The Federal Communications Commission is seeking comments on expanding non-ionizing radiofrequency radiation (RF) human exposure safety limits for new wireless telecommunications equipment that will emit RF frequencies above 6 Gigahertz (GHz), that do not penetrate the body beyond the skin. The new due date to submit comments has been extended from May 6 to May 15, 2020. The FCC Proposed Rule will apply to frequencies from 6GHz to 300GHz to 3 TetraHertz (THz) for use in new commercial high frequency wireless technologies including 5G, 6G and beyond. In addition, comments are requested regarding several issues around wireless power transfer devices such as device time averaging. They also include requests for comments through the Initial Regulatory Flexibility Analysis (IRFA) on human and environmental impacts via NEPA.

Key Points Regarding Expanding FCC Guidelines to Higher Frequencies

Researchers and physicians are concerned that the new proposed FCC guidelines are flawed in their assumptions of safety for the following reasons:

  • New guidelines for higher frequencies will still only consider heat effects, not biological effects demonstrated at non-thermal levels far below current safety guidelines, including reproductive, neurologic, immunologic and carcinogenic effects
  • There are no special considerations for pregnant women, children, the elderly, those with chronic illness or those who are electrosensitive
  • New guidelines do not consider mechanisms of harm from non-ionizing radiation such as oxidation, calcium channel effects, resonance effects, radical pair mechanism (alteration of the spin sate of free radical)
  • There are scientific concerns with regards to injury to the skin and eyes with regards to higher frequencies. There is also evidence that metabolic dysregulation can occur through skin signaling
  • There is a recognized absence of independent safety testing in higher Gigahertz and Tetrahertz frequency radiation
  • Studies are typically performed on one frequency, not the mix of frequencies we will be exposed to
  • Averaging radiation makes it appear that levels and exposure are very low, however, peak levels of radiation as well as modulation (pulsation) are known to be more harmful to biological and cellular processes
  • Environmental concerns have been dismissed for the same reasons stated above

Requested submissions can be statements, letters and/or peer reviewed scientific research article links which document evidence of  biological effects from non ionizing electromagnetic radiation. If sending links to scientific studies please state the following, “Links hereby incorporated by reference” to ensure that the study becomes a part of the record, or paste the entire study or citation with full references into the comments.

Comments Are Due May 15, 2020.

The full report of the Proposed Rule of FCC 19-226 Human Exposure to Radiofrequency Electromagnetic Fields is here

How to Comment on FCC Proceedings

To Register comments for Human Exposure to Radiofrequency Electromagnetic Fields, Docket No. 19–226, go to

  • Fill out first tab –PROCEEDINGS– insert the docket number only- 19-226(it will refer to “Targeted changes to the Commission’s rules regarding Human Exposure to Radiofrequency Electromagnetic Fields\
  • Fill in the next box NAME OF FILERwith your name and click enteror it will erase the name
  • Fill in PRIMARY CONTACT EMAILContact Email if you want to receive email confirmation
  • Fill in TYPE OF FILING– drop down menu- click on COMMENT
  • Fill in required fields of the ADDRESS
  • At the bottom you can drag or place documents, Powerpoint presentations, PDF’s, etc in the box that says “Upload Documents”
  • Once this is done you will see the uploaded files and there will be a box to the right for description. You can put “comments”, “letter” or if you have a list of research only you can state “Links hereby incorporated by reference” 
  • Click on the small box that says Email Confirmationif you wish to receive an email.
  • Click on Continue to Review Screen and check the information. You can go back to correct if needed.
  • Click on the SUBMIT button at the bottom to complete the comment filing when you are done
  • Copy the CONFIRMATION NUMBERat the top of the screen so you can check and make sure it was submitted.
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NOTE: The information you submit is not private and will be shared on the website.

NOTE:  The FCC will upload comments in 1 to 2 days

To check to make sure your comments were filedgo to the same page, and at the top press CHECK FILING STATUS and enter your confirmation number

To look at all the filings for this docketgo to the same page , , and press FILINGS AND PROCEEDINGS SEARCH, then enter the docket number 19-226 ( or other docket number you may be interested in)


To request materials in accessible formats for people with disabilities (braille, large print, electronic files, audio format), send an email to [email protected]or call the Consumer & Governmental Affairs Bureau at 202–418–0530 (voice), 202– 418–0432 (tty


Martin Doczkat, email: [email protected] of the Office of Engineering and Technology Electromagnetic Compatibility Division; the Commission’s RF Safety Program, [email protected]; or call the Office of Engineering and Technology at (202) 418–2470.

Human Exposure to Radiofrequency Electromagnetic Fields. Federal Communications CommissionFederal Register Vol 85, Proposed Rules April 6, 2020.  Docket No. 19–226

Excerpts from FCC Document 19-226

“Although the radio spectrum is managed up to 3,000 GHz (3 THz), the Commission’s exposure limits are currently specified only up to 100 GHz. The Commission is unaware of any reason the limits should be different above 100 GHz. As frequency increases up to 3,000 GHz (3 THz), body penetration is reduced and ultimately approaches zero. Accordingly, there is no reason to expect that thermal effects will effectively change at the increasingly higher frequencies. Accordingly, the Commission proposes to extend the same constant exposure limits that presently apply from 6 GHz to 100 GHz up to an upper frequency of 3,000 GHz (3 THz), which is considered to be the upper bound of existing radiofrequency bands.”

Proposed Limit of 4mW/cm2from 6GHz to 3THz.

“Because portable devices are being developed for operation at higher frequencies for future 5G services, the Commission proposes a localized exposure limit above 6 GHz of 4 mW/cm2 averaged over 1 cm2 for the general population, applicable up to the upper frequency boundary of 3 THz… The Commission notes that both the ICNIRP guidelines and the IEEE standards specify a spatial maximum power density of 20 times the whole-body MPE limit (e.g., between 3 and 10 GHz), generally averaged over 1 cm2…The Commission proposes a localized exposure limit above 6 GHz for occupational settings of 20 mW/cm2 averaged over 1 cm2, which is consistent with the typical ratio of 5:1 for the occupational limits relative to the general population limits. The Commission tentatively concludes not to adopt an extremity limit at this time…”

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“Based on planar models, this standard suggests that a power density of 4 mW/cm2 just above 6 GHz is consistent with the Commission’s 1-gram SAR limit of 1.6 W/kg at 6 GHz. Also, the thermal perception threshold at frequencies approaching 100 GHz for large areas of exposure is indicated at about 4 mW/ cm2. Maintaining 4 mW/cm2 across the entire frequency range of 6 GHz to 3 THz will avoid any potential discontinuity between SAR and power density limits at 6 GHz, while also preventing the possibility of perception of warmth at higher millimeter-wave frequencies.”

Time-averaging Principles

“The Commission seeks comment on the range and type of parameters that should be considered to apply the proposed time-averaging principles.”

“With respect to the appropriate time-averaging period, the Commission notes two references for specifying time- averaging limits: (1) The ICNIRP standard that provides for averaging over 6 minutes at 10 GHz, and reduces to 10 seconds at 300 GHz on a complex basis; and (2) the IEEE standard that provides for an averaging time of 25 minutes at 6 GHz, dropping to 10 seconds at 300 GHz. However, since the Commission does not limit temporal- peak SAR or power density, all of the energy available in a time-averaging period could be deposited in an instant, resulting in a well-defined temperature rise, yet still be compliant with the rules. Thus, using the extended time- averaging periods of 6 or 30 minutes as set forth in the Commission’s rules in other contexts, or either of the alternative time windows specified by ICNIRP and IEEE, could allow for inappropriate temperature rises in extreme cases when intense exposure occurs for only a brief period.”

Wireless Power Transfer Devices

“Finally, the Commission seeks input on the following issues: Under what category of spectrum use should the Commission consider wireless power transfer.”

“The Commission seeks comment on a suitable definition and operating parameters for wireless power transfer devices that provide charging of receiving units located at a distance from the power transfer unit (i.e., 50 cm or greater), with future developments intended at distances suitable for room- size operation, and while the RU is in motion.”

“On specifying the conditions and methods for averaging the RF exposure, in both time and area, during evaluation for compliance with the RF exposure limits in the rules; on addressing new RF exposure issues raised by wireless power transfer (WPT) devices; and on the definition of a WPT device.”

Initial Regulatory Flexibility Analysis (IRFA)

“As required by the Regulatory Flexibility Act of 1980 (RFA), the Commission prepared an Initial Regulatory Flexibility Analysis (IRFA) of the possible significant economic impact on a substantial number of small entities by the policies and rules proposed in the  Notice of Proposed Rulemaking (NPRM). The Commission requests written public comment on the IRFA, which is contained in Appendix C to the NPRM. Comments must be identified as responses to the IRFA and must be filed by the deadline for comments provided in this NPRM.”

“In the IRFA, the Commission noted that the National Environmental Policy Act of 1969 (NEPA) requires agencies of the Federal Government to evaluate the effects of their actions on the quality of the human environment. To meet its responsibilities under NEPA, the Commission has adopted requirements for evaluating the environmental impact of its actions. One of several environmental factors addressed by these requirements is human exposure to radiofrequency (RF) energy emitted by FCC-regulated transmitters, facilities, and devices.”

  1. The NPRM proposes to amend Parts 1, 2, and 18 of its rules relating to the compliance of FCC-regulated transmitters, facilities, and devices with the guidelines for human exposure to radiofrequency (RF) energy. Specifically, the Commission is proposing to make certain revisions in its rules that it believes will result in more efficient, practical and consistent application of its RF exposure compliance procedures. The NPRM seeks to develop a record that will enable the Commission to meet the challenges presented by evolving technological advances not resolved in the previous RF exposure proceedings.
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Physicians for Safe Technology