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The Regulation of Wireless Radiation in the United States: Exemplar of a Regulatory Gap

Oct 28, 2023

The Regulation of Wireless Radiation in the United States: Exemplar of a Regulatory Gap 

Theodora Scarato MSW Executive Director of Environmental Health Trust

American Public Health Association Annual Conference

Law Section Poster Presentation 

See also The Case for Mitigating Wireless Radiation in the School Setting as Primary Prevention  to support children’s physical and mental health by Theodora Scarato MSW Executive Director of Environmental Health Trust here 

Link to American Public Health Association Conference webpage on the presentation. 

November 14, 2023

Theodora Scarato, Executive Director of Environmental Health Trust presented on how regulation of wireless radiation exemplifies the concept of a regulatory gap. This webpage documents the research related to the poster presentation and has scientific citations and sources.

LINK to Full Poster Image

Outdated Regulations: 1996 Limits for Wireless Radiation

U.S. limits for human exposure to wireless radio-frequency (RF) radiation have remained unchanged and unreviewed since 1996. Sources of exposure include cell phones, cell towers, Wi-Fi, Bluetooth, 4G and 5G networks.

The 1996 limits promulgated by the Federal Communication (FCC) were designed only to protect against effects from short term high powered exposures, not long term chronic exposures. The basis for the U.S. FCC limits are studies from the 70s & 80s of rats and a few small monkeys. Level of “adverse effect” was identified as the temperature at which the starved animals stopped pressing a food lever. These antiquated studies exposed animals for under 60 minutes. (1)

The EPA has repeatedly confirmed the fact that wireless radiation limits do not address long term exposure:

“The exposure guidelines did not consider information that addresses nonthermal, prolonged exposures, i.e., from research showing effects with implications for possible adversity in situations involving chronic/prolonged, low-level (nonthermal) exposures.”

–2002 Letter from Norbert Hankin of the EPA Office of Radiation and Air to Janet Newton EMF Network

Wireless radiation limits also do not address children’s unique vulnerability nor impacts to wildlife, trees and plants.(2)

A Lack of Prevention: FCC Ignores Long Term Impacts

Children absorb higher levels of wireless radiation deeper into their brain compared to adults because they have thinner skulls, smaller heads and a higher water content in their brains.(3)

Research (4) has found:

  • 10-fold greater in the pediatric cerebellum and bone marrow of the skull

  • 30-fold greater in the hippocampus

  • 2- to almost 5-fold in eye

Furthermore, children’s rapidly developing brains are uniquely sensitive due to their rapidly developing brains and systems.(5)  Analysis of the National Toxicology program animal studies indicates a health based exposure limit for RF levels is recommended at least 200 to 400 times more protective than current FCC limits.(6)

Research on laptop radiation also shows higher exposure into a child’s brain compared to an adult.(7)

Numerous medical organizations and experts (8) are calling to reduce public exposures due to the growing body of scientific evidence links long term exposure to non-ionizing wireless radiation to a broad range of harmful effects at at legally allowed levels including cancer, memory damage and  impacts on brain development, the endocrine system, thyroid function, reproduction, and DNA/genetic damage. (9)

Timetable

A timetable of the history of laws and regulation in the United States including the absence and inadequate activities of various federal agencies reveal a series of regulatory deficiencies.

Note:  This is a brief summary timetable as there are numerous additional events omitted for brevity.

Post WWII

The 70s and 80s 

1995

  • EPA meets with FCC & presents EPA’s plan to develop RF safety limits

1996

1999

  • FDA requests the National Toxicology Program to study cell phone radiation because of the lack of safety data on health effects from long term chronic exposure.

2008

2009

2011

  • Radiofrequency electromagnetic fields (RF-EMF) were classified as a Group 2B possible carcinogen by the World Health Organization’s International Agency for Research on Cancer (WHO/IARC). The WHO/IARC scientists clarified that their determination was for RF-EMF from any source be it cell phones, wireless devices, cell towers or any other type of wireless equipment

2012

2013

2014

2018

  • National Toxicology Program (NTP) releases Final Reports on large scale animal studies of chronic exposure to cell phone radiation and concludes “clear evidence” of cancer.

  • The FDA rejects the NTP findings.

  • Ramazzini Institute of Italy publishes new findings from their large scale rat study with RF exposures set to mimic base station (ambient cell tower) exposures.of increased tumors (same heart sheath tumors as elevated in NTP).

2019

  • The WHO/IARC advisory committee recommended that radiofrequency radiation be re-evaluated as a “high” priority in light of the new research.

  • The FCC decides not to update its 1996 RF limits (See FCC 19-126 )

2021

  • European Parliament requested a research report “Health Impact of 5G” which was released in July 2021 and concluded that commonly used RFR frequencies (450 to 6000 MHz) are probably carcinogenic for humans and clearly affect male fertility with possible adverse effects on the development of embryos, fetuses and newborns.

  • U.S. Court of Appeals, D.C. Circuit Court Ruling  in EHT et al. v. the FCC. The FCC’s decision not to update 1996 wireless limits was deemed “arbitrary and capricious.” The Court ordered FCC to provide evidence of properly examining:

    • Impacts from long-term exposure

    • Children’s vulnerability

    • Environmental effects

    • Radiation test procedures

    • Technological developments since 1996

2023

  • No response from the FCC regarding the issues the court mandated them to address.

LINK to Full Poster Image

A Lack of Federal Accountability

Environmental wireless exposures from cell towers and base stations are largely unregulated in the United States as there is no agency with health expertise evaluating the exposure for health impacts. There are no funded activities by the EPA, FDA or CDC related to cell tower radiation. There is no scientific group of governmental experts reviewing the up to date science to ensure public health or environmental (i.e wildlife and trees) protection from rising ambient levels.

EPA

The EPA used to have a team of about 30 people working on EMF bioeffects.  They also coordinated with the FCC on an EMF monitoring program. Now they have no activities.

More recently, the EPA confirmed they have no funded mandate nor dedicated staff to maintain expertise in the area of non ionizing EMF. (10) Furthermore, they also stated they are not aware of any developed safety limits or research reviews related to impacts of wireless on birds, bees, wildlife and the natural environment.

The Food And Drug Administration 

The FDA has engaged in limited activities related to cell phones and cancer. In 2020, the FDA released a now outdated literature review (ending in 2018) focused solely only on cell phones and cancer. Impacts to memory, the brain and reproduction were omitted.

A January 11, 2022 letter by Ellen Flannery of the Director of the FDA Office of Policy Center for Devices and Radiological Health confirms the absence of FDA authority and research in the area. When asked about 5G “small” cell tower safety by a California mother who had a wireless facility in front of her home, FDA’s Flannery responded,  “The FDA does not regulate cell towers or cell tower radiation.  Therefore, the FDA has no studies or information on cell towers to provide in response to your questions.” Link to FDA’s Ellen Flannery Letter. 

A June 20, 2016 email by FDA’s David Kassiday also confirms that the FDA does not address the environmental, ambient exposures from cell phone towers. Kassiday stated, “We don’t have jurisdiction over cellphone towers since those are environmental emitters.”

A Pittsburgh Law Review article on the FDA and its role in ensuring public safety in regards to wireless radiation entitled, The FCC Keeps Letting Me Be: Why Radiofrequency Radiation Standards Have Failed to Keep Up With Technology concludes, “The FCC and FDA have failed in their obligation to prescribe safe RFR guidelines produced from wireless communication devices to protect the public health and safety.”

National Institute for Occupational Safety and Health 

OSHA has never developed occupational EMF exposure limits and currently has no funded activities nor staff with bioeffects expertise. Before it’s EMF activities ceased, NIOSH experts recommended precautionary measures to reduce exposure and  also had proposed a comprehensive RF protection program, including workplace RF exposure surveillance as well as medical monitoring. (See 1999 OSHA’s proposed a comprehensive RF Protection Program.) None of these programs were finalized.

“ it would be judicious to keep exposure levels as low as reasonably possible until the safety of microwave exposures can be determined. Recommendations for lowering exposure…”

-1992 NIOSH Report: HEALTH HAZARD EVALUATION REPORT HETA 92-0224-2379 The Hazard Evaluations and Technical Assistance Branch of NIOSH CDC

The Centers for Disease Control and Prevention

There are no scientific reports by the CDC on wireless safety, nor does the agency have staff with expertise monitoring the science and evaluating risk.  EHT’s FOIA investigations have found an industry consultant was brought in to help draft several CDC webpages.

National Cancer Institute 

Although the NCI has a lengthy web page on cell phones, the NCI has repeatedly stated that “Neither the literature reviews, nor the fact sheets, make safety determinations.” (Letter from NCI to Scarato).

When directly asked about its opinion on cell phone safety issues,  the National Cancer Institute responded, “As a Federal research agency, the NCI is not involved in the regulation of radiofrequency telecommunications infrastructure and devices, nor do we make recommendations for policies related to this technology…Our sister agencies, the FDA as well as the FCC, retain responsibility for reviewing guidance on safety concerns and informing the public if those circumstances change.”

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International Policy

In France cell phone and wireless device consumer information states  “Keep radio equipment away from the belly of pregnant women, and away from the lower abdomen of adolescents.”

2015 National Legislation entitled “Law on sobriety, transparency, information and consultation for exposure to electromagnetic waves.”  Original Report

  • WiFi Banned in Nursery Schools,

  • WiFi on “OFF” as Default to Minimize Exposures in Schools

  • Cell Tower Emission Compliance Verified

  • Citizens Will Have Access Cell Tower Radiation Measurements

  • Cell Antennae Maps For the Country

  • Continued Evaluation of Health Effects

  • SAR Radiation Labeling for Phones Mandated

  • Information on Reducing Exposures Mandatory- on cell phone package. .

  • WIFI Hotspots will be Labeled

  • Advertisements Must Recommend Devices to Reduce Radiation Exposure to the Brain

  • Advertising for cell phone not accompanied by such a kit is forbidden. Companies in violation will be fined 75,000 Euros.

  • Children Must Be Provided Protections: At the request of the buyer, equipment reducing cell phone radiation exposures to the head for children less than 14 years should be provided.

  • New public information campaign on reducing exposure.

Worldwide, over 20 countries clearly recommend that children reduce cell phone radiation exposure and several have banned the sale and advertising of cell phones to young children.

Numerous countries also label cell phones for radiation at point of sale and have robust radiation post market compliance programs.

The Parliamentary Assembly of the Council of Europe, Austrian, Vienna, Cyprus and Athens Medical Associations, the International Doctors for the Environment and hundreds of scientists all recommend reducing child’s exposure to wireless radiation.

In 2011 the Parliamentary Assembly of the Council of Europe Resolution 1815: “The Potential Dangers of Electromagnetic Fields and Their Effect on the Environment” which is a call to European governments to “take all reasonable measures” to reduce exposure to electromagnetic fields “particularly the exposure to children and young people who seem to be most at risk from head tumours.”  The Resolution calls for member states to:

  • Implement “information campaigns about the risk of biological effects on the environment and human health, especially targeting children and young people of reproductive age. “

  • “Reconsider the scientific basis for the present standards on exposure to electromagnetic fields set by the International Commission on Non-Ionising Radiation Protection, which have serious limitations, and apply ALARA principles, covering both thermal effects and the athermic or biological effects of electromagnetic emissions or radiation.”

  • “For children in general, and particularly in schools and classrooms, give preference to wired Internet connections, and strictly regulate the use of mobile phones by school children on school premises.”

The U.S. Public Is Not Informed: Industry Lawsuits Halt Awareness

Unlike the U.S., numerous countries have multimedia public health campaigns to educate the public on why and how to reduce wireless radiation exposure.

San Francisco became the first city in the country to pass and adopt cell phone safety legislation in 2011. The ordinance required cell phone retailers to provide their customers with information detailing that if a user holds a phone too close to their body, a phone may exceed the radiofrequency energy exposure limitation set by the Federal Communications Commission. However, implementation of the ordinance was blocked in 2012 after a three year court battle. 

Cell phone retailers were to provide information that provides measures customers can take to reduce their exposure to radiofrequency energy from cell phones. The original ordinance required that this information be provided via a store poster, warning statements included in sample phone displays, and in a factsheet to be given out with each phone sold and upon customer request.

Berkeley followed and was the first city in the nation to implement an ordinance that requires cell phone retailers to provide those who purchase a new phone an informational fact sheet  stating:

“The City of Berkeley requires that you be provided the following notice: To assure safety, the Federal Government requires that cell phones meet radio frequency (RF) exposure guidelines. If you carry or use your phone in pants or shirt pocket or tucked into a bra when the phone is ON and connected to a wireless network, you may exceed the federal guidelines for exposure to RF radiation. Refer to the instructions in your phone or user manual for information about how to use your phone safely.”

However after a years long court battle with the wireless industry, implementation was halted.

In both of these cases, the wireless industry sued the Cities stating such ordinances violated their rights to speech (that they should not be forced to say things.)

Examples of Awareness Campaigns

Cyprus

In 2017 the Minister of Culture and Education issued a directive to ban Wi-Fi from kindergartens, remove Wi-Fi from elementary classrooms.  The Cyprus National Committee on Environment and Child Health along with the Ministry of Health launched a public information campaign in 2019 that ran large scale ads on the backs of buses and featured 5 ways to reduce cell phone and Wi-Fi exposure.  The Committee has long issued a brochure how to reduce EMF for families and has PSA videos for parents, pregnant women and teens. In 2017 the Cyprus Medical Association  issued Sixteen recommendations to reduce cell phone radiation exposure.

Croatia 

The Ministry of Health maintains a dedicated web page,  a video and brochures on  Non-ionizing electromagnetic radiation:The most common questions and answers,  EMF Protection Principles and  Non-ionizing electromagnetic radiation are part of their public information campaign. Croatia has “sensitive areas” with lower cell tower radiation levels  for buildings, schools, maternity hospitals and hospitals. The owner of the electromagnetic field source is obliged to provide a new measurement of the electromagnetic field levels every three years and submit the results to the Ministry of Health.

French Polynesia

“The use of mobile phones by children is not recommended before the age of 15: their brains have not matured and are more sensitive to electromagnetic waves. Parents are advised to advise their children or adolescents to use their phone only for essential calls.”

In 2016 French Polynesia passed landmark legislation to create a public educational campaign on how to reduce cell phone, wireless and other electromagnetic radiation.  The law prohibits advertising of cell phones to children under 14, prohibits advertising cell phones without showing how to minimize radiation exposure to the head, prohibits wireless in nursery schools, restricts wireless in primary schools and reduces exposures to workers. The government is implementing measurement and monitoring of levels of public exposure to electromagnetic fields throughout the country. The multimedia campaign of the French Polynesia Directorate-General for the Digital Economy (DGEN) includes a video, posters and a brochure promoted on television, radio, and social networking platforms translated into Tahitian and French. The  video  visually depicts how common household electronics – such as a Wi-Fi router, video game console, and wireless baby monitor – emit microwave electromagnetic radiation like cell phone emissions. The campaign also addresses the electromagnetic radiation from electricity-powered alarm clocks and appliances.

Belgium

Experts – including those on the Superior Health Council – advise everyone to limit their exposure to mobile phone radiation.” – Health Food Environment Agency of Belgium

The Belgium health agency has long issued issued Tips for prudent use and in 2013 the government has banned phones designed for young children. In 2014 Ghent Belgium banned wi-fi from pre-schools and day care.

 

A Regulatory Gap

The issue exemplifies the concept of a regulatory gap. Current regulations are inadequate to protect health as regulatory activities are non-existent for environmental monitoring, premarket safety testing, postmarket health/environmental  surveillance, scientific hazard and risk assessment, compliance oversight and interagency coordination.

Laws need to be updated with a comprehensive research review as emerging science indicates adverse health effects at legally allowed levels of exposure.  Even with a 2021 US Court Appeals DC Circuit ruling that found the FCC had failed to properly review human exposure limits, no federal agency has begun funded activities to address the issues identified by the court.

The United States is lagging behind compared to numerous countries with a variety of policies, laws and regulations related to public health/prevention, research, monitoring, transparency, oversight and compliance.

In the US, the American Academy of Pediatrics, California Department of Health as well as

California Department of Health, Maryland State Children’s Environmental Health and Protection Advisory Council, New Jersey Education Association, New Hampshire State 5G Commission and Santa Clara Medical Association have released advisories to reduce wireless radiation.

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Recommendations to Address the Regulatory Gaps and Deficiencies 

Bio-effects research

  • US agencies with health and environmental expertise need to be funded for non ionizing EMF bioeffect activities. The EPA plus various agencies- such as Health Assessment and Translation (HAT) group (formerly Office of Health Assessment and Translation (OHAT))  should conduct a  technical state of the science assessment focused on understanding the potential for adverse effects of RF on human health and Fish and Wildlife can provide expertise regarding wildlife impacts.

Evidence-based up to date regulations need to be developed and continuously reviewed

  • Federally developed RF safety standards should  address

    • biological impacts from non thermal (non heating) exposures

    • Impacts from chronic long term exposures

    • Sensitive populations-  children, pregnant people, elderly and medically vulnerable

    • flora and fauna-  with an ecosystem approach

  • Ongoing research review with periodic updates to ensure regulations and limits are up to date.

  • New technologies and frequencies need to be tested for biological impacts before deployment to ensure regulations are appropriate and potentially develop new safety standards (i.e higher frequencies)

Update RF compliance tests for devices and towers/networks

  • Tests should  mimic real world use positions of devices in direct contact and include age specific tissue specific models- pregnancy/child models

  • Re-evaluate the heat based SAR metric for RF compliance and research alternative methods to assess/measure exposures

  • Standardization for RF compliance evaluations is needed.

Risk mitigation policies

  • Public health agencies develop a robust set of recommendations for the public regarding phones, laptops, ipads, Wi-Fi devices and smart things etc.

  • Evaluate and implement risk mitigation policies and regulations  to reduce RF exposure during pregnancy,  childhood, elderly, medically vulnerable.

Worker protections

  • Occupational exposures- worker safety issues- NIOSH and Dept of Labor need to launch a full scope of activities (monitoring, measuring, mitigating, education) to protect workers as numerous occupations now involve a multitude of exposures and they have zero activities at this time.

Nationwide EMF Monitoring

  • Launch a nationwide RF monitoring system inside and outside buildings (focused on sensitive areas such as schools, daycares, parks)

  • Registry for all wireless facilities – cell towers 4G/5G and base station antennas

 

Post Market Surveillance

  • Reporting system for reporting health and environmental  impacts

  • Robust post market surveillance for RF compliance of phones, devices and consumer equipment-  taking devices off shelves and testing

Compliance and enforcement

  • Program that provides robust oversight of RF compliance program for towers, base stations, cell phones and devices (reviews RF reports, complaints) with full transparency on complaints, investigations and actions

  • Dedicated staff to ensure enforcement of regulations, fines etc

Transparency

  • Labeling:  Consumer information on cell phone and wireless devices so that consumers know devices emit RF and how to reduce exposure.

  • Registry of wireless sites,  RF level reports, EMF monitoring data should be online in easily accessible maps.

  • Enforcement actions, fines should be publicly posted

 

Environmental Protections

  • Ensure enforcement of all environmental laws such as the National Environmental Policy Act and Endangered Species Act.

  • Develop exposure limits specifically for wildlife and critical habitat (trees, plants and air) that protects against adverse effects of long-term chronic low-level EMF exposures.

  • Utilize an ecosystem approach to regulation and policy that considers the interdependent, interconnected relationships of microbiota, plants, and animals.

  • Ensure federal agencies with environmental expertise are engaged in research activities including field studies on bioeffects to wildlife, especially related to effects on endangered species and pollinators.

  • Mitigate exposures as much as possible especially in ecologically sensitive areas.

  • Ensure adequate oversight and enforcement for the RF emissions of wireless networks.

  • Conduct full environmental reviews prior to the licensing and national buildout of major new technologies like 5G, 6G and beyond.

  • Measure, monitor and map EMF levels across the country, especially in ecologically sensitive areas.

  • Implement an environmental surveillance and reporting mechanism for impacts to flora and fauna after telecommunications and wireless technology network installations.

  • Update measurement protocols and exposure parameters to consider the local ecosystem and wildlife behavior and habitat, i.e birds nesting on towers/power lines and tree limbs in close proximity to RF main beams. Currently compliance tests only consider where humans exist.

 

Scientific References  

EMF Medical Conference 2021 Program Videos

LINK to Full Poster Image

1). International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF), (2022). Scientific evidence invalidates health assumptions underlying the FCC and ICNIRP exposure limit determinations for radiofrequency radiation: implications for 5G. Environ Health. Oct 18;21(1):92.

2). Levitt, B. B., Lai, H. C., & Manville, A. M. (2021). Effects of non-ionizing electromagnetic fields on flora and fauna, Part 3. Exposure standards, public policy, laws, and future directions. Reviews on Environmental Health.

Hardell, L., & Sage, C. (2008). Biological effects from electromagnetic field exposure and public exposure standards. Biomedicine & Pharmacotherapy = Biomedecine & Pharmacotherapie, 62(2), 104–109. 

3). A. Christ, M.-C. Gosselin, M. Christopoulou, S. Kühn, N. Kuster, 2010 “Age-dependent tissue-specific exposure of cell phone users”, Physics Medicine Biology 55, pp.1767–1783

Fernández-Rodríguez, C. E., De Salles, A. A. A., & Davis, D. L. (2015). Dosimetric Simulations of Brain Absorption of Mobile Phone Radiation–The Relationship Between psSAR and Age. IEEE Access, 3, 2425–2430. 

Ferreira, J., & Almeida de Salles, A. (2015). Specific Absorption Rate (SAR) in the head of Tablet users. The 7Th IEEE Latin-American Conference On Communications (Latincom 2015), 1538, 5-9. Retrieved 3 June 2020.

Gandhi, O. P. (2015). Yes the Children Are More Exposed to Radiofrequency Energy From Mobile Telephones Than Adults. IEEE Access, 3, 985–988. 

Gandhi, O. P., Morgan, L. L., de Salles, A. A., Han, Y.-Y., Herberman, R. B., & Davis, D. L. (2012). Exposure Limits: The underestimation of absorbed cell phone radiation, especially in children. Electromagnetic Biology and Medicine, 31(1), 34–51. 

Mohammed, B., Jin, J., Abbosh, A. M., Bialkowski, K. S., Manoufali, M., & Crozier, S. (2017). Evaluation of Children’s Exposure to Electromagnetic Fields of Mobile Phones Using Age-Specific Head Models With Age-Dependent Dielectric Properties. IEEE Access, 5, 27345–27353.

 

4). Fernández, C., de Salles, A. A., Sears, M. E., Morris, R. D., & Davis, D. L. (2018). Absorption of wireless radiation in the child versus adult brain and eye from cell phone conversation or virtual reality. Environmental Research, 167, 694–699.

5). Davis, D., Birnbaum, L., Ben-Ishai, P., Taylor, H., Sears, M., Butler, T., & Scarato, T. (2023). Wireless technologies, non-ionizing electromagnetic fields and children: Identifying and reducing health risks. Current Problems in Pediatric and Adolescent Health Care, 53(2), 101374.

Miller, A. B., Sears, M. E., Morgan, L. L., Davis, D. L., Hardell, L., Oremus, M., & Soskolne, C. L. (2019). Risks to Health and Well-Being From Radio-Frequency Radiation Emitted by Cell Phones and Other Wireless Devices. Frontiers in Public Health, 7. 

Moon, J.-H. (2020). Health effects of electromagnetic fields on children. Clinical and Experimental Pediatrics, 63(11), 422–428. 

Redmayne, M., & Johansson, O. (2015). Radiofrequency exposure in young and old: Different sensitivities in light of age-relevant natural differences. Reviews on Environmental Health, 30(4), 323–335. 

Sage, C., & Burgio, E. (2018). Electromagnetic Fields, Pulsed Radiofrequency Radiation, and Epigenetics: How Wireless Technologies May Affect Childhood Development. Child Development, 89(1), 129–136. 

6). Uche, U. I., & Naidenko, O. V. (2021). Development of health-based exposure limits for radiofrequency radiation from wireless devices using a benchmark dose approach. Environmental Health, 20(1), 84. 

7). Ferreira, J., & Almeida de Salles, A. (2015). Specific Absorption Rate (SAR) in the head of Tablet users. The 7Th IEEE Latin-American Conference On Communications (Latincom 2015), 1538, 5-9. Retrieved 3 June 2020.

Ferreira, Juliana Borges, and Álvaro Augusto Almeida de Salles. “Specific Absorption Rate (SAR) in the head of Tablet users.” Skin38 (2015): 1-464.

Siervo, B., Morelli, M. S., Landini, L., & Hartwig, V. (2018). Numerical evaluation of human exposure to WiMax patch antenna in tablet or laptop. Bioelectromagnetics, 39(5), 414–422.

2020 Consensus Statement of UK and International Medical and Scientific Experts 3500 Medical Doctors

8). Lai, H., & Levitt, B. B. (2022). The roles of intensity, exposure duration, and modulation on the biological effects of radiofrequency radiation and exposure guidelines. Electromagnetic Biology and Medicine, 41(2), 230–255. 

Lin, J. C. (2023). Incongruities in recently revised radiofrequency exposure guidelines and standards. Environmental Research, 222, 115369.

Lopez I, Rivera M, Feliz N,  Maestu C. (2022) It is mandatory to review environmental radiofrequency electromagnetic field measurement protocols and exposure regulations: An opinion article. Front. Public Health, 24 October

Hardell, L., & Nyberg, R. (2020). Appeals that matter or not on a moratorium on the deployment of the fifth generation, 5G, for microwave radiation. Molecular and Clinical Oncology, 12(3), 247–257. 

Miller, A. B., Morgan, L. L., Udasin, I., & Davis, D. L. (2018). Cancer epidemiology update, following the 2011 IARC evaluation of radiofrequency electromagnetic fields (Monograph 102). Environmental Research, 167, 673–683. 

9). Bandara, P., & Carpenter, D. O. (2018). Planetary electromagnetic pollution: It is time to assess its impact. The Lancet Planetary Health, 2(12), e512–e514.

Belpomme, D., Hardell, L., Belyaev, I., Burgio, E., & Carpenter, D. O. (2018). Thermal and non-thermal health effects of low intensity non-ionizing radiation: An international perspective. Environmental Pollution, 242, 643–658.

Carpenter DO. (2013) Human disease resulting from exposure to electromagnetic fields. Rev Environ Health.;28(4):159-72.

Davis, D., Sears, M. E., Miller, A. B., & Bray, R. (2017). Microwave/Radiofrequency Radiation and Human Health: Clinical Management in the Digital Age. In A. Cohen, F. S. vom Saal, & A. Weil (Eds.), Integrative Environmental Medicine (p. 0). Oxford University Press. 

Davis, D., Birnbaum, L., Ben-Ishai, P., Taylor, H., Sears, M., Butler, T., & Scarato, T. (2023). Wireless technologies, non-ionizing electromagnetic fields and children: Identifying and reducing health risks. Current Problems in Pediatric and Adolescent Health Care, 53(2), 101374.

Directorate-General for Parliamentary Research Services (European Parliament), & Belpoggi, F. (2021). Health impact of 5G: Current state of knowledge of 5G related carcinogenic and reproductive/developmental hazards as they emerge from epidemiological studies and in vivo experimental studies. Publications Office of the European Union.

Alliance of Nurses for Healthy Environments. (n.d.). E-Textbook – Environmental Health in Nursing

10. Letter from Lee Ann Veal  EPA office of Radiation and Air to Theodora Scarato Environmental Health Trust  March 7, 2023

Letter from Lee Ann Veal  EPA office of Radiation and Air to Theodora Scarato Environmental Health Trust , July 8, 2020

References on the regulatory gap of wireless and wildlife. 

Amicus of NRDC: Natural Resources Defense Council  on Wireless Radiation and the Environment

Balmori, A. (2015). Anthropogenic radiofrequency electromagnetic fields as an emerging threat to wildlife orientation. Science of The Total Environment, 518–519, 58–60.  

Balmori A. (2014). Electrosmog and species conservation. Science of The Total Environment,  496:314-316 

Balmori A. Radiotelemetry and wildlife: Highlighting a gap in the knowledge on radiofrequency radiation effects. Sci Total Environ. 2016 Feb 1;543 

Balmori A. Electromagnetic pollution from phone masts. Effects on wildlife. Pathophysiology. 2009 Aug;16(2-3):191-9 

Balmori, A. The incidence of electromagnetic pollution on wild mammals: A new “poison” with a slow effect on nature?. Environmentalist 30, 90–97 (2010).  

Cucurachi, S., Tamis, W. L. M., Vijver, M. G., Peijnenburg, W. J. G. M., Bolte, J. F. B., & de Snoo, G. R. (2013). A review of the ecological effects of radiofrequency electromagnetic fields (RF-EMF). Environment International, 51, 116–140.  

Levitt BB, Lai HC and Manville AM II (2022) Low-level EMF effects on wildlife and plants: What research tells us about an ecosystem approach. Front. Public Health 10:1000840. doi: 10.3389/fpubh.2022.1000840

Levitt, B. B., Lai, H. C., & Manville, A. M. (2022a). Effects of non-ionizing electromagnetic fields on flora and fauna, part 1. Rising ambient EMF levels in the environment. Reviews on Environmental Health, 37(1), 81–122. 

Levitt, B. B., Lai, H. C., & Manville, A. M. (2022b). Effects of non-ionizing electromagnetic fields on flora and fauna, Part 2 impacts: How species interact with natural and man-made EMF. Reviews on Environmental Health, 37(3), 327–406.  

Levitt, B. B., Lai, H. C., & Manville, A. M. (2021). Effects of non-ionizing electromagnetic fields on flora and fauna, Part 3. Exposure standards, public policy, laws, and future directions. Reviews on Environmental Health.  

Sivani, S, and D. Sudarsanam. (2012): “Impacts of radio-frequency electromagnetic field (RF-EMF) from cell phone towers and wireless devices on biosystem and ecosystem-a review.” Biology and Medicine 4, no. 4 202-216.

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