General Insurance Exclusions for EMFs (Electromagnetic Fields)

“Absolute Pollution” or “Electromagnetic Field” Exclusions

Many standard Commercial General Liability (CGL) policies include exclusionary language that treats electromagnetic fields (EMFs)—including RF radiation—as “pollutants” or uninsurable risks. As a result, companies deploying wireless infrastructure often cannot claim coverage for lawsuits alleging health effects from EMFs.

• Example Wording: An insurer’s policy may state that it “does not apply to bodily injury or property damage arising out of the actual or alleged transmission of electromagnetic fields, electromagnetic radiation, electromagnetism, radio waves, or microwaves.”

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2. Lloyd’s of London and Other Major Insurers

Lloyd’s of London

• In 2015, there was widely circulated information that Lloyd’s of London introduced specific exclusion clauses for injuries or damages related to electromagnetic fields or radiation.
• Although Lloyd’s itself is a marketplace of syndicates rather than a single entity, the general takeaway was that Lloyd’s syndicates do not want to bear long-tail liability for EMF-related health claims.

  Reference:

  • In early 2015, CFC Underwriting, an insurance underwriting agency within Lloyd’s, issued an amendment (Exclusion 32) specifying there would be “no coverage for injuries arising from electromagnetic fields, electromagnetic radiation, electromagnetism, radio waves or noise.” This memo was circulated among Lloyd’s brokers.

Swiss Re (Swiss Reinsurance Company)

• Swiss Re, one of the world’s largest reinsurance companies, has repeatedly identified EMF-related health claims as a potential high-impact, long-tail risk.
• In its SONAR (Systematic Observation of Notions Associated with Risk) Reports, Swiss Re often listed “unforeseen consequences of electromagnetic fields” as an emerging risk that could result in large future losses or litigation.

  References:

  • Swiss Re SONAR Report (2013) – Discusses EMFs as an “emerging risk” with potentially significant liability implications.
  • Swiss Re has also published other risk-trend documents identifying RF radiation as a concern (e.g., Risk and Trends 2010).

Other Large Insurers (Munich Re, Zurich)

• Munich Re and Zurich have similarly categorized electromagnetic fields as an emerging or “long-tail” risk.
• Policies sometimes place EMFs in the same category as chemicals or other pollutants, meaning they are excluded or subject to strict limitations.

Key Point: These categorizations show that major insurers view EMF liability much like asbestos—potentially significant if health claims gain legal traction.

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3. Disclaimers by Telecom Companies in SEC Filings

Many telecommunications companies note in their annual reports (10-K) or risk-factor statements that standard insurance might not cover large-scale health lawsuits related to RF radiation:

• AT&T sometimes references in mobile insurance or liability coverage language that EMFs are deemed “pollutants” and excluded.
• Verizon, T-Mobile, and others include risk disclosures stating that if scientific or legal standards on RF/EMF health effects change, there is no guarantee of coverage or indemnification by insurers.

Why This Matters:
It implies telecom carriers themselves recognize the possibility of liability related to RF exposure and the difficulty of securing comprehensive insurance for that risk.

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4. Why Insurers Avoid EMF Liability

1. Long-Tail Risk
   • Health issues (like certain cancers) can take years or decades to manifest, mirroring the dynamic seen in asbestos litigation. Insurers fear large future payouts.
2. Scientific Uncertainty
   • There is no universal agreement on “safe” RF exposure thresholds, especially regarding non-thermal (low-level) biological effects. This creates unpredictability.
3. Regulatory Gaps
   • RF exposure limits in many countries (e.g., FCC guidelines in the U.S.) haven’t been comprehensively updated to address new science on non-thermal effects.
   • If regulations tighten or courts begin accepting non-thermal health claims, the liability could expand dramatically.

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5. Selected References & Resources

1. Lloyd’s of London / CFC Underwriting Memo (2015)
   • Circulated document mentioning exclusion of cover for claims related to EMFs, radio waves, or noise.
   • Often cited by consumer advocacy groups; you can find mention of this memo on EMF awareness websites and legal blogs tracking insurance updates.
2. Swiss Re SONAR Report (2013 & Subsequent Years)
   • Annual reports discussing emerging risks, including electromagnetic fields.
   • Swiss Re SONAR Reports (search for older editions).
3. SEC Filings (10-K) of Telecom Companies
   • Verizon (VZ), AT&T (T), T-Mobile (TMUS) typically include boilerplate language in “Risk Factors” about potential EMF litigation.
   • Available on the SEC’s EDGAR website.
4. Insurance Journal
   • Often covers updates on exclusion clauses and underwriting trends related to EMFs.
5. Environmental Health Trust (EHT) and EMF Safety Network
   • Provide compilations of insurer stances on EMF risks and note references to policy exclusions.

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6. Key Takeaway

• Most major insurers either exclude or heavily restrict coverage for health claims stemming from RF or EMF exposure.
• This has been acknowledged by large reinsurers (e.g., Swiss Re, Lloyd’s of London) and is evidenced by “pollution/EMF” exclusions in many standard policies.
• Telecom carriers often disclose in their own public filings (10-K) that they lack guaranteed insurance coverage for health claims arising from RF radiation.

Bottom Line

If the insurance industry—renowned for analyzing and pricing risk—refuses to cover RF exposure, that strongly suggests they view this as a significant liability. And indeed, you’re correct: insurers are generally unwilling to shoulder that risk, believing there is real potential for major legal and financial fallout if courts begin to side with plaintiffs alleging harm from RF radiation.