Tuesday, December 1, 2020

Government Accountability Office (GAO) 2020 Report on 5G

November 30, 2020 (Updated December 1, 2020)

 On November 24, 2020, the U.S. Government Accountability Office (GAO) published a report on 5G. The GAO recognizes that public concern regarding the health effects from exposure to radiofrequency radiation (RFR) is likely to intensify with the deployment of 5G technology.

The report acknowledges that policy makers are faced with a challenge as they need relevant information on the health effects of 5G, but long-term effects are unknown. The report recommends that "(p)olicymakers will need to identify a funding source or determine which existing funding streams to reallocate" to pay for the needed research. 

The GAO interviewed government officials who dismissed the research on RFR health effects: "Officials from federal regulatory and research agencies did not indicate any cause for alarm due to these unknowns because of the research from observational studies on pre-5G technology and from experimental studies of high-band 5G technology." 

How can these officials ignore the results of the government's $30 million study which proved that long-term exposure to RFR caused cancer or the Ramazzini Institute study which reproduced these results using much lower intensity RFR? How can they ignore the results of epidemiologic studies that find increased tumor risk among heavier cell phone users?

"In 2008, a committee convened by the National Research Council (part of the National Academies of Sciences, Engineering, and Medicine) reported that further research was needed to characterize exposure to RF energy in juveniles, young children, and pregnant women and fetuses in observational studies." So why didn't our government fund the research needed to ask the critical questions re: RFR exposure that would enable our health agencies to adopt protective safety limits?

"While research on the biological effects of RF energy has been underway for decades, FDA officials do not expect changes to the current safety standards from 5G technology."

For more than two decades, FDA officials have ignored the lack of consensus in the scientific community regarding the safety of RFR. The majority of scientists who study RFR effects now believe that current RFR national and international safety standards are inadequate to protect our health. More than 240 scientists from 44 countries who have published over 2,000 papers in professional journals on electromagnetic fields (EMF) and biology or health have signed the International EMF Scientist Appeal which calls for stronger safety standards and health warnings.

The GAO report also failed to mention the 5G Appeal signed by more than 400 scientists and doctors who have demanded a moratorium on the deployment of 5G. 

Government Accountability Office (GAO-21-26SP), Nov 24, 2020

What GAO Found

Fifth-generation (5G) wireless networks promise to provide significantly greater speeds and higher capacity to accommodate more devices. In addition, 5G networks are expected to be more flexible, reliable, and secure than existing cellular networks. The figure compares 4G and 5G performance goals along three of several performance measures.

Note: Megabits per second (Mbps) is a measure of the rate at which data is transmitted, milliseconds (ms) is a measure of time equal to one thousandth of a second, and square kilometer (km²) is a measure of area.

As with previous generations of mobile wireless technology, the full performance of 5G will be achieved gradually as networks evolve over the next decade. Deployment of 5G network technologies in the U.S. began in late 2018, and these initial 5G networks focus on enhancing mobile broadband. These deployments are dependent on the existing 4G core network and, in many areas, produced only modest performance improvements. To reach the full potential of 5G, new technologies will need to be developed. International bodies that have been involved in defining 5G network specifications will need to develop additional 5G specifications and companies will need to develop, test, and deploy these technologies. GAO identified the following challenges that can hinder the performance or usage of 5G technologies in the U.S.

GAO developed six policy options in response to these challenges, including the status quo. They are presented with associated opportunities and considerations in the following table. The policy options are directed toward the challenges detailed in this report: spectrum sharing, cybersecurity, privacy, and concern over possible health effects of 5G technology.

Policy options to address challenges to the performance or usage of U.S. 5G wireless networks

Policy OptionOpportunitiesConsiderations

Spectrum-sharing technologies (report p. 47)

Policymakers could support research and development of spectrum sharing technologies.

  • Could allow for more efficient use of the limited spectrum available for 5G and future generations of wireless networks.
  • It may be possible to leverage existing 5G testbeds for testing the spectrum sharing technologies developed through applied research.
  • Research and development is costly, must be coordinated and administered, and its potential benefits are uncertain. Identifying a funding source, setting up the funding mechanism, or determining which existing funding streams to reallocate will require detailed analysis.

Coordinated cybersecurity monitoring (report p. 48)

Policymakers could support nationwide, coordinated cybersecurity monitoring of 5G networks.

  • A coordinated monitoring program would help ensure the entire wireless ecosystem stays knowledgeable about evolving threats, in close to real time; identify cybersecurity risks; and allow stakeholders to act rapidly in response to emerging threats or actual network attacks.
  • Carriers may not be comfortable reporting incidents or vulnerabilities, and determinations would need to be made about what information is disclosed and how the information will be used and reported.

Cybersecurity requirements (report p. 49)

Policymakers could adopt cybersecurity requirements for 5G networks.

  • Taking these steps could produce a more secure network. Without a baseline set of security requirements the implementation of network security practices is likely to be piecemeal and inconsistent.
  • Using existing protocols or best practices may decrease the time and cost of developing and implementing requirements.
  • Adopting network security requirements would be challenging, in part because defining and implementing the requirements would have to be done on an application-specific basis rather than as a one-size-fits-all approach.
  • Designing a system to certify network components would be costly and would require a centralized entity, be it industry-led or government-led.

Privacy practices (report p. 50)

Policymakers could adopt uniform practices for 5G user data.

  • Development and adoption of uniform privacy practices would benefit from existing privacy practices that have been implemented by states, other countries, or that have been developed by federal agencies or other organizations.
  • Privacy practices come with costs, and policymakers would need to balance the need for privacy with the direct and indirect costs of implementing privacy requirements. Imposing requirements can be burdensome, especially for smaller entities.

High-band research (report p. 51)

Policymakers could promote R&D for high-band technology.

  • Could result in improved statistical modeling of antenna characteristics and more accurately representing propagation characteristics.
  • Could result in improved understanding of any possible health effects from long-term radio frequency exposure to high-band emissions.
  • Research and development is costly and must be coordinated and administered, and its potential benefits are uncertain. Policymakers will need to identify a funding source or determine which existing funding streams to reallocate.
Status quo (report p. 52)
  • Some challenges described in this report may be addressed through current efforts.
  • Some challenges described in this report may remain unresolved, be exacerbated, or take longer to resolve than with intervention.

Why GAO Did This Study

GAO was asked to assess the technologies associated with 5G and their implications. This report discusses (1) how the performance goals and expected uses are to be realized in U.S. 5G wireless networks, (2) the challenges that could affect the performance or usage of 5G wireless networks in the U.S., and (3) policy options to address these challenges.

To address these objectives, GAO interviewed government officials, industry representatives, and researchers about the performance and usage of 5G wireless networks. This included officials from seven federal agencies; the four largest U.S. wireless carriers; an industry trade organization; two standards bodies; two policy organizations; nine other companies; four university research programs; the World Health Organization; the National Council on Radiation Protection and Measurements; and the chairman of the Defense Science Board's 5G task force. GAO reviewed technical studies, industry white papers, and policy papers identified through a literature review. GAO discussed the challenges to the performance or usage of 5G in the U.S. during its interviews and convened a one-and-a-half day meeting of 17 experts from academia, industry, and consumer groups with assistance from the National Academies of Sciences, Engineering, and Medicine.

GAO received technical comments on a draft of this report from six federal agencies and nine participants at its expert meeting, which it incorporated as appropriate.

For more information, contact Hai Tran at (202) 512-6888, tranh@gao.gov or Vijay A. D’Souza at (202) 512-6240, dsouzav@gao.gov.

The 2020 GAO report can be downloaded: from https://www.gao.gov/assets/720/710861.pdf .

Excerpt from the 2020 GAO report (pp. 40-45)

"3.4 Concern over possible health effects

The deployment of 5G technology, including the numerous small cell base stations needed to transmit and receive high-band frequencies, may exacerbate existing public concerns that RF energy exposure may cause cancer 93 or otherwise endanger human health, although there is limited evidence to support these concerns. Several U.S. localities, private citizens, and non-profits have filed lawsuits involving the deployment of 5G, including claims that the FCC has failed to update its RF exposure limits in light of the new technology. 94 Health concerns have also interrupted 5G deployment abroad, with several Swiss communities delaying rollouts, and protesters in the United Kingdom and the Netherlands damaging 5G towers.

To respond to public concerns, decision makers need policy-relevant information on the long-term health effects of 5G technology. Although there is currently no consistent evidence of health risks related to 5G RF exposure in humans, responding to public concerns remains a challenge, in part due to the possibility of unknown long-term health effects and the challenges in researching this topic.

3.4.1 Unknown long-term health effects

While research on the biological effects of RF energy has been underway for decades, research on the long-term health effects of pre-5G technology is ongoing and research on the possibility of long-term health effects of 5G technology is largely unknown because the technology is still new and has not been widely deployed.

Officials from federal regulatory and research agencies did not indicate any cause for alarm due to these unknowns because of the research from observational studies on pre-5G technology and from experimental studies of high-band 5G technology. 95 The National Cancer Institute (NCI) reviewed three large observational studies and several smaller observational studies of humans exposed to pre-5G technology. 96 The results of the large studies were inconsistent in linking cell phones and cancer outcomes and methodological challenges may have affected the findings. A few of the smaller studies showed a relationship with non-malignant tumors. 5G technology introduces RF energy at higher frequencies than used for existing cellular communications systems. However, higher frequencies have less penetration into the human body and therefore are thought to be less of a concern than lower frequencies.

While research on the biological effects of RF energy has been underway for decades, FDA officials do not expect changes to the current safety standards from 5G technology.

According to officials, the unknown long-term health effects and R&D opportunities related to 5G technology include the following:

• High-band 5G frequencies. The latest IEEE standard on electromagnetic safety published in 2019 focused on the effects of frequencies above 6 GHz in experimental studies. However, no studies have been carried out on the long-term health effects of high-band 5G frequencies in observational studies, such as those in settings experienced by the general public, because the technology has not been deployed for long enough or widely enough to conduct these studies. According to an NCI scientist, even after high-band 5G technology has been put into use in the coming years, the long-term health effects on people, if any, may not be known for many years later because some health outcomes could take decades to develop. The high-band frequencies used in 5G will only be available for observational studies once 5G technology has been deployed widely. A National Institutes of Health scientist noted that the 5G frequencies are still not clearly defined, making it difficult to understand the impact on human exposure.

• Active antennas with beamforming. FCC stated that RF exposure below the exposure limits are safe. However, no research has been conducted to characterize long-term exposure to the multiple active antennas with beamforming that are a feature of 5G. It is unknown how the signals from these antennas may affect human health in the long-term. It could be computationally intensive to study the long-term exposure to these antennas due, in part, to their many possible configurations, which may increase or decrease the RF energy exposure. According to NIST experts, a statistical model is needed to study these configurations, and it will be necessary to evaluate this model against measurements of actual systems. NSF officials believe that artificial intelligence techniques have the potential to better address this modeling challenge.

• Certain high-risk populations, cancer, and non-cancer outcomes. In 2008, a committee convened by the National Research Council (part of the National Academies of Sciences, Engineering, and Medicine) reported that further research was needed to characterize exposure to RF energy in juveniles, young children, and pregnant women and fetuses in observational studies. 97 An NCI scientist we interviewed reiterated these unknown long-term health effects for pre-5G technology and with respect to 5G. Further research was also needed for non-cancer outcomes, such as developmental and behavioral outcomes, according to the committee proceedings and the NCI scientist. Observational studies may be used to study health outcomes that take years and decades to behavioral, and cancer outcomes. However, as mentioned above, there have been no observational studies on the long-term health effects of high-band 5G frequencies because the technology is still new.

3.4.2 Research challenges

Challenges in understanding research on the possibility of long-term health effects of exposure to RF energy from pre-5G and 5G technology include: (1) measuring RF exposure to populations, and (2) synthesizing research for decision makers and for the public.

Measuring population exposure to RF

Measuring RF exposure in observational studies is a challenge, but these types of studies are of interest in making policy relevant recommendations. Observational studies ask participants to report their current cell phone use, or attempt to measure RF exposure. Yet asking participants about their current cell phone use or using cell phone call logs may not be a good proxy for RF exposure, since people may use phones for more than voice calls and call logs do not account for potential exposure to surrounding small cells and base stations, Wi-Fi networks, and other environmental exposures. NCI scientists noted that cancer and other chronic exposures require collection of not only current RF exposures, but past RF exposures that may contribute to total exposure. The type of RF exposure relevant to health outcomes is also unknown whether it be peak exposure or cumulative, according to NCI scientists. However, none of the recent observational studies attempted to estimate the entire accumulated RF dose in the individual environments of the study subjects.

To better address the measurement of RF exposure in future studies involving high-band frequencies, an NCI scientist noted that studies that measure exposure to RF energy and the amount of RF energy deposited into the body (dosimetry) would first need to be performed to prepare for human observational studies and to help understand how exposure is different with 5G technology.

Synthesizing research for decision makers and the public

Due to the challenges of measuring long-term exposure to RF energy and unavailability of the evidence at this time, assessments of 5G technology will likely be based on human or animal experimental studies (usually short-term) and human observational studies that rely on self-reporting exposure to RF energy, all of which have limitations. The experimental studies may not be relevant to long-term human exposure to RF energy as studies conducted over a shorter period may not detect outcomes that take decades to develop. As noted above, self-reporting may not be a good proxy for total, peak, or cumulative exposure to RF energy.
Because there is a large and evolving body of relevant research, it is important that the results be regularly synthesized for Congress and the public. The FCC relies on the FDA as well as other organizations—principally IEEE and the National Council on Radiation Protection and Measurements (NCRP)—to review scientific research and provide recommendations for setting RF safety standards. 98 However, each of these organizations has only reviewed a subset of the relevant research and, of these organizations, only IEEE updates its formal assessments regularly. Specifically:

• According to officials, the FDA monitors peer-reviewed science regarding RF energy and health. The agency does not typically make its assessments publicly available, but released one assessment publicly in February 2020. 99 The assessment focused on cancer-related animal and human studies of frequencies below 6 GHz. The assessment did not include non-cancer outcomes or frequencies above 6 GHz. The agency does not have plans to update this review for the FCC unless it becomes aware of research that would lead it to change its current assessment, that the current scientific evidence has not linked RF energy from cell phones with health problems in humans. 

• IEEE has periodically published standards for RF energy exposure in 1991, 2005, and 2019.100 While IEEE does include reviews of observational studies of frequencies below 6 GHz in its latest standard, its assessment of those studies was that many were weak in terms of their design and exposure assessment. The IEEE noted, “while the available results do not indicate a strong causal association, they cannot establish the absence of a hazard.” The review did not include observational studies above 6 GHz because the technology has not been deployed for long enough or widely enough to conduct these studies, as mentioned above.

• NCRP reviewed two larger observational studies in its 1986 review; however, it has not published an update since. 101 The studies reviewed included a retrospective study of U.S. naval personnel conducted by the National Academies of Sciences and a retrospective study of American embassy personnel in Moscow conducted by Johns Hopkins University. 102  Neither study found evidence of an association between RF energy and adverse outcomes. The naval study used occupation as a proxy for exposure to RF energy, and the embassy study was not able to obtain complete information on exposures and outcomes for participants. These studies focused on persons occupationally exposed to RF energy and may not be relevant to public exposure to RF energy."

Agency comments

"We provided a draft of this product to the Departments of Commerce, Energy, and Health and Human Services; DHS; DOD; FCC; and NSF for their review. DOD told us that they had no technical comments on the draft report; the remaining six agencies provided technical comments, which we incorporated as appropriate. Participants in our expert meeting from CTC Technology & Energy, CTIA, Google, Illinois Institute of Technology, National Consumer Law Center, Nokia—North and South America, PwC, University of Colorado, and U.S. Cellular also reviewed a draft of this product; we incorporated their technical comments as appropriate."

Appendix I

"To understand the health effects of wireless technology, we interviewed officials from the Department of Health and Human Services, the National Council on Radiation Protection and Measurements, and the World Health Organization; reviewed safety standards; and reviewed assessments published by DOD, FDA, and the National Institutes of Health. We also requested and reviewed a DOD bibliography of peer-reviewed articles, technical notes, technical reports, and special reports published in fiscal years 1997 through 2019 on the physiological effects of microwave or millimeter wave energy."


93 The RF spectrum used in cellular communications has not been definitively linked to cancer or other health outcomes, according to FCC and FDA. The lower frequencies of the radio frequency spectrum that are used for wireless communication, including 5G communication, are considered “nonionizing radiation” because these frequencies lack sufficient energy to remove electrons from atoms and molecules. In contrast, X-rays are considered “ionizing” radiation, which can have significant human health effects and are known to increase the risk of cancer. The radio frequencies used by cellular communications systems can lead to tissue heating, but is not thought to emit enough RF energy to cause harmful heating.

94 The U.S. Court of Appeals for the Ninth Circuit dismissed a challenge claiming that FCC failed to reassess its RF exposure limits, because, by the time of the decision, FCC had completed its evaluation of the effects of 5G technology on its RF updated. City of Portland v. United States, 969 F.3d 1020, 1046-47 (9th Cir. 2020). FCC’s evaluation and decision not to update its RF exposure limits is currently being challenged in the D.C. Circuit Court of Appeals. Brief of Petitioners at 65-69, Environmental Health Trust v. FCC, No. 20-1025 (D.C. Cir. July 29, 2020).

95 Experimental studies are those in which the exposure to RF energy is determined by the investigator. Observational studies are those where exposure to RF energy is observed (usually reported or measured).

96 NCI reviewed the Interphone, Million Women Study, Danish Registry Linkage Study, which all evaluated 2G and 3G technologies; RF exposure from high-band 5G technology was not evaluated in these studies. 

97 National Research Council, Identification of Research Needs Relating to Potential Biological or Adverse Health Effects of Wireless Communication Devices, National Academies Press (Washington, D.C.: 2008).

98 While other organizations synthesize the literature on RF energy and health outcomes, we focus on the three organizations (FDA, IEEE, and NCRP) that FCC principally relies on for synthesizing the literature and providing recommendations for setting RF safety standards. NCRP was chartered in law by the U.S. Congress in 1964 to collect, analyze, and disseminate information and recommendations about radiation protection in the public interest. Pub. L. No. 88-376, 78 Stat. 320 (1964). The International Commission on Non-ionizing Radiation Protection (ICNIRP) also synthesizes experimental and observational studies. It is an independent, non-governmental organization chartered in Germany that provides guidelines followed by several European Union countries. IEEE and ICNIRP have been working to harmonize their standards.

99 FDA, Review of Published Literature between 2008 and 2018 of Relevance to Radiofrequency Radiation and Cancer (Silver Spring, Md.: February 2020).

100 According to IEEE officials, the standards have a 10-year revision cycle. However, the standard is a “living” document that may be revised sooner, for example, if the conclusions of an ongoing World Health Organization Environmental Health Criteria systematic review reveal any significant results.

101 NCRP Report No. 86, Biological Effects and Exposure Criteria for Radiofrequency Electromagnetic Fields, 1986. According to an NCRP official, NCRP produces reports at the request and funding of federal agencies. NCRP has not been funded to update Report No. 86.

102 Observational studies may be prospective or retrospective. In prospective studies, participants are enrolled and data are collected on their current exposures. Then, participants are followed up over a period of time (some cohort studies have been ongoing for years) to observe outcomes that develop. In retrospective studies, participants are enrolled and asked about exposures and outcomes that have already occurred. The benefit of a prospective study is that it is less subject to recall bias, which may be present in retrospective studies where outcomes are known and participants are asked to report past exposure.