SUBJECT: Health and Safety at Work (Radiation Exposure)
RELATED : a. YA 53571/3839/2000 (Government Gazette B΄ 1105, “Measures to protect the public from the operation of antennas installed on land”)
b. Law 3850/2010 (Official Gazette A’ 84, “Sanction of the Code of Laws on the health and safety of workers”)
c. SYA HYPTHA 2022
d. No. prot. 17/2023 ESPEE Kalymnos
According to a very serious complaint by the Military Association of the Kalymnos Regional Unit (E.S.PE.E.KA.) which we are sending you as attachments, recently there has been an installation of a mobile phone antenna near places where there are activities of military personnel in Farmakonissi.
As the Union reports, there have long been complaints of frequent headaches, which are probably not only due to the constant hum caused by the antenna. Given that the area of the island in question is not large, so obviously the possibilities were limited, a reasonable question arises if there had been a study regarding the installation, in the context of which any side effects had been investigated.
At this point we must point out that exposure to electromagnetic radiation is marked with the SAR index, while the nature of the radiation (natural form) undoubtedly implies that it is exposure to harmful factors as understood by the existing regulatory and institutional framework on protection of health and safety at work, so they fall under the provisions of article 36 of (b) of the relevant Code. As a result, a series of important obligations of the Service towards the staff arise, for which we now have reasonable doubts as to whether they have been respected from the beginning, as they should have been.
In support of the above, we would like to remind you that with the current framework [(α) σχετικό] specific “basic limitations … so as to take into account the uncertainties that exist in terms of individual susceptibility, environmental conditions as well as differences in the age and state of health of the public” (Article 2, para.2) have been defined. Commonly. By accepting the term “uncertainty” it is accepted that the effect of electromagnetic radiation from mobile phone antennas on humans remains unknown and therefore strict measures must be taken.
In relation to the above, according to paragraph 1 of article 6 of the same YA, “the observance of the limits of safe exposure of the general population to electromagnetic radiation coming from a specific antenna installed on land, is established by preparing a study of the electromagnetic radiation of the antenna”, while below (para.2) it is clarified on the one hand that “the owner of the antenna is obliged to keep an antenna file which will be at the disposal of the competent authorities at all times”, on the other hand the contents of the file.
Additionally, we would like to remind you that, according to the “Short Safety Guide” issued by GDOSY/DADP for mobile telephony in 2008, “The effect of electromagnetic radiation on our health depends on the following 3 factors: a. the intensity of the radiation, b. the frequency and c. the duration of it.”, which makes it clear (from the results of the headaches) in this particular case that at least two of the three factors (intensity – duration) are met.
Paragraph 2 of article 37 of (b) describes the obligations of the employer (subject to articles 42 and 43 thereof) to carry out compliance checks and safety studies, as well as to inform the staff of the existing risks, which are due or otherwise have been reflected in the annual review of the Written Occupational Risk Assessment (WHA), in the context of which the area must have been visited by a competent Occupational Physician. However, from what we have been told, none of the personnel involved knows the intensity (exact radiation value) of the emission from this antenna, or the risks to which it is exposed on a continuous basis.
Following the above, we ask you for the following:
a. Let us know what observations have been endorsed by the Safety Technician and the Occupational Physician during the last review of the GEEK, as well as what remedial actions have been taken on them.
b. The immediate movement of the antenna to the most remote area of the island in relation to human activities.
c. The information regarding the intensity of radiation (SAR) to which the staff is exposed as well as the reasons why they are not aware of the risks.
d. If the personnel involved have been examined by an Occupational Physician.
We remain at your disposal for any clarification or information.
Messrs. Members of the Hellenic Parliament, to whom this is communicated, are requested to highlight the matter, through parliamentary control.
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