At the end of Part I left you in 1980. A great year! Punk was in full swing. I was 15. Cellphones hadn’t been invented (they had, but in Thatcher’s Britain we didn’t know about them). It was a blast!! You could go out of the house for 5 hours and nobody called you or asked where you were. Oh, I forgot. The Soviets were going to nuke us, but Jimmy (Carter) would save us, and you could sneak into a pub and get served! The youth of today don’t know what they are missing! But I digress, let’s talk about serious stuff…….
I left you with a plum. In the world of exposure safety levels to Radio Frequency radiation the choice of 10 mW/cm2 as the safe limit was little more than a whim from Bell Labs. The belief was that the only damage to you from prolonged exposure would be tissue heating and less than 100 mW/cm2 wouldn’t kill you (literally. They boiled dogs alive at this level after one hour ). As long as exposure was limited to no more than an hour (the recommendations of H. Schwarm ) everything should be ok.
Indeed that was ok. Most of us were exposed only to our AM/FM radio and the TV. The ambient level of exposure was only 10-7 mW/cm2, one ten millionth of the recommended exposure level.
Actually, this was not a standard yet, just a recommendation. It became a standard in 1966. The policies, thinking and motivation that turned this to a standard was summarized in two documents in 1980 , one a federal study  and the other a Science paper . Initially, after Col. Knauf had boiled his dogs and their testes (literally), the matter had been handed over to a joint committee of the US Navy and the American Standards Association (ASA). By the end of 1966 this august body had produced a document (grandly titled C95) that for the first time considered the standard as a standard for exposure for the general public, rather than for occupational exposure. The problem was how to confirm that there would be damage. The committee returned to more animal studies . The majority of these studies would expose the poor animals to 100s mW/cm2 without seeing any ill effects (although with little standardization of exposure time, regimes or an agreed definition of “little effect”.), reinforcing the belief in the arbitrary limit. Col. Knauf even stated “Up to today we have not seen any research data which shakes our faith in the validity of the arbitrary safe exposure level which we sponsored five years ago” . Not surprising as they looked for short term immediate effects, rather than the more insidious long terms effects we see today. However, a small portion of those researchers did report finding anomalistic results that supported non thermal effects. They were ignored. In fact non-thermal effects had been reported as early as the 1920s . There were competing opinions, some in Industry wanted C95 scrapped, arguing that it was unnecessary and restrictive, others were content with it as it was, and others wanted more research. Eventually it was agreed to and the standard C95.1 is the first established safety standard set the exposure level to 10 mW/cm2. It was made by people who only considered exposure in terms of Radar Operators and Communications. The public was never supposed to be exposed. Its title was “Safety Level of Electromagnetic Radiation with Respect to Personnel.” It was for radar operators.
The American Standards Association morphed into the American National Standards Institute in 1969 and maintained the standard. In 1974 they even reaffirmed it as ANSI C95.1-1974 .
HOWEVER (sorry to shout), the ANSI is not a legislative body, in that it is not an arm of the American government. Its standards do not have the force of law! It is only in 1971 does the Department of Labor actually adopt C95.1 as a non-mandatory recommendation! Confused? It gets worse. By 1980 the responsibilities for microwave radiation are shared by the Department of Health (DOH), the Department of Labor (DOL) and the Environmental Protection Agency (EPA). Inside the DOH the Food and Drug Administration sets the standards for how much electromagnetic radiation a device or machine can emit, and they are responsible for promoting research. So, they instituted the Bureau of Radiological Health (BRH). Then there is the National Institute for Occupational Safety and Health (NIOSH), part of the Department of Health, and they advise the Department of Labor. Then there is the Occupational Safety and Health Administration (OSHA), Department of Labor. Then there is the Environmental Protection Agency (EPA), who is supposed to establish environmental radiofrequency exposure guidelines. So, they establish the Office of Radiation Programs…..
I imagine that by now you are as confused as I am about who, in 1980, was responsible for exposure guidelines. As pointed out in a Federal Report , “The process for establishing microwave regulations, as for any new ruling, is complicated and involves a series of steps, with administrative procedures varying from agency to agency”. And then there is the Federal Communications Commission (FCC), responsible for the licensing and regulation of transmitters. More about them later.
And then there is international cooperation, the World Health Organization (WHO), the International Radiation Protection Association (IRPA), The European Regional Office (ERO) of the WHO, the International Union of Radio Science (URSI)…………… But all this disguises one central fact. The belief underlying all standardization is that the only biological implication from exposure to radio waves up to the 100s GHz is an immediate heating effect in the tissue and if the intensity is less than 10 mW/cm2 they are no consequences.
So that was the situation in 1980 when I was pogoing to Punk.
One central question was just how do you decide when too much exposure is too much? Obviously if you have boiled a person alive or blinded them, it may be considered a little extreme. But a little bit of pain? ANSI came up with the idea (based on some university research) of using animal behavior. The rationale here is that if an animal’s behavior changed during exposure to an RF signal, then it must be the result of internal heating making the animal feel bad. So in 1982 they published the first dosimetry standard , . Based on research that showed that mice subjected to continuous signals at 400 MHz to 700 MHz (The original cellphone frequencies) – changed their feeding behavior if they absorbed between 4 W/kg to 8 W/kg of radiofrequency radiation. This is the first time I have introduced the concept of Specific Absorption Rates (SAR), measured in Watts per kilogram (W/kg). Translated this means “how much energy is translated into heat per second per kilogram of flesh”. And how do you measure that in a rat? You make a bag of saline gel approximately the same size as your rat with more or less the same electrical conductivity of flesh. You irradiate it at the desired frequency for the desired time and desired power, and measure its rise in temperature . From there it is a relatively simple calculation. But a bag of saline is not a rat! Nevertheless they used rectal thermometers to measure temperature rises in the body core  of the rats as they were exposed. That should have been enough to change their behavior! No matter how much the rat may have changed its behavior, if it recovered afterwards the exposure was deemed ok. They then took a 10-fold safety factor for human exposures and that is how we get TODAY’s (the emphasis is deliberate) exposure level of 0.4 W/kg whole body exposure averaged over 6 minutes. You can read more on this in the reference . And this was still not a fully fledged regulation! Although the experimental work referred to 700 MHz, ANSI decided that their standard would cover 300 kHz to 100 GHz! To approximately frequency 100 times higher! This standard allowed something even more sinister. To simplify the jargon, if the exposure was confined to a small piece of flesh weighing about 1 gram then you can absorb 8 W/kg. That means for phone next to your head the exposure could be 20 times higher!! Nobody knows why this was allowed in their standard .
In 1987 ANSI finally admitted that it did not have the medical expertise to manage the standard it had invented. So in a magnanimous gesture they handed over the management of EMF radiation standards to a body with even less knowledge in medical, biological or public health issues, the Institute of Electrical and Electronic Engineers (IEEE)! A classic example of “out of the frying pan and into the kitchen fire”.
Then in 1991 the IEEE revised the standard by giving it a new name – IEEE C95.1-1991 . Essentially it is the same old ANSI standard, which is the same old Tri-Services recommendation, which reaffirms a 1957 whim from Bell Labs. I think you begin to get the picture.
In 1996 the FCC finally produces the FIRST regulation governing exposure, because now we have cell phones and this regulation is for them! I quote from Gandhi et al.  :
The FCC exposure limits were, and remain, identical to the 1991 IEEE standard. The FCC SAR adopted values were:
- For occupational exposures, “0.4 W/kg as averaged over the whole-body and spatial peak SAR not exceeding 8 W/kg as averaged over any 1 gram of tissue (defined as a tissue volume in the shape of a cube). Exceptions are the hands, wrists, feet, and ankles where the spatial peak SAR shall not exceed 20 W/kg as averaged over any 10 grams of tissue (defined as a tissue volume in the shape of a cube) [averaged over 6 minutes].”
- For the general population exposures, “0.08 W/kg as averaged over the whole body and spatial peak SAR not exceeding 1.6 W/kg as averaged over any 1 gram of tissue (defined as a tissue volume in the shape of a cube). Exceptions are the hands, wrists, feet and ankles where the spatial peak SAR shall not exceed 4 W/kg, as averaged over any 10 grams of tissue (defined as a tissue volume in the shape of a cube) [averaged over 30 minutes].”
Essentially it is the IEEE standard, considering only heating as a problem and adding a safety margin. Notice the 1.6 W/kg allowed for short localized peak exposures. Your cellphone manufacturer doesn’t tell you that you phone call should be less than 6 minutes and the device kept at least 2.5 cm from your head. But then again, they don’t even keep this limit! (see this French report). So, we all routinely go beyond the FCC regulation…….
With the cellphone revolution in full swing another portentous date arrives – April 1998 and the issuing of the standard by the International Commission on Non-Ionizing Radiation Protection (ICNIRP). ICNIRP is a strange bird. It was formed in 1992  as an outgrowth of the International Radiation Protection Association (IRPA). The IRPA is an association of professionals who work with or in the field of ionizing radiation, a union of sorts, formed in 1996 to represent all national radiation societies active in the US at the time. Simply put, during the 1970s public concern of microwaves (principally the presence of the microwave oven in the home and maybe television) prompted IRPA to establish working groups to look at microwaves and issue guidelines, not something that it usually would do. As the use of microwaves began to increase in other countries too, institutions like the International Labour Office, who deals with the work environment, began to take an interest too . They turned to the only professional body on the horizon and so those IRPA working groups began to go international. Then in 1983 the European Union also expressed an interest and even began funding IRPA. Then the Union of Radioscientifique Internationale , then International Electrotechnical Commission, responsible for setting standards for equipment, also agrees to use the working group guidelines , and so the story goes on. Eventually, in 1992, these workshops morphed into ICNIRP as a separate entity. Many of the organizations I have mentioned are really members-only groups, guilds if you will. They set standards to suit themselves. ICNIRP is an independent international commission, chartered to examine science and issue guidelines for EMF . But a commission is made up of people and these people are supposed to be free of industry influence, something that has been challenged by the European Parliament –. Its members choose their own new members and there is no international charter or government body or oversight mechanism to hold them to account. The result is that they work by the same strange , dogmatic view that the only damage to health can be via heating over the short term. In 1998 ICNIRP issued its guidelines, that are almost identical to those of the FCC. In 2020 these were basically confirmed without change . Unfortunately, many governments rely on these guidelines verbatim, without seriously considering health implications which maybe inconvenient for industry……. or they rely on the International EMF Project of the world health organization. Not surprisingly ICNIRP and the EMF Project are completely in sync with each other. They would be. They were set up by the same person and the current head of the project was his protégé  .
In 2001 the FCC released a standard for the testing of all cellphones, the SAM cell phone certification process, which reduced the person to a bag of saline gel, just as they had done for rats in 1974, to measure temperature rise from absorbed EMF from the phone. And little has changed since.
So there you have it. The safety standard that governs your phone was an arbitrary decision from 1957 to serve an unstated purpose in Bell Labs. Since then, all research has been done to prove that they got it right, while ignoring anything that says they got it wrong. And on this has been built an edifice of respectability, of organizations dedicated to maintaining a deeply flawed concept. And, like those rats exposed to microwaves, we have changed our behaviour.
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