Comparing Five Exposure Limits for RF Electromagnetic Microwave Radiation

Adapted from paper by Kenneth R. Foster, Department of Bioengineering, University of Pennsylvania, Philadelphia PA 19104 USA | Original is here.


Exposure limits in effect in Russia have historically been far lower than those in the West, and the current limits have not changed significantly since Soviet times. The following discussion is largely based on a 2012 review by Repacholi et al. (2012). For more recent reviews, see Grigoriev (2017) and Bukhtiyarov et al. (2015) . . . These differences reflect long-held views of experts in the Soviet Union/Russian Federation that RF energy is biologically active, even at very low exposure levels (com- pared to Western exposure limits). The Soviet/Russian medical literature has many papers on health and biological effects of RF energy going back to the 1960s or before, many of which report biological effects or medical problems at very low levels of exposure (for reviews in English, see Repacholi et al. (2012) and Pakhomov et al. (2000)). In addition, the medical literature in the former Soviet Union contains many reports, going back for more than half a century, on use of millimeter waves (<200 W/m 2 ) to treat a variety of prob- lems with many claims of therapeutic benefit.

This Conference is entitled “Criteria for EMF Standards Harmonization”. Harmonization, used in the present context, is the process of reducing the large discrepancies in EMF exposure standards that are in effect throughout the world.

For many years, these differences were most apparent between limits of Russia and most of Eastern Europe (which originated in the days of the Soviet Union and the Warsaw Pact) and those of the United States and West Europe. This situation has become even more complicated with the recent adoption of “precautionary” limits by Switzerland, Italy, and a few other countries. Behind these differences are large differences in perception of science and health protection. Before any “harmonization” can succeed, it is necessary first to understand the differences among these approaches. I focus on exposure guidelines to radiofrequency (RF) energy in the range around 1-2 GHz, which is used by mobile telephones (and a host of other applications).

Pulsed, data-modulated, Radio-frequency Electromagnetic Microwave Radiation (RF-EMR) Exposure Limits at 2,000 MHz

The list below compares five different exposure limits for RF energy at 2000 MHz in average µW/m² (not peak) exposures in frequencies commonly used ion many cellular telephones throughout the world. The limits are for long-term exposure to the general population.

Country Limit for general public exposure to RF fields (2,000 MHz) for extended periods of exposure, in µW/m² (applies to far-field exposure, extended duration, meaning forever)

  1. 10,000,000 µW/m² — ICNIRP (adopted in numerous countries worldwide)

  2. 10,000,000 µW/m² — U.S. Federal Communications Commission (FCC) Bulletin 65, “Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields”, Washington DC 1997, which generally follows IEEE C95.1- 1999 with some modifications

  3. 100,000 µW/m² — China UDC 614.898.5 GB 9175 –88

  4. 100,000 µW/m² — Russia Sanitary Norms and Regulations 2.2.4/

  5. 100,000 µW/m² — Switzerland Ordinance on Protection from Non-ionising Radiation (NISV) of 23 December 1999

  6. 10,000 µW/m² — Typical Maximum Exposure from Cellular Base Station Mounted on 50 meters (164 feet) tower (assuming a total effective radiated power of 2500 watts in each sector or 7500 Watts ERP for all three scectors, summed over all channels)

Limits in the United States, most Western European countries, and many countries in other parts of the world follow IEEE C95.1-19991 or the (quite similar) ICNIRP limits.[^]2 Those in the Russian Federation, (together with most of its former Warsaw Pact allies), China, Switzerland, and a few other countries are as much as a hundred times lower.

. . . .

There is a considerable body of commentary about the Russian and Eastern European standards by scientists who have been professionally involved in RF health and safety studies, including some by Russian and East European scientists (e.g. 4 5 6 7 8 9 ).

I thank Dr. A.G. Pakhomov for providing an English translation of the present Russian standard (SanPin 2.2.4/ The Russian (and several Eastern European) limits are far below thermal levels. More strikingly (from the perspective of Western limits) they embody the concept of dose, i.e. the incident power density multiplied by time.

One Russian authority indicated that the limits of the Russian Federation for RF exposure at the frequencies used by wireless communications were set on the basis of biological experiments that found that a 3-hr daily exposure at 2,500,000 µW/m² (950 MHz) could be regarded as a threshold for harmful physiological effects in experimental animals.[^10]

Thus, Russian (and Eastern European) limits clearly reflect the conviction that long-term (hours or more) exposures at levels far below Western limits result in adverse health effects. Indeed, the Russian and Eastern European medical literature contains many reports of health effects from low-level exposure to RF energy. These include, for example, nonspecific problems (such as headaches, fatigability, irritability, sleep disorders, and dizziness) in workers in radio factories, who are exposed to RF energy at undetermined levels (11 12).

The Chinese literature contains similar reports.[^13} The Russian literature contains references to a “microwave disease” characterized by “asthenic, asthenovegetatic, and hypothalamic syndromes”14 The disease is not recognized in Western medicine, and its diagnostic criteria would undoubtedly strike many Western physicians as vague and nonfalsifiable.

Even some Eastern European physicians have complained about the nonspecificity of these criteria as well.(15 16)

The large difference, between Russian and Eastern European exposure limits and those in the U.S. and
most of Western Europe, is of longstanding duration. The latest Russian exposure standards (1996, 1997)
are essentially identical to previous ones (1976, 1978, 1984).

The Swiss levels . . . might exclude base stations mounted at elevations lower than 50 meters (164 feet) on buildings (not to mention many broadcast facilities, airport radars, and other high-powered transmitters).

Harmonization of pulsed, data-modulated, Radio-frequency Electromagnetic Microwave Radiation (RF-EMR) Exposure Limits

The combination of uncertain quality, together with inadequate reporting, is an impossible barrier.

The document that promulgates the Russian standard lists asthenic, astheno-vegetative, and hypothalamic syndromes as “clinical disorders resulting from EMR [electromagnetic radiation] RF exposure”.[^17] Such concepts are familiar in Russian medicine, and the Russian and Eastern European literature on health effects of RF energy abounds with such concepts.

Clearly, “harmonizing” Russian and US limits (for example) will be far more than a technocratic exercise. The differences between these science-based standards involve different medical traditions with different concepts of health and disease.

The precautionary principle is well established in international law and enjoys widespread political support. By their very nature, precautionary policies are set in the absence of scientific knowledge, not on the basis of such knowledge.

In a “Backgrounder” on the precautionary principle19, the World Health Organization recommended that precautionary policies “be adopted only under the condition that scientific assessments of risk and science-based exposure limits should not be undermined by the adoption of arbitrary cautionary approaches. That would occur, for example, if limit values were lowered to levels that bear no relationship to the established hazards or have inappropriate arbitrary adjustments to the limit values to account for the extent of scientific uncertainty.”

WHO noted that a variety of “precautionary” approaches (such as improved risk communication) can be taken to EMF regulation, apart from setting mandatory limits. WHO also noted that some European “precautionary” policies about EMF field regulation would seem to be inconsistent with recent commentary by the European Commission on the proper use of the principle.20

In the end, harmonization may come about from political and economic pressures rather than from scientific data. Recently, the Czech Republic revised its limits upwards, to those of ICNIRP, as part of the process of integration into the European Union. Other Eastern European nations, in their bids to join the EU, are considering similar changes.


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16 Djordjevic Z, Kolak A, Djokovic V, Ristic P, Kelecevic Z (1983) Results of our 15-year study into the biological effects of microwave exposure. Aviat Space Environ Med 54:539-42

17 Sanitary Rules and Norms (SanPin 2.2.4/ (1996) Radiofrequency electromagnetic radiations (2.2.4. physical factors of industrial surroundings. 2.1.8. physical factors of the environment) p. 28

18 Foster KR, Vecchia P, Repacholi MH (2000) Science and the precautionary principle. Science 288: 979-980

19 World Health Organization (March 2000) Electromagnetic fields and public health cautionary policies (available on the WWW at

20 Foster KR, Vecchia P, Repacholi MH (2000) Science and the precautionary principle. Science 288: 979-980