Dec 2019 Release of FCC Cell Phone RF-EMR Exposure Test

12/20/19 Statement from Prof. Trevor Marshall, PhD

These Cell Phone SAR tests conducted by the FCC are rendered meaningless by the knowledge that the human body is affected by peak intensities of pulsed, data-modulated, Radio-frequency Electromagnetic Microwave Radiation (RF-EMR), just as it is by ionizing-radiation. Biology is harmed by peak, as well as average RF-EMR exposures. The nature of the damage is generally dependent on the peak energy, with the total damage depending on how long the exposure lasts. With Microwave radiation the photon energy, its wavelength, along with the total number of photons, are all just as important as when these photons carry ionizing wavelengths. The microwave photons generally disturb protein-to-protein interactions, while the ionizing radiation disturbs atoms themselves.

X-Ray technicians are taught to both reduce the peak intensity and minimize total exposure times in order to minimize "long-term effects" of the radiation. We have known all this for half a century. Yes, I understand that the FCC on Dec,4, 2019 publicly said it is not worried about "long-term effects," so why bother to do any measurements at all? The assumption that long-wavelength microwave photons will behave fundamentally differently from short-wavelength ionizing photons makes no scientific sense at all. At the very least, every ‘safety’ test using only SAR should carry the small-text warning, as does the 12/4/19 FCC document 19-126, in which the says it now longer considers the "long-term effects" of the radiation exposure.

The FCC’s focus on SAR (an average) and exclusion of RF-EMR’s peak intensities, is plainly wrong in this world of low duty-cycle 4G and 5G data transmission protocols. The crest factor leads to typically 13dB, or 20 times strength difference between peak and average** power values. The measurement of peak envelope power is the all-encompassing imperative when human safety is concerned.


7435 Oakland Mills Road
Columbia, MD 21046
Telephone: 301-362-3000

December 10, 2019

Original FCC documents are here.

[Annotated] Results of FCC Cell Phone RF Exposure Compliance Test

S4WT Note: Yes, that is Compliance, NOT Safety because in matters of exposures to pulsed, data-modulated, Radio-frequency Electromagnetic Microwave Radiation (RF-EMR), compliance does not confer safety.

Please further note that This page is a DRAFT set of annotations. Links to specific US Code and US Regulations citations will be completed later today.


a) Apple Inc.

b) BLU Products, Inc.

c) Motorola Mobility, LLC

d) Samsung Electronics Co Ltd

Model Numbers:

1) iPhone 7

2) iPhone X

3) iPhone XS

4) Vivo 5 Mini

5) Moto e5 Play

6) Moto g6 Play

7) Galaxy S9

8) Galaxy J3


1) BCG-E3091A

2) BCG-E3161A

3) BCG-E3218A


5) IHDT56XC4

6) IHDT56XB1

7) A3LSMG960U

8) A3LSMJ337A

Report Number:






   3.1 System Verification . . . 4

      3.1.1 Tissue Simulating Liquids Dielectric Parameters Verification . . . 4

      3.1.2 Dipole Verification . . . 4

   3.2 Devices Under Test (DUT) . . . 4

   3.3 SAR Test Setup . . . 6

4. TEST RESULTS . . . 8

5. CONCLUSION . . . 8


On August 21, 2019, the Chicago Tribune published an article entitled “We tested popular cellphones for radio frequency radiation. Now the FCC is investigating.” The Chicago Tribune article reported that its testing revealed that several popular cell phones produced radio frequency (RF) radiation levels in excess of the FCC’s specific absorption rate (SAR) limits for RF exposure. The Chicago Tribune’s tests, conducted by RF Exposure Lab, LLC located in San Marcos, California, included devices manufactured by Apple Inc., BLU Products, Inc., Motorola Mobility LLC, and Samsung Electronics Co Ltd.

The FCC takes claims of non-compliance with its regulations seriously and commenced its own testing program of the implicated handsets to determine if those handsets comply with the FCC rules as asserted by the manufacturers or if they are indeed operating over the RF exposure limits as claimed by the Chicago Tribune.

S4WT Note: Seriously? How Seriously? Any more seriously than the FCC policing of any violations of pulsed, data-modulated, Radio-frequency Electromagnetic Microwave Radiation (RF-EMR) exposures from Wireless Telecommunications Facilities (WTFs) infrastructure antennas? We will research and report back the dates of any previous such SAR test conducted by the FCC, the regularity of such tests and the record of the FCC’s policing of WTF RF-EMR exposures. Our sense is that the record will show that the FCC is just "spinning" another story here and they have not taken these RF-EMR exposure issues seriously at all. We have placed this data in the public record at the FCC in September, 2018 and October 2018, spoke directly to Julius Knapp, as well as to FCC Commissioners Carr and Rosenworcel at the conclusion of the October 2018 FCC Open Hearing (Chairman Pai and Commissioner O’Reilly literally ran away from me).

The FCC Laboratory, pursuant to the rules ((47 CFR § 2.945)[xxx]), requested a device sample for testing from the manufacturers and grantees of those devices. The FCC Laboratory also requested grantees to provide any necessary test software, RF cables, and other accessories required for testing the devices. All grantees provided the requested materials. Additionally, the FCC Laboratory purchased samples of the Apple iPhone XS, Samsung Galaxy S9, Motorola Moto G6 Play, and BLU Vivo 5 Mini from the open market for additional testing. FCC testing commenced on August 30, 2019 and concluded on September 23, 2019. This report summarizes those results, which show that the handsets in question do comply with applicable FCC RF exposure limits.

S4WT Note: Reporting compliance is not surprising, but the words of Andrew A. Marino, PhD sum up the irrelevance of SAR quite succicntly:

Dr. Andrew A. Marino on the Hazards of EMFs and RF Microwave Radiation

Q: Are SAR measurements useful in your research?

Dr. Marino Answer:

"In connection with understanding mobile phone fields, none whatsoever. I think they’re meaningless with regard to that application.""

Q: Why are SAR measurements meaningless?

Dr. Marino Answer:

"Several reasons. First you need to understand where SAR came from. I was there when SAR was invented. Richard Phillips, Don Justesen, Saul Michaelson, Herman Schwann, these were men who created SAR, whose mind gave rise to it.

And the reason they did was because they were interested in developing microwave ovens and in understanding how to cook meat. And it’s useful for understanding how to cook meat. But it has no application whatsoever, that I have ever seen suggested or advanced, for understanding mobile phones.

SAR works for dead muscle. It has just no applicability in my opinion for live brain."

Q: Why are SAR measurements not applicable to the live brain?

Dr. Marino Answer:

"Because the health hazards associated with mobile phone fields have nothing to do with heat. So it makes no sense to say, “I have a really great way of measuring heat” when the measurement of heat is irrelevant to understanding health hazards. Any measurement that you make that has no connection with what you’re interested in is just a waste of time."

SAR can produce a lot of data and when the calculations of SAR are done they can produce beautiful pictures but the pictures are arbitrary and the measurements are meaningless. It’s quite clear that that’s the case.

The Commission’s RF exposure limits for the subject devices are based on SAR, which is a measure of the rate at which energy is absorbed by the human body when exposed to an RF electromagnetic field.

S4WT Note: Not exactly . . . xxx . . . check back for this note. It will be a good one.

The FCC rules, 47 CFR §1.1310, specify limits based on frequency of operation and expected exposure conditions. For the type of exposure condition (i.e., general population/uncontrolled environment) under investigation, the FCC rules limit the maximum SAR level to 1.6 watts per kilogram (W/kg) or less averaged over the volume containing a mass of 1 gram (1-g) of tissue that is absorbing the most signal.

S4WT Note: We should all know from where this back-of-the envelope number originated. The following should appall us all.

The FCC Maximum Permissible Exposure Guideline for pulsed, data-modulated, Radio-frequency Electromagnetic Microwave Radiation (RF-EMR) exposures is, unbelievably, based on only the RATE of exposure, NOT the TOTAL DOSE of poison delivered over time. This has been a scam since day one.

The 1986 NCRP Review, used to justify this nonsense, defined both Specific Absorption (the total DOSE of radiation in Joules) and Specific Absorption Rate (the RATE of radiation exposure in Watts).

For the FCC MPE RF-EMR exposure guideline, the NCRP picked the latter because “it was easier to measure.” . . . right . . . (head slap!).

Power Density and SAR Thresholds for Behavioral Disruption

This, unbelievably, is the basis for our National RF-EMR Exposure Guidelines

Species &
225 MHz
1,300 MHz
2,450 MHz
5,800 MHz
NR – PFD n/a 100,000,000 µW/m² 280,000,000 µW/m² 200,000,000 µW/m²
NR – SAR n/a 2.5 W/kg 5.0 W/kg 4.9 W/kg
SM – PFD n/a n/a 450,000,000 µW/m² 400,000,000 µW/m²
SM – SAR n/a n/a 4.5 W/kg 7.2 W/kg
RM – PFD 80,000,000 µW/m² 570,000,000 µW/m² 670,000,000 µW/m² 1,400,000,000 µW/m²
RM SAR 3.2 W/kg 4.5 W/kg 4.7 W/kg 8.4 W/kg
  • CW = Continuous Wave | PFD = Power Flux Density | SAR = Specific Absorption Rate
  • NR = Norwegian Rat | SM = Squirrel Monkey | RM = Rhesus Monkey
What was the “Behavioral Disruption?”
  • Rats and Monkeys were irradiated with RF-EMR exposures at higher and higher doses, until the lab animals became unresponsive: they could no longer seek and eat their food
  • After the animals were this significantly maimed, the scientists then stuck a thermometer up their butts and measured the animals’ core body temperature.

What else is not to like about the FCC RF-EMR exposure guideline?

  • Biologically-based peak RF-EMR exposure guidelines say exposures from 0.1 to 10 µW/m² are a slight hazard.
  • Peak 4G RF-EMR exposures are from 100 to 1,000 times higher than average RF-EMR exposures
  • Peak 5G Millimeter wave RF-EMR exposures are from 1,000 to 20,000 times higher than average RF-EMR exposures
  • The FCC RF-EMR exposure guideline is based only the rate of electromagnetic power flowing through the air, NOT the total electromagnetic power delivered over time
  • As detailed in this 1986 NCRP scientific review, the FCC RF-EMR guideline, inexplicably chose Specific Absorption Rate (SAR) over the vastly more relevant Specific Absorption (SA).
  • RF-EMR exposures of 1% of 10,000,000 µW/m² = 100,000 µW/m² — a level that does not imply safety because it is still 10,000 times higher than a slight hazard, per biologically-based RF-EMR guidelines

SAR testing uses standardized models of the human head and body that are filled with liquids that simulate the RF absorption characteristics of different human tissues.

S4WT Note: And . . . that is important for what reasons? Does this non-living water/salt/sugar solution represent the RF-EMR effects on living tissue? Uh . . . NO.

In order to determine compliance with the limit, each cell phone is tested while operating at its highest power level in all the frequency bands in which it operates, and in various specific positions against the head and body models, to simulate the way different users’ typically hold a cell phone, including to each side of the head.

S4WT Note: Hold on . . . are the test phones actually sending and receiving data during the test? What data? Are the testers downloading an HD Youtube video? What exactly are the configuration and activities that define "operating at its highest power level"?

To test cell phones for SAR compliance, the cell phone is precisely placed in various common positions next to the head and body models, and a robotically-positioned probe takes a series of measurements of the electric field (proportional to SAR) at specific pinpoint locations in a very precise, grid-like pattern within the head and torso models.

S4WT Note: Hold on . . . apparently the cell phones are NOT placed directly next to the liquid-filled, plastic head or directly next to the liquid-filled plastic body. Table 2, below reports that all phones were measured while being placed between 5 and 15 millimeters from the plastic "head" or "body" x— which does not represent how the vast majority of people use the phones and carry their phones in their pockets — People generally place the phone directly against the ear or body. Gee, is there any consideration of biological interactions from the pulsed, data-modulated, Radio-frequency Electromagnetic Microwave Radiation (RF-EMR) that is penetrating users’ bodies and interrupting exquisitively sensitive biological operations that occur at 50 millie electron Volts which is 0.000000000000000000008 Watts? The order of magnitude difference between biological operations (50 m-eV) and what is compliant (1.6 W/kg.) is 1022. Any one screaming at this point? . . . You should be.

All data for each cell phone placement is submitted as a part of the equipment approval test report for final authorization. The highest SAR values for each frequency band are used in the final authorization to demonstrate compliance with the FCC’s RF exposure limits.

S4WT Note: Again . . . what does compliance with an obviously gamed FCC RF-EMR exposure guideline mean? Anything at all? What did Marino say?

"SAR can produce a lot of data and when the calculations of SAR are done they can produce beautiful pictures but the pictures are arbitrary and the measurements are meaningless. It’s quite clear that that’s the case"

Yeah . . . we should all be with Marino on this. Please pay attention. Ignoring this information could injure or kill you or your loved ones.

Modern cell phones have a very large number of sensors, transmitters and antennas which need to be properly configured to ensure that the tests are conducted in the worst-case permissible operation. Testing each cell phone under its worst-case configuration requires detailed understanding of its design and antenna arrangements; most of this information is non-public and proprietary.

S4WT Note: So . . . what exactly were the configuration settings used? Without knowing that, the data collected in this test produces tables that "arbitrary and the measurements are meaningless". Read the excuse, above that has been offered as justication to hide this critically important information This "non-public and proprietary" excuse is not acceptable for firms that are being allowed to transmit RF-EMR into our homes from the public rights-of-way: these Close Proximity Microwave Radiation Antennas (CPMRA) Wireless Telecommunications Facilities (WTFs) transmit RF-EMR and conducted emissions poison 24/7 in order to create an unconstitutional surveillance and crowd control system — from the Utility/Light poles as close as six feet (in San Francisco) from bedroom windows. This has to stop.

This investigation focused on the operational modes evaluated in the Chicago Tribune report.


RF exposure testing for the devices under test (DUT) was performed according to the following rules, standards, and policies and procedures.

  • Link to 47 CFR § 1.1307
  • Link to 47 CFR § 1.1310
  • Link to 47 CFR § 2.1093
  • Link to ANSI/IEEE Std C95.1-1992
  • Link to IEEE Std 1528-2013
  • Link to FCC KDB Publication 447498 D01 General RF Exposure Guidance v06
  • Link to FCC KDB Publication 865664 D01 SAR Measurement 100 MHz to 6 GHz v01r04
  • Link to FCC KDB Publication 648474 D04 Handset SAR V01r03
  • Link to FCC KDB Publication 941225 D01 3G SAR Procedures v03r01
  • Link to FCC KDB Publication 941225 D06 Hotspot Mode v02r01


3.1 System Verification

An important step in performing SAR measurements is verification to ensure the measurement system will accurately and precisely measure SAR. This step consists of two parts, the Tissue Simulating Liquids Dielectric Parameters Verification and the Dipole Verification. Each of these parts has measurable quantities that must be within a specific tolerance in order to verify the system. General information about the Tissue Simulating Liquid Dielectric Parameter Verification and the Dipole Verification is contained in Sections 3.1.1 and 3.1.2, respectively. FCC engineers verified that the SAR measurement system was within tolerance to assure that subsequent testing would provide valid results.

S4WT Note: Ooooh . . . this sounds real scientific doesn’t it?The problem is that this test is based on a false premise, as explained well here. Yet, the FCC still pretends that SAR is relevant. It is not. It is a national disgrace and a prime example of FUBAR at the FCC and of old, tired, irreseponsible READY-FIRE-AIM! tactics of the Trump FCC that is chaired by Ajit Pai, a former Verizon attorney.

3.1.1 Tissue Simulating Liquids Dielectric Parameters Verification

A key component of the SAR measurement system is the Tissue Simulating Liquid (TSL). This liquid is composed of varying chemicals including water and/or sucrose, bactericide, diethyl glycol butyl ether (DGBE), among others. These chemicals are combined in different proportions to create TSLs having conductivity and permittivity that mimic either brain or body tissue at a given frequency.

S4WT Note: Yet, all these words from the FCC do not tell you that this special liquid cannot mimic a living system. Full stop. We all need to wake up and no longer tolerate that the emperor has no clothes.

It is important to confirm that these parameters are within a specific range close to the target parameters as variation in these parameters can significantly affect SAR results. A TSL verification was performed before SAR testing on each sample. General reference information, including sample TSL compositions, can be found in FCC KDB Publication 865664 D01.

3.1.2 Dipole Verification

The second step in the system verification is the dipole verification. A calibrated reference dipole is used to verify that the system accurately and precisely measures SAR. FCC KDB Publication 865664 D01 specifies that the system should measure a SAR result within ±10% of the expected value. Equipment calibrated by a certified calibration laboratory was utilized in performing the dipole verification as well as the subsequent SAR testing.

3.2 Devices Under Test (DUT)

Table 1 identifies and summarizes the manufacturer-provided as well as the FCC’s purchased devices.

Table 1: Test Sample Serial Numbers
FCC ID Manufacturer Description Serial Number Sample Type
BCG-E3091A Apple iPhone 7 Portable Handset C6K6HD69HG7N Provided by Manufacturer
BCG-E3161A Apple iPhone X Portable Handset C39VF007JH2Q Provided by Manufacturer
BCG-E3218A Apple iPhone XS Portable Handset GONZ50M7KPFR Purchased by FCC
A3LSMG960U Samsung Galaxy S9 Portable Handset R38K609SMYL Provided by Manufacturer
A3LSMG960U Samsung Galaxy S9 Portable Handset R3M706TT9A Purchased by FCC
A3LSMJ337A Samsung Galaxy J3 Portable Handset RF8KA1J3X6E Provided by Manufacturer
IHDT56XC4 Motorola Moto e5 play Portable Handset 359524090350295 Provided by Manufacturer
IHDT56XB1 Motorola Moto g6 Play Portable Handset 351864090034178 Provided by Manufacturer
IHDT56XB1 Motorola Moto g6 Play Portable Handset 3518643090300620 Purchased by FCC
YHLBLUVIVO5MN BLU Vivo 5 Mini Portable Handset 1080021018057240 Provided by Manufacturer
YHLBLUVIVO5MN BLU Vivo 5 Mini Portable Handset 1080021018069900 Purchased by FCC

Figure 1 is a generic diagram of a DUT, showing how the edges and faces of a DUT are designated for testing purposes. This labeling convention is identical across each testing laboratory: the respective accredited testing laboratories used for the original device certifications, RF Exposure Lab LLC (Chicago Tribune’s contractor), and the FCC laboratory. Identifying each cell phone surface in a consistent way is important because testing is required for each surface to determine where the maximum SAR value occurs and labeling of edges and faces can be ambiguous during device operation due to screen rotation capabilities (portrait, landscape, etc.). Figure 1 depicts both the front and back views of the device, with the screen as reference.

3.3 SAR Test Setup

The test configuration corresponding to the maximum reported SAR value varied for each cell phone model, as shown in the original certification filing’s RF exposure compliance report for each device. Each cell phone model was tested for the specific bands of operations investigated by the Chicago Tribune’s test laboratory under the same configuration identified in the manufacturer’s RF exposure compliance report submitted at the time of its application for equipment authorization.

S4WT Note: Uh . . . which bands, were tested? Shouldn’t the FCC share this with the public?

Using a Rohde & Schwarz CMU 200 Universal Radio Communication Tester, an over-the-air call was established with the DUT using this configuration. Figure 2 and Figure 3 depict an example of the Connection Control Screen and the Power Slot Graph Screen of the CMU 200, indicating that a successful connection was established.

S4WT Note: A call . . . only a call! Hmmm, downloading an HD Youtube video or a Netflix episode would result in much higher RF-EMR exposures!

Each DUT was positioned under the flat phantom of the FCC Laboratory’s DASY 6 SAR measurement system, which had been verified immediately preceding the SAR test (as described in Section 3.1). The DUT orientations and test separation distances used for the FCC’s SAR testing were the same as in each device’s original certification filing and were also used by RF Exposure Lab, LLC for its testing. The 1-g average SAR values were measured according to the procedures established in applicable FCC KDB Guidance Publications. This process was followed for both the grantee-provided DUTs and the FCC-purchased DUTs.


Table 2 contains the SAR results for each device, including from the device’s original certification SAR report, the RF Exposure Lab, LLC tests, and the FCC Laboratory tests. The SAR test configurations correspond to the configuration having the highest reported SAR in each device’s respective original certification SAR reports. For comparison purposes in this report, all SAR results listed are the actual measured values; FCC procedures allow devices to be tested within their output power tune-up tolerance range, then with SAR results scaled to the maximum rated output power for compliance demonstration purposes. The maximum measured SAR must be below 1.6 watts per kilogram (W/kg) averaged over the volume containing a mass of 1 gram (1-g) of tissue for the device to be compliant with the FCC rules. 

S4WT Note: OK, will you please explain exactly what the following means:

  • "output power tune-up tolerance range" ?
  • "scaled to the maximum rated output power for compliance demonstration purposes" ?

Table 2: SAR Test Results
FCC ID Manufacturer Description Wireless Tech Tested Test Distance (mm) Original SAR Report Measured SAR Value (W/kg) Chicago Tribune Measured SAR Value (W/kg) FCC Lab Maximum Measured SAR Value (W/kg)
BCG-E3091A Apple iPhone 7 Portable Handset WCDMA 5 1.140 3.560 0.946
BCG-E3161A Apple iPhone X Portable Handset WCDMA 5 1.090 2.191 0.799
BCG-E3218A Apple iPhone XS Portable Handset GPRS 5 0.047 N/A1 01.350
A3LSMG960U Samsung Galaxy S9 Portable Handset CDMA 15 00.795 00.625 00.538
A3LSMJ337A Samsung Galaxy J3 Portable Handset WCDMA 10 1.040 1.380 1.230
IHDT56XC4 Motorola Moto e5 Play Portable Handset WCDMA 5 1.120 4.700 1.020
IHDTF6XB1 Motorola Moto g6 Play Portable Handset WCDMA 5 0.944 0.247 1.250
YHLBLUVIVO5MN BLU Vivo 5 Mini Portable Handset GPRS 10 1.246 0.295 0.668

1 The Chicago Tribune SAR results are for iPhone X with FCC ID BCG-E3175A; the FCC Lab SAR results are for iPhone X with FCC ID BCG-E3161A since the phone with the FCC ID BCG-E3175A was not available.

2 This cell phone was purchased by the FCC Lab and was not included in the Chicago Tribune report.


All sample cell phones tested by the FCC Laboratory, both grantee-provided and FCC-purchased samples, produced maximum 1-g average SAR values less than the 1.6 W/kg limit specified in the FCC rules.

S4WT Comments: So what? It looks like the rules are set up to allow the FCC to play a similar role to that played by the three "captured" bond ratings agencies (Moody’s, Standar and Poor’s and Fitch) in the mortgage-backed securities debacle, circa 2008

Therefore, all tested sample devices comply with the FCC RF radiation exposure general population/uncontrolled limits for peak spatial-average SAR of 1.6 W/kg, averaged over any 1 gram of tissue as specified in 47 CFR § 2.1093(d)(2), and these tests did not produce evidence of violations of any FCC rules regarding maximum RF exposure levels.

S4WT Comments: So what? compliance to this obviouosly contrived test, which does not mimic how people actually use their phones in 2019, is Vintage "Captured Agency" FCC behavior. The Federal District Courts of Appeals judges are exasperated with the Trump FCC and so is the public. These three FCC Commissioners, the ones that voted through the 30+ interlocking FCC Orders that are now unraveling in the Courts should be severely reprimanded and removed from their positions for not adequately acting in the public interest — time and time again.