His approach is to approve of studies that appear to offer some glimmer that cell phone energy is carcinogenic and at the same time to find fault with studies that show no evidence of an effect.
Legislation which came into effect at the end of 2012 entitled anyone finding themselves homeless through no fault of their own to settled accommodation.
"With this data now available from more than one study, it really becomes the responsibility of parents, physicians, and teachers to pay attention to the relative-age effect and not intervene with treatment and labeling of children who it's no fault of their own what time of year they were born, " Garland says.