Outdated FCC “Safety” Standards

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FCC guidelinesWhen these guidelines were developed, a cell phone was the size of a brick and there was no Wi-Fi at the coffee shop. Times have changed. The laws have not.

Fact: There Are No Safety Standards

Currently there are no national or international “standards” for safe levels of the radiation emitted by wireless or microwave devices. Instead, the US government adopted “guidelines” developed by industry based on decades old research. Guidelines have a much lower certainty than a “standard” as proper long term safety testing was not done to ensure the public was protected from all possible harm.

In fact, no “safe” level has been scientifically determined for children or pregnant women. Therefore, the claim that a device “meets government standards” or that radiation levels are “FCC compliant” gives a false impression of safety.

The FCC guidelines rest on five fallacies (false assumptions) and therefore renders FCC guidelines obsolete. Compliance with “federal safety standards” does not assure your nor your family’s safety. In fact, our federal safety limits are in essence meaningless when it comes to our health.

The Five Fallacies of the Electromagnetic Radiation Exposure Limits

Developed by ANSI, IEEE and by ICNIRP in association with industry and military organizations, the existing exposure limits are based on these five false assumptions:

Fallacy 1: The only adverse biological effect from exposure to electromagnetic radiation (EMR) is heating.

Fact: Heating is not the issue. Hundreds if not thousands of studies show adverse health effects from headaches and sperm damage to many types of cancer including brain cancer. In all of studies with no temperature change. These were the kinds of studies that led the World Health Organization (WHO) to declare radio frequency radiation a Group 2B (possible) Human Carcinogen.

Fallacy 2: Only immediate (acute) adverse biological effects are important to consider; long-term (chronic) effects are not a concern.

Fact: The FCC’s exposure limits did not consider the health effects to people if they are exposed to hours and hours of this radiation over several years. Cancers can have long latency periods, and several significant research studies show links between long-term exposure and brain tumors. Such research led to the IARC Group 2B (possible) Human Carcinogen classification, and this information on long term effects was not considered when FCC’s exposure limits were developed decades ago.

Fallacy 3: Measuring radiation power levels by averaging over time allows us to understand the impact to our health. Peak radiation exposures are not necessary to measure to understand the potential impact from an exposure.

Fact: Peak millisecond radiation bursts impact our bodies at the cellular level. FCC’s exposure limits average the radiation exposures for 30 minutes, rather than consider the intense pulses that people are exposed to. Many scientists are concerned that it is the erratic nature of the wireless signal that can cause the harmful biological effects. If you report averages then those are numbers determined by calculation instead of reporting the actual peak levels. How much lower are the averages than the peaks? Averages can report numbers that appear to be far lower than peak levels.

Background: In the U.S., the FCC regulations (mostly for IEEE C95.1-1991) averaged exposure to the public over a 30 minute time period, and for workers a 6 minute time period. ICNIRP defines the averaged exposure to the public and to workers over a 6 minute time period.

To illustrate: I punch you, and that breaks your nose. I say the power of my punch can be averaged over the last year (that’s 365 days) and therefore you should not be hurt as I really did not punch you hard over the entire year—considering only the average power. Does this make sense? Should we use average or peak when we talk about measuring the impact on our bodies?

Fallacy 4: Assessments of the the unique vulnerability of children and the fetus is not necessary—only the radiation absorption into a large man is important.

Fact: FCC compliance testing utilizes a model of a 220 pound male head. Research repeatedly indicates that the radiation penetrates deeper into children’s smaller bodies and brains. The current FCC exposure limits did not consider the higher energy absorption in fetuses, children and women.

Fallacy 5: All body tissue uniformly absorbs radio frequency radiation. The ability of radiofrequency radiation to be absorbed differently into different body tissues and to have different biological effects due to the unique makeup of different body tissues and organs is not important to consider in understanding risks to public health.

Fact: The FCC’s exposure limits do not consider how this radiation is differentially absorbed by various body tissues. For example, female breast tissue is highly absorbent tissue, therefore the radiation will result in a much higher dose. Eyes and testes are also particularly vulnerable to electromagnetic radiation. Children’s bodies have been shown to have a higher water content making their tissues more absorptive of the radiation. However scientific documentation of the different electrical properties of different tissues in humans of various ages does not exist in the decades old FCC exposure limit guidelines.

FCC compliance testing for wireless devices utilizes a system whereby David Gultekin, working with Bell Labs electrical engineer Lothar Moeller, reported this month that normal working cell phones can create tiny hotspots within living brain tissue.


Some other examples of how FCC exposure limits have not kept up with the times:

  1. FCC exposure limits are based on the assumption that wireless signals at a human body from a distance are from only one transmitter antenna.
    • In the 21st century, we are not exposed to one Wi-Fi transmitter antenna. One typical school classroom might have dozens of radiation streams from dozens of transmitting antennas: 30 laptops, 30 cell phones, a wireless printer, a wireless security system, an overhead internet access point and a cell tower located in line of sight outside the window.
  2. FCC “standard operating positions” do not reflect the way we use our devices today.
    • FCC regulations specify what are called consumer “standard operating positions”, such as that laptops are distanced at least 20 cm (8 inches) from the user. Placing a laptop on the lap is then in violation of this “standard operating position”. Devices are radiation tested at these distances, and when we violate these “standard operating positions” we can be exposed to radiation levels in excess of the FCC exposure limits. Women now place cell phones in their bra or tucked against their abdomen under spandex exercise pants. Men have cell phones in front pockets of jeans. None of these common positions are in accordance with the FCC’s regulations.
Letters From US Agencies that Raise Serious Concerns About Outdated FCC Exposure Limits

Radio Frequency Interagency Workgroup Concerns About RF Exposure Limits Gregory Lotz NIOSH 1999 Letter

Interagency Radio Frequency Workgroup 2003 Letter from EPA Norbert Hankin on Additional Concerns about RF Exposure Guidelines

US Department of the Interior Letter 2014 on FCC Guidelines

EPA 1995 Letter on Development of Guidelines that were never completed as the EPA was defunded on this issue

FCC RADIO FREQUENCY GUIDELINES FAQ’S
How did it happen that these exposure limits are based on decades-old science and have not been updated?
The current FCC exposure limit was adopted by the FCC in 1996. However, based substantially on the IEEE C95.1-1991 but officially ANSI/IEEE C95.1-1992 which is identical  as the U.S. government’s exposure limit regulation. This means that effectively the standards adopted in 1996 are really from 1991. EHT scientific advisor Lloyd Morgan took a look at the history of the development of the standards and has detailed the key statements in the documents so that you can understand how the guidelines developed. Read it here. 
Why didn’t the United States EPA ever develop safety limits for this radiation?
In fact, the EPA began the process of developing exposure guidelines but then never finished it as funding was cut off. Click here to see a 1995 Briefing for the FCC by the EPA on the Development of RF Exposure Guidelines. The EPA drafted stage 1 RF exposure guidelines and sent them to comment prior to release in 1996. Stage 1 was only for thermal effects. The EPA announced that Stage 2 would protect against non thermal effects and would be ready in 1998. Then the Telecommunications Industry Association lobbied Congress to prohibit the EPA from releasing any guidelines. The 1996 Appropriations Bill that Congress passed defunded the EPA’s work in this area and contained language specifically prohibiting the EPA from increasing its regulations stating that “… EPA should not engage in [electromagnetic field] activities”. The 1996 Telecommunications Act gave authority over the health effects of wireless technology to a non-health agency–the FCC.
Is the government aware of the problems with the FCC guidelines?
The US Government Accountability Office published a report in 2012 urging the U.S. Federal Communications Commission to revisit the outdated safety standards for the exposures from wireless devices. The 2012 report states, “The Federal Communications Commission’s (FCC) RF energy exposure limit may not reflect the latest research, and testing requirements may not identify maximum exposure in all possible usage conditions.”
Will the guidelines ever be assessed, considering they may not protect the public?
The GAO 2012 Report spurred the FCC to review radiofrequency regulations. The FCC has received more than 900 submissions to their inquiry calling for health and safety information. To access these papers go to the FCC’s web site for Proceeding Number 13-84. However, there is no timeline in place as to when a determination will be made on the issue. Many expert groups and organizations have submitted informative comments. We recommend Dr. Moskowitz’ webpage which organizes these submissions to easily sort through the large volume of material.
Are agencies calling on the government to update these FCC limits?
Many doctors, scientists, and even branches of the US government have asked the FCC to revise their limits or have expressed concern that the current FCC limits are not protective or have cited instances of biological harm. They include:

  • The US Department of the Interior states that “The electromagnetic radiation standards used by the Federal Communications Commission (FCC) continue to be based on thermal heating, a criterion now nearly 30 years out of date and inapplicable today.” Read The 2014 Letter.
  • In 2012, the Government Accountability Office (GAO) published a 2012  Report that states, “The Federal Communications Commission’s (FCC) RF energy exposure limit may not reflect the latest research” and the report officially recommended that the FCC “Formally reassess the current RF energy exposure limit, including its effects on human health, the costs and benefits associated with keeping the current limit, and the opinions of relevant health and safety agencies, and change the limit if determined appropriate.”
  • The FCC is formally in review of these 20 year old standards and has stated it is “not a health and safety organization” and has called for expert comments. The FCC has so far received over 900 comments and they can be accessed at the FCC here: go to the FCC’s website for Proceeding Number 13-84. You can see the ~1000 submissions the FCC received here, from various scientists, doctors, government agencies, and organizations asking the FCC to change their limits to protect against bioeffects other than heating.  It could be many years before we see any changes from the FCC, if any, on safer wireless standards as there is no timeline for them to take action.
  • The EPA states pretty clearly that:1. Children, pregnant women and the elderly were not considered in the current radiation safety regulations in the USA. and 2. The regulations were to protect against heating damage only. They do not protect us from increased  cancer risk, not DNA damage, not immune damage, not inflammation (nope just heating). Read the Letter HERE.
  • The 2008 National Academy of Sciences (NAS) Report, Identification of Research Needs Relating to Adverse Health Effects of Wireless Communication, was tasked to identify any inadequacies in the research upon which the current US Radiofrequency radiation (RF) safety guidelines are based. The NAS Report found numerous inadequacies in that research record. An inadequate research record results in safety regulations that fail to address all exposures encountered by the public. Based on the 2008 NAS findings it cannot be asserted that US RF safety policy protects all members of the public from all mechanisms of harm in all exposure scenarios.
  • The American Academy of Pediatrics, which represent over 62,000 pediatricians in the US
  • has repeatedly called on the government to update its regulations stating that “Current FCC standards do not account for the unique vulnerability and use patterns specific to pregnant women and children.” Read it here.
  • The California Medical Association (which is the California branch of the AMA), which represent over 40,000 physicians. passed a Wireless Resolution that states:

Whereas scientists are increasingly identifying EMF from wireless devices as a new form of environmental pollution with a growing body of peer reviewed scientific evidence finding significant adverse health and biologic effects on living organisms with exposure to low levels of non-ionizing microwaves currently approved and used in wireless communication, and

Whereas peer reviewed research has demonstrated adverse biological effects of wireless EMF including single and double stranded DNA breaks, creation of reactive oxygen species, immune dysfunction, cognitive processing effects, stress protein synthesis in the brain, altered brain development, sleep and memory disturbances, ADHD, abnormal behavior, sperm dysfunction, and brain tumors; and…Resolved, That CMA support efforts to implement new safety exposure limits for wireless devices to levels that do not cause human or environmental harm based on scientific research. Read it here. Read a magazine article on their resolution here.

Dr. De Kun Li, a Senior Research Scientist at the Division of Research, Kaiser Permanente Northern California, sums up the problem with FCC regulations:

“In summary, we do not currently have scientific data to determine where the safe RF exposure level is regarding the non thermal effects. Therefore, it should be recognized that we are dealing with uncertainty now and most likely for the foreseeable future. The question for government agencies especially those concerned with public health and safety, is, given the uncertainty, should we err on the side of safety and take precautionary measures avoidance measures? Unknown does not mean safe. “

Letter from Dr. De-Kun Li, MD, PhD, MPH to the FCC

I have been told that the RF radiation levels from a proposed cell tower (or from our school’s Wi-Fi system) is well below FCC’s maximum permissible exposure levels (i.e. FCC compliant) and therefore I should not be concerned. Is there a health risk even at FCC compliant levels?
 Compliance to FCC limits means falling below FCC’s thermal limit, which is explained above. However there is a lot of peer-reviewed research that demonstrate negative health effects at levels far below the FCC thermal limits.  For example, as the 2012 Bioinitiative Report details, peer reviewed published research studies have found negative health effects begin as low as 0.003uW/cm2 . Please see the Charts showing these studies. 0.003uW/cm2 is orders of magnitude below FCC’s thermal limit of 1000uW/cm2 for 30 minutes. It is common for the power density around a cell tower or school Wi-Fi access point to be in the range 0.1-1.0 uW/cm2, which is well below the FCC (thermal) limit. Reports from RF measuring companies will often report the RF levels as a fraction of the FCC limit, and it is common for the report to say that the RF levels in a school environment with Wi-Fi or around a cell tower to be 1/10,000th of the FCC limit.  While this sounds low and “safe,” you should know that background levels (i.e. areas that are not near a cell tower or do not have Wi-Fi on) can be as low as 0.0003uW/cm2, which is less than 1/1,000,000 of the FCC limit!  In other words, the RF levels around a cell tower or school Wi-Fi access point could be more than 1000 times the background levels. These chronic levels of exposure to RF radiation near a cell tower or in a school Wi-Fi environment have NEVER been tested for long-term effects, so one cannot say that these levels that are “safe” just because they are 1/10,000 of the FCC limit.  In fact, reports from RF measuring companies never say that the RF levels are “safe,” only that they are FCC compliant.

In summary, FCC compliance means only that there is not enough microwave radiation from the cell tower or device to cook you if you are at a safe distance from it, and FCC limits only protect you from microwave heating effects.

Are the RF limits in all countries thermal like the US? If not, why not?
Not all countries have thermal limits as lenient as the US. The reason they have more protective standards is that either they have demonstrated harmful bioeffects at non-thermal levels through their own research or they have chosen to adopt the precautionary principle because of the growing body of peer-reviewed research that has shown negative health effects at levels far below thermal limits. Here’s a chart showing RF limits of several countries:

Outdoor-Pulsed-RF -RadiationLimits Other Countries

USA FCC guidelines versus RF guidelines in other countries

I keep reading that FCC’s limits for RF radiation are “thermal” limits. What does this mean?

A: The only negative health effect from RF (radiofrequency aka microwave) radiation that the FCC acknowledges is the heating of body tissues, which occurs when the power density of the RF radiation is high enough to cause tissue heating.  For example,  high levels of microwave radiation cook foods in your microwave oven. RF waves from cell towers, Wi-Fi, cell phones, cordless phones, baby monitors, laptops, tablets, and smart meters are also in the microwave frequency range of the electromagnetic spectrum, and they also can cause heating effects just like the microwave oven if the power density is high enough.

Our government’s limits are set to protect the public from heating levels of microwaves. For portable wireless devices that are held close to the body such as cell phones, laptops and tablets, the FCC has set a SAR limit (Specific Absorption Rate) which equals 1.6W/kg measured over a 1 gram mass of tissue.  SAR is the amount of RF radiation absorbed by the body from the portable device.  For things like cell towers which affect your living environment, that thermal limit is 1000 uW/cm2 (=1mW/cm2) averaged over 30 minutes for frequencies 1.5-100GHz, first set in 1986 based on recommendations by the National Council on Radiation Protection and Measurements (NCRP). Exposures above the thermal limit could cause your body tissues to heat. You can read more here in Title 47 CFR Section 1.1310 

RESOURCES TO LEARN MORE

ANSI C95.1-1982 Standard

IEEE Standard for Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 3 kHz to 300 GHz September 1991

Comments on the ANSI and IEEE Standard: EHT scientific advisor Lloyd Morgan took a look at the development of the standards and has detailed the key statements in the documents so that you can understand how the guidelines were improperly set. Please read it here.

Researcher, PhD Mikko Ahonen put together a slide presentation on the development of the international guidelines that informs our current FCC guidelines. Please take the time to view the slides below.

Presentation about RF guidelines and their history. By PhD Mikko Ahonen

Microwave Radiation, Guidelines and Debate during the Last 50 years. Presentation about FCC and ICNIRP guidelines. By PhD Mikko Ahonen

Letter to the FCC by Dr. De-Kun Li, MD, PhD, MPH on the Inadequacy of FCC guidelines

Evidence for Inadequacy of the Standards

This Chapter of the BioInitiative Report 2012 details the GAO Report, the WHO IARC Classification, President’s Cancer Panel Report of 2010, the U.S. Federal Radiofrequency Interagency Working Group Conclusions and more.

Why the FCC Must Strengthen Radiofrequency Radiation Limits in the U.S. by Joel M. Moskowitz, Ph.D., Director Center for Family and Community Health, The UC Berkeley Prevention Research Center, School of Public Health, University of California, Berkeley November 5, 2013

Read Critiques of ICNIRP (International Commission of Non-Ionizing Radiation Protection)

& WHO International EMF Project & the IEEE on Chronic Exposure

The Scientist Magazine: Opinion: Cell Phone Health Risk? Security concerns during the Cold War may have led to the generation of misinformation on the physiological effects of microwave radiation from mobile phones By Scientist and Researcher Allan H. Frey

RESOURCES ON INTERNATIONAL GUIDELINES

Powerwatch (2010) International Guidance Levels – A Comparison.

German Building biology guidance levels, for bedrooms less than 1 µW/m². Based on 10.000 home measurements.

ICNIRP – International Commission of Non-Ionizing Radiation Protection – Guidelines for Limiting Exposure to Time-Varying Electric, Magnetic, and Electromagnetic Fields (up to 300 GHz) 1998

DOCUMENTATION BY US AGENCIES

2014 Letter from the U.S. Department of Interior states, “The electromagnetic radiation standards used by the Federal Communications Commission (FCC) continue to be based on thermal heating, a criterion now nearly 30 years out of date and inapplicable today.” Read it here.

2002 Letter from Norbert Hankin of the EPA about the FCC guidelines states that children, pregnant women and the elderly were not considered in the regulations and that the regulations were to protect against hearing damage only and did not consider long-term chronic exposure. Read it here.

1999 Letter: The U.S. Radiofrequency Interagency Work Group Chief W. Gregory Lotz, Ph.D., at NIOSH (National Institute of Occupational Safety and Health) wrote a letter to Mr. Richard Tell, Chair of the IEEE SCC28 Risk Assessment Work Group, in which they identified 14 issues that “need to be addressed to provide a strong and credible rationale to support RF exposure guidelines.” Read it here.

2008 Report:  National Academy of Sciences Report “Identification of Research Needs Relating to Adverse Health Effects of Wireless Communication.”

Please watch this must watch documentary from 2010 that explores the development of the radiofrequency standards.
ADDITIONAL RESOURCES

EMF Portal: The EMF-Portal is an extensive literature database with an inventory of 22,066 publications and 5,327 summaries of individual scientific studies on the effects of electromagnetic fields. Here, scientific studies from journals with a so-called peer-reviewed process are collected, summarized and available free of charge to the user in both German and English.

The ICEMS’ Monograph, “Non-Thermal Effects and Mechanisms of Interaction Between Electromagnetic Fields and Living Matter”, edited by Livio Giuliani and Morando Soffritti for the European Journal of Oncology – Library Vol. 5 of the National Institute for the Study and Control of Cancer and Environmental Diseases “Bernardo Ramazzini”, Bologna, Italy, 2010, Part I and Part II.

Download the Summary (Adobe Acrobat PDF format)

Download Part I (Adobe Acrobat PDF format)

Download Part II (Adobe Acrobat PDF format)

FCC Radio Frequency Safety Webpage

OSHA Radiofrequency and Microwave Radiation Hazard Locations and Solutions

Occupational Safety and Health Administration (OSHA) page on RFR resources for hazard locations and solutions.

Recommended Practice for Measurement of Potentially Hazardous Electromagnetic Fields, RF and Microwave

Institute of Electrical and Electronics Engineers (IEEE) Standard, IEEE C95.3-2002.

Safety Levels with Respect to Human Exposure to Electromagnetic Fields 0-3 kHz

Institute of Electrical and Electronics Engineers (IEEE) Standard, IEEE C95.6, 2002.

Safety Levels with Respect to Human Exposure to Radiofrequency Electromagnetic Fields 3kHz to 3GHz

Institute of Electrical and Electronics Engineers (IEEE) Standard, IEEE Std.C95.1, 1999 Edition.

FCC 2008 Testimony on the Health Effects of Cell Phone Use

Expert testimony on the health effects of cell phones. Dr. Herberman, Ellie Marks, Dr. Hoover, Dr. Carpenter spoke about the exponential use of cellphones, the science on the connection between usage and human health effects, and studies looking fro links between usage and various forms of cancer.

C-SPAN VIDEOS OF CONGRESSIONAL HEARINGS

2001: GAO Report Cell Phones Press Conference

Senators Markey and Lieberman spoke to reporters about a Government Accounting Office study of the safety of cell phones and the potential impacts of increased exposure to radio frequency emissions. Because the report did not contain definitive conclusions, they called for greater consumer education and further study of the potential problems. Following their remarks they answered questions from reporters.

2008 Congressional Hearing: Health Effects of Cell Phone Use

Witnesses testified about research into cellular telephone use and its potential impact on human health, as well as the potential side effects and consequences of cell phone use. They focused on studies that had examined potential links between cell phones and cancer, and about warnings issued by some groups on cell phone safety. Recent epidemiological studies involving humans suggest that heavy cell phone users of 10 years or more have developed brain tumors on the same side of their heads as where they used to hold their mobile phones.

David Carpenter, Ronald B. Herberman M.D.,Robert Hoover, Darrell IssaJulius P. Knapp II,Ellie MarksDanny “Dan” Lee BurtonDennis KucinichDiane Watson

2009 Congressional Hearing on Cell Phone Radiation

Health Effects of Cell Phone Use Witnesses testified about research into cellular telephone use and its potential impact on human health, as well as the potential side effects and consequences of cell phone use. They focused on studies that had examined potential links between cell phones and cancer, and about warnings issued by some groups on cell phone safety.

John BucherDevra L. DavisLinda ErdreichThomas “Tom” HarkinDariusz LeszczynskiOlga NaidenkoMark PryorSiegal SadetzkiArlen Specter

2011: Communicators with Nora Volkow

Dr. Nora Volklow talked about tests conducted by National Institutes of Health (NIH) scientists and the Energy Department’s Brookhaven National Laboratory. The test results show that brain chemistry becomes altered after 50 minutes of cell phone usage. Also featuring Kenneth Foster and Devra Davis.

Book Discussion on Disconnect

Devra Davis presented her book Disconnect: The Truth About Cell Phone Radiation, What the Industry Has Done to Hide It, and How to Protect Your Family, published that day by Dutton. She argued that cell phone radiation damages the human body. She said that recently disclosed research shows that cell phones negatively affect human DNA and increase the user’s risk of developing memory loss, cancer, and various neurological diseases. Ms. Dutton talked about the industry practices that have hidden the dangers and her recommendations for cell phone use.

Book Discussion on Cell Phones: Invisible Hazards in the Wireless Age

Martin Schram and George Carlo talked about their book Cell Phones: Invisible Hazards In the Wireless Age about Carlos work heading up the WTO Cell Phone Research study that found problems “suppressed” by the Wireless Industry.

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