12 Questions posed to the FCC in letter September 9, 2016


  1. Clarification is requested as to whether the FCC’s 1.6 W/kg psSAR limit accounts for the IEEE ±30% uncertainty factor. Documentation requested.


  1. Should the FCC be certifying cell phones for sale in instances where the measured psSAR is greater than 1.231 W/kg, since, with the IEEE ±30% uncertainty factor, a cell phone’s psSAR could otherwise rise above the 1.6 W/kg limit to as high as 2.08 W/kg?*


  1. What proximity sensors are required for phones, laptops, iPads and similar devices and how are they implemented? Do they reduce the psSAR so it is within the FCC 1.6 W/kg limit if the device is used on the lap or within the 20 cm distance allowed in certification testing? Do the sensors work when a person’s hands are continually on a laptop while typing? Details on FCC proximity sensor requirements for manufacturers, status of industry’s implementation of proximity sensors, and the FCC’s psSAR compliance and efficacy monitoring are requested.


  1. What specific surveillance activity does the FCC undertake to assess the impacts on psSAR from manufacturing variability (which can add another 10-20% to the psSAR)?


  1. What is the scope and extent of TCB post-market surveillance activities? Requested two examples of TCB Annual Reports on post-market surveillance activities and findings for the year 2015.


  1. As TCB Accreditation is excluded for ‘spread spectrum devices’, and since ‘spread spectrum’ technology is used in most modern cell phones and wireless transmitting devices, please explain what entity then regulates ‘spread spectrum’ technology?


  1. If testing laboratories can be within the same corporation as the TCB, what steps are taken to assure full independence and no conflicts of interest in the cell phone accreditation process?


  1. Given greater absorption of cell phone radiation in children, and the fact that cell phone manufacturers do not presently offer cell phone models with a low psSAR for children, how does the FCC consider its present guidelines to protect children?


  1. Since the SAM (Specific Anthropomorphic Mannequin) method of assessing the psSAR is an estimation of cell phone radiation in the head alone, as absorbed in a large man, and does not account for radiation absorbed in other body tissues, or amounts absorbed in people of smaller sizes and ages, as the FDTD (“Finite Difference Time Domain”) methodology can assess, how does the FCC presently determine the psSAR levels in body tissues beyond the head?


  1. Between the FCC and the FDA, where exactly does responsibility for assuring cell phones and all other forms of WTDs conform to the 1.6 W/kg psSAR limit reside?


  1. In what ways does the FCC rely on the expertise of the FDA if the FDA does not actually review the safety of cell phones and WTDs like it would a drug or medical device?


  1. In the interest of safety, should the FDA’s expertise in assessing radiation absorption using FDTD computer simulation be utilized to assess psSAR absorption given it is vastly superior to the SAM methodology used presently by the FCC?

*In the case of newer phones with multiple antennae, where the psSAR could potentially rise 33.6% (considering the allowance for the psSAR to be 1.662 W/kg in cases of phones with simultaneous transmissions plus the +30% IEEE allowed uncertainty factor), where the psSAR could otherwise rise as high as 2.14 W/kg, the FCC should not be certifying cell phones for sale in instances where the psSAR is greater than 1.195 W/kg.

Read full Swankin-Turner Letter to FCC

Download 12 Questions Posed to the FCC (PDF)


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