Wednesday, November 23, 2022

What's Wrong with Cell Phone Radiation Exposure Limits?

A leading expert, Professor Om Gandhi, blames the inadequacies of the Specific Absorption Rate (SAR) safety standard and the Specific Anthropomorphic Mannequin (SAM) model used to test cell phones on industry and military engineers who dominated the IEEE standard setting meetings. He discusses the dangers of 5G radiation.

The We Know Show / PodBean, Nov 21, 2022

Meet the man whose research inspired the SAM campaign. Om P. Gandhi, Emeritus Professor of Electrical and Computer Engineering with the University of Utah, taught courses on biological effects of antennas, RF and microwave electromagnetic fields for over 50 years.

Prof. Om P. Gandhi is a world expert on how mobile phone radiation penetrates the human brain. Once a consultant to major cell phone companies, Gandhi now refuses to work with them. 

He has authored or co-authored several book chapters, and over 200 journal articles in electromagnetic dosimetry, microwave tubes, and solid-state devices. He also edited a book entitled Biological Effects and Medical Applications of Electromagnetic Energy and co-edited a book entitled Electromagnetic Biointeraction.

Dr. Gandhi was elected as a fellow of the American Institute for Medical and Biological Engineering in 1997. He was the Chairman of the Department of Electrical Engineering, University of Utah, from 1992 to 1999, the President of the Bioelectromagnetics Society from 1992 to 1993, the Co-Chairman of the IEEE SCC 28. IV Subcommittee on the RF Safety Standards from 1988 to 1997, and the Chairman of the IEEE Committee on Man and Radiation from 1980 to 1982. He received the d’Arsonval Medal of the Bioelectromagnetics Society for pioneering contributions to the field of bioelectromagnetics in 1995, the Microwave Pioneer Award of the IEEE MTTS in 2001, and the State of Utah Governor’s Medal for Science and Technology in 2002.

“The SAR (Specific Absorption Rate) for a 10-year old is up to 153% higher than the SAR for the SAM model and MRI scans of children between 5 and 8 years of age and found approximately 2 times higher SAR in children compared to adults. When electrical properties are considered, a child’s head’s absorption can be over two times greater, and absorption of the skull’s bone marrow can be ten times greater than adults”

– O. P. Gandhi et al, 2012

“It is a fact that humans of all sizes and ages from children to older individuals are using cell phones, and testing for compliance testing for a 220 lb., 6 feet 2 inch tall adult male underestimates the actual energy absorbed by up to a factor of two, thus releasing into the market telephones that would not pass if a proper safety compliance testing method was used.”

- Dr. Om P. Gandhi Professor of Electrical and Computer Engineering in his FCC Submission

The We Are Not SAM movement is not based on opinion - it's backed by science and the leading independent scientists from around the world have a lot to say about this testing dummy called SAM.  Tune in to hear some of the mind-boggling insights from Om’s research, the specifics around the SAM test which has allowed mobile phones to proliferate the market with unsafe devices, the FDTD Method - an alternative solution to the SAM test which can detect radiation with precision, the antenna affect, why humans absorb radiation and act like a conductor + so much more!

Show notes:

1:58 – Why are they testing mobile phones on a plastic dummy, how it violates SAR (specific absorption rate) testing standards

7:39 –  As a professor, they can’t stop me publishing research

10:25 – Mobile phone tower proximity matters – a weak signal requires more radiation

12:54 – Uncovering different radiation absorption rates for children and adults

16:22 – Children 5-12 years are absorbing twice the amount of radiation compared to adults

31:10 – FDTD method, the alternative biological test for safety, why is this hidden?

33:26 – The Antenna Effect, why humans absorb radiation then act like a conductor

38:13 – Does the 5G technology have the potential to create human transmitters?

42:16 – Revealing studies conclude you should stay away from mobile phone towers

44:19 – Biggest health risks of 5G infrastructure is higher rates of cancer

49:00 – The FCC does not take long-term exposure into account

57:22 – "5G is being rolled out unnecessarily without proper testing, that’s a fact!"


Download and read Om Gandhi's 2012 research paper titled “Exposure Limits: The underestimation of absorbed cell phone radiation, especially in children

Link to more of Om Gandhi’s research papers

Watch Dr. Gandhi share his research showing children receive higher cell phone radiation exposures than adults + more details of his ground-breaking research.

To download this interview (mp3):


Sep 28, 2017

Does the FCC Adequately Enforce its Cell Phone Radiation Exposure Limits?

Last September, the Washington, DC law firm, Swankin & Turner, sent a letter to the Federal Communications Commission (FCC) that questioned whether the agency adequately enforced its cell phone radiation exposure limits.

The letter raised four areas of concern about current testing procedures and posed twelve specific questions.

One concern is that the FCC's two-decade-old cell phone testing procedures allow for a 30% margin of error. This means that a cell phone with a Specific Absorption Rate (SAR) greater than 1.231 W/kg can actually exceed the FCC's exposure limit of 1.6 W/kg. The law firm's clients estimate that about 75% of the cell phones on the market may exceed the current exposure limits.

In 2012, the U.S. General Accountability Office, an independent, nonpartisan agency that works for Congress, presented a report to the FCC which raised concerns about the adequacy of cell phone testing procedures. The Commission has yet to address the GAO's concerns so it is unlikely that the FCC will provide a timely response to Swankin &Turner.

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.

The eleven page letter can be downloaded at:

June 19, 2017

Current Cell Phone Radiation Standards 
Do Not Protect Human Health

National and international regulatory limits for radiofrequency radiation (RFR) exposure from cell phones and cell towers are outdated according to Dr. Yuri Grigoriev. Moreover, the standards are inadequate to protect human health, especially the health of children and those who are hypersensitive to RFR.

Dr. Grigoriev calls for research on the biological effects of chronic exposure to low-intensity RFR in order to develop stronger RFR standards, “bearing in mind, above all, long-term exposure on the brain at all levels of development.”  He argues that until we adopt protective regulations, we should “provide the public with full information on the possible dangers of mobile communication for their health. “ 

Finally, he appeals to his colleagues “Do not sin against the truth!”

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.

Grigoriev Y. “Methodology of Standards Development for EMF RF in Russia and by International Commissions: Distinctions in Approaches." In Markov, M (Ed.), Dosimetry in Bioelectromagnetics. Chapter 15. pp. 315-337. Boca Raton, FL: Taylor & Francis. 2017.


“The ultimate goal of electromagnetic field (EMF) standards is to protect human health. Exposure limits are intended to protect against adverse health effects of EMF exposure across the entire frequency range and modulation.”

“The Russian standard for base stations has already been in existence for more than 30 years and is more rigid than the maximum level recommended by the International Commission of Non-Ionizing Radiation Protection (ICNIRP). This distinction has been discussed at scientific meetings for many years—unfortunately, without result.
The second EMF source of mobile communication—the mobile phone—has no sufficient substantiation on exposure limits. The irradiation of a brain is not limited and is not supervised. The children using mobile phones are especially at high risk.”

“The first RF EMF standard for the population, SanPiN 848-70, was approved by the Ministry of Health of the USSR in 1970 and was considered for the population exposure limit of 1 μW/cm² in the microwave band of 300 MHz to 300 GHz. In 1978, the USSR  Ministry of Health approved the next SanPiN No. 1823-78. In this document, MPL for the population in the frequency range of 300 MHz to 300 GHz was set as 5 μW/cm².”

“Currently, three questions remain relevant for standardization: 
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?”
“….These results together with numerous studies conducted by scientists from many countries provide direct evidence that RF EMF intensity of up to 10 mW/cm² may have a nonthermal mechanism of action.”

“There is evidence that RF EMF can cause development of tumors in the brain of mobile phone users after a 10–12 year “waiting period” (Hardell and Calberg, 2009). The term 'heavy users' that appeared in some publications linked the unfavorable bioeffects of the prolonged mobile phone use to accumulative processes of adverse biological effects.

It has been shown that after a single exposure to low-intensity RF EMF, certain changes in the brain EEG occur (Lukyanova, 1999, 2015). During the first hours after exposure, there is a restoration of bioelectrical activity of the brain, which indicates the insinuation of compensatory processes. Naturally, in these conditions, a repeated exposure might weaken compensatory processes and lead to development of the process of accumulation (Lukyanov et al., 2015).”

“The threshold level is the lowest level of exposure of the physical factor (EMF RF), below which the risk to public health does not exist, is introduced in analogy with the principles of ionizing radiation.  Given the complexity of this problem, we propose to determine the threshold level as a criterion for the body’s response to RF EMF exposure, but on the condition that this response should not be pathological. This reaction may be compensatory/ adaptive and should exist within the physiological range.”

“When determining the limit values for base stations, the RNCNIRP decided to leave the limit value for the general public of 10 μW/cm² unchanged, as it was set in 1984. This value was well justified by previous research, and so there was no need for changing it (Vinogradov and Dumanskiy, 1974, 1975; Shandala and Vinogradov, 1982; Shandala et al., 1983, 1985; Vinogradov and Naumenko, 1986; Vinogradov et al., 1999).

It is important to note that the MPL of 10 μW/cm² for the population has remained intact for more than 30 years. Previously, the standard was used only in Russia and the countries formerly in coalition with the Soviet Union. Now, MPLs of 10 μW/cm² or less are used as RF legal exposure limits or nonbinding recommendations for national, regional, urban, or sensitive areas for at least 20 countries worldwide (Figure 15.1).”

“The adoption of the standard in 2003 for the mobile phone in terms of formalizing requirements for methods of measuring the near field and for the establishment of a threshold for the evaluation of RF EMF exposure on brain function as a critical organ was not optimal….There was a proposal to use a safety factor of 5 and set to the cell phone MPL at 100 μW/cm² (Russian Standard, 2003—SanPiN 2.1.8/ It should be emphasized that SanPiN 2.1.8/, for the first time, introduced the recommendation to limit cell phone use for persons younger than 18 years as well as pregnant women.”

“The following factors allow us to conclude that the potential risk to the health of children who use mobile phones is very high:

– Absorption of electromagnetic energy by the head of a child is much higher than in the head of adults (children’s brain tissue has a higher conductivity, the size of the child’s head is smaller, and the skull bone of the child is thin).
– The distance from the antenna to the brain is short, because the child’s ear shell is very soft and has almost no layer of the cartilage.
– The child’s body is more sensitive to EMFs than adults.
– The child’s brain is more vulnerable to the effects of EMF.
– The brains of children have a greater propensity to accumulation of adverse reactions in the context of repeated exposures to EMF.
– EMF RF may have an adverse effect on cognitive functions.
– Today’s children use mobile phones at an early age and will continue to use them during their lifespan, and so the duration of the exposure of children to electromagnetic radiation will be substantially larger than that of modern adult users.”

“According to the members of the Russian National Committee of Non-Ionizing Radiation Protection (RNCNIRP, 2008), some possible disorders that might originate in children who use mobile phones include weakened memory, decline of attention, reduction  of mental and cognitive abilities, irritability, sleep disturbance, tendency to stress reactions, and increased epileptic readiness.

It is also possible to expect the development of the adverse effects in older age as the result of the accumulation of adverse effects both in cells and in various functional systems of the body: brain tumors, tumors of the auditory and vestibular nerves (at age 25–30 years), Alzheimer’s disease, “dementia,” depressive syndrome, and other manifestations of degeneration of the nervous structures of the brain (at age 50–60 years).

Children users of mobile phones are not able to know that their brains are subjected to EMF, risking their health. This is a significant factor in moral ethics for parents. Also important is that the risk of EMF RF exposure is not less than the risk for children’s health from tobacco or alcohol.”

“Currently, international standards are developed by ICNIRP, IEEE, CENELEC, and other international and national commissions. Their methodology uses only the results of experimental animal studies obtained under the conditions of acute effects and thermal-level EMF RF (Bernhard, 1999).

Any standard safety margin depends on the predetermined threshold. Outside Russia, the threshold level is determined on the basis of “stable pathological reactions” in the conditions of acute exposure to RF EMF heat level (WHO Handbook, 2002).”

“Our long experience with ionizing and non-ionizing radiations led us to formulate the following postulate: “The development of hygiene standards for the population should take into account the actual conditions of EMF RF exposure of the population—local or total exposure, acute single exposure or chronic, constant, or repeated exposure; the functional importance of ‘critical organ’ or ‘critical body systems’; and effect on all population groups or only on certain limited groups of the population” (Grigoriev, 1997, 2008a).

Taking into account this postulate, we can make a clear conclusion that the Western standards do not meet the basic hygienic requirements …. Western regulations do not take into account events that occurred for the first time during the life of our civilization. Children who use mobile phones voluntarily irradiate their brains. This EMF RF exposure of the brain occurs every day, and the fractional exposure is projected for many years.

We criticized the Western standards because they do not correspond to the actual conditions of RF EMF exposure on the population (report in 2003 at an international seminar in China, Grigoriev et al., 2003b).”

“This analysis of the methodology of RF EMF regulation abroad allows us to conclude that the current so-called International Recommendations/Guidelines (ICNIRP, 1998) and the IEEE Standards (S95.1-2005), CENELEC (EN 50166-2.2000) do not correspond to existing conditions of RF EMF exposure on the population and cannot guarantee the safety of the public health.

Interestingly, this view was confirmed by the European Parliament in 2009 ….”

“We believe that it is necessary within the framework of the development problems of the methodology of EMF RF standards to specifically consider additional criteria for risk assessment related to the exposure of children to RF EMF who became active users of mobile phones.

Western experts working on new standards, completely ignoring the problem of childhood cell phone use do not take into account the WHO opinion on the higher sensitivity of children to environmental factors in the International standards: ‘children are different from adults.’

Children have a unique vulnerability. As they grow and develop, there are “windows of susceptibility”: periods when their organs and systems may be particularly sensitive to the effect of certain environmental threats (WHO, 2003).”

“The electromagnetic burden on the population is growing daily. At the same time, over the last 20 years, debates are still continuing on the following topic: Is the health of the population at risk because of increasing pollution due to RF EMF from the base stations and mobile phones?

The brains of almost all people on earth are exposed to EMF radiation. However, practically, there are no restrictions for the use of mobile communications. Having the advantages and convenience of mobile communication, the population is ignoring the information about the possible risks to their health. This threat affects everybody, including children aged 3–4 years. Pregnant women do not protect their fetuses from exposure to EMF.

The scientific community is watching this picture and is waiting for the results of this uncontrolled global experiment (Markov and Grigoriev, 2013). We saw similar hazards during the Victorian period in Britain (wallpaper with mercury and toys with lead).”

“…there are four postulates that show the risk to public health from mobile communication (Grigoriev, 2013). It is necessary to convince the population and to create an environment of reasonable restrictions on the use of this  communication.

The first postulate: ‘EMF—harmful type of radiation.’ Mobile communication uses RF EMF. This type of electromagnetic radiation is considered harmful. Exceeding the permissible levels can cause disease; therefore, it requires hygienic control. This is the absolute truth.

The second postulate: ‘The brain and EMF.’ The mobile phone is an open source of EMF, and there is no protection for valuable human organs. EMFs affect the brain during mobile phone use. Nerve structures inside the internal ear (the vestibular and the auditory apparatus) are located directly under the beam of EMF. This is the absolute truth.

The third postulate: ‘Children and EMF.’ For the first time, in history the child’s brain is subjected to RF EMF. There are no results of the study of chronic local RF EMF exposure on the brain. Children are more vulnerable to external environmental factors. This opinion was expressed by WHO (2003) and in the Parma Declaration (WHO European Region, 2010). This is the absolute truth.

Fourth postulate: ‘The lack of adequate recommendations/standards.’ There is no agreement on the methodology for determining the EMF RF remote control and for the development of international standards, and there are no results from 20 years of debate on this issue. This is a real fact.”

“I believe that the time has come to provide the public with full information on the possible dangers of mobile communication for their health. The abovementioned four postulates allow the public to comprehend the likely risks to their health from uncontrolled use of mobile communication.”

“I appeal to colleagues: Do not sin against the truth!”


“Of course, new sources of electromagnetic radiation are creating additional problems in the development of standards. Public health protection issues in connection with the use of mobile communications have become completely different. The use of mobile phones has led to the local long-term RF EMF exposure to the brain. The normative level is not considered a permanent RF EMF exposure on the brain of the user. Existing regulations do not address to the real hazard RF EMF exposure. Given these circumstances, standards cannot currently guarantee the well-being of adults and children.

Children mobile phone users were included in the group of high risk. In this regard, there is a need to develop more appropriate stringent standards to ensure absolute security for growing children. Existing standards should take into consideration the vulnerable group of people hypersensitive to RF EMF.

Given that the current regulations are outdated, it is necessary to carry out complex research into possible biological effects on conditions of chronic exposure to low-intensity EMF RF, bearing in mind, above all, long-term exposure on the brain at all levels of development.

As a temporary measure of limiting exposure to EMF on the population, it is necessary to introduce the concept of “voluntary risk”; that is, mobile telephony should be a product of self-selection on the background of the official public information about possible health hazards.”

The document can be downloaded from the Radiation Research Trust:

June 23, 2014

What's Wrong with Cell Phone Radiation 
Exposure Limits?

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.

Considerable research, however, suggests that both the U.S. and ICNIRP standards do not adequately protect us from health risks due to exposure to cell phone radiation. The Specific Absorption Rate (SAR) and testing procedures are based upon four fallacies:

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

DJ Panagopoulos, O Johansson, GL Carlo. Evaluation of Specific Absorption Rate as a Dosimetric Quantity for Electromagnetic Fields Bioeffects. PLoS One. 2013; 8(6): e62663. Published online 2013 Jun 4. doi: 10.1371/journal.pone.0062663


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.


For further information about the FCC review of the SAR exposure limits in the U.S. see ...

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

What's Wrong with the GAO Report on Cell Phone Radiation?