Regulatory Gaps in U.S. Wireless Radiation Policy: Public Health Implications and Recommendations for Reform

At the American Public Health Association Annual Meeting, Theodora Scarato presented at a roundtable discussion on cell towers and critical gaps in U.S. regulation of wireless radiation, highlighting regulatory deficiencies and gaps in oversight and protection.

She shared details of the landmark lawsuit against the FCC. In 2021, the federal court issued a mandate that the FCC show proper examination of evidence on its record related to non-cancer health effects (such as impacts to reproduction, brain development, and the immune system), long-term exposure, children’s vulnerability, and environmental impacts. The court also mandated the FCC explain how its compliance test procedures were adequate. In short, the FCC was ordered to show how its 1996 wireless radiation safety limits were protective in light of recent technology and over two decades of published research studies since the limits were set. The FCC has not responded.

Many people assume that federal wireless human exposure limits are regularly reviewed by independent scientists and federal health agencies to ensure protection for the public. The Court’s ruling confirmed that this assumption is incorrect, as no federal agency has shown review of the totality of current research.  Therefore, FCC compliance cannot be equated with safety—particularly for children, long-term exposures, and the environment- all issues the FCC ignored. 

American Public Health Association  

Title: Regulatory Gaps in U.S. Wireless Radiation Policy: Public Health Implications and Recommendations for Reform

Session: Law Section Roundtable
Date: Tuesday, November 4, 2025

Below are selected issues Scarato shared.

Summary of Scarato’s Presentation 

Wireless technologies such as cell phones, laptops and “smart” things are ubiquitous in every sector of our modern life from home to school to work. Yet the regulatory framework that governs the wireless radiofrequency radiation (RFR) exposures from these devices has not evolved with their rapid expansion. 

Common school and household sources include Wi-Fi routers, tablets, laptops, cell phones, cordless phones, smart boards, Bluetooth devices, baby monitors, wireless printers, and microwave ovens.

The Federal Communications Commission (FCC) is the lead U.S. agency for RFR exposure regulation, yet it relies on human exposure limits established in 1996, designed to protect only against heating effects from short-term exposure rather than biological impacts from long-term, low-level exposure.  No U.S. public health or environmental federal agency currently maintains an active program to review the expanding body of scientific research investigating health and environmental impacts. Significant policy gaps related to oversight and transparency paired with heavy industry involvement leave the public, workers, and the environment without adequate protection. 

Key Deficiencies of the US Regulatory Framework for Wireless Radiation

  • Outdated 1996 human exposure limits that do not protect for effects of long term exposure. 
  • Minimal federal health and environmental agency research on the health effects of wireless radiation.
  • No safeguards for children’s vulnerability.  
  • No premarket safety testing before deployment of new technologies.
  • Flawed compliance test procedures.
  • No oversight program to ensure cell phones and cell tower emissions are compliant. No required yearly checks or audits for cell towers.
  • No national program to measure and monitor RFR exposures in communities.
  • No national, publicly accessible database of all cell tower and antenna sites.
  • No robust occupational health program for wireless and non-ionizing radiation protection at work
  • No post-market surveillance of health or environmental impacts.
  • No reporting mechanism for medical professionals to report impacts.
  • No protections for wildlife. 

The U.S. Permits High Wireless Exposures Compared to Other Countries

The U.S. is among the countries that allow for the highest levels of cell tower radiofrequency (RF) radiation in the environment. The graph below shows the selected countries regulations regarding public exposure limits for 1800 W/m2 equivalent plane wave density RF radiation, applicable to schools and/or homes. Many countries have limits that apply to places of “sensitive use” such as apartment buildings, schools, hospitals, permanent workplaces, and children’s playgrounds. The U.S. has no specific safeguards for children or schools. In addition, in contrast to the U.S., countries have enacted various policy measures to provide oversight, transparency, and mitigate risk

Minimal Federal Agency Review of Mounting Science on Cell Tower and Wireless Radiation Health Risk

The FCC has no scientists or public health experts on staff, reportedly relying on other federal agencies for expertise in these areas stating:

“Since the Commission is not a health and safety agency, we defer to other organizations and agencies with respect to interpreting the biological research necessary to determine what levels are safe.”

However, at this time no U.S. federal civilian agency with expertise in health or environment is actively evaluating the effects of wireless exposure. 

The Environmental Protection Agency (EPA), once tasked with establishing RFR safety standards, lost its funding for non-ionizing radiation work in the mid-1990s. When asked in 2020 about the EPAs activities, Lee Ann B. Veal, then Director of the EPA’s Radiation Protection Division, stated,  “EPA does not have a funded mandate for radiofrequency matters, nor do we have a dedicated subject matter expert in radiofrequency exposure. 

The National Institute for Occupational Safety and Health (NIOSH) and the Occupational Safety and Health Administration (OSHA) no longer maintain research programs on electromagnetic field exposure. On July 1, 2015, William Perry, the Director of OSHA’s Directorate of Standards and Guidance, when asked about the agencies related to the FCCs regulations, wrote that “RF emissions are not on OSHA’s active regulatory agenda, so we have not conducted a comprehensive literature review or risk assessment on RF hazards.” 

The Food and Drug Administration (FDA) does not conduct original research, and its one well criticised literature review from 2018 was narrow in scope, focused solely on cancer and cell phones, notably dismissing the cancer findings of the $ 30M animal study it requested be conducted.

A 2014 U.S. Department of the Interior letter warned that FCC standards are “based on thermal heating, a criterion now nearly 30 years out of date and inapplicable today,” and highlighting the need for U.S. research on radiation impacts to migratory birds and other species. Yet they have performed no reviews. 

This lack of interagency engagement has created a vacuum where no entity is responsible for integrating the growing scientific data into public policy. The absence of an active federal review structure is one of the most fundamental gaps in U.S. wireless governance.

No Consideration for Wildlife or Ecosystem Impacts

U.S. wireless exposure regulations were designed solely for human protection and do not address effects on wildlife or ecosystems. A major review of over 1,2000 studies documented a broad range of impacts to birds, bats, insects, and mammals at exposure levels far below human safety limits. Pollinators, such as bees, are uniquely sensitive due to their smaller size which results in significantly higher exposures. 

Growing Science on Health Effects

A 2023 systematic review and metanalysis of studies on the biological effects of non-ionizing EMFs to insects of non-ionizing electromagnetic fields was published in Reviews on Environmental Health found the “vast majority of studies found effects, generally harmful ones” with adverse effects such as impacts to reproduction and immune health occurring at legally allowed exposure levels. 

“Based on an assessment of the overall study situation on insects, we must warn against a careless deployment of further mobile telephony infrastructure, as harmful effects on insect populations would be likely, especially if interactions with other noxious agents are taken into account (including high-voltage power lines and artificial lighting). This might lead to further declines of already dwindling populations of pollinators, and would thereby entail costs for humanity.”  

Further, compliance tests for cell towers focus only on ground-level human exposure. They do not evaluate radiation levels in the airspace where birds fly tree limbs and bird nests exist. The DC Circuit Court concluded in 2021 that the FCC had “completely failed” to address substantive evidence of environmental harm. Flora and fauna are entirely unprotected under its current guidelines.

 A large and growing body of peer-reviewed research now reports biological effects at exposure levels far below FCC limits, including cancer , DNA and genetic damage , endocrine disruption , and impacts to the reproductive system and brain development    Chronic exposure has also been linked to cellular stress responses and increased oxidative stress which can contribute to chronic disease.  Long-term animal studies from the U.S. National Toxicology Program  and the Ramazzini Institute in Italy have reported increased rates of brain and heart tumors at exposure levels comparable to cell phones and cell towers. A review on people living near cell towers found the majority of studies found effects from cancer, to radiation sickness symptoms to biochemical changes.

A review of low intensity studies found that biological effects could occur at a median specific absorption rate (SAR) of 0.0165 W/kg,  much lower than the FCC’s limits of 1.6 W/kg (cell phone and wireless device local tissue limit) and 0.08 W/kg (averaged whole body limit). Further, FCC limits are often stated to have a 50 times safety factor, which the current scientific evidence does not support. The review, published in the peer-reviewed journal Electromagnetic Biology and Medicine, states:

“RFR effects have been observed at low intensities (< 0.4 W/kg) – a list of which is included in Supplement 1 – far below the guidelines. This points to both the nonlinearity of how living systems couple with nonionizing radiation as well as the inadequacy of acute thresholds. The studies encompass many different biological effects to myriad systems, including: apoptosis induction, adrenal gland activity, blood–brain barrier permeability, brain transmitter levels, calcium concentration in heart muscle, calcium efflux, calcium movement in cells, cell growth, cognitive functions, cellular damage in liver, decreased cell proliferation, embryonic development, endocrine changes, enolase activity, genetic effects, hippocampal neuronal damage, immunological functions, kidney development, memory functions, latency of muscular contraction, membrane chemistry, nerve cell damage, metabolic changes, neural electrical activity, oxidative stress, plant growth, prion level, protein changes, renal injury, serum testosterone concentration, heat-shock protein induction, testis morphology, testosterone synthesis, thymidine incorporation, and ultrastructural alteration in cell cytoplasm. In fact, there are not many physiological functions in humans, animals, or plants that are not affected by low-level RFR.”

Regulatory Capture and Industry Influence

Over the past several decades, the FCC is deeply  intertwined with the telecommunications industry. Many former FCC commissioners and legal counsels have moved directly into wireless industry leadership roles, and vice versa. As detailed in the Harvard Press book “Captured Agency: How the Federal Communications Commission is Dominated by the Industries it Presumably Regulates,” written by investigative journalist Norm Alster, this revolving door is evidence of regulatory capture.65 

The investigation “Captured Agency” describes:

  • A revolving door between regulators and the wireless industry
  • Heavy lobbying and funding through “nonprofit” fronts
  • Industry influence over Congress and public relations
  • Reliance on discredited, industry-funded scientists
  • Misleading claims of “scientific consensus”
  • Cuts to independent health research
  • Dismissal of credible experts raising concerns
  • Push for minimal regulation and refusal to review health evidence
  • Aggressive intimidation and lawsuits against researchers

Now, a decade since the investigation was written, the situation continues on. The current FCC Chair, Brendan Carr, previously worked as an attorney representing the wireless industry, including in a major case in which the City of San Francisco passed its “Cell Phone Right-to-Know” ordinance in 2009. The industry had sued, claiming the law violated companies’ free speech rights. The ordinance, passed unanimously,  was ultimately not implemented. Today, as FCC Chair, Brendan Carr is pushing forward rules to fastrack cell towers across the nation. 

Published analyses also indicate that the source of funding can significantly shape the reported outcomes when it comes to non-ionizing EMF bioeffects research. Studies supported by industry are consistently less likely to identify adverse health effects, while independently funded or government-sponsored investigations more often report biological impacts.  Comprehensive reviews have found that higher-quality, independently funded research more frequently demonstrates statistically significant associations between long-term mobile phone use and brain tumor risk, in contrast to industry-funded studies that generally find no such links.  The same patterns have been found in studies in powerlines and magnetic field exposure. Elevated risks of childhood leukemia from powerline EMFs are less often found in electric industry-sponsored work.  Analyses of millimeter-wave radiation studies funded by industry also report less biological effects compared to those supported by government or academic institutions. 

Image: Figure 2. The relative proportion of “Effects” and “No Effects” outcomes from studies according to the funding source from  McCredden, J. E., Weller, S., & Leach, V. (2023). The assumption of safety is being used to justify the rollout of 5G technologies. Frontiers in public health, 11, 1058454. 

Summary of Key Recommendations 

  1. Reinstate a comprehensive national EMF bioeffects research program across federal agencies, with ongoing scientific review and interagency coordination.
  2. Update FCC human exposure limits to protect against non-heating and long-term exposure, using current science and safety margins protective of children and vulnerable populations.
  3. Establish national EMF monitoring and surveillance programs, prioritizing schools, homes, and environmentally sensitive areas, with publicly accessible data.
  4. Require rigorous premarket safety testing for all new wireless technologies, including human, wildlife, and cumulative exposure impacts.
  5. Modernize compliance testing and enforcement to reflect real-world use, including body contact, multiple devices, and routine audits of networks and cell towers.
  6. Create a national registry of wireless infrastructure, including cell towers, antennas, and 4G/5G installations, with transparent permitting and RF radiation compliance data.
  7. Implement clear consumer labeling and public health guidance on wireless radiation exposure and practical steps to reduce exposure.
  8. Prioritize exposure reduction in homes and schools, including wired alternatives, limits on cell towers and infrastructure near schools and daycares, and mitigation measures for children.
  9. Establish a robust occupational RF/EMF safety program with exposure monitoring, medical surveillance, training, and worker protections.
  10. Develop science-based protections for wildlife and ecosystems, including updated NEPA reviews, low-EMF zones, and monitoring in ecological areas.

The current U.S. approach to regulating radiofrequency radiation is outdated and insufficient. The FCC’s 1996 standards were never designed to address the realities of continuous, multifrequency, low-intensity exposure that now defines daily life. With no active federal review of emerging science, no monitoring of environmental levels, and no post-market oversight, the United States lacks an adequate system for ensuring the safety of wireless technologies.

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