FCC Replies to RF Exposure Guideline Revisions Due
November 1 1


CautionFCCThe FCC has received more than 750 comments on its Notice of Inquiry (NOI) released March 29, 2013, on RF exposure limits and policies (set in 1997). The American Academy of Pediatrics weighed in by the deadline, calling for a review of exposure guidelines for children (the Notice of Inquiry specifically asked about this concern and AAP confirmed it).

Comments were due September 3, 2013, but several have been received since then and are listed on the FCC website. Some of the tardy comments appear to be followups to related issues. The International Brotherhood of Electrical Workers filed a comment September 17 expressing concerns about warning signage and the inability of technical workers to independently assess how much RF energy they are being exposed to in any given situation. Verizon submitted an ex parte document October 17 confirming a discussion with government officials about deployment, maintenance and operations of rooftop wireless transmitters.

Exposures to radiofrequency emissions from wireless transmitters on rooftops, whether experienced by electrical workers or by other contractors performing separate work in these locations, is just one of many issues with RF exposure.

Sunroom Desk’s earlier article on this FCC review included an excerpt from a comment submitted by B. Blake Levitt. Levitt subsequently submitted another comment, jointly, with Henry C. Lai, Research Professor Emeritus at the University of Washington. Excerpts:

The FCC expresses confidence in the current thermal-only basis, but acknowledges that with the rapid proliferation of wireless devices over the years, as well as the ubiquity of antennas needed for supportive infrastructure, and the new technological designs that allow much closer-to-the-body operation and medical implantation, that a new review is in order. The GAO report expressed similar confidence in the current methodology. This is in stark opposition to the most current data, and the direction that many other countries are taking regarding precautionary approaches.

Neither these authors, nor many expert members of the international research community, harbor the same confidence in such narrowly defined standards, which are premised upon understanding underlying biological mechanisms. Many now think that, given the peer-reviewed literature published since 1997,…setting an exposure threshold should based mainly on the knowledge at which level biological/health effects are observed, and not on the mechanism of the effects. Most of that research has come from outside of the U.S, including the recent classification of RF fields as a 2B (possible) carcinogen by the International Agency for Research on Cancer (IARC) at the World Health Organization (WHO). Indeed hundreds of studies have found biological/health effects at orders of magnitude below the current FCC thresholds. The changes regarding SAR allowances for the pinna (ear), as well as possible new setbacks from products and infrastructure, and potential new classifications that would supplant categorical exclusions, go nowhere near far enough in protecting public health and, in some areas, may serve to increase exposures to the general population.

…FCC proposes to standardize compliance via adopting thresholds of power, distance and frequency for routine environmental evaluation. Below the threshold of one milliwatt (1mW) of power or less, services or devices would be exempt, continuing the blanket exemption for the most popular and ubiquitous consumer products today, as well as those to be developed in the future. Yet no cumulative exposure criterion is set for radiating sources for myriad products operating simultaneously. Exemptions are taken one product or service at a time and with this ruling, FCC will continue that policy without setting levels for the sum of effects from different sources and cumulative effects over time, such as DNA damage in the genome that become larger with repeated exposure.

There has been an exponential increase for both low-level RFR fixed transmitters like wifi, and voluntary personal portable/mobile devices. This is in addition to involuntary exposures from accompanying infrastructure like cell towers with multiple providers, antennas mounted on/in existing structures, and DAS systems which bring RFR much closer to the population. There is an increasing new layer of RF with smart grid/metering — an involuntary direct RF delivery system into homes and businesses…Both personal environments and large ambient environmental RFR levels have risen dramatically in the last 20 years, and continue to do so.

The FCC’s replies to all comments are due November 1, 2013. New RF exposure limits and policies developed as a result of this process will affect not only commercial wireless providers, operators of private wireless networks, broadcasters, and technical workers, but also anyone working in proximity to wireless transmission facilities, owners and occupants of physical structures where transmitters are located, and users of wireless technology…in other words, almost everyone nationwide.

To see all the comments, go to the FCC’s Electronic Comment Filing System webpage, click Search for Filings, and enter 03-137 as the Proceeding Number (you may need to clear the date received box).

Photo credit: Mark_Smith’s Flickr photostream

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November 1

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