Telecommunications: Exposure and Testing Requirements for Mobile Phones Should Be Reassessed
Published: 2012-07-24T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.
section_title: What GAO Recommends
paragraphs: 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

section_title: Letter
paragraphs: 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. The rapid adoption of  mobile phones has occurred amidst controversy over whether the  technology poses a risk to human health. Like other devices that transmit  radio signals, mobile phones emit radio-frequency (RF) energy. At high  power levels, RF energy can heat biological tissue and cause damage.  Though mobile phones operate at power levels well below the level at  which this thermal effect occurs, the question of whether long-term  exposure to RF energy emitted from mobile phones can cause other  types of adverse health effects, such as cancer, has been the subject of  research and debate.
The Federal Communications Commission (FCC) and the Food and Drug  Administration (FDA) share regulatory responsibilities for mobile phones.  FCC, in compliance with the National Environmental Policy Act of 1969,  regulates RF energy emitted from FCC-regulated transmitters, including  mobile phones. Toward that end, FCC has implemented a certification program to ensure that all mobile phones sold in the United States  comply with the agency’s limit on RF energy exposure. This limit was  designed to protect users from the thermal effects of acute exposure to  RF energy. FDA is responsible for carrying out a program designed to  protect public health and safety from electronic product radiation. 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. To date, FDA has not taken such action, but the agency  regularly evaluates scientific studies on mobile phones and health to  determine whether they raise public health questions.
In 2001, we reported on the status of scientific knowledge about potential  health risks of RF energy exposure from mobile phones and the federal  government’s regulatory actions to ensure mobile phone safety. We found that FDA and others had concluded that the research did not show  RF energy exposure from mobile phones had adverse health effects, but  more studies were needed. We also found that FCC had not issued  standardized procedures for testing mobile phones and that FCC’s and  FDA’s consumer materials could be improved. Since 2001, FCC has  issued revised guidance for mobile phone testing, and both FCC and FDA  have provided updated information to consumers about the health effects  of mobile phone use.
At your request, we are updating information related to mobile phone  health effects and regulatory issues. Specifically, this report addresses:  1.  What is known about the human health effects of RF energy exposure  from mobile phone use, and what are the current research activities of  federal agencies and other organizations?  2.  How has FCC set the RF energy exposure limit for mobile phones and  how does FCC ensure compliance with the limit?  3.  What actions have federal agencies and the mobile phone industry  taken to inform the public about issues related to mobile phone health  effects?
To determine what is known about the human health effects of RF energy  exposure from mobile phone use, we reviewed selected studies, including  studies and reports that review and assess the scientific research as well  as key individual studies. We identified these studies through literature  searches in online databases, such as Embase and Medline, and  interviews with officials from federal agencies, academic institutions,  consumer groups, and industry associations. We also interviewed subject  matter experts in a range of fields, such as public health and engineering.  To determine the current research activities of federal agencies related to  mobile phone use and health, we interviewed officials from FCC; the  Department of Health and Human Services’ FDA, Centers for Disease  Control and Prevention (CDC), and National Institutes of Health (NIH);  Department of Defense; Department of Labor’s Occupational Safety and  Health Administration (OSHA); and the Environmental Protection Agency  (EPA). To determine the research activities of other organizations, we  interviewed representatives of the International Agency for Research on  Cancer (IARC), academic institutions, consumer groups, mobile phone  industry associations, mobile phone manufacturers, and mobile phone  providers. To determine how FCC set the RF energy exposure limit and  ensures compliance with it, we reviewed FCC regulations and guidance.  We also reviewed reports from international organizations that  recommend RF energy exposure limits. We conducted interviews with  officials from FCC and Telecommunication Certification Bodies (TCBs) to  understand their role in certifying mobile phones. We also interviewed  representatives of the mobile phone industry and consumer  organizations, and experts in RF energy exposure limits to obtain their  perspectives on the testing and certification of mobile phones. To  determine the actions federal agencies and the mobile phone industry  have taken to inform the public about issues related to mobile phone  health effects, we reviewed information on the public websites of CDC,  EPA, FCC, FDA, NIH, and OSHA. We also reviewed the user manuals for  selected top-selling mobile phones of 2011 to identify the information  manufacturers provided to consumers. (See 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  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.
subsections: section_title: Background
paragraphs: 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.  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. 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.  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.
Mobile phones are low-powered radio transceivers—a combination  transmitter and receiver—that use radio waves to communicate with fixed  installations, called base stations or cell towers. The radio waves used by  mobile phones are a form of electromagnetic radiation—energy moving  through space as a series of electric and magnetic waves. The spectrum  of electromagnetic radiation comprises a range of frequencies from very  low, such as electrical power from power lines, through visible light, to  extremely high, such as gamma rays, as shown in figure 1. The portion of  the electromagnetic spectrum used by mobile phones—as well as other  telecommunications services, such as radio and television broadcasting— is referred to as the RF spectrum.
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.
section_title: Research on RF Energy Exposure from Mobile Phones Has Not Demonstrated Adverse Health Effects, but More Studies Are Under Way
subsections: section_title: Scientific Research
paragraphs: 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. Following another decade of scientific research and  hundreds of studies examining health effects of RF energy exposure from  mobile phone use, FDA maintains this conclusion. FDA stated that while  the overall body of research has not demonstrated adverse health effects,  some individual studies suggest possible effects. Officials from NIH,  experts we interviewed, and a working group commissioned by IARC— the World Health Organization’s agency that promotes international  collaboration in cancer research—have reached similar conclusions. For  example, in May 2011 IARC classified RF energy as “possibly  carcinogenic to humans.” 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. 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.
A broad body of research is important for understanding the health effects  of RF energy exposure from mobile phone use, because no single study  can establish a cause-and-effect relationship and limitations associated  with studies can make it difficult to draw conclusions. Two types of  studies, epidemiological and laboratory, are used in combination to  examine effects from mobile phones. Epidemiological studies investigate  the association, if any, between health effects and the characteristics of  people and their environment. Laboratory studies conducted on test  subjects—including human volunteers, laboratory animals, biological  tissue samples, or isolated cells—are used to determine a causal  relationship between possible risk factors and human health, and the  possible mechanisms through which that relationship occurs.
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. 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. 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. Other epidemiological studies have not found associations  between mobile phone use and tumors, including cancerous tumors. For  example, findings from a nationwide cohort study conducted in Denmark  that originally followed 420,095 individuals did not show an association  between increased risk for certain types of tumors, including cancerous  tumors, and mobile phone use. 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. Further, these findings did not change for  individuals in the cohort with 13 or more years since their first mobile  phone subscription. Also, the CEFALO study—an international case- control study that compared children aged 7 to 19 diagnosed with certain  types of brain tumors, including brain cancers, to similar children who  were not diagnosed with brain tumors—found no relationship between  mobile phone use and risk for brain tumors. 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.
Limitations associated with epidemiological studies can make it difficult to  draw definitive conclusions about whether adverse health effects are  linked to RF energy exposure from mobile phone use. One such limitation  is that it is difficult to measure and control for all variables that may affect  results. For example, it can be difficult to accurately measure RF energy  exposure from mobile phone use because humans are exposed to RF  energy from many sources within their environments and mobile phone  technology and user patterns frequently change. Also, epidemiological  studies to date have been limited in their ability to provide information  about possible effects of long-term RF energy exposure because the  prevalence of long-term mobile phone use is still relatively limited and  some tumors, including some cancerous tumors, do not develop until  many years after exposure. In addition, epidemiological studies,  specifically cohort studies, are sometimes limited in their ability to provide  information about increased risks for rare outcomes, such as certain  types of brain tumors. To address challenges with assessing rare  outcomes, case-control studies, which collect information about past  mobile phone use among study participants, may be undertaken with  large numbers of cases and controls. While these studies can potentially  provide information on long-term use, and include enough cancer cases  to examine whether this use is associated with rare diseases, collecting  data in this way can introduce bias, such as recall bias, into study data  and further limit findings. To mitigate this potential bias, some  epidemiological studies, specifically cohort studies, follow large  populations over time and collect data about mobile phone use before  participants develop a certain outcome. In spite of these limitations,  experts we spoke with told us that epidemiological studies are a key  component of the body of research used for assessing the health effects  of mobile phones.
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, others  failed to replicate such an effect using similar experimental conditions.  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.  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.
Limitations associated with laboratory studies can make it difficult to draw  conclusions about adverse human health effects from RF energy  exposure from mobile phone use. For example, studies conducted on  laboratory animals allow researchers to examine the effects of RF energy  exposure on animal systems, but this type of research is limited because  effects on laboratory animals may not be the same on humans.  Additionally, studies on test subjects may observe biological or  physiological changes, but in some circumstances it is unclear how or  even if these changes affect human health. Further, to increase the  strength of the evidence that observed changes in laboratory studies are  the effect of RF energy exposure, studies must be replicated and  confirmed with additional research using different dose rates, durations,  and conditions of RF energy while observing similar effects. To date,  according to FDA officials and some experts we interviewed, only a few  laboratory studies that have shown effects from RF energy have been  replicated, and some replicated studies have not confirmed earlier results.
Studies we reviewed and experts we interviewed identified key areas for  additional epidemiological and laboratory studies, and according to  experts, additional research may increase understanding of any possible  effects. For example, additional epidemiological studies, particularly large  long-term prospective cohort studies and case-control studies on children,  could increase knowledge on potential risks of cancer from mobile phone  use. Also, studies and experts identified several areas for additional  laboratory studies. For example, additional studies on laboratory animals  as well as human and animal cells examining the possible toxic or  harmful effects of RF energy exposure could increase knowledge on  potential biological and health effects of RF energy. Further, additional  laboratory studies on human and animal cells to examine non-thermal  effects of RF energy could increase knowledge of how, if at all, RF energy  interacts with biological systems. However, some experts we spoke to  noted that, absent clear evidence for adverse health effects, it is difficult  to justify investing significant resources in research examining non- thermal effects of RF energy from mobile phone use. Another area  identified for additional laboratory research is studies on human  volunteers examining the effect of changes in the neurological system,  which could help determine if these possible observed changes in  neurological functioning from RF energy are adverse effects. In addition  to conducting additional research, experts we interviewed reported that  the broader body of evidence on RF energy should be re-evaluated when  findings from key studies become available, to determine whether  additional research in certain areas is still warranted.
section_title: Current Research Activities
paragraphs: Current research activities of federal agencies, international  organizations, and the mobile phone industry include funding and  supporting ongoing research on the health effects of RF energy exposure  from mobile phones. NIH is the only federal agency we interviewed that is  directly funding ongoing studies on health effects of RF energy from  mobile phone use. NIH officials reported that the agency has provided  about $35 million for research in this area from 2001 to 2011. (See table 1  for more information on ongoing studies funded by NIH.) Although other  federal agencies are not directly funding research in this area, some  agencies are providing support for ongoing studies. For example, FDA  officials reported that FDA’s National Center for Toxicological Research,  with funding provided by NIH as part of the National Toxicology Program,  is conducting studies on rat and bovine brain cells to examine whether RF   Also, CDC officials reported  energy emitted from mobile phones is toxic.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.
Federal agencies are also engaged in other activities to support research  on the health effects of mobile phone use. For example, FDA collaborates  with other organizations on research-related projects. According to FDA  officials, the agency helped the World Health Organization develop its  WHO Research Agenda for Radiofrequency Fields in 2001 and has  provided comments to the World Health Organization on updates to this  research agenda.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.
Also, officials from federal agencies that have  International organizations also support research on health effects of RF  energy exposure from mobile phone use. Officials from IARC told us that  the organization is currently supporting research activities for ongoing  studies examining health effects of mobile phone use with respect to  cancer. For example, IARC is involved in the identification of research  sites for and implementation of the COSMOS study—a large  international, prospective, cohort study that will follow individuals for 25 or  more years to examine possible long-term health effects of using mobile  phones, such as brain tumors, including cancers, and other health  outcomes. IARC is also coordinating additional data analyses on  previously published studies examining mobile phone health effects. For  example, IARC is coordinating additional analyses of data collected for  the INTERPHONE study. Additionally, the European Commission—the  European Union’s executive body that represents the interest of Europe  as a whole—is supporting research in this field. Under its research  program—the Seventh Framework Programme—the European  Commission has provided funds for the MOBI-KIDS study, an  international case-control study examining the possible association  between communication technology, including mobile phones and other  environmental exposures, and the risk of brain tumors in people aged 10  to 24 years.
The mobile phone industry supports research by providing funding for  studies. According to representatives from mobile phone manufacturers,  service providers, and industry associations, most industry funding for  scientific research is provided by the Mobile Manufacturers Forum—an  international not-for-profit association that is largely comprised of wireless  device manufacturers. According to representatives from the Mobile  Manufacturers Forum, the association has provided about $46 million for  RF energy research since 2000 and is currently providing support for  epidemiological and laboratory studies. Although representatives from all  four mobile phone manufacturers that we interviewed reported that their  companies support research through their industry associations,  representatives from one manufacturer reported that it is also funding two  studies examining the effects of RF energy emitted from mobile phones  on human hands and the head.
section_title: FCC’s RF Energy Exposure Limit May Not Reflect Latest Evidence on Thermal Effects, and Mobile Phone Testing Requirements May Not Identify Maximum Exposure
subsections: section_title: RF Energy Exposure Limit
paragraphs: 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. 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).recommended limit was based on evidence related to the thermal effects   This  of RF energy exposureexposure—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.  —the only proven health effects of RF energy  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. 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. 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. 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.
See IEEE Std. C95.1-2005.
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.  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. FCC could alternatively release  a Notice of Inquiry to gather information on this issue without formally  initiating rulemaking.
Stakeholders we spoke with varied on whether the current U.S. RF  energy exposure limit should be changed to reflect the new  recommended limit. For instance, a few experts and consumer groups we  spoke with said FCC should not adopt the new recommended exposure  limit because of the relative uncertainty of scientific research on adverse  health effects from mobile phone use. An official from one consumer  group told us that adopting the 2.0 watts per kilogram exposure limit  would be a step back, since it could allow users to be exposed to higher  radiation levels. Conversely, some experts we spoke with maintained that  both the 1.6- and 2.0-watts-per-kilogram limits protect users from the  thermal effects of RF energy exposure—which the experts maintained are  the only conclusively demonstrated effects of exposure—since a safety  factor of fifty was applied to obtain the limits, meaning that the maximum  permitted exposure is a fiftieth of what was determined to be the  exposure at which potentially deleterious thermal effects are likely to  occur.
Nevertheless, by not formally reassessing its current RF energy exposure  limit, FCC cannot ensure that it is using a limit that reflects the latest  evidence on thermal effects from RF energy exposure, and may impose  additional costs on manufacturers and limitations on mobile phone  design. FCC’s current limit was established based on recommendations  made more than 20 years ago. According to IEEE, the new  recommended limit it developed is based on significantly improved RF  research and therefore a better understanding of the thermal effects of  RF energy exposure. Additionally, three of the four mobile phone  manufacturers we spoke with favored harmonization of RF energy  exposure limits, telling us that maintaining the separate standards can  result in additional costs and may affect phone design in a way that could  limit performance and functionality. According to some manufacturers we  spoke with, many of their phones are sold in multiple countries. As a  result, the manufacturers have to develop and test phones based on  different exposure limits, which can require additional resources and slow  the time it takes to get new phones into the market. Additionally, one  manufacturer indicated that some features are not enabled on phones  sold in the United States that are available in other countries to comply  with FCC’s current limit. A reassessment by FCC would help it to  determine if any changes to the limit are appropriate.
section_title: Mobile Phone Certification
paragraphs: FCC ensures compliance with its RF energy exposure limit by certifying  all mobile phones sold in the United States. In its application for  certification, manufacturers must provide evidence that their mobile  phones meet FCC’s RF energy exposure limit. FCC has authorized 23  TCBs in the United States and other countries to review applications that  involve evaluation of RF exposure test data and issue certifications on  behalf of the agency. TCBs are private organizations that have been  accredited to perform these functions. 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.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  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.
section_title: Mobile Phone Testing
paragraphs: 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.
FCC has implemented standardized testing procedures requiring mobile  phones to be tested for compliance with the RF energy exposure limit  when in use against the ear and against the body while in body-worn  accessories, such as holsters, but these requirements may not identify  the maximum exposure under other conditions. 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. The results of these testing requirements  are two different values: a maximum SAR value for the head and a  maximum SAR value for the body. However, these testing procedures  may not identify the maximum SAR for the body, since some consumers  use mobile phones with only a slight distance, or no distance, between  the device and the body, such as placing the phone in a pocket while  using an ear piece. Using a mobile phone in this manner could result in  RF energy exposure above the maximum body-worn SAR determined  during testing, although that may not necessarily be in excess of the  FCC’s limit. In such a case, exposure in excess of FCC’s limit could occur  if the device were to transmit continuously and at maximum power.
FCC has not reassessed its testing requirements to ensure that testing  identifies the maximum RF energy exposure for the other usage  conditions a user could experience when mobile phones are in use  without body-worn accessories or as advised by the manufacturer’s  instructions, rather than the head. Although FCC officials said that they  provide case-by-case guidance for many mobile phones operating with  new technologies, they do not require testing of mobile phones when  used without body-worn accessories unless such conditions are  specifically identified by the manufacturer’s operating instructions.  Representatives of some consumer groups we spoke with expressed  concern about the exposure to RF energy that can come with such use.  Officials from IEEE, though, told us that the average power and resultant  radiation level of mobile phones while in use is very low, such that even  when a mobile phone is used against the body it is unlikely that the RF  energy exposure would exceed the FCC limit. Nevertheless, FCC has not  reassessed its testing requirements to ensure that mobile phones do not  exceed the RF energy exposure limit in all possible usage conditions.
Beyond the testing required for certification, FCC also ensures that  mobile phones meet its RF energy exposure limit by reviewing  information collected as part of routine surveillance of mobile phones on  the market. FCC requires TCBs to carry out this post-market surveillance  program, through which each TCB tests one percent of the mobile  phones they have certified for RF energy exposure, to ensure that the  phones continue to meet FCC’s RF energy exposure limit. According to  FCC, no mobile phone tested under this surveillance program has been  found in violation of the RF energy exposure limit.
section_title: Federal Agencies and Mobile Phone Industry Provide Information to the Public through Websites and User Manuals
subsections: section_title: Information Provided by Federal Agencies
paragraphs: 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.
The types of information that federal agencies’ websites provide on  mobile phone health effects and related issues vary, in part because of  the agencies’ different missions, though the websites provide a broadly  consistent message. For instance, NIH primarily provides information  about the research on health effects of RF energy exposure from mobile  phone use, while FCC provides information on how mobile phones are  tested and certified. Nevertheless, the concluding statements about  whether RF energy exposure from mobile phone use poses a risk to  human health are generally consistent across selected federal agencies’  websites that we reviewed, though the specific wording of these  concluding statements varies.
Representatives from some consumer groups and experts we spoke with  raised concerns that the information on federal agency websites about  mobile phone health effects is not precautionary enough, among other  things. In particular, these representatives and experts said that federal  agencies should include stronger precautionary information about mobile  phones because of the uncertain state of scientific research on mobile  phone health effects as well as the fact that current testing requirements  may not identify the maximum possible RF energy exposure.  Representatives from one consumer group also said that federal agency  websites should provide more consumer information, such as the impact  of different mobile phone technologies on RF energy exposure. Officials  from FCC and NIH maintained that the information on their websites  reflects the latest scientific evidence and provides sufficient information  for consumers concerned about potential health effects related to mobile  phones.
Some consumer groups noted that they would like FCC to mention  IARC’s recent classification of RF energy exposure as “possibly  carcinogenic” on FCC’s website. FCC noted that it generally defers to the  health and safety agencies for reporting on new research, though FCC’s  website did include information on the recent INTERPHONE study when  we reviewed the site in June 2012. FCC does provide links to CDC, EPA,  FDA, and other websites, some of which have information about the  IARC’s classification. FDA notes on its website that the IARC  classification means there is limited evidence showing RF carcinogenicity  in humans and insufficient evidence of carcinogenicity in experimental  animals.
Some local governments are taking steps to provide precautionary  information to consumers. For example, the city of San Francisco has  developed a Web page on mobile phone health issues, including steps to  reduce RF energy exposure from mobile phone use, and has passed an  ordinance requiring local mobile phone retailers to distribute a flyer on  ways that consumers can reduce their exposure.
section_title: Information Provided by Mobile Phone Industry
paragraphs: 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   Most manuals we reviewed provide  health effects of mobile phone use.information about how the device was tested and certified, as well as the  highest energy exposure measurement associated with the device. Some  manufacturers also provide suggestions, often based on information from  FDA, to consumers about how to minimize their exposure, among other  things.
All manuals we reviewed, except one, include a statement that, when  used on the body, as opposed to against the ear, a minimum distance  between the body and the mobile phone should be maintained. These  distances ranged from 1.5 to 2.5 centimeters. Since all mobile phones are  tested for RF energy exposure compliance at a distance from the body,  as discussed previously in this report, these instructions are consistent  with how the devices were tested and certified by FCC. Some consumer  groups and experts we spoke with noted that consumers could be  unaware of these instructions if they do not read the entire user manual.
section_title: Conclusions
paragraphs: FCC’s current RF energy exposure limit for mobile phones, established in  1996, may not reflect the latest evidence on the thermal effects of RF  energy exposure and may impose additional costs on manufacturers and  limitations on mobile phone design. FCC regulates RF energy emitted  from mobile phones and relies on federal health and safety agencies to  help determine the appropriate RF energy exposure limit. However, FCC  has not formally asked FDA or EPA for their assessment of the limit since  1996, during which time there have been significant improvements in RF  energy research and therefore a better understanding of the thermal  effects of RF energy exposure. This evidence has led to a new RF energy  exposure limit recommendation from international organizations.  Additionally, maintaining the current U.S. limit may result in additional  costs for manufacturers and impact phone design in a way that could limit  performance and functionality. Reassessing its current RF energy  exposure limit would ensure that FCC’s limit protects the public from  exposure to RF energy while allowing industry to provide  telecommunications services in the most efficient and practical manner  possible.
The current testing requirements for mobile phones may not identify the  maximum RF energy exposure when tested against the body. FCC  testing requirements state that mobile phone tests should be conducted  with belt-clips and holsters attached to the phone or at a predetermined  distance from the body. These requirements were developed by FCC to  identify the maximum RF energy exposure a user could experience when  using a mobile phone, to ensure that the mobile phone meets the  agency’s RF energy exposure limit. This limit was designed to ensure that  mobile phones do not expose the public to levels of RF energy that could  be potentially harmful. By testing mobile phones only when at a distance  from the body, FCC may not be identifying the maximum exposure, since  some users may hold a mobile phone directly against the body while in  use. Using a mobile phone in this manner could result in RF energy  exposure above the maximum body-worn SAR determined during testing,  although that may not necessarily be in excess of FCC’s limit.  Reassessing its testing requirements would allow FCC to ensure that  phones used by consumers in the United States do not result in RF  energy exposure in excess of FCC’s limit.
section_title: Recommendations for Executive Action
paragraphs: 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.
section_title: Agency Comments and Our Evaluation
paragraphs: 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  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.
section_title: Appendix I: Scope and Methodology
paragraphs: To determine what is known about the human health effects of radio- frequency (RF) energy exposure from mobile phone use, we reviewed  selected studies including studies and reports that review and assess the  scientific research, such as meta-analyses and government reports, as  well as key individual epidemiological and laboratory studies. 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. We selected 38 studies that met  these criteria. (See app. II for a list of the 38 studies we reviewed.)
To collect information on the 38 selected studies, we developed a data  collection instrument that contained 16 open- and closed-ended questions  about the entity or entities that published and funded the study; the study  methods, key findings, and limitations; and additional research needs. To  apply this data collection instrument, one analyst reviewed each study  and recorded information in the data collection instrument. A second  analyst then reviewed each completed data collection instrument to verify  the accuracy of the information recorded. We summarized the findings  and limitations of studies based on the completed data collection  instruments, as well as areas for additional research identified in the  studies. Additionally, we used this analysis to identify key, individual,  epidemiological and laboratory studies.
We also interviewed subject matter experts to determine what is known  about the human health effects of RF energy exposure from mobile  phone use. First, we identified 123 potential subject matter experts to  interview through the following sources: (1) interviews with officials from  federal agencies and representatives of academic institutions, consumer  groups, and industry associations and (2) participant lists of recent expert  panels and workgroups on this topic. These panels and workgroups  included:
The National Research Council’s Committee on Identification of  Research Needs Relating to Potential Biological or Adverse Health  Effects of Wireless Communications Devices,
The International Agency for Research on Cancer’s (IARC)
Monograph Working Group on RF electromagnetic fields,
The INTERPHONE Study Group,
The European Commission’s Scientific Committee on Emerging and  Newly Identified Health Risks.
Baan, R., et al, “Carcinogenicity of Radiofrequency Electromagnetic Fields,” Lancet  Oncology, 2011, 12(7): 624-626.
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.
European Commission, Health Effects of Exposure to EMF, 2009. 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.
To determine the current research activities of federal agencies and other  organizations related to mobile phone use and health, we interviewed  representatives from various agencies and organizations. We identified  agencies and organizations by reviewing information on their websites on  RF energy and conducting interviews with officials from federal agencies  and representatives of organizations familiar with research on health  effects of mobile phone use. To determine the current research activities  of federal agencies related to mobile phone use and health, we  interviewed officials from the Department of Defense; Department of  Health and Human Services’ Centers for Disease Control and Prevention  (CDC), Food and Drug Administration (FDA), and National Institutes of  Health (NIH); Department of Labor’s Occupational Safety and Health  Administration (OSHA); Environmental Protection Agency (EPA); and  Federal Communications Commission (FCC). To determine the research  activities of other organizations, we interviewed representatives from  IARC, academic institutions, consumer groups, mobile phone industry  associations, mobile phone manufacturers, and mobile phone providers.
To determine how FCC set the RF energy exposure limit and ensures  compliance with it, we reviewed and summarized FCC regulations and  guidance as well as reports from international organizations that  recommend RF energy exposure limits. We also reviewed and  summarized FCC testing and certification regulations and guidance for  mobile phones. We conducted interviews with officials from FCC and  representatives from selected Telecommunication Certification Bodies  (TCBs). We selected the four TCBs that approved the most mobile phone  certification applications for fiscal years 2000-2011 according to FCC:  PCTEST Engineering Laboratory, Inc.; ACB, Inc.; CETECOM ICT  Services GmbH; and Timco Engineering, Inc. These four TCBs have  approved 69 percent of all U.S. mobile phone applications since 2000.  We interviewed representatives from National Institute of Standards and  Technology, American National Standards Institute, and American  Association for Laboratory Accreditation to discuss their role in  accrediting entities as TCBs and monitoring the activities of current TCBs.  We also conducted interviews with representatives of the mobile phone  industry and consumer groups for their perspectives on RF energy  exposure limits as well as the testing and certification of mobile phones.  Representatives of the mobile phone industry we spoke with included  industry associations (CTIA-The Wireless Association and Mobile  Manufacturers Forum) as well as the top four mobile phone service  providers (AT&T, Sprint, T-Mobile, and Verizon) that represent about 90  percent of U.S. mobile phone service subscribers. We also spoke with  representatives from four mobile phone manufacturers that represent  over 70 percent of the U.S. market (LG, Motorola, Nokia, and Samsung).
To determine the actions federal agencies and the industry take to inform  the public about issues related to mobile phone health effects, we  reviewed the information on federal agency websites. We identified six  federal agencies that have information about mobile phones and health- related issues on their websites: CDC, EPA, FCC, FDA, NIH, and OSHA.  We conducted interviews with officials from those federal agencies to  learn how they developed and update their websites. We spoke with  representatives of the mobile phone industry noted above and consumer  groups to obtain perspectives on the strengths and limitations of federal  agency public-information-sharing efforts. We also spoke with the  representatives of the mobile phone industry about how and why  manufacturers include warnings or specific usage guidelines in their user  manuals. Finally, we reviewed the user manuals of selected mobile  phones (see table 4) to identify the usage and health information being  provided to consumers, including any instructions to hold the mobile  phone away from the body during use. The specific mobile phone models  were identified by the manufacturers we spoke with as their top selling  models in 2011.
section_title: Appendix II: Studies GAO Reviewed
paragraphs: Ahlbom, Anders, Maria Feychting, Adele Green, Leeka Kheifets, David A.  Savitz, and Anthony J. Swerdlow. “Epidemiological Evidence on Mobile  Phones and Tumor Risk: A Review.” Epidemiology, vol. 20, no. 5 (2009):  639-652.
Balbani, Aracy Pereira Silveira, and Jair Cortez Montovani. “Mobile  Phones: Influence on Auditory and Vestibular Systems.” Brazilian Journal  of Otorhinolaryngology, vol 74, no. 1 (2008): 125-131.
Clapp, Richard W., Molly M. Jacobs, and Edward L. Loechler.  “Environmental and Occupational Causes of Cancer: New Evidence  2005-2007.” Reviews on Environmental Health, vol. 23, no. 1 (2008): 1- 37.
Committee on Man and Radiation. “COMAR Technical Information  Statement: Expert Reviews on Potential Health Effects of Radiofrequency  Electromagnetic Fields and Comments on the Bioinitiative Report.” Health  Physics, vol. 97, no. 4 (2009): 348-356.
Edumed Institute for Medicine and Health. Non-Ionizing Electromagnetic  Radiation in the Radiofrequency Spectrum and its Effects on Human  Health. Latin American Experts Committee on High Frequency  Electromagnetic Fields and Human Health. June 2010.
European Health Risk Assessment Network on Electromagnetic Fields  Exposure. “Risk Analysis of Human Exposure to Electromagnetic Fields.”  Deliverable Report D2, Executive Agency for Health and Consumers  Framework of the Programme of Community Action in the Field Of Health  2008-2013. July 2010.
European Health Risk Assessment Network on Electromagnetic Fields  Exposure. “D3 – Report on the analysis of risks associated to exposure to  EMF: in vitro and in vivo (animals) studies.” July 2010.
French Environmental Health and Safety Agency. “AFSSE Statement on  Mobile Phones and Health.” AFSSE. April 16, 2003.
German Mobile Telecommunication Research Programme. “Health Risk  Assessment of Mobile Communications.” Department Radiation  Protection and Health. Germany: 2008.
Habash, Riadh W.Y., J. Mark Elwood, Daniel Krewski, W. Gregory Lotz,  James P. McNamee, and Frank S. Prato. “Recent Advances in Research  On Radiofrequency Fields and Health: 2004-2007.” Journal of Toxicology  and Environmental Health, Part B, vol. 12 (2009): 250-288.
Han, Yueh-Ying, Hideyuki Kano, Devra L. Davis, Ajay Niranjan, and L.  Dade Lunsford. “Cell Phone Use and Acoustic Neuroma: The Need for  Standardized Questionnaires and Access to Industry Data.” Surgical  Neurology, vol. 72 (2009): 216-222.
Health Council of the Netherlands. “Electromagnetic Fields: Annual  Update 2008.” The Hague: Health Council of the Netherlands, 2008;  publication no. 2009/02.
HERMO. Health Risk Assessment of Mobile Communications. A Finnish  Research Programme. Finland: 2007.
Institution of Engineering and Technology. “The Possible Harmful  Biological Effects of Low-Level Electromagnetic Fields of Frequencies up  to 300 GHz.” 2010 Position Statement, Institution of Engineering and  Technology. United Kingdom: 2010.
International Commission on Non-Ionizing Radiation Protection. Exposure  to high frequency electromagnetic fields, biological effects and health  consequences (100 kHz-300 GHz). Germany: 2009.
Juutilainen, Jukka, Anne Höytö, Timo Kumlin, and Jonne Naarala.  “Review of Possible Modulation-Dependent Biological Effects of  Radiofrequency Fields.” Bioelectromagnetics, vol. 35 (2011): 511-534.
Khurana, Vini G., Charles Teo, Michael Kundi, Lennart Hardell, and  Michael Carlberg. “Cell Phones and Brain Tumors: A Review Including  the Long-Term Epidemiological Data.” Surgical Neurology, vol. 72 (2009):  205-215.
Kohli, D., A. Sachdev, and H. Vats. “Cell Phones and Tumor: Still In No  Man’s Land.” Indian Journal of Cancer, vol. 46, no. 1 (2009): 5-12.
Kundi, Michael. “The Controversy About a Possible Relationship Between  Mobile Phone Use and Cancer.” Ciencia & Saude Coletiva, vol. 15, no. 5  (2010): 2415-2430.
Levis, Angelo G., Nadia Minicuci, Paolo Ricci, Valerio Gennaro, and  Spiridione Garbisa. “Mobile Phones and Head Tumours. The  Discrepancies in Cause-Effect Relationships in the Epidemiological  Studies – How Do They Arise?” Environmental Health, vol. 10, no. 59.  (2011): 1-15.
Marino, Andrew A., and Simona Carrubba. “The Effects of Mobile-Phone  Electromagnetic Fields of Brain Electrical Activity: A Critical Analysis of  the Literature.” Electromagnetic Biology and Medicine, vol. 28 (2009):  250-274.
McKinlay, A.F., S.G. Allen, R. Cox, P.J. Dimbylow, S.M. Mann, C.R.  Muirhead, R.D. Saunders, Z.J. Sienkiewicz, J.W. Stather, and P.R.  Wainwright. “Advice on Limiting Exposure to Electromagnetic Fields (0- 300 GHz).” Documents of the NRPB, vol. 15, no. 2. National Radiological  Protection Board, 2004.
Mobile Telecommunications and Health Research Programme. “Report  2007.” United Kingdom: October 2007.
Myung, Seung-Kwon, Woong Ju, Diana D. McDonnell, Yeon Ji Lee, Gene  Kazinets, Chih-Tao Cheng, and Joel M. Moskowitz. “Mobile Phone Use  and Risk of Tumors: A Meta-Analysis” Journal of Clinical Oncology, vol.  27, no. 33 (2009): 5565-5572.
National Council on Radiation Protection and Measurements. “Biological  Effects of Modulated Radiofrequency Fields.” NCRP Commentary, no. 18.  Bethesda, MD: 2003.
National Research Council. Identification of Research Needs Relating to  Potential Biological or Adverse Health Effects of Wireless  Communication. Washington, D.C.: 2008.
Nieden, Anja zur, Corrina Dietz, Thomas Eikmann, Jürgen Kiefer, and  Caroline E.W. Herr. “Physicians Appeals On the Dangers of Mobile  Communication – What Is the Evidence? Assessment of Public Health  Data.” International Journal of Hygiene and Environmental Health, vol.  212 (2009): 576-587.
Pourlis, Aris F., “Reproductive and Developmental Effects of EMF in  Vertebrate Animal Models.” Pathophysiology, vol. 16 (2009): 179-189.
Regel, Sabine J., and Peter Achermann. “Cognitive Performance  Measures in Bioelectromagnetic Research – Critical Evaluation and  Recommendations.” Environmental Health, vol. 10, no. 10 (2011).
Röösli, Martin, and Kerstin Hug. “Wireless Communication Fields and  Non-Specific Symptoms of Ill Health: A Literature Review.” Weiner  Medizinische Wochenschrift, vol. 161, no. 9-10 (2011): 240-250.
Scientific Committee on Emerging and Newly Identified Health Risks.  Health Effects of Exposure to EMF. European Commission. January 19,  2009.
Sixth Framework Programme. “EMF-NET: Effects of the Exposure to  Electromagnetic Fields: From Science to Public Health and Safer  Workplace.” WP2.2 Deliverable report D4bis: Effects on Reproduction  and Development. Italy: 2007.
Swedish Radiation Protection Authority. Recent Research on EMF and  Health Risks Fifth Annual Report from SSI:s Independent Expert Group  on Electromagnetic Fields, 2007, Sweden: 2008.
Swedish Radiation Safety Authority. Recent Research on EMF and  Health Risk Seventh Annual Report from SSM:s Independent Expert  Group on Electromagnetic Fields, 2010. Sweden: 2010.
Valentini, E., G. Curcio, F. Moroni, M. Ferrara, L. De Gannaro, and M.  Bertini. “Neurophysiological Effects of Mobile Phone Electromagnetic  Fields on Humans: A Comprehensive Review.” Bioelectromagnetics, vol.  28 (2007): 415-432.
Vanderstraeten, Jacques, and Luc Verschaeve. “Gene and Protein  Expression Following Exposure to Radiofrequency Fields from Mobile  Phones.” Environmental Health Perspectives, vol. 116, no. 9 (2008):  1131-1135.
Vijayalaxmi, and Thomas J. Prihoda. “Genetic Damage in Mammalian  Somatic Cells Exposed to Radiofrequency Radiation: A Meta-Analysis of  Data from 63 Publications (1990-2005).” Radiation Research, vol.169  (2008): 561-574.
World Health Organization. WHO Research Agenda for Radiofrequency  Fields. Switzerland: 2010.
section_title: Appendix III: Comments from the Federal Communications Commission
section_title: Appendix IV: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: 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.