The U.S. Government Accountability Office (GAO) released a report on August 7, 2012, titled “Exposure and Testing Requirements for Mobile Phones Should Be Reassessed.” The report states that “[s]cientific research to date has not demonstrated adverse human health effects of exposure to radio-frequency (RF) energy from mobile phone use, but research is ongoing that may increase understanding of any possible effects.”

Nevertheless, the report recommends that the Federal Communications Commission (FCC) formally reassess the current exposure limit for RF energy from mobile phone use. Notably, this conclusion is based on the fact that since the FCC adopted its limit, the IEEE revised its standard to 2.0 watts per kilogram over ten grams of tissue, as opposed to the current FCC standard of 1.6 watts per kilogram over one gram of tissue. According to the report, the IEEE views this standard, which has been adopted by more than 40 countries, as representing “scientific consensus on RF energy exposure limits.”

The report also recommends that the FCC reassess its testing requirements to ensure that they identify the maximum exposure in likely use configurations, particularly when phones are held against the body.

  1. Background
  • GAO was asked to examine issues related to mobile phone health effects and regulation, given that the “rapid adoption of mobile pones has occurred amidst controversy over whether the technology poses a risk to human health.” (2012 GAO RF Report, Highlights).
  • The report updates information related to mobile phone health effects and regulatory addresses. The report specifically addresses (1) what is known about the human health effects of RF energy exposure from mobile phone use, and the current research activities by federal agencies and other organizations on this issue; (2) how the FCC has set the limit for RF energy exposure and how it ensures compliance with the limit; and (3) what actions federal agencies and the mobile phone industry have taken to inform the public about issues related to mobile phone health effects. (2012 GAO RF Report, 2).
  1. “Research on RF Energy Exposure from Mobile Phones Has Not Demonstrated Adverse Health Effects, but More Studies are Underway”
  • “Scientific research to date has not demonstrated adverse human health effects from RF energy exposure from mobile phone use, but additional research may increase understanding of possible effects.” (2012 GAO RF Report, 6).
    • After another decade of scientific research, FDA stands by its 2001 conclusion that insufficient information is available to conclude that mobile phones pose no risk. The overall body of research does not demonstrate adverse health effects, but some individual studies suggest possible effects. (2012 GAO RF Report, 6). – The National Institutes of Health (NIH) officials interviewed by GAO, subject matter experts, and the IARC working group have reached similar conclusions. (2012 GAO RF Report, 6).
    • In May 2011, the International Agency for Research on Cancer (IARC) classified RF energy as “possibly carcinogenic.” It determined that the evidence from the scientific research for gliomas (a specific type of cancerous brain tumor) was limited and that the evidence was inadequate to permit a conclusion about the causal association with respect to other cancers. (2012 GAO RF Report, 6-7).
    • In April 2012, an advisory group to the United Kingdom’s Health Protection Agency concluded that “there is no convincing evidence that RF energy below guideline levels causes health effects in adults or children.” (2012 GAO RF Report, 7).
  • “[N]o single study can establish a cause-and-effect relationship, and limitations associated with studies can make it difficult to draw conclusions.” (2012 GAO RF Report, 7).
    • Though epidemiological studies are a key component of the body of research on this issue, they have limitations that make it difficult to draw definitive conclusions about whether adverse health effects are linked to RF energy exposure from mobile phone use. (2012 GAO RF Report, 9-10).
    • The epidemiological research has not demonstrated adverse health effects from RF energy exposure from mobile phone use, but the research is not conclusive because some studies (including INTERPHONE’s study) suggest a possible association with certain types of tumors. (2012 GAO RF Report, 8).
    • GAO reviewed a subset of epidemiological studies and interviewed experts on the epidemiological research. The report highlights the INTERPHONE study, analyses of a national cohort study conducted in Denmark, an international casecontrol study, and an NIH-led study. (2012 GAO RF Report, 8-9).
    • GAO also reviewed a subset of laboratory studies and interviewed experts on laboratory research, and concluded that the laboratory research has not demonstrated adverse human health effects from RF energy exposure from mobile phone use, but the research is not conclusive because some studies have observed effects on test subjects. GAO noted that there are limitations associated with laboratory studies that make it difficult to draw conclusions about adverse human health effects. (2012 GAO RF Report, 10).
  • Additional epidemiological studies, including case-control studies on children, could increase knowledge on potential risks. Additional laboratory studies on animals, human cells, and human volunteers could also increase knowledge of potential biological and health effects of RF energy. (2012 GAO RF Report, 12).
  • Some experts have noted that, “absent clear evidence for adverse health effects, it is difficult to justify investing significant resources in research on non-thermal effects of RF energy from mobile phone use.” (2012 GAO RF Report, 12).
  • The broader body of evidence on RF energy should be re-evaluated when key studies become available to determine whether additional research is needed. (2012 GAO RF Report, 12).
  • Federal agencies, international organizations and the mobile phone industry fund and support ongoing research. (2012 GAO RF Report, 12-15).
    • NIH is the only federal agency directly funding ongoing studies at this time.
    • The Food and Drug Administration’s (FDA) National Center for Toxicological Research is currently conducting studies.
    • The Centers for Disease Control (CDC) is collaborating with others to conduct studies, including a study to conduct additional analyses on the data collected from the INTERPHONE study.
    • IARC and the European Commission are also coordinating and supporting further research.
  1.  “FCC’s RF Energy Exposure Limit May Not Reflect Latest Evidence on Thermal Effects, and Mobile Phone Testing Requirements May Not Identify Maximum Exposure.”
  • Updating RF Emissions Limits
    • The FCC’s current standard for RF energy exposure from mobile phones is 1.6 watts per kilogram averaged over one gram of tissue, developed from input from federal health and safety agencies as well as a 1991 recommendation from the Institute of Electrical and Electronics Engineers (IEEE). (2012 GAO RF Report, 16).
    • In 2006, IEEE updated its recommendation to an exposure limit of 2.0 watts per kilogram averaged over ten grams of tissue, based on improved RF energy research and a better understanding of the thermal effects of RF energy exposure. This recommendation was harmonized with an earlier recommendation of the International Commission on Non-Ionizing Protection, which has been adopted by more than 40 countries, including the EU countries. According to the IEEE, this standard reflects a “scientific consensus on RF energy exposure limits.” (2012 GAO RF Report, 17).
    • “[B]y not formally reassessing its current RF energy exposure limit, FCC cannot ensure that it is using a limit that reflects the latest evidence on thermal effects from RF energy exposure, and may impose additional costs on manufacturers and limitations on mobile phone design.” The current FCC limit was based on recommendations made more than 20 years ago. (2012 GAO RF Report, 18-19).
    • “Officials from FDA and EPA told [the GAO] that FCC has not formally asked either agency for an opinion on the RF energy limit. FDA officials noted, though, that if they had a concern with the current RF energy exposure limit, then they would bring it to the attention of FCC.” (2012 GAO RF Report, 18).
    • Consumer groups oppose the new limit because it would allow users to be exposed to higher RF energy levels. (2012 GAO RF Report, 19).
      • Three of the four mobile phone manufacturers interviewed by GAO support harmonization of the RF energy limits, as many phones are sold in multiple countries. The report notes that lack of harmonization may limit the availability of certain features, impact performance of wireless devices, and impose additional costs. (2012 GAO RF Report, 19).
  • Reassessing Testing Procedures
    • The FCC ensures compliance with the current limit by certifying all mobile phones sold in the United States. Manufacturers are generally satisfied with the review and certification of mobile phones, but complex certifications can take a long time to process. (2012 GAO RF Report, 19-20).
    • Manufacturers conduct tests on phones following standardized FCC testing procedures or, in some complex cases, alternative procedures approved by the FCC. Testing procedures call for use against the ear or against the body (while in accessories such as a holster) but these requirements may not identify the maximum exposure under other conditions. Exposure in excess of the FCC’s limit could occur. (2012 GAO RF Report, 22-23).
    • The FCC has not reassessed its testing requirements to ensure that testing identifies the maximum RF energy exposure for other usage conditions. (2012 GAO RF Report, 23-24).
    • The FCC also conducts “post-market surveillance” to ensure that phones continue to meet the current RF standard. No mobile phone tested under this program has been found in violation. (2012 GAO RF Report, 24).
  1. “Federal Agencies and Mobile Phone Industry Provide Information to the Public through Websites and User Manuals.”
  • Federal agencies provide information to the public on the health effects of mobile phone use and related issues primarily through their websites. These websites include summaries of research and agencies’ conclusions about the health effects of mobile phone use. Websites of the CDC, EPA, FCC, FDA, NIH, and Occupational Safety and Health Administration (OSHA) also include suggestions on how mobile phone users can reduce their exposure to RF energy. This information varies based on the agencies’ different missions, but they provide a broadly consistent message. (2012 GAO RF Report, 24-25).
    • Some consumer groups and experts raised concerns that this information was not precautionary enough. Officials at the FCC and NIH maintained “the information on their websites reflects the latest scientific evidence and provides sufficient information for consumers concerned about potential health effects.” (2012 GAO RF Report, 25).
    • Some consumer groups want the FCC to mention IARC’s classification of RF as “possibly carcinogenic.” The FCC notes that it generally defers to the health and safety agencies for reporting new research, though there is information on the INTERPHONE study available on the website as of June 2012. (2012 GAO RF Report, 26).
    •  The FDA website notes that the IARC classification means there is limited evidence of carcinogenicity in experimental animals. (2012 GAO RF Report, 26).
  • Some local governments are taking steps to provide precautionary information to consumers. San Francisco has developed a website on mobile phone health issues, “including steps to reduce RF energy exposure from mobile phone use, and has passed an ordinance requiring local mobile phone retailers to distribute a flyer on ways that consumers can reduce their exposure.” (This ordinance has been challenged and is currently on appeal to the U.S. Court of Appeals for the Ninth Circuit.) (2012 GAO RF Report, 26).
  • “The mobile phone industry provides information to consumers on the health effects of mobile phone use and related issues through user manuals and websites.” This information is provided voluntarily. Most manuals provide information on how devices are tested and certified, and some also provide suggestions on how to minimize RF exposure. All but one manual include a statement that a minimum distance between the body and the phone should be maintained. (2012 GAO RF Report, 26-27).
  1. Conclusions
  • The FCC’s current RF energy exposure limit for mobile phones “may not reflect the latest evidence” and “may impose additional costs on manufacturers and limitations on mobile phone design.” (2012 GAO RF Report, 27).
  • The FCC “has not formally asked FDA or EPA for their assessment of the limit since 1996, during which time there have been significant improvements in RF energy research and therefore a better understanding of the thermal effects of RF energy exposure.” International organizations have updated their exposure limit recommendation to reflect the improved research, which suggests a less restrictive limit than the current FCC regulations. (2012 GAO RF Report, 27).
  • A reassessment of the current RF energy exposure limit would ensure that the FCC’s limit protects the public from exposure to RF energy while allowing industry to provide telecommunications services in the most efficient and practical manner possible. (2012 GAO RF Report, 27).
  • The current testing requirements for mobile phones may not identify the maximum RF energy exposure when tested against the body. By testing mobile phones only when at a distance from the body, the FCC may not be identifying the maximum exposure, since some users may hold a mobile phone directly against the body while in use. (2012 GAO RF Report, 27-28).
  • Reassessing its testing requirements would allow the FCC to ensure that phones used by consumers in the United States do not result in RF energy exposure in excess of the FCC’s limit. (2012 GAO RF Report, 28).
  1. Recommendations for Executive Action
  • The FCC Chairman should:
    • Formally reassess the current RF energy exposure limit (including its effects on human health), the costs and benefits associated with keeping the current limit, and the opinions of relevant health and safety agencies, and change the limit if determined appropriate. (2012 GAO RF Report, 28).
    • Reassess whether mobile phone testing requirements result in the identification of maximum RF energy exposure in likely usage configurations, particularly when mobile phones are held against the body, and update testing requirements as appropriate. (2012 GAO RF Report, 28).
  1. Agency Comments and GAO Evaluation
  • The FCC provided comments from the Chief of the Office of Engineering and Technology. In it, the FCC noted that the FCC’s staff has independently arrived at the same conclusions about RF exposure guidelines as the GAO. The FCC also noted that a draft Order and Further Notice of Proposed Rulemaking, along with a new Notice of Inquiry, which has been submitted by the FCC staff to the Commission for their consideration, has the potential to address the recommendations made in this report. (2012 GAO RF Report, 28).
  • The GAO stated that since the FCC has not yet initiated a review of the RF energy exposure limit or mobile phone testing requirements, its recommendations are still relevant. (2012 GAO RF Report, 28).
  1. Appendices
  • Appendix I reviews the scope and methodology of GAO’s research in preparation for the report, specifically by reviewing scientific research, interviewing subject matter experts, and interviewing officials from federal agencies.
  • Appendix II lists the scientific studies reviewed by GAO. GAO reviewed 38 studies.
  • Appendix III provides the text of a letter from Julius Knapp, Chief of the Office of Engineering and Technology at the FCC on GAO’s draft report.
    • Knapp calls the GAO report “thorough and cogent.”
    • Knapp notes “the report finds that scientific evidence to date has not demonstrated adverse human effects of [RF].”
    • The Commission staff has paid close attention to the developments in RF exposure research, and the FCC “believe[s] our current standards are appropriate and protect the public against the possible harmful effects of RF exposure.” However, the Commission appreciates that it has been many years since conducting a formal review of its standard.
    • Staff have drafted and presented to the Commission for consideration a combined Order and Notice of Proposed Rulemaking, along with a Notice of Inquiry to review the standards and related matters.
    • “[T]he Commission’s staff had independently arrived at the same conclusions as are reflected in the GAO report. We believe that the draft document correctly under consideration by the Commission has the potential to address and even expand on the recommendations in the GAO report to thoroughly review our RF safety rules.”