American Academy of Pediatrics Demands FCC Protect Children from Cell Phone & Wireless Radiation

Letter from the American Academy of Pediatrics to the 

FCC Regarding Radiofrequency Electromagnetic Radiation Standards

The American Academy of Pediatrics submitted the following letter to the Federal 
Communications Commission (FCC). 

The letter urges the FCC to adopt radiation standards that:

1.)  protect children's health and well-being from radiation emitted by cell phones and other 
wireless devices; 2.)  reflect how people actually use their cell phones; and 
3.)  provide sufficient information to enable consumers to make informed purchasing decisions.

The letter is also  available on the FCC's web site at http://bit.ly/17tQclg.

August 29, 2013 

The Honorable Mignon L. Clyburn

Acting Commissioner 

Federal Communications Commission 

445 12th Street SW 

Washington, DC 20054

The Honorable Dr. Margaret A. Hamburg

Commissioner 

U.S. Food and Drug Administration 

10903 New Hampshire Avenue 

Silver Spring, MD 20993

  

Dear Acting Chairwoman Clyburn and Commissioner Hamburg:

The American Academy of Pediatrics (AAP), a non-profit professional organization of 
60,000 primary care pediatricians, pediatric medical subspecialists, and pediatric surgical 
specialists dedicated to the health, safety and well-being of infants, children, adolescents, 
and young adults appreciates this opportunity to comment on the Proposed Rule 
“Reassessment of Exposure to Radiofrequency Electromagnetic Fields Limits and Policies” 
published in the Federal Register on June 4, 2013. 
 
In the past few years, a number of American and international health and scientific bodies 
have contributed to the debate over cell phone radiation and its possible link to cancer. The
International Agency for Research on Cancer (IARC), part of the United Nations’ 
World Health Organization, said in June 2011 that a family of frequencies that includes 
mobile-phone emissions is “possibly carcinogenic to humans.”  The National Cancer 
Institute has stated that although studies have not demonstrated that RF energy from 
cell phones definitively causes cancer, more research is needed because cell phone technology 
and cell phone use are changing rapidly. These studies and others clearly demonstrate the 
need for further research into this area and highlight the importance of reassessing current 
policy to determine if it is adequately protective of human health. 

As radiation standards are reassessed, the AAP urges the FCC to adopt radiation standards 
that:  

Protect children’s health and well-being. Children are not little adults and are 
disproportionately impacted by all environmental exposures, including cell phone radiation. 
Current FCC standards do not account for the unique vulnerability and use patterns specific 
to pregnant women and children. It is essential that any new standard for cell phones or other 
wireless devices be based on protecting the youngest and most vulnerable populations to 
ensure they are safeguarded throughout their lifetimes. 

Reflect current use patterns. The FCC has not assessed the standard for cell phone 

radiation since 1996. Approximately 44 million people had mobile phones when the standard 

was set; today, there are more than 300 million mobile phones in use in the United States. 

While the prevalence of wireless phones and other devices has skyrocketed, the behaviors 

around cell phone uses have changed as well. The number of mobile phone calls per day, the 

length of each call, and the amount of time people use mobile phones has increased, while cell 

phone and wireless technology has undergone substantial changes. Many children, adolescents

and young adults, now use cell phones as their only phone line and they begin using wireless 
phones at much younger ages. Pregnant women may carry their phones for many hours per 
day in a pocket that keeps the phone close to their uterus. Children born today will experience 
a longer period of exposure to radio-frequency fields from cellular phone use than will adults, 
because they start using cellular phones at earlier ages and will have longer lifetime exposures. 
FCC regulations should reflect how people are using their phones today. 

Provide meaningful consumer disclosure. The FCC has noted that it does not provide 

consumers with sufficient information about the RF exposure profile of individual phones to 

allow consumers to make informed purchasing decisions. The current metric of RF exposure 

available to consumers, the Specific Absorption Rate, is not an accurate predictor of actual 

exposure. AAP is supportive of FCC developing standards that provide consumers with the 

information they need to make informed choices in selecting mobile phone purchases, and to 

help parents to better understand any potential risks for their children. To that end, we 

support the use of metrics that are specific to the exposure children will experience. 

The AAP supports the reassessment of radiation standards for cell phones and other wireless 
products and the adoption of standards that are protective of children and reflect current 
use patterns. If you have questions, please contact Clara Filice in the AAP’s Washington 
Office at 202/347-8600.

Sincerely, 

Thomas K. McInerny, MD FAAP

President