TELECOMMUNICATIONS

Exposure and Testing 

Requirements for Mobile 

Phones Should Be 

Reassessed

Report to Congressional Requesters

July 2012

GAO-12-771

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-771, a report to 

congressional requesters

July 2012

TELECOMMUNICATIONS

Exposure and Testing Requirements for Mobile 

Phones Should Be Reassessed

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 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. 

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. 

View 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. 
Page i GAO-12-771 Telecommunications

Letter 1 

Background 4

Research on RF Energy Exposure from Mobile Phones Has Not 

Demonstrated Adverse Health Effects, but More Studies Are 

Under Way 6

FCC’s RF Energy Exposure Limit May Not Reflect Latest Evidence 

on Thermal Effects, and Mobile Phone Testing Requirements 

May Not Identify Maximum Exposure 16

Federal Agencies and Mobile Phone Industry Provide Information 

to the Public through Websites and User Manuals 24

Conclusions 27

Recommendations for Executive Action 28

Agency Comments and Our Evaluation 28

Appendix I Scope and Methodology 30

Appendix II Studies GAO Reviewed 35

Appendix III Comments from the Federal Communications Commission 39

Appendix IV GAO Contacts and Staff Acknowledgments 41

Tables

Table 1: Ongoing NIH-Funded Studies on Health Effects of RF 

Energy Exposure from Mobile Phone Use 14

Table 2: Federal Agency Website Information on Mobile Phones 

and Health as of June 2012 25

Table 3: Subject Matter Experts Interviewed 32

Table 4: Mobile Phone User Manuals Reviewed 34

Contents
Page ii GAO-12-771 Telecommunications

Figures

Figure 1: The Electromagnetic Spectrum 5

Figure 2: U.S. Mobile Phone Certification Process 20

Figure 3: Photographs of Mobile Phone Testing near the Body 22

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 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-12-771 Telecommunications

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.1

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.

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.

2

 

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.

Toward that end, FCC has implemented a certification 

2

47 C.F.R. § 1.1307(b)(2).

 
 

Page 2 GAO-12-771 Telecommunications

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.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.4

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.

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.

5

At your request, we are updating information related to mobile phone 

health effects and regulatory issues. Specifically, this report addresses:

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.

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

21 U.S.C. §§ 360hh—360ss.

4

21 U.S.C. § 360ll.

5

GAO, Telecommunications: Research and Regulatory Efforts on Mobile Phone Health 

Issues, GAO-01-545 (Washington, D.C.: May 7, 2001).
 

Page 3 GAO-12-771 Telecommunications

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 app. I for more information 

on our scope and methodology and app. 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 
 

Page 4 GAO-12-771 Telecommunications

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.

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.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.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.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 2006.9

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 

 

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).

Background 
 

Page 5 GAO-12-771 Telecommunications

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

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.
 

Page 6 GAO-12-771 Telecommunications

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.10

 

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 

GAO-01-545. 

Research on RF 

Energy Exposure 

from Mobile Phones 

Has Not 

Demonstrated 

Adverse Health 

Effects, but More 

Studies Are Under 

Way

Scientific Research
 

Page 7 GAO-12-771 Telecommunications

carcinogenic to humans.”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.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.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 

 

11IARC’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.

12IARC also determined that the evidence from the scientific research was limited for 

acoustic neuromas, a type of non-cancerous brain tumor. 

13Health Protection Agency, Health Effects from Radiofrequency Electromagnetic Fields,

RCE-20 (2012). 
 

Page 8 GAO-12-771 Telecommunications

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.

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 2010.14 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.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.16

 

14This 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. 

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 

15A “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.

16RF 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. 

Epidemiological Studies
 

Page 9 GAO-12-771 Telecommunications

tumors, and mobile phone use.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.18 Further, these findings did not change for 

individuals in the cohort with 13 or more years since their first mobile 

phone subscription.19 Also, the CEFALO study—an international casecontrol 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.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.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 

 

17A “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.

18Schüz, 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.

19Frei, P., et al, “Use of Mobile Phones and Risk of Brain Tumours: Update of Danish 

Cohort Study,” British Medicine Journal, 2011, 343: d6387. 

20Aydin, 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.

21Inskip, 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.
 

Page 10 GAO-12-771 Telecommunications

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.

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,

22

 

22For 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 GFSHR17 Rat Granulosa Cells In Vitro,” Mutation Research, 2005, 583(2): 178-183.

others 

Laboratory Studies
 

Page 11 GAO-12-771 Telecommunications

failed to replicate such an effect using similar experimental conditions.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.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.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 

 

23For 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. 

24For 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.

25For 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.
 

Page 12 GAO-12-771 Telecommunications

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.

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 nonthermal 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 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 

Areas for Additional Research

Current Research 

Activities
 

Page 13 GAO-12-771 Telecommunications

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.26

 

26The 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. 

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.
 

Page 14 GAO-12-771 Telecommunications

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

Description

NIH institute

funding the study

Total

NIH funding 

Estimated year

of completion

Examining environmental and genetic factors for 

meningioma, a type of brain tumor, at research sites in 

five states 

National Cancer Institute $8,779,998 2012

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

National Cancer Institute Not applicablea Not applicablea

Examining effects of mobile phones on brain glucose National Institute on Alcohol 

Abuse and Alcoholism

$595,700 2012

Examining effects of exposure to mobile phones in 

childhood on the central nervous system using children in 

the Danish National Birth Cohortb

National Institute of 

Environmental Health Sciences

$423,500 2012

Examining toxicology and carcinogenic effects of RF 

energy in laboratory animals as part of the National 

Toxicology Programc

National Institute of 

Environmental Health Sciences

$25,600,000 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.

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 
 

Page 15 GAO-12-771 Telecommunications

research agenda.27

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.

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.

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 

 

27The 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).
 

Page 16 GAO-12-771 Telecommunications

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.

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.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).29

 

2861 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.

This 

recommended limit was based on evidence related to the thermal effects 

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

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
 

Page 17 GAO-12-771 Telecommunications

of RF energy exposure30

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.

—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.

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.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.33

 

30In 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.

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.

31See IEEE Std. C95.1-2005.

32The 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.

33See 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.
 

Page 18 GAO-12-771 Telecommunications

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.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.35

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 

FCC could alternatively release 

a Notice of Inquiry to gather information on this issue without formally 

initiating rulemaking.

 

34In re Guidelines for Evaluating the Environmental Effects of Radiofrequency Radiation, 

11 FCC Rcd 15123, 15125 (1996). 

35FCC’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.
 

Page 19 GAO-12-771 Telecommunications

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.

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 

Mobile Phone Certification
 

Page 20 GAO-12-771 Telecommunications

accredited to perform these functions.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.37

Figure 2: U.S. Mobile Phone Certification Process

Figure 2 

illustrates the mobile phone certification process.

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 

 

36In 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. 

37According 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.
 

Page 21 GAO-12-771 Telecommunications

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.

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.

Mobile Phone Testing
 

Page 22 GAO-12-771 Telecommunications

Figure 3: Photographs of Mobile Phone Testing near the Body

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.

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 
 

Page 23 GAO-12-771 Telecommunications

accessories, such as holsters, but these requirements may not identify 

the maximum exposure under other conditions.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.39

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 

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.

 

38These 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.

39FCC guidance states that mobile phone body-worn tests should be conducted with beltclips 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.
 

Page 24 GAO-12-771 Telecommunications

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.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 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.

 

40Testing may be performed at either the TCB’s testing facilities or at a subcontracted test 

facility.

Federal Agencies and 

Mobile Phone 

Industry Provide 

Information to the 

Public through 

Websites and User 

Manuals 

Information Provided by 

Federal Agencies
 

Page 25 GAO-12-771 Telecommunications

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

Types of information provided Agency

What RF energy or radiation is CDC, EPA, FCC, FDA, NIH, OSHA

Current mobile phone RF energy exposure limits CDC, FCC, OSHA

How mobile phones are tested or certified FCC

Thermal effects of RF energy exposure CDC, FCC, NIH, OSHA

Non-thermal effects of RF energy exposure CDC, FCC, OSHA

Health issues and research related to mobile phones CDC, FCC, FDA, NIH, OSHA

Summaries or links to ongoing studies CDC, FDA, NIH 

Information on how to minimize or reduce RF energy exposure from mobile phone use 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.

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.
 

Page 26 GAO-12-771 Telecommunications

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.41

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.

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.

42

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.43

 

41FCC’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.

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.

42The ordinance has been challenged in federal court. The case is currently being 

considered by the U.S. Court of Appeals for the 9th Circuit.

43FCC does require a statement that the mobile phone complies with the agency’s RF 

energy exposure limit, among other things. 47 CFR § 2.1077.

Information Provided by 

Mobile Phone Industry
 

Page 27 GAO-12-771 Telecommunications

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.

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 

Conclusions 
 

Page 28 GAO-12-771 Telecommunications

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.

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.

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 app. 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 

Recommendations for 

Executive Action

Agency Comments

and Our Evaluation
 

Page 29 GAO-12-771 Telecommunications

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 

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. 

Mark L. Goldstein

Director, Physical Infrastructure

Marcia Crosse

Director, Health Care
Appendix I: Scope and Methodology

Page 30 GAO-12-771 Telecommunications

To determine what is known about the human health effects of radiofrequency (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.1 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.

2

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 

We selected 38 studies that met 

these criteria. (See app. II for a list of the 38 studies we reviewed.)

 

1

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.

2

See National Research Council, Identification of Research Needs Relating to Potential 

Biological or Adverse Health Effects of Wireless Communication (Washington, D.C.: 

2008). 

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 31 GAO-12-771 Telecommunications

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,3

• The International Agency for Research on Cancer’s (IARC) 

Monograph Working Group on RF electromagnetic fields,4

• The INTERPHONE Study Group,5

• The European Commission’s Scientific Committee on Emerging and 

Newly Identified Health Risks.

and

6

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 

 

3

National Research Council, Identification of Research Needs Relating to Potential 

Biological or Adverse Health Effects of Wireless Communication (Washington, D.C.: 

2008). 

4

Baan, R., et al, “Carcinogenicity of Radiofrequency Electromagnetic Fields,” Lancet 

Oncology, 2011, 12(7): 624-626.

5

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.

6

European Commission, Health Effects of Exposure to EMF, 2009.
Appendix I: Scope and Methodology

Page 32 GAO-12-771 Telecommunications

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 Title Institutiona

Carl Blackman a founder and former President (1990-91) Bioelectromagnetics Society 

Linda Erdreich Senior Managing Scientist Center for Epidemiology and Computational Biology, 

Exponent

Jukka Juutilainen Professor of Radiation Biology and Radiation 

Epidemiology

Department of Environmental Science, University of Eastern 

Finland

Leeka Kheifets Professor of Epidemiology Department of Epidemiology, School of Public Health, 

University of California, Los Angeles

Henry Lai Research Professor Department of Bioengineering, University of Washington

James Lin Professor of Electrical Engineering, Bioengineering, 

Physiology, and Biophysics

University of Illinois, Chicago

David McCormick Senior Vice President and Director IIT Research Institute 

Martin Röösli Assistant Professor Unit for Environmental Exposures and Health, Swiss 

Tropical and Public Health Institute, Basel

Siegal Sadetzki Head

Associate Professor

Cancer and Radiation Epidemiology Unit, The Gertner

Institute, Chaim Sheba Medical Center, Israel

Sackler School of Medicine, Tel-Aviv University, Israel

Jonathan Samet Professor and Flora L. Thornton Chair Department of Preventive Medicine, Keck School of 

Medicine, University of Southern California

Bernard Veyret Senior Scientist 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.
Appendix I: Scope and Methodology

Page 33 GAO-12-771 Telecommunications

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 
Appendix I: Scope and Methodology

Page 34 GAO-12-771 Telecommunications

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 healthrelated 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 Phone model

Applea iPhone 4

LG Octane

Optimus

Motorola Bionic

Razr

Nokia 1616

6350

X2-01

Samsung GoPhone

Gusto

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.
Appendix II: Studies GAO Reviewed

Page 35 GAO-12-771 Telecommunications

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.

Appendix II: Studies GAO Reviewed
Appendix II: Studies GAO Reviewed

Page 36 GAO-12-771 Telecommunications

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.
Appendix II: Studies GAO Reviewed

Page 37 GAO-12-771 Telecommunications

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.
Appendix II: Studies GAO Reviewed

Page 38 GAO-12-771 Telecommunications

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.
Appendix III: Comments from the Federal 

Communications Commission

Page 39 GAO-12-771 Telecommunications

Appendix III: Comments from the Federal 

Communications Commission
Appendix III: Comments from the Federal 

Communications Commission

Page 40 GAO-12-771 Telecommunications
Appendix IV: GAO Contacts and Staff 

Acknowledgments

Page 41 GAO-12-771 Telecommunications

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

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

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.

Appendix IV: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts

Staff 

Acknowledgments 

(543290)
The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO’s website (www.gao.gov). Each weekday afternoon, 

GAO posts on its website newly released reports, testimony, and 

correspondence. To have GAO e-mail you a list of newly posted products, 

go to www.gao.gov and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO’s website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube. 

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts. 

Visit GAO on the web at www.gao.gov. 

Contact:

Website: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony 

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations 

Public Affairs

Please Print on Recycled Paper.