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Mobile Phones Should Be Reassessed' which was released on August 7, 
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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

July 2012: 

Telecommunications: 

Exposure and Testing Requirements for Mobile Phones Should Be 
Reassessed: 

GAO-12-771: 

GAO Highlights: 

Highlights of GAO-12-771, a report to congressional requesters. 

Why GAO Did This Study: 

The rapid adoption of mobile phones has occurred amidst controversy 
over whether the technology poses a risk to human health as a result 
of long-term exposure to RF energy from mobile phone use. FCC and FDA 
share regulatory responsibilities for mobile phones. GAO was asked to 
examine several issues related to mobile phone health effects and 
regulation. Specifically, this report addresses (1) what is known 
about the health effects of RF energy from mobile phones and what are 
current research activities, (2) how FCC set the RF energy exposure 
limit for mobile phones, and (3) federal agency and industry actions 
to inform the public about health issues related to mobile phones, 
among other things. GAO reviewed scientific research; interviewed 
experts in fields such as public health and engineering, officials 
from federal agencies, and representatives of academic institutions, 
consumer groups, and the mobile phone industry; reviewed mobile phone 
testing and certification regulations and guidance; and reviewed 
relevant federal agency websites and mobile phone user manuals. 

What GAO Found: 

Scientific 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. In addition, officials from the Food and Drug 
Administration (FDA) and the National Institutes of Health (NIH) as 
well as experts GAO interviewed have reached similar conclusions about 
the scientific research. Ongoing research examining the health effects 
of RF energy exposure is funded and supported by federal agencies, 
international organizations, and the mobile phone industry. NIH is the 
only federal agency GAO interviewed directly funding studies in this 
area, but other agencies support research under way by collaborating 
with NIH or other organizations to conduct studies and identify areas 
for additional research. 

The Federal Communications Commission’s (FCC) RF energy exposure limit 
may not reflect the latest research, and testing requirements may not 
identify maximum exposure in all possible usage conditions. FCC set an 
RF energy exposure limit for mobile phones in 1996, based on 
recommendations from federal health and safety agencies and 
international organizations. These international organizations have 
updated their exposure limit recommendation in recent years, based on 
new research, and this new limit has been widely adopted by other 
countries, including countries in the European Union. This new 
recommended limit could allow for more RF energy exposure, but actual 
exposure depends on a number of factors including how the phone is 
held during use. FCC has not adopted the new recommended limit. The 
Office of Management and Budget’s instructions to federal agencies 
require the adoption of consensus standards when possible. FCC told 
GAO that it relies on the guidance of federal health and safety 
agencies when determining the RF energy exposure limit, and to date, 
none of these agencies have advised FCC to change the limit. However, 
FCC has not formally asked these agencies for a reassessment. By not 
formally reassessing its current limit, FCC cannot ensure it is using 
a limit that reflects the latest research on RF energy exposure. FCC 
has also not reassessed its testing requirements to ensure that they 
identify the maximum RF energy exposure a user could experience. Some 
consumers may use mobile phones against the body, which FCC does not 
currently test, and could result in RF energy exposure higher than the 
FCC limit. 

Federal agencies and the mobile phone industry provide information on 
the health effects of mobile phone use and related issues to the 
public through their websites and mobile phone manuals. The types of 
information provided via federal agencies’ websites on mobile phone 
health effects and related issues vary, in part because of the agencies’
 different missions, although agencies provide a broadly consistent 
message. Members of the mobile phone industry voluntarily provide 
information on their websites and in mobile-phone user manuals. There 
are no federal requirements that manufacturers provide information to 
consumers about the health effects of mobile phone use. 

What GAO Recommends: 

FCC should formally reassess and, if appropriate, change its current 
RF energy exposure limit and mobile phone testing requirements related 
to likely usage configurations, particularly when phones are held 
against the body. FCC noted that a draft document currently under 
consideration by FCC has the potential to address GAO’s 
recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-12-771]. For more 
information, contact Mark Goldstein at (202) 512-2834 or 
goldsteinm@gao.gov, or Marcia Crosse at (202) 512-7114 or 
crossem@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Research on RF Energy Exposure from Mobile Phones Has Not Demonstrated 
Adverse Health Effects, but More Studies Are Under Way: 

FCC's RF Energy Exposure Limit May Not Reflect Latest Evidence on 
Thermal Effects, and Mobile Phone Testing Requirements May Not 
Identify Maximum Exposure: 

Federal Agencies and Mobile Phone Industry Provide Information to the 
Public through Websites and User Manuals: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Studies GAO Reviewed: 

Appendix III: Comments from the Federal Communications Commission: 

Appendix IV: GAO Contacts and Staff Acknowledgments: 

Tables: 

Table 1: Ongoing NIH-Funded Studies on Health Effects of RF Energy 
Exposure from Mobile Phone Use: 

Table 2: Federal Agency Website Information on Mobile Phones and 
Health as of June 2012: 

Table 3: Subject Matter Experts Interviewed: 

Table 4: Mobile Phone User Manuals Reviewed: 

Figures: 

Figure 1: The Electromagnetic Spectrum: 

Figure 2: U.S. Mobile Phone Certification Process: 

Figure 3: Photographs of Mobile Phone Testing near the Body: 

Abbreviations: 

ANSI: American National Standards Institute: 

CDC: Centers for Disease Control and Prevention: 

DNA: deoxyribonucleic acid: 

EPA: Environmental Protection Agency: 

FCC: Federal Communications Commission: 

FDA: Food and Drug Administration: 

IARC: International Agency for Research on Cancer: 

IEEE: Institute of Electrical and Electronics Engineers: 

NIH: National Institutes of Health: 

OSHA: Occupational Safety and Health Administration: 

RF: radio frequency: 

SAR: specific absorption rate: 

TCB: Telecommunication Certification Body: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

July 24, 2012: 

The Honorable Henry A. Waxman:
Ranking Member:
Committee on Energy and Commerce:
House of Representatives: 

The Honorable Anna G. Eshoo:
Ranking Member:
Subcommittee on Communications and Technology:
Committee on Energy and Commerce:
House of Representatives: 

The Honorable Edward J. Markey:
House of Representatives: 

Mobile phone use in the United States has risen dramatically over the 
last 20 years, and Americans increasingly rely on mobile phones as 
their sole or primary means of telephone communication.[Footnote 1] 
The rapid adoption of mobile phones has occurred amidst controversy 
over whether the technology poses a risk to human health. Like other 
devices that transmit radio signals, mobile phones emit radio-
frequency (RF) energy. At high power levels, RF energy can heat 
biological tissue and cause damage. Though mobile phones operate at 
power levels well below the level at which this thermal effect occurs, 
the question of whether long-term exposure to RF energy emitted from 
mobile phones can cause other types of adverse health effects, such as 
cancer, has been the subject of research and debate. 

The Federal Communications Commission (FCC) and the Food and Drug 
Administration (FDA) share regulatory responsibilities for mobile 
phones. FCC, in compliance with the National Environmental Policy Act 
of 1969, regulates RF energy emitted from FCC-regulated transmitters, 
including mobile phones.[Footnote 2] Toward that end, FCC has 
implemented a certification program to ensure that all mobile phones 
sold in the United States comply with the agency's limit on RF energy 
exposure. This limit was designed to protect users from the thermal 
effects of acute exposure to RF energy. FDA is responsible for 
carrying out a program designed to protect public health and safety 
from electronic product radiation.[Footnote 3] FDA does not review the 
safety of all radiation-emitting electronic products, such as mobile 
phones, before they are marketed. However, FDA has the authority to 
take action, such as requiring manufacturers to replace or recall 
mobile phones that are shown to emit RF energy at a level that is 
hazardous.[Footnote 4] To date, FDA has not taken such action, but the 
agency regularly evaluates scientific studies on mobile phones and 
health to determine whether they raise public health questions. 

In 2001, we reported on the status of scientific knowledge about 
potential health risks of RF energy exposure from mobile phones and 
the federal government's regulatory actions to ensure mobile phone 
safety.[Footnote 5] We found that FDA and others had concluded that 
the research did not show RF energy exposure from mobile phones had 
adverse health effects, but more studies were needed. We also found 
that FCC had not issued standardized procedures for testing mobile 
phones and that FCC's and FDA's consumer materials could be improved. 
Since 2001, FCC has issued revised guidance for mobile phone testing, 
and both FCC and FDA have provided updated information to consumers 
about the health effects of mobile phone use. 

At your request, we are updating information related to mobile phone 
health effects and regulatory issues. Specifically, this report 
addresses: 

1. What is known about the human health effects of RF energy exposure 
from mobile phone use, and what are the current research activities of 
federal agencies and other organizations? 

2. How has FCC set the RF energy exposure limit for mobile phones and 
how does FCC ensure compliance with the limit? 

3. What actions have federal agencies and the mobile phone industry 
taken to inform the public about issues related to mobile phone health 
effects? 

To determine what is known about the human health effects of RF energy 
exposure from mobile phone use, we reviewed selected studies, 
including studies and reports that review and assess the scientific 
research as well as key individual studies. We identified these 
studies through literature searches in online databases, such as 
Embase and Medline, and interviews with officials from federal 
agencies, academic institutions, consumer groups, and industry 
associations. We also interviewed subject matter experts in a range of 
fields, such as public health and engineering. To determine the 
current research activities of federal agencies related to mobile 
phone use and health, we interviewed officials from FCC; the 
Department of Health and Human Services' FDA, Centers for Disease 
Control and Prevention (CDC), and National Institutes of Health (NIH); 
Department of Defense; Department of Labor's Occupational Safety and 
Health Administration (OSHA); and the Environmental Protection Agency 
(EPA). To determine the research activities of other organizations, we 
interviewed representatives of the International Agency for Research 
on Cancer (IARC), academic institutions, consumer groups, mobile phone 
industry associations, mobile phone manufacturers, and mobile phone 
providers. To determine how FCC set the RF energy exposure limit and 
ensures compliance with it, we reviewed FCC regulations and guidance. 
We also reviewed reports from international organizations that 
recommend RF energy exposure limits. We conducted interviews with 
officials from FCC and Telecommunication Certification Bodies (TCBs) 
to understand their role in certifying mobile phones. We also 
interviewed representatives of the mobile phone industry and consumer 
organizations, and experts in RF energy exposure limits to obtain 
their perspectives on the testing and certification of mobile phones. 
To determine the actions federal agencies and the mobile phone 
industry have taken to inform the public about issues related to 
mobile phone health effects, we reviewed information on the public 
websites of CDC, EPA, FCC, FDA, NIH, and OSHA. We also reviewed the 
user manuals for selected top-selling mobile phones of 2011 to 
identify the information manufacturers provided to consumers. (See 
appendix I for more information on our scope and methodology and 
appendix II for a list of studies we reviewed.) 

We conducted this performance audit from August 2011 through July 2012 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

The United States has experienced dramatic changes in mobile phone use 
since nationwide cellular service became available in the mid-1980s. 
For example, the number of estimated mobile phone subscribers has 
grown from about 3.5 million in 1989 to approximately 286 million by 
the end of 2009, according to the most recent data reported by FCC. 
[Footnote 6] Further, the number of Americans who rely exclusively on 
mobile phones for voice service has increased in recent years. For 
example, by the end of 2009 over 50 percent of young adults aged 25 to 
29 relied exclusively on mobile phones, according to the most recent 
FCC data.[Footnote 7] The way individuals use mobile phones has also 
changed. For instance, while average minutes of use per mobile phone 
subscriber per month has declined in recent years, mobile text 
messaging traffic has increased.[Footnote 8] About 88 percent of 
teenage mobile phone users now send and receive text messages, which 
is a rise from the 51 percent of teenagers who texted in 2006. 
[Footnote 9] 

Mobile phones are low-powered radio transceivers--a combination 
transmitter and receiver--that use radio waves to communicate with 
fixed installations, called base stations or cell towers. The radio 
waves used by mobile phones are a form of electromagnetic radiation--
energy moving through space as a series of electric and magnetic 
waves. The spectrum of electromagnetic radiation comprises a range of 
frequencies from very low, such as electrical power from power lines, 
through visible light, to extremely high, such as gamma rays, as shown 
in figure 1. The portion of the electromagnetic spectrum used by 
mobile phones--as well as other telecommunications services, such as 
radio and television broadcasting--is referred to as the RF spectrum. 

Figure 1: The Electromagnetic Spectrum: 

[Refer to PDF for image: illustration] 

Non-ionizing: 10 Hertz to 10x16 Hertz; 
Ionizing: 10x16 Hertz to 10x26 Hertz. 

Below 3 kilohertz: 
Power lines: 10x2, 10x3. 

3 kilohertz to 300 gighertz: Radio frequencies: 
Radio and television; 
Mobile phones; 
Microwaves. 

Above 300 gigahertz: 
Infra-red; 
Visible light; 
Ultra-violet; 
X-rays; 
Gamma rays. 

Source: FCC. 

[End of figure] 

The electromagnetic spectrum includes ionizing and non-ionizing 
radiation. Ionizing radiation, such as gamma rays, has energy levels 
high enough to strip electrons from atoms and molecules, which can 
lead to serious biological damage, including the production of 
cancers. RF energy, on the other hand, is in the non-ionizing portion 
of the electromagnetic spectrum, which lacks the energy needed to 
cause ionization. However, RF energy can produce other types of 
biological effects. For example, it has been known for many years that 
exposure to high levels of RF energy, particularly at microwave 
frequencies, can rapidly heat biological tissue. This thermal effect 
can cause harm by increasing body temperature, disrupting behavior, 
and damaging biological tissue. The thermal effect has been 
successfully harnessed for household and industrial applications, such 
as cooking food and molding plastics. Since mobile phones are required 
to operate at power levels well below the threshold for known thermal 
effects, the mobile phone health issue has generally focused on 
whether there are any adverse health effects from long-term or 
frequent exposure to low-power RF energy emissions that are not caused 
by heating. 

Research on RF Energy Exposure from Mobile Phones Has Not Demonstrated 
Adverse Health Effects, but More Studies Are Under Way: 

Scientific Research: 

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. In 2001, we 
reported that FDA and others had concluded that research had not shown 
RF energy emissions from mobile phones to have adverse health effects, 
but that insufficient information was available to conclude mobile 
phones posed no risk.[Footnote 10] Following another decade of 
scientific research and hundreds of studies examining health effects 
of RF energy exposure from mobile phone use, FDA maintains this 
conclusion. FDA stated that while the overall body of research has not 
demonstrated adverse health effects, some individual studies suggest 
possible effects. Officials from NIH, experts we interviewed, and a 
working group commissioned by IARC--the World Health Organization's 
agency that promotes international collaboration in cancer research--
have reached similar conclusions. For example, in May 2011 IARC 
classified RF energy as "possibly carcinogenic to humans."[Footnote 
11] IARC determined that the evidence from the scientific research for 
gliomas, a type of cancerous brain tumor, was limited--meaning that an 
association has been observed between RF energy exposure and cancer 
for which a causal relationship is considered to be credible, but 
chance, bias, or confounding factors could not be ruled out with 
reasonable confidence.[Footnote 12] With respect to other types of 
cancers, IARC determined that the evidence was inadequate--meaning 
that the available studies are of insufficient quality, consistency, 
or statistical power to permit a conclusion about the causal 
association. Additionally, in April 2012 an advisory group to the 
Health Protection Agency--an independent organization established by 
the United Kingdom government to protect the public from environmental 
hazards and infectious diseases--concluded that although there is 
substantial research on this topic, there is no convincing evidence 
that RF energy below guideline levels causes health effects in adults 
or children.[Footnote 13] 

A broad body of research is important for understanding the health 
effects of RF energy exposure from mobile phone use, because no single 
study can establish a cause-and-effect relationship and limitations 
associated with studies can make it difficult to draw conclusions. Two 
types of studies, epidemiological and laboratory, are used in 
combination to examine effects from mobile phones. Epidemiological 
studies investigate the association, if any, between health effects 
and the characteristics of people and their environment. Laboratory 
studies conducted on test subjects--including human volunteers, 
laboratory animals, biological tissue samples, or isolated cells--are 
used to determine a causal relationship between possible risk factors 
and human health, and the possible mechanisms through which that 
relationship occurs. 

Epidemiological Studies: 

Studies we reviewed suggested and experts we interviewed stated that 
epidemiological research has not demonstrated adverse health effects 
from RF energy exposure from mobile phone use, but the research is not 
conclusive because findings from some studies have suggested a 
possible association with certain types of tumors, including cancerous 
tumors. Findings from one such study, the INTERPHONE study, were 
published in 2010.[Footnote 14] This retrospective case-control study 
with more than 5,000 cases examined the association between mobile 
phone use and certain types of brain tumors, including cancerous 
tumors, in individuals aged 30-59 years in 13 countries.[Footnote 15] 
Overall study findings did not show an increased risk of brain tumors 
from mobile phone use, but at the highest level of exposure, findings 
suggested a possible increased risk of glioma.[Footnote 16] Other 
epidemiological studies have not found associations between mobile 
phone use and tumors, including cancerous tumors. For example, 
findings from a nationwide cohort study conducted in Denmark that 
originally followed 420,095 individuals did not show an association 
between increased risk for certain types of tumors, including 
cancerous tumors, and mobile phone use.[Footnote 17] Additionally, 
findings from a subset of the cohort--56,648 individuals with 10 or 
more years since their first mobile phone subscription--did not show 
an increased risk for brain and nervous system tumors.[Footnote 18] 
Further, these findings did not change for individuals in the cohort 
with 13 or more years since their first mobile phone subscription. 
[Footnote 19] Also, the CEFALO study--an international case-control 
study that compared children aged 7 to 19 diagnosed with certain types 
of brain tumors, including brain cancers, to similar children who were 
not diagnosed with brain tumors--found no relationship between mobile 
phone use and risk for brain tumors.[Footnote 20] Findings from 
another study, which was conducted by NIH and examined trends in brain 
cancer incidence rates in the United States using national cancer 
registry data collected from 1992 to 2006, did not find an increase in 
new cases of brain cancer, despite a dramatic increase in mobile phone 
use during this time period.[Footnote 21] 

Limitations associated with epidemiological studies can make it 
difficult to draw definitive conclusions about whether adverse health 
effects are linked to RF energy exposure from mobile phone use. One 
such limitation is that it is difficult to measure and control for all 
variables that may affect results. For example, it can be difficult to 
accurately measure RF energy exposure from mobile phone use because 
humans are exposed to RF energy from many sources within their 
environments and mobile phone technology and user patterns frequently 
change. Also, epidemiological studies to date have been limited in 
their ability to provide information about possible effects of long-
term RF energy exposure because the prevalence of long-term mobile 
phone use is still relatively limited and some tumors, including some 
cancerous tumors, do not develop until many years after exposure. In 
addition, epidemiological studies, specifically cohort studies, are 
sometimes limited in their ability to provide information about 
increased risks for rare outcomes, such as certain types of brain 
tumors. To address challenges with assessing rare outcomes, case-
control studies, which collect information about past mobile phone use 
among study participants, may be undertaken with large numbers of 
cases and controls. While these studies can potentially provide 
information on long-term use, and include enough cancer cases to 
examine whether this use is associated with rare diseases, collecting 
data in this way can introduce bias, such as recall bias, into study 
data and further limit findings. To mitigate this potential bias, some 
epidemiological studies, specifically cohort studies, follow large 
populations over time and collect data about mobile phone use before 
participants develop a certain outcome. In spite of these limitations, 
experts we spoke with told us that epidemiological studies are a key 
component of the body of research used for assessing the health 
effects of mobile phones. 

Laboratory Studies: 

Studies we reviewed suggested and experts we interviewed stated that 
laboratory research has not demonstrated adverse human health effects 
from RF energy exposure from mobile phone use, but the research is not 
conclusive because findings from some studies have observed effects on 
test subjects. Some laboratory studies have examined whether RF energy 
has harmful effects by exposing samples of human and animal cells to 
RF energy over a range of dose rates, durations, and conditions to 
detect any changes in cellular structures and functions. For example, 
some studies have examined the effects of RF energy on 
deoxyribonucleic acid (DNA) in rodent and human cells. While some of 
these studies found that RF energy exposure damaged DNA,[Footnote 22] 
others failed to replicate such an effect using similar experimental 
conditions.[Footnote 23] Other studies have exposed laboratory animals 
to RF energy, examined the animals for changes, and compared outcomes 
with a control group. For example, some studies have measured the 
behavior or cognitive functioning of rats to assess the neurological 
effects of RF energy.[Footnote 24] According to some studies we 
reviewed, while some of these studies have observed changes in 
behavior and cognitive function, overall, these studies have not 
consistently found adverse effects from RF energy levels emitted from 
mobile phones. Laboratory studies also have exposed human volunteers 
to RF energy to investigate possible effects, such as effects on the 
neurological system or blood pressure. According to studies we 
reviewed, some studies on human volunteers have observed changes, such 
as changes in brain activity, but the implications of these 
physiological changes in relation to adverse effects on human health 
are unknown.[Footnote 25] 

Limitations associated with laboratory studies can make it difficult 
to draw conclusions about adverse human health effects from RF energy 
exposure from mobile phone use. For example, studies conducted on 
laboratory animals allow researchers to examine the effects of RF 
energy exposure on animal systems, but this type of research is 
limited because effects on laboratory animals may not be the same on 
humans. Additionally, studies on test subjects may observe biological 
or physiological changes, but in some circumstances it is unclear how 
or even if these changes affect human health. Further, to increase the 
strength of the evidence that observed changes in laboratory studies 
are the effect of RF energy exposure, studies must be replicated and 
confirmed with additional research using different dose rates, 
durations, and conditions of RF energy while observing similar 
effects. To date, according to FDA officials and some experts we 
interviewed, only a few laboratory studies that have shown effects 
from RF energy have been replicated, and some replicated studies have 
not confirmed earlier results. 

Areas for Additional Research: 

Studies we reviewed and experts we interviewed identified key areas 
for additional epidemiological and laboratory studies, and according 
to experts, additional research may increase understanding of any 
possible effects. For example, additional epidemiological studies, 
particularly large long-term prospective cohort studies and case-
control studies on children, could increase knowledge on potential 
risks of cancer from mobile phone use. Also, studies and experts 
identified several areas for additional laboratory studies. For 
example, additional studies on laboratory animals as well as human and 
animal cells examining the possible toxic or harmful effects of RF 
energy exposure could increase knowledge on potential biological and 
health effects of RF energy. Further, additional laboratory studies on 
human and animal cells to examine non-thermal effects of RF energy 
could increase knowledge of how, if at all, RF energy interacts with 
biological systems. However, some experts we spoke to noted that, 
absent clear evidence for adverse health effects, it is difficult to 
justify investing significant resources in research examining non-
thermal effects of RF energy from mobile phone use. Another area 
identified for additional laboratory research is studies on human 
volunteers examining the effect of changes in the neurological system, 
which could help determine if these possible observed changes in 
neurological functioning from RF energy are adverse effects. In 
addition to conducting additional research, experts we interviewed 
reported that the broader body of evidence on RF energy should be re-
evaluated when findings from key studies become available, to 
determine whether additional research in certain areas is still 
warranted. 

Current Research Activities: 

Current research activities of federal agencies, international 
organizations, and the mobile phone industry include funding and 
supporting ongoing research on the health effects of RF energy 
exposure from mobile phones. NIH is the only federal agency we 
interviewed that is directly funding ongoing studies on health effects 
of RF energy from mobile phone use. NIH officials reported that the 
agency has provided about $35 million for research in this area from 
2001 to 2011. (See table 1 for more information on ongoing studies 
funded by NIH.) Although other federal agencies are not directly 
funding research in this area, some agencies are providing support for 
ongoing studies. For example, FDA officials reported that FDA's 
National Center for Toxicological Research, with funding provided by 
NIH as part of the National Toxicology Program, is conducting studies 
on rat and bovine brain cells to examine whether RF energy emitted 
from mobile phones is toxic.[Footnote 26] Also, CDC officials reported 
that the agency is collaborating with others to conduct ongoing 
studies in this area. For example, CDC officials reported that one of 
the agency's staff is collaborating with researchers in seven 
countries to conduct additional analyses on data collected through the 
INTERPHONE study to determine whether occupational exposure to RF 
energy and chemicals was a risk factor for brain cancer. 

Table 1: Ongoing NIH-Funded Studies on Health Effects of RF Energy 
Exposure from Mobile Phone Use: 

Description: Examining environmental and genetic factors for 
meningioma, a type of brain tumor, at research sites in five states; 
NIH institute funding the study: National Cancer Institute; 
Total NIH funding: $8,779,998; 
Estimated year of completion: 2012. 

Description: Evaluating brain cancer incidence trends in the United 
States using cancer registry data to determine if trends are 
consistent with reported epidemiological associations of mobile phone 
use and certain types of cancer; 
NIH institute funding the study: National Cancer Institute; 
Total NIH funding: Not applicable[A]; 
Estimated year of completion: Not applicable[A]. 

Description: Examining effects of mobile phones on brain glucose; 
NIH institute funding the study: National Institute on Alcohol Abuse 
and Alcoholism; 
Total NIH funding: $595,700; 
Estimated year of completion: 2012. 

Description: Examining effects of exposure to mobile phones in 
childhood on the central nervous system using children in the Danish 
National Birth Cohort[B]; 
NIH institute funding the study: National Institute of Environmental 
Health Sciences; 
Total NIH funding: $423,500; 
Estimated year of completion: 2012. 

Description: Examining toxicology and carcinogenic effects of RF 
energy in laboratory animals as part of the National Toxicology 
Program[C]; 
NIH institute funding the study: National Institute of Environmental 
Health Sciences; 
Total NIH funding: $25,600,000; 
Estimated year of completion: 2015. 

Source: GAO analysis of NIH information. 

[A] The National Cancer Institute regularly monitors and evaluates the 
U.S. brain cancer incidence trends using Surveillance Epidemiology and 
End Result data. According to NIH officials, the National Cancer 
Institute does not separately track funding associated with performing 
this task. The most recent publication of data from this surveillance 
activity was published in 2012. See Little, M.P., et al, "Mobile Phone 
Use and Glioma Risk: Comparison of Epidemiological Study Results With 
Incident Trends In the United States," British Medical Journal, 2012, 
344: e1147. 

[B] The Danish National Birth Cohort consists of over 100,000 Danish 
children who were born from 1996 to 2002. Data on lifestyle factors, 
dietary habits, and environmental exposures have been collected on 
these children, and data on current mobile phone use by children have 
been collected since these children reached the age of seven. 

[C] The National Toxicology Program is an interagency program that 
evaluates factors, such as RF energy, that could affect public health 
for the federal government. The three core federal agencies that make-
up this program are NIH's National Institute of Environmental Health 
Sciences, CDC's National Institute for Occupational Safety and Health, 
and FDA's National Center for Toxicological Research. The National 
Toxicology Program is conducting comprehensive carcinogenicity studies 
on laboratory animals. According to FDA officials, FDA is conducting 
one of these National Toxicology Program studies in its National 
Center for Toxicological Research laboratory. 

[End of table] 

Federal agencies are also engaged in other activities to support 
research on the health effects of mobile phone use. For example, FDA 
collaborates with other organizations on research-related projects. 
According to FDA officials, the agency helped the World Health 
Organization develop its WHO Research Agenda for Radiofrequency Fields 
in 2001 and has provided comments to the World Health Organization on 
updates to this research agenda.[Footnote 27] Also, officials from 
federal agencies that have responsibility for different aspects of RF 
energy safety and work--CDC, EPA, FCC, FDA, NIH, the National 
Telecommunications and Information Administration, and OSHA--are 
members of the Radiofrequency Interagency Work Group, which works to 
share information on RF energy related projects at the staff level. 
According to FCC and FDA officials, this group periodically meets to 
discuss RF energy related issues, including recently published and 
ongoing research on the health effects of RF energy exposure. 

International organizations also support research on health effects of 
RF energy exposure from mobile phone use. Officials from IARC told us 
that the organization is currently supporting research activities for 
ongoing studies examining health effects of mobile phone use with 
respect to cancer. For example, IARC is involved in the identification 
of research sites for and implementation of the COSMOS study--a large 
international, prospective, cohort study that will follow individuals 
for 25 or more years to examine possible long-term health effects of 
using mobile phones, such as brain tumors, including cancers, and 
other health outcomes. IARC is also coordinating additional data 
analyses on previously published studies examining mobile phone health 
effects. For example, IARC is coordinating additional analyses of data 
collected for the INTERPHONE study. Additionally, the European 
Commission--the European Union's executive body that represents the 
interest of Europe as a whole--is supporting research in this field. 
Under its research program--the Seventh Framework Programme--the 
European Commission has provided funds for the MOBI-KIDS study, an 
international case-control study examining the possible association 
between communication technology, including mobile phones and other 
environmental exposures, and the risk of brain tumors in people aged 
10 to 24 years. 

The mobile phone industry supports research by providing funding for 
studies. According to representatives from mobile phone manufacturers, 
service providers, and industry associations, most industry funding 
for scientific research is provided by the Mobile Manufacturers Forum--
an international not-for-profit association that is largely comprised 
of wireless device manufacturers. According to representatives from 
the Mobile Manufacturers Forum, the association has provided about $46 
million for RF energy research since 2000 and is currently providing 
support for epidemiological and laboratory studies. Although 
representatives from all four mobile phone manufacturers that we 
interviewed reported that their companies support research through 
their industry associations, representatives from one manufacturer 
reported that it is also funding two studies examining the effects of 
RF energy emitted from mobile phones on human hands and the head. 

FCC's RF Energy Exposure Limit May Not Reflect Latest Evidence on 
Thermal Effects, and Mobile Phone Testing Requirements May Not 
Identify Maximum Exposure: 

RF Energy Exposure Limit: 

In 1996, FCC adopted the RF energy exposure limit for mobile phones of 
1.6 watts per kilogram, averaged over one gram of tissue, a 
measurement of the amount of RF energy absorbed into the body. 
[Footnote 28] FCC developed its limit based on input from federal 
health and safety agencies as well as the 1991 recommendation by the 
Institute of Electrical and Electronics Engineers (IEEE) that was 
subsequently approved and issued in 1992 by the American National 
Standards Institute (ANSI).[Footnote 29] This recommended limit was 
based on evidence related to the thermal effects of RF energy 
exposure[Footnote 30]--the only proven health effects of RF energy 
exposure--and was set at a level well below the threshold for such 
effects. FCC noted that the limit provided a proper balance between 
protecting the public from exposure to potentially harmful RF energy 
and allowing industry to provide telecommunications services to the 
public in the most efficient and practical manner possible. 

In 2006, IEEE published its updated recommendation for an RF energy 
exposure limit of 2.0 watts per kilogram, averaged over 10 grams of 
tissue.[Footnote 31] This new recommended limit could allow for more 
RF energy exposure from mobile phone use, although actual exposure 
depends on a number of factors, including the operating power of the 
phone, how the phone is held during use, and where it is used in 
proximity to a mobile phone base station.[Footnote 32] According to 
IEEE, improved RF energy research and a better understanding of the 
thermal effects of RF energy exposure on animals and humans, as well 
as a review of the available scientific research, led to the change in 
recommended RF energy exposure limit. IEEE's new recommended limit was 
harmonized with a 1998 recommendation of the International Commission 
on Non-Ionizing Radiation Protection, which has been adopted by more 
than 40 countries, including the European Union countries.[Footnote 
33] Both of these recommendations call for an exposure limit of 2.0 
watts per kilogram averaged over 10 grams of tissue, which according 
to IEEE represents a scientific consensus on RF energy exposure limits. 

According to senior FCC officials, the agency has not adopted any 
newer limit because federal health and safety agencies have not 
advised them to do so. FCC officials told us that they rely heavily on 
the guidance and recommendations of federal health and safety agencies 
when determining the appropriate RF energy exposure limit and that, to 
date, none of these agencies have advised FCC that its current RF 
energy limit needs to be revised. Officials from FDA and EPA told us 
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. 

Although federal guidance states that agencies should generally use 
consensus standards, FCC officials provided reasons why they did not 
have current plans to change the RF energy exposure limit. Office of 
Management and Budget Circular A-119 concerning federal use of 
technical standards states that federal agencies must use "consensus 
standards in lieu of government-unique standards," except where 
inconsistent with law or otherwise impractical. FCC officials noted 
that no determination has been made that the new recommended RF energy 
exposure limit is inconsistent with law or impractical. FCC has 
recognized that research on RF energy exposure is ongoing and pledged 
to monitor the science to ensure that its guidelines continue to be 
appropriate.[Footnote 34] FCC officials noted that an assessment of 
the current limit and the new recommended limit could be accomplished 
through a formal rulemaking process, which would include a 
solicitation of information and opinions from federal health and 
safety agencies.[Footnote 35] FCC could alternatively release a Notice 
of Inquiry to gather information on this issue without formally 
initiating rulemaking. 

Stakeholders we spoke with varied on whether the current U.S. RF 
energy exposure limit should be changed to reflect the new recommended 
limit. For instance, a few experts and consumer groups we spoke with 
said FCC should not adopt the new recommended exposure limit because 
of the relative uncertainty of scientific research on adverse health 
effects from mobile phone use. An official from one consumer group 
told us that adopting the 2.0 watts per kilogram exposure limit would 
be a step back, since it could allow users to be exposed to higher 
radiation levels. Conversely, some experts we spoke with maintained 
that both the 1.6-and 2.0-watts-per-kilogram limits protect users from 
the thermal effects of RF energy exposure--which the experts 
maintained are the only conclusively demonstrated effects of exposure--
since a safety factor of fifty was applied to obtain the limits, 
meaning that the maximum permitted exposure is a fiftieth of what was 
determined to be the exposure at which potentially deleterious thermal 
effects are likely to occur. 

Nevertheless, by 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. FCC's current limit was 
established based on recommendations made more than 20 years ago. 
According to IEEE, the new recommended limit it developed is based on 
significantly improved RF research and therefore a better 
understanding of the thermal effects of RF energy exposure. 
Additionally, three of the four mobile phone manufacturers we spoke 
with favored harmonization of RF energy exposure limits, telling us 
that maintaining the separate standards can result in additional costs 
and may affect phone design in a way that could limit performance and 
functionality. According to some manufacturers we spoke with, many of 
their phones are sold in multiple countries. As a result, the 
manufacturers have to develop and test phones based on different 
exposure limits, which can require additional resources and slow the 
time it takes to get new phones into the market. Additionally, one 
manufacturer indicated that some features are not enabled on phones 
sold in the United States that are available in other countries to 
comply with FCC's current limit. A reassessment by FCC would help it 
to determine if any changes to the limit are appropriate. 

Mobile Phone Certification: 

FCC ensures compliance with its RF energy exposure limit by certifying 
all mobile phones sold in the United States. In its application for 
certification, manufacturers must provide evidence that their mobile 
phones meet FCC's RF energy exposure limit. FCC has authorized 23 TCBs 
in the United States and other countries to review applications that 
involve evaluation of RF exposure test data and issue certifications 
on behalf of the agency. TCBs are private organizations that have been 
accredited to perform these functions.[Footnote 36] TCBs now perform 
the majority of mobile phone certifications, with FCC generally only 
handling the more complex certifications, such as mobile phones with 
multiple transmitters using third generation and fourth generation 
technology.[Footnote 37] Figure 2 illustrates the mobile phone 
certification process. 

Figure 2: U.S. Mobile Phone Certification Process: 

[Refer to PDF for image: illustration] 

Phone manufactured: 
Manufacturers develop and introduce new models of mobile phones with 
new features and designs.  

Phone tested: 
Manufacturers must test their mobile phones for compliance with FCC's 
RF energy exposure limit. Manufacturers may conduct the tests 
themselves at their own facilities or have the testing done for them 
by testing laboratories.  

Phone reviewed: 
Manufacturers must submit an application for certification that their 
phone meets FCC's RF energy exposure limit. Either FCC or a TCB 
reviews the application, a process which may involve repeated 
inquiries to the manufacturer.  

Phone certified: 
A written certification, which allows the mobile phone to be put on 
the U.S. market, is issued by FCC, or by a TCB on behalf of FCC, once 
it is determined that applicable requirements, including the RF energy 
exposure limit, have been met. 

Source: GAO. 

[End of figure] 

Representatives from mobile phone manufacturers we spoke with were 
generally satisfied with how TCBs review and certify mobile phones, 
but noted that complex certifications handled by FCC can take a long 
time to process. For instance, since there are generally no 
established test procedures for new technologies, FCC must work with 
the manufacturer to develop appropriate procedures by which the agency 
can determine if the device meets the RF energy exposure limit. 
According to FCC, part of this review may result in changes to testing 
guidance. For example, representatives from one manufacturer told us 
that FCC may take many months to process an application for a newer 
product. FCC officials told us that over the last 10 years, the 
average time to review an application submitted directly to the agency 
has ranged from 45 to 60 days. Representatives from one TCB we spoke 
with noted that the TCB review can be as short as a week, though FCC 
does not collect data on how long it takes TCBs to process 
applications. 

Mobile Phone Testing: 

To ensure that mobile phones comply with FCC's RF energy exposure 
limit, manufacturers conduct tests at their own laboratories or have 
the testing conducted for them by private laboratories. Laboratories 
must follow standardized FCC testing procedures or work with FCC to 
develop acceptable alternatives in some complex cases. These 
procedures require that the SAR be measured to ensure the mobile 
phone's compliance with the FCC exposure limit, which was designed to 
ensure that mobile phones do not expose the public to levels of RF 
energy that could be potentially harmful. FCC periodically updates the 
testing procedures as new mobile phone technology is introduced. A 
typical testing set-up is shown in figure 3. 

Figure : Photographs of Mobile Phone Testing near the Body: 

[Refer to PDF for image: 2 photographs] 

Source: GAO. 

Note: To test mobile phones, a mold in the shape of an adult torso and 
head is filled with fluid mixture designed to simulate the electrical 
properties of human tissue. A phone is placed near the head or torso 
(the torso, or body, testing is illustrated above) and operated at 
maximum power. A probe attached to a computer-controlled mechanical 
arm is inserted into the mixture at various locations to measure SAR. 
This procedure is repeated for a number of closely specified phone 
positions and operating frequencies. To receive FCC certification, 
none of the SAR measurements can exceed FCC's exposure limit of 1.6 
watts per kilogram. 

[End of figure] 

FCC has implemented standardized testing procedures requiring mobile 
phones to be tested for compliance with the RF energy exposure limit 
when in use against the ear and against the body while in body-worn 
accessories, such as holsters, but these requirements may not identify 
the maximum exposure under other conditions.[Footnote 38] The specific 
minimum separation distance from the body is determined by the 
manufacturer (never to exceed 2.5 centimeters), based on the way in 
which the mobile phone is designed to be used.[Footnote 39] The 
results of these testing requirements are two different values: a 
maximum SAR value for the head and a maximum SAR value for the body. 
However, these testing procedures may not identify the maximum SAR for 
the body, since some consumers use mobile phones with only a slight 
distance, or no distance, between the device and the body, such as 
placing the phone in a pocket while using an ear piece. Using a mobile 
phone in this manner could result in RF energy exposure above the 
maximum body-worn SAR determined during testing, although that may not 
necessarily be in excess of the FCC's limit. In such a case, exposure 
in excess of FCC's limit could occur if the device were to transmit 
continuously and at maximum power. 

FCC has not reassessed its testing requirements to ensure that testing 
identifies the maximum RF energy exposure for the other usage 
conditions a user could experience when mobile phones are in use 
without body-worn accessories or as advised by the manufacturer's 
instructions, rather than the head. Although FCC officials said that 
they provide case-by-case guidance for many mobile phones operating 
with new technologies, they do not require testing of mobile phones 
when used without body-worn accessories unless such conditions are 
specifically identified by the manufacturer's operating instructions. 
Representatives of some consumer groups we spoke with expressed 
concern about the exposure to RF energy that can come with such use. 
Officials from IEEE, though, told us that the average power and 
resultant radiation level of mobile phones while in use is very low, 
such that even when a mobile phone is used against the body it is 
unlikely that the RF energy exposure would exceed the FCC limit. 
Nevertheless, FCC has not reassessed its testing requirements to 
ensure that mobile phones do not exceed the RF energy exposure limit 
in all possible usage conditions. 

Beyond the testing required for certification, FCC also ensures that 
mobile phones meet its RF energy exposure limit by reviewing 
information collected as part of routine surveillance of mobile phones 
on the market. FCC requires TCBs to carry out this post-market 
surveillance program, through which each TCB tests one percent of the 
mobile phones they have certified for RF energy exposure, to ensure 
that the phones continue to meet FCC's RF energy exposure 
limit.[Footnote 40] According to FCC, no mobile phone tested under 
this surveillance program has been found in violation of the RF energy 
exposure limit. 

Federal Agencies and Mobile Phone Industry Provide Information to the 
Public through Websites and User Manuals: 

Information Provided by Federal Agencies: 

Federal agencies provide information to the public on the health 
effects of mobile phone use and related issues primarily through their 
websites. This information includes summaries of research, and 
agencies' conclusions about the health effects of mobile phone use, as 
well as suggestions for how mobile phone users can reduce their 
exposure to RF energy. Table 2 summarizes selected information on 
mobile phones and health provided by six federal agencies on their 
websites. 

Table 2: Federal Agency Website Information on Mobile Phones and 
Health as of June 2012: 

Types of information provided: What RF energy or radiation is; 
Agency: CDC, EPA, FCC, FDA, NIH, OSHA. 

Types of information provided: Current mobile phone RF energy exposure 
limits; 
Agency: CDC, FCC, OSHA. 

Types of information provided: How mobile phones are tested or 
certified; 
Agency: FCC. 

Types of information provided: Thermal effects of RF energy exposure; 
Agency: CDC, FCC, NIH, OSHA. 

Types of information provided: Non-thermal effects of RF energy 
exposure; 
Agency: CDC, FCC, OSHA. 

Types of information provided: Health issues and research related to 
mobile phones; 
Agency: CDC, FCC, FDA, NIH, OSHA. 

Types of information provided: Summaries or links to ongoing studies; 
Agency: CDC, FDA, NIH. 

Types of information provided: Information on how to minimize or 
reduce RF energy exposure from mobile phone use; 
Agency: CDC, EPA, FCC, FDA, NIH, OSHA. 

Source: GAO analysis of federal agency websites. 

Note: Some federal agency websites include additional information on 
mobile phones and health beyond the major topics listed above. 

[End of table] 

The types of information that federal agencies' websites provide on 
mobile phone health effects and related issues vary, in part because 
of the agencies' different missions, though the websites provide a 
broadly consistent message. For instance, NIH primarily provides 
information about the research on health effects of RF energy exposure 
from mobile phone use, while FCC provides information on how mobile 
phones are tested and certified. Nevertheless, the concluding 
statements about whether RF energy exposure from mobile phone use 
poses a risk to human health are generally consistent across selected 
federal agencies' websites that we reviewed, though the specific 
wording of these concluding statements varies. 

Representatives from some consumer groups and experts we spoke with 
raised concerns that the information on federal agency websites about 
mobile phone health effects is not precautionary enough, among other 
things. In particular, these representatives and experts said that 
federal agencies should include stronger precautionary information 
about mobile phones because of the uncertain state of scientific 
research on mobile phone health effects as well as the fact that 
current testing requirements may not identify the maximum possible RF 
energy exposure. Representatives from one consumer group also said 
that federal agency websites should provide more consumer information, 
such as the impact of different mobile phone technologies on RF energy 
exposure. Officials from FCC and NIH maintained that the information 
on their websites reflects the latest scientific evidence and provides 
sufficient information for consumers concerned about potential health 
effects related to mobile phones. 

Some consumer groups noted that they would like FCC to mention IARC's 
recent classification of RF energy exposure as "possibly carcinogenic" 
on FCC's website. FCC noted that it generally defers to the health and 
safety agencies for reporting on new research, though FCC's website 
did include information on the recent INTERPHONE study when we 
reviewed the site in June 2012. FCC does provide links to CDC, EPA, 
FDA, and other websites, some of which have information about the 
IARC's classification.[Footnote 41] FDA notes on its website that the 
IARC classification means there is limited evidence showing RF 
carcinogenicity in humans and insufficient evidence of carcinogenicity 
in experimental animals. 

Some local governments are taking steps to provide precautionary 
information to consumers. For example, the city of San Francisco has 
developed a Web page 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.[Footnote 42] 

Information Provided by Mobile Phone Industry: 

The mobile phone industry provides information to consumers on the 
health effects of mobile phone use and related issues through user 
manuals and websites. The information provided in user manuals by 
manufacturers is voluntary, as there are no federal requirements that 
manufacturers provide any specific information to consumers about the 
health effects of mobile phone use.[Footnote 43] Most manuals we 
reviewed provide information about how the device was tested and 
certified, as well as the highest energy exposure measurement 
associated with the device. Some manufacturers also provide 
suggestions, often based on information from FDA, to consumers about 
how to minimize their exposure, among other things. 

All manuals we reviewed, except one, include a statement that, when 
used on the body, as opposed to against the ear, a minimum distance 
between the body and the mobile phone should be maintained. These 
distances ranged from 1.5 to 2.5 centimeters. Since all mobile phones 
are tested for RF energy exposure compliance at a distance from the 
body, as discussed previously in this report, these instructions are 
consistent with how the devices were tested and certified by FCC. Some 
consumer groups and experts we spoke with noted that consumers could 
be unaware of these instructions if they do not read the entire user 
manual. 

Conclusions: 

FCC's current RF energy exposure limit for mobile phones, established 
in 1996, may not reflect the latest evidence on the thermal effects of 
RF energy exposure and may impose additional costs on manufacturers 
and limitations on mobile phone design. FCC regulates RF energy 
emitted from mobile phones and relies on federal health and safety 
agencies to help determine the appropriate RF energy exposure limit. 
However, 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. This 
evidence has led to a new RF energy exposure limit recommendation from 
international organizations. Additionally, maintaining the current 
U.S. limit may result in additional costs for manufacturers and impact 
phone design in a way that could limit performance and functionality. 
Reassessing its current RF energy exposure limit would ensure that 
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. 

The current testing requirements for mobile phones may not identify 
the maximum RF energy exposure when tested against the body. FCC 
testing requirements state that mobile phone tests should be conducted 
with belt-clips and holsters attached to the phone or at a 
predetermined distance from the body. These requirements were 
developed by FCC to identify the maximum RF energy exposure a user 
could experience when using a mobile phone, to ensure that the mobile 
phone meets the agency's RF energy exposure limit. This limit was 
designed to ensure that mobile phones do not expose the public to 
levels of RF energy that could be potentially harmful. By testing 
mobile phones only when at a distance from the body, FCC may not be 
identifying the maximum exposure, since some users may hold a mobile 
phone directly against the body while in use. Using a mobile phone in 
this manner could result in RF energy exposure above the maximum body-
worn SAR determined during testing, although that may not necessarily 
be in excess of FCC's limit. Reassessing its testing requirements 
would allow FCC to ensure that phones used by consumers in the United 
States do not result in RF energy exposure in excess of FCC's limit. 

Recommendations for Executive Action: 

We recommend that the Chairman of the FCC take the following two 
actions: 

* 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. 

* 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. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Department of Commerce, 
Department of Defense, Department of Health and Human Services, 
Department of Labor, EPA, and FCC for review and comment. FCC provided 
comments in a letter from the Chief, Office of Engineering and 
Technology. (See appendix III.) In this letter, FCC noted that FCC's 
staff has independently arrived at the same conclusions about the RF 
exposure guidelines as GAO. 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 FCC staff to the Commission for 
their consideration, has the potential to address the recommendations 
made in this report. We agree that FCC's planned actions may address 
our recommendations. However, since FCC has not yet initiated a review 
of the RF energy exposure limit or mobile phone testing requirements, 
our recommendations are still relevant. FCC and the Departments of 
Commerce, Defense, and Health and Human Services also provided 
technical comments, which were incorporated as appropriate. The 
Department of Labor and EPA did not provide comments on the draft. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies of this report 
to the appropriate congressional committees, the Chairman of the FCC, 
the Administrator of the EPA, as well as the Secretaries of the 
Departments of Commerce, Defense, Health and Human Services, and 
Labor. The report will also be available at no charge on GAO's website 
at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions or would like to discuss this 
work, please contact Mark Goldstein at (202) 512-2834 or 
goldsteinm@gao.gov or Marcia Crosse at (202) 512-7114 or 
crossem@gao.gov. Contact points for our Offices of Congressional 
Relations and Public Affairs may be found on the last page of this 
report. Individuals making key contributions to this report are listed 
in appendix IV. 

Signed by: 

Mark L. Goldstein: 
Director, Physical Infrastructure: 

Signed by: 

Marcia Crosse: 
Director, Health Care: 

[End of section] 

Appendix I: Scope and Methodology: 

To determine what is known about the human health effects of radio-
frequency (RF) energy exposure from mobile phone use, we reviewed 
selected studies including studies and reports that review and assess 
the scientific research, such as meta-analyses and government reports, 
as well as key individual epidemiological and laboratory studies. 
[Footnote 44] We identified 384 studies that examine the health 
effects of RF energy emitted from mobile phone use through literature 
searches and interviews. We conducted literature searches in six 
online databases with health and engineering content--Embase, Inspec, 
Medline, National Technical Information Service Bibliographic, 
SciSearch, and SocialSciSearch--containing peer-reviewed publications 
and government reports to identify studies published from January 2006 
through September 2011 using health-, mobile phone-, and RF energy-
related search terms. Additionally, we interviewed officials from 
federal agencies and representatives of academic institutions, 
consumer groups, and industry associations to identify studies 
published through December 2011. To select studies for our review, we 
conducted a preliminary review of the 384 studies and included those 
that met the following criteria: (1) reviewed and assessed the 
scientific research in a systematic way, such as meta-analyses, and 
discussed their methods for identifying, selecting, and assessing the 
scientific research that were used to draw conclusions or (2) were key 
reports that identify areas for additional research in these fields, 
such as the 2008 National Research Council's Identification of 
Research Needs Relating to Potential Biological or Adverse Health 
Effects of Wireless Communication.[Footnote 45] We selected 38 studies 
that met these criteria. (See appendix II for a list of the 38 studies 
we reviewed.) 

To collect information on the 38 selected studies, we developed a data 
collection instrument that contained 16 open-and closed-ended 
questions about the entity or entities that published and funded the 
study; the study methods, key findings, and limitations; and 
additional research needs. To apply this data collection instrument, 
one analyst reviewed each study and recorded information in the data 
collection instrument. A second analyst then reviewed each completed 
data collection instrument to verify the accuracy of the information 
recorded. We summarized the findings and limitations of studies based 
on the completed data collection instruments, as well as areas for 
additional research identified in the studies. Additionally, we used 
this analysis to identify key, individual, epidemiological and 
laboratory studies. 

We also interviewed subject matter experts to determine what is known 
about the human health effects of RF energy exposure from mobile phone 
use. First, we identified 123 potential subject matter experts to 
interview through the following sources: (1) interviews with officials 
from federal agencies and representatives of academic institutions, 
consumer groups, and industry associations and (2) participant lists 
of recent expert panels and workgroups on this topic. These panels and 
workgroups included: 

* The National Research Council's Committee on Identification of 
Research Needs Relating to Potential Biological or Adverse Health 
Effects of Wireless Communications Devices,[Footnote 46] 

* The International Agency for Research on Cancer's (IARC) Monograph 
Working Group on RF electromagnetic fields,[Footnote 47] 

* The INTERPHONE Study Group,[Footnote 48] and: 

* The European Commission's Scientific Committee on Emerging and Newly 
Identified Health Risks.[Footnote 49] 

Second, we assigned each expert to one or more broad categories that 
captured his or her general area of expertise. Next, we e-mailed those 
experts who, based on our initial review, (1) were identified through 
at least one source and we had information on their general area of 
expertise or (2) were identified through at least two sources 
regardless of whether we had information on their general area of 
expertise. We received responses from 42 experts agreeing to help us 
with our study. Based on these responses, we selected a judgmental 
sample of 11 experts who represented a range of expertise and 
professional backgrounds including public health and policy; biology 
and medicine; biostatistics; epidemiology; engineering, including 
bioelectrical engineering; and RF energy standards. (See table 3 for 
the list of individuals interviewed.) These experts were interviewed 
as individuals, not as representatives of any institution. Further, 
all of the experts completed a form stating that they had no conflicts 
of interest that would affect their ability to provide us with their 
perspectives on what is known about the human health effects of RF 
energy exposure from mobile phone use and related issues. 

Table 3: Subject Matter Experts Interviewed: 

Name: Carl Blackman; 
Title: a founder and former President (1990-91); 
Institution[A]: Bioelectromagnetics Society. 

Name: Linda Erdreich; 
Title: Senior Managing Scientist; 
Institution[A]: Center for Epidemiology and Computational Biology, 
Exponent. 

Name: Jukka Juutilainen; 
Title: Professor of Radiation Biology and Radiation Epidemiology; 
Institution[A]: Department of Environmental Science, University of 
Eastern Finland. 

Name: Leeka Kheifets; 
Title: Professor of Epidemiology; 
Institution[A]: Department of Epidemiology, School of Public Health, 
University of California, Los Angeles. 

Name: Henry Lai; 
Title: Research Professor; 
Institution[A]: Department of Bioengineering, University of Washington. 

Name: James Lin; 
Title: Professor of Electrical Engineering, Bioengineering, 
Physiology, and Biophysics; 
Institution[A]: University of Illinois, Chicago. 

Name: David McCormick; 
Title: Senior Vice President and Director; 
Institution[A]: IIT Research Institute. 

Name: Martin Röösli; 
Title: Assistant Professor; 
Institution[A]: Unit for Environmental Exposures and Health, Swiss 
Tropical and Public Health Institute, Basel. 

Name: Siegal Sadetzki; 
Title: Head; 
Institution[A]: Cancer and Radiation Epidemiology Unit, The Gertner; 
Institute, Chaim Sheba Medical Center, Israel; 
Title: Associate Professor; 
Institution[A]: Sackler School of Medicine, Tel-Aviv University, 
Israel. 

Name: Jonathan Samet; 
Title: Professor and Flora L. Thornton Chair; 
Institution[A]: Department of Preventive Medicine, Keck School of 
Medicine, University of Southern California. 

Name: Bernard Veyret; 
Title: Senior Scientist; 
Institution[A]: National Center for Scientific Research, Bordeaux 
University, France. 

Source: GAO. 

[A] We interviewed experts as individuals, not as representatives of 
any institution. We provide information on institutions to help 
readers identify experts. 

[End of table] 

To determine the current research activities of federal agencies and 
other organizations related to mobile phone use and health, we 
interviewed representatives from various agencies and organizations. 
We identified agencies and organizations by reviewing information on 
their websites on RF energy and conducting interviews with officials 
from federal agencies and representatives of organizations familiar 
with research on health effects of mobile phone use. To determine the 
current research activities of federal agencies related to mobile 
phone use and health, we interviewed officials from the Department of 
Defense; Department of Health and Human Services' Centers for Disease 
Control and Prevention (CDC), Food and Drug Administration (FDA), and 
National Institutes of Health (NIH); Department of Labor's 
Occupational Safety and Health Administration (OSHA); Environmental 
Protection Agency (EPA); and Federal Communications Commission (FCC). 
To determine the research activities of other organizations, we 
interviewed representatives from IARC, academic institutions, consumer 
groups, mobile phone industry associations, mobile phone 
manufacturers, and mobile phone providers. 

To determine how FCC set the RF energy exposure limit and ensures 
compliance with it, we reviewed and summarized FCC regulations and 
guidance as well as reports from international organizations that 
recommend RF energy exposure limits. We also reviewed and summarized 
FCC testing and certification regulations and guidance for mobile 
phones. We conducted interviews with officials from FCC and 
representatives from selected Telecommunication Certification Bodies 
(TCBs). We selected the four TCBs that approved the most mobile phone 
certification applications for fiscal years 2000-2011 according to 
FCC: PCTEST Engineering Laboratory, Inc.; ACB, Inc.; CETECOM ICT 
Services GmbH; and Timco Engineering, Inc. These four TCBs have 
approved 69 percent of all U.S. mobile phone applications since 2000. 
We interviewed representatives from National Institute of Standards 
and Technology, American National Standards Institute, and American 
Association for Laboratory Accreditation to discuss their role in 
accrediting entities as TCBs and monitoring the activities of current 
TCBs. We also conducted interviews with representatives of the mobile 
phone industry and consumer groups for their perspectives on RF energy 
exposure limits as well as the testing and certification of mobile 
phones. Representatives of the mobile phone industry we spoke with 
included industry associations (CTIA-The Wireless Association and 
Mobile Manufacturers Forum) as well as the top four mobile phone 
service providers (AT&T, Sprint, T-Mobile, and Verizon) that represent 
about 90 percent of U.S. mobile phone service subscribers. We also 
spoke with representatives from four mobile phone manufacturers that 
represent over 70 percent of the U.S. market (LG, Motorola, Nokia, and 
Samsung). 

To determine the actions federal agencies and the industry take to 
inform the public about issues related to mobile phone health effects, 
we reviewed the information on federal agency websites. We identified 
six federal agencies that have information about mobile phones and 
health-related issues on their websites: CDC, EPA, FCC, FDA, NIH, and 
OSHA. We conducted interviews with officials from those federal 
agencies to learn how they developed and update their websites. We 
spoke with representatives of the mobile phone industry noted above 
and consumer groups to obtain perspectives on the strengths and 
limitations of federal agency public-information-sharing efforts. We 
also spoke with the representatives of the mobile phone industry about 
how and why manufacturers include warnings or specific usage 
guidelines in their user manuals. Finally, we reviewed the user 
manuals of selected mobile phones (see table 4) to identify the usage 
and health information being provided to consumers, including any 
instructions to hold the mobile phone away from the body during use. 
The specific mobile phone models were identified by the manufacturers 
we spoke with as their top selling models in 2011. 

Table 4: Mobile Phone User Manuals Reviewed: 

Manufacturer: Apple[A]; 
Phone model: iPhone 4. 

Manufacturer: LG; 
Phone model: Octane; 
Phone model: Optimus. 

Manufacturer: Motorola; 
Phone model: Bionic; 
Phone model: Razr. 

Manufacturer: Nokia; 
Phone model: 1616; 
Phone model: 6350; 
Phone model: X2-01. 

Manufacturer: Samsung; 
Phone model: GoPhone; 
Phone model: Gusto; 
Phone model: TracFone. 

Source: GAO. 

[A] We included the Apple iPhone because of its prominence in the 
industry. Representatives from Apple declined to speak with us for 
this report. 

[End of table] 

[End of section] 

Appendix II: Studies GAO Reviewed: 

Ahlbom, Anders, Maria Feychting, Adele Green, Leeka Kheifets, David A. 
Savitz, and Anthony J. Swerdlow. "Epidemiological Evidence on Mobile 
Phones and Tumor Risk: A Review." Epidemiology, vol. 20, no. 5 (2009): 
639-652. 

Balbani, Aracy Pereira Silveira, and Jair Cortez Montovani. "Mobile 
Phones: Influence on Auditory and Vestibular Systems." Brazilian 
Journal of Otorhinolaryngology, vol 74, no. 1 (2008): 125-131. 

Clapp, Richard W., Molly M. Jacobs, and Edward L. Loechler. 
"Environmental and Occupational Causes of Cancer: New Evidence 2005-
2007." Reviews on Environmental Health, vol. 23, no. 1 (2008): 1-37. 

Committee on Man and Radiation. "COMAR Technical Information 
Statement: Expert Reviews on Potential Health Effects of 
Radiofrequency Electromagnetic Fields and Comments on the 
Bioinitiative Report." Health Physics, vol. 97, no. 4 (2009): 348-356. 

Edumed Institute for Medicine and Health. Non-Ionizing Electromagnetic 
Radiation in the Radiofrequency Spectrum and its Effects on Human 
Health. Latin American Experts Committee on High Frequency 
Electromagnetic Fields and Human Health. June 2010. 

European Health Risk Assessment Network on Electromagnetic Fields 
Exposure. "Risk Analysis of Human Exposure to Electromagnetic Fields." 
Deliverable Report D2, Executive Agency for Health and Consumers 
Framework of the Programme of Community Action in the Field Of Health 
2008-2013. July 2010. 

European Health Risk Assessment Network on Electromagnetic Fields 
Exposure. "D3 - Report on the analysis of risks associated to exposure 
to EMF: in vitro and in vivo (animals) studies." July 2010. 

French Environmental Health and Safety Agency. "AFSSE Statement on 
Mobile Phones and Health." AFSSE. April 16, 2003. 

German Mobile Telecommunication Research Programme. "Health Risk 
Assessment of Mobile Communications." Department Radiation Protection 
and Health. Germany: 2008. 

Habash, Riadh W.Y., J. Mark Elwood, Daniel Krewski, W. Gregory Lotz, 
James P. McNamee, and Frank S. Prato. "Recent Advances in Research On 
Radiofrequency Fields and Health: 2004-2007." Journal of Toxicology 
and Environmental Health, Part B, vol. 12 (2009): 250-288. 

Han, Yueh-Ying, Hideyuki Kano, Devra L. Davis, Ajay Niranjan, and L. 
Dade Lunsford. "Cell Phone Use and Acoustic Neuroma: The Need for 
Standardized Questionnaires and Access to Industry Data." Surgical 
Neurology, vol. 72 (2009): 216-222. 

Health Council of the Netherlands. "Electromagnetic Fields: Annual 
Update 2008." The Hague: Health Council of the Netherlands, 2008; 
publication no. 2009/02. 

HERMO. Health Risk Assessment of Mobile Communications. A Finnish 
Research Programme. Finland: 2007. 

Institution of Engineering and Technology. "The Possible Harmful 
Biological Effects of Low-Level Electromagnetic Fields of Frequencies 
up to 300 GHz." 2010 Position Statement, Institution of Engineering 
and Technology. United Kingdom: 2010. 

International Commission on Non-Ionizing Radiation Protection. 
Exposure to high frequency electromagnetic fields, biological effects 
and health consequences (100 kHz-300 GHz). Germany: 2009. 

Juutilainen, Jukka, Anne Höytö, Timo Kumlin, and Jonne Naarala. 
"Review of Possible Modulation-Dependent Biological Effects of 
Radiofrequency Fields." Bioelectromagnetics, vol. 35 (2011): 511-534. 

Khurana, Vini G., Charles Teo, Michael Kundi, Lennart Hardell, and 
Michael Carlberg. "Cell Phones and Brain Tumors: A Review Including 
the Long-Term Epidemiological Data." Surgical Neurology, vol. 72 
(2009): 205-215. 

Kohli, D., A. Sachdev, and H. Vats. "Cell Phones and Tumor: Still In 
No Man's Land." Indian Journal of Cancer, vol. 46, no. 1 (2009): 5-12. 

Kundi, Michael. "The Controversy About a Possible Relationship Between 
Mobile Phone Use and Cancer." Ciencia & Saude Coletiva, vol. 15, no. 5 
(2010): 2415-2430. 

Levis, Angelo G., Nadia Minicuci, Paolo Ricci, Valerio Gennaro, and 
Spiridione Garbisa. "Mobile Phones and Head Tumours. The Discrepancies 
in Cause-Effect Relationships in the Epidemiological Studies - How Do 
They Arise?" Environmental Health, vol. 10, no. 59. (2011): 1-15. 

Marino, Andrew A., and Simona Carrubba. "The Effects of Mobile-Phone 
Electromagnetic Fields of Brain Electrical Activity: A Critical 
Analysis of the Literature." Electromagnetic Biology and Medicine, 
vol. 28 (2009): 250-274. 

McKinlay, A.F., S.G. Allen, R. Cox, P.J. Dimbylow, S.M. Mann, C.R. 
Muirhead, R.D. Saunders, Z.J. Sienkiewicz, J.W. Stather, and P.R. 
Wainwright. "Advice on Limiting Exposure to Electromagnetic Fields (0-
300 GHz)." Documents of the NRPB, vol. 15, no. 2. National 
Radiological Protection Board, 2004. 

Mobile Telecommunications and Health Research Programme. "Report 
2007." United Kingdom: October 2007. 

Myung, Seung-Kwon, Woong Ju, Diana D. McDonnell, Yeon Ji Lee, Gene 
Kazinets, Chih-Tao Cheng, and Joel M. Moskowitz. "Mobile Phone Use and 
Risk of Tumors: A Meta-Analysis" Journal of Clinical Oncology, vol. 
27, no. 33 (2009): 5565-5572. 

National Council on Radiation Protection and Measurements. "Biological 
Effects of Modulated Radiofrequency Fields." NCRP Commentary, no. 18. 
Bethesda, MD: 2003. 

National Research Council. Identification of Research Needs Relating 
to Potential Biological or Adverse Health Effects of Wireless 
Communication. Washington, D.C.: 2008. 

Nieden, Anja zur, Corrina Dietz, Thomas Eikmann, Jürgen Kiefer, and 
Caroline E.W. Herr. "Physicians Appeals On the Dangers of Mobile 
Communication - What Is the Evidence? Assessment of Public Health 
Data." International Journal of Hygiene and Environmental Health, vol. 
212 (2009): 576-587. 

Pourlis, Aris F., "Reproductive and Developmental Effects of EMF in 
Vertebrate Animal Models." Pathophysiology, vol. 16 (2009): 179-189. 

Regel, Sabine J., and Peter Achermann. "Cognitive Performance Measures 
in Bioelectromagnetic Research - Critical Evaluation and 
Recommendations." Environmental Health, vol. 10, no. 10 (2011). 

Röösli, Martin, and Kerstin Hug. "Wireless Communication Fields and 
Non-Specific Symptoms of Ill Health: A Literature Review." Weiner 
Medizinische Wochenschrift, vol. 161, no. 9-10 (2011): 240-250. 

Scientific Committee on Emerging and Newly Identified Health Risks. 
Health Effects of Exposure to EMF. European Commission. January 19, 
2009. 

Sixth Framework Programme. "EMF-NET: Effects of the Exposure to 
Electromagnetic Fields: From Science to Public Health and Safer 
Workplace." WP2.2 Deliverable report D4bis: Effects on Reproduction 
and Development. Italy: 2007. 

Swedish Radiation Protection Authority. Recent Research on EMF and 
Health Risks Fifth Annual Report from SSI:s Independent Expert Group 
on Electromagnetic Fields, 2007, Sweden: 2008. 

Swedish Radiation Safety Authority. Recent Research on EMF and Health 
Risk Seventh Annual Report from SSM:s Independent Expert Group on 
Electromagnetic Fields, 2010. Sweden: 2010. 

Valentini, E., G. Curcio, F. Moroni, M. Ferrara, L. De Gannaro, and M. 
Bertini. "Neurophysiological Effects of Mobile Phone Electromagnetic 
Fields on Humans: A Comprehensive Review." Bioelectromagnetics, vol. 
28 (2007): 415-432. 

Vanderstraeten, Jacques, and Luc Verschaeve. "Gene and Protein 
Expression Following Exposure to Radiofrequency Fields from Mobile 
Phones." Environmental Health Perspectives, vol. 116, no. 9 (2008): 
1131-1135. 

Vijayalaxmi, and Thomas J. Prihoda. "Genetic Damage in Mammalian 
Somatic Cells Exposed to Radiofrequency Radiation: A Meta-Analysis of 
Data from 63 Publications (1990-2005)." Radiation Research, vol.169 
(2008): 561-574. 

World Health Organization. WHO Research Agenda for Radiofrequency 
Fields. Switzerland: 2010. 

[End of section] 

Appendix III: Comments from the Federal Communications Commission: 

Federal Communications Commission: 
Washington, D.C. 20554: 

July 6, 2012: 

Mr. Mark Goldstein: 
Director, Physical Infrastructure Issues: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Goldstein, 

Thank you for providing the Federal Communications Commission with the 
opportunity to comment on your draft Report: Mobile Phone Exposure and 
Testing Should Be Reassessed. 

The report presents a thorough and cogent explication of the 
challenging and complex area of the potential health effects of 
radiofrequency (RF) emissions from cell phones. Notably, the report 
finds that scientific research to date has not demonstrated adverse 
human health effects of radiofrequency (RF) exposure from mobile phone 
use, but that the FCC's current RF exposure guidelines for mobile 
phones may not reflect the latest standards and information on the 
thermal effects of RF exposure and the current testing requirements 
may not reflect the maximum exposure for certain use cases. 

The Commission staff has continuously paid close attention to 
developments related to RF exposure and has worked closely with other 
federal agencies with health expertise such as the Food and Drug 
Administration. At this juncture, we believe our current standards are 
appropriate and protect the public against the possible harmful 
effects of RF exposure. However, we appreciate that it has been many 
years since the Commission conducted a formal review of the current 
standard. 

As you are aware, the Commission issued a Notice of Proposed Rule Making
(Notice) in ET Docket 03-137 in 2004 to clarify various of the RF 
exposure rules. The Notice specifically excluded consideration of the 
RF exposure standards. Many of the issues in the Notice that were 
related to equipment certification have been addressed through our 
equipment authorization program. Meanwhile the staff continued to work 
on a draft decision and proposal as a next step. With the passage of 
time and the increase in research and other developments, the staff 
appreciated that it would be appropriate to review the standards as 
well. Accordingly, the Commission staff has drafted and presented to 
the Commission for consideration a combined Order and Further Notice 
of Proposed Rulemaking in ET Docket 03-137, along with a Notice of 
Inquiry under a new docket number to review the standards and related 
matters. 

In short, the Commission's staff had independently arrived at the same 
conclusions as are reflected in the GAO report. We believe that the 
draft document currently 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. 

In discussing our referral of consumers to other agencies' websites 
for information about research in this area, you note that our 
weblinks to the websites of the Food and Drug Administration and the 
Environmental Protection Agency were not functional when you tried to 
use them in April of this year. We can advise you that those weblinks 
are currently functioning properly. 

Thank you again for the opportunity to provide comments and further 
information with respect to this GAO Report. If you have any 
questions, please contact Bruce Romano at 202-418-2124 or 
bruce.romano@fcc.gov. 

Sincerely, 

Signed by: 

Julius P. Knapp: 
Chief: 
Office of Engineering and Technology: 
Federal Communications Commission: 

[End of section] 

Appendix IV: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Mark L. Goldstein, (202) 512-2834 or goldsteinm@gao.gov: 

Marcia Crosse, (202) 512-7114 or crossem@gao.gov: 

Staff Acknowledgments: 

In addition to the contacts named above, Janina Austin and Teresa 
Spisak, Assistant Directors, as well as Kyle Browning, Owen Bruce, 
Marquita Campbell, Leia Dickerson, Kristin Ekelund, Lorraine Ettaro, 
Colin Fallon, David Hooper, Rosa Leung, and Maria Stattel made key 
contributions to this report. 

[End of section] 

Footnotes: 

[1] In this report, we use the term "mobile phone" to refer to 
handheld (i.e., wireless) cellular telephones, including newer 
personal communication devices, such as "smart phones," that can 
deliver voice, data, and images. 

[2] 47 C.F.R. § 1.1307(b)(2). 

[3] 21 U.S.C. §§ 360hh--360ss. 

[4] 21 U.S.C. § 360ll. 

[5] GAO, Telecommunications: Research and Regulatory Efforts on Mobile 
Phone Health Issues, [hyperlink, 
http://www.gao.gov/products/GAO-01-545] (Washington, D.C.: May 7, 
2001). 

[6] Federal Communications Commission, Annual Report and Analysis of 
Competitive Market Conditions With Respect to Mobile Wireless, 
Including Commercial Mobile Services, Fifteenth Report (June 27, 2011). 

[7] Annual Report and Analysis of Competitive Market Conditions With 
Respect to Mobile Wireless, Including Commercial Mobile Services 
(2011). 

[8] Annual Report and Analysis of Competitive Market Conditions With 
Respect to Mobile Wireless, Including Commercial Mobile Services 
(2011). 

[9] Lenhart, A., et al, Teens and Mobile Phones, Pew Internet & 
American Life Project (April 20, 2010). 

[10] [hyperlink, http://www.gao.gov/products/GAO-01-545]. 

[11] IARC's classification of RF energy is based on conclusions of an 
IARC working group of more than 30 scientists from 14 countries who 
reviewed the scientific evidence on the exposure to RF energy from 
personal devices, such as mobile phones and other sources. IARC 
published a summary of this working group's findings, see Baan, R., et 
al, "Carcinogenicity of Radiofrequency Electromagnetic Fields," The 
Lancet Oncology, 2011, 12(7): 624-626. According to IARC officials, 
the IARC Monograph containing the complete assessments of the working 
group will be published in fall 2012. IARC has five groups for 
classifying factors: 1--carcinogenetic to humans, 2A--probably 
carcinogenic to humans, 2B--possibly carcinogenic to humans, 3--not 
classifiable as to its carcinogenicity to humans, and 4--probably not 
carcinogenic to humans. As of July 11, 2012, IARC had classified 952 
factors, of which 779 have been classified in groups 2B or 3. Factors 
classified in the 2B group include coffee and gasoline. 

[12] IARC also determined that the evidence from the scientific 
research was limited for acoustic neuromas, a type of non-cancerous 
brain tumor. 

[13] Health Protection Agency, Health Effects from Radiofrequency 
Electromagnetic Fields, RCE-20 (2012). 

[14] This study was conducted at 16 research sites. Several 
publications are available on study findings from the individual 
research sites. Findings discussed here are the primary study findings 
published by the INTERPHONE Study Group. See The INTERPHONE Study 
Group, "Brain Tumour Risk In Relation To Mobile Telephone Use: Results 
of the INTERPHONE International Case-Control Study," International 
Journal of Epidemiology, 2010, 39: 675-694. 

[15] A "case-control" study is a study that compares individuals with 
a particular disease or outcome--cases--to individuals without that 
disease or outcome--controls--to investigate if the outcome is 
associated with exposure to a specific factor. Case-control studies 
are sometimes called retrospective studies, because the outcome 
occurred before the study began. 

[16] RF energy exposure levels from mobile phone use were measured in 
terms of (1) the number of years since first use, (2) cumulative 
number of calls, and (3) cumulative duration of calls. Analysis of the 
relationship between RF energy exposure and risk of four types of 
tumors--tumors of the brain including glioma and meningioma, acoustic 
nerve, and parotid gland--were done using these three measures. 
Individuals that fell into the highest level of exposure are those 
that reported 1,640 or more cumulative lifetime hours of mobile phone 
use, which ranged from less than 1 year to more than 10 years of use. 

[17] A "cohort" study is a study that follows a defined group of 
people--the cohort--over time. Outcomes of the people in subsets of 
the cohort are compared to examine if a particular intervention or 
factor is associated with a particular outcome. Cohort studies are 
sometimes called prospective studies, although they can be performed 
either retrospectively from historical records or prospectively. 

[18] Schüz, J., et al, "Cellular Telephone Use and Cancer Risk: Update 
of a Nationwide Danish Cohort," Journal of the National Cancer 
Institute, 2006, 98(23):1707-1713. 

[19] Frei, P., et al, "Use of Mobile Phones and Risk of Brain Tumours: 
Update of Danish Cohort Study," British Medicine Journal, 2011, 343: 
d6387. 

[20] Aydin, D., et al, "Mobile Phone Use and Brain Tumors in Children 
and Adolescents: A Multicenter Case-Control Study," Journal of the 
National Cancer Institute, 2011, 103: 1-13. 

[21] Inskip, P.D., Hoover, R.N., Devesa, S.S., "Brain Cancer Incidence 
Trends In Relation To Cellular Telephone Use In the United States," 
Neuro-Oncology, 2010, 12(11): 1147-1151. 

[22] For example see Nikolova, T., et al, "Electromagnetic Fields 
Affect Transcript Levels of Apoptosis-Related Genes In Embryonic Stem 
Cell-Derived Neural Progenitor Cells," The FASEB Journal, 2005, 12: 
1686-1688 and Diem, E., et al, "Non-Thermal DNA Breakage by Mobile-
Phone Radiation (1800 MHz) In Human Fibroblasts and In Transformed 
GFSH-R17 Rat Granulosa Cells In Vitro," Mutation Research, 2005, 
583(2): 178-183. 

[23] For example see Speit, G., Schütz, P., Hoffmann, H., "Genotoxic 
Effects of Exposure To Radiofrequency Electromagnetic Fields (RF-EMF) 
In Cultured Mammalian Cells Are Not Independently Reproducible," 
Mutation Research, 2007, 626(1-2): 42-47 and Hook, G.J., et al, 
"Measurement of DNA Damage and Apoptosis In Molt-4 Cells After In 
Vitro Exposure To Radiofrequency Radiation," Radiation Research, 2004, 
161(2):193-200. 

[24] For example see Kumlin T., et al, "Mobile Phone Radiation and the 
Developing Brain: Behavioral and Morphological Effects in Juvenile 
Rats," Radiation Research, 2007, 168(4): 471-479 and Nittby, H., et 
al, "Cognitive Impairment in Rats After Long-Term Exposure to GSM-900 
Mobile Phone Radiation," Bioelectromagnetics, 2008, 29(3): 219-232. 

[25] For example see Volkow, N.D., et al, "Effects of Cell Phone 
Radiofrequency Signal Exposure on Brain Glucose Metabolism," Journal 
of the American Medical Association, 2011, 305(8): 808-813 and Regel, 
S.J., et al, "Pulsed Radio-Frequency Electromagnetic Fields: Dose-
Dependent Effects on Sleep, the Sleep EEG and Cognitive Performance," 
Journal of Sleep Research, 2007, 16: 253-258. 

[26] The National Toxicology Program is an interagency program that 
evaluates factors, such as RF energy, that could affect public health 
for the federal government. The three core federal agencies that make-
up this program are NIH's National Institute of Environmental Health 
Sciences, CDC's National Institute for Occupational Safety and Health, 
and FDA's National Center for Toxicological Research. The National 
Toxicology Program is conducting comprehensive carcinogenicity studies 
on laboratory animals. Collectively these studies will provide 
information about potential human health effects of RF energy exposure. 

[27] The World Health Organization most recently updated this research 
agenda in 2010. See The World Health Organization, WHO Research Agenda 
for Radiofrequency Fields, Geneva, Switzerland (2010). 

[28] 61 Fed. Reg. 41017, August, 7, 1996. This measurement is called 
the specific absorption rate (SAR) and is the widely accepted 
measurement of RF energy absorbed into the body in watts per kilogram, 
averaged over an amount of tissue ranging from the entire body to one 
gram. 

[29] See IEEE Std. C95.1-1991 and 47 CFR Sec. 2.1093(d)(2). 

[30] In scientific tests, animals had adverse behavioral effects once 
they absorbed enough RF energy to increase their body temperature by 1 
degree Celsius. IEEE incorporated a safety factor into its standards 
for general human exposure by setting them at one-fiftieth the 
exposure shown to cause adverse effects in animals. Because this limit 
is based on whole-body exposure, it was further adjusted to account 
for the fact that mobile phones expose only a part of the body to RF 
energy. 

[31] See IEEE Std. C95.1-2005. 

[32] The output power of a phone is variable, using the minimum 
necessary for successful communication, and at any time will be a 
function of distance to the nearest mobile phone antenna and the 
presence of obstructions. 

[33] See International Commission on Non-Ionizing Radiation 
Protection, Guidelines for Limiting Exposure to Time-Varying Electric, 
Magnetic, and Electromagnetic Fields (Up to 300 GHz) (1998). The 
International Commission on Non-Ionizing Radiation Protection is an 
independent scientific organization that provides guidance and advice 
on the health hazards of non-ionizing radiation exposure. Its 
recommended exposure limit is for frequencies up to 10 gigahertz. The 
IEEE recommendation was made for frequencies between 100 kilohertz and 
3 gigahertz. 

[34] In re Guidelines for Evaluating the Environmental Effects of 
Radiofrequency Radiation, 11 FCC Rcd 15123, 15125 (1996). 

[35] FCC's rulemaking process includes multiple steps as outlined by 
law, with several opportunities for public participation. FCC 
generally begins the process by releasing a Notice of Proposed 
Rulemaking and establishing a docket to gather information submitted 
by the public or developed within FCC to support the proposed rule. 
FCC analyzes information in the docket and drafts a final rule. 

[36] In 1999, FCC established a TCB program and requested that the 
National Institute of Standards and Technology accredit entities to 
perform TCB functions. The National Institute of Standards and 
Technology determined, in accordance with its procedures and in 
consultation with the FCC, that it would recognize qualified 
accreditation bodies to accredit TCBs. Subsequently, the National 
Institute of Standards and Technology approved ANSI in May 2000 and 
the American Association for Laboratory Accreditation in April 2007 as 
accreditation organizations for TCBs. These accreditation bodies 
assess new and current TCBs to ensure they comply with relevant 
requirements. 

[37] According to FCC, third and fourth generation mobile phone 
technologies allow consumers to access a variety of different services 
and functionalities, such as Web browsing, e-mail, access to 
application stores, video conference or chat, mapping and navigation 
systems, mobile commerce, and the downloading of content. 

[38] These procedures were based on IEEE Std. 1528-2003. Because 
mobile phones are not tested when in use directly against the body, 
FCC recommends that mobile phone user manuals note that a minimum 
separation distance must be maintained between the user's body and the 
phone to comply with RF exposure limits. 

[39] FCC guidance states that mobile phone body-worn tests should be 
conducted with belt-clips and holsters attached to the phone and 
positioned against the flat surface of the mold in normal use 
configurations. If the manufacturer does not supply these accessories, 
a predetermined distance from the back of the mobile device to the 
flat surface of the mold is recommended. 

[40] Testing may be performed at either the TCB's testing facilities 
or at a subcontracted test facility. 

[41] FCC's links to the EPA and FDA websites were not functional when 
we reviewed them in April 2012. After we provided our draft report to 
FCC these links were fixed and were functional as of July 2012. 

[42] The ordinance has been challenged in federal court. The case is 
currently being considered by the U.S. Court of Appeals for the 9TH 
Circuit. 

[43] FCC does require a statement that the mobile phone complies with 
the agency's RF energy exposure limit, among other things. 47 CFR § 
2.1077. 

[44] Epidemiological studies investigate the association, if any, 
between health effects and the characteristics of people and their 
environment. Laboratory studies conducted on test subjects--including 
human volunteers, laboratory animals, biological tissue samples, or 
isolated cells--are used to determine a causal relationship between 
possible risk factors and human health, and the possible mechanisms 
through which that relationship occurs. 

[45] See National Research Council, Identification of Research Needs 
Relating to Potential Biological or Adverse Health Effects of Wireless 
Communication (Washington, D.C.: 2008). 

[46] National Research Council, Identification of Research Needs 
Relating to Potential Biological or Adverse Health Effects of Wireless 
Communication (Washington, D.C.: 2008). 

[47] Baan, R., et al, "Carcinogenicity of Radiofrequency 
Electromagnetic Fields," Lancet Oncology, 2011, 12(7): 624-626. 

[48] The INTERPHONE study is a retrospective case-control study that 
examined effects of mobile phone use on certain types of brain cancers 
or tumors in more than 5,000 cases aged 30-59 years in 13 countries. 
See Cardis, E, et al, "Brain Tumor Risk in Relation to Mobile 
Telephone Use: Results of the INTERPHONE International Case-Control 
Study," International Journal of Epidemiology, 2010, 39: 675-694. 

[49] European Commission, Health Effects of Exposure to EMF, 2009. 

[End of section] 

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