FCC Cell Phone Safety Guidelines Underestimate Harmful Radiation Absorbed by Children and Small Adults, Says New Analysis

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A new paper published online today in Electromagnetic Biology and Medicine demonstrates children and small adults absorb significantly more cell phone radiation than had been previously understood by using the conventional and widely used assessment methodology, the Specific Anthropomorphic Mannequin (i.e. plastic model of a brain, or SAM), to assess the ”Specific Absorption Rate”, known as the SAR.

Download Summary PDF“Exposure Limits: The underestimation of absorbed cell phone radiation, especially in children” by Om P. Gandhi, L. Lloyd Morgan, Alvaro Augusto de Salles,Yueh-Ying Han, Ronald B. Herberman & Devra Lee Davis (Corresponding author is L. Lloyd Morgan at 510-841-4362 or [email protected])

The study, “Exposure Limits: The underestimation of absorbed cell phone radiation, especially in children”, by Om Gandhi et al, concludes that the SAM assessment methodology must be replaced with a more accurate risk assessment tool, one the authors say already exists and is used widely in research, including in research on cell phone risks at the FDA. This study is important because it calls into question present cell phone exposure guidelines from an engineering, not health, point of view.

The alternative method for assessing radiation exposure, called the FDTD computer simulation cellphone certification process, is immediately available and provides 3-orders of magnitude higher resolution than the SAM-based system for the head used in determining the SAR. Both methods, the FDTD, which uses MRI, and the SAM, have been FCC approved for use in the certification process to determine if a phone meets the Federal Communications Commission’s (FCC) exposure limit for the maximum amount of microwave cellphone radiation absorbed in the head. The new paper, showing dramatically greater evidence of risk from cell phones, and especially for children, with the MRI approach, will prompt a call for use of the MRI-based computer simulation method of cell phone risk assessment.

It is possible that as many as half of the cell phones on the market today will not pass muster, and instead, that many phones will be in violation of the FCC exposure limits. If that is the case, steps must be taken to make phones safer if they exceed the FCC safety guidelines.


The SAM method of estimating exposure uses a plexiglass mannequin head filled with fluid to simulate exposure of a large man to the thermal effects of cell phone radiation (see Figure 1 from the study, to the left) in only 6 minutes of cell phone use.

The methodology being proposed, the FDTD (Finite Difference Time Domain), uses MRI-scans of a set of real human beings to determine the amount of radiation absorbed in every tissue when exposed to a given phone. The approach is called the “Virtual Family” (see Figure 3 from the report below) and includes a 5-year old girl, a 6-year old boy, an 8-year old girl, an 11-year old girl, a 14-year old boy, a 26-year old female, a 35-year old male, an obese male adult and 3 pregnant women at 3rd, 7th and 9th months of gestation. It allows detail not just on what is estimated to be happening in the brain, but in any body part, including the eyes and the testes, tissues known to be especially sensitive to electromagnetic radiation (For a succinct summary of fertility risks see ElectromagneticHealth.org’s “Letter to Parents on Fertility and Other Risks to Children from Wireless Technologies”).



Lloyd Morgan, B.S., one of the paper’s authors, says,

“There is absolutely no excuse not to use the more accurate method of assessing cell phone radiation exposure. We are now using an industry-designed certification process that greatly underestimates risks from cell phones. The methodology conceals the fact that all cell phone users who keep cell phones in their pockets absorb cell phone radiation above the FCC thermal exposure limits, and that people of smaller sizes and younger ages will be more vulnerable.”

Below is Figure 5 from the report, a simulated SAR distribution to the head and neck using the proposed, superior FDTD risk assessment methodology.



Alvaro Augusto de Salles, Ph.D., Professor, Electrical Engineering Dept., Federal University of Rio Grande do Sul, Porto Alegre, Brazil and one of the paper’s authors, says:

“The higher risk of tissue damage from common cell phone use demonstrated in this study, using the computer simulation method of SAR assessment, suggests prudent public health policies, globally, would call for cell phones to be manufactured without the ability to use the phone against the head, nor with a speakerphone, but only allow communication with a wired headset. This would dramatically lower risk of biological, and genetic, damage to the population, and to children and other especially vulnerable populations, such as pregnant women, by keeping the radiation, thereby, away from both the head and body.”

A Summary of Key Points in the paper by Lloyd Morgan, B.S. of the Environmental Health Trust can be found here.

The report drew several conclusions, including:


(1) Because, the SAM-based cell phone certification process substantially underestimates the SAR for 97% of the population, especially for children, the SAM-based certification process should be discontinued forthwith.

(2) An alternative FDTD computer simulation cell phone certification process is immediately available and provides three orders of magnitude higher resolution than the SAM-based system for the head.

(3) The anatomically based “Virtual Family” includes sensitive groups such as small children, pregnant women, and the fetus.

(4) Advisories found in cell phone manuals violate the FCC compliance guidelines, because they do not take into account customary use of phones in pockets and held directly next to the head.

(5) The SAM-based cell phone certification process is unable to address exposure to sensitive tissues such as the testes or the eyes, while the FDTD method can addresses exposures to such sensitive tissues.

(6) Because billions of young children and adults with heads smaller than SAM are now using cell phones extensively, and because they absorb proportionally greater cell phone radiation, it is essential and urgent that governments around the world revise approaches to setting standards for cell phone radiation, to include sufficient protection of children.

Please note that while this paper raises an extremely important point about the methodology used to calculate the SAR, there are other equally important issues regarding cell phone radiation risk not part of this discussion, but nonetheless important. These include the non-heating effects from the radiation not measured by the SAR, such as the effects from the cell phone frequencies and modulations of the signal. (See article on SAR deficiencies “Top Safe Cell Phones That Aren’t ‘Safe’” ). These are still of great concern, are not measured by the SAR, and may be as important biologically than the heating effects.

Of course, the most important determinant of risk is how frequently one uses the cell phone and the duration of calls. Heating effects for the much longer durations of typical cell phone use today (much longer than 6 minutes), especially among business users, as well as among school children using cell phones for their homework, must now immediately be further evaluated using the more accurate Finite Difference Time Domain (FDTD) SAR assessment methodology.

ElectromagneticHealth.org urges all readers to contact their elected officials in Congress and request the FCC require cell phone safety testing be conducted with the more accurate FDTD (Finite Difference Time Domain) SAR assessment methodology.

How To Look Up Your Representatives in Congress:


House Members



L. Lloyd Morgan
Corresponding Author
Berkeley, CA
[email protected]

Camilla Rees
Founder, ElectromagneticHealth.org
[email protected]

Emily Roberson
Media Relations, ElectromagneticHealth.org
[email protected]

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