Introduction: The entire population is currently exposed to high-frequency electromagnetic fields (EMFs) (emitted by radio and TV antennas, Wi-Fi access points, routers, client adapters, smartphones, tablets, cordless phones, cell phones including their bases, Bluetooth devices) and low-frequency EMFs (emitted, for example, by electrical cables, lamps, and household appliances). Added to this is now 5G ("5th Generation"), which will use the 700 MHz, 3.4-3.8 GHz, and 26 GHz bands and, subsequently, the bands in the range between 24.25 and 86 GHz (Source: AGCOM). The level of indoor radiofrequency radiation in industrialized countries increased 5,000-fold between 1985 and 2005 (Maes, 2005). Until 1940, the natural pulsed background was 0.0002 V/m. Currently, the legal limit in Italy is 6 V/m (average over 24 hours) and with 5G it could increase further to 61 V/m, as recently requested by mobile operators who won the auction for the first frequencies needed to implement the new network infrastructure.

Devices such as smartphones, tablets, microwave ovens, and Wi-Fi routers emit electromagnetic radiation associated with radio frequencies or low-intensity, high-frequency microwaves (from 300 MHz to 300 GHz). Power lines and electrical devices are sources of electromagnetic fields (mainly magnetic for power lines and transformers) and radiation at lower frequencies (50 Hz) but higher intensities. According to the WHO, electromagnetic fields of all frequencies are one of the most common and rapidly increasing pollutants in the environment. All populations are exposed to varying degrees of electromagnetic fields, the intensity levels of which will continue to increase with current technological developments. Numerous scientific studies have demonstrated the ability of EMFs to induce biological changes in cells and living organisms, including humans. Therefore, from the point of view of possible environmental a n d health consequences, authorizations and legal limits for EMFs should be considered on a par with those for medicines, drugs, pesticides, and toxic chemicals such a s heavy metals o r endocrine disruptors. For this reason, independence, absence of conflicts of interest, scientific authority a n d credibility, and transparency must be considered essential qualities for anyone involved in assessing the potential impacts of EMFs on the environment a n d human health a n d in defining the regulations that govern them. Telecommunications companies, with government support, will implement the fifth generation (5G) wireless network within the next few years. This is a global technological change that will result in "smart" homes, businesses, highways, cities, and self-driving cars. The stated goal is to achieve 5G coverage in the homes of at least 80% of the national population (99.4% by June 2023) by 2022. According to AGCOM, to achieve these goals, the 5G network infrastructure will be fully operational with a density of approximately one million connected devices per square kilometer.

Concerns for human health arise in particular from the following points:

1. The propagation in urban areas of some of the frequencies used by 5G (known as 'millimeter waves') when fully operational is limited by physical obstacles (e.g., buildings, trees, etc.). For this reason, the 5G infrastructure involves the use of a dense network of "small cells," devices necessary for proper signal propagation, which can be placed at virtually every street corner, traffic light, or public lighting point. Added to this, as already mentioned, is the enormous proliferation of connected devices (one million per km2), which will add to the existing network (mainly the current mobile phone radio frequency network), generating an exponential and inevitable increase in the exposure of the population, particularly the most vulnerable (e.g., children, pregnant women) and those who are electrosensitive. We will move on to the 'Internet of Things' (IoT) and most objects will be connected to each other and to the Internet. The artificial electromagnetic field will have global coverage and everyone on Earth will have access t o high-speed, low-latency wireless communications from anywhere on the planet, even in rainforests, in the middle of the ocean, and in Antarctica.

2. Millimeter waves have specific biological effects that have only been partially studied, with preliminary results that are cause for concern (Di Ciaula, 2018). This has prompted hundreds of independent international researchers to call for caution, arguing that further scientific research is needed before these frequencies can be used on a global scale. Despite this, approximately 4 million residents in Italy have already been exposed to the so-called "5G trial" with exposure densities a n d frequencies that have not yet been explored on such a large scale, without this "trial" being preceded by adequate information, consent procedures, environmental and health risk analyses, and without the involvement of the institutions responsible for protecting the environment and health (ISPRA, ARPA, Ministry of the Environment and Protection of Land and Sea, Ministry of Health, National Institute of Health)2.

3. The legal limits governing exposure to EMFs, which are supposed to protect health and the environment, are based solely on "thermal" effects (the ability to generate heat) following acute exposure and not, as they should, on biological effects (the ability, independent of thermal effects, to cause biological changes in living organisms at various levels, from molecular and sub-cellular to systemic) following chronic exposure. If these were taken into account, numerous scientific findings would suggest a drastic reduction in the current legal limits.

The implementation of 5G will bring unprecedented global environmental changes. Millions of new 5G base stations are expected on Earth and 20,000 new satellites in space, with an estimated 200 billion transmitting objects that will be part of the Internet of Things by 2020 and a trillion objects a few years later. In mid-2018, commercial 5G at lower frequencies and speeds was used in Qatar, Finland, and Estonia. The rollout of 5G at extremely high frequencies (millimeter waves) is expected by the end of 2018. At the end of 2018-beginning of 2019, 5G trials began in Milan, Prato, L'Aquila, Matera, and Bari. The widespread rollout of 5G in other cities, however, is expected to take place over the next 3 or 4 years. The scientific evidence available on the effects of high-frequency electromagnetism in general and, in particular, on those of exposure to millimeter waves, makes it essential to apply the precautionary principle referred to in Article 191 of the Treaty on the Functioning of the European Union (EU) and recognized by Italian national legislation, the purpose of which is to ensure a high level of environmental protection through preventive measures in the event of risk.

Recourse to the precautionary principle is justified when three conditions are met, namely:

• the identification of potentially negative effects;
• evaluation of available scientific data;
• the extent of scientific uncertainty.

As a preliminary to our brief analysis, we believe it is appropriate to recall Article 32 of the Constitution, which establishes the right to health of Italian citizens. We would also like to recall Article 41 of the Constitution ("Private economic initiative is free. It cannot be carried out in conflict with social utility or in such a way as to damage safety, freedom, and human dignity") a n d , finally, Article 3(p) of the Treaty establishing the European Community, "the activities of the Community shall include a contribution to the attainment of a high level of health protection"; the Treaty also provides for "the protection of the health of workers and consumers."

We have serious doubts that politicians have followed these regulatory pillars in approving the introduction of this new technology without hesitation and without preliminary risk assessments, effectively entrusting private entities with ownership of specific frequency bands and allowing them to use the new 5G infrastructure in the context of regulations currently based on limits that lack scientific validation and, therefore, unable to protect the environment and public health in the best possible way. 

The entire electromagnetic emissions sector, as has been amply demonstrated, has effects on the environment and on human and animal health and must therefore be urgently subjected to a Strategic Environmental Assessment. This assessment must involve, in a spirit of absolute transparency and exchange of information, not only research bodies, institutions responsible for environmental and health protection, and government commissions, but also citizens, professional associations, associations, and committees, in the name of participatory democracy, the rules that govern it, and those on the transparency of administrative acts. In view of these facts, it appears to the writers that the government has not requested any health opinion on 5G pursuant to Health Reform Law 833 of 1978. In particular:

• INAIL states that it has no documentation on the safety of 5G;
• the Ministry of Health states that it was not consulted on the safety of 5G by the Ministry of Economic Development prior to the sale of 5G frequencies and that the Higher Health Council also did not address the issue; 
• The Ministry of Economic Development responds that the requested documentation (the health opinion) is not within its competence.
• The Higher Institute of Health states that it has not produced any health opinion but has responded to AGICOM, which requested the simplification of the procedures for installing the new 5G antennas.