Biomarkers Archives - EMFSA

BfS International workshop: Impact of electric, magnetic and electromagnetic fields on oxidative stress – February 2022

Editor — Wed, 19 Apr 2023 13:54:24 +0000

Federal Office for Radiation Protection (BfS):

Publication date: 24-Mar-2023

In Germany, the expansion of the power grid and the construction of several new high-voltage lines across the country are a result of the switch to renewable energy sources. In addition, the new 5G mobile communications standard and the introduction of digital technologies in almost all scenarios of daily life are imminent. This leads to changed exposure conditions of the population and the environment to electric, magnetic and electromagnetic fields (EMF) of all frequency ranges. As a result, public concern about possible health effects from EMF could increase. In scientific and public debates, oxidative stress is often postulated as an EMF-induced mechanism affecting biological systems. The term oxidative stress describes the imbalance between the production of reactive (oxidizing) chemical species and the breakdown of such chemical species by antioxidant defense mechanisms. The WHO has commissioned several systematic reviews dealing with possible health effects of radiofrequency electromagnetic fields. One of these systematic reviews addresses the topic of radiofrequency fields and biomarkers for oxidative stress. As part of the international workshop, the current state of research was comprehensively examined with international experts in a three-day event in order to approach the topic from different scientific perspectives, identify gaps in knowledge and, where necessary, initiate new research.

http://nbn-resolving.de/urn:nbn:de:0221-2023032336903

PDF of the meeting:

https://doris.bfs.de/jspui/bitstream/urn:nbn:de:0221-2023032336903/4/BfS_2023_3621EMF104_Anlagen.pdf

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John Bucher, who studied toxic agents from A to Z, retires from NIEHS

Editor — Mon, 24 May 2021 15:49:22 +0000

#NTPtox senior scientist John Bucher, Ph.D., retired in April after nearly four decades at the institute. His scientific achievements, innovative thinking, and mentorship will leave a lasting influence, according to colleagues. https://t.co/8PjTc7Q70P pic.twitter.com/BZyquwrhbi
— NIEHS (@NIEHS) May 24, 2021

NIEHS News Environmental Factor May 2021

During almost four decades at the institute, he brought innovation to many complex issues, such as reducing animal use in research.

BY JESSE SAFFRON

John Bucher, Ph.D., senior scientist in the NIEHS Division of the National Toxicology Program (DNTP), retired in April after nearly four decades at the institute. His scientific achievements, innovative thinking, and mentorship will leave a lasting influence, according to colleagues.

Throughout his career, Bucher advanced knowledge on the health effects of numerous environmental agents, such as fluoride and cell phone radiation. He also expanded understanding and adoption of nonanimal approaches to toxicological research.

Reducing use of animals

After earning his undergraduate degree in biology from Knox College in Illinois, Bucher received a master’s in biochemistry from the University of North Carolina at Chapel Hill. He then took up pharmacology as a doctoral student at the University of Iowa.

Later, Bucher drew insights from pharmacology when developing ways to reduce the use of animals in toxicological research and study chemicals more rapidly and efficiently. He said that his achievements in this regard are especially rewarding.

“Traditional toxicology studies often are too expensive and time-consuming, and it can take years for findings to be disseminated,” said Bucher. “I am proud that my colleagues and I recognized that this was unsustainable and worked to advance novel experimental approaches.”

Read the article at:

https://factor.niehs.nih.gov/2021/5/awards-recognition/bucher/index.htm

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NTP’s future plans for studying cell phone RFR, including 5G

Editor — Sat, 15 Aug 2020 13:55:03 +0000

What are NTP’s future plans for studying cell phone RFR?

NTP is working to better understand the biological basis for the cancer findings reported in its earlier RFR studies. The program has developed smaller RFR exposure chambers for additional short-term studies that will take weeks and months to complete rather than years. NTP aims to better understand the underlying effects of RFR on biological systems, such as looking at biomarkers of damage. The biomarkers are measurable physical changes, such as DNA damage, that can be seen in shorter amounts of time than it takes to develop cancer and that might be predictive of disease. NTP scientists also want to know if heat or exposure-related stress plays a role in cancer development.

With 5G technology on the horizon, many questions have been raised about what this means with respect to human exposures to RFR. One significant difference between 5G networks and the current networks is that 5G will utilize a broader range of frequencies, including those much higher than NTP previously evaluated (> 6000 MHz). The lower frequency ranges that are currently in use (700-2700 MHz) remain relevant since they will continue to be used in existing cellular communication networks, as well as the 5G network. The higher frequencies, known as millimeter waves, can rapidly transmit enormous amounts of data with increased network capacity compared with current technologies. Millimeter waves do not travel as far and do not penetrate the body as deeply as do the wavelengths of the lower frequencies. Since these millimeter waves are likely to penetrate no deeper than the skin, there is less concern that these frequencies can cause harmful effects in the heart and brain. However, scientists do not know if millimeter waves may cause toxicity in the skin and other human tissues. Since the NTP’s studies have demonstrated that there is some interaction between RFR exposure at the tested frequencies and cancers of certain tissues, there is a need to understand the interaction between RFR and biological tissues and the factors that affect that interaction.

The exposure system is also designed to allow NTP to conduct studies with various RFR frequencies and modulations used by cell phones to keep up with changing technologies in the telecommunications industry. In general, NTP scientists want to understand the impact of exposure to RFR on biological tissues, regardless of generation, or G.

Source: https://ntp.niehs.nih.gov/whatwestudy/topics/cellphones/index.html

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Technical Assessment of Ultrasonic Cerebral Tomosphygmography and New Scientific Evaluation of Its Clinical Interest for the Diagnosis of Electrohypersensitivity and Multiple Chemical Sensitivity

Editor — Sun, 05 Jul 2020 19:46:41 +0000

Greco, F. Technical Assessment of Ultrasonic Cerebral Tomosphygmography and New Scientific Evaluation of Its Clinical Interest for the Diagnosis of Electrohypersensitivity and Multiple Chemical Sensitivity. Diagnostics 2020, 10, 427.

Ultrasonic cerebral tomosphygmography (UCTS), also known as “encephaloscan”, is an ultrasound-based pulsatile echoencephalography for both functional and anatomical brain imaging investigations. Compared to classical imaging, UCTS makes it possible to locate precisely the spontaneous brain tissue pulsations that occur naturally in temporal lobes. Scientific publications have recently validated the scientific interest of UCTS technique but clinical use and industrial development of this ancient brain imaging technique has been stopped notably in France, not for scientific or technical reasons but due to a lack of financing support. UCTS should be fundamentally distinguished from transcranial Doppler ultrasonography (TDU), which, although it also uses pulsed ultrasounds, aims at studying the velocity of blood flow (hemodynamics) in the cerebral arteries by using Doppler effect, especially in the middle cerebral artery of both hemispheres. Instead, UCTS has the technical advantage of measuring and locating spontaneous brain tissue pulsations in temporal lobes. Recent scientific work has shown the possibility to make an objective diagnosis of electrohypersensitivity (EHS) and multiple chemical sensitivity (MCS) by using UCTS, in conjunction with TDU investigation and the detection of several biomarkers in the peripheral blood and urine of the patients. In this paper, we independently confirm the clinical interest of using UCTS for the diagnosis of EHS and MCS. Moreover, it has been shown that repetitive use of UCTS in EHS and/or MCS patients can contribute to the objective assessment of their therapeutic follow-up. Since classical CT scan and MRI are usually not contributive for the diagnosis and are poorly tolerated by these patients, UCTS should therefore be considered as one of the best imaging technique to be used for the diagnosis of these new disorders and the follow-up of patients. View Full-Text

Added notes by EMFSA: Professor Dominique Belpomme:

“Given the technical and scientific interest of this method to localize precisely the spontaneous pulsometric defect that we have observed in temporal lobes in EHS and/or MCS patients, we therefore now push international companies to manufacture this type of software which could be included in the widespread and presently existing echo doppler machines.”

Reviews

https://www.mdpi.com/2075-4418/10/6/427/review_report

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NTP Turns to Mechanisms DNA Breaks, Oxidative Stress and Gene Expression Are on the Agenda

Editor — Wed, 18 Sep 2019 10:34:31 +0000

Re-posted from:

https://microwavenews.com/news-center/ntp-turns-search-mechanisms?fbclid=IwAR2WTm8mY7tcuHzPLXcj7YDJvjeImLufcshES1H9P5Vl6CSNCL1JZyirq7s

September 17, 2019

The U.S. National Toxicology Program (NTP) will soon embark on a new phase of its long-running RF project. Last year, the NTP concluded that RF radiation causes cancer; now it will begin a systematic search for mechanisms to explain how and why the tumors developed. Work is expected to begin by the end of the year.

The research plan is wide-ranging. It includes studies on gene expression, oxidative stress and DNA damage and repair, as well as the possible role played by heat. Other priorities on the NTP agenda are studies on behavior and stress.

We’re “optimistic” that we can detect changes in gene expression and identify biomarkers of RF effects, NTP’s Michael Wyde told Microwave News. Wyde is leading the new project. He will continue to work with John Bucher, the former NTP associate director, who ran its $30 million animal study, which showed “clear evidence” that RF radiation can lead to malignant tumors in male rats.

The NTP has already reported finding more DNA breaks —as detected with the comet assay— among the RF–exposed animals, including in the brain where rats later developed tumors. Those results, presented at a conference two years ago, have been submitted for publication. The paper is currently under peer review, according to Sheena Scruggs in NIEHS’ Office of Communications and Public Information. (The NTP and NIEHS are closely connected.)

How Does RF Radiation Cause DNA Breaks?

The fact that the NTP documented DNA damage “adds to the credibility of the animal findings,” said Ron Melnick. “It’s very supportive.” Melnick led the team that designed the NTP study; he retired in 2009.

Still missing, however, is how RF radiation causes DNA damage. “The breaks themselves don’t tell you anything about the mechanism at work,” Henry Lai explained in a recent interview. Twenty-five years ago, Lai and N.P. Singh were the first to show that RF radiation can induce DNA breaks —as it happened, in the brains of rats.

It is generally accepted that RF radiation is in itself not powerful enough to break chemical bonds and therefore unable to directly tear DNA apart. At the outset, Lai and Singh offered two possible mechanisms: oxidative stress and impaired DNA repair. Oxidative stress is shorthand for the sequence of events that follows an increase in the number of free radicals —biologically active molecules that can damage DNA. Alternatively, RF radiation may hinder the cell’s ability to repair DNA breaks, which occur naturally and not infrequently.

In 1997, two years after their original paper, Lai and Singh followed up with strong evidence implicating oxidative stress. When they treated the rats with melatonin —a natural hormone that neutralizes free radicals— before RF exposure there were no more DNA breaks. If the radiation could indeed generate free radicals, they pointed out, the risks would go beyond cancer to include premature aging as well as Alzheimer’s, ALS and other neurological diseases.

“If I were to design the project, I would look at the link between oxidative stress and DNA damage,” Melnick said. “That’s doable.”

A recent review of some 100 journal articles found that more than 90 percent “confirmed that [low-level] RF radiation induces oxidative effects in biological systems.” It was published in Electromagnetic Biology and Medicine in 2016.

NTP’s Wyde said that an important first step will be “to replicate the comet assays” to confirm that RF radiation damages DNA. He cited some uncertainty due to the wide variation in the extent of the breaks seen in the original NTP experiments and the small number of animals used. If the breaks are replicated, Wyde plans to run additional “more specific and robust assays” to evaluate the DNA damage and repair enzymes.

New Smaller Exposure Chambers

For this new phase of the RF project, the NTP has again turned to the IT’IS Foundation in Zurich to design and build new reverberation chambers, which are more compact and less expensive than the room-size units built for the original study. As before, these smaller units will also allow animals to move freely while being exposed to 900 MHz or 1800 MHz radiation. Each can house up to ten animals.

The NTP declined to discuss the new exposure setups, stating only that the information would be posted on the NTP RF website in due course. Niels Kuster, the director of IT’IS, confirmed that four new chambers have been delivered to the NIEHS/NTP Campus in Research Triangle Park, NC.

For the time being, the NTP is planning only animal studies. When asked whether in vitro RF experiments (using living cells) are under consideration, the NTP communications office replied that their feasibility is “still being assessed.”

In a recent posting on its website, the NTP announced that it is in the midst of evaluating the literature on the higher frequencies used in 5G.

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What are NTP’s future plans for studying cell phone RFR and 5G wireless technology?

Editor — Wed, 21 Aug 2019 22:44:58 +0000

5G is currently emerging and will eventually overtake the existing 2G, 3G, and 4G technology. In the meantime, consumers will continue to be exposed to RFR from these sources in the 700-2700 MHz range. As the 5G network is implemented, some of the signals will use the same lower frequencies as the older technology previously studied by NTP. Additionally, concern has been raised because the 5G network will also use higher frequencies, up to 60,000 MHz, thereby exposing wireless consumers to a much broader spectrum of frequencies. The higher frequencies, known as millimeter waves, can rapidly transmit enormous amounts of data with increased network capacity compared to current technologies. Millimeter waves do not travel as far and do not penetrate the body as deep as the wavelengths from the lower frequencies. Millimeter waves are likely to penetrate no deeper than the skin, as opposed to the lower frequencies that have been shown to penetrate at least three to four inches into the human body.

NTP is currently evaluating the existing literature on the higher frequencies intended for use in the 5G network and is working to better understand the biological basis for the cancer findings reported in earlier studies on RFR with 2G and 3G technologies. Additionally, work is ongoing to develop smaller RFR exposure chambers for additional short-term studies that will take weeks and months rather than years. The exposure system is also being designed with the capability of conducting studies with various RFR frequencies and modulations to keep up with the changing technologies in the telecommunications industry.

NTP is also hoping to identify biomarkers of damage from RFR exposure. These would be measurable physical changes that can be seen in shorter periods of time than it takes to develop cancer. Examples could be changes in behavior after exposure or molecular changes that might be predictive of cancer. If scientists can better understand biological changes in animals, they will know more about what to look for in humans.

Source: https://ntp.niehs.nih.gov/results/areas/cellphones/index.html

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Oxidative stress in electrohypersensitivity self‑reporting patients: Results of a prospective in vivo investigation with comprehensive molecular analysis.

Editor — Fri, 20 Jul 2018 17:07:24 +0000

Int J Mol Med. 2018 Jul 12. doi: 10.3892/ijmm.2018.3774. [Epub ahead of print]

Irigaray P¹, Caccamo D², Belpomme D¹.

Abstract

A total of 32 electrohypersensitivity (EHS) self‑reporting patients were serially included in the present prospective study for oxidative stress and antioxidative stress response assessment. All thiobarbituric acid‑reactive substances (TBARs) were measured in the plasma, particularly malondialdehyde (MDA) for lipid peroxidation; additional measurements included total thiol group molecules, reduced glutathione (GSH), oxidized glutathione (GSSG) for oxidative stress assessment and nitrotyrosine, a marker of peroxynitrite‑induced oxidative/nitrosative stress. In addition, the activity of Cu‑Zn superoxide dismutase (SOD1) was measured in red blood cells (RBCs) and glutathione reductase (GR) and glutathione peroxidase (GPx) in RBCs and plasma. Depending of the biomarker considered, 30‑50% of EHS self‑reporting patients presented statistically significantly increased TBARs, MDA, GSSG and NTT mean plasmatic level values in comparison with normal values obtained in healthy controls (P<0.0001). By contrast, there were no plasmatic level values above the upper normal limits for GSH, GSH/GSSG ratio, total glutathione (GluT) and GSH/GluT ratio, and values for these GSH‑associated biomarkers were statistically significantly decreased in 20‑40% of the patients (P<0.0001). Furthermore, in RBCs, mean SOD1 and GPx activities were observed to be statistically significantly increased in ~60% and 19% (P<0.0001) of the patients, respectively, while increased GR activity in RBCs was observed in only 6% of the patients. The present study reports for the first time, to the best of our knowledge, that overall ~80% of EHS self‑reporting patients present with one, two or three detectable oxidative stress biomarkers in their peripheral blood, meaning that these patients‑as is the case for cancer, Alzheimer’s disease or other pathological conditions‑present with a true objective new pathological disorder.

PMID:: 30015864
DOI:: 10.3892/ijmm.2018.3774

Oxidative stress in electrohypersensitivity self‑reporting patients(1)

Note by EMFSA – James Lech explains:

The first author of the study is Prof. Belpomme. This paper is a build on from his previous paper.

The paper Oxidative stress in electrohypersensitivity self‑reporting patients(1) is extremely detailed and comprehensive. It is done to a standard that is easily replicable and how-to for other scientists that wish to replicate it.

The study is backed up from previous biomarker tests and the physics supports the explanation.

Because Belpomme’s previous work had such a large population study already, in this study, it was not needed to have a large sample because statistical significant values were easily attainable.

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The implications of non-linear biological oscillations on human electrophysiology for electrohypersensitivity (EHS) and multiple chemical sensitivity (MCS).

Editor — Fri, 09 Mar 2018 16:43:05 +0000

Sage C. The implications of non-linear biological oscillations on human electrophysiology for electrohypersensitivity (EHS) and multiple chemical sensitivity (MCS). Rev Environ Health. 2015;30(4):293-303. doi: 10.1515/reveh-2015-0007. PMID: 26368042.

Abstract

The ‘informational content’ of Earth’s electromagnetic signaling is like a set of operating instructions for human life. These environmental cues are dynamic and involve exquisitely low inputs (intensities) of critical frequencies with which all life on Earth evolved. Circadian and other temporal biological rhythms depend on these fluctuating electromagnetic inputs to direct gene expression, cell communication and metabolism, neural development, brainwave activity, neural synchrony, a diversity of immune functions, sleep and wake cycles, behavior and cognition. Oscillation is also a universal phenomenon, and biological systems of the heart, brain and gut are dependent on the cooperative actions of cells that function according to principles of non-linear, coupled biological oscillations for their synchrony. They are dependent on exquisitely timed cues from the environment at vanishingly small levels. Altered ‘informational content’ of environmental cues can swamp natural electromagnetic cues and result in dysregulation of normal biological rhythms that direct growth, development, metabolism and repair mechanisms. Pulsed electromagnetic fields (PEMF) and radiofrequency radiation (RFR) can have the devastating biological effects of disrupting homeostasis and desynchronizing normal biological rhythms that maintain health. Non-linear, weak field biological oscillations govern body electrophysiology, organize cell and tissue functions and maintain organ systems. Artificial bioelectrical interference can give false information (disruptive signaling) sufficient to affect critical pacemaker cells (of the heart, gut and brain) and desynchronize functions of these important cells that orchestrate function and maintain health. Chronic physiological stress undermines homeostasis whether it is chemically induced or electromagnetically induced (or both exposures are simultaneous contributors). This can eventually break down adaptive biological responses critical to health maintenance; and resilience can be compromised. Electrohypersensitivity can be caused by successive assaults on human bioelectrochemical dynamics from exogenous electromagnetic fields (EMF) and RFR or a single acute exposure. Once sensitized, further exposures are widely reported to cause reactivity to lower and lower intensities of EMF/RFR, at which point thousand-fold lower levels can cause adverse health impacts to the electrosensitive person. Electrohypersensitivity (EHS) can be a precursor to, or linked with, multiple chemical sensitivity (MCS) based on reports of individuals who first develop one condition, then rapidly develop the other. Similarity of chemical biomarkers is seen in both conditions [histamines, markers of oxidative stress, auto-antibodies, heat shock protein (HSP), melatonin markers and leakage of the blood-brain barrier]. Low intensity pulsed microwave activation of voltage-gated calcium channels (VGCCs) is postulated as a mechanism of action for non-thermal health effects.

https://pubmed.ncbi.nlm.nih.gov/26368042/

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Comments on ‘Representative survey on idiopathic environmental intolerance attributed to electromagnetic fields in Taiwan and comparison with the international literature’

Editor — Sat, 27 Jan 2018 12:42:34 +0000

Link to the study:

https://ehjournal.biomedcentral.com/articles/10.1186/s12940-018-0351-8

The conclusions of the study:

We found the prevalence rate of IEI-EMF has been declining, instead of increasing as predicted previously. Women are more likely to report having IEI-EMF than men. Further studies to explore the causes leading to the declines may help the public, scientific community, and government deal with idiopathic intolerance to other environmental exposures.

Comments by James C. Lech

The results are skewed and open to weakness based on the methodology and limited scope.
The way the questions are explained are different to historical questions.
Questionnaires can also be problematic because they are subject to bias. In addition there are no dosimetery or biomarker tests conducted to correlate the data in the study. Studies that include all three demonstrate better results.
The rate of decline is also subject to social currency parameters. Wireless devices are now needed for people’s consumerism requirements. Gaming consoles, banking, social networks, etc. If you provide information that jeopordises their way of life, the first social instinct is to deny it as they are not aware of any other form. This is why there are psychiatric DSM studies that look at the addiction element.
The words ‘sensitivity or allergy’ are used, which many people may confuse with the word allergy. Also in Chinese culture most studies trying to map any form of disability are compromised by the cultural factor that the society does not accept and shun’s disabled persons. Therefore, again, the study requires biomarker tests.
The results collected are technically correct, but these results are flawed because of the flawed details of the methodology.

Weaknesses and misleading results of the study are as follows:

1. IEI-EMF. It is not the official designation by the WHO but rather the designation by a sub-domain of the WHO. From my thesis, (see below) it is not technically correct to label one scientifically or medically as EHS. From a scientific-technical-analysis, a biological system is broken up into three states:
  1. Sensitive: the degree to which a system will respond to a change in the pollutant variable condition, including the extent of change in ecosystem composition, structure and functioning.
  2. Adaptability: the degree to which adjustments are possible in practices, processes, or structures of systems to projected or actual changes of climate. Adaptation can be spontaneous or planned and can be carried out in response to, or in anticipation of changes.
  3. Vulnerability: the extent to which pollutant emmissions change may damage or harm a system. This depends on a system’s sensitivity and ability to adapt to new environmental conditions.
  4. First, everyone is electrosensitive, this is fact, however, everyone has different adaptability compensatory mechanisms to EMF radiation as a pollutant emission. It is when the adaptability begins to fail that the person or biology enters into a state of vulnerability to which damage and harm occurrs.
  5. I found Prof. Belpomme to provide the best and accurate medical description for a state of vulnerability of the Electromagnetic Field Intolerance Syndrome (EMFIS), a condition that has been recognized by the State and conferred in the High Court of Cape Town. Medically, using the term EMFIS, it is more effective at describing the relevant ICD-10 codes, and investigation of different symptoms because a syndrome is a compilation of multiple issues, and different persons will demonstrate different degrees of vulnerability to different sources for biological and non-linear reasons.
2. The mechanism of the questions has not evolved to the updated phenomenon of the incidence of technological systems in social systems in modern society.
3. Many recent studies have demonstrated an actual increase of incidences of intolerance to EMF radiation exposure and not a decrease as described in the study.
4. The study does not take into account influence by community values as a result of the occurrence of the shifting baseline syndrome, which, in turn, may offset tracking a model forecast for adaptability.
  1. A shifting baseline (also known as sliding baseline) is a type of change to how a system is measured, usually against previous reference points (baselines), which themselves may represent significant changes from an even earlier state of the system.
  2. Historically, the proliferation of EMF emissions and sources were minimal in comparison to today. In the past persons may have complained about symptoms because they were only occurring when in proximity to exposure.
  3. With the ubiquitousness of EMF devices, the allergy stimuli is constant, meaning that the person is unable to properly discern between an alternative. For example, a bad smell in the air, at first it is noticeable, but if it continues for days, the body adapts and compensates to think that it is ambient.
  4. Regarding EMF sensitivity: different population categories have different levels of sensitivity. Of those, an even much smaller level has “sense-sitivity”, the ability to sense EMF. The majority that do not “sense” but are still sensitive would then demonstrate a syndrome of symptoms and diseases.
5. Social currency and cultural factors: society today is constructed as an information structure dependant on wireless technology for essential purposes, for example, banking, municpal services etc. The most prevalent and powerful is social currency. Consumerism requires the latest phone, Xbox or Playstation, social media, the biggest TV etc… in order to maintain a social standing. The study did not account for this skew in the data recorded. Persons bound by social currency, would then rather lie about a reaction to the EMF radiation, because to do so would result in them having to reduce their use of the technology, causing their excommunication with their societal networks. This is why there are psychiatric DSM studies that look at the addiction element with devices that are designed to leverage on addiction through Game Theory in order to enable interaction for prolonged periods of time.
6. In Chinese culture most studies trying to map any form of disability is compromised by the cultural factor that the society does not accept and shuns disabled persons. Therefore, again the study requires biomarker tests.
7. Most EMF related studies that lack detailed dosimetry, biomarker or bioset data are inherently weaker. This is mainly because of the complexity of the EMF domain and the shifting baseline syndrome issue.

James Lech curriculum vitae :

Biosketch – JC Lech copy

Link to thesis below:

CONSTRUCTING AN EMF RADIATION HYGEIA FRAMEWORK AND MODEL TO DEMONSTRATE A PUBLIC INTEREST OVERRIDE

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