is missing.  Please add at line 130: “[...] (Mir, 2008); please refer to section 4.3.1.” We did not believe that this was sufficiently important to add.
21 13 Main 129 Editorial Please replace by “dielectric This has been amended as suggested.
21 14 Main 153 Editorial units of watt instead of "units of watts" This has been amended as suggested.
21 15 Main 156 General The physical quantity of energy density  is per SI-unit J/m³ a volume metric and is not used in areal contexts. Therefore it is not adequatly applicable to the addressed physical context. Using H for mag. field strength as well as for energy density is misleading This has now been changed to 'U' (and 'transmitted' changed to 'absorbed').
21 16 Main 156 Table 1 Technical Hinc is not explained in table 1. Cf comment 15, and please add: Hinc  Incident plane wave energy density (J.m-2).     Table 1 should serve as guide for all basic restrictions and reference levels. The tables have been completely rewritten, and this issue resolved.
21 17 Main 156, Table 1 Technical Seq is not explained further in the document, nor in the appendices.     Please add explanation. The tables have been completely rewritten, and this issue resolved.
21 18 Main 156 Table 1 Technical Radiant exposure is not a unit but a quantity .     Add "radiant exposure" in the 1st column after a comma to Transmitted energy density and replace it in the column of units by "joule per square meter" The tables have been completely rewritten, and this issue resolved.
21 19 Main 157 Editorial Add the chapter number 4.2

This has been amended as suggested.
21 20 Main 233 Editorial humidity is missing, see comment #10. Please add:
”[…] such as environmental temperature, humidity, clothing, and work rate.”
This has been amended as suggested.
21 21 Main 260, 869 Editorial ACGIH, 2017 is cited, but in the reference only 2 publications from 2018 (2018a and 2018b) are listed  This has been amended as suggested.
21 22 Main 272-282 Not Given The shift from 6 to 30 min averaging time (duration) is a significant deviation from ICNIRP 1998 Gdl. The fact should be highlighted and thoroughly explained, especially in means of additional evidence. This is described in more detail in Apendix A.
21 23 Main 287-288 Technical For higher penetration depth isn't it true that the largest contribution comes from "conduction"?     “[...] environment through convection and conduction; this is [...]” This has been rewritten to clarify this point.
21 24 Main 296, 590 Tab. 2 Technical Above 6 GHz now 2 basic restrictions are proposed: wb-SAR and local power density Str.
1.) following the discussion in lines 296 ff , body core heating and exceeding wb-SAR seems unlikely, provided Str values are met over the body surface
2.) with those proposed restrictions, assessment for wb-SAR will be compulsory for many (upcoming) technologies. How should this be done in practice, if there is (except Brockow et al.) apparently no literature on this subject yet?     Wb-SAR should be applicable from 100 kHz to 6 GHz only with Str applicable between 3 - 300 GHz.     To change the paradigm of using SAR up to 10 GHz we rate the presented scientific evidence (e.g. one study about treatment of Fibromyalgia in a very different frequency range with completely different mechanisms of heat absorption) as nonsufficient and presented too intransparent. Please back up the here presented argumentation similar to IEEE C95.1a from 2010.

Applicability is an important issue.
The standing of the evidence, and why it leads to the conclusion that a restriction is warranted, is provided in the text.
21 25 Main 319 Editorial The citation "Yarmalenko et al." is not included in the references This has been amended as suggested.
21 26 Main 321 ff General Classification of tissue, normothermal temperature, and choice of operational adverse health effect thresholds (OAHET): 1.) The classification of the whole „limb“ as type 1 tissue with a normothermal T of < 33-36 °C (even in deeply-lying tissue of the thigh!) is absolutely not plausible and not covered by the cited reference where only superficial (skin) temperature at moderate ambient temperatures are given.     In hot environments temperature at the thigh is comparable to the trunk.     2.) An OAHET of +2°C for brain tissue (type 2, normothermal T of ~38°C) seems to be also quite high and defined only such, that a value of SAR-head 10 W/kg together with a heating factor of 0.1°C/kg*W still allows for a (quite low) reduction factor of 2.                                1.) OAHET for relative temperature of +5°C for type 1 tissue (skin, whole limbs…) must be reconsidered!     For superficial (skin) temperature over the body in given environmental temperatures see e.g. Deetjen Speckmann, “Physiologie” (6. ed, 2013).    2.) OAHET for brain tissue should be checked for conservativeness. These issues have been considered and argued for in the text. No evidence is given to suggest that this approach is not appropriate.
21 27 Main 326 Editorial Please replace:
"thermo-normal" with "normothermal"
This has been amended as suggested.
21 28 Main 339, Tab. 2 Technical The definition of  “Limbs”, comprising the upper arm, forearm, hand, thigh, leg and foot leads to problems together with an occ. basic restriction of SAR-limbs 20 W/kg .    Even for skin at the limbs, with a possible heating factor of 0.2°C/kg*W, 4°C might be reached so that only negligible safety or reduction factor is left.   Definition of limbs needs to be more accurate (see IEEE Std C95.1-2005, Annex C.2.2.2.  Definition of extremities starting form elbows and knees).   OAHT for relative temperature of +5°C as well as SAR-limbs needs to be reconsidered, also in view of heating factors for limbs. Further clarification of the heating factor derivation is provided in Apendix A. We believe that our definition of limbs is appropriate for providing safety.
21 29 Main 378-379 Technical Please add:
“[...] below the type-2 tissue operational adverse health effect threshold (2°C).”
This has been amended as suggested.
21 30 Main 382 Editorial Replace "2.15 x 2.15 cm" with
"2.15 cm x 2.15 cm"
This has been amended as suggested.
21 31 Main 420, 147 Technical Why do you use Htr and Str instead of Hinc and Sinc for basic restrictions. Please specify 1) the differences between transmitted and incidence quantities more precisely and (2) why transmitted quantities are preferably used. This has now been changed to 'U' (and 'transmitted' changed to 'absorbed'). The reasons for this are described in Apendix A.
21 32 Main 423-424 Technical SA and Htr are conservative in that, under worst-case (adiabatic) conditions, they are not sufficient to raise temperature by 5°C. Please specify, why do you refer to tissue-type 1 when stating “conservative” and “worst-case conditions” instead of tissue-type 2? In means of wearing sources in close proximity to the body, e.g. smart body worn appliances like smart glasses, all tissue types should be considered. Therefore a “conservative” and “worst-case condition” should consider tissue type 2 with max. permitted temperature raise of 2°C. This has been reworded to clarify that neither the 2 or 5 deg tissue temperature rises will be exceeded.
21 33 Main 433, 434 Technical What does "...as well as exposure and health more generally," mean? Please clarify or delete these words. Referring to a relationship between exposure and health more generally is too vague. This has been amended as suggested.
21 34 Main 449 Editorial Please add “[...] operational adverse health effect threshold [...]” This has been amended as suggested.
21 35 Main 478 Editorial Probably "Torso" should be written with an upper-case letter. This has been amended as suggested.
21 36 Main Lines 567, 582, 585, Sec. 5.1.6.  General High OAHET values  are based on normothermic conditions, only. For hot environments such as workplaces involving heat or elevated ambient temperatures only vague guidelines for risk mitigation are given, some of which appear unrealistic. How should a worker verify his body (core) temperature while performing a task?     For superficial exposure, discomfort & pain might come as a warning, but VHF and UHF exposure will not be superficial!     Please elaborate on risk mitigation in respect to workplaces with high heat load. Workplaces with relevant RF-exposure and high heat load may not be adequately covered by these guidelines. Further guidance for occupationalupational exposure has been provided, including reference to additional heat loads.
21 37 Main 606 Editorial for t < 1 s, t = 1 s must be used This line has been removed.
21 38 Main 626-627 Technical Please add: “[...] averaged over 6 minutes; table 7, for detailed information refer to Appendix A, 4.6).”     Provided links to all relevant information at one point. This has been structured to make the document more accessible, which has involved moving some of the more technical detail to the appendices.
21 39 Main 631, Tab. 4 General It is not discussed here, and thus remains unclear how ICNIRP 2018 (whole-body) reference levels may deviate strongly from ICNIRP 1998 in the kHz and few MHz region, while the basic restrictions have been kept constant.     Discuss (and cite if necessary) basis of change in reference levels.   The document must be comprehensive and must explain significant changes relative to previous guidelines.  This is now clarified in Apendix A.
21 40 Main 632 Technical It is not explained what "reactive and radiative" means. Please add: “[...] radiative near field; for detailed information see below. [...]”. This is now further clarified in Apendix A.
21 41 Main 637 Technical due to a range of factors is too non-specific and should be amended by a few examples. This is now further clarified in Apendix A.
21 42 Main 643, 644 Editorial Please replace "λ/2π" with "λ/(2π)" or "λ/(2.π)". This has been amended as suggested.
21 43 Main 644-645 Editorial Please explain relevant differences in reactive and radiative nearfield as well as far field.  This is now further clarified in Apendix A.
21 44 Main 643-644 Technical For occupational sources, the reactive nearfield is expected to be larger in area. Therefore applying far-field reference levels to reactive near-field exposures may lead to an underestimation and hence over exposure. Please use a more conservative approach to determine the transition from reactive to radiant near-field with “2λ”. For detailed information please refer to: Vallauri, R. et al.: “Electromagnetic field zones around an antenna for human exposure assessment”, IEEE Antennas and Propagation Magazine, vol. 57, no. 5, pp. 53-63, 2015. This has been considered, with the final determination clarified in the main document and Apendix A.
21 45 Main 644 Technical 2D²/λ is not sufficient for mobile antennas Such complexities and how they should be addressed are described in Apendix A.
21 46 Main 661-680 Technical ICNIRP guidelines must aim to protect 100% of occupational and general public against adverse health effects.     The statement in line 650-651 severly discredits the protection scheme of these guidelines and hence the credibility of ICNIRP at large.     Please reconsider the frequency ranges, values, or even reduction factors of basic restrictions in order to guarantee that when reference levels are met the respective basic restrictions are not exceeded. Note that this comment relates to the relation between basic restrictions and refernce levels, and not to health protection. This is clarified in the guidelines.
21 47 Main table 5, 6 General Very difficult to apply and confusing.   Please don’t use links to different tables with various physical quantities and frequency ranges.     To avoid misinterpretation, these guidelines should provide a userfriendly and unambiguous structure and layout. The links to other tables have been removed.
21 48 Main Table 4, Note 3 and # Editorial As stated in these guidelines, explanations in # contradict note 3. The tables have been completely rewritten, and this issue resolved.
21 49 Main Table 3, Note * Technical If the more general approach to field zones (please refer to comment line 643-644) is accepted, the area covered by reactive near-field is larger.  Therefore, please provide guidance of how to assess occupational exposure and with what physical quantities to comply with. As currently stated, guidance about what physical quantities to comply with is missing for f > 400 MHz. The text and tables have been redrafted to make the specifications clearer. Some, however, will rely on input from technical standards bodies (as stated in Apendix A).
21 50 Main Table 5&6 Editorial The exponent is not written clearly, as negative sign is very hard to spot. The tables have been completely rewritten, and this issue resolved.
21 51 Main Table 5 Editorial Exposure time provided in table header is condratictory. The tables have been completely rewritten, and this issue resolved.
21 52 Main Table 5, note 2 Technical Please provide additional guidance, with what physical quantities local exposure with f ≤ 30 MHz should comply with. The tables have been completely rewritten, and this issue resolved.
21 53 Main Table 5, note 4 Editorial 66-30 GHz This has been amended as suggested.
21 54 Main Table 5, note 4 Editorial Please add:
“[...] in space, approximating the exposed body surface.”
This has been amended to clarify this issue.
21 55 Main Table 6 Editorial opening square bracket is missing The tables have been completely rewritten, and this issue resolved.
21 56 Main Table 6, line 722 Editorial Please add:
“1. f is frequency in GHz; ‘t’ is time interval, in seconds; for t < 1, ‘t = 1’ must be used.”
The tables have been completely rewritten, and this issue resolved.
21 57 Main table 6, note 3 Editorial Please add:
“[...] in space, representative the exposed body surface.”
This has been amended to clarify this issue.
21 58 Main Table 6, note 4 Editorial We assume, that one must calculate Hinc 2times: firstly based on E-value and secondly based on H-value. This is described in Apendix A.
21 59 Main 740 Editorial Please elaborate on reasons for extending the applicable frequency range down to 100 kHz. This is described in Apendix A.
21 60 Main 741 Technical It is not explained why a value of 45 mA is recommended instead of e.g. 20 mA, which would be a factor of 5 lower than the 100  mA for occupational. Please provide additional guidance, why a smaller reduction factor is used. This is merely a scale issue (a RF of 5 relates to power, whereas this is current and thus sqrt[5]).
21 61 Main 760 and 774 Editorial Please use established terminology “touch” and replace “point” and “finger”. This has been amended as suggested.
21 62 Main 807 Editorial Add a full stop at the end. This has been amended as suggested.
21 63 Main 823, 833 Editorial Replace "5.4.1" with "5.4.1." This has been amended as suggested.
21 64 Main Sec 5.4.2 Technical Clarify summation rules! Proposed:
> 400 MHz: maximum of assessment in E, H or S
< 400 MHz: E and H must both be satisfied 
Summation rules have been redrafted and now deal with this issue.
21 65 Main 825-828 Editorial Missing index “i” in the denominator of equation 1 and 2. Summation rules have been redrafted and now deal with this issue.
21 66 Main 825-840 Technical With coming radio technologies (e.g. small cells, small cell under an umbrella macro cell) it might be necessary to consider the exposure of all frequency bands of different types of sources – nearby and distant sources. Applying only reference levels might be over conservative. Applying only whole body SAR values is not practical for macro cells which will be at a distance of 10 m or 20 m or more.
In such an exposure situation it might be appropriate to consider the exposure of nearby sources using the whole body SAR values and the exposure of distant sources using reference levels.
Summation rules have been redrafted and now deal with this issue.
21 67 Main 831 Editorial Check whether S in Str is used as a vector quantity and therefore has to be written non-italic (cf. table 2) and S bolded? The font used for vector/scalar values has now been clarified, and used consistently through the documents.
21 68 Main 833-846 Technical Clarification is required regarding what restrictions to comply to.   Please add at line 835:  “[...] field strengths should be applied to the field levels with equations 3-5 to be fulfilled;”
The summation rule section has now been redrafted and now deals with this issue.
21 69 Main 853, 861 Editorial Cf comment 63 This has been amended as suggested.
21 70 Main 883 Editorial Please replace "wärmehaushalt des menschen" with "Wärmehaushalt des Menschen" This has been amended as suggested.
21 71 Main 899 Editorial Please add a blank line after line 899 This has been amended as suggested.
21 72 Main 954 Editorial Please replace "Biololgy" with "Biology" This has been amended as suggested.
21 73 Main 963-965 Editorial Please shift this reference after line 990 and add a space between "guide" and "for" in line 964 This has been amended as suggested.
21 74 App A 17 Technical Please add:
“[…] document, the operational adverse health effects threshold (OAHETs)”
This has been amended as suggested.
21 75 App A 70 Editorial Please replace "kg m-1" with "kg×m-3" This has been amended as suggested.
21 76 App A 71, 72 Editorial Please replace "STR" and "HTR" with "Str" and "Htr" These have been removed from the text.
21 77 App A 85 Technical Please specify H* for further use. This has been amended as suggested.
21 78 App A 94 Editorial Is "strength" the correct technical term or "value"? This has been amended as suggested.
21 79 App A 114 Editorial Does the same exist for TE waves too? This has been reworded for clarity.
21 80 App A 135 Technical Please add: “[...] heat transfer from the body surface to air via convection or radiative emission, including the effect of vasodilation […]” This has been amended as suggested.
21 81 App A 213-216 Technical Please provide an equation to describe the relationship described in lines 213-216. This is beyond the scope of Apendix A.
21 82 App A 244 Technical Please add: "[…] in term of the whole body average SAR limit in order to be more conservative." The conservative nature of this decision has now been stated.
21 83 App A 273 Editorial Please double check citation. This has now been amended.
21 84 App A 300 Editorial Replace "Hirata et al." with "Hirata" This has been amended as suggested.
21 85 App A 301 Editorial Replace "Watanabe et al.2007" with "Watanabe et al. 2007a"  This has been amended as suggested.
21 86 App A 326 Editorial Please add: “[...] this is that the operational adverse health effect thresholds [...]” This has been amended as suggested.
21 87 App A 366 Editorial Please add: "[…] surface tissues for frequencies higher than about 6 GHz." The lack of precision has now been emphasised.
21 88 App A 369 Table 3.1 Editorial Delete all full stops after the single number and provide equal amount of decimal places after zero. This has been amended as suggested.
21 89 App A 446 Editorial Please add: "[...] (Kodera et al. 2018, unpublished) [...]

This has been amended as suggested.
21 90 App A 446, 456, 976 Technical Please wait for published (peer reviewed) results or provide additional references supporting the new operational health effect threshold. The published paper has now been cited.
21 91 App A 481 Editorial Replace "et al" with "et al." This has been amended as suggested.
21 92 App A 577 Technical Please add: “[...] (Kashiwa at al., 2018, unpublished).”  This reference has been removed.
21 93 App A 617 Editorial Clarify whether it is "Hirata et al. (2009a), (2009b) or (2009c)"

This has now been clarified.
21 94 App A 680 Editorial Clarify whether it is "Hirata et al. (2008a) or (2008b)"  This has now been clarified.
21 95 App A 693 Editorial  Please add: “[...] reference level is lower than at other frequencies."  This has been amended as suggested.
21 96 App A 702 Editorial  Please replace: "λ/2π" with "λ/(2π)" or "λ/(2.π)"    This has been amended as suggested.
21 97 App A 705 Editorial Please add: "[…] body exponentially decays theoretically in the direction […]"
This was not changed as we believe it was unnecessarily detailed.
21 98 App A 709 Editorial Replace "2007" with "2007b" This has been amended as suggested.
21 99 App A 709 Editorial Replace "Kuhn" with "Kühn" This has been amended as suggested.
21 100 App A 898-900 Editorial Please check running order of references: Shift the reference of “Gandhi …” after line 904 (reference Gabriel … 2005. This has been checked and amended accordingly.
21 101 App A 992 Editorial Please add page numbers: 593-595 (as per BioEM2018 Abstract Book) The published paper has now been cited.
21 102 App A 996 Editorial Start with the last name and then add the first letter of the first name for all authors. This has been amended as suggested.
21 103 App B 5 Editorial As per Appendix A, please change font style in Italic. This has been amended as suggested.
21 104 App B 47 footnote 1 Technical Is it really true that details concerning "substantiated" can be found in the main guidelines? Please provide detailed information about where to find the promised details. Yes, this is in the main guidelines document.
21 105 App B 54 Technical Nothing is said on cancer!!! Please add additional reasoning why cancer is not of importance at this part of your argumentation. Cancer is considered in detail later in the document.
21 106 App B 150 General Blood-brain barrier leakage has been shown not once, but repeatedly. It remains unclear what level of exactness in replication is needed for ICNIRP to acknowledge a result being replicated.   Please reassess risk for blood-brain barrier leakage based on a consistent wording and a clear classification of evidence. This issue has been considered and we do not agree that there is evidence that RF EMF affects the BBB. No evidence was provided to the contrary.
21 107 App B 176 Technical It is not clear, what point is made by the statement about eye blinks in means of thickness of eye lid with approx. 0,5 mm in relation to table 3.1 (Appendix A) stating penetration depth of 30 GHz with 0.92 mm, 60 GHz 0.49 mm and 100 GHz 0.35 mm.     Please specify your conclusion, e.g. what effects exactly are precluded by blinking at what blink rates. This has been amended for clarity.
21 108 App B 191 Editorial Please replace "Roschmann" with "Röschmann" This has been amended as suggested.
21 109 App B 321 General Please reassess risk based on a consistent wording and a clear classification of evidence.  A consistent wording and a clear classification of evidence (and risk) must be found and kept throughout the document. NTP or IARC classifications might be used  Wording has been checked for consistency, and the methods of evaluation have been described in the text.
21 110 App B 390 General Malignant neoplasms in the temporal lobe are actually rising, e.g. in UK . Please include de Vocht, 2016, https://doi.org/10.1016/j.envint.2016.10.019 into discussion and decide transparently about its inclusion. This has been considered in the evaluation.
21 111 App B 348 Technical There exists a newer draft from the NTP-study.   Please cite the current NTP-(draft) version, when these guidelines are published. This has been amended as suggested.
21 112 App B 476 Technical The results of the German Mobile Telecommunication Research Program (DMF-Project) http://www.bfs.de/EN/bfs/science-research/results/dmf/dmf_node.html were not included into the discussion.  Please consider the results from DMF in respect to acute effects, chronic effects, and action mechanisms and decide transparently about its inclusion.

It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
21 113 Main 825-828, in relation to table 2 General SAR is physiologically correct applicable only up to frequencies of 6 GHz, with a transition zone into S (from volume to areal metrics) between 3-6 GHz. Please refer to IEEE C95.1a (2010).  Please replace Equation 7 by Equation 8 We do not agree with this position and so have not changed this.
21 114 Main 825-840, in relation to table 2 General Cf comment 66 and SAR is physiologically correct applicable only up to frequencies of 6 GHz, with a transition zone into S (from volume to areal metrics) between 3-6 GHz. Please refer to IEEE C95.1a (2010). Please replace Equation 9 by Equation 10 We do not agree with this view and so have not changed this.
22 1 Main  146, 147, 156,420, 421-423, 602, 605, 854-860  Technical Issues:     1) The use of the letter H both to represent Htr / Hinc – transmitted- / Incident-  energy density and elsewhere H on its own to represent the magnetic field is unnecessarily confusing.  Editorially, subscripts are conventionally used as qualifiers to the main letter script and not to completely change the represented variable.     2) With respect to Table 1, radiant exposure is NOT a unit and the term is not used elsewhere in the guidelines.     3) “Energy density” as introduced in these guidelines is not a metric which is generally used or measured in practical radio engineering applications. Further, the term “density” is more commonly associated with a volume or a mass rather than an area so may confuse readers until they really study what ICNIRP intends e.g.  https://en.wikipedia.org/wiki/Energy_density,  https://energyeducation.ca/encyclopedia/Energy_density,   https://energyeducation.ca/encyclopedia/Energy_density_vs_power_density                                      Alternative expression to Htr and Hinc:    An alternative metric can easily be defined which is traceably representative of the intended “energy density”, and which relates better to common practices. Using this would aid comprehension and practical application of the guidelines.    Representing the basic restriction limit in terms of the rate of power absorbed accross the skin boundary in a given area – with specified time averaging - is of equal validity in physics and avoids the need to use „transmitted energy density“ at all.    Since Htr = Str*1/t, the basic restriction could equally be expressed  in terms of time-averaged Str  with (virtually) the same notes and with equal physical accuracy.     Similarly,  the corresponding reference level Hinc can be expressed in terms of  time-averaged Sinc  considering Hinc = Sinc*1/t     The key thing for the guidelines to empasise is the ‘tr‘ subscript – i.e. the part of the incident field Sinc which crosses the surface of the body and is absorbed in the body (with specified averaging area) – and the time-averaged qualifier defining the time avaraging.     This alternative expression also gives better linkage for comparison of local and whole body restrictions.     See also comments 5 and 6; Unable to specify a correction to this problem since it is for ICNIRP to clarify the local exposure limit relaxation with respect to whole body exposure limit at 400 MHz. These issues have been carefully considered, and in most cases acounted for.
22 2 Main 682 Technical Table 4 Issue - There should be no discontinuities such as step changes in reference limits at boundaries between frequency ranges.    Reasoning:   1) Discontinuities in limits at specific frequencies are difficult to accommodate in practical „shaped“ field probes and so constitute an additional measurement uncertainty in compliance measurements.   2) A step change in limit at a specific frequency makes no sense biologically, thereby reducing confidence in the ICNIRP guidence.   3) More precise definitions are no more difficult to implement in computations than less precise definitions.   For brevity, the changes proposed below also include aspects of comments 3 and 4. Step functions have been removed in most cases.
22 3 Main 682 Technical Table 4 issue -  reference levels for >2 GHz do not include electric and magnetic field strengths.   Reasoning:    1) Excluding E and H as valid reference levels implies an evaluation of the Poynting vector in computation.   2) E H exclusion implies need to measure both E and H vectorially at 2 to 6 GHz even in the far field.    Consequence:    It would no longer be valid to determine Sinc above 2 GHz by measurement using an instrument with only an electric field isotropic probe. This would have serious practical implications for measuring whether a specific far-field exposure circumstance is within the guidelines. Measurement issues are outside the scope of the guidelines. The refernce levels (and quantities) themselves were chosen to provide safety for the user, and to do so required us making this choice. Please see Apendix A for more explanation.
22 4 Main 430-434, 682 Technical Issue: - The 2018 guidelines do not include the more-restrictive limits from the ICNIRP 2010 guidelines within the overlap frequency range 0.1 to 10 MHz.
Reasoning:
1) Splitting up the exposure limit guidance between 2010 and 2018 on the basis of health effect AND frequency range is very confusing. 
2) For the development of compliance procedures and regulations it is more important the ICNIRP guidelines clearly express the values of the limiting EMF parameters at any stated frequency rather than the limiting effect. Traceability is also required as to what effects are being covered but this can be in the appendices.
3) Where there is a frequency overlap between 2010 and 2018 guidelines (ie 100 kHz to 10 MHz) then the 2018 guidance should give the critical exposure considering all effects which ICNIRP consider relevant at any given frequency.
4) Discontinuities in limits at frequency boundaries should be avoided -  see comment 2.

It can be seen from the following table that if the ICNIRP 2010 guidelines are still valid, then the ICNIRP 2018 guidelines do NOT provide the reference level against the limiting effect for at least some of the frequency range below 10 MHz. The discrepancy being a factor which can be over 60x.

See comment 2

See tables in sheet Zollmann table comment#4
The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
22 5 Main 731-738 Technical Local exposure Table 6 Issue - Gross discontinuity in local exposure limit at 400 MHz
Reasoning:
The Table 6 reference levels for local exposure of (just under) 360 seconds should be consistent with the 6 minute average reference levels in Table 5 for exposures for >= 360 seconds.
Table 6 399.999 MHz Note 2 applies referencing Table 5   
Table 5 399.999 MHz Note 2 applies referencing Table 4
Table 4  399.999 MHz   Occupational Sinc = 10 W m-2
Table 6 400.001 MHz Occupational 360 Sec: Hinc = 0.8 * 0.4^0.51  * (2.5 + 1.77 Sqrt[360 - 1] ), Hinc = 18.067 kJ m-2
If we consider that one watt = one joule per second;  Sinc( W m-2) = Hinc(kJ m-2) *1000/t(seconds)
To convert to equivalent Sinc for 360 sec exposure,   Sinc = Hinc*1000/360 = 50.19 W m-2 
I.e. At 399.999 MHz, the local peak incident field limit (360.01 sec exposure) is 10 W m-2 whilst at 400.001 MHz the local peak field exposure for 299.999999 sec) is 50.19 W m-2

If the same comparison is done at 6 GHz
Table 4  6. GHz Occupational, whole body exposure Sinc = 50 W m-2
Table 5  6 GHz Occupational 6 mins, local exposure  Sinc = 275 * 6^-0.177 = 200.26 W m-2
Table 6  6 GHz Occupational 360 seconds, local exposure:  Hinc = 2.75 * 6.0^-0.177  * (2.5 + 1.77 Sqrt[360 - 1] ), Hinc = 72.168 kJ m-2
Using  Sinc( (W m-2) = Hinc(kJ m-2) *1000/t(seconds) gives   Sinc = Hinc*1000/360 = 200.47 W m-2 
For the 6 GHz case, the Table 5 and Table 6 local exposure reference levels align reasonably well (proving conversion Hinc to Sinc equiv) and shows a factor of 4 difference between whole body average (over 30 mins) and local peak exposure (over 6 mins) , with the local peak exposure allowed to have the greater instantaneous field level – as might reasonably be anticipated.

This discontinuity might have shown up earlier ICNIRP deliberations had the reference values been expressed in consistent units.
In the context of a reference level definition, i.e. for fields in the absence of the body, it is far better to express guidance limits in a way which is widely known and well understood.  For short-duration local peak exposure, rather than using term “Incident plane wave energy density” the above shows how to continue to use Sinc also for short duration local exposure limits, fully consistent with physics and giving easier comprehension of the ICNIRP limits.
See comment 1
These issues have been carefully considered, and in most cases acounted for.
22 6 Main 697-738 Technical Issues:
1) Table 5 and Table 6 both introduce reference limits for local exposure but use different metrics (comment 1).
2) Table 6 refers to Table 5 which refers to Table 4. Table 5 refers forward to Table 6. The complexity of having two tables for local exposure reference levels is unnecessary.
3) The formula in Table 6 for Occupational Incident plane wave energy density for frequency range >6 GHz to 300 GHz is missing an opening “[“.
4) In the presentation of Table 6 formulae for the limits >6 GHz, the “-“ sign is not very clear.
5) In Tables, formulae should be simplified such that constants are multiplied out so that no extraneous multiplication of constants is required to determine the guideline limit.  Using square root sign would also make the formulae more readable compared with (.....)0.5.  The detailed explanation of how the limit numbers were derived can be included in the Appendix A.
6) The use of numeric and # * note “numbering“ is unnecessary.
7) Table 5 and Table 6 can easily be combined into a single table expressing a metric which can be measured, and the notes simplified - provided the constraints on t are defined as: t<1, t set to 1; and t>360, t set to 360.
8) Note 2 includes term “equivalent incident plane wave energy density” which is not used anywhere else in the guidelines and hence is undefined.
9) Table 3 includes a note limiting the minimum value of t to 1 second – a constraint which is also needed when defining the local exposure reference levels to avoid having a square root of a negative number in the limit definition.

Reasoning:
1) The primary difference between Table 5 and Table 6 is the exposure time. In Table 5 t is set at 6 mins (or rather 360 seconds) and “built in” to the formulae for the reference limits while in Table 6 t is expressly used in more complex formulae leading to a value for a metric which is not directly measurable (one of the key tenets of a “reference” level).
2) Consider that Sinc = Hinc*1000/t   - (x 1000/t to convert kJ m-2 to W m-2)
3) Having a single table for reference levels for whole body and a single table for reference levels for part body exposures simplifies the guidelines.

See comment 1

The tables have been completely rewritten, and this issue resolved.
22 7 Main e.g 699 All Editorial Editorially express frequency ranges in a consistent format.   Choose a clear format.  Use form as per line 707  “ >400 MHz to 6 GHz“ rather than the form of line 709    “>30-300GHz“.

This has been amended as suggested.
22 8 Main All Tables with notes Editorial Review and revise all tables applying the following editorial formatting rules:
a) „Notes to Table ....“ – heading for notes under the Table
b) For notes applicable to complete columns, include “see note 1" as part of the column header
c) For notes applicable to complete rows, include “see note 1..” as part of the row header
d) For notes applicable to specific cells, include “see note 1..” as part of the cell information
e) If there are notes remaining which are not then referenced, delete them since they are not relevant to that table.
The tables have been completely rewritten, and this issue resolved.
22 9 Main 522, 523 Editorial Care should be taken to avoid confusing line breaks due to automatic justification by the editing software. The numeric value and ALL the text defining the associated unit should be on the same line.  Having the „2“ on the following line  to „W m-„ is really poor presentation.     Line 523 - 200 W m-2 The formatting has been amended as suggested.
23 1 Main 685 General Although the 30 minutes averaging (6 min in the ICNIRP 1998) can be understood for the basic restrictions, when it is kept for the reference levels it makes this guideline very difficult to use in real life. For example, if measurements for exposure assessment have to be done around telecom base stations (something quite common in some countries nowadays), to do it at several points with a 30 minute average makes it is very time consuming. When 3, 6 or 9 measurements for spatial average have to be made for every points, it makes it really difficult, it makes it a whole working day to test a single site.
In the past last years many people have been wishing for a shorter than 6-min time period for practical reasons, now this is in the opposite direction.
There are a lot of safety margins between 6 W/kg-1 hour to 4 W/kg-30 min to 0.4 W/kg-30 min to 0.08 W/kg-30 min. We do not see the reason to make measurements much more time consuming and to make the people believe you are relaxing the conditions.
We propose the averaging to stay at 6 min, at least for the reference levels. When exposure is compliant for any 6 min, it will be compliant for any 30 min.
Note that measurement duration does not necessarily need to correspond to exposure duration for refernce levels (this will depend on independent measurement standards). This is now clarified in the text.
23 2 Main Table 4 Technical Reference levels below 10 MHz are higher than those of ICNIRP 2010. As stated in line 430, in order to be compliant,  ICNIRP 2010 reference levels must not be exceeded so the reference table should be consistent with ICNIRP 2010.
Modify Table 4 to comply with ICNIRP 2010. One example: occupational levels should be 170 V/m from 100 kHz to 7,06 MHz
We need to be consistent with ICNIRP 2010 and do not offer reference levels based on phenomena but based on frequency range.
The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
23 3 Main Table 5 Editorial  Notes make the table very hard to understand and confusing.
Note 3 should be replaced with a value (calculated from the table 6 where t= 360).
Note 2 should be replaced also by some values taken out the table 4 (this would oblige to create more lines and columns with the limit in V/m and A/m). A note should explain what is the spatial peak value, to avoid misunderstandings. We understand it is the maximum value out of the different points considered for a spatial average, not the peak value of the signal.
The tables have been completely rewritten, and this issue resolved.
23 4 Main Table 5 Technical Reference levels present some discontinuities at 400 MHz. Occupational: 10 to 50 W/m2 and public 2 to 10 W/m2.
Limits should be continuous
Discontinuity cannot be admitted as it does not represent any physical phenomena
The restrictions have been reconsidered to provide continuity where possible. This has reduced the number of step functions considerably.
23 5 Main 709 Technical We cannot see any practical way to measure these limits with these surface restrictions.
Maybe it could be define a maximum antenna length or maximum isotropic antenna volume.
EMF measurements are typically made with isotropic probes. To be isotropic, probes must have a volume, not just a surface.
Measurement issues are outside the scope of the guidelines.
23 6 Main Table 6 Editorial There is no comment on the case where t is below 1 second.
Table should have a note explaining that if it is below 1 second, 1 should be use anyway
These formulas have been revised to account for these and other issues.
23 7 Main 836 Technical We are concerned with the formula because it means that you can have 2 signals, one below 30 MHz and another above 2 GHz, each of them equal to the reference limit, and still complying because the whole frequency range from 100 kHz to 300 GHz is not taken into account.
We propose to write only the first 2 formulas but from 100 kHz to 300 kHz and state that compliance with both have to be demonstrated in the near field, while compliance with one of them is enough in the far field.
ICNIRP 1998 did englobe the whole frequency range for these formulas.
All signals are now included (i.e. need to be summated) within the formulae of this section.
24 1 Appendix A 326 Technical With reference to lines 326 and 327 of the ICNIRP RF Guidelines, Appendix A, the local SAR OAHET for exposure durations >6 minutes (or reaching steady-state in 30 minutes) is stated to be 20 W/kg (averaged over 10g). If put in terms of SA (averaged over 10g), this threshold can be expressed as SA10g = 20 td, where td is the exposure duration in seconds and 20 is the slope (in W/kg) of the curve of SA10g versus td. 

With reference to the local SA OAHET for exposure durations < 6 minutes (line 450), it is given as the formula: SA10g =500+354*( t
d -1)0.5 for 360s > td >1s. The slope of this SA10g function varies smoothly with td.  At td =359 s, it is calculated to be 9.3 W/kg (the slope has the functional form: 177*(td -1)-0.5). At  td =361 s and beyond, the slope is 20 W/kg.

At the transition exposure duration of t
d = 360s, there is an artificial discontinuity of the slope of the OAHET SA10g versus td curve. Numerical calculations of the heating factors of multi-layer, planar tissue models under far-field exposure conditions at 1 and 3 GHz suggests that this discontinuity should be less abrupt. The worst-case calculations suggest that the asymptotic slope of the OAHET SA10g curve for td >360s could be reduced to 12 W/kg or even lower. This would provide a smoother transition, in terms of slope, between the OAHET SA10g curves above and below the transition td. This adjustment of the SA10g slope for td >360s would consequently imply a revision of the OAHET SAR10g (below 6 GHz and td > 360s) downwards by the same amount.
Investigate possible revisions to OAHET local SAR10g using planar tissue models under far-field exposure.
Attachment showing details and results of numerical calculations is available upon request.
We believe that SA better matches the biological effect of interest and so have retained this. The discontinuity has been removed with an amendment to the formulae.
24 2 Main 596,605,709,727 Technical For local exposures above 6 GHz, consideration should be given to specifying circular areas as opposed to square ones for spatial averaging of incident power density. The reasons include:
1) In practice, power density exposure patterns are circular or elliptical when projected on the measurement plane. 
2) A circular pattern usually has a bell-shaped intensity distribution that can be characterized by determining the distance between half-power points from a single scan. The intensity distribution in an elliptical pattern is also bell-shaped in each principal axis. Its shape can be characterized by measuring the distance between the two half-power points on each principal axis.
3) The intensity distribution can be modeled as Gaussian and with knowledge of the distance between half-power points along both principal axes, the spatially averaged intensity can be readily estimated.
4) The entire spatial averaging procedure would consist of two linear scans, one along each principle axis, followed by a calculation. It is assumed that the spatial resolution of the probe is greater than the averaging area.
5) Most portable, hand-held, isotropic power density probes have circular symmetry and, in some cases, have projected sensing areas close in size to the 4 cm2 or 1 cm2 recommended spatial averaging area. As a result, the probe inherently provides spatially averaged readings. A circular spatial averaging area would, therefore, be compatible with the use of these probes when calibrated appropriately.
6) A circular averaging area avoids the low power density values that would occur in the corners of a square and is therefore, a more conservative approach.

consider specifying circular spatial averaging areas as opposed to square
 Attachment showing details is available upon request.
We do not believe that there is sufficient requirement to change this to a circle (although it is clearly another good option).
25 1 Main All Editorial The font used for these documents makes it challenging to distinguish between number 1 and letter capital I.
Choose a clearer font
The final font will be dictated by the journal that publishes the guidelines, but we will endeavour to overcome this issue.
25 2 Main 146, 147, 156,420, 421, 423, 602, 605, 859  Editorial The use of the letter H both to represent Htr – transmitted energy density and elsewhere H on its own to represent the magnetic field is unnecessarily confusing.  Editorially, subscripts conventionally are used as qualifiers to the main letter script and not to completely change the represented variable.
Whilst https://en.wikipedia.org/wiki/Radiant_exposure does suggest the use of He for the parameter „radiant exposure“, the use in these guidelines is to represent the term „transmitted energy density“.   Since use of „E“ for energy would clash with electric field, it would be better to use a different character. E.g. J
tr 
Further, with respect to Table 1, radiant exposure is NOT a unit and the term is not used elsewhere in the guidelines.

Replace H
tr with Jtr throughout guidelines and appendices and never use term „radiant exposure“.
In Line 156 - Table 1, replace „radiant exposure“ with „joule per meter“ 
This has now been changed to 'U' (and 'transmitted' changed to 'absorbed').
25 3 Main 437 Technical The guidelines include science/engineering based concepts and also precaution. In explaining the rationale for two thresholds unambiguously, additional clarification of the ICNIRP understanding should be provided to distinguish between:-
Case A:  There is no known adverse health effect for any human irrespective of health, age, gender, racial background or pregnancy from EMF exposures at up to the occupational limit which is subject to a reduction factor below known adverse effect exposure level as a precaution to accommodate scientific uncertainty and potential outliers for susceptible people. A further precautionary reduction factor has been applied to establish the G public limits to assist the practical management of EMF exposure.

Case B: For healthy people there is no known adverse health effect for any human irrespective of gender, racial background from EMF exposures at up to the occupational limit which is subject to reduction factor below known adverse effect exposure level to accommodate scientific uncertainty.
There have been studies [reference] suggesting that some people [age, pregnant, ill] may have adverse health effects at levels [close to occupational limit]/[between occupational limit and G public limit] and so for G public exposure, a further reduction factor is applied to establish the G public limits.

 ICNIRP should clarify their position and include text for Case A or Case B as ICNIRP consider appropriate.

Clearly distinguishing what ICNIRP conclude science has demonstrated and what ICNIRP has included on the basis of precaution helps policy makers and compliance-standards developers in their implementation of the guidelines and also promotes public understanding.  
This has now been clarified in Section 2 of the main document, as suggested.
25 4 Main 597 Technical The exposure scenario for BASIC RESTRICTIONS does not include plane wave power density – only Str.
Part 5 of Note a is therefore not applicable to Table 2.

Delete part 5 of Note a.
Else include clarification why it is relevant.

Inclusion of non-applicable notes may cause confusion to the reader.
The tables have been completely rewritten, and this issue resolved.
25 5 Main 646 Editorial The term diameter is incorrect here for sources below 30 MHz and is a poor descriptor at other frequencies .  E.g. a half-wave dipole for 3.5 MHz will have a LENGTH of something like 38m but be constructed of a wire of DIAMETER 4mm.  Further, the field source may not actually be an antenna.

Amend the text to read: „....refer to the maximum dimension (e.g. length) of the radiating source and wavelength respectively.“
This has been amended as suggested.
25 6 Main 682 Technical There should be no discontinuities such as step changes in reference limits at boundaries between frequency ranges. The factors in Table 4 should be adjusted slightly to remove/minimise these steps by including additional significant figures where needed.

Occupational E-field:
0.1 to 20 MHz    1228/f
>20 to 30 MHz    61.4
>30 to 400 MHz    61.4
>400 to 2000 MHz     3.07 f0.5
>2 to 300 GHz 137

Occupational H-field:
0.1 to 20 MHz    4.9/f
>20 to 30 MHz    4.9/f
>30 to 400 MHz    0.163
>400 to 2000 MHz     0.00815 f0.5
>2 to 300 GHz   0.163

G public E-field:
0.1 to 20 MHz    550/f
>20 to 30 MHz    27.5
>30 to 400 MHz    27.5
>400 to 2000 MHz     1.375 f0.5
>2 to 300 GHz  61.4

G public H-field:
0.1 to 20 MHz    2.19/f
>20 to 30 MHz    2.19/f
>30 to 400 MHz    0.0728
>400 to 2000 MHz     0.00364 f0.5
>2 to 300 GHz 0.163

Discontinuities in limits at specific frequencies are difficult to accommodate in practical „shaped“ field probes and so constitute an additional compliance uncertainty in measurements. 
More precise definitions are no more difficult to implement in computations than less precise definitions.
Step functions have been removed in most cases.
25 7 Main 682 Technical The Table 4 reference levels for >2 GHz exclude electric and magnetic field strengths, in effect requiring an evaluation of the Poynting vector or at least the measurement of BOTH E and H. This implies that it would no longer be valid to use an electric field isotropic probe above 2 GHz – even if it has a readout in W m-2.   This has serious practical implications for measuring whether a specific exposure circumstance is within the guidelines.

E and H values for 2 to 300 GHz should be included (to 3 significant figures) corresponding to Sinc = 50 W m-2.
Occupational E-Field 137 V m-1, H-Field = 0.364 A m-1
G Public E-Field 61.4 V m-1, H-Field = 0.163 A m-1
To ensure that currently available best practice electric field probes may continue to be used above 2 GHz fully consistent with compliance assessment with these guidelines rather than imply the need to develop and use new instrumentation that doesn‘t currently exist – e.g E H combined probes or using thermal-based techniques.
Measurement issues are outside the scope of the guidelines. We decided not to present the E and H values as it didn't importantly contribute to the purpose of the guidelines (although we see that it could have had benefits in terms of pursuasion).
25 8 Main 430, 682 Technical Splitting up the exposure limit guidance between 2010 and 2018 on the basis of health effect AND frequency range is very confusing.  For the development of compliance procedures and regulations it is important to have the traceability as to what effect is being covered but ultimately it is more important the guidelines clearly express the limiting EMF parameter nalues at any stated frequency rather than the limiting effect. 
Specifically, By not including nerve stimulation in the 2018 guidance, there is a challenge to establish what should actually be complied with in the overlap frequency range between ICNIRP2010 and ICNIRP2018 guidance. Where there is a scope overlap between 2010 and 2018 guidelines (ie 100 kHz to 10 MHz) then the 2018 guidance should give the critical limit for all (proven...) effects.
See proposed tables in subsequent sheet: Cochrane
It can be seen from the above that if the ICNIRP2010 guidelines are still valid, then the ICNIRP2018 guidelines do NOT provide the reference level against the limiting effect for at least some of the frequency range below 10 MHz. The discrepancy being a factor which can be over 60x.

Discontinuities at frequency boundaries should be avoided – see comment 6

Amend ICNIRP Table 4 to address this and include addiional note(s) as required to reference ICNIRP2010 for justification:
Table 4 Occupational E Field new frequency range 0.1 MHz to 7.18 MHz with a limit 170 Vm-1 with a new note pointing to ICNIRP 2010 Table 3.  A further frequency range 7.18 MHz to 20 MHz would retain the 1228/f.
 
Table 4 GP E Field new frequency range 0.1 MHz to 6.63 MHz with a limit 83 Vm-1 with a new note pointing to ICNIRP 2010 Table 4.  A further range 6.63 MHz to 20 MHz would retain the 550/f.

ICNIRP 2018 should be consistent in establishing the limiting effect at any given frequency and applying the corresponding exposure limit irrespective of whether the effect is covered in detail in ICNIRP2010 or ICNIRP2018 guidance. 
The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
25 9 Main 683, 701 Technical The REFERENCE LEVELS include plane wave power density considering near- and far- field cases so the part 5 note from line 597 may apply to Tables 4 and 5.

Consider if part 5 of Note a in line 597 is technically applicable to Table 4 and Table 5 and if so include it there.
The tables have been completely rewritten, and this issue resolved.
25 10 Main 709, 728 + All Editorial The applicable frequency range from 66-30 GHz may be a typo but is unclear.  The x-y unit presentation may not always be clear.

Consistantly express frequency ranges throughout the guidelines using form xmin Unit to xmx Unit to ensure clarity rather than the x-y unit form.  E.g.:
Line 709            6 GHz to 30 GHz.
Line 728            6-30 GHz, >30 – 300 GHz    should rather be expressed         6 GHz to 30 GHz,  >30 GHz to 300 GHz.
......many other places
Ensuring clarity
This has been amended as suggested.
25 11 Main 720 Technical When defining formulas, it is good practice to ensure that all terms are uniquely and consistently identified.
Having the time interval expressed in line 719 in units of minutes and then in line 730 stating that t is measured in seconds is really confusing.

Decide whether to express time intervals in seconds OR minutes and be consistent.
Where t is a rolling averaging period in seconds
This has been amended as suggested.
25 12 Main 792 Editorial The term „EMF region“ is undefined and is potentially confusing.

Redraft the end of the sentance to be „...within the frequency range 100 kHz to 110 MHz.“ 
This has been amended as suggested.
25 13 Main 720 Editorial The formula in Table 6 for Occupational Incldent plane wave energy density for frequency range >6 GHz to 300 GHz seems to be missing an opening „[„.

In the formulae for the limits >6 GHz, the „-„ sign is not very clear.

The formulae in this table should be simplified such that constants are multiplied out so that there is no extraneous multiplication of constants required to determine the guideline limit.  The square root sign  would also make the formulae more readable.





  

Explain the context of your comment.
These formulas have been revised to account for these and other issues.
25 14 Main All tables with notes Editorial The note numbering and referencing is challenging to follow. There is the „a“ type for reference which seems to be to all notes, then there is the „1, 2,3 ...“ notation as sub-notes and also „*“ and „#“ notation.
Sometimes the note „1“  indication is used – but then not all of the notes under the table are expliciely referenced within the table.
 
Apply the following editorial formatting rules:
a) „Notes to Table ....“ – under the Table
b) For notes applicable to complete columns, include
“see note 1..” as part of the column header
c) For notes applicable to complete rows, include “
see note 1..” as part of the row header
d) For notes applicable to specific cells, include
“see note 1..” as part of the cell information
e) If there are notes remaining which are not then referenced,  delete them since they are not relevant to that table.
This has been amended as suggested.
25 15 Main 429-431 and Table 4 (681-695) Technical Comparison between the Occupational H-field Reference Levels in this proposal and those of the 2010 Guidance shows a discontinuity at 100 kHz that is difficult to understand.

2010 Guidance: (3 kHz – 10 MHz): 80 Am-1
2018 Proposal: (100 kHz): 4.9/f(MHz) = 49 Am
-1

Lines 429-431 can be interpreted as saying that, where the two sets of guidance overlap, the more restrictive applies. This then suggests that, from a practical perspective, we can use a reference level of 80 Am
-1 at 99.99 kHz but only 49 Am-1 at 100.001 kHz.

Such an abrupt change for a biological system is difficult to understand without additional information
 
Either:
i  Add an explanation to the rationale to explain how to interpret the discontinuity
or
ii. Ensure there is no discontinuity at the frequency boundary between the two documents
e.g. Since the guidance in the 2010 guidance (“1 Hz to 100 kHz”) extends beyond 100 kHz, perhaps the values in Table 4 of this proposal (“100 kHz – 300 GHz”), could extend to frequencies below 100 kHz?
The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
26 1 Main 192 General ICNIRP should synthesize both guidelines (2010 et 2018) and provide a single reference level and a single limit for workers as well as a single limit and reference for the public. The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
26 2 Main 681/697 Technical  ICNIR should provide better consistency between the two tables 4 et 5.  The tables have been completely rewritten, and this issue resolved.
26 3 Main 610 to 738 Editorial Simplify the tables: repeat values if necessary
The tables have been completely rewritten, and this issue resolved.
26 4 App A 601 General  ICNIRP does not provide arguments / studies to explain how reference levels for local exposure for frequencies <6 GHz are established.     provide the basis for reference levels for local exposure <6 GHz

These are now provided in Apendix A.
27 1 Main 6 General The Guidelines are for Heating and Short-term effects only. This should be clearly stated in the title so that they are not confused with existing international Guidelines for Biological and Long-term and Short-term effects.
„GUIDELINES BASED ON HEATING AND SHORT-TERM EFFECTS FOR LIMITING EXPOSURE TO TIME-VARYING ELECTRIC...“
It should be clearly stated in the title that these Guidelines are for Heating and Short-term effects, so that they are not confused with existing international Guidelines for Biological and Long-term and Short-term effects (e.g. Bioinitiative 2012, EUROPAEM 2016).
The guidelines considers and protects against all effects (regardless of whether they are thermally mediated), except those specified as outside scope. 
27 2 Main 14 General  It should be clearly stated that these guidelines are not „for the protection of humans“ but only „for the protection from heating and short-term effects in some humans“ so that they are not confused with existing international Guidelines for Biological and Long-term and Short-term effects. The ICNIRP also needs to state at the start of the guidelines that it has already declared that people whom it recognises are not protected by these guidelines should choose guidelines which are protective and protect against tthe many established biological and long-term health effects and not just heating and short-term effects.
„The guidelines described here are for the protection from heating and short-term effects in some humans exposed to radiofrequency electromagnetic fields (EMFs) in the range 100 kHz to 300 GHz (hereafter ‚radiofrequency‘). The ICNIRP recognises that these guidelines are not protective of biological and long-term advserse health effects, especially cancers, cardiovascular and neurological harm, including Electromagnetic Hypersensitivity, and fertility damage, all of which have been known since the 1930s onwards in the published scientific literature. The ICNIRP has already stated in 2002 that some members of the G population are vulnerable to exposure levels below these guidelines and recognises that such people need to choose international biological and long-term guidelines such as Bioinitiative 2012 or EUROPAEM 2016.“
1. It is essential that it is explained that these guidelines are based on Schwan’s invalidated hypothesis of 1953, rejected by the majority of scientists and almost half the regulators and governments around the world, that the only adverse health effects of radio frequency EMFs are the result of raising the body temperature by one degree in six minutes. Since it is possible to raise the body temperature by one degree within six minutes (or 30 minutes, averaged) through exercise or sitting in strong sunlight, but without the established health harm from pulsed RF EMFs such as cancer promotion or co-promotion, cardiovascular and neurological harm, including Electromagnetic Hypersensitivity, and fertility damage, all of which have been known since the 1930s onwards in the published scientific literature, it should be clearly stated that these guidelines are not „for the protection of humans“ but only „for the protection from heating and short-term effects in some humans“.
2. These guidelines are inconsistent with the ICNIRP’s stated G approach published in 2002 that there are members of the G population for whom these heating and short-term guidelines are not protective and that these members of the G population need non-thermal and long-term guidelines, such as Bioinitiative 2012 and EUROPAEM 2016.
3.The chair of the ICNIRP in 2016 stated that everyone has the right to choose whether to follow the ICNIRP heating and short-term guidelines, or the international biological and long- and short-term guidelines such as Bioinitiative 2012 and EUROPAEM 2016. This free choice should be made clear in the introduction to these heating and short-term guidelines.
The guidelines protect against all adverse health effects identified by science, and so it would not be appropriate for the guidelines to state otherwise. There is no evidence that there are populations whose health is particularly sensitive to RF-EMF.
27 3 Main 18 General These guidelines are not based on „the best science currently available“.
 „These guidelines are based on a selection of the science currently available which does not claim to be comprehensive, and it is recognized ...“
The ICNIRP guidelines, as explained above point 1, are based on a fundamental mistake made by Schwan in 1953 that the only adverse health effect from RF EMFs is heating the body by one degree in six minutes. Since the vast majority of international scientists have long rejected this viewpoint and many governments, regulators and courts have adopted non-thermal approaches, and since the ICNIRP has recognised since 2002 that some members of the G population are adversely affected at levels of exposure under ICNIRP’s thermal guidelines, it is blatantly wrong and totally unscientific to claim that they are based on the „best“ science available.
Many leading scientists have shown that in fact these ICNIRP guidelines are not based on the „best“ science, but are based on an interpretation of selected studies suiting the heating hypothesis, thus denying the convincing and consistent outcome of the majority studies now available. The majority studies confirm what has been established since the 1930s, that RF can have biological and long-term adverse health effects.
On average some 80% of studies agree in showing adverse effects at non-thermal levels for outcomes like infertility, neurological and cardiovascular effects. These guidelines do not recognise this fact and are misleading in adopting the minority viewpoint.
These adverse effects from non-thermal levels of exposures have also been well established over several decades from studies on geomagnetic effects, usually at much lower levels of exposure than man-made radiation. This should be clearly acknowledged in the main guidelines as well as in the supporting documentation.
These guidelines would not pass a balanced peer-review panel. By stating that they are based on the „best“ science available, when they are clearly not, no competent peer-review panel could allow an unsubstantiated claim like this.
No evidence is provided in support of these statements, and accordingly no changes have been made.
27 4 Main 24 General The ICNIRP has already stated in 2002 that their heating and short-term guidelines do not provide protection „for all people“.
„for some people“
 The ICNIRP‘s statement in 2002 that their heating and short-term guidelines do not provide protection „for all people“ is inconsistent with the claim in line 24. 
The guidelines protect against all people. This is stated in the documents.
27 5 Main 24 General It is invalid to state „against known adverse health effects“ since at present, under similar guidelines, there are already many thousands of people suffering „known adverse health effects“ which have been established by the convincing and consistent weight of evidence in the scientific literature.
„against some known adverse health effects“
To claim what is patently untrue according to the scientific literature over many decades is misleading and unscientific.
No evidence is provided in support of these statements, and accordingly no changes have been made.
27 6 Main 43 General These guidelines are not „for safe personal exposure“. If such guidelines were safe, then there would not be thousands of people harmed by current EMF levels.
„for personal exposure which prevent acute adverse effects from a temperature rise in the body“
As explained above, it is scientifically invalid to claim that EMF exposure which causes established harm is safe.
No evidence is provided in support of these statements, and accordingly no changes have been made.
27 7 Main 432 General As shown above, it is invalid based on the scientific evidence to claim „do not cause any known health effect“ since thousands of people are adversely effected by the levels permitted under the ICNIRP guidelines.
„do not cause some known health effects“
To be scientifically valid the claim made here should be scientifically accurate and be limited to „some“ not „any“ known health effect.
We believe that what is stated in the documents is accurate in this regard, and so no changes have been made.
27 8 Appendix B 95-102 General These three sentences in lines 95-102 are scientifically and factually inaccurate. They are based on a confusion between Electrophobia or the nocebo effect, established in the scientific literature in the 1980s, and the physiological reactions to EMF exposures established from the 1930s onwards. There have been numerous studies confirming both separate conditions. To equate them is invalid scientifically and undermines the scientific basis of these guidelines.
„A small portion of the population experiences a negative pyschological reaction to the presence of observed wireless devices. This is known as Electrophobia or Idiopathic Environmental Intolerance psychologically attributed to EMF  (IEI-psychological-EMF)  and was first described in the literature in the 1980s. Some double-blind experimental studies have failed to identify a relation between radiofrequency EMF exposure and non-specific symptoms in this  Electrophobia  or  IEI-psychological-EMF  population, as well as in healthy population samples. Some interpretations of these human experimental studies assumed that ‚belief about exposure‘ (e.g. the so-called ‚nocebo‘ effect) , and not the exposure itself, is the relevant symptom determinant for  Electrophobia or  IEI-psychological-EMF.  Another small portion of the population experiences specific physiological symptoms, conscious and/or subconscious, in the presence of various types of RF EMF exposure. This has been described in the scientific literature since the 1930s and is known as Electrical Sensitivity or Intolerance, or Electromagnetic Hypersensitivity (EHS). This condition is now established and diagnosed by a growing number of physicans and in specialist centres worldwide by means of multi-system objective tests, including blood-flow perfusion, changes to endocrine, hormone and protein expression, ROS and VGCC effects, and fMRI scans, along with temporal correlation of exposure and specific symptoms, and the evidence of absence of specific symptoms in the absence of exposure. About 1% of people with EHS also suffer from  Electrophobia or  IEI-psychological-EMF.“
1.
The psychological condition of  Electrophobia or IEI-not-EMF, or the nocebo effect, has been shown in the scientific literature to be different from the physiological condition of EHS with specific conscious symptoms and many subconscious physiological changes in the body. The ICNIRP guidelines should not be making such an elementary mistake.
2.
The specific symptoms caused by Electrical Intolerance or Sensitivity are the same as for EHS according to the literature from the 1930s onwards. This has been shown in numerous studies, including some on base stations and exposure to mobile phones, Wifi etc.
3.
These specific symptoms caused by electrical intolerance or sensitivity and EHS are the same as for those from geomagetic events,  according to the literature from the 1960s onwards.
4.
These specific symptoms caused by electrical intolerance or sensitivity and EHS are the same as for those from electromagnetic warfare and military usage (eg Golomb B 2018).
5.
These specific symptoms caused by electrical intolerance or sensitivity and EHS can be the result of variant DNA which has been shown by DNA sequencing (eg De Luca C et al 2011, De Luca C et al 2014). It is increasingly shown for conditions which involve variations in myelin.
6.
These subconscious and conscious specific symptoms caused by electrical intolerance or sensitivity and EHS can be measured objectively with a number of biological markers (eg Buchner K et al 2011, Belpomme D et al 2015, Belyaev I et al 2016).
7.
Use of fMRI can show objective abnormal brain patterns in people with EHS (Heuser G et al 2017).
8.
The conditions of real physiological ES and EHS has been given international  ICD recognition since 2000. It has been recognised in a growing number of courts of law, employment and pension tribunals and occupational health advisors, and it is specifically included under some government disability regulations. The specific symptoms of real physiological ES and EHS are listed under health warnings on a number of RF wireless devices and are becoming common knowledge among much of society.
8.
The separate condition of  Electrophobia or  IEI-psychological-EMF, or the nocebo effect, requires prior congitive conditioning. This is not the case for real physiological EHS which can affect unaware adults, children and animals, none of whom have experienced prior cognitive condtioning (eg  Lamech F 2014, Dieudonne M 2016).
9.
Because, as the WHO has stated, EHS is individual to the person concerned like all environmental biological reactions, all tests must be conducted and recorded individually. The process of averaging test results and the failure to screen subjects beforehand for whether they actually have EHS obviously mean that the results will fail to find the small portion of the G population who have EHS. Where individual EMF exposures are correlated with specific EHS symptoms for the relevant signals to which an individual is sensitive, then it is possible to confirm the existence of EHS by this type of test (eg Rea W et al 1991, Havas M 2006, Havas M et al 2010, Buchner K et al 2011, McCarty D et al 2011, Tuengler A et al 2013, Belpomme D et al 2015, Bogers R et al 2018, Irigaray P et al 2018,  etc)
10.
My list of March 2018 provides over 2,000 studies and references relevant to both Electromagnetic Sensitivity and Electromagnetic Hypersensitivity available at:  http://www.es-uk.info/wp-content/uploads/2018/05/Selected%20ES%20and%20EHS%20studies.pdf
These include references to numerous studies from the 1930s-1970s which established convincingly and consistently a wide range of physiological and adverse health outcomes from exposure to RF EMFs.
CONCLUSION:
The claims in the draft ICNIRP guidelines in lines 95-102 are not based on scientific facts and need to be rewritten. The ICNIRP guidelines should take into account the established science which has shown convincingly and consistently by weight of evidence that some people do experience specific physiological adverse heatlh from exposure to RF EMF. The guidelines should not confuse this real physiological condition with a psychological condition which has been shown convingly and consistently to have different aetiological processes.
The material provided does not demonstrate any weaknesses in the conclusions reached in Apendix B, or the restrictions more generally. No changes have been made.
27 9 Appendix B 408-476 General The draft guidelines do not seem to acknowledge the established concerns in the scientific literature about their failure to protect human health. The reference section should include these studies and the text should explain the ICNIRP response to these studies, which are both consistent and convincing in being based on the viewpoint of the large majority of international scientists.
• Bailey WH ET AL.: “Accounting for human variability and sensitivity in setting standards for electromagnetic fields” Health Phys. (2007) PMID: 17495668.
• Bandara P et al.: “Letter to the Editor [Wifi exposure in Australian schools]” Rad Prot Dosimetry (2017) doi.org/10.1093/rpd/ncx108. Article.
• Bandara P et al.: “Cardiovascular disease: Time to identify emerging environmental risk factors” Eur J Prev Cardiol. (2017) PMID: 28969497. Article.
• Bortkiewicz A et al.: [Biological effects and health risks of electromagnetic fields at levels classified by ICNIRP as admissible among occupationally exposed workers: a study of the Nofer Institute of Occupational Medicine, Lodz] Med Pr. (2003) PMID: 14669585.
• Fernández C et al.: “Absorption of wireless radiation in the child versus adult brain and eye from cell phone conversation or virtual reality” Environ Res. (2018) PMID: 29884550.
• Frey AH: “Is a toxicology model appropriate as a guide for biological research with electromagnetic fields?” J Bioelect. (1990) Article.
• Frey AH: “Biological function as influenced by low power modulated RF energy” IEEE Trans Microwave Theory and Techniques. (1971) Article.
• Grigoriev Y: “Methodology of Standards Development for EMF RF in Russia and by International Commissions: Distinctions in Approaches” in Markov M (ed.) (2017) Dosimetry in Bioelectromagnetics (2017) ISBN: 978-1498774130. Article.
• Grigoriev YuG: “From Electromagnetic Smog to Electromagnetic Chaos. To Evaluating the Hazards of Mobile Communication for Health of the Population” Med Radiol Radiat Safety. (2018) Abstract.
• Hardell L et al.: “Biological effects from electromagnetic field exposure and public exposure standards” Biomed Pharmacother. (2008) PMID: 18242044.
• Hardell L: “World Health Organization, radiofrequency radiation and health – a hard nut to crack (Review)” Int J Oncology. (2017) PMID: 28656257. PMC5504984.
• Hasan GM et al.: “Effect of electromagnetic radiations on neurodegenerative diseases- technological revolution as a curse in disguise” CNS Neurol Disord Drug Targets. (2014) PMID: 25345513.
• Hensinger P et al.: “Wireless communication technologies: New study findings confirm risks of nonionizing radiation” umwelt-medizin-gesellschaft. (2016) Article.
• Iakimenko IL et al.: [Metabolic changes in cells under electromagnetic radiation of mobile communication systems] Ukr Biokhim Zh (1999). (2011) PMID: 21851043.
• Johansson O: “Disturbance of the immune system by electromagnetic fields - A potentially underlying cause for cellular damage and tissue repair reduction which could lead to disease and impairment” Pathophysiology.  (2009) PMID: 19398310.
• Koh WJ et al.: “Non-ionizing EMF hazard in the 21th century” IEEE Xplore. (2018) Abstract.
• Lan JQ et al.: “On the effects of glasses on the SAR in human head resulting from wireless eyewear devices at phone call state” Prog Biophys Mol Biol. (2018) PMID: 29428220.
• Leszczynski D ET AL.: “Mobile phone radiation health risk controversy: the reliability and sufficiency of science behind the safety standards” Health Res Policy Syst. (2010) PMID: 20205835. Article.
• Lin JC: “Clear Evidence of Cell Phone RF Radiation Cancer Risk” IEEE Microwave Mag. (2018) Abstract.
• Marino AA et al.: “Trigeminal neurons detect cellphone radiation: Thermal or nonthermal is not the question” Electromagn Biol Med. (2017) PMID: 27419655.
• Markov M et al.: “Protect children from EMF” Electromagn Biol Med. (2015) PMID: 26444201.
• Markovà E et al.: “Microwaves from GSM mobile telephones affect 53BP1 and gamma-H2AX foci in human lymphocytes from hypersensitive and healthy persons” Environ Health Perspect. (2005) PMID: 16140623. PMC1280397.
• Pall ML: “Scientific evidence contradicts findings and assumptions of Canadian Safety Panel 6: microwaves act through voltage-gated calcium channel activation to induce biological impacts at non-thermal levels, supporting a paradigm shift for microwave/lower frequency electromagnetic field action” Rev Environ Health. (2015) PMID: 25879308.
• Panagopoulos DJ et al.: “Evaluation of specific absorption rate as a dosimetric quantity for electromagnetic fields bioeffects” PLoS One.(2013) PMID: 23750202.
• Paul B et al.: “Mobile phones: time to rethink and limit usage” Indian J Public Health. (2015) PMID: 25758729. Article.
• Redmayne M: “International policy and advisory response regarding children's exposure to radio frequency electromagnetic fields (RF-EMF)” Electromagn Biol Med. (2015) PMID: 26091083.
• Rubtsova N et al.: “Intensity-time dependence dosing criterion in the EMF exposure guidelines in Russia” Electromagn Biol Med. (2018) PMID: 29493302.
• Sage C et al.: “Comments on SCENIHR: Opinion on potential health effects of exposure to electromagnetic fields, Bioelectromagnetics 36:480-484 (2015)” Bioelectromagnetics. (2015) PMID: 26688202. RG.
• Sagioglou NE et al: “Apoptotic cell death during Drosophila oogenesis is differentially increased by electromagnetic radiation depending on modulation, intensity and duration of exposure” Electromagn Biol Med. (2016) PMID: 25333897.
• Sarkar S et al.: “Effect of low power microwave on the mouse genome: a direct DNA analysis” Mutat Res. (1994) PMID: 7506381.
• Starkey SJ: “Inaccurate official assessment of radiofrequency safety by the Advisory Group on Non-ionising Radiation” Rev Environ Health. (2016) PMID: 27902455. Article.
• Steneck NH et al.: “The origins of U.S. safety standards for microwave radiation” Science. (1980) PMID: 6990492.
• Syaza SKF et al.: “Non-ionizing radiation as threat in daily life” J. Fundam. Appl. Sci. (2017) Article.
• Webster PC: “Federal Wi-Fi safety report is deeply flawed, say experts” CMAJ.(2014) PMID: 24756628. Article.
• Yakymenko I et al.: “Long-term exposure to microwave radiation provokes cancer growth: evidences from radars and mobile communication systems” Exp Oncol. (2011) PMID: 21716201.
It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
27 10 Appendix B 408-476 General  The draft guidelines do not seem to acknowledge the specific concerns in the scientific literature about their failure to protect the health of the wildlife and all living systems on earth. The reference section should include these studies and the text should explain the ICNIRP response to these studies.

• Engels S et al.: “Anthropogenic electromagnetic noise disrupts magnetic compass orientation orientation in a migratory bird” Nature. (2014) PMID: 24805233.
• Manta AK et al.: “Mobile-phone radiation-induced perturbation of gene-expression profiling, redox equilibrium and sporadic-apoptosis control in the ovary of Drosophila melanogaster” Fly (Austin). (2017) PMID: 27960592. PMC5406167.
• Margaritis LH et al: “Drosophila oogenesis as a bio-marker responding to EMF sources” Electromagn Biol Med. (2014) PMID: 23915130.

Explain the context of your comment.

It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
28 1 Main 16-17 General It is unclear whether the ICNIRP 2018 publication will fully replace the ICNIRP 1998 publication or not. In the ICNIRP 2018 publication, for example, there are insufficient references to justify the choice of 4 W/kg as the lowest exposure level leading to adverse health effects on animals. The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
28 2 Main 23-41 Technical The ICNIRP guidelines exclude electromagnetic compatibility issues and refer explicitly to compliance with standard 60601-1-2. There have been changes to the limits in the 100 kHz – 10 MHz band, and measuring methods have considerably evolved. The ICNIRP 2010 recommendations are more nuanced on this point even if they cited the same references.
Moreover, by approaching implants from the point of view of electromagnetic compatibility, the thermal effects on passive implants appear to be hidden. What other effects are there besides those generated by electrical equipment? Are they excluded? Or are they included in the notion of an object or medical act?

We do not agree that these are hidden; they are merely out of scope and described as such within the Scope section.
28 3 Main 43-53 Technical ICNIRP should give a more detailed definition and evidence-based justification for the following categories (preferably in a table): (i) biological effects, (ii) health effects, (ii) adverse health effects, (iv) substantiated adverse health effects. These definitions are necessary to apprehend the summary conclusions at the end of Appendix B sections, which are currently very assertive.

We do not believe that this would provide the greatest benefit to the reader and so have not adopted this suggestions. These terms are all explained in the revised guidelines.
28 4 Main 49-53 Technical The weight of evidence for the methodology used to determine harmful effects to human health is not sufficiently described and needs to be made more transparent. How many times must an effect be replicated to be considered as sufficient? How many studies are required? How is “sufficient scientific quality“ assessed by ICNIRP? Which indicators are needed? The scientific basis of “scientifically substantiated” should be made more explicit.
Insert your proposed change.
Rigorous methods to assess the weight of evidence for issues related to electromagnetic fields have been developed over time (e.g. by ANSES and Health Canada…). A detailed description in the core guidelines document and appendices of the weight of evidence approach taken by ICNIRP is needed and should be more thorough and transparent.
We have tried to make the methodology as clear as possible within the constraints of a guidelines document. The level of detail requested is outside the scope of this.
28 5 Main 49-50 General The part of the sentence which says “explicable more Gly within the context of the scientific literature“ should be clarified. This has been amended as suggested.
28 6 Main 54-59 Technical The concept and definition of “operational threshold” is new in the ICNIRP rationale. A more detailed explanation of this concept is needed. This has now been clarified further.
28 7 Main 60 Technical  What exactly does “more-G” knowledge mean?

This has been changed to 'additional'
28 8 Main 95 Technical The key issue which requires attention in the guidelines is whether the foetus is a more sensitive population within the G public or not.
Insert your proposed change.
The foetus, children, pregnant women and ill people are often considered to be part of a sensitive population. Furthermore, in its Opinion (ANSES, 2016), ANSES notes that children are more exposed to radiofrequencies than adults, for self-explanatory anatomical reasons. These observations had already led the Health Council of the Netherlands, in 2011, and Health Canada, in 2015, to reconsider the reference levels to protect the health and safety of the G population, and more particularly of children.  
The rationale for the treatment of a pregnant woman has been described in Apendix A.
28 9 Main 100 Technical Regretfully the “presumed exposure scenarios” are not described in the document.

Further details about the exposure scenarios are provided in Apendix A.
28 10 Main 122 Technical If ICNIRP considers temperature elevation, nerve stimulation, dielectric breakdown of biological membranes or electroporation as health effects, brain parameter disorders such as EEG parameter changes during sleep should also be discussed.

The guidelines consider adverse health effects, rather than biological effects (unless shown to result in adverse health effects). This is described in the text.
28 11 Main 134 Technical Could ICNIRP justify the 6 GHz cut-off, because it does not match a biological cut-off. Furthermore, the IEEE sets the limit at 3 GHz, considering that it offers better health protection (based on Hirata et al., 2013).

This is clarified in Apendix A.
28 12 Main 146, 156 Table 1. Technical The symbol for transmitted energy, Htr, is similar to the symbol for magnetic field strength, H. This may be misleading for the reader.
We suggest changing the symbol for transmitted energy, e.g. Tr.

This has now been changed to 'U' (and 'transmitted' changed to 'absorbed').
28 13 Main 169 Technical Nerve stimulation, membrane permeabilization and temperature elevation are here described as the “three primary biological effects“, and this rise in temperature is used to derive exposure limits. This appears to be in contrast with appendix B (line 48), where the distinction between biological and adverse health effects is explained, and it is said that “only adverse health effects require limits for the protection of humans”.   Note that the cited text refers to biological effects, whereas in Apendix B it relates to adverse health effects (i.e. there is no inconsistency).
28 14 Main 179-183 General There are several references on thermal physiology in the literature. The document should therefore include more references on thermal physiology and a more detailed description of the thermally-based operational adverse health effects/threshold.

Further clarification of the thermal physiology has been provided, but only in so far as it helps the reader understand the logic of the guidelines.
28 15 Main 226-228 General In which cases does ICNIRP consider lower temperatures on which to base limits?

The cases where lower temperatures are used are described in the text.
28 16 Main 255 Technical The term “mild hyperthermia” should be more precisely explained.

This term has now been removed.
28 17 Main 260 Editorial Reference to ACGIH 2017 should be changed to ACGIH 2018a,b
This has been amended as suggested.
28 18 Main 272 General The “recent theoretical models” should be referenced.

The detail has been provided in Apendix A, and the text refers the reader to Apendix A for such detail, so no change is needed here.
28 19 Main 276 General An ambient temperature of 28°C cannot actually be considered as “moderate”, considering that the thermoneutral environment for the human body is about 21°C. Or should it be so? In which case it should be fully justified?

It is now specified that it is under thermoneutral conditions, which it is for the naked human used in the model.
28 20 Main 334 Technical The ICNIRP 1998 Guidelines stipulate that “The hypothalamus is considered to be the control center for normal thermoregulatory processes, and its activity can be modified by a small local temperature increase under conditions in which rectal temperature remains constant” and they refer to a study by Adair et al. (1984) where “altered thermoregulatory behaviour starts when the temperature in the hypothalamic region rises by as little as 0.2 – 0.3°C”. In the ICNIRP 2018 Guidelines, the operational adverse health effect threshold for brain tissues is 2oC, assigned as a Type 2 tissue. Therefore, the 2°C temperature elevation in the brain is 10 times higher than found by Adair’s study.
ICNIRP should add references about the effects of an increase in brain temperature up to 2oC and explain the inconsistency between the 2018 and 1998 ICNIRP Guidelines concerning this particular issue.
We do not see any contradiction between these two statements. Most importantly, harm associated with RF exposure has been described in App. B, and is what the restrictions are based on.
28 21 Main 364-366 Technical These sentences are confusing: “Further, ICNIRP assumes realistic exposures (such as from radio-communications sources). This method provides for higher exposures in the limbs than in the head and torso.” This should be clarified.

This has been amended as suggested.
28 22 Main 366 General On which study is the choice of 20 W/kg for the head and torso, or 40 W/kg for the limbs based? This is clarified in Apendix A.
28 23 Main 370 Technical ICNIRP should be more explicit as to why the 6-minute average closely matches the thermal time constant for local exposure.

This is clarified in Apendix A.
28 24 Main 406-414 Technical More explanation and references should be added to understand the origin and basis of the equations.

This is now described in greater detail in Apendix A, including the relevant citation.
28 25 Main 410 Technical The rationale of the SA formula should be made explicit and described.

This is clarified in Apendix A.
28 26 Main 414 General The clarity of this paragraph should be improved. This has been amended as suggested.
28 27 Main 429 General “To be compliant with the present guidelines, exposure cannot exceed any of the restrictions described below, nor those for the 100 kHz – 10 MHz range of the ICNIRP (2010)”
Insertyourproposedchange.
2010 ICNIRP’s guidelines are established in order to limit exposure to low-frequency electromagnetic fields (1 to 100 kHz) and some guidance is extended to 10 MHz. However, the most restrictive values at e.g. 1 MHz can be extracted from ICNIRP’s 2010 guidelines but are not in ICNIRP’s 2018 guidelines.

The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
28 28 Main 450, 467 General The document needs to include a cross-check of the reduction factors (with specific attention given to consistency) with the other reduction factors, e.g. local exposure). It looks as if ICNIRP does not intend to change the basic restrictions issued in 1998.
The reduction factors are clearly described in the main document.
28 29 Main 461 Technical What are the scientific references to justify the choice of a 30-minute average?

This is clarified in Apendix A.
28 30 Main 487 General Health effects associated with the local and centrally-mediated thermoregulatory process should be named.

These are now provided in the revision.
28 31 Main 682 Technical For a frequency of 100 kHz, reference levels could refer to ICNIRP 2010 or ICNIRP 2018 guidelines. However, values do not match, whether for electrical or magnetic fields (e.g. at 100 kHz 12,200 V/m (2018) vs. 170 V/m (2010) for workers).
Even ICNIRP’s 2010 guidelines do not apply to frequencies above 100 kHz; reference levels are given in the table. Between 0.1 MHz and 10 MHz, the limit values are not harmonized with ICNIRP 2010 LF Guidelines (e.g. at 10 MHz 122 V/m (2018) vs. 170 V/m (2010). This could be confusing.
The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
28 32 Main 601, 718 Table 3, Table 6 Technical The definition of <6 min is not sufficient. For example, for a repeated pulsed radiation (e.g. 1 ms pulse) which lasts more than 6 min, how should we interpret the SA? In some working conditions, workers can be exposed to highly varying short-term exposure levels; how can the exposure be defined?
This has now been defined more clearly.
28 33 Main 709 Editorial Typing error: 6 GHz instead of 66 GHz
This has been amended as suggested.
28 34 Main 825,828,836,837,840,849,856,864 Technical How is frequency "i" defined within a given frequency range? 
Insert your proposed change.
If one considers RF power measurement, a resolution bandwidth is defined in order to have consistent and repeatable measurements. Discrete summations can give a value >1 even for communication channels that are “off” (noise) if a high number is considered!
Further clarification is outside the scope of the guidelines, and will need to be considered in technical (product safety) standards.
28 35 Appendix A none General ICNIRP states that studies should be independently replicated in order to be taken as evidence, but most studies showing a temperature rise in the organs are authored by A. Hirata, member of the Icnirp RF guidelines project group.

This is the case for some types of knowledge only. We have now explained this distinction in more detail in the text.
28 36 Appendix A 190 Technical “There is no data on body core temperature elevation for whole body exposure to radiofrequency EMF above 6 GHz.“ Having said that, the guidelines may therefore be highly uncertain about core temperature elevation above 6 GHz. The data from IR exposure is not able to replace data from microwave exposure.
This is noted in the text.
28 37 Appendix A 210 General Reference to be checked: Hirata et al. (2008b) seems to examine whole body SAR in the nine-month-old infant model, not a three-year-old child model.

This has been checked and we are happy with the text as written.
28 38 Appendix A 230 Technical It is questionable to extend the data on the temperature rise in a foetus up to 6 GHz from the data between 40-500 MHz. Local SAR/temperature hot spots in the foetus could be generated due to RF exposure above 500 MHz and up to 6 GHz.

Further detail about the fetus is now provided in Apendix A.
28 39 Appendix A 334 Editorial Takei et al, : already published This has been revised as suggested.
28 40 Appendix A 456 Editorial Reference to be checked (see doi:  10.1186/s12938-017-0432-x) Reference list has been updated. 
28 41 Appendix B all General In all chapters, the references should be extended.

It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
28 42 Appendix B 23 General Note that the WHO report is a draft document.
This is noted in the text.
28 43 Appendix B 48 General The difference between biological and adverse health effects is not clear. Temperature elevation is a biological effect, but it is considered as the critical effect used to derive limit values.  The distinction has been clarified in the text.
28 44 Appendix B 78 General ICNIRP should provide a reference to justify “SAR>4 W/kg for non-human primates, exposures which correspond to an increase in body core temperatures of approximatively 1°C”

It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
28 45 Appendix B 92-115 General ICNIRP should provide references. It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. We have added further explanation of key issues in Apendix B that were highlighted in the public consultation process.
28 46 Appendix B 161-176 General Cataracts and other effects on the eye may be included in section 3, “Auditory, vestibular and ocular function“

We acknowledge that this research could also be included within Section 3, but we believe it is more useful here.
28 47 Appendix B 189 Technical “The most recent report has provided ……. (Roschmann, 1991)”. This reference is old and only one publication is referred to here. This section needs more references.

It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. However, reference to 'recent' has been removed.
28 48 Appendix B 200 General What is the meaning of “changes to normal sensory processing“?

This refers to absolutely any changes, and in this case includes self report, auditory basic restrictionain stem, early and midlatency event related potentials and more. We do not believe it is useful to give a complete list here.
28 49 Appendix B 216 General The rationale and scientific basis of “robust changes“ should be clarified.

This has now been changed to 'substantiated', which is described in the main document.
28 50 Appendix B 220 General ICNIRP should provide references for “daily exposure to mobile phone signals does not impact plasma levels of melatonin or melatonin metabolism“ As per the other endpoints, this summary of the literature does not describe every study from which its conclusions have been derived (as might be expected from a systematic review). The individual studies have thus not been cited, and the interested reader should consult the review documents that the Appendix has cited. 
28 51 Appendix B 226 General The references of these epidemiological studies should be given. Does this mean that people’s melatonin levels can vary just by them thinking that they are exposed? This has been amended as suggested. The relevance of the question is not clear and has not been addressed.
28 52 Appendix B 211 & 232 General Is there a sound reason why the chapters on the neuroendocrine system and neurodegenerative diseases are not included in the chapter “brain physiology and function“? The chapter structure is based on that of the public consultation version of the WHO Environmental Health Criteria.
28 53 Appendix B 275 Editorial The phrase “these are serious adverse health effects that need to be avoided” talking about death and thermal breakdown is awkward. This has been amended as suggested.
28 54 Appendix B 346 General The NTP reports are currently draft documents. The final documents are now referenced instead of the draft reports.
28 55 Appendix B 378-386 General An effect could be observed for higher cumulative call time groups even if there were no trends observed for any of the lower cumulative call time groups. This result may be interpreted carefully.  This is noted.
28 56 Appendix B 406 General "In Summary, no effects of radiofrequency EMF on Cancer have been substantiated" may sound like a contradiction with IARC’s conclusion in its monographs (Non Ionizing Radiations, Part 2: Radiofrequency electromagnetic Fields) “Radiofrequency Electromagnetic Fields are "possibly Carcinogenic to Humans (group 2B)"” We do not think a change is needed here, and none has been suggested by the respondent.
29 1 Main 22-41 General The purpose of the guidelines is stated as being „high level of protection for all people against known adverse health effects from direct, non-medical exposures to both short- and long-term, continuous and discontinuous radiofrequency EMFs“. Later in the purpose and scope section (starting on line 38), it is stated that „Radiofrequency EMF may also interfere with electrical equipment, which can affect health indirectly by causing equipment to malfunction. This is referred to as electromagnetic compatibility, and is outside the scope of these guidelines (for further information, see ISO14117 and IEC 60601-1-2).“
These statements are contradictory and partially incorrect:
1. People with active implantable medical devices are in fact no different from persons without such an implant, in that the “equipment” they bear is for all intents and purposes a permanent part of their physiology, one which they cannot simply turn off or ignore. The interference from EMF that can occur with these implants may lead to adverse health effects, some of which can be life threatening.
2. Citing the two standards above (ISO 14117 and IEC 60601-1-2) as examples of “equipment” that is out of scope of the
guidelines represents a misunderstanding of these two very different standards. IEC 60601-1-2 addresses electromagnetic compatibility (EMC) of medical electrical equipment and systems, and is correctly cited in the context above, in the sense that it does not apply to active implantable medical devices (AIMDs) themselves. It does however apply to the nonimplantable parts of AIMD systems, such as a body-worn insulin pump controller.
In contrast, ISO 14117 is concerned with EMC of implanted pacemakers and defibri llators (ICD), which as pointed out are not “equipment”, but rather a vital part of a living human being that is needed to improve their quality of life. Similar standards apply to neurostimulators, cochlear implants, implanted infusion pumps and circulatory assist devices. These active implantable medical device standards establish EMC requirements to allow for proper and intended device operation, and take into account current EMF exposure guidelines as well as state-of-the-art device designs. The EMF exposure levels proposed greatly exceed the EMC requirements established for active implantables medical devices, and thus increase the likelihood of interactions that may occur, creating an increased safety risk for people with active implantable medical devices.
The guidelines must consider the effects of EMF on persons bearing active implantable medical devices with the same level of concern as for any other person.
Today, there are over 6 million patients worldwide (a conservative estimate) bearing a pacemaker or ICD, and similar numbers of patients with neurostimulators. This represents a large and growing segment of the population who should be considered in the establishment of guidelines for EMF exposure in both the G public and occupational exposure environments. These same concerns have been conveyed to the US Federal Communications Commission as part of its ongoing rulemaking efforts to establis hsimilar exposure limits at low frequencies (i.e. below 300 kHz). For reference, please see the documents submitted by AAMI (Association for the Advancement of Medical Instrumentation) as part of an ex parte filing at the following links: https://www.fcc.gov/ecfs/filing/60000983676
https://ecfsapi.fcc.gov/file/60000987169.pdf
There are a number of areas that are outside of the scope of the guidelines, and these are detailed in the text. The confusion in that section regarding standards has now been remedied.
30 1 Main  138 and remainder of document  Editorial The term „Power Flux Density“ rather than „Power Density“ better reflects the concept of power passing through a unit area
Replace the term „power density“ by „power flux density“ (in all instances in the document) 
We have kept the term because it is more commonly used within this field.
30 2 Main 152 Editorial  No definition is given for ‘equivalent power density’. Note also comment 1

 To the end of line 154, add a definition of equivalent power density: eg. “Here, equivalent power density is that obtained from E-field or H-field levels, assuming far field consitions. See also Appendix A,  section 2.3”
This has now been defined.
30 3 Main  429-431  Technical Using both 2010 guidance and proposed new guidance in the frequency range 100 kHz – 10 MHz.
It would be very helpful for additional guidance to be given as to how to use both the documents together. Simply taking the lower reference limit leads to additional questions, see comments 4 and 5.
Add additional text giving guidance on using the 2010 guidance with this new proposed guidance in the overlap frequency range.

The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
30 4 Main  681-682, 697-699, 718-720  Technical Table headings are difficult to distinguish; amend to emphasise distinctions.

Table 4: Reference levels for exposure to time-varying far-field electric, magnetic and electromagnetic fields, from 100 kHz to 300 GHz (unperturbed rms values):
Whole Body Exposure

Table 5. Reference levels for exposure to time varying far-field electric, magnetic and  electromagnetic fields, from 100 kHz to 300 GHz (unperturbed rms values):
Local Exposure for time intervals ≥ 6 minutes.

Table 6.
Reference levels for exposure to time varying far-field electric, magnetic and  electromagnetic fields, from 100 kHz to 300 GHz (unperturbed rms values):
Local Exposure for time intervals ≤ 6 minutes.
This has been amended for clarity.
30 5 Main 681-695 Technical Overlap region with 2010 Low frequency guidance:
The proposed E-field reference levels are significantly higher at the lower frequencies in the range than those for the same frequencies in the 2010 guidance. Eg at 100 kHz, proposed occupational E-field reference level is 12.2 kV/m compared with 170 V/m in the 2010 guidance.

Add text to the rationale to explain when this higher reference level can be used. For example, could the higher 2018 reference levels be used if certain controls are in place?
The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
30 6 Main 681-695 Technical  Overlap region with 2010 Low frequency guidance:
There is a discontinuity at 100 kHz between the 2010 guidance (Occupational: 80 A/m) and this proposed guidance (Occupational 49 A/m.

 Add text to the rationale to explain how to interpret the discontinuity in H-field reference levels at 100 kHz.

The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
30 7 Main 687-688, 690-692  Technical Table 4, Note 3 and Note # appear contradictory for frequencies below 400 MHz (a subset of frequencies up to 2 GHz).
Does Note 3 apply only in the far field ?

Note 3: For frequencies  from 400 MHz to 2 GHz,  compliance is demonstrated if either the E-field, H-field or Sinc value is within the reference levels; only one is required; similarly for frequencies up to 400 MHz when in the far field.
The tables have been completely rewritten, and this issue resolved.
30 8 Main 769-770 Technical This explanation is not usable; specifically the phrase, „100 Vm-1 at their source“
Any definition needs to clarify the following:
• What is the location at which 100 V/m is determined?
• Is it rms or peak?
• What happens when an antenna emits more than one frequency?
It does not make sense to talk about the field strength at the „source“ and the field strength will vary with location

Specify this in terms of the power input (W); ensure it is clear how to deal with a source / antenna operating at more than one frequency.
This has been rewritten to improve clarity.
31 1 Main All General We welcome this proposal and are pleased to have the opportunity to comment on it. Colleagues have told me that they find it easier to understand than the 1998 guidance and the detailed rationale is useful. In addition, the efforts to ensure stability in the guidance is appreciated. No response required.
31 2 Main 129 Editorial Comment : “dialectric“ is incorrect spelling.
Proposed change  : Change spelling to  “dielectric“

This has been amended as suggested.
31 3 Main  429-431  General Comment : Using the proposed guidance in conjunction with the 2010 guidance in the range 100 kHz – 10 MHz is not as simple as might be thought at first. (See also comments 4 and 5)
 Proposed change : Add text to give more detailed guidance for using both publications (2010 and 2018) in the overlap frequency range where the two apply.
The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
31 4 Main 681-695 Technical Comparison between the H-field reference level at 100 kHz and that in the 2010 LF guidance shows a drop from 80 Am-1 (2010, occupational) to 49 Am-1 (2018, occupational) at the 100 kHz boundary. Since biological systems Gly do not show such sharp discontinuities, this is difficult to interpret.
e.g. If we simply take the lower reference level where both the 2010 and 2018 guidance are applicable, then at 99.99 kHz, the H-field reference level is 80 Am-1 but at 100 kHz it is only 49Am-1.

Add text to provide additional guidance on how to interpret the discontinuity at 100 kHz.
The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete). At present, the discontinuity will have to remain given that the newer science supports the new refernce levels.
31 5 Main  681-695  Technical Comment : Comparison between the E-field  reference level at 100 kHz and that in the 2010 LF guidance shows a significant increase from 170  Am-1 (2010, occupational) to 12200  Vm-1 (2018, occupational). However, without additional guidance, use of this significantly higher reference level is difficult. (Noting that it is assumed that reference levels are given to allow assessments without the need for detailed computational modelling against the biological restrictions)
For example, are there measures that could be put in place (such as prevention of arcing etc) that could allow use of this higher reference level without needing to assess against 2010 biological restrictions?
Proposed change : Add text to provide additional guidance on when it is possible to make use of this higher E-field reference level.
The new guidelines now provide all restrictions above 100 kHz (with the LF 2010 guidelines above 100 kHz now obselete).
31 6 Main 687-692, Table 4 Note 3 and #  Technical Comment : The range of frequencies up to 400 MHz is contained within the range of frequencies up to 2 GHz. Therefore, Note 3 seems to be inconsistent with #, unless Note 3 relates to far field conditions only.
Clarification is needed to make it clear when compliance with only either the E- or the H-field reference level is required and when both are required.

Proposed change : If it is the case that Note 3 is intended for far field conditions only, then the suggested text for Note 3 is:
“For frequencies up to 2 GHz, in the far field, compliance is demonstrated if either the E-field, H-field or Sinc value is within the reference levels; only one is required.”

If the above suggestion is incorrect, then the proposed change is to modify Note 3 and/or # to ensure they are mutually consistent.

The tables have been completely rewritten, and this issue resolved.
31 7 Main 693-695, Table 4, Note * Technical Comment : This note (*) to Table 4 is inconsistent with the text in Appendix A (lines 529-537). Frequencies above 400 MHz are contained within the range 30 MHz to 6 GHz.
Note * in the main document states that no reference level is provided for reactive fields above 400 MHz. However, Appendix A states, “From 30  MHz to 6 GHz, ………….. In the reactive near-field, ICNIRP therefore requires evaluation of both the E-field and H-field and confirmation that both fields do not exceed the reference levels“

Proposed change : Add clarification so that users of the guidance are able to comply fully with the requirements
The tables have been completely rewritten, and this issue resolved. The rules concerning reactive near-field have been clarified. However, some compliance issues remain outside the scope of the guidelines. 
31 8 Main 769-770 Technical Comment : The given definition of “high-power radiofrequency fields“ cannot be used. Specifying a field strength “at its source“ is not valid.
Moreover, field strength varies with position; therefore a change to the definition that included specifying distances in terms of wavelength would be problematic for multi-frequency sources; specifying distances in terms of antenna aperture would be problematic for Low/Medium frequencies where it can be argued that the ground forms part of the antenna.

Proposed Change: “For the purpose of specification, ICNIRP here defines high-power radiofrequency fields as those with an total mean input power greater than [xxx] W.”
(Where [xxx] is an appropriate power in watts)
This has been amended as suggested.
32 1 Main 118-119 Technical The field inside the body depends on many more parameters.
„on the EMF source properties (size of the transmitter elements, distance from the source, frequency, field intensity, modulation, and polarization), on the body size and shape and inclination of the surface, as well as on the physical properties and spatial distribution of the tissues within the body.“
It is better to include as many parameters determining the field distribution as possible.
This comment has been repeated and is not addressed again.
32 2 Main 129 Editorial dialectric
dielectric
Typo
This comment has been repeated and is not addressed again.
32 3 Main 156 Editorial In the third column of Table 1, line 10, the entry is „radiant exposure“, instead of the units.
Change to „joule per square meter“
Consistency
This comment has been repeated and is not addressed again.
32 4 Main 231 Technical „health effects are primarily related to absolute temperature“: This is true for whole body exposure. In the case of local exposure, tissue damage is dependent on temperature and time at that temperature. This is why the CEM43oC concept was introduced and is mentioned in line 319, further below. The concept is also needed to determine the peak-to-average and appropriate averaging time
„related to absolute temperature and the time at this temperature“.
Consistency.
This comment has been repeated and is not addressed again.
32 5 Main 272-275 Editorial „human adults“: It is important to mention whether these were resting human adults.
„resting human adults“
Consistency
This comment has been repeated and is not addressed again.
32 6 Main 319-320 Editorial „Yarmolenko et al. 2011“ is missing from the reference list.
Insert reference in the reference list.
Consistency
This comment has been repeated and is not addressed again.
32 7 Main 479 Editorial „a SAR of“
„an SAR of“
Typo
This comment has been repeated and is not addressed again.
32 8 Main 482-487 Technical „A reduction factor of 2“
Justify better the selection of reduction factors and explain how uncertainty was taken into account for deriving them.
The need for the reduction factor is clear and discussed at several points in the document. However, the value of 2 is not documented in detail. Was it derived quantitatively by following a rigorous uncertainty analysis procedure, or is it an educated guess? Moreover, it is different than the reduction factor of whole body exposure. The fact that „the associated health effect is less serious medically“ for local exposure should not play a role in the derivation of the reduction factors. The procedure for deriving these numbers should be self-consistent and uniform throughout the guidelines. Any deviations should be adequately (and in a scientific way) justified
This comment has been repeated and is not addressed again.
32 9 Main 675-677 Technical „a smaller temperature rise“
Give a value (or percentage) and the respective reference.
This is a sensitive issue, because it relates to children, and a significant one because it has an impact on the decision of not changing the reference levels. The statement here reads like a hypothesis/assertion. It would better to give a value for the expected temperature rise with respect to adults, or a reference to support the statement. 
This comment has been repeated and is not addressed again.
32 10 Main 709 Editorial „(66-30 GHz)“
„(6-30 GHz)“
Typo
This comment has been repeated and is not addressed again.
32 11 Appendix A 171-172 Technical „As described above, power absorption is confined within the surface tissues at frequencies above 6 GHz. This may lead to thermoregulatory response initiation time being reduced.“
Remove the sentence.
What is the biological rationale for this? Is there a reference to support it? At the surface of the body (skin) there are numerous heat receptors sending signals to the hypothalamus.
This comment has been repeated and is not addressed again.
32 12 Appendix A 341 Editorial „°C kg W-1“
„°C kg W-1“
Typo
This comment has been repeated and is not addressed again.
32 13 Appendix A 672 Technical „internationally standardized child models“
Remove the whole sentence.
These are scaled voxel models of Janapese children. (a) They are not globally valid; (b) they are not models of real children but scaled down from adult Japanese models; and (c) they should not be considered „standardized“: Who and when did standardize them? Is there an international standard document describing them? By which standardization organization?
This comment has been repeated and is not addressed again.
32 15 Appendix B 27-29 Technical „In order to provide an indication of ICNIRP’s evaluation process, overviews of the literature and conclusions that ICNIRP reached, as well as a limited number of examples, are provided.“
Elaborate further.
Are the inclusion/exclusion criteria for the studies of the peer-reviewed literature that have been considered during the risk assessment process itemized somewhere? Will ICNIRP issue a detailed report on the evaluation of the studies and the list of those that have been considered in the risk assessment process?
This comment has been repeated and is not addressed again.
32 16 Main 16 General „This publication replaces the radiofrequency part of the 1998 guidelines (ICNIRP 1998);“
Elaborate further.
An abstract with the changes that have been made to the previous guidelines would be most useful.

This comment has been repeated and is not addressed again.
32 17 Main 523 Technical “4 cm2” up to 30 GHz with a step function at 30 GHz to 1 cm2
 Decrease the averaging area.

It can be calculated that a beam with a Gaussian profile of 1 mm width, normally incident on the skin can induce a surface temperature rise of 3.9 C instead of the 1 C produced by a plane wave with the same incident power density averaged over 4cm^2. The temperature rise can become even higher, if a lower perfusion rate is assumed, since the 102 ml/min/kg perfusion rate assumed in the document is rather high: the energy is absorbed superficially on the skin in non-perfused layers, therefore a three fold lower effective perfusion rate would be more reasonable. Then, in the above example the localized temperature rise would be about 4.1 C (5% higher). 
We have changed the transition at 30 GHz, such that 4 cm^2 is applied from 6 to 300 GHz, with an additional criteria for frequencies above 30 GHz. Specific restrictions are not provided for extremely small beams (as in the laser guidelines), because there is currently no evidence that they will affect health in a way that cannot be accounted for with the 1 cm^2 restrictions.
32 18 Main 553 Technical „less than 1 second“
Introduce a limit to the maximum energy density per pulse.
Introducing a constant energy density below 1s allows for ultrashort pulses to deliver high amounts of energy and increase the temperature considerably. It is recommended to introduce a limit to the maximum energy density per pulse.
This comment has been repeated and is not addressed again.
32 19 Main 596 Technical „square“
Change the shape of the surface for the averaging of the incident power density for frequencies above 6GHz from a square to a circle of the same area. On non-planar evaluation surfaces, the shape of the averaging area would then be determined by intersecting it with a sphere with its center at the evaluation point and a radius that maintains the averaging area.
Defining the averaging area as a square leads to problems with reproducibility, because the square is not rotationally symmetric. A square requires the definition of the orientation of its edges around its surface normal. This definition is arbitrary and will lead to ambiguities when assessing compliance in practical situations. Furthermore, a square does not conform to a non-planar surface. The definition that we propose is free of these problems.
Despite the problem of definition, a spherical intersection will also massively reduce the effort required for compliance testing.
This comment has been repeated and is not addressed again.
32 20 Appendix A 79 Technical „power and energy densities“
„power density“
Equation 2.9 is the averaged power density, not energy density.
This comment has been repeated and is not addressed again.
32 21 Appendix A 94 Technical „absolute strength of the Poynting vector“
„modulus of the complex Poynting vector“
Consistency
This comment has been repeated and is not addressed again.
32 22 Appendix A 412 Technical The Sasaki study is an important paper. Latest studies taking into considerations detailed skin properties, showed that simplifications result in insufficient conclusions. The most important one is that the layered model considered did not take into account the epidermis structure, i.e., did not differentiate between stratum corneum and viable epidermis. This is important, as it increases power transmission at higher frequencies (stratum corneum acts as a matching layer).  The thermal parameters used in the Sasaki study Gly yield a lower temperature increase than the ones in published databases. These different parameters (and using fat instead of muscle as terminating layer) explain the remaining differences to Sasaki even without the stratum corneum and with mixed thermal boundaries instead of the adiabatic ones.
Consider newer results about the heating factor, taking into account more detailed models.
 It can be shown that at frequencies above 15GHz, the stratum corneum (SC) acts as an impedance matching layer for the incident electromagnetic fields. Significantly increased transmission of the energy can be observed for thick layers of SC (0.36–0.70mm), which occur in the palms. The worst-case heat conversion factor for normal incidence occurs at 60 GHz for a thick SC and is 0.04 K/(W/m^2).
References (available upon request):
Christ et al. 2018. RF-Induced Temperature Increase in a Stratified Model of the Skin for Plane-Wave Exposure at 6 to 100 GHz . Bioelectromagnetics. Submitted.
Samaras and Kuster. 2018. Power transmitted to the body as a function of angle of incidence and polarization at frequencies >6GHz and its relevance for standardization. Bioelectromagnetics. Submitted.  
This comment has been repeated and is not addressed again.
32 23 Appendix A 415 Technical This may not be so conservative after all, considering the limitations of the study by Sasaki et al (2017) and the ambiguity about the transmitted power density at oblique incidence, especially for TM polarization.
Consider newer results about the heating factor, taking into account more detailed models.
Conservativeness of reference levels. 
This comment has been repeated and is not addressed again.
32 24 Appendix A 733-736 Technical “Recent research has shown that the normal angle results in the maximum transmitted power density (greatest absorption) and is used for calculating the reference levels (Li et al., 2018).”
 Replace this incorrect statement by the conclusions from the Samaras et al. paper (see below).
 The angle that corresponds to maximum transmittance at TM mode cannot correspond to normal incidence.  This reference cannot be used to support the incorrect assumption that normal incidence is the worst case. The Li 2018 presentation is not published in a peer-reviewed journal, and the paper by Samaras et al comes to a different conclusion.  Samaras and Kuster. 2018. Power transmitted to the body as a function of angle of incidence and polarization at frequencies >6GHz and its relevance for standardization. 
This comment has been repeated and is not addressed again.
32 25 Main 122 Editorial „polarized molecules“
„polar molecules“
“polarized” means that something caused the substance to acquire polarity. Water is a polar molecule meaning that its polarity is inherent, not acquired.
This comment has been repeated and is not addressed again.
32 26 Main 71 Editorial „These quantities cannot be easily measured“
„These quantities may be difficult to evaluate“
Induced quantities, such as SAR, have become relatively easy to evaluate. This the reason for changing to “may be difficult”. Also, changed “measure” to “evaluate” as a more G term, as numerical methods are well used and standardized.
This comment has been repeated and is not addressed again.
32 27 Main 89 Editorial „which may include particularly vulnerable groups or individuals“
„which includes particularly vulnerable groups or individuals “
“G public” includes everyone, so “may include” is incorrect.
This comment has been repeated and is not addressed again.
32 28 Main 156 Technical „Htr
“U
tr
It is confusing to use H for energy density and magnetic field. Use a different symbol (e.g. U). It should be a scalar, not a vector (i.e. not bold)
This comment has been repeated and is not addressed again.
32 29 Main 429 General „To be compliant with the present guidelines, exposure cannot exceed any of the restrictions described below, nor those for the 100 kHz – 10 MHz range of the ICNIRP (2010) low frequency guidelines“
Please clarify what limits to apply where there are differences between ICNIRP 2018 and ICNIRP 2010. The limits should be consistent and in one single standard.  Also replace “cannot” with “must not”.
Reference levels in ICNIRP 2018 and 2010 are different in some cases. 
This comment has been repeated and is not addressed again.
32 30 Main 590 Technical  Headings of Tables 2 and 3, and Tables 5 and 6, are misleading.
 Delete ">= 6 minutes" and "< 6 minutes" from the headings.
The two sets of limits should both apply always. The SA and energy density restrictions are limiting when transmitting short pulses, and the SAR and power density restrictions are limiting when transmitting continuous signals, but both sets of limits apply regardless of the type of signal. This should be made clear in the text also.
This comment has been repeated and is not addressed again.
32 31 Main 813 Technical „Simultaneous exposure to multiple frequency fields”
Add guidance if a person is exposed simultaneously to signals that fall under both > 6 minutes and < 6 minutes.
 There is no guidance if a person is exposed simultaneously to signals that fall under both > 6 minutes and < 6 minutes.
This comment has been repeated and is not addressed again.
32 32 Main 140 Technical „10-g cubical mass “
Add guidance on what to do if the body surface is not flat.
A cube does not conform to a non-flat surface, resulting in air in the volume or tissue that is not considered. IEC 62704-1 includes considerations on what to do about this problem.  Adapting the surface of the cube to the curved SAM shell is common practice in the compliance testing standards. However, problems still remain dealing with the lack of rotational symmetry of a cube. A better approach is to use a sphere whose center is at the point of interest and radius is set such that 10-grams is included. This would be a hemisphere for a point on a flat surface.
This comment has been repeated and is not addressed again.
32 33 Main 374 Technical „From 6 to 10 GHz there may still be significant absorption in the subcutaneous tissue. “
We agree with the above statement and propose extending the frequency range for SAR as a basic restriction to 10 GHz.
IEC draft 62209-1528 has already included procedures, sources and validation for frequencies from 6 – 10 GHz. The available literature demonstrates that SAR measurements are achievable within reasonable uncertainty bounds at these frequencies.
Reference
K. Pokovic et al, "Methods and Instrumentation for Reliable Experimental SAR Assessment at 6 – 10 GHz," BioEM Meeting, Hangzhou China, 2017.
This comment has been repeated and is not addressed again.
32 34 Main 481 Editorial „(5 C in Type-1 tissue and 2 C in Type-2 tissue)“
“(2 C in Type-2 tissue)”
This section talks about the Head and Torso only.
This comment has been repeated and is not addressed again.
32 35 Main 522 Editorial „200 W m-2 “
Keep on same line
This is broken across 2 lines.
This comment has been repeated and is not addressed again.
32 36 Main 715 Technical „no reference levels are provided for reactive near-field exposure conditions within this frequency range “
Add reference levels for near-field exposure, or extend SAR as a basic restriction above 6 GHz. An alternative is to recommend compliance testing based on transmitted power.
Exposure to reactive near fields is likely to be common for 5G devices and the basic restrictions may be difficult to measure. Currently there are no measurement systems available that measure the transmitted power density. This makes it very difficult to demonstrate compliance with EM exposure. It is also important to point out that the incident power density flux crossing the surface is not always conservative as a proxy for transmitted power
This comment has been repeated and is not addressed again.
32 37 Main 156 Editorial „Seq, Sinc, Htr, Str “
Use scalar rather than vector quantities.
The limits are defined as scalar values, so the symbols should also be scalars (without bold)
This comment has been repeated and is not addressed again.
32 38 Main 126 Technical Typically interact
randomly collide
correct terminology


ICNIRP views 'typically interact' as appropriate and so has not changed this.
32 39 Main 127 Technical Movement energy    
Kinetic energy
Correct terminology
This has been amended as suggested.
33 1 Main 64-68 General ICNIRP states that the reduction factors for its exposure limit values includes an allowance for the dosimetric uncertainty associated with deriving exposure values. However, it is not clear whether this dosimetric uncertainty allowance is also intended to cover the uncertainty of RF exposure assessments when evaluating compliance with ICNIRP’s limits.
ICNIRP should state explicitly whether the reduction factors in its basic restriction and reference level limits cater for the uncertainty of RF exposure assessments when evaluating compliance with its limits. If so, ICNIRP should state explictly (in units of dB) what maximum level has been allowed for in the upper bound of the RF exposure assessment uncertainty. If not, ICNIRP should advise on how RF exposure assessment uncertainty should be considered when evaluating compliance with its limits.
There is currently considerable variability between various standards bodies and RF safety assessment agencies on how to deal with RF exposure assessment uncertainties. Some take a very cautious approach and prescribe that the lower uncertainty bound of the RF exposure assesment should be used when making comparison to the limits. Most simply specify that the best estimate of the RF exposure should be used for making comparison with limits, with the IEC standards permitting up to 6dB of uncertainty in the upper bound of the assessment. These differences in interpretation can lead up to a 10x difference in the assessed permissable RF exposure between different standards and RF safety assessment agencies, thereby causing confusion and eroding confidence in the universality of the ICNIRP limits.
This has now been stated.
33 2 Main 396-738 General ICNIRP’s new approach of setting SA, Htr and Hinc limits for short (< 6 min) RF exposures is confusing, difficult to implement and not well justified for frequencies below 30 GHz.
Restrict the application of the SA, Htr and Hinc limits to frequencies above 30 GHz. At frequencies below 30 GHz, continue with the exisiting approach of defining SAR, E, H and S as 6 minute averages.
Even as an experienced RF safety practitioner, I had much difficulty in coming to a proper understanding of these limits and therefore consider that they would likely cause substantial ongoing confusion within the RF safety assessment community. As a G rule, safety procedures which are hard to understand and implement are often overlooked and ignored which is a poor outcome for everybody, except perhaps lawyers. As I understand it, ICNIRP’s proposed rationale for these limits is to avoid excessive peaks in temperature rises (dT), particulalry at the skin surface. As exposure frequency declines, the skin depth of RF absorption increases, thereby increasing the size of the thermal mass (and hence thermal inertia) of the RF exposed tissues. At frequencies below ~30 GHz the skin depth of RF penetration is sufficiently large to ensure a thermal mass that will effectively smooth out dT peaks to within acceptable levels for the shortest RF pulses that may realistically be expected to occur.
These formulas have been revised to account for these and other issues.
33 3 Main 83-96 General The ICNIRP rationales for setting occupational and G public limits do not make sense for RF devices which are intrinsically safe up to the occupational limits.
Specify that occupational exposure limits are applicable for all persons exposed to RF devices which are intrinsically safe up to the occupational limits.
There is a large class of RF devices which by their design cannot induce whole body or localised RF exposures above the occupational limits, regardless of how they are used. For such devices, ICNIRP’s stated rationale of limiting the G public to lower tier limits based on their presumed lack of awareness of their RF exposure from these devices is not plausible since holding such knowledge would have no influence anyway on their zero risk of being exposed above the occupational limits.
The guidelines are to provide safety, rather than compliance methods or advice. This is thus outside of the scope of the guidelines. 
34 1 App A Line number General This draft is an invaluable product of tremendous efforts of lots of scientists and researchers. However, there seems to be some problems in the rationale and the review results in the Appendix A: 1) It should be confirmed that the author’s  intentions of the published research results are reflected correctly, 2) It should be reconsidered that some results for the  worst cases are ignored in consideration of cost-benefit effect, even though it is desrcibed that as a conservative step, reference levels have been derived such that under worst-case exposure conditions(which are highly unlikely to occur in practice).    Some texts in the Appendix need to be modified properly. These comments have been considered, and amendments made where appropriate.
34 2 Main 697 Technical In Table 5, the reference levels for local exposure  are discontinuous at 400 MHz and 6 GHz.  Please check if this kind of tendency is what expected in the draft. Some (but not all) discontinuities have been removed.
34 3 Main 711 Editorial The description in Note 5 of Table 5 does not seem to be necessary. The tables have been completely rewritten, and this issue resolved.
34 4 Main 718 Technical In Table 6, the reference level  is discontinuous at 400 MHz. Yes, this aspect of the refernce level is intended to be discontinuous. This is justified in Apendix A.
34 5 Main 718 Technical The reference levels for occupational and general public above 6 GHz given in Table 6, are inconsistetant with  the reference levels (Sinc) in Table 5 at t=360 (that is, the values are not the same at t=360). This has been amended to make consistent.
34 6 App A 632-634 General 1) It is stated that Nagaoka et al., 2007 is the most recent study. However, since 2007,  there have been many researches on children and WBA SAR. Therefore, it should be modified.
2) Throughout the document the terms such as “significant”, “at most 15%”, and “at most 40%”are confusing and subjective.
 3)  A study using child models which have used the standard dimensions specified by ICRP showed that the increases of the whole body average SARs are 15% (Nagaoka et al., 2007)
Insert your proposed change.
This issue is now justified in greater detail in the text.
34 7 App A 627-632 Technical The relevant reference should be specified correctly. Contextually, it is described as if it seems to be related to Lee and Choi, 2012. Even if it is so, there are some points to be made clear in this sentence. 1) In  Lee and Choi, 2012, child models were not scaled down from an adult model. The 1- and 5-year-old models were non-liniearly deformed from a real 7-year-old model with the 50th percentile dimensions of 7-y-o Korean males (Lee et al., 2009). 2)  In  Lee and Choi, 2012, the average physique as well as the thin physique were considered. 3) The fundamental principle of ICNIRP is to adopt a conservative approach. However, the scope of the conservativeness is unclear. How many percentages of the public would be protected from exposures with this guidelines? Even standing 50th percentile 1- and 5-year-old child models exceeded the basic restrictions (WBA SAR)  at frequencies of their whole body resonances and at above 1 GHz. The text has been modified to be more general in terms of the degree to which the scaling was linear (as the text needs to account for multiple studies).
34 8 App A 609,611,618,619 Technical  Replace ′E-polarization plane wave  incidence′ with ′vertically polarized plane wave incidence′, and also replace ′H-polarized plane wave incidence′ with ′horizontally polarized plane wave incidence′. This has been amended as suggested.
34 9 App A 623-625 Technical After the publication of ICNIRP statement 2009, some relevant papers other than Bakker et al. (2010) also have been published. The sentence “After this ICNIRP statement, Bakker et al., (2010) reported similar (but slightly higher) enhancements (45%) of the child whole body average SAR.“ should be modified. It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. The additional references have thus not been added.
34 10 App A 683-686 Technical  The document states that a smaller heating factor of children and the uncertaintay of numerical analysis are the reasons not to revise the current reference levels. However, children under 2 years are vulnerable to thermoregulatory responses. Furthermore, numerical uncertainty should not be ignored and be added to the measured result for conservative estimation. Need to be taken into acount this point properly. We have rewritten this section to make it clearer that the temperature rise is the most crucial determinant of health, and that that is the main factor that determines our decision.
34 11 App A 771 Editorial 100 mA and 20 mA --> 100 mA and 45 mA This has been amended as suggested.
34 12 Main Line number General A lot of editorial errors in technical expressions/descriptions as well as in English.
Proof readings and proper corrections need to be necessary.
Appropriate proofing has now taken place to improve the documents.
34 13 App B 9. CANCER Technical Add the following sentences at the proper position in Section 9, and also add the relevant reference: ”Although the odds ratio (OR) of tumor incidence according to mobile phone use was 0.956, vestibular schwannomas may coincide with the more frequently used ear of mobile phones and tumor volume that showed strong correlation with amount of mobile phone use. Thus, there is a possibility that mobile phone use may affect tumor growth (Moon et al., 2014).” [add the followinf literature in the reference] Moon IS et al., Association between vestibular schwannomas and mobile phone use. Tumor Biol. 2014, 35(1): 581–587. We do not believe that this addition importantly improves the document and so have not added it.
34 14 App A 40-43 & 62-68 Technical The expressions for the definitions of point-SAR and mass-averaged SAR, given in Eq.‘s 2.2, 2.3, 2.7, and 2.8, are inconsistent. The wording has been changed to avoid this issue.
34 15 App A 67 Technical The volume of a certain averaging mass is defined as a shape of a cube. However, in the previous ICNIRP guidelines, it was a contiguous volume of the averaging mass. The rationale of the change in the shape needs to be described. This has been added to Apendix A.
34 16 App A 37, 38 Technical It would be more appropriate to replace dr with dv for volume integral.





This has been amended as suggested.
34 17 App A 40 Technical Energy stored in electic or magnetic field can also be include in the incremental energy in this sentence. For more clarification, it would be better to change the expression of ′incremantal energy′ as proposed. This has been amended as suggested.
34 18 App A 44,45,46 Technical More detail would be better. Further detail is beyond the scope of the present documents.
34 19 App A 54 Editorial  ”where C is heat capacity (J kg-1 °C-1) of the tissue,”  -->  ”where C is specific heat capacity (J kg-1 °C-1) of the tissue,”  This has been amended as suggested.
34 20 App A 55,56 Editorial  ”Eqn. 2.4 is not applied to actual cases because a large amount of heat energy rapidly diffuses during the exposure.” --> ”When a large amount of heat energy rapidly diffuses during the exposure Eqn. 2.4 is not applied to actual cases.” This has been reworded for clarity.
34 21 App A 68 Editorial  Need to improve the expression for more clarification.








The additional information that the change would provide was not considered sufficiently important to be added.
34 22 App A 70 Editorial  1000 kg m-1--> 1000 kg m-3 This has been amended as suggested.
34 23 App A 78,79 Technical  (Eqn.2.9) describes only power density, not energy density.   ”Therefore, the transmitted power and energy densities are defined at the body surface;”  -->  ”Therefore, the transmitted power densities(W/m2) are defined at the body surface;” This has been amended as suggested.
34 24 App A 87 Technical Some more explanation would be necessary for (Eqn. 2.10).     ”with the normal direction of the integral area 𝐴.” --> ”with the normal direction to the integral area A. E and H are rms phasors of electric or magnetic field strength vectors each including both incident and reflected wave.” This has been rewritten for clarity.
34 25 App A 88 Editorial It would be better to add a unit for the transmitted energy density.   ”′ the transmitted energy density‘ --> ′the transmitted energy density(J/m2)′   This has now been given earlier in the section (for absorbed energy density)
34 26 App A 90 Editorial More detailed explanation for the integration variable ′t′ seems to be necessary for (Eqn. 2.11).   Add the following sentence below the (Eqn. 2.11): ”Note that the parameter t in (Eqn. 2.11) is  not for denoting highly changing rf variation but for usually slowly varying EMF strength.” This is not necessarily the case for this Eqn, and so has not been added.
34 27 App A 94 Editorial dielectric - typo This has been amended as suggested.
35 1 Main 129 Editorial Typo. Dielectric This has been amended as suggested.
35 2 Main 252 General Degrees C
C
 C is just Celsius after Andres Celsius not degrees Centigrade; this is similar to just saying (value) Kelvin
This has been amended as suggested.
35 3 Main 326 Editorial Remove text – which typically has a lower thermo-normal temperature
 Line 330/331 states this temperature range.
Both instances of this have been removed as the temperatures of each are stated in the next sentences.
35 4 Main 591 Editorial SAR in column 4 and column 5
Label column header as SAR_10g
The tables have been completely rewritten, and this issue resolved.
35 5 Appendix A 56/57 Technical  Specify t (duration of exposure) and relate to section 3.1.2
 Need to clarify approximation to adiabatic conditions where heat diffusion is not significant

Reference to adiabatic conditions was not useful here and has been removed.
35 6 Appendix A 82/83 Editorial Need reference to section 3.3.2
This then explains why you use 2 cm x 2 cm < 30 GHz, and 1 cm x 1 cm >30 GHz
It should be noted that references have been provided to better understand key issues, but not to provide a comprehensive account of the literature. This has been stated in the text. Details are provided in Apendix A.
35 7 Appendix A 108 Editorial  Move – above 6 GHz
 However above 6 GHz, the reactive ...
 Reads better.
This has been amended to improve clarity.
35 8 Appendix A 298/299 & 318/319 Technical Need consistent definition of heating factor
Insert your proposed change.
There are two different definitions of heating factor albeit they are used in different context.
We have revised the defintion for the heating factor for SAR and power density.
36 1 Main 95-96 General  It is not clear whether medical procedures (lines 29-31) involving a pregnant woman and/or her fetus are excluded from the statement "Note that a fetus is here defined as a member of the G public, regardless of exposure scenario, and is subject to the G public restrictions." (Lines 95-96).
 Suggest excluding medical procedures involving pregnant women and/or their fetus from the statement  “..... a fetus is here defined as a member of the G public, regardless of expsoure scenario ....“
Pregnant women give informed consent prior undergoing MRI procedures. Such procedures may be indicated either to examine the mother or the fetus or both. Clearly the health status of the mother has implications for the health of the fetus. It is common practice that parents/guardians provide informed consent prior to neonates and minors (who can be described as individuals of differing health statuses, who may have no knowledge of or control over their exposure to EMF) undergoing MRI procedures.
If fetal exposure is subject to G public basic restrictions, then MRI procedures involving pregnant women would be limited to maternal head scanning. Numerical simulations of 3T MRI exposure of a pregnant woman body model carried out in our department (as yet unpublished) show that fetal whole body SAR would exceed 0.08 W/kg for scanning of other maternal anatomical sites. Such restriction would deprive the mother and her fetus of clinically important diagnostic information.
Defining the fetus as a member of the G public with respect to medical procedures is inconsistent with other ICNIRP documents.  For example, there is no mention of the fetus in ICNIRP GUIDELINES ON LIMITS OF EXPOSURE TO STATIC MAGNETIC FIELDS (2009). Since the G public basic restriction is 400 mT, defining the fetus in this way would exclude pregnant women from MRI procedures. The ICNIRP STATEMENT AMENDMENT TO THE ICNIRP STATEMENT ON MEDICAL MAGNETIC RESONANCE (MR) PROCEDURES: PROTECTION OF PATIENTS (2009) implies MRI exposure of the fetus, stating: "For the normal operating mode there should be an upper limit for whole-body exposure of 4 T, in view of uncertainties regarding the effects of higher fields, including effects on fetuses and infants".
This has now been clarified in the text.
36 2 Main 353-356 General  Classifying the fetus as a type 2 tissue when considering local temperature increase is more relaxed than other guidance and standards.
 Suggest considering fetus as a special case with temeprature increase limited in line with previous guidance and standards.
The fetus is normally 0.3-0.5 deg C above maternal core temperature and heat loss from the embryo and fetus across the placental barrier may be less efficient than heat dissipation in other well vascularised tissues. A local temperature increase of 2 deg C is likely to exceed the guidance given in ICNIRP STATEMENT ON MEDICAL MAGNETIC RESONANCE (MR) PROCEDURES: PROTECTION OF PATIENTS (2004) namely "It seems reasonable to assume that adverse developmental effects will be avoided with a margin of safety if the body temperature of pregnant women does not rise by more than 0.5°C and the temperature of the fetus is less than 38°C." The IEC-60601-2-33 (2015) standard also adopts this more cautious approach which is especially important during the first trimester of pregnancy.
The issue of the pregnant woman has now been elaborated on in Apendix A. Note that a 2 deg increase is not permitted for the fetus.
37 1 Main 84 to 88 Technical Only two groups of people are considered, we would prefer three groups: occupational as defined in the text, G public as defined and vulnerable people’s group.
Insert your proposed change.
 Insert vulnerable persons to account for schools (pupils and students), hospitals and health care places (illness bring fragility to any type of radiations), old people who have lower thermoregulation capacities, and rural places where people may be exposed but have no means to protect themselves. This would also put a constrain to physical location of some equipements near these places.

There has not been a demonstration that there is a vulnerable group in terms of RF at the levels relevant here, and so an additional group is not justified.
37 2 Main 95 General A pregnant woman is vulnerable and should be place in the third group The rationale for the treatment of a pregnant woman has been described in Apendix A.
37 3 Main 112 to 117 Technical The phrasing is not clear regarding power and energy definition
As the field propagates away from a source, it transfers power (in watt or power per unit of surface) from its source to a receiving object. When the said power is applied  during a time t the receiving object absorbs an equivalent energy (in joule which is power x time).
The phrasing of this definition is important for the remainder of the text. It is the application oft he power during time that brings heat and allows for changes and consequences in the body. 
This has been rewritten to improve clarity.
37 4 Main 119 - 120 Technical There is a need of clearly stating that EMF is composed of electric and magnetic field. Not only electric field E Note that the intention is not to provide a complete account of such issues, but to describe the most saliant features to the reader (particularly the reader who may not have a strong background in this area). As E is the most relevant to health in these guidelines, that is why it has been described here.
37 5 Main 125 Technical The effect of induced electric field on electrons and molecules may lead to oxidyzation. This phenomenon is known to cause certain health problems but not mentioned here. In particular, in appendix B, impacts on calcium ion dynamics have been mentioned.   Even if there is currently no evidence, it should be mentioned either here or in Appendix B. Another possible effect on blood is mentioned in the article of M. Havas (see comment 13 below). This needs tob e discussed as prolonged exposure has some damaging affects.

This comment has been repeated and is not addressed again.
37 6 Main 156 Technical Assumed tissue density and average body density are not mentioned in the table nor is the conductivity. (see also line 357-364).
Insert your proposed change.
Tissue mass is considered for dosimetric specification. But tissue/body part density varies depending on which part is considered. Bones are different from skin, cells etc. And the EMF propages through different media. 
This is clarified in Apendix A.
37 7 Main 284-285 Technical Eyes are sensitive as they mainly contain water. Even if EMF does not penetrate, it can induce eye dryness because of superficial dryness caused by heat. This should be revisited in the text.

This comment has been repeated and is not addressed again.
37 8 Main 371 Technical There is a need of reassessing this sentence. When a high frequency reaches the body, it is predominantly absorbed by superficial tissues. However, it can go deaper by being attenuated and with lower frequencies.  As such other effects could  be found such as nerve excitation for lower frequencies transmitted by attenuation effect. The studies mentioned do not go further but it should be clearly said that this is a possibility that has not been investigated.
This comment has been repeated and is not addressed again.
37 9 Main 458 to 466 Technical On the risk factor, please include vulnerable people.
Insert your proposed change.
By including vulnerable people, it will force emf equipment to be put away from these people/places.
The restrictions, and the reduction factors that they are derived with, provide safety for all people. This is stated in the guidelines.
37 10 Main 502 Technical Why 400 MHz instead of 100 Mhz as stated in the concerned range of frequency
Replace 400 by 100
This comment has been repeated and is not addressed again.
37 11 Main 532 – 532 and 552 Technical There is need of clarifying that  transmitted energy as average transmitted power over time. For example for G public 20 W/m2 over 2s gives 40W/m2. However using the other formula for energy gives something much above the 40W/m2 (in KJ/m2).  (see also comment 3).  This comment has been repeated and is not addressed again.
37 12 Main 681-718 Technical Best to put frequency f in the same units in all Tables otherwise it is confusing to have it in MHz and after in GHz. Choose GHz as it is most used This comment has been repeated and is not addressed again.
37 13 Main 866 Technical Additional reference
Magda Havas, Radiation from wireless technology affects the blood, the heart and the autonomic nervous systems. Rev. Environ. Healt 2013; 28(2-3): 75-84.
Magda Havas,  Electromagnetic Hypersensitivity: Biological Effects of Dirty Electricity with Emphasis on Diabetes and Multiple Sclerosis. Electromagnetic Biology and Medicine, 25: 259–268, 2006
In these articles, vulnerable persons such as pupils are cited and also effect on the blood and nervous system. Also effects of health such as diabete. 
This comment has been repeated and is not addressed again.
37 14 Appendix A 69-70 Technical It is assumed that tissue has the same density as water which is not true as the dry part of a tissue is not negligable; Water is is Gly assumed be around 70-80% of the body.  This comment has been repeated and is not addressed again.
37 15 Appendix A 80 Technical Please correct the equation: the correct