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FCC and ICNIRP Limits

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FCC and ICNIRP Human Exposure Limits  

Inadequate to Protect Health or Environment

The wireless radiation exposure limits of the U.S.  Federal Communications Commission (FCC) and the International Commission on Non Ionizing Radiation Protection (ICNIRP) are inadequate to protect health. They ignore hundreds of scientific studies documenting adverse health effects at wireless exposures below the threshold dose claimed by these agencies, which was used to establish human exposure limits. The International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF) are scientists with expertise regarding the  health effects of cell towers, cell phones, Wi-Fi , 4G, 5G, wireless networks and non-ionizing electromagnetic fields. 

ICBE-EMF published a scientific paper documenting the  false assumptions that FCC and ICNIRP limits are based on. 

The ICBE-EMF published a scientific paper in Environmental Health, “Scientific evidence invalidates health assumptions underlying the FCC and ICNIRP exposure limit determinations for radiofrequency radiation: implications for 5G,” arguing how the FCC and ICNIRP limits, based on science from the 1980s – before cell phones were ubiquitous – do not adequately protect workers, children, people with electromagnetic hypersensitivity, and the public from exposure to the non-ionizing radiation from wireless data transmission.(1) 

The three take-away messages from this paper are:

  • Radiofrequency radiation exposure limits set by ICNIRP and the FCC are based on invalid assumptions, are not protective of human health, and ignore the impact on wildlife. Consequently, an independent assessment is needed of the effects and risks of radiofrequency radiation which is based on evidence from scientific studies conducted over the past 25 years; the aim of such assessment would be to establish health protective exposure standards for workers and the general population.
  • The general public should be informed of the health risks of radiofrequency radiation and encouraged to take precautions to minimize exposures and risks, especially for children, pregnant women and people who are electromagnetically hypersensitive.
  • ICBE-EMF calls for an immediate moratorium on further development of 5G wireless technologies until safety is demonstrated, and not simply assumed.

The paper detailed 14 erroneous assumptions that underpin FCC and ICNIRP exposure limits for RF radiation.

A) Effects of RE radiation at exposures below the putative SAR threshold of 4 W/kg. 

Assumption 1

There is an exposure threshold for any adverse health effect caused by RF radiation; in the frequency range of 100 kHz to 6 GHz it is a whole body exposure that exceeds an SAR of 4 W/kg. Any biological effect of radiation above the threshold exposure is due to tissue heating. 

Assumption 2

The RF radiation is incapable of causing DNA damage other than by heating; there is no mechanism for non-thermal DNA damage. 

Assumption 3

Two to seven exposures to RF radiation for up to one hour are sufficient to exclude adverse effects of RF radiation for any duration of exposure, including chronic exposure. 

Assumption 4

No additional effects would occur from RF radiation with co-exposure to other environmental agents

B) Factors influencing dosimetry

Assumption 5 

Health effects are dependent only the SAR value; carrier wave modulations, frequency, or pulsing do not matter except as they influence the SAR.

C) Human brain cancer risk

Assumption 6

The multiple human studies that find associations between exposure to cell phone RF radiation and increases in brain cancer risk are flawed because of biases in the published case-control studies, and because brain cancer rates have remained steady since the use of wireless communication devices became widespread.

D) Individual variations in exposure and sensitivity to RF-EMF 

Assumption 7 

There are no differences among individuals, including children, in the absorption of RF-EMF and susceptibility to this radiation. 

Assumption 8

There are no differences among individuals in their sensitivity to this RF radiation-induced health effects. 

E) Applied safety factors for EMF-RF workers and the general population 

Assumption 9

A 50-fold safety factor for the whole-body exposure to RF radiation is adequate for protecting the general population from any health risk from RF radiation.

Assumption 10

A 10-fold safety factor for whole body exposure to RF radiation is adequate for protecting workers from any health risk from RF radiation.

Assumption 11   

Exposure of any gram of cube-shaped tissue up to 1.6 W/kg, or 10 grams of cube-shaped tissue up to 10 W/kg, (duration not specified) will not increase the risk of that tissue to any toxic or carcinogenic effects in the general population.

Assumption 12  

Exposure of any gram of cube-shaped tissue up to 8 W/kg, or 10 grams of cubed-shaped tissue, (duration not specified) will not increase the risk that tissue to any toxic or carcinogenic effects in workers. 

F) Environmental exposure to RF radiation 

Assumption 13

There is no concern for environmental effects of RF radiation or the effects on wildlife or household pets.

G) 5G (5th generation wireless) 

Assumption 14

No health effects data are needed for exposures to 5G: safety is assumed because penetration is limited to the skin (“minimal body penetration”).

The ICBE-EMF position is that numerous questions need answers before safety assurances are put forward that wireless technologies are safe for human health and the environment.

  • Radiofrequency radiation (RFR) exposures are associated with a range of adverse health effects including cardiomyopathy, carcinogenicity, DNA damage, neurological effects, increased permeability of the blood brain barrier and sperm damage.
  • Since 2002(2), multiple robust epidemiologic studies of cell phone radiation have found increased risks for brain tumors3 which are supported by evidence of carcinogenicity of the same cell types (glial cells and Schwann cells) from animal studies.(4,5)
  • Based on very limited research conducted 40 years ago (before most people had cell phones), the Federal Communications Commission (FCC) for the U.S., and the International Commission on Non Ionizing Radiation Protection (ICNIRP) for many other countries, determined in the 1990s and again in 2020 that there are no adverse health effects from RFR exposure below the Specific Absorption Rate (SAR) of 4 watts per kilogram (W/kg) for frequencies ranging from 100 kHz to 6 GHz. The assumed safe level is based on a behavioral effect observed in acute studies (up to 1 hour) conducted with small numbers of rats and monkeys in the 1980s.(6,7)

“Many studies have demonstrated oxidative effects associated with exposure to low-intensity RFR, and significant adverse effects including cardiomyopathy, carcinogenicity, DNA damage, neurological disorders, increased permeability of the blood-brain barrier, and sperm damage,” explains Dr. Ronald Melnick, ICBE-EMF Commission chair and a former senior toxicologist with the U.S. National Toxicology Program at the National Institute of Environmental Health Sciences. “These effects need to be addressed in revised and health-protective exposure guidelines. Furthermore, the assumption that 5G millimeter waves are safe because of limited penetration into the body does not dismiss the need for health effects studies.”

The FCC and ICNIRP state that any biological effect observed at exposures above the putative 4 W/kg threshold is due to tissue heating.(8-11) However, a large and growing number of peer- reviewed experimental studies have found adverse biological and health effects at lower doses or for longer durations of exposure, demonstrating that an SAR of 4 W/kg is not a threshold for effects of RFR.(12)

Additionally:

  • The current RFR exposure limits do not consider potential synergistic effects that reflect modern day exposures to multiple environmental agents.
  • There is insufficient information on health effects of 5G radiation.
  • Neurological effects, some of which are acknowledged by ICNIRP and are currently being experienced by persons with electromagnetic hypersensitivity (EHS), are health effects that can be mitigated with radiation-free areas for hypersensitive individuals.

 

ICBE-EMF Paper: Scientific evidence invalidates health assumptions underlying the FCC and ICNIRP exposure limit determinations for radiofrequency radiation: implications for 5G

Factsheet: Scientific Evidence Invalidates Health Assumptions of Government Exposure Limits for Radiofrequency Radiation (RFR): Implications for 5G 

References

  1. International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF). Scientific evidence invalidates health assumptions underlying the FCC and ICNIRP exposure limit determinations for radiofrequency radiation: implications for 5G. Environ Health (2022) 21:92. https://doi.org/10.1186/s12940-022-00900-9.
  2. Hardell et al. Cellular and cordless telephones and the risk for brain tumours. Eur J Cancer Prev. 2002 Aug;11(4):377-86. doi: 10.1097/00008469-200208000-00010.
  3. Choi et al. Cellular Phone Use and Risk of Tumors: Systematic Review and Meta-Analysis. Int J Environ Res Public Health. 2020 Nov 2;17(21):8079. https://doi.org/10.3390/ijerph17218079
  4. National Toxicology Program (NTP). NTP technical report on the toxicology and carcinogenesis studies in Hsd:Sprague Dawley SD rats exposed to whole-body radio frequency radiation at a frequency (900 MHz) and modulations (GSM and CDMA) used by cell phones, Technical report series no. 595. Research Triangle Park: National Institutes of Health, Public Health Service, U.S. Department of Health and Human Services; 2018. https://ntp.niehs.nih.gov/ntp/htdocs/lt_rpts/tr595_508.pdf
  5. Falcioni et al. Report of final results regarding brain and heart tumors in Sprague-Dawley rats exposed from prenatal life until natural death to mobile phone radiofrequency field representative of a 1.8 GHz GSM base station environmental emission. Environ Res. 2018 Aug;165:496-503. doi: 10.1016/j.envres.2018.01.037.
  6. De Lorge & Ezell. Observing-responses of rats exposed to 1.28- and 5.62-GHz microwaves. Bioelectromagnetics. 1980;1:183–98.
  7. De Lorge. Operant behavior and colonic temperature of Macaca mulatta exposed to radio frequency fields at and above resonant frequencies. Bioelectromagnetics. 1984;5:233–46.
  8. ICNIRP. Guidelines for limiting exposure to electromagnetic fields (100 kHz to 300 GHz). Health Phys. 2020;118:483–524.
  9. ICNIRP. ICNIRP guidelines for limiting exposure to time-varying electric, magnetic and electromagnetic fields (up to 300 GHz). Health Phys. 1998;74:494–522.
  10. National Council on Radiation Protection and Measurements. Biological effects and exposure criteria for radiofrequency electromagnetic fields. NCRP Report No. 86, 1986. https://ncrponline.org/publications/reports/ncrp-report-86/
  11. American National Standards Institute (ANSI). Safety levels with respect to human exposure to radio frequency electromagnetic fields, 3 kHz to 300 GHz., ANSI/IEEE C95.1–1992. https://emfguide.itu.int/pdfs/c95.1-2005.pdf
  12.  ICBE-EMF. Scientific evidence invalidates health assumptions underlying the FCC and ICNIRP exposure limit determinations for radiofrequency radiation: implications for 5G. Appendix 1, Table 1. Studies demonstrating increased oxidative DNA damage and other indicators of oxidative stress at SAR < 4 W/kg. Environ Health (2022) 21:92. https://doi.org/10.1186/s12940-022-00900-9
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