The WHO provides a current overview of the worldwide standards for limiting exposure to electromagnetic fields in its Global Health Observatory (GHO) web portal. It allows comprehensive comparisons of the standards between countries over the world. The recommendations and guidelines of the European Union for limiting the exposure of the general public (EU recommendation 1999/519/EC) or workers (EU Directive 2013/35/EU, which replaced the former EU Directive 2004/40/EC) are a common basis for legislation in many countries in Europe. In both guidance documents, the limits are derived in large part from the recommendations of the ICNIRP. But there are large differences in the national implementation of the recommendations and guidelines.
GermanyIn Germany, compliance with the limits for the general public in the ranges of low-frequency and radiofrequency fields is regulated by law by the 26. BlmSchV (Ordinance on Electromagnetic Fields). Moreover, the internationally recognized standards for product safety, which limit the emissions of devices, and the accident prevention regulations for the protection of workers are applied (Limit values in Germany (occupational exposure)).
For the low frequency range, the German Federal Office for Radiation Protection has compiled the regulations and limits in Europe in an overview. As from April 2011, a study published by the National Institute for Public Health and the Environment of the Netherlands provides an overview of the exposure limits in different countries of the world in the ranges of 50 Hz fields and mobile communication fields (GSM-900, GSM-1800, and 2100 MHz UMTS) for the general public and occupational exposure.
Under public discussion are particularly those countries that have introduced partially stricter limits in their national policy than the limits recommended by the ICNIRP and EU. In the low-frequency range, these include for example the Netherlands and Switzerland, and in the high-frequency range (especially for mobile communication) Italy, Luxembourg, Switzerland and Belgium. It should be noted that both the scopes of application and the bases of assessment are often not directly comparable between the different countries. Some examples are mentioned in the following.
NetherlandsIn the Netherlands, for power lines the low-frequency reference levels according to the ICNIRP guidelines are applied. However, since 2005 there is also a recommendation by the Dutch Ministry of Infrastructure and the Environment applying to newly built power lines in sensitive areas, according to which a magnetic flux density of 0.4 µT should not be exceeded (Source:Rijksoverheid). On closer examination, it is a recommendation to local authorities for new installations to maintain a distance between high voltage power lines and areas with "sensitive assignments" (e.g. homes, schools, kindergartens and day nurseries), so that children are not exposed in the long-term to magnetic fields above 0.4 µT. The definition of the magnetic field zone to be avoided is, however, based on the annual average assuming 30% capacity utilization. Thus it cannot be compared for example with the German limit (because it is based on highest capacity utilization). Moreover, because the upgrading of existing lines is not considered as a new construction, the recommendation does not apply to upgraded lines. For the electric field, the ICNIRP reference level of 5 kV/m remains unchanged. In contrast to the Ministry, the Health Council of the Netherlands (an independent scientific body, which advises the Government and the Parliament in matters of health) saw no reason for more stringent measures (Source: BfS).
SwitzerlandAlso in Switzerland, the limit of immission (i.e. the basis restriction) for 50 Hz magnetic fields from power lines is based on the ICNIRP recommendations of 1998 and is thus 100 µT – similar to the reference level in Germany. However, for the precautionary limitation of emission, the Swiss “Ordinance relating to Protection from Non-Ionizing Radiation” (NISV) sets a reference level (so-called “installation limit value”; cf. Reference levels) of 1 µT for magnetic fields regarding installations that were built after 1 February 2000. Here the distinction between immission and emission limits is important, because also in Switzerland the immission limit is still at 100 µT. Thus there are two widely separated limits for the same situation. In the ordinance there is no definition of an installation limit value for the electric field strength.
With the amendment to the ordinance on 1 July 2016 (preprint, only in German), the regulations were modified and rendered more precisely, particularly as regards changes to older power lines.
Also in the range of radiofrequency fields, the ordinance dating from 2000 has adapted the basic restrictions according to ICNIRP for all publicly accessible areas. A lower installation limit value for the electric field strength exists, however, for mobile phone base stations. Here the limit is one tenth of the limit in the ICNIRP recommendation. For other transmitters and for radar the limits are even lower down to 3 percent of the corresponding ICNIRP limit, depending on the frequency.
ItalyIn the radiofrequency range, Italy deviates from the ICNIRP guidelines insofar as the reference levels in the range between 3 MHz and 3 GHz are fixed instead of the frequency-dependent definition in the ICNIRP guidelines. At the mobile communication frequency of 900 MHz, it results for example in a limit for the magnetic field strength, which is 45 percent of the limit in the ICNIRP recommendation. In the case of power density, it is 22 percent of the ICNIRP limit at the same frequency. In places with "sensitive use" (such as schools and kindergartens) and in places where people could stay longer than four hours, even lower limits apply. These limits also apply to new installations.
BelgiumIn Belgium, especially low limits have been adopted for the Flemish part of the country and for Brussels. In the frequency range of mobile communications, the limits partially lie only at 0.5 percent of the corresponding limits in the ICNIRP recommendation.
USAIn the United States there is no uniform legislation to limit the low-frequency fields from power lines. In some states (Colorado, Connecticut, Hawaii, Maryland, Ohio) the principle of “prudent avoidance” is applied under which the exposure of the population to 60 Hz fields should be limited, but at reasonable cost (Source: EMF-Portal). In other states (Florida, Minnesota, Montana, New Jersey, New York, Oregon) there are fixed limits for the fields from power lines that lie between 0.2 times and nearly 2.5 times the reference levels in the European Council Recommendation 1999/519/EC (Source: EMF Portal).
For radio systems, the federal legislation in the USA sets basic restrictions identical to that in the European Council Recommendation. However, due to another calculation model, the reference levels are higher (e.g. at 900 MHz by about one fifth for the electric and the magnetic field strengths, and by about one third for the power density).