Outdated FCC “Safety” Standards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?
Why didn’t the United States EPA ever develop safety limits for this radiation?
Is the government aware of the problems with the FCC guidelines?
Will the guidelines ever be assessed, considering they may not protect the public?
Are agencies calling on the government to update these FCC limits?
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?
Are the RF limits in all countries thermal like the US? If not, why not?
I keep reading that FCC’s limits for RF radiation are “thermal” limits. What does this mean?
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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