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Comment for the Access Board about EMR Exposure

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6. All households and workplaces with children, people with implants or people with EHS must be allowed to opt-out of wireless transmitting meters for gas, electric and/or water utilities at no charge. This requires a federal policy.

7. Microwave ovens are tested for EMR emissions before they leave the factory. Electrical grounds on buildings are tested at installation. However, aging of electronics and grounds often creates EMR emissions beyond compliance with standards and codes. Aging can also decrease energy efficiency. Wherever children, pregnant women, workers, people with implants or EHS spend time (homes, schools, libraries, hospitals, etc.), periodic retesting of EMR emissions from electronics, building electrical grounds and wiring should be required. Retesting should be conducted by independent testers supervised by ADA or FDA.

8. Printers, computers and other electronics should be required to have wired functions. All electronics should be required to have wireless capabilities shut off. New goods should be properly labeled for having a wired function.

Three

A few US regulations worth noting in order to illuminate that they have not kept up with the pace of deployments:

* In 1934, Congress passed The Broadcasting Act and established our FCC. The FCC encouraged entrepreneurs to invent and market electronics and appliances--as long as they did not create "harmful interference." The FCC defined harmful interference as anything that interferes with existing radio or TV broadcasts. More recently, "harmful interference" includes cellular and Internet services: new products and services may not interfere with existing radio or TV broadcasts or cellular or Internet services. The FCC's definition of "harmful interference" has never included biological harm to humans or wildlife.

* In the mid-90s, the FCC determined whether mobile devices are safe for human use by filling the head of a standard anthropomorphic man (SAM) with salty fluid and taking his temperature. (SAM's size is similar to that of a 200-pound man.) Engineers gave the dummy a cell phone for six minutes, then they took his temperature again. Because SAM's temperature did not change by two degrees in those six minutes, the FCC determined that mobile devices are safe to market. In other words, the FCC determined mobile device safety solely by the immediate, thermal effects of EMR-exposure. (For studies about the non-thermal effects of exposure, visit www.bioinitiative.org and www.saferemr.com.)

* FCC tests and regulations of electronics do not account for differences in exposure experienced by adult men and fetuses, infants, children, women, people with medical implants, the infirm, people on medication, the elderly, nor for exposure to multiple transmitters at the same time. Some medical-implant manufacturers recommend exposure limits of no more than 0.25 W/kg for fifteen minutes (www.MRIsafety.com).

* In 2013, the FCC reclassified the pinna (outer part) of our ears as extremities, effectively allowing the head to absorb nearly three times as much radiation as had been allowed before this reclassification.

* Section 704 of the 1996 Telecommunications Act prohibits municipalities from regulating "wireless service facilities on the basis of the environmental effects of radiofrequency emissions." In other words, environmental and health concerns may not interfere with the installation of cell towers.

* In September, 2015, Sen. Richard Blumenthal (D-Conn) and Rep. Anna Eshoo (D-Calif.) wrote FCC Chair Tom Wheeler "even though the FCC recommends that wireless carriers control exposure to harmful RF radiation using safety protocols such as signs, barricades and training... these recommendations have not consistently been implemented to protect workers." The senators added that because cellular antennas are now found atop apartments, schools, hospitals, churches and fire stations, "RF technicians but also roofers, water proofers, electricians, carpenters, building maintenance personnel, HVAC technicians, painters, firefighters" and others are at risk of EMR exposure. While the FCC has made deploying wireless broadband a priority, including easing tower-siting policies, these legislators don't want that to come at the expense of safety. See John Eggerton's piece with MultiChannel News, Sept. 17, 2015.

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Katie Singer writes about nature and technology in Letters to Greta. She spoke about the Internet's footprint in 2018, at the United Nations' Forum on Science, Technology & Innovation, and, in 2019, on a panel with the climatologist Dr. (more...)
 

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