oversight

Telecommunications: Exposure and Testing Requirements for Mobile Phones Should Be Reassessed

Published by the Government Accountability Office on 2012-07-24.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States Government Accountability Office

GAO          Report to Congressional Requesters




             TELECOMMUNICATIONS
July 2012




             Exposure and Testing
             Requirements for Mobile
             Phones Should Be
             Reassessed




GAO-12-771
                                              July 2012

                                              TELECOMMUNICATIONS
                                              Exposure and Testing Requirements for Mobile
                                              Phones Should Be Reassessed
Highlights of GAO-12-771, a report to
congressional requesters




Why GAO Did This Study                        What GAO Found
The rapid adoption of mobile phones           Scientific research to date has not demonstrated adverse human health effects of
has occurred amidst controversy over          exposure to radio-frequency (RF) energy from mobile phone use, but research is
whether the technology poses a risk to        ongoing that may increase understanding of any possible effects. In addition,
human health as a result of long-term         officials from the Food and Drug Administration (FDA) and the National Institutes
exposure to RF energy from mobile             of Health (NIH) as well as experts GAO interviewed have reached similar
phone use. FCC and FDA share                  conclusions about the scientific research. Ongoing research examining the health
regulatory responsibilities for mobile        effects of RF energy exposure is funded and supported by federal agencies,
phones. GAO was asked to examine              international organizations, and the mobile phone industry. NIH is the only
several issues related to mobile phone
                                              federal agency GAO interviewed directly funding studies in this area, but other
health effects and regulation.
                                              agencies support research under way by collaborating with NIH or other
Specifically, this report addresses
(1) what is known about the health
                                              organizations to conduct studies and identify areas for additional research.
effects of RF energy from mobile              The Federal Communications Commission’s (FCC) RF energy exposure limit
phones and what are current research          may not reflect the latest research, and testing requirements may not identify
activities, (2) how FCC set the RF            maximum exposure in all possible usage conditions. FCC set an RF energy
energy exposure limit for mobile              exposure limit for mobile phones in 1996, based on recommendations from
phones, and (3) federal agency and            federal health and safety agencies and international organizations. These
industry actions to inform the public         international organizations have updated their exposure limit recommendation in
about health issues related to mobile
                                              recent years, based on new research, and this new limit has been widely
phones, among other things. GAO
                                              adopted by other countries, including countries in the European Union. This new
reviewed scientific research;
interviewed experts in fields such as         recommended limit could allow for more RF energy exposure, but actual
public health and engineering, officials      exposure depends on a number of factors including how the phone is held during
from federal agencies, and                    use. FCC has not adopted the new recommended limit. The Office of
representatives of academic                   Management and Budget’s instructions to federal agencies require the adoption
institutions, consumer groups, and the        of consensus standards when possible. FCC told GAO that it relies on the
mobile phone industry; reviewed               guidance of federal health and safety agencies when determining the RF energy
mobile phone testing and certification        exposure limit, and to date, none of these agencies have advised FCC to change
regulations and guidance; and                 the limit. However, FCC has not formally asked these agencies for a
reviewed relevant federal agency              reassessment. By not formally reassessing its current limit, FCC cannot ensure it
websites and mobile phone user                is using a limit that reflects the latest research on RF energy exposure. FCC has
manuals.                                      also not reassessed its testing requirements to ensure that they identify the
                                              maximum RF energy exposure a user could experience. Some consumers may
What GAO Recommends                           use mobile phones against the body, which FCC does not currently test, and
FCC should formally reassess and, if          could result in RF energy exposure higher than the FCC limit.
appropriate, change its current RF
                                              Federal agencies and the mobile phone industry provide information on the
energy exposure limit and mobile
phone testing requirements related to
                                              health effects of mobile phone use and related issues to the public through their
likely usage configurations, particularly     websites and mobile phone manuals. The types of information provided via
when phones are held against the              federal agencies’ websites on mobile phone health effects and related issues
body. FCC noted that a draft document         vary, in part because of the agencies’ different missions, although agencies
currently under consideration by FCC          provide a broadly consistent message. Members of the mobile phone industry
has the potential to address GAO’s            voluntarily provide information on their websites and in mobile-phone user
recommendations.                              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.
                                                                                      United States Government Accountability Office
Contents


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




               Page i                                       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 ii                                                   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 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. 2 Toward that end, FCC has implemented a certification



                                   1
                                    In this report, we use the term “mobile phone” to refer to handheld (i.e., wireless) cellular
                                   telephones, including newer personal communication devices, such as “smart phones,”
                                   that can deliver voice, data, and images.
                                   2
                                    47 C.F.R. § 1.1307(b)(2).




                                   Page 1                                                      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 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. 5 We
found that FDA and others had concluded that the research did not show
RF energy exposure from mobile phones had adverse health effects, but
more studies were needed. We also found that FCC had not issued
standardized procedures for testing mobile phones and that FCC’s and
FDA’s consumer materials could be improved. Since 2001, FCC has
issued revised guidance for mobile phone testing, and both FCC and FDA
have provided updated information to consumers about the health effects
of mobile phone use.

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

1. What is known about the human health effects of RF energy exposure
   from mobile phone use, and what are the current research activities of
   federal agencies and other organizations?
2. How has FCC set the RF energy exposure limit for mobile phones and
   how does FCC ensure compliance with the limit?




3
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 2                                               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 3                                          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
Background   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).




             Page 4                                                   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 5                                         GAO-12-771 Telecommunications
Research on RF
Energy Exposure
from Mobile Phones
Has Not
Demonstrated
Adverse Health
Effects, but More
Studies Are Under
Way

Scientific Research   Scientific research to date has not demonstrated adverse human health
                      effects from RF energy exposure from mobile phone use, but additional
                      research may increase understanding of possible effects. In 2001, we
                      reported that FDA and others had concluded that research had not shown
                      RF energy emissions from mobile phones to have adverse health effects,
                      but that insufficient information was available to conclude mobile phones
                      posed no risk. 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




                      10
                       GAO-01-545.




                      Page 6                                        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



11
  IARC’s classification of RF energy is based on conclusions of an IARC working group of
more than 30 scientists from 14 countries who reviewed the scientific evidence on the
exposure to RF energy from personal devices, such as mobile phones and other sources.
IARC published a summary of this working group’s findings, see Baan, R., et al,
“Carcinogenicity of Radiofrequency Electromagnetic Fields,” The Lancet Oncology, 2011,
12(7): 624-626. According to IARC officials, the IARC Monograph containing the complete
assessments of the working group will be published in fall 2012. IARC has five groups for
classifying factors: 1—carcinogenetic to humans, 2A—probably carcinogenic to humans,
2B—possibly carcinogenic to humans, 3—not classifiable as to its carcinogenicity to
humans, and 4—probably not carcinogenic to humans. As of July 11, 2012, IARC had
classified 952 factors, of which 779 have been classified in groups 2B or 3. Factors
classified in the 2B group include coffee and gasoline.
12
  IARC also determined that the evidence from the scientific research was limited for
acoustic neuromas, a type of non-cancerous brain tumor.
13
 Health Protection Agency, Health Effects from Radiofrequency Electromagnetic Fields,
RCE-20 (2012).




Page 7                                                    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.

Epidemiological Studies   Studies we reviewed suggested and experts we interviewed stated that
                          epidemiological research has not demonstrated adverse health effects
                          from RF energy exposure from mobile phone use, but the research is not
                          conclusive because findings from some studies have suggested a
                          possible association with certain types of tumors, including cancerous
                          tumors. Findings from one such study, the INTERPHONE study, were
                          published in 2010. 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 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




                          14
                            This study was conducted at 16 research sites. Several publications are available on
                          study findings from the individual research sites. Findings discussed here are the primary
                          study findings published by the INTERPHONE Study Group. See The INTERPHONE
                          Study Group, “Brain Tumour Risk In Relation To Mobile Telephone Use: Results of the
                          INTERPHONE International Case-Control Study,” International Journal of Epidemiology,
                          2010, 39: 675-694.
                          15
                            A “case-control” study is a study that compares individuals with a particular disease or
                          outcome—cases—to individuals without that disease or outcome—controls—to
                          investigate if the outcome is associated with exposure to a specific factor. Case-control
                          studies are sometimes called retrospective studies, because the outcome occurred before
                          the study began.
                          16
                            RF energy exposure levels from mobile phone use were measured in terms of (1) the
                          number of years since first use, (2) cumulative number of calls, and (3) cumulative
                          duration of calls. Analysis of the relationship between RF energy exposure and risk of four
                          types of tumors—tumors of the brain including glioma and meningioma, acoustic nerve,
                          and parotid gland—were done using these three measures. Individuals that fell into the
                          highest level of exposure are those that reported 1,640 or more cumulative lifetime hours
                          of mobile phone use, which ranged from less than 1 year to more than 10 years of use.




                          Page 8                                                    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 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. 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



17
   A “cohort” study is a study that follows a defined group of people—the cohort—over
time. Outcomes of the people in subsets of the cohort are compared to examine if a
particular intervention or factor is associated with a particular outcome. Cohort studies are
sometimes called prospective studies, although they can be performed either
retrospectively from historical records or prospectively.
18
 Schüz, J., et al, “Cellular Telephone Use and Cancer Risk: Update of a Nationwide
Danish Cohort,” Journal of the National Cancer Institute, 2006, 98(23):1707-1713.
19
 Frei, P., et al, “Use of Mobile Phones and Risk of Brain Tumours: Update of Danish
Cohort Study,” British Medicine Journal, 2011, 343: d6387.
20
 Aydin, D., et al, “Mobile Phone Use and Brain Tumors in Children and Adolescents: A
Multicenter Case-Control Study,” Journal of the National Cancer Institute, 2011, 103: 1-13.
21
 Inskip, P.D., Hoover, R.N., Devesa, S.S., “Brain Cancer Incidence Trends In Relation To
Cellular Telephone Use In the United States,” Neuro-Oncology, 2010, 12(11): 1147-1151.




Page 9                                                     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.

Laboratory Studies   Studies we reviewed suggested and experts we interviewed stated that
                     laboratory research has not demonstrated adverse human health effects
                     from RF energy exposure from mobile phone use, but the research is not
                     conclusive because findings from some studies have observed effects on
                     test subjects. Some laboratory studies have examined whether RF
                     energy has harmful effects by exposing samples of human and animal
                     cells to RF energy over a range of dose rates, durations, and conditions
                     to detect any changes in cellular structures and functions. For example,
                     some studies have examined the effects of RF energy on
                     deoxyribonucleic acid (DNA) in rodent and human cells. While some of
                     these studies found that RF energy exposure damaged DNA, 22 others




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




                     Page 10                                                  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



23
  For example see Speit, G., Schütz, P., Hoffmann, H., “Genotoxic Effects of Exposure To
Radiofrequency Electromagnetic Fields (RF-EMF) In Cultured Mammalian Cells Are Not
Independently Reproducible,” Mutation Research, 2007, 626(1-2): 42-47 and Hook, G.J.,
et al, “Measurement of DNA Damage and Apoptosis In Molt-4 Cells After In Vitro
Exposure To Radiofrequency Radiation,” Radiation Research, 2004, 161(2):193-200.
24
  For example see Kumlin T., et al, “Mobile Phone Radiation and the Developing Brain:
Behavioral and Morphological Effects in Juvenile Rats,” Radiation Research, 2007,
168(4): 471-479 and Nittby, H., et al, “Cognitive Impairment in Rats After Long-Term
Exposure to GSM-900 Mobile Phone Radiation,” Bioelectromagnetics, 2008, 29(3): 219-
232.
25
  For example see Volkow, N.D., et al, “Effects of Cell Phone Radiofrequency Signal
Exposure on Brain Glucose Metabolism,” Journal of the American Medical Association,
2011, 305(8): 808-813 and Regel, S.J., et al, “Pulsed Radio-Frequency Electromagnetic
Fields: Dose-Dependent Effects on Sleep, the Sleep EEG and Cognitive Performance,”
Journal of Sleep Research, 2007, 16: 253-258.




Page 11                                                 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.

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


Current Research                Current research activities of federal agencies, international
Activities                      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


                                Page 12                                          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 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.




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




Page 13                                                 GAO-12-771 Telecommunications
Table 1: Ongoing NIH-Funded Studies on Health Effects of RF Energy Exposure from Mobile Phone Use

                                                                   NIH institute                                    Total           Estimated year
Description                                                        funding the study                         NIH funding             of completion
Examining environmental and genetic factors for                    National Cancer Institute                   $8,779,998                        2012
meningioma, a type of brain tumor, at research sites in
five states
                                                                                                                           a                          a
Evaluating brain cancer incidence trends in the United             National Cancer Institute              Not applicable             Not applicable
States using cancer registry data to determine if trends
are consistent with reported epidemiological associations
of mobile phone use and certain types of cancer
Examining effects of mobile phones on brain glucose                National Institute on Alcohol                 $595,700                        2012
                                                                   Abuse and Alcoholism
Examining effects of exposure to mobile phones in                  National Institute of                         $423,500                        2012
childhood on the central nervous system using children in          Environmental Health Sciences
                                b
the Danish National Birth Cohort
Examining toxicology and carcinogenic effects of RF                National Institute of                     $25,600,000                         2015
energy in laboratory animals as part of the National               Environmental Health Sciences
                    c
Toxicology Program
                                             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 14                                                             GAO-12-771 Telecommunications
research agenda. 27 Also, officials from federal agencies that have
responsibility for different aspects of RF energy safety and work—CDC,
EPA, FCC, FDA, NIH, the National Telecommunications and Information
Administration, and OSHA—are members of the Radiofrequency
Interagency Work Group, which works to share information on RF energy
related projects at the staff level. According to FCC and FDA officials, this
group periodically meets to discuss RF energy related issues, including
recently published and ongoing research on the health effects of RF
energy exposure.

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

The mobile phone industry supports research by providing funding for
studies. According to representatives from mobile phone manufacturers,
service providers, and industry associations, most industry funding for
scientific research is provided by the Mobile Manufacturers Forum—an
international not-for-profit association that is largely comprised of wireless


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




Page 15                                              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.



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

RF Energy Exposure Limit   In 1996, FCC adopted the RF energy exposure limit for mobile phones of
                           1.6 watts per kilogram, averaged over one gram of tissue, a
                           measurement of the amount of RF energy absorbed into the body. 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 This
                           recommended limit was based on evidence related to the thermal effects



                           28
                             61 Fed. Reg. 41017, August, 7, 1996. This measurement is called the specific
                           absorption rate (SAR) and is the widely accepted measurement of RF energy absorbed
                           into the body in watts per kilogram, averaged over an amount of tissue ranging from the
                           entire body to one gram.
                           29
                            See IEEE Std. C95.1-1991 and 47 CFR Sec. 2.1093(d)(2).




                           Page 16                                                  GAO-12-771 Telecommunications
of RF energy exposure 30—the only proven health effects of RF energy
exposure—and was set at a level well below the threshold for such
effects. FCC noted that the limit provided a proper balance between
protecting the public from exposure to potentially harmful RF energy and
allowing industry to provide telecommunications services to the public in
the most efficient and practical manner possible.

In 2006, IEEE published its updated recommendation for an RF energy
exposure limit of 2.0 watts per kilogram, averaged over 10 grams of
tissue. 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 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.



30
  In scientific tests, animals had adverse behavioral effects once they absorbed enough
RF energy to increase their body temperature by 1 degree Celsius. IEEE incorporated a
safety factor into its standards for general human exposure by setting them at one-fiftieth
the exposure shown to cause adverse effects in animals. Because this limit is based on
whole-body exposure, it was further adjusted to account for the fact that mobile phones
expose only a part of the body to RF energy.
31
 See IEEE Std. C95.1-2005.
32
  The output power of a phone is variable, using the minimum necessary for successful
communication, and at any time will be a function of distance to the nearest mobile phone
antenna and the presence of obstructions.
33
  See International Commission on Non-Ionizing Radiation Protection, Guidelines for
Limiting Exposure to Time-Varying Electric, Magnetic, and Electromagnetic Fields (Up to
300 GHz) (1998). The International Commission on Non-Ionizing Radiation Protection is
an independent scientific organization that provides guidance and advice on the health
hazards of non-ionizing radiation exposure. Its recommended exposure limit is for
frequencies up to 10 gigahertz. The IEEE recommendation was made for frequencies
between 100 kilohertz and 3 gigahertz.




Page 17                                                    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 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


34
  In re Guidelines for Evaluating the Environmental Effects of Radiofrequency Radiation,
11 FCC Rcd 15123, 15125 (1996).
35
  FCC’s rulemaking process includes multiple steps as outlined by law, with several
opportunities for public participation. FCC generally begins the process by releasing a
Notice of Proposed Rulemaking and establishing a docket to gather information submitted
by the public or developed within FCC to support the proposed rule. FCC analyzes
information in the docket and drafts a final rule.




Page 18                                                  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.


Mobile Phone Certification   FCC ensures compliance with its RF energy exposure limit by certifying
                             all mobile phones sold in the United States. In its application for
                             certification, manufacturers must provide evidence that their mobile
                             phones meet FCC’s RF energy exposure limit. FCC has authorized 23
                             TCBs in the United States and other countries to review applications that
                             involve evaluation of RF exposure test data and issue certifications on
                             behalf of the agency. TCBs are private organizations that have been


                             Page 19                                         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
                                         illustrates the mobile phone certification process.

Figure 2: U.S. 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



                                         36
                                           In 1999, FCC established a TCB program and requested that the National Institute of
                                         Standards and Technology accredit entities to perform TCB functions. The National
                                         Institute of Standards and Technology determined, in accordance with its procedures and
                                         in consultation with the FCC, that it would recognize qualified accreditation bodies to
                                         accredit TCBs. Subsequently, the National Institute of Standards and Technology
                                         approved ANSI in May 2000 and the American Association for Laboratory Accreditation in
                                         April 2007 as accreditation organizations for TCBs. These accreditation bodies assess
                                         new and current TCBs to ensure they comply with relevant requirements.
                                         37
                                           According to FCC, third and fourth generation mobile phone technologies allow
                                         consumers to access a variety of different services and functionalities, such as Web
                                         browsing, e-mail, access to application stores, video conference or chat, mapping and
                                         navigation systems, mobile commerce, and the downloading of content.




                                         Page 20                                                  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.


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




                       Page 21                                       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 22                                                           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 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



38
  These procedures were based on IEEE Std. 1528-2003. Because mobile phones are
not tested when in use directly against the body, FCC recommends that mobile phone
user manuals note that a minimum separation distance must be maintained between the
user’s body and the phone to comply with RF exposure limits.
39
   FCC guidance states that mobile phone body-worn tests should be conducted with belt-
clips and holsters attached to the phone and positioned against the flat surface of the
mold in normal use configurations. If the manufacturer does not supply these accessories,
a predetermined distance from the back of the mobile device to the flat surface of the mold
is recommended.




Page 23                                                   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 and
Mobile Phone
Industry Provide
Information to the
Public through
Websites and User
Manuals

Information Provided by   Federal agencies provide information to the public on the health effects of
Federal Agencies          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.




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




                          Page 24                                                    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 25                                                       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 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. 42


Information Provided by   The mobile phone industry provides information to consumers on the
Mobile Phone Industry     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 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.




                          41
                            FCC’s links to the EPA and FDA websites were not functional when we reviewed them
                          in April 2012. After we provided our draft report to FCC these links were fixed and were
                          functional as of July 2012.
                          42
                           The ordinance has been challenged in federal court. The case is currently being
                                                                           th
                          considered by the U.S. Court of Appeals for the 9 Circuit.
                          43
                            FCC does require a statement that the mobile phone complies with the agency’s RF
                          energy exposure limit, among other things. 47 CFR § 2.1077.




                          Page 26                                                  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
Conclusions   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


              Page 27                                       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
Recommendations for   actions:
Executive Action
                      •   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,
Agency Comments       Department of Defense, Department of Health and Human Services,
and Our Evaluation    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



                      Page 28                                          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




Page 29                                         GAO-12-771 Telecommunications
Appendix I: Scope and Methodology
             Appendix I: Scope and Methodology




             To determine what is known about the human health effects of radio-
             frequency (RF) energy exposure from mobile phone use, we reviewed
             selected studies including studies and reports that review and assess the
             scientific research, such as meta-analyses and government reports, as
             well as key individual epidemiological and laboratory studies. 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 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



             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).




             Page 30                                                  GAO-12-771 Telecommunications
Appendix I: Scope and Methodology




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 and
•   The European Commission’s Scientific Committee on Emerging and
    Newly Identified Health Risks. 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.




Page 31                                                  GAO-12-771 Telecommunications
                                            Appendix I: Scope and Methodology




                                            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
                                                                                           a
Name                Title                                                    Institution
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             Department of Environmental Science, University of Eastern
                    Epidemiology                                             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, University of Illinois, Chicago
                    Physiology, and Biophysics
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                                                     Cancer and Radiation Epidemiology Unit, The Gertner
                                                                             Institute, Chaim Sheba Medical Center, Israel
                    Associate Professor                                      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.




                                            Page 32                                                          GAO-12-771 Telecommunications
Appendix I: Scope and Methodology




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



Page 33                                         GAO-12-771 Telecommunications
Appendix I: Scope and Methodology




representatives from four mobile phone manufacturers that represent
over 70 percent of the U.S. market (LG, Motorola, Nokia, and Samsung).

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

Table 4: Mobile Phone User Manuals Reviewed

    Manufacturer                                Phone model
            a
    Apple                                       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.




Page 34                                                       GAO-12-771 Telecommunications
Appendix II: Studies GAO Reviewed
             Appendix II: Studies GAO Reviewed




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

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

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

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

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

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

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

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

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




             Page 35                                       GAO-12-771 Telecommunications
Appendix II: Studies GAO Reviewed




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.




Page 36                                        GAO-12-771 Telecommunications
Appendix II: Studies GAO Reviewed




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.




Page 37                                         GAO-12-771 Telecommunications
Appendix II: Studies GAO Reviewed




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.



Page 38                                      GAO-12-771 Telecommunications
Appendix III: Comments from the Federal
              Appendix III: Comments from the Federal
              Communications Commission



Communications Commission




              Page 39                                   GAO-12-771 Telecommunications
Appendix III: Comments from the Federal
Communications Commission




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



Acknowledgments

                  Mark L. Goldstein, (202) 512-2834 or goldsteinm@gao.gov
GAO Contacts
                  Marcia Crosse, (202) 512-7114 or crossem@gao.gov


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




(543290)
                  Page 41                                       GAO-12-771 Telecommunications
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