Application of the Precautionary Principle to Cell Phone Radiation
By Rong Wang, PhD | December 16, 2013 | Categories: Cell Phone Radiation Protection | Pong Case by Pong Research
Although there is still no definitive answer whether cell phone radiation is harmful to human health, Pong, along with many other experts and health organizations around the world recommends the adoption of the “Precautionary Principle” on this matter. So what does this mean?
The Precautionary Principle
The Precautionary Principle is a policy of social responsibility aimed at protecting the public and environment from possible harm when the scientific community has validated a plausible risk. It is essentially a common sense based “better safe than sorry” approach suggesting that action should be taken to avoid harm even when it is not certain to occur.
There are many definitions of the Precautionary Principle. Precaution may be defined as ‘caution in advance,’ ‘caution practiced in the context of uncertainty,’ or ‘informed prudence’.
According to the COMEST (2005) report on the Precautionary Principle, “when human activities may lead to morally unacceptable harm that is scientifically plausible but uncertain, actions shall be taken to avoid or diminish that harm.” 
According to the World Health Organization (WHO), the Precautionary Principle is a risk management policy applied in circumstances with a high degree of scientific uncertainty, reflecting the need to take action for a potentially serious risk without awaiting the results of scientific research.
Simply speaking, the Precautionary Principle has three basic components: a harm condition, a knowledge uncertainty condition, and a remedy. Whether or not to invoke the Precautionary Principle is a decision exercised where there are indications that the existing level of protection may not adequately protect the environment or human health from potential dangers, where scientific information is insufficient, inconclusive, or uncertain and where there exit readily available solutions to reduce or eliminate the potential dangers at a reasonable cost.
The Precautionary Principle in the Context of Cell Phone Radiation
As the global cell phone subscription soared to 7 billion in 2013, the health impact of long-term exposure to excessive cell phone radiation has aroused considerable public concerns and scientific debate.
In the United States, the safety of radiation-emitting medical devices and consumer products (such as x-ray systems and microwave ovens) is regulated by the Food and Drug Administration (FDA). For example, the FDA requires that all microwave ovens must have a label stating that they meet the safety standard and a label explaining precautions for use. According to the FDA, when using a microwave oven, “consumers should take certain common sense precautions” because of “the fact that many scientific questions about exposure to low levels of microwaves are not yet answered” . However, the FDA does not regulate the safety of cell phones or similar wireless devices despite the facts that they emit the same type of radiation as microwave ovens do and that consumers tend to receive much more radiation exposure from cell phones than from microwave ovens due to their more frequent use and closer proximity to human head and body.
As a matter of fact, cell phones were introduced to the market without any safety testing on humans at all. In contrast, before a new drug is released to the public, it undergoes many stages of testing, both on animals and on human volunteers, to ensure its safety and effectiveness. The testing involving humans, called clinical trials, generally takes 10 years or more to complete. Although the Federal Communications Commission (FCC) does enforce certain cell phone exposure limits, known as SAR, to restrict how much radiation a cell phone can emit, the standards were based on a couple of animal behavioral studies in the 1970s and only considered the thermal (heating) effect of short-term exposure. As of today, cell phones have been in widespread use for more than 15 years, and there is still extremely limited research data on the long-term effects and the effects on children.
In other words, cell phones were basically assumed “safe” and permitted for society-wide use without any pre-market human safety testing or proof of long-term use safety. This approach has allowed consumers to enjoy the enormous benefits and convenience of wireless technology without having to wait to understand the long-term health effects of wireless radiation. However, this approach also comes with its intrinsic risk, a risk of “conducting a global experiment on our children and ourselves”  without any informed consent.
So is there any current solution for the cell phone radiation safety dilemma? Here comes the Precautionary Principle.
As stated previously, the Precautionary Principle has three basic components: a harm condition, a knowledge uncertainty condition, and a remedy. Let’s take a look at why the Precautionary Principle should be invoked for cell phone radiation.
- Since the inception of cell phones in the 1970s, there is an increasing body of scientific evidence on the possible adverse effects of cell phone radiation. According to the BioInitiative 2012, about 1800 new scientific studies were published between 2007-2012 reporting biological and health effects at exposure levels hundreds or thousands of times lower than current safety standards. The reported health effects include cancer, impaired brain and nervous functions, sperm damages and behavioral problems in children, to list a few. The current body of scientific evidence led the WHO to classify cell phone radiation as “possibly carcinogenic to humans” in May 2011. (Harm condition)
- Science is still inconclusive on whether cell phones are safe or harmful to humans. The results from the thousands of studies in this field are largely mixed and contradictory. Most studies are for acute and short-term exposures. The possible long-term health effects and the effects on children have been left open and are the subject of ongoing research. (Knowledge uncertainty)
- There are various simple, economic and readily available solutions to limit and reduce exposure. They range from simple changes of cell phone use behavior (e.g. using a speaker phone or a headset, texting instead of calling) to advanced technology at affordable prices (such as a Pong case) to effectively help cell phone users reduce their exposure. (Remedy)
From above analysis, cell phone radiation is a case that meets all three basic requirements to invoke the Precautionary Principle. In fact, the U.K. government recommended the Precautionary Principle more than a decade before the WHO’s classification.
In April 1999, the U.K. government commissioned the Independent Expert Group on Mobile Phones (IEGMP) to look into the possible health effects from the use of mobile phones, base stations and transmitters. Following a wide-ranging inquiry and review of scientific evidence, the Stewart Report (named after its chairman Sir William Stewart) was published in May 2000 (and updated in January 2005), which acknowledged that “it is not possible at present to say that exposure to RF radiation, even at levels below national guidelines, is totally without potential adverse health effects, and that the gaps in knowledge are sufficient to justify a precautionary approach” and therefore recommended that ‘a precautionary approach should be taken to the use of mobile phone technologies until more detailed information on any health effects becomes available’.
The WHO’s classification of cell phone radiation as a “possible carcinogen” to humans further strengthens the rational of the application of the Precautionary Principle to cell phone use. In his comment on the classification, IARC Director Christopher Wild said “Given the potential consequences for public health of this classification and findings, it is important that additional research be conducted into the long-term, heavy use of mobile phones. Pending the availability of such information, it is important to take pragmatic measures to reduce exposure.”
The U.S. government has yet to adopt the Precautionary Principle in regards to wireless radiation. However, over the past few years, the issue has come to the forefront.
A Report released by the U.S. Government Accountability Office (GAO) in August 2012 (the “GAO Report”) urged the FCC to update its portable device radiation exposure and testing guidelines, which has been in place since 1997 (some 4 years before the first smartphones became commercially available). In the Report, GAO pointed out the knowledge uncertainty in regards to the safety issue of wireless radiation. 
In March 2013, the FCC issued a formal Notice of Inquiry to seek for comments on whether the current exposure standards are sufficient in protecting the public. In the Inquiry, the FCC asked for comment on “whether any precautionary action would be either useful or counterproductive…. and if any action is found to be useful, whether it could be efficient and practical.”
Until the Precautionary Principle is formally embraced by the U.S. regulatory agencies, consumers need to remain informed about the current scientific uncertainty and take appropriate steps to limit exposures whenever possible. This is especially important for children, who are more susceptible to cell phone radiation due to their thinner skull and skin, still developing nervous systems and a potential life-long exposure. With the right information and education, prudent consumers can start to adopt the Precautionary Principal on a voluntary basis and begin taking actions to protect themselves and their family members from the potential health risks of cell phone radiation.
 Morally unacceptable harm refers to harm to humans or the environment that is ‘threatening to human life or health’, or ‘serious and effectively irreversible’, or ‘inequitable to present or future generations’, or ‘imposed without adequate consideration of the human rights of those affected.’ The judgment of plausibility should be grounded in scientific analysis. Analysis should be ongoing so that chosen actions are subject to review. Uncertainty may apply to, but need not be limited to, causality or the bounds of the possible harm. Actions are interventions that are undertaken before harm occurs that seek to avoid or diminish the harm. Actions should be chosen that are proportional to the seriousness of the potential harm, with consideration of their positive and negative consequences, and with an assessment of the moral implications of both action and inaction. The choice of action should be the result of a participatory process
 Manson 2002
 According to the FDA, “Less is known about what happens to people exposed to low levels of microwaves. Controlled, long-term studies involving large numbers of people have not been conducted to assess the impact of low-level microwave energy on humans. … The fact that many scientific questions about exposure to low levels of microwaves are not yet answered requires FDA to continue to enforcement of radiation protection requirements. Consumers should take certain common sense precautions”
 According to Electric Power Research Institute (EPRI) Field Measurement Study “Radio Frequency Exposure Levels for Smart Meters, a Case Study of One Model, February 2011”, the maximum/minimum RF power density level for cell phones at ear is 5000/1000 μW/cm2 compared to 200/50 μW/cm2 for microwave oven at 2 feet.
 SAR stands for Specific Absorption Rate. It is defined as the power absorbed per mass of body tissue when exposed to a radio frequency (RF) electromagnetic field and has units of watts per kilogram (W/kg). Maximum SAR levels for modern mobile devices are set by governmental regulating agencies in many countries. In the United States, the Federal Communication Commission (FCC) sets the SAR limit for public exposure to cell phone radiation to be 1.6 W/kg.
 By Devra Davis
 “In 2001, we reported that [the FDA] and others had concluded that research had not shown RF energy emissions from mobile phones to have adverse health effects, but that insufficient information was available to conclude mobile phones posed no risk. Following another decade of scientific research and hundreds of studies examining health effects of RF energy exposure from mobile phone use, FDA maintains this conclusion.”