Comments were due September 3, 2013, for those individuals and organizations desiring to comment on the FCC’s “Notice of Inquiry” to assess its current radiofrequency (RF) exposure guidelines.

As stated in its Notice of Inquiry, the FCC has a responsibility to “provide a proper balance between the need to protect the public and workers from exposure to potentially harmful RF electromagnetic fields and the requirement that industry be allowed to provide telecommunications services to the public in the most efficient and practical manner possible.”  …  Such a “balance” involves an inherent conflict of interest between safety and corporate profits.

The FCC likely (and begrudgingly) initiated its review in response to a General Accounting Office report, dated July 2012, that stated: “By not formally reassessing its current limit, FCC cannot ensure it is using a limit that reflects the latest research on RF energy exposure.”

Unfortunately, the FCC gave indication in its Notice of Inquiry that it is not objective as an agency in its approach to the reassessment of RF exposure guidelines.  Let us look at two glaring examples of bias contained in the Notice of Inquiry.

1.  Risks for Non-Thermal Biological Effects Not Established?

The FCC describes its current exposure guidelines as “conservative.”  It then stated that despite its conservative limits, “there has been discussion of going even further to guard against the possibility of risks from non-thermal biological effects, even though such risks have not been established by scientific research.”

The problem with the above statement is there are literally hundreds and hundreds of scientific studies that demonstrate non-thermal biological effects.  For example, in December 2012, the “BioInitiative 2012 Report,” published by 29 highly respected health professionals from ten countries, comprehensively reviewed over 1,800 new studies.  In twenty-four technical chapters, the contributing authors of the “BioInitiative 2012 Report” discussed the content and implications of the new studies.  Overall, the studies were said to report:

• Abnormal gene transcription;
• Genotoxicity and single-and double-strand DNA damage;
• Stress proteins because of the fractal RF-antenna like nature of DNA;
• Chromatin condensation and loss of DNA repair capacity in human stem cells;
• Reduction in free-radical scavengers – particularly melatonin;
• Neurotoxicity in humans and animals;
• Carcinogenicity in humans;
• Serious impacts on human and animal sperm morphology and function;
• Effects on the fetus, neonate and offspring;
• Effects on brain and cranial bone development in the offspring of animals that are exposed to cell phone radiation during pregnancy; and
• Findings in autism spectrum disorders consistent with EMF/RFR exposure.

The “BioInitiative 2012 Report” stated that:  “There is reinforced scientific evidence of risk from chronic exposure to low-intensity electromagnetic fields and to wireless technologies.”

The FCC and similar bureaucratic organizations just won’t recognize studies like those described above because they don’t fit the narrative that only thermal RF effects are relevant in setting exposure standards intended to protect the public.

2.  Anxiety in the Population?

The FCC states that “adoption of extra precautionary measures may have the unintended consequence of ‘opposition to progress and the refusal of innovation, ever greater bureaucracy,… [and] increased anxiety in the population.’”  Increased anxiety in the population?  What about the anxiety and physical harm being caused by not taking prudent measures to reduce exposure?

Actually at the point where the FCC refers to “anxiety in the population,” it was selectively quoting a French published article entitled, “Conclusions. The Precautionary Principle: Its Advantages and Risks.”  That article (as the title indicates) discussed the “pros and cons” of implementing a precautionary principle.  One of the statements in that same article was that “the precautionary principle can have advantages, such as motivating decision-makers in the public or private sector to explain and quantify their reasoning, and to give objective information.”  Of course, the FCC did not quote that portion of the article.

Summary

The FCC exposure guideline assessment is welcome and long overdue.  That said, it is disheartening that the FCC would initiate an “inquiry” to assess its current exposure guidelines in a manner that appears clearly biased in favor of the interests of the telecommunications industry.

An unbiased approach would have been to very objectively request an evaluation on the adequacy of the FCC exposure guidelines that are intended to protect the health and safety of the public.  Instead, the FCC in its “Notice of Inquiry” attempts to undercut the critical debate needed to more formally recognize non-thermal biological effects by referring to such effects as “not established” and then talks about creating “anxiety in the population” if we were to do anything to further protect the public health and safety.  Unbelievable.