Wednesday, May 6, 2020

Symptoms Experienced by Persons with Electromagnetic Hypersensitivity: Submissions to FCC Docket #13-84

The Federal Communications Commission (FCC) requested public input regarding radio frequency radiation (RFR) exposure limits and policies in the United States via Docket #13-84 in 2013. The earliest submission for this docket was dated June 24, 2012. As of January 21, 2020, the FCC had received 1,302 submissions for this docket.

In November 2013, the cities of Boston and Philadelphia filed a submission to the Federal Communications Commission (FCC) (Dockets #13-84 and #03-137) that accused the FCC and federal health agencies of negligence for failing to investigate whether electrosensitive persons are harmed by wireless radiation:
"The FCC admits its own lack of expertise in the field. But the overlap of federal agency responsibilities for RF radiation protection and the merely advisory status of the Radiofrequency Interagency Work Group often leaves leadership unclear and encourages a pass-the-buck attitude ..."
"The 1999-2000 judicial challenge to the FCC’s 1996 rules never reached the issue of “electrosensitivity” as a cognizable disability under the Americans with Disabilities Act. (“ADA”) Here again, an agency responsible for ADA implementation acknowledges that the impairment may be disabling but has promised merely further inquiry. After more than a decade, that investigation remains unopened. The dockets here have been updated with massive additional evidence of the crippling effects of RF radiation on an admitted minority – but a suffering minority – of U.S. citizens. The FCC and its sister regulatory agencies share responsibility for adherence to the ADA and should replace promises with serious attention to a serious medical problem. This is one area where the FCC could lead in advice to electrosensitive persons about prudent avoidance."
The Americans with Disabilities Act (ADA) is the nation's first comprehensive civil rights law that addresses the needs of people with disabilities, prohibiting discrimination in employment, public services, public accommodations, and telecommunications. The ADA defines a disability as a physical or mental impairment that substantially limits one or more major life activities, a history of having such an impairment, or being regarded as having such an impairment.

Many of the submissions to Docket #13-84 called on the FCC to strengthen existing RFR exposure limits. I created an index with links to representative submissions for this docket on my Electromagnetic Radiation Safety web site located at The index is organized using the following categories: (1) resolutions from scientists calling for stronger regulations; (2) expert comments that support stronger regulations; (3) expert comments that support weaker regulations; (4) advice from consumer, environmental and health organizations; (5) advice from government agencies; (6) advice from wireless industry corporations and associations; and (7) miscellaneous other. I also created links to important scientific papers submitted for this docket.

The following results are based on submissions to FCC Docket #13-84 from persons who self-identified as experiencing electromagnetic sensitivity or hypersensitivity (EHS).

Persons Reporting Electromagnetic Hypersensitivity (EHS) in Submissions
to FCC Docket #13-84 (N = 184)
TABLE 1: Common Symptoms Attributed to Radio Frequency Radiation Exposure
(N = 1641)
52% Headaches or migraines
48% Other neuro-cognitive problems (memory/concentration/confusion/dizziness)
31% Insomnia or sleep disorders
29% Cardiovascular problems (mostly heart palpitations)
23% Tinnitus (ringing in ears)
18% Digestive problems (mostly nausea)
17% Fatigue
16% Nervous system disorders
13% Eyes/vision problems
 8% Muscular problems (weakness, pain)
32% Other symptoms

1 Of the 184 individuals who reported experiencing EHS in their submissions to FCC Docket #13-84, many reported multiple symptoms and/or sources of exposure. Twenty individuals did not report symptoms, and 27 did not report sources of exposure.

The report can be downloaded from:

Related Posts:

Electromagnetic Hypersensitivity (EHS)

Part I: Why We Need Stronger Cell Phone Radiation Regulations--Key Testimony Submitted to the FCC

On August 8, 2019, the FCC published a news release in which Ajit Pai, the FCC chairperson, issued a proposal that the FCC not change its existing radiofrequency (RF) exposure limits. He also proposed to gather public comment on rules to determine compliance with the exposure limits and establish uniform guidelines to ensure compliance.

The press release makes the following claims:
“The FCC sets radiofrequency limits in close consultation with the FDA and other health agencies. After a thorough review of the record and consultation with these agencies, we find it appropriate to maintain the existing radiofrequency limits, which are among the most stringent in the world for cell phones,” said Julius Knapp, chief of the FCC’s Office of Engineering and Technology.
As Jeffrey Shuren, Director of the Food and Drug Administration’s Center for Devices and Radiological Health, wrote to the FCC, “[t]he available scientific evidence to date does not support adverse health effects in humans due to exposures at or under the current limits…” and “[n]o changes to the current standards are warranted at this time.”
Unfortunately, these assertions do not reflect the state of the scientific literature regarding RF health effects, nor do they adequately reflect the public comment received by the FCC over the past six years regarding RF exposure limits for Proceeding Number 13-84.

The FCC has no health expertise and relies upon Federal health agencies, especially the FDA, for advice about RF exposure limits. However, these agencies have lacked the requisite expertise to provide this guidance as their RF health experts retired or took industry jobs. In the past decade, these agencies have failed to monitor the vast and growing body of peer-reviewed research that documents adverse health effects from low-intensity exposure to radiofrequency radiation. Rather, the Federal government has increasingly relied upon advice from engineers and scientists with conflicts of interest and industry lobbyists.

Following is an index of key submissions to the FCC regarding RF exposure limits and RF health effects since mid-2012.

November 1, 2019 

Selected FCC Submissions re: 

"Reassessment of Federal Communications Commission Radiofrequency 

Exposure Limits and Policies" (Proceeding Number 13-84)

Part I: Key Testimony Submitted to the FCC

Last revision: October 1, 2019
The FCC received more than 1,200 submissions regarding its cell phone radiation regulations. These documents reveal what we know about wireless radiation health effects, and why we need to strengthen regulations and provide precautionary warnings to the public.
In response to the Federal Communications Commission's (FCC) request for input regarding its radiofrequency radiation regulations adopted in 1996, individuals and organizations submitted thousands of documents, testimonials, research papers and scientific publications that are now available to the public. 
These documents reveal what we know about wireless radiation health effects, and why we need to strengthen regulations and provide precautionary warnings to consumers.

Although more than fifteen countries have issued precautionary health warnings about cell phone radiation and recommendations about how to reduce risks, the wireless industry in the U.S. has opposed precautionary warnings and wants to weaken cell phone radiation standards.
In all, the FCC received more than 1,200 submissions between June 25, 2012 and November 1, 2019. Many submissions include multiple documents. The preponderance of submissions call on the FCC to adopt stronger exposure limits on radiofrequency radiation.
Hundreds of individuals submitted statements that document their personal health problems and diseases experienced from exposure to radiofrequency radiation. These and other submissions can be viewed or downloaded by clicking on Proceeding Number 13-84 on the FCC web site.
The FCC's obsolete RF exposure limits are 23 years old. The current request for public input is six years old. The FCC never reported on or acted upon a similar request for public input issued in 2003.
In 2015, a Harvard publication exposed how industry captured the FCC, "As a captured agency, the FCC is a prime example of institutional corruption. Officials in such institutions do not need to receive envelopes bulging with cash. But even their most well-intentioned efforts are often overwhelmed by a system that favors powerful private influences, typically at the expense of public interest."
Obviously, updating RF regulations and testing procedures has not been a priority for the FCC even though the U.S. General Accountability Office recommended this in 2012.
Although there is a search engine on the FCC web site, one cannot easily find important documents. Hence, I constructed several indices.
Part I which appears below contains key submissions to the FCC regarding cell phone radiation and its health effects, and cell phone testing procedures and regulatory standards.

The submissions are organized under the following categories:

(1) Scientific Expert Resolutions Calling for Stronger Regulations
(2) Expert Comments in Support of Stronger Regulations
(3) Expert Comments that Support Weaker Regulations
(4) Consumer, Environmental and Health Organizations
(5) Government Agencies
(6) Wireless Industry Corporations and Associations
(7) Miscellaneous Other 
Not indexed below are submissions from individuals without organizational or institutional affiliations.  Many of these submissions discuss electromagnetic hypersensitivity (EHS).
Part II contains a list of key research papers that can be downloaded from the FCC web site. (updated Aug 11, 2019)
Part III lists 98 scientific experts from 23 nations who have signed resolutions between 2002 and 2014 that call for stronger regulations on wireless radiation, especially cell phone radiation.
In 2015, scientists who published peer-reviewed research on the health effects of electromagnetic fields (EMF) submitted a petition to the United Nations, the World Health Organization, and all world leaders calling for stronger regulations on exposure to radiofrequency radiation than current national and international exposure limits allow. The International EMF Scientist Appeal was also submitted to the FCC.
The Appeal has been signed by more than 240 scientists who have published peer-reviewed research on electromagnetic fields and biology and health. These scientists representing over 40 nations have published more than 2,000 papers and letters on EMF in professional journals. This petition was recently submitted to the United Nations Environment Programme. 
Part IV summarizes the responses of 184 persons with self-reported electromagnetic hypersensitivity (EHS) who submitted comments to the FCC and reported either their symptoms or the sources of their problematic exposure to radio frequency radiation.

Scientific Expert Resolutions Calling for Stronger Regulations  
Catania Resolution (2002; 16 signees)

Benevento Resolution (2006; 52 signees)
Seletun Scientific Panel (2009); 7 signees)
Health Canada Safety Code 6 Declaration  (Jul 9, 2014; 54 signees)
The International EMF Scientist Appeal (May 11, 2015; 200 signees)
The International EMF Scientist Appeal (Aug 25, 2019; 250 signees)
The 5G Appeal (2017 moratorium; signed by 245 scientists and doctors)

Expert Comments in Support of Stronger Regulations
Omer Abid, MD, MPH

David Adams, PhD
Norm Alster ("FCC captured agency")
Frank Barnes, PhD

BioInitiative Working Group (29 contributing authors)
Martin Blank, PhD
David O. Carpenter, MD

Neil Cherry, PhD
Richard H. Conrad, PhD

Devra L. Davis, PhD, MPH
Devra Davis PhD MPH, Alvaro de Salles PhD, Susan Downs MD, Gunnar Heuser MD PhD, Anthony Miller MD. Lloyd Morgan BSEE, Yael Stein MD. Elihu Richter MD MPH (rebuttal of CTIA's claims)

Alan H. Frey

Om Gandhi, PhD

Livio Giulani, PhD

Lennart Hardell, MD, PhD
Martha Herbert, MD, PhD
Isaac Jamieson, PhD
Toril Jeter, MD, FAACP
Olle Johansson, PhD
Suleyman Kaplan, PhD
Henry C. Lai, PhD

Victor Leach / Simon Turner   
Dariusz Leszczynski, PhD
B. Blake Levitt

De-Kun Li, MD, PhD, MPH

James C. Lin, PhD
Don Maisch, PhD
Lloyd Morgan, BSEE

Joel M. Moskowitz, PhD
Martin Pall, PhD
Jerry L. Phillips, PhD
Ronald M. Powell, PhD
William J. Rea, MD
Cindy Lee Russell, MD
Cindy Sage, Lennart Hardell, MD & Martha Herbert, MD, PhD

Cindy Sage & David O. Carpenter, MD

J. Bertel Schou, PhD & Diane Schou, PhD

Miriam D. Weber, MD

Grace Ziem, MD, MPH, DrPH

Expert Comments that Support Weaker Regulations
Joe A. Elder, PhD

Consumer, Environmental and Health Organizations

American Academy of Environmental Medicine

Center for Electrosmog Prevention

Electromagnetic Safety Alliance, Inc.
EMF Safety Network

Environmental Health Trust
Environmental Working Group
Environmental Working Group (petition w/ 26,000 signatures):
Global Union Against Radiation Deployment from Space

Pharmacists Planning Service Inc (PPSI)

Stop Smart Meters New York

Wireless Education Action

Government Agencies

Cities of Boston, Massachusetts and Philadelphia, Pennsylvania
Environmental Protection Agency
FCC Office of the Chairman (Response to Sen. Blumenthal & Rep. Eshoo)
FCC Office of Engineering Technology Bureau
Food and Drug Administration (FDA)
International Agency for Research on Cancer, World Health Organization

Los Angeles Unified School District

Town of Hillsborough, California
Montgomery County, Maryland 
National Cancer Institute & National Institute of Environmental Health Sciences 
National Institute for Occupational Safety and Health

City of Portland, Oregon

City and County of San Francisco

Radiation Protection Division, Environmental Protection Agency
Radiofrequency Interagency Working Group (Federal)
City of Tucson and County of Pima, Arizona Resolution

U.S. Department of Labor

Wireless Industry Corporations and Associations

Alarm Industry Communications Committee

ARRL, the National Association for Amateur Radio

Fixed Wireless Communications Coalition

GSM Association

IEEE International Committee on Electromagnetic Safety (ICES) 
Medtronic Inc
MMWave Coalition 
Momentum Dynamics Corporation and Oak Ridge National Laboratory

National Association of Broadcasters

National Association of Telecommunications Officers and Advisors

PCIA-The Wireless Infrastructure Association and The HetNet Forum

Telecommunications Industry Association
Richard Tell Associates

American Association for Justice
Austrian Medical Association 
California Medical Association
Council of Europe - Resolution 1815
Senator Bill Galvano (Florida)
Green Swan, Inc.
National Assn. of Telecommunications Officers, National League of Cities, National Assn of Counties, & U.S. Conference of Mayors
North America's Building Trade Unions