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The installation of wireless ‘smart meters’ in California can produce significantly high levels of radiofrequency radiation (RF) depending on many factors (location of meter(s) in relation to occupied or usable space, duty cycle or frequency of RF transmissions, reflection and re-radiation of RF, multiple meters at one location, collector meters, etc).
Power transmitters that will relay information from appliances inside buildings with wireless smart meters produce high, localized RF pulses. Any appliance that contains a power transmitter (for example, dishwashers, washers, dryers, ranges and ovens, convection ovens, microwave ovens, flash water heaters, refrigerators, etc) will create another ‘layer of RF signals’ that may cumulatively increase RF exposures from the smart meter(s).
It should be emphasized that no single assertion of compliance can adequately cover the vast number of site-specific conditions in which smart meters are installed. These site-specific conditions determine public exposures and thus whether they meet FCC compliance criteria.
Tables in this report show either distance to an FCC safety limit (in inches) or they show the predicted (calculated) RF level at various distances in microwatts per centimeter squared (uW/cm2).
Both depictions are useful to document and understand RF levels produced by smart meters (or multiple smart meters) and by collector meters (or collections of one collector and multiple smart meters).
Large differences in the results of computer modeling occur in this report by bracketing the uncertainties (running a sufficient number of computer scenarios) to account for variability introduced by possible duty cycles and possible reflection factors.
FCC equations from FCC OET 65 provide for calculations that incorporate 60% or 100% reflection factors. Studies cited in this report document higher possible reflections (in highly reflective environments) and support the inclusion of higher reflection factors of 1000% and 2000% based on Vermeeren et al, 2010, Hondou et al, 2006 and Hondou, 2002. Tables in the report provide the range of results predicted by computer modeling for duty cycles from 1% to 100%, and reflection factors of 60%, 100%, 1000%, and 2000% for comparison purposes. FCC violations of time-weighted average calculations and peak power limit calculations come directly from FCC OET 65 and from ANSI/IEEE c95.1-1992, 1999. Duty cycle (or how frequently the meters will produce RF transmissions leading to elevated RF exposures) is uncertain, so the full range of possible duty cycles are included, based on best available information at this date.
• Tables 1-2 show radiofrequency radiation (RF) levels at 6” (to represent a possible face exposure). These are data tables.
• Tables 3-4 show RF levels at 11” (to represent a possible nursery/bedroom exposure). These are data tables.
• Tables 5-6 show RF levels at 28” to represent a possible kitchen work space exposure. These are data tables.
• Tables 7-9 show the distance to the FCC violation level for time-weighted average limits and for peak power limits (in inches). These
are data tables.
• Tables 10-15 show where FCC violations may occur at the face, in the nursery or in the kitchen scenarios. These are colored tables highlighting where FCC violations may occur under all scenarios.
• Tables 16-29 show comparisons of smart meter RF levels with studies that report adverse health impacts from low-intensity, chronic exposure to similar RF exposures. These are colored tables highlighting where smart meter RF levels exceed levels associated with adverse health impacts in published scientific studies.
• Tables 30-31 show RF levels in comparison to Medtronics advisory limit for MRI exposures to radiofrequency radiation at 0.1 W/Kg or about 250 uW/cm2. These are colored tables highlighting where smart meter RF levels may exceed those recommended for RF exposure.
• Tables 32-33 show RF levels from smart meters in comparison to the BioInitiative Report recommendation of 0.1 uW/cm2 for chronic exposure to pulsed radiofrequency radiation.
Findings
RF levels from the various scenarios depicting normal installation and operation, and possible FCC violations have been determined based on both time-averaged and peak power limits (Tables 1 – 14).
Potential violations of current FCC public safety standards for smart meters and/or collector meters in the manner installed and operated in California are illustrated in this Report, based on computer modeling (Tables 10 – 17).
Tables that present data, possible conditions of violation of the FCC public safety limits, and comparisons to health studies reporting adverse health impacts are summarized (Tables 18 – 33).
Where do predicted FCC violations occur for the 655 uW/cm2 time-averaged public safety limit at the face at 6” distance from the meter?
Table 10 shows that for one smart meter, no violations are predicted to occur at 60% or 100% reflection factor at any duty cycle, but violations are predicted to occur with nearly all scenarios using either 1000% or 2000% reflection factors.
Table 10 also shows that for multiple smart meters, FCC violations are predicted to occur at 60% reflection factor @ 50% to 100% duty cycles; and also at 100% reflection factor @ 30% to 100% duty cycle. All scenarios using either 1000% or 2000% reflection factors indicate FCC violations can occur (or conservatively at 12% to 22% of those in Hondou et al, 2006).
Table 11 shows that for one collector meter, one violation occurs at 60% @ 100% duty cycle; and at 100% reflection factor for duty cycles between 60% and 100%. Violations are predicted to occur at all scenarios using either 1000% or 2000% reflection factors.
Table 11 also shows that for one collector meter plus multiple smart meters, FCC violations can occur at 60%reflection factor @ 40% to 100% duty cycles; and also at 100% reflection factor @ 30% to 100% duty cycle. All scenarios using either 1000% or 2000% reflection factors indicate FCC violations can occur.
Where do predicted FCC violations occur for the 655 uW/cm2 time-averaged public safety limit in the nursery crib at 11” distance?
Table 12 shows that for one smart meter, no violations are predicted to occur at 60% or 100% reflection factor at any duty cycle, but violations would be predicted with nearly all scenarios using either 1000% or 2000% reflection factors.
Table 12 also shows that for multiple smart meters, no FCC violations are predicted to occur at 60% reflection factor at any duty cycle; and also at 100% reflection factor @ 90% and 100% duty cycle. All scenarios using either 1000% or 2000% reflection factors indicate FCC violations can occur.
Table 13 shows that for one collector meter, one violation occurs at 100% reflection @100% duty cycle. No violations at 60% reflection are predicted. Violations are predicted to occur at all scenarios using 1000% reflection except @ 1% duty cycle. All 2000% reflection scenarios indicate FCC violations can occur.
Table 13 shows that for one collector meter plus multiple smart meters, FCC violations are not predicted to occur at 60% reflection factor. At 100% reflection factor, violations are predicted at 60% to100% duty cycles. FCC violations are predicted for all1000% and 2000% reflection factors with the exception of 1000% reflection at 1% duty cycle.
Where do predicted FCC violations occur for the 655 uW/cm2 time-averaged public safety limit in the kitchen work space at 28” distance?
Table 14 shows that for one smart meter, no violations are predicted to occur at 60% or 100% reflection factor at any duty cycle. Violations would be predicted with scenarios of 1000% reflection @ 70% to 100% duty cycles and at 2000% reflection factor @ 20% to 100% duty cycles.
Table 14 also shows that for multiple smart meters, no FCC violations are predicted to occur at 60% or at the 100% reflection factors at any duty cycle. Violations are predicted at 1000% reflection factor @ 70% to 100% duty cycles and at 2000% reflection factor @20% to 100% duty cycles.
Table 15 shows that for one collector meter, one violation occurs at 100% reflection @100% duty cycle. No violations at 60% reflection are predicted. Violations are predicted to occur at all scenarios using 1000% reflection except @ 1% duty cycle. All 2000% reflection scenarios indicate FCC violations can occur.
Table 15 shows that for one collector meter plus multiple smart meters, FCC violations are not predicted to occur at 60% or at 100% reflection factors at any duty cycle. At 1000% reflection factor, violations are predicted at 30% to 100% duty cycles. FCC violations are also predicted at 2000% reflection factor @10 to 100% duty cycles.
Where can peak power limits be violated? The peak power limit of 4000 uW/cm2 instantaneous public safety limit at 3” distance? This limit may be exceeded wherever smart meters and collector meters (face plate or any portion within 3” of the internal antennas can be accessed directly by the public.
Table 16 shows that for one smart meter, no violations are predicted to occur at 60% or 100% reflection factor at any duty cycle. Peak power limit violations would be predicted with scenarios of 1000% reflection @ 10% to 100% duty cycles and at 2000% reflection factor @ 10% to 100% duty cycles.
Table 16 also shows that for multiple smart meters, peak power limit violations are predicted to occur at 60% reflection @ 60% to 100% duty cycle and for 100% reflection @ 40% to 100% duty cycles. Violations are predicted at 1000% reflection factor @ 10% to 100% duty cycles and at 2000% reflection factor @1% to 100% duty cycles.
Table 17 shows that for one collector meter, peak power limit violations are predicted to occur at 60% reflection @80% to 100% duty cycles and at 100% reflection @ 50% to 100% duty cycles. Violations of peak power limit are predicted to occur at all scenarios using 1000% reflection except @ 1%; and for 2000% reflection violations of peak power limit are predicted at all duty cycles.
Table 17 shows that for one collector meter plus multiple smart meters, peak power limit violations are predicted to occur at 60% @ 40% to 100% and 100% reflection @ 30% to 100% duty cycles. At 1000% and 2000% reflection factors, peak power limit violations are predicted at all duty cycles.
Where are RF levels associated with inhibition of DNA repair in human stem cells at 92.5 uW/cm2 exceeded the in the nursery crib at 11” distance?
Table 18 shows that for one smart meter, RF exposures associated with inhibition of DNA repair in human stem cells are predicted to occur at 60% reflection factor@ 70% to 100% duty cycles, and at 100% reflection factor @ 50% to 100% duty cycles. All scenarios using either 1000% or 2000% reflection factors exceed these RF exposures except 1000% at 1% duty cycle.
Table 18 also shows that for multiple smart meters, RF exposures associated with inhibition of DNA repair in human stem cells are predicted to occur at 60% reflection factor@ 20% to 100% duty cycles, and at 100% reflection factor @ 20% to 100% duty cycles. All scenarios using either 1000% or 2000% reflection factors exceed these RF exposure levels except 1000% at 1% duty cycle.
Table 19 shows that for one collector meter, RF exposures associated with inhibition of DNA repair in human stem cells are predicted to occur at 60% reflection factor@ 30% to 100% duty cycles, and at 100% reflection factor @ 20% to 100% duty cycles. All scenarios using either 1000% or 2000% reflection factors exceed these RF exposure levels.
Table 19 shows that for one collector meter plus multiple smart meters, RF exposures associated with inhibition of DNA repair in human stem cells are predicted to occur at 60% reflection factor@ 20% to 100% duty cycles, and at 100% reflection factor @ 10% to 100% duty cycles. All scenarios using either 1000% or 2000% reflection factors exceed these RF exposure levels.
Where are RF levels associated with pathological leakage of the blood-brain barrier at 0.4 – 8 uW/cm2 exceeded the in the nursery crib at 11” distance?
Table 20 shows that for one smart meter, RF exposures associated with pathological leakage of the blood-brain barrier at 8 uW/cm2 are predicted to occur at 60% reflection factor@ 10% to 100% duty cycles, and at 100% reflection factor @ 5% to 100% duty cycles. RF levels at 0.4 uW/cm2 (the lower end of the range) are exceeded at all duty cycles and at all reflection factors in the nursery in the crib.
Table 20 also shows that for multiple smart meters, RF exposures associated with pathological leakage of the blood-brain barrier at 8 uW/cm2 are predicted to occur at 60% reflection factor@ 5% to 100% duty cycles, and at 100% reflection factor @ 5% to 100% duty cycles. RF levels at 0.4 uW/cm2 (the lower end of the range) are exceeded at all duty cycles and at all reflection factors in the nursery in the crib.
Table 21 shows that for one collector meter, RF exposures associated with pathological leakage of the blood-brain barrier at 8 uW/cm2 are predicted to occur at 60% reflection factor@ 5% to 100% duty cycles, and at 100% reflection factor @ 5% to 100% duty cycles. RF levels at 0.4 uW/cm2 (the lower end of the range) are exceeded at all duty cycles and at all reflection factors in the nursery in the crib.
Table 21 shows that for one collector meter plus multiple smart meters, .RF exposures associated with pathological leakage of the blood-brain barrier at 8 uW/cm2 are predicted to occur at 60% reflection factor@ 5% to 100% duty cycles, and at 100% reflection factor @ 1% to 100% duty cycles. RF levels at 0.4 uW/cm2 (the lower end of the range) are exceeded at all duty cycles and at all reflection factors in the nursery in the crib.
Where are RF levels associated with adverse neurological symptoms, cardiac problems and increased cancer risk exceeded in the nursery crib at 11” distance?
Table 22 shows that for one smart meter, RF exposures associated with adverse neurological symptoms above 0.1 uW/cm2 are exceeded at all duty cycles and at all reflection factors in the nursery in the crib.
Table 22 shows that for multiple smart meters, RF exposures associated with adverse neurological symptoms above 0.1 uW/cm2 are exceeded at all duty cycles and at all reflection factors in the nursery in the crib.
Table 23 shows that for one collector meter, RF exposures associated with adverse neurological symptoms above 0.1 uW/cm2 are exceeded at all duty cycles and at all reflection factors in the nursery in the crib.
Table 23 shows that for one collector meter plus multiple smart meterss, RF exposures associated with adverse neurological symptoms above 0.1 uW/cm2 are exceeded at all duty cycles and at all reflection factors in the nursery in the crib.
Where are RF levels associated with inhibition of DNA repair in human stem cells at 92.5 uW/cm2 exceeded the in the kitchen work space at 28” distance?
Table 24 shows that for one smart meter, RF levels do not exceed those associated with inhibition of DNA repair at 60% or 100% reflection factor at any duty cycle. RF levels are exceeded at 1000% @ 10% to 100% duty cycles; and at 2000% reflection factor @ 5% to 100% duty cycles.
Table 24 also shows that for multiple smart meters, RF levels do not exceed those associated with inhibition of DNA repair at 60% or 100% reflection factor at any duty cycle. RF levels are exceeded at 1000% @ 5% to 100% duty cycles; and at 2000% reflection factor @ 1% to 100% duty cycles.
Table 25 shows that for one collector meter, RF levels do not exceed those associated with inhibition of DNA repair at 60% at any duty cycle; at 100% reflection factor they are exceeded at 70% to 100% duty cycles.. RF levels are exceeded at 1000% @ 5% to 100% duty cycles; and at 2000% reflection factor @ 1% to 100% duty cycles.
Table 25 shows that for one collector meter plus multiple smart meters, RF levels exceed those associated with inhibition of DNA repair at 60% reflection@100% duty cycle; at 100% reflection factor they are exceeded at 70% to 100% duty cycles.. RF levels are exceeded at 1000% @ 5% to 100% duty cycles; and at 2000% reflection factor @ 1% to 100% duty cycles.
Where are RF levels associated with pathological leakage of the blood-brain barrier and neuron death at 0.4 – 8 uW/cm2 risk in the kitchen work space at 28” distance?
Table 26 shows that for one smart meter, RF exposures associated with pathological leakage of the blood-brain barrier at 8 uW/cm2 are predicted to occur at 60% reflection factor@ 40% to 100% duty cycles, and at 100% reflection factor @ 30% to 100% duty cycles, and at all 1000% and 2000% reflections. RF levels at 0.4 uW/cm2 (the lower end of the range) are exceeded at all duty cycles and at all reflection factors in the kitchen work space except at 1% duty cycle for 60% and 100% reflections.
Table 26 also shows that for multiple smart meters, RF exposures associated with pathological leakage of the blood-brain barrier at 8 uW/cm2 are predicted to occur at 60% reflection factor@ 30% to 100% duty cycles, and at 100% reflection factor @ 20% to 100% duty cycles, and at all 1000% and 2000% reflections. RF levels at 0.4 uW/cm2 (the lower end of the range) are exceeded at all duty cycles and at all reflection factors in the kitchen.
Table 27 shows that for one collector meter, RF exposures associated with pathological leakage of the blood-brain barrier at 8 uW/cm2 are predicted to occur at 60% reflection factor@ 20% to 100% duty cycles, and at 100% reflection factor @ 10% to 100% duty cycles. RF levels at 0.4 uW/cm2 (the lower end of the range) are exceeded at all duty cycles and at all reflection factors in the kitchen work space.
Table 27 shows that for one collector meter plus multiple smart meters, .RF exposures associated with pathological leakage of the blood-brain barrier at 8 uW/cm2 are predicted to occur at 60% reflection factor@ 20% to 100% duty cycles, and at 100% reflection factor @ 20% to 100% duty cycles. RF levels at 0.4 uW/cm2 (the lower end of the range) are exceeded at all duty cycles and at all reflection factors in the kitchen work space.
Where are RF levels associated with adverse neurological symptoms, cardiac problems and increased cancer risk in the kitchen work space at 28” distance?
Table 28 shows that for one smart meter, RF exposures associated with adverse neurological symptoms above 0.1 uW/cm2 are exceeded at all duty cycles and at all reflection factors in the kitchen work space.
Table 28 shows that for multiple smart meters, RF exposures associated with adverse neurological symptoms above 0.1 uW/cm2 are exceeded at all duty cycles and at all reflection factors in the kitchen work space.
Table 29 shows that for one collector meter, RF exposures associated with adverse neurological symptoms above 0.1 uW/cm2 are exceeded at all duty cycles and at all reflection factors in the kitchen work space.
Table 29 shows that for one collector meter plus multiple smart meterss, RF exposures associated with adverse neurological symptoms above 0.1 uW/cm2 are exceeded at all duty cycles and at all reflection factors in the kitchen work space.
Where do RF levels exceed the Medtronics Safety Advisory?
Table 30: At no duty cycles for either 60% or 100% reflection factors; between 10% and 100% duty factors for 1000% and between 5% and 100% duty factors for 2000% reflection (for one smart meter).
Table 30: At 60% reflection @ 60% to 100% duty cycle; and at 100% reflection @ 40% to 100% duty cycle; at 1000% reflection @ 5% to 100% duty cycle and for all duty cycles at 2000% reflection (for multiple smart meters).
Table 31: At 60% reflection @ 70% to 100% duty cycle; at 100% reflection at 50% to 100% duty cycles; at 1000% reflection @ 5% to 100% and at all duty cycles for 2000% reflection (for one collector meter).
Table 31: At 60% reflection @ 40% to 100% duty cycle; at 100% reflection at 30% to 100% duty cycles; and at all duty cycles for both 1000% reflection and for 2000% reflection (for one collector meter plus three smart meters).
Where are RF levels associated with smart meters in all their configurations (one meter, multiple smart meters, one collector meter, one collector plus multiple smart meters) above those recommended in the BioInitiative Report (2007)?
Tables 32 and 33 depict the distance from the center of radiation for the smart meter(s) and collector meter scenarios in feet. The distances (in feet) at which RF levels exceed the BioInitiative Report recommended limit of 0.1 uW/cm2 is as small as 3.4’ (one smart meter at 60% reflection and 1% duty cycle). At 60% reflection and 100% duty cycle, the distance to the BioInitiative recommended limit increases to 34 feet for one smart meter.
When multiples of smart meters are considered, the shortest distance to where the BioInitiative Report recommended limit is exceeded is 9.7 feet (for 60% reflection @ 1% duty cycle). It increases to 97’ @100% duty cycle for multiple smart meters.
For a single collector meter, the shortest distance to a BioInitiative Report exceedence is 5.9 feet (60% reflection @ 1% duty cycle). At 60% reflection and 100% duty cycle, it increases to 59 feet.
For a collector and multiple smart meters, the shortest distance is 10.9 feet at 60% reflection @ 1% duty cycle, and increases to108 feet at 100% duty cycle.
Conclusions
FCC compliance violations are likely to occur under widespread conditions of installation and operation of smart meters and collector meters in California. Violations of FCC safety limits for uncontrolled public access are identified at distances within 6” of the meter. Exposure to the face is possible at this distance, in violation of the time-weighted average safety limits (Tables 10-11). FCC violations are predicted to occur at 60% reflection and 100% reflection factors*, both used in FCC OET 65 formulas for such calculations for time-weighted average limits. Peak power limits are not violated at the 6” distance (looking at the meter) but can be at 3” from the meter, if it is touched.
This report has also assessed the potential for FCC violations based on two examples of RF exposures in a typical residence. RF levels have been calculated at distances of 11” (to represent a nursery or bedroom with a crib or bed against a wall opposite one or more meters); and at 28” (to represent a kitchen work space with one or more meters installed on the kitchen wall).
FCC compliance violations are identified at 11” in a nursery or bedroom setting using Equation 10* of the FCC OET 65 regulations (Tables 12-13). These violations are predicted to occur where there are multiple smart meters, or one collector meter, or one collector meter mounted together with several smart meters.
FCC compliance violations are not predicted at 28” in the kitchen work space for 60% or for 100% reflection calculations. Violations of FCC public safety limits are predicted for higher reflection factors of 1000% and 2000%, which are not a part of FCC OET 65 formulas, but are included here to allow for situations where site-specific conditions (highly reflective environments, for example, galley-type kitchens with many highly reflective stainless steel or other metallic surfaces) may be warranted (see Methodology Section).
In addition to exceeding FCC public safety limits under some conditions of installation and operation, smart meters can produce excessively elevated RF exposures, depending on where they are installed. With respect to absolute RF exposure levels predicted for occupied space within dwellings, or outside areas like patios, gardens and walk-ways, RF levels are predicted to be substantially elevated within a few feet to within a few tens of feet from the meter(s).
For example, one smart meter at 11” from occupied space produces somewhere between 1.4 and 140 microwatts per centimeter squared (uW/cm2) depending on the duty cycle modeled (Table 12). Since FCC OET 65 specifies that continuous exposure be assumed where the public cannot be excluded (such as is applicable to one’s home), this calculation produces an RF level of 140 uW/cm2 at 11” using the FCCs lowest reflection factor of 60%. Using the FCC’s reflection factor of 100%, the figures rise to 2.2 uW/cm2 – 218 uW/cm2, where the continuous exposure calculation is 218 uW/cm2 (Table 12). These are very significantly elevated RF exposures in comparison to typical individual exposures in daily life.
Multiple smart meters in the nursery/bedroom example at 11” are predicted to generate RF levels from about 5 to 481 uW/cm2 at the lowest (60%) reflection factor; and 7.5 to 751 uW/cm2 using the FCCs 100% reflection factor (Table 13). Such levels are far above typical public exposures.
RF levels at 28” in the kitchen work space are also predicted to be significantly elevated with one or more smart meters (or a collector meter alone or in combination with multiple smart meters). At 28” distance, RF levels are predicted in the kitchen example to be as high as 21 uW/cm2 from a single meter and as high as 54.5 uW/cm2 with multiple smart meters using the lower of the FCCs reflection factor of 60% (Table 14).
Using the FCCs higher reflection factor of 100%, the RF levels are predicted to be as high as 33.8 uW/cm2 for a single meter and as high as 85.8 uW/cm2 for multiple smart meters (Table 14). For a single collector meter, the range is 60.9 to 95.2 uW/cm2 (at 60% and 100% reflection factors, respectively) (from Table 15).
Table 16 illustrates predicted violations of peak power limit (4000 uW/cm2) at 3” from the surface of a meter. FCC violations of peak power limit are predicted to occur for a single collector meter at both 60% and 100% reflection factors. This situation might occur if someone touches a smart meter or stands directly in front.
Uncertainty About Actual RF Levels
Consumers may also have already increased their exposures to radiofrequency radiation in the home through the voluntary use of wireless devices (cell and cordless phones), PDAs like BlackBerry and iPhones, wireless routers for wireless internet access, wireless home security systems, wireless baby surveillance (baby monitors), and other emerging wireless applications.
Neither the FCC, the CPUC, the utility nor the consumer know what portion of the allowable public safety limit is already being used up or pre-empted by RF from other sources already present in the particular location a smart meter may be installed and operated.
Consumers, for whatever personal reason, choice or necessity who have already eliminated all possible wireless exposures from their property and lives, may now face excessively high RF exposures in their homes from smart meters. This may force limitations on use of their otherwise occupied
space, depending on how the meter is located, building materials in the structure, and how it is furnished.
People who are afforded special protection under the federal Americans with Disabilities Act are not sufficiently acknowledged nor protected. People who have medical and/or metal implants or other conditions rendering them vulnerable to health risks at lower levels than FCC RF limits may be particularly at risk (Tables 30-31). This is also likely to hold true for other subgroups, like children and people who are ill or taking medications, or are elderly, for they have different reactions to pulsed RF. Childrens’ tissues absorb RF differently and can absorb more RF than adults (Christ et al, 2010; Wiart et al, 2008). The elderly and those on some medications respond more acutely to some RF exposures.
Eyes and Testes – Safety standards for peak exposure limits to radiofrequency have not been developed to take into account the particular sensitivity of the eyes, testes and other ball shaped organs. There are no peak power limits defined for the eyes and testes, and it is not unreasonable to imagine situations where either of these organs comes into close contact with smart meters and/or collector meters, particularly where they are installed in multiples (on walls of multi-family dwellings that are accessible as common areas).
What can be determined from the relevant standards (FCC and ANSI/IEEE and certain IEEE committee documents is that the eye and testes are potentially much more vulnerable to damage, but that there is no scientific basis on which to develop a new, more protective safety limit. What is certain is that the peak power limit of 4000 uW/cm2 exceeds what is safe (Appendix C).
In summary, no positive assertion of safety can be made by the FCC, nor relied upon by the CPUC, with respect to pulsed RF when exposures are chronic and occur in the general population. Indiscriminate exposure to environmentally ubiquitous pulsed RF from the rollout of millions of new RF sources (smart meters) will mean far greater general population exposures, and potential health consequences. Uncertainties about the existing RF environment (how much RF exposure already exists), what kind of interior reflective environments exist (reflection factor), how interior space is utilized near walls), and other characteristics of residents (age, medical condition, medical implants, relative health, reliance on critical care equipment that may be subject to electronic interference, etc) and unrestrained access to areas of property where meter is located all argue for caution.
Electronic Interference
Consumers may experience electronic interference (electromagnetic interference or EMI) from smart meter wireless signals. The FCC also is charged with investigating consumer complaints about electronic interference.
“The FCC requires that unlicensed low-power RF devices must not create interference and users of such equipment must resolve any interference problems or cease operation. According to the FCC (47CFR Part 15): “The operator of a radio frequency device shall be required to cease operating the device upon notification by a Commission representative that the device is causing harmful interference. Operation shall not resume until the condition causing the harmful interference has been corrected.”
(EPRI, 2010)
Medical and other critical care equipment in the home environment may not work, or work properly due to electronic interference from smart meters.
Security systems, surveillance monitors and wireless intercoms may be rendered inoperable or unreliable. Some cordless telephones do not work reliably, or have substantial interference from smart meter RF emissions.
Electronic equipment and electrical appliances may be damaged or have to be replaced with other, newer equipment in order not to be subject to electromagnetic interference from smart meter RF bursts.
Americans With Disabilities Act
People who have medical implants, particularly metal implants, may be more sensitive to spurious RF exposures for two reasons. Electromagnetic interference (EMI) with critical care medical equipment and medical implants is a potentially serious threat. Patients with deep-brain stimulators (Parkinson’s disease patients) have reported adverse health effects due to RF from various environmental sources like security gates and RFID scanners. Patients with deep brain stimulators have reported the devices to be reprogramming or electrodes shut-down as a result of encounters with wireless RFID scanners. One manufacturer, Medtronics, has issued a warning for DBS implant patients to limit RF exposure to less than 0.1 W/Kg SAR (or sixteen times lower than for the general public) for MRI exposures.
The IEEE SC4 committee (2001) considered changes to existing ANSI/IEEE standards adopted in 1992 (C95.1-1992). They discussed vulnerable organs (eyes, testes) and metallic implants that can intensify localized RF exposures within the body and its tissues.
“Question 20: Are there specific tissues or points within the body that have particularly high susceptibilities to local heating due to thermal properties in the immediate vicinity of the tissue?”
Committee minutes include the following discussion on metallic implants.
“Metallic implants are an interesting example of this question. There can be very localized high field concentrations around the tips of long metal structures, in the gaps of wire loops. Of course, these metal devices don’t create energy, but can only redistribute it, so the effect is limited to some extent. Also the high thermal conductivity and specific heat capacity make them good thermal sinks for any localized heat sources generated around them.”
Since deep brain stimulators in Parkinson’s patients involve metal implants that are essentially long metal structures with tips that interface with brain tissue and nerves within the brain and body, exposing such patients with implants to high levels of pulsed RF that can produce localized, high RF within the body is certainly inadvisable. It is clear the IEEE SC4 committee recognized the potential risk by to calling such implanted metallic devices good ‘thermal sinks’ for localized heating dissipation.
The FCC’s Grants of Authorization and other certification procedures do not ensure adequate safety to safeguard people under Department of Justice protection under the Americans with Disabilities Act.
References
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June 2001 SC-4 Committee Minutes
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