Experts Call on FCC to Develop Protective Safety Limits for Wireless and 5G

American and European Experts Call on FCC to Develop Protective Safety Limits for Wireless and 5G

(Washington, DC)  

Environmental Health Trust and professors from Portugal, Israel, and Ireland submitted their science based opposition to the FCC’s proposed rules on 5G frequencies. They are calling on the Federal Communications Commission (FCC) to overhaul their antiquated approach to testing cellphones and other wireless devices to reflect the scientific evidence.  Over 1700 submissions were filed with the FCC last month regarding  the FCC’s new proposal to extend the limits for human exposure to higher frequencies all the way up to 3 THz and all the way down to 3 KHz.

International experts charge that the FCC should not move forward with their proposed rule. They contend that the FCC is ignoring the major actions of other governments,  more than 30,000 publications and the 30 Million US study which find “clear evidence” of cancer.  More than 377 scientists, including authorities from Australia, Austria and France,  are calling for a halt to 5G pending thorough scientific review.  Further, the scientists urge that the FCC reject an unsigned unreviewed FDA report cited as justification for reissuing the 2-decade old test limits that has been thoroughly criticized by other experts in the field.  

Excerpts from  Environmental Health Trust FCC Submission 19-226  

“It is our professional opinion that the agency should not move forward with the above proposal and needs to develop safety standards that protect against long-term health and environmental effects.” 

“We recommend a halt to the roll-out of the fifth generation, 5G, for telecommunication and for the expansion of wireless networks until hazards for human health and the environment of these new frequencies and the densification of networks have been fully investigated by scientists independent from industry. 5G paired with densification of 4G antennas will substantially increase environmental exposure to radiofrequency electromagnetic fields. We also recommend federally developed safety limits based on empirical scientific studies that have thoroughly investigated long term effects to humans, animals, insects, trees and the environment. Federal safety limits should be based on adequate data from animal and human research, not based on assumptions.” 

Read Environmental Health Trust FCC Submission 19-226  Proposed FCC changes to Measuring and Evaluating Human Exposure to Radiofrequency Electromagnetic Fields and Wireless Power Transfer Devices are Flawed:  need for biologically-based standards  ( ET Docket No. 19–226; FCC 19–126; FRS 16618)By Paul Ben Ishai,  Mikko Ahonen,  Hugo Gonçalves Silva,  and Devra Davis

Read Appendix 2: Worldwide governmental actions on cell phones and wireless radiation limits detailing actions by governments worldwide on EMFs. 

• The NPRM of the FCC in its Docket No. ET 19-226, “Human Exposure to Radiofrequency (RF) Electromagnetic Fields.” seeks to extend the current 24-year old recommended methods for testing radiofrequency radiation exposures for the general public and occupational arenas in force below 3 GHz to the frequency band from 3 GHz to 3,000 GHz (3 THz). 
• It is our professional opinion that the agency should not move forward with the above proposal and needs to develop safety standards that protect against long-term health and environmental effects. Further, the agency should provide revised standards for testing and monitoring that reflect submitted peer-reviewed evidence that protection is required against nonthermal effects from current levels of non-ionizing radiation. ET 19-226 closes dockets opened since 2013, fails to take seriously the hundreds of peer-reviewed publications and other expert comments submitted as part of this docket, uncritically adopts the minority scientific guidelines developed by ICNIRP  for internal fields in the frequency band below 3 GHz and extends them to those up to 3,000 GHz.  In adopting ICNIRP positions of a group of 13 scientists many of which have close ties to industry, the agency also fails to take into account the fact that the majority including several hundred experts in the fields of bioelectromagnetics and related matters strongly dissent from the conclusions of ICNIRP, which remains a self-appointed self-governing minority group that has no independent oversight or accounting for its funding.
• We recommend a halt to the roll-out of the fifth generation, 5G, for telecommunication and for the expansion of wireless networks until hazards for human health and the environment of these new frequencies and the densification of networks have been fully investigated by scientists independent from industry. 5G paired with densification of 4G antennas will substantially increase environmental exposure to radiofrequency electromagnetic fields. We also recommend federally developed safety limits based on empirical scientific studies that have thoroughly investigated long term effects to humans, animals, insects, trees and the environment. Federal safety limits should be based on adequate data from animal and human research, not based on assumptions. 
• The FCC lacks staff expertise to assess health implications of its proposed policies and has neglected its regulatory duty to take a “hard look” at the hundreds of comments and peer-reviewed publications submitted to the record since 2013.   Furthermore, it is noted that the FDA, in advising the FCC,  has dismissed the results of research that they themselves commissioned from the NTP when those findings negated their insistence that only thermal effects are relevant in exposure studies.
• FCC plans for satellite-based 5G coverage will involve an unprecedented number of satellites, disrupt weather forecasting, astronomy and critical science programs. As such, these FCC plans are opposed by NASA, NOAA and the US Navy.  As noted below the space-based transmissions from these satellites fall in the same frequency range as the critical atmospheric water emission line (23.8 GHz) and would effectively ‘blind’ radiometric readings of airborne moisture, undermining the capacity for accurate weather forecasting.  Pointedly the FCC also lacks expertise or knowledge to properly assess the lasting global impacts of this action.
• Despite extensive peer-reviewed scientific evidence submitted to the docket by EHT on more than 60 occasions that document nonthermal impacts of RF,  the FCC persists in adopting the view that thermal damage is the sole effect to be prevented from exposures to Radio frequency radiation.  Accordingly, it sets the exposure levels to a SAR level 1.6 W/kg averaged over a 1 g  volume of the entire head (which is treated as a homogenous entity) and a power density of 10 W/m2  and treats the ear (pinna) like the hand, wrist or foot, where the spatial peak SAR shall not exceed 4 W/kg, as averaged over any 10 grams of tissue (defined as a tissue volume in the shape of a cube) [averaged over 30 minutes] This statement of the docket is fundamentally flawed, even in the narrow definition of heating effects, as it ignores well known EM wave/tissue coupling effects as outlined herein. 
• The FCC has failed in its obligation to  maintain an accessible and searchable database of previous submissions to this docket and thus has abrogated its duty to accord serious consideration of such submissions.
• Contrary to the FCC position, non-thermal effects that are biologically important can occur from currently permitted and lower levels of RF and include disruption of cellular signaling and membrane integrity, the rise of reactive oxygen and nitrogen species (RONS) in the cell interiors and in blood, indirect damage to DNA, impairment of human reproduction and increased risk of cancer, infertility and neurological disease, altered neurotransmitter functions, permeability of the blood-brain barrier, morphology, electrophysiology, cellular metabolism, calcium efflux, and gene and protein expression.
• We and hundreds of other expert scientists do not agree with the FCC assumption that because transmissions at higher frequencies of 5G cellular networks would be absorbed superficially by the skin, such frequencies pose no danger to the public.  First, or the foreseeable future for 5G to operate, these networks will have to include 3G and 4G frequencies, judged to cause an array of biological impacts by French, Israeli, Indian governments and other expert groups, including Oceania Radiofrequency Scientific Advisory Association (ORSAA, EHT, the Bioinitiative Report, among others.  Second, the interaction between the higher frequencies of 5G and the skin has not been demonstrated to be benign. Instead the currently available research suggests biological and physiologically relevant effects.
• Submitted peer-reviewed publications document that exposures that take place in the top layers of the skin can have major immunologic and other systemic effects. The FCC ignores numerous submitted peer-reviewed publications from us and other experts detailing the complex biological  role of the skin, including the fact that it is the largest organ of the body, that it carries out important immunological roles and is vital for the production of vitamin D.  
• Furthermore the FCC ignores the fact that hotspots can form as a result of more efficient modalities of absorption in the skin, such as Standing Wave Coupling, due to the layered nature of the tissues and the short wavelength of the radiation, as is documented in peer-reviewed publications submitted to the docket.
• In addition, the effect of time division signals–time pulses—has been shown by numerous authors in peer-reviewed publication and submitted comments to be detrimental and lead to peaks of heightened skin temperatures, to the point of pain.  The FCC ignores this fact, despite the publications in the scientific record, and claims that average values (that eliminate these peaks) are sufficient.
• The FCC intends no change to the Specific Anthropomorphic Mannequin (SAM) method for modeling compliance to RF exposures that employs the large homogenous head and body of an adult male.  This, despite the indisputable fact that, by design, SAM does not gauge exposures within the specific tissues of the brain, skull, reproductive organs and bodies of infants, toddlers, and elementary school children that are among the fastest growing users of new wireless devices. At least Finite-Difference Time-Domain (FDTD) algorithm-based method should be utilised in modelling compliance to RF exposures.
• The FCC has ignored peer-reviewed publications regarding the possible impact of 5G on insect life, especially bees.  As bees and other pollinators are critical to the production of food, this issue requires critical attention as  the increase in wireless frequencies and use of higher frequencies will impact agriculture. 
• In its refusal to update testing regimes, models and standards, the FCC ignores over 30,000 peer-reviewed scientific articles that form the solid foundation for questioning its decisions as illustrated by the EMF Scientists Appeal, ORSAA, the French ANSES assessments,  the German national radiation assessments, among others.  
• There are major national differences in monitoring and surveillance of exposures that reflect policy differences more so than technical ones.  Thus, the Israeli Ministry of Environmental Protection regularly monitors on-line all cell towers and antennas and has canceled 20 towers in 2019 for exceeding their guidelines.  Several countries have federal agencies that regularly monitor radiofrequency levels and provide this information to the public.    U.S. (with more than 150,000 towers and up to a million planned in the next two years), Canada, Australia, and other nations have no regular federal monitoring, nor means of ensuring compliance with their standards for towers. 
• Exposure limits in Russia, China, Switzerland and Italy are 100 times lower than those proposed by the FCC. Russia and China have “science based” limits.   
• No secondary insurance companies provide coverage for liability from health or environmental damages from tower operation, with Swiss Re in 2019 terming 5G “off the leash” as a risk comparable to asbestosProposed expansions of wireless power transfer will rely on standards that are at least a decade old and need regulation in terms of acceptable body internal fields. Despite advances in  technology and the need to take into account far-field wireless transfer as distances between the device and its charging station grow, the FCC intends to adopt the 2010 standard of the ICNIRP.  The authors and many other well-published experts in the field strongly advise that there be an independent scientific review of this and other proposed FCC policies.
• Other nations are adopting positions that  consider the public good before the communications industry.  Thus, France has recalled dozens of cellphones found to emit unsafe levels of RF, Israel has cancelled cell towers found to exceed acceptable levels, India has set levels for tower radiation that are one tenth those of ICNIRP, many Italian cities have called to halt 5G, and national governments from Switzerland to Belgium and Greece are questioning the rush to 5G, especially in light of the refusal of secondary insurance firms to provide coverage for any health or environmental damages tied with electromagnetic fields generally, including 5G.  
• As experts in the field, we recommend that the FCC seek the advice of an independent multidisciplinary panel of an organization such as ORSAA, ANSES. the Royal College of Physicians of the UK, or the U.S. National Academies of Sciences, Engineering and Medicine to carry out an independent study of the health and environmental implications of 5G and its current exposure levels.  Until such an expert panel can produce a biologically-based exposure standard, we recommend that safe exposure levels be adopted using the As Low As Reasonably Achievable (ALARA) principle (currently employed in radiology) that employs advances in hardware and software to achieve the lowest exposures. Connections using ethernet and cable should be preferred (rather than wireless) in buildings and homes to drastically reduce the need for wireless.
• Further, as scientific evidence continues to grow linking RF exposures to cancer and other serious health impacts, the communications industry will be faced with a mounting burden of litigation and liability.  As the regulatory authority that failed to provide protection from such exposures,  the FCC will find itself  culpable. 

Read Environmental Health Trust FCC Submission 19-226  Proposed FCC changes to Measuring and Evaluating Human Exposure to Radiofrequency Electromagnetic Fields and Wireless Power Transfer Devices are Flawed:  need for biologically-based standards  ( ET Docket No. 19–226; FCC 19–126; FRS 16618)By Paul Ben Ishai,  Mikko Ahonen,  Hugo Gonçalves Silva,  and Devra Davis

Read Appendix 2: Worldwide governmental actions on cell phones and wireless radiation limits

EHT’s additional submissions  of science and policy can be found here. 

More submissions to consider include:

https://ehtrust.org/31473-2/