Resources for Policy Makers

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Welcome Elected Officials, Administrators and Policy Makers

Decision makers who give the issue of wireless its due diligence need access to the best available science and current policy developments. Below you will find Q & A plus documents and resources you need in order to be fully informed. Fully informed, you can protect public health while also meeting the community need for technology access.

Frequently Asked Questions
What is the stance of the federal government? (United States)

US federal regulations are decades out of date. RF/microwave (“Wireless”) Radiation was last reviewed by the US in 1996 and is substantially based on industry/military professional organization’s standard released in 1991.The Federal Communications Commission (FCC) regulations pertain to Maximum Permissible Exposure (MPE) limits.

What is the problem with these federal guidelines?

These outdated guidelines were set to apply to short-term thermal heating from RF/microwave Radiation. This means the limits are based on a fallacy that the only adverse biological effects from wireless radiation is due to over-heating of tissues.  This is false. There are hundreds to thousands of peer-reviewed science papers showing non-thermal adverse health effects in conditions with no measurable temperature change.

Furthermore, federal guidelines are based on research that does not consider the special vulnerabilities of various population cohorts such as children or pregnant mothers. According to the Environmental Protection Agency (EPA), “Federal health and safety agencies have not yet developed policies concerning possible risk from long-term, non thermal exposures.” This quote is from a letter by Robert Hankin of the EPA’s Radiation Protection Division. People are using devices differently than in 1991 and at that time the public was not exposed to today’s daily 24-hour long-term low-level exposures.

What is a safe level of Wireless Radiation?

Research has not yet identified a “safe level”of Wireless Radiation. The Food and Drug Administration (FDA) and EPA did not do pre-market safety testing nor did they perform research to determine a safe level of Wireless Radiation. Research shows that Wireless radiation at very low levels (thousands of times below presently legal federal safety limits) can result in neurological and reproductive damage.

What government reports have been issued?

The US government is supposedly in the midst of reevaluating their outdated RF/microwave Radiation exposure limits. However, so far, there there has been no response to these Government Reports from 2008 to 2012.

  • As a result, in 2012, the Government Accountability Office (GAO) published their report “Exposure and Testing Requirements for Mobile Phones Should Be Reassessed” that calls on the FCC to “formally reassess and, if appropriate, change its current RF energy (microwave) exposure limit and mobile phone testing requirements related to likely usage configurations, particularly when phones are held against the body.”
  • In response, in 2012, the FCC opened a proceeding to explore whether it should modify its radiofrequency exposure standards stating, “we specifically seek comment as to whether our current limits are appropriate as they relate to device use by children.” Over 900 submissions have been made to the FCC. To access these papers go to the FCC’s web site for Proceeding Number 13-84. To date no actions have been taken by the FCC or any other Federal agency.
Do all countries deal with this issue in the same way?

A recent review of international policy found over 20 countries have implemented a wide range of “precautionary” actions to reduce exposures to the public. Please see the 2015 publication International policy and advisory response regarding children’s exposure to radio frequency electromagnetic fields (RF-EMF). Please also see our policy document detailing international policy actions to reduce exposure to the public.

What role can policy makers play in the Wireless Radiation health issue?

Elected officials can champion and support legislation that will:

  1. Limit or ban the Marketing of RF/microwave Radiation Emitting Devices to Children: Children must be aware of Wireless Radiation health risks and how they can be avoided. France has handled this issue by mandating that advertisements never include children and clearly indicate the recommendation of hands-free kits to minimize brain exposures. Companies found in violation will be fined 75,000 Euros. Belgium has simply banned phones for children under 7 years old and enforces a total advertising ban on cell phones aimed at children younger than 14 years old. Turkey and Taiwan have also banned advertising with and for children.
  2. Inform people: Right To Know laws, such as the Berkeley Ordinance, inform people about the fine print instructions buried in their cell phones. The Maine Wireless Information Act  would have required information on radiofrequency exposure be visible on each cell phone’s product packaging. Canada’s BILL C-648 would require manufacturers of wireless devices to place health warning labels on their packaging. Please see the press conference on Bill C-648.
  3. Protect Children via Clear Limits on Public School Exposures: For example, France and Israel have banned Wi-Fi in school for young children and officially recommend wired (instead of Wi-Fi) internet connections in classrooms. In Belgium’s Ghent Municipality wireless is banned in preschools and daycares.
  4. Label Wireless Transmitters in Public Places: The New York USA Suffolk County Legislature passed legislation that requires all county buildings to post notices that display “Notice: Wireless technology in use.” In France, WiFi hotspots will be labeled. Labeling is a first step as the best step is to reduce wireless transmitters in public places so that such places are safely accessible.
  5. Resolve to Adopt Precautionary Frameworks For Prudent Decision Making: In Spain, the Parliament of Navarra voted to urge removal of WIFI in schools and to apply the precautionary principle in relation to exposure limits to electromagnetic fields. Similarly, Spain’s Vitoria City Council unanimously approved a precautionary approach with wireless.
  6. Initiate and Fund a Public Education Campaign to Protect Public Health: The State Parliament of South Tyrol voted to apply the precautionary principle, mandating the state government to start an education and awareness campaign that informs the public about possible health risks. Israel has created a public information website TNUNDA about electromagnetic fields (EMFs). France has started the process of gathering data to inform the public. The City of Greenbelt Maryland in the US hands out educational brochures on safer ways to use technology in community buildings, for example, at health fairs.
  7. Improve Transparency Around Public Radiation Exposures: France’s 2015 legislation now allows citizens to be informed of the Wireless Radiation measurements around their homes. A process is in place so that any member of the public can officially request this information and cell tower emission compliance will be verified. Cell Network antennae Maps will also be created for each town.
How can Congress provide better oversight to the FCC on current guidelines?

A response from the FCC is needed on the following:

The Status of the Review of RF Exposure Standards: The FCC put out a call for a “Review of RF Exposure Policies on March 29, 2013 (Proceeding 13-84).  Almost 2 years have passed.

  • What is the status of this Review? Will Mr Wheeler recuse himself from major decisions regarding mobile phones and wireless devices in light of his close association with the wireless industry?

Exposure limits do not protect children nor pregnant women: FCC exposure limits are based on an adult male. The FCC needs different exposure limits for those most vulnerable (babies, toddlers, and pre-teens).

On July 12, 2012 the American Academy of Pediatrics sent a letter to the FCC Chairman in favor of the RF Review stating, “ concerns have been raised that long-term RF exposure at this level affects the brain and other tissues and may be connected to types of brain cancer, including glioma and meningioma” . The AAP noted that the World Health Organization said “mobile-phone emissions are ‘possibly carcinogenic to humans… Children, however, are not little adults and are disproportionately impacted by all environmental exposures, including cell phone radiation…. In fact, according to IARC [International Agency for Research on Cancer], when used by children, the average RF energy deposition is two times higher in the brain and 10 times higher in the bone marrow of the skull, compared with mobile phone use by adults.”

  • Will the FCC consider children, the developing fetus  and other vulnerable populations when setting revised RF  standards?

The Testing and Certification of Cell Phones Needs to Be Updated: The FCC certification process to certify that consumers’ cellphone and other wireless transmitting devices (WTDs), do not exceed the maximum Specific Absorption Rate (SAR) of 1.6 Watts per kilogram of tissue (1.6 W/kg) has a ± 30% uncertainly value (i.e., for a SAR=1.6 W.kg is could be anywhere from SAR=1.21 W/kg {30% lower] to 2.08 W/kg). The FCC certifies any cellphone or other wireless transmitting device with a SAR value greater the 1.21 W/kg (70% of the exposure limit).  The FCC also has  declared that the ear is equivalent to an arm or a leg thereby substantially raising the exposure to the ear.

  • Why is such an excess over the exposure limit certified? Why did the FCC declare the ear equivalent to the arm  rather than having cellphone power reduced so that the ear’s exposure did not exceed the exposure limit?

Wireless in Schools poses a Serious Health Risk.  Schools are deploying wireless networks and using Wi-Fi to connect children’s tablets and laptops the Internet, thereby irradiating children for 6 plus hours a day with this possible human carcinogen.

  • Why doesn’t the FCC recommend that schools use cables to connect to the Internet?

Federal Safety Limits Need To Be Developed by the EPA. The FCC is not a scientific public health agency. No one is medically qualified to set true safety standards at FCC. FCC guidelines currently only protect against thermal effects despite thousands of studies show non-thermal or subthermal effects including Airforce’s and Navy’s own reports. FCC guidelines for RF radiation exposure being used as safety standards but they are not federally developed safety standards. We do not yet have the studies needed to determine a safe level.

  • When will the FCC send the RF Radiation reassessment  to the EPA so that federally developed safety standards can be set that adequately protect children and vulnerable populations from thermal and non-thermal effects.

The Public is Not Using Devices in the Manner They Are Tested: Smartphones today come with warnings about safe distances for use.  If you have an iPhone and go to settings/general/about/legal/rfexposure, you will find specific advice about the distance a phone should be kept from the body. Laptops are tested at 20 cm from the body.

  • Specifically what steps is the agency taking to ensure that devices such as laptops and tablets that are tested at a distance of 20 centimeters (about 8 inches) away from the body are in fact used on tables and not placed directly on laps?  And that Smartphones are not carried directly on the body per manufacturer’s advice?
Have federal agencies ever raised concerns about the US thermally based standards?

Yes, In fact several government letters document the recommendation that the EPA develop safety standards. Letters also detail how US health and safety authorities were concerned. Take some time to look at the letters below to understand the story.

Letters From US Agencies that Document Serious Concerns on Outdated RF Exposure Limits

1984: US Science Advisory Board Letter that recommends that the EPA develop radiation protection guidance to protect the public (Note: they were never issued.)

  • The Science Advisory Board wrote the administrator of the EPA Mr. William Ruckelshaus with this report on their review of the radiofrequency issue. April 25, 1984. It includes a 2/22/1983 letter from the FCC to the EPA which states that “the FCC lacks the necessary expertise and statutory authority to promulgate its own health and safety standards and therefore, must look to EPA and other responsible agencies for guidance in this area.” The FCC makes clear their support for the EPA’s guidance and encourages the EPA to “complete this process as expeditiously as possible.”
  • The National Telecommunications and Information Administration wrote the EPA on March 23, 1984 to  “express my concern that the functional and economic impact of such guidance on telecommunications …be carefully identified and evaluated prior to promulgation in order to avoid or minimize any unnecessary dislocation or disruption.”
  • Page 30 shows a chart which details how SARS at very low levels showed biological effects and notes the different exposure levels various federal agencies were considering.

1995 EPA Letter to the FCC on Development of Guidelines by the EPA.

  • In this letter to the FCC the EPA Director of Radiation and Indoor Air states the guidelines are almost complete and ready to go to review with completion date in 1996. (Note, these guidelines never saw the light of day because the EPA’s work on guidelines was defunded in 1996.
  • This shows how the EPA never set standards to protect the public based on their systematic review of the science.  The EPA draft guidelines referred to in this letter have not been made public despite public information requests.) Read a slide presentation by the EPA in 1995 Briefing the FCC   on the Development of RF Exposure Guidelines.

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

  • The members of the Radiofrequency Inter-Agency Work Group identity several critical  issues with the RF exposure guidelines. Their concerns include the need for a biological basis for SAR limit and they point out that the limits for brain and bone marrow should be lower than those from muscles and fat as tissues are not equally sensitive. They question the selection criteria for the adverse effect and state there is extensive data on acute effects but that the lower-level non-thermal chronic exposure effects may be very different and chronic effects need to be accounted for.  They state the uncertainties in the data should be addressed.  “These studies have resulted in concern that exposure guidelines based on thermal effects, and using information and concepts (time-averaged dosimetry, uncertainty factors) that mask any differences between intensity-modulated RF radiation exposure and CW exposure, do not directly address public exposures, and therefore may not adequately protect the public.”

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

  • In this letter the EPA’s Norbert Hankin writes C.K. Chou about the concerns the Interagency Workgroup expressed in the 1999 letter (as it had not been responded to) and adding additional issues. They question why the Penna is treated as an extremity and ask for an explanation on how the guidelines account for the sensitivity of different tissues to temperature. Hankin asked that the interagency workgroup be provided with a copy of the response to these issues. We are not aware that these concerns with the RF limits were ever responded to with documentation.

2014: US Department of the Interior Letter (2014) on FCC Guidelines

  • This letter details  research showing harm to birds at very very low levels of radio frequency radiation and concludes, 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.”

Additional documents from the EPA of note:

1993: EPA: Summary and Results of the April 26-27 1993 Radiofrequency Radiation Conference Vol.2 Papers

1992: EPA: EMF in Your Environment: Magnetic Field Measurements of Everyday Electrical Devices

1991: EPA:” Electric and Magnetic Fields: An EPA Perspective on Research Needs and Priorities for Improving Health Risk Assessment

1983: EPA: Biological Effects Of RadioFrequency Radiation

1981: EPA: Index of Publications on Biological Effects of Electromagnetic Radiation (0-100 GHz)


BRIEFINGS AND FACT SHEETS

The Cell Phone Fine Print Ordinance Briefing

The Fine Print Instructions Factsheet

International Policy Actions on Wireless Exposures

United States Policy Briefing

Schools and Safe Technology Briefing

Alster, Norm. Captured agency: How the Federal Communications Commission is dominated by the industries it presumably regulates. Cambridge, MA:  Edmund J. Safra Center for Ethics, Harvard University.  2015.

Comments Submitted to the FCC on Proposed RF-Radiation Standards and Testing by the Environmental Health Trust

SOLUTIONS

An Example of A School’s Safe Technology Policy: The Upper Sturt School

The Collaborative for High Performing Schools (CHPS) Low EMF Best Practices

LETTERS

2015 Letter to Arne Duncan on Safe Technology in School

2015 Letter to Massachusetts Lawmakers Concerning Bills on Electromagnetic Radiation

2013 Letter to San Francisco Supervisors “Strengthened Scientific Circumstances further increase necessity for the City’s Right-To-Know Ordinance and Justify a Major Public Health Education Campaign on Cell Phone Safety”

VIDEOS

2013 An Expert Panel on Cell Phone Radiation:The Commonwealth Club of California in San Francisco

PUBLISHED MAGAZINE ARTICLES OF NOTE

LEGAL BUT LETHAL: Read Dr. Davis’s article in San Francisco Medicine: “Flying Blind: The Public Health Impacts of Wireless Radiation”

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

Consumer Reports November Issue: Does Cell-Phone Radiation Cause Cancer?

Letters From US Agencies that Document Serious Concerns on Outdated RF Exposure Limits

2014: US Department of the Interior Letter (2014) on FCC Guidelines

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

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

1995 EPA Letter to the FCC on Development of Guidelines by the EPA.

Read a slide presentation by the EPA in 1995 Briefing the FCC   on the Development of RF Exposure Guidelines.

1993: EPA: Summary and Results of the April 26-27 1993 Radiofrequency Radiation Conference Vol.2 Papers

1992: EPA: EMF in Your Environment: Magnetic Field Measurements of Everyday Electrical Devices

1991: EPA:” Electric and Magnetic Fields: An EPA Perspective on Research Needs and Priorities for Improving Health Risk Assessment

1984: US Science Advisory Board Letter that recommends that the EPA develop radiation protection guidance to protect the public (Note: they were never issued.)

1983: EPA: Biological Effects Of RadioFrequency Radiation

1981: EPA: Index of Publications on Biological Effects of Electromagnetic Radiation (0-100 GHz)

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