The FCC's lack of responsiveness to the Congress and to the American people is explained in a Harvard publication by Norm Alster, "Captured agency: How the Federal Communications Commission is dominated by the industries it presumably regulates."
Swankin & Turner sent the letter to the FCC on behalf of its clients -- The National Institute for Science, Law and Public Policy and Environmental Health Trust.
Dr. Grigoriev is the Chairman of the Russian National Committee on Non-ionizing Radiation Protection (RNCNIRP), and a member of the International Advisory Committee on Electromagnetic Fields and Health for the World Health Organization.
Following are excerpts from Dr. Grigoriev's book chapter and a link to download the document.
1. Are there nonthermal biological effects of low levels of RF EMF?2. Is it possible that the irradiation of the population with RF EMF throughout human life leads to increased adverse biological effects?3. Is there a “threshold” level of exposure to RF EMF, and if so how do we define it?”
In 1996, the Federal Communications Commission (FCC) adopted a cell phone radiation exposure limit based upon a measure called the Specific Absorption Rate or SAR. A SAR testing procedure was developed that is applied to all cell phones sold in the U.S.
In the U.S and about a half dozen other countries, cell phones are allowed to have a maximum SAR of 1.6 watts per kilogram of tissue averaged over one gram of tissue. Many countries, however, adopted a more permissive standard, that was developed by a self-appointed body, known as the International Commission on Non-Ionizing Radiation Protection or ICNIRP. The ICNIRP standard allows for up to 2.0 watts per kilogram of tissue averaged over ten grams of tissue.
Recent studies have determined that the head can absorb 2-3 times the radiation from a phone based on the ICNIRP standard as compared to the U.S. standard. Nonetheless, the cell phone industry in the U.S. has been lobbying the FCC to adopt the ICNIRP standard using the euphemism, "harmonization," to justify this weakening of the regulatory standard.
1) The SAR standards assume that a thermal (or heating) effect is the only way that microwave radiation emitted by cell phones can harm tissue.
However, many studies have found that exposure to low-intensity, microwave radiation at non-thermal levels where there is no measurable temperature change can produce DNA damage, reactive oxygen species, and stress proteins, and can alter brain activity and open the blood-brain-barrier. The SAR standards do not protect mobile device users from these non-thermal effects.
2) The standards are based upon averaging cell phone radiation exposure over one or ten grams of tissue and over time.
However, peak exposures and/or "hot spots" which damage tissue are not considered.
3) The standards only consider the immediate, acute effects of cell phone radiation exposure.
However, chronic effects due to long-term exposure are ignored.
4) The SAR test procedure uses a Specific Anthropomorphic Mannequin (SAM) which simulates a very large man's head and body.
The standards do not address exposure to fetuses, children, or women, different tissue types, or metallic objects worn on the body that influence the absorption of radiation (e.g., metal eye glasses, earrings, or dental braces). Research indicates that a child's brain absorbs 2-3 times the radiation of an adult's brain.
Evaluation of Specific Absorption Rate as a Dosimetric Quantity for Electromagnetic Fields Bioeffects
Purpose To evaluate SAR as a dosimetric quantity for EMF bioeffects, and identify ways for increasing the precision in EMF dosimetry and bioactivity assessment.
Methods We discuss the interaction of man-made electromagnetic waves with biological matter and calculate the energy transferred to a single free ion within a cell. We analyze the physics and biology of SAR and evaluate the methods of its estimation. We discuss the experimentally observed non-linearity between electromagnetic exposure and biological effect.
Results We find that: a) The energy absorbed by living matter during exposure to environmentally accounted EMFs is normally well below the thermal level. b) All existing methods for SAR estimation, especially those based upon tissue conductivity and internal electric field, have serious deficiencies. c) The only method to estimate SAR without large error is by measuring temperature increases within biological tissue, which normally are negligible for environmental EMF intensities, and thus cannot be measured.
Conclusions SAR actually refers to thermal effects, while the vast majority of the recorded biological effects from man-made non-ionizing environmental radiation are non-thermal. Even if SAR could be accurately estimated for a whole tissue, organ, or body, the biological/health effect is determined by tiny amounts of energy/power absorbed by specific biomolecules, which cannot be calculated. Moreover, it depends upon field parameters not taken into account in SAR calculation. Thus, SAR should not be used as the primary dosimetric quantity, but used only as a complementary measure, always reporting the estimating method and the corresponding error. Radiation/field intensity along with additional physical parameters (such as frequency, modulation etc) which can be directly and in any case more accurately measured on the surface of biological tissues, should constitute the primary measure for EMF exposures, in spite of similar uncertainty to predict the biological effect due to non-linearity.
FCC Needs Input on Radio Frequency Radiation
Does The FCC Plan To Rubber Stamp Outdated Cell Phone Radiation Standards?
Comments submitted to FCC re: "FCC Proposes Changes in the Commission's Rules and Procedures Regarding Human Exposure to RadioFrequency Electromagnetic Energy" (Proceeding Number 03-137), Feb 5, 2013