The Cisco 4410N WAP has been irradiating teachers and children in the classroom, pictured below, every minute of every school day — unnecessarily.. The RF/EMF microwave radiation levels in this classroom exceed federal safety guidelines many times, every day, based on total cumulative radiation exposure. This cumulative calculation method was confirmed by senior FCC and OSHA engineers. In August 2013, these engineers analyzed the radio frequency electromagnetic fields (RF/EMF) measurement in this classroom and agreed that the math driving the animation, below, is correct. See the totals below.
Please note, the calculated totals exclude radiation from any wireless devices in use in the classroom. Actual totals could be 25x-30x higher when students are using wirelessly-connected iPads, Chromebooks or laptops. Similar RF/EMF total cumulative exposure levels can be calculated for any classroom in the school district, using information provided by California Public Information Requests, accurate RF/EMF measurements and these FCC-and-OSHA-approved calculations.
I purchased GigaHerz Solutions meters and attended the one week training from the International Institute For Building-Biology & Ecology to make sure I knew everything I could about how to properly measure and mitigate RF/EMF microwave radiation. I devoured the information at antenna-theory.com and had multiple conversations with James Cassata, Executive Director of the NCRP, Edwin Mantiply of the FCC Office of Engineering and Technology, and Jeffery Lodwick of Federal OSHA as I shepherded an OSHA claim against my school district through the system in July/August 2013. I insisted on reaching agreement, in writing, on how one should calculate total cumulative RF/EMF microwave radiation exposure before OSHA compared this total to any existing standards. I got the agreement in writing:
Re: Cal OSHA Complaint Number 077971364 - Agreements from First Meeting August 16, 2013 Dear Mr. Kirkham and Dr. Lodwick, Thank you for meeting with me at the CA State OSHA offices at 455 Golden Gate Ave. in San Francisco this morning to discuss the conclusions from the calculations included in my 8/9/13 email to Dr. Jeffrey Lodwick, that I copied to both Chris Kirkham and Chris Grossgart. Please read this email all the way through. It is important and deserves your attention. I appreciate you both taking time out of your busy schedules this morning to engage in a fruitful and intellectually rigorous discussion. I came away convinced that you both want to 'get this right' by first accurately calculating RF/EMF exposure levels faced by public school teachers in a typical work day and then by comparing these accurately calculated RF/EMF exposure levels levels to our existing Federal and CA State OSHA guidelines and laws that are on the books today. We confirmed today our agreement on how to calculate the total amount of 'Work' (Power delivered over Time) that a public school teacher might face in an eight-hour work day. Participating in person: Chris Kirkham, MPH, CIH, CSP Senior Safety Engineer, Region 1 Cal/OSHA Enforcement San Francisco District Office 455 Golden Gate Ave., Suite 9516 San Francisco, CA 94102 w 415-557-0800 [Parent] [Address] [Tel] Participating by phone: Jeffrey Lodwick Federal OSHA Salt Lake Technical Center 8660 South Sandy Parkway Sandy Utah, 84070 w 801-233-4913 >>> Start of Agreements Made Today We agreed that using the following definitions: Definitions ----------- 1 Joule = 1 Ampere through 1 Ohm 1 Joule = 1 Watt-second 1 Watt = 1 Joule per second 1 µW = 1/1,000,000 Joule per second = 1/1,000,000 Watt-second per second OSHA Guidelines From Article 104. Non-ionizing Radiation (http://www.dir.ca.gov/title8/5085.html): "Employees shall not be exposed to RF energy from continuous wave or repetitively pulsed sources exceeding the following limits, as averaged over any possible six minute (0.1 hour) period:" * "Continuous exposure to a power density of 10 mW/cm2 (milliwatts per square centimeter)", which is equivalent to 100,000,000 µW/m2 (microwatts per square meter). * "Exposure to interrupted or modulated RF energy shall not exceed a power density of 1 mW hrs/cm2 (milliwatt-hours per square centimeter)", which is equivalent to 10,000,000 µW-hrs/m2 (microwatt-hours per square meter) . . . and using the following assumptions/measurements: Assumptions and Measurements ============================ RF/EMF from wireless devices and wireless access points is pulsed (interrupted or modulated). 16,000 µW/m2 = power density measurement of each pulse (from actual 4/15/13 measurement in PCSD Superintendent Steve Bolman's office) 0.002 sec. = duration of each pulse 100 Hz = frequency of pulses (100 per second) 360 seconds = # of seconds in a 6-minute period 36,000 pulses = # of pulses in a 6-minute period 3,600 seconds = # of seconds in 1-hour period 360,000 pulses = # of pulses in a 1-hour period 28,800 seconds = # of seconds in an 8-hour period 2,880,000 pulses = # of pulses in an 8-hour period . . . we can then calculate the total amount of 'Work' (Power delivered over Time) that a public school teacher might face over a nominal six-minute period, a nominal one-hour period and a nominal eight-hour period. We agreed that the following two equations are identical and, as such, reach the same result: ***************** From [Parent]: 32 µW-seconds/m2 x 36,000 = 1,152,000 µW-seconds/m2 for one device in one six-minute period From Lodwick: The total energy in 6 minutes would be (3200 µJ/s-m2)(360 s) = 1,152,000 µJ/m2 ***************** From today's agreement on the logic of the calculations above, we can then refine the results by using actual data (peak RF/EMF measurements per device in actual specific classroom usage scenarios) and actual manufacturer specs (from Cisco, Apple, Dell, HP, Lenovo, Samsung, HTC and others) that will establish the following key parameters: 1. The frequencies of the pulses (reported in Hz or pulses/second). 2. The duration of each pulse (reported in microseconds). 3. The peak power of each pulse (reported in microwatts/m2 at 12" from the device during actual specific classroom usage scenarios). . . . to calculate the total Work (Power over Time) released into a typical school classroom in a typical day. The math now is simple and can be performed by any fifth-grader. Assuming the worst-case scenario, simultaneously downloading a ten-minute 720p video from one WAP to 21 wirelessly connected-devices (one teacher device and 20 student devices), we then calculate the total RF/EMF contributed by 22 wirelessly-connected devices in the classroom: 1 WAP + 1 teacher device + 20 student devices = 22 wirelessly-connected devices in the classroom. The totals are as follows for one nominal six-minute period: 32 µW-seconds/m2 per pulse x 36,000 pulses = 1,152,000 µW-seconds/m2 for one device 1,152,000 µW-seconds/m2 for one device x 22 devices = 25,344,000 µW-seconds/m2 for all 22 devices The totals are as follows for one nominal one-hour period: 25,344,000 µW-seconds/m2 for all 22 devices x 10 six-minute periods in an hour = 253,440,000 µW-seconds/m2 The totals are as follows for one nominal eight-hour period: 253,440,000 µW-seconds/m2 for all 22 devices x 8 hours in a typical work day = 2,027,520,000 µW-seconds/m2 We agreed this morning that this accurate way of calculating the total amount of RF/EMF Work (power delivered over time) to which an employee in a school work environment is exposed is not dependent on any standard set by any health safety agency, including OSHA. We also recognized that these calculations make no attempt to compare the total amount of Work experienced by an employee in a school work environment from RF/EMF exposure to any standard set by any health safety agency, including OSHA. Mr. Lodwick has agreed to respond to the questions I raised in my 8/9/13 email to him and to determine if the totals calculated above represent a valid OSHA complaint. Based on his determination, I then understand the next steps that I can take in the OSHA complaint process. >>> End of Agreements Made on 8/16/13 Discussion ---------- I recognize that we face three real constraints in the OSHA complaint process:  The workloads that you both face in your current lean/understaffed environment prevent you from being able to fully review all of the supporting materials quoted in my original OSHA complaint. Near the end of our meeting, we encountered one such example: Dr. Lodwick quoted one sentence from page 421 of the following WHO Monograph: https://dl.dropboxusercontent.com/u/33504620/WHO-IARC-monograph-102.pdf World Health Organization's International Agency for Research on Cancer Monograph 102, Non-Ionizing Radiation, Part 2: Radio-frequency Electromagnetic Fields Released May, 2013 "There is limited evidence in humans for the carcinogenicity of radio frequency radiation. Positive associations have been observed between exposure to radio frequency radiation from wireless phones and glioma, and acoustic neuroma." . . . to support his position that the WHO classified RF/EMF *only from cell phones* as a class 2B Carcinogen. That is an incorrect understanding and represents Mr. Lodwick's limited review of the document. The truth is that the WHO classified RF/EMF from all sources (wi-fi, WAPs, wirelessly-connected laptops, tablets, Chromebooks, smart phones, baby monitors, wireless security systems, wireless gaming devices and others) based on the health effects scientists are seeing in cell phone users, as this use has been the one most studied. The 31 International scientists reviewed all of the relevant literature to conclude that the RF/EMF radiation from cell phone usage is virtually identical to the RF/EMF from these other wireless devices so they are using the data from cell phone studies to classify RF/EMF from all sources as a class 2B carcinogen. You can here it directly from the source, from Dr. John Samet, the chair of the committee: http://www.youtube.com/watch?v=s4E2i5XFX9M . . . which is a link that I sent you on 7/17/13 and again on 8/9/13. A more thorough review of the supporting materials quoted in my original 7/17/13 OSHA complaint would have prevented this error. How many other errors remain?  You are both working with many OSHA guidelines that have not been updated in many years and that, by your own admission, are not protective of the public, or reflective of current scientific understanding; in fact, today you were quoting guidelines from 1966, guidelines from thirty years prior to the broad-scale usage of wireless technologies in our business and school environments. We have learned a lot since 1966, including the 2,000+ studies that I quoted in my original OSHA complaint.  It is not your jobs to comment on or change the current OSHA guidelines and laws that are on the books; we all recognized if a change in the OSHA guideline is critical to protecting the health of public school employees, I would then have to work directly with standards-settings bodies to try to make the change. Of real importance right now is that the FCC, which is such a standards-settings body, is currently reviewing its RF/EMF guidelines and is inviting public comment from both the public and other federal agencies, such as OSHA. It's also important to recognize that we we agreed to today was not an accurate total, but an accurate way to calculate the total RF/EMF 'Work' that a teacher might face in any nominal time period. The accurate total would require further refinement in actual usage scenarios that take the following factors into account: [a] How long the wireless devices are actually powered on and connected to the WAPS. [b] The size of the data payloads the devices are both downloading and uploading (both the size of the data payload and the direction of the transmission, whether downloading or uploading, may lead to different RF/EMF measurements both at the wirelessly connected laptop/tablet/smartphone and at the Wireless Access Points (WAP). [c] What are the reflective, refractive and absorption properties of the surfaces in each classroom. A metal filing cabinet, for example, may either shield an employee from RF/EMF exposure or create RF/EMF 'hot-spots' in a classroom, depending on the geometry of the WAP and filing cabinet placement in the classroom. In short, accurately tracking the cumulative total levels of RF/EMF to which employees (and students) are exposed in the classroom, is very complicated and could not possibly be adequately addressed by any single health-agency guideline number. On-going, continuous monitoring would be the only way to accurately track these exposures, which would be an administrative burden. It would be much safer and less expensive to use only wired connectivity and devices in public school classrooms. We did, however, discuss one truth that is not part of the current current OSHA guidelines and laws that are on the books. The nominal six-minute period in the current OSHA guideline is exactly that, nominal. There is no magic to six minutes of exposure, it is just a convenient way to divide an hour into ten equal parts. If a teacher is exposed to RF/EMF that is just under the OSHA guideline at the end of this first nominal six-minute period, then we can't just zero out the first six minutes of exposure and start measuring all over again for another six minutes. We have to total all of the exposure over the full 12 minutes. Of course, 12 minutes of exposure is just as nominal, so the important measure is the total RF/EMF to which one is exposed over the effective time period -- the time period required to achieve the desired (or undesired) effect: i.e. the time it takes to cook a potato. We have that answer already in published, peer reviewed science that was part of the evidence in the WHO 2013 Monograph, quoted earlier. Research from Hardell and others has shown that long-term chronic exposure to the toxic pollutant of RF/EMF can lead to increased cancer rates in 10 years: a 500% increase for young people who have been exposed to RF/EMF for 30 minutes a day -- just 1,640 hours of exposure. Employees in public schools today are getting over 1,200 hours or RF/EMF exposure each year, or over 12,000 hours of exposure in ten years. Yes, I understand that this accepted scientific result does not fit neatly into the current OSHA nominal six-minute period, but, so what? What's our goal here? To protect the teachers (and, by association, the students) in the classroom from an effective dose of RF/EMF that leads to negative health effects. Is it possible to step out of the straight-jackets imposed on us by our jobs/bosses/political pressures and actually recognize what really matters and what we really know? Yes, it is possible. One can take steps to eliminate unnecessary RF/EMF in public schools and other public places to protect the health of employees and the general public, as I pointed out in my 8/9/13 email to Lodwick, Kirkham and Grosscart. Thank you, once again, for your time this morning. I will look forward to Dr. Lodwick's response to my 8/9/13 email. Regards, [Parent]
Re: Cal OSHA Complaint Number 077971364 - Still Need A Conference Call August 9, 2013 Dear Dr. Lodwick, This email is my detailed response to your document titled "2013-08-09 - [Parent] Response Rev 2.docx" that I received from you by email on 8/9/13 @ 3:22 pm EDT. In this document, you comment on analyses that I forwarded to you on 7/31/13 and 8/2/13. I also emailed you my current goals for the analyses on 8/9/13. >>>>> On 8/9/13 @ 3:22 am, Jeffrey Lodwick, Federal OSHA wrote to [Parent]: > [Parent], > > Attached is the response that you requested for the questions that you sent me via email on 8/2/2013. I have added the responses to the 8/2/2013 questions at the bottom of the response I sent you on 8/5/2013. > > Thanks, > > Jeff Lodwick > Dr Lodwick, it was great to see that we reached some agreement: [Parent]: 32 µW-seconds/m2 x 36,000 = 1,152,000 µW-seconds/m2 in one six-minute period for one device Lodwick : The total energy in 6 minutes would be (3200 uJ/s-m2)(360 s) = 1,152,000 uJ/m2 We also have to recognize that both [Parent] and Lodwick have made some errors along the way; errors that once identified and corrected should lead to consensus on how we calculate the total RF/EMF Work (power over time) applied to a person in any nominal period: 6 minutes, one hour or 8 hours. Once we agree on how to calculate, then, we can input actual data from manufacturer specs and actual metered RF/EMF readings in realistic usage scenarios in classrooms to arrive at an accurate answer. No one, including me, wants to sound a false alarm. But if the numbers are high enough to warrant it, then OSHA needs to take action. I am not so worried about the existing mistakes, as long as we are open to correcting them. I am, however, very concerned about any effort to base a validation or invalidation of an OSHA claim based on any analysis that includes errors. I expect you want to get this right, without any errors, as well. I would very much appreciate having a conference call about these analyses because I think it would save us all a lot of time. I am writing very complete emails to make sure that I am not misunderstood. In my original OSHA complaint, I included references to a large volume of supporting materials that I am fairly confident that you all have not had time to review. I recognize that my complaint is just one of many and that I am discussing a matter much closer to long-term chronic exposure to second-hand cigarette smoke than to the possibility of immediate death by electrocution. That may place my complaint lower on the urgency scale, but when you consider the number of public school employees (and the students) impacted in the US, mine is actually a very important complaint. The invisible RF/EMF is the second-hand cigarette smoke or our generation. We, as a society, have taken the important steps to remove the sources of second-hand cigarette smoke from our airplanes, restaurants, schools, public parks and other public places -- using OSHA employee-protection as the mechanism. We protected the health of restaurant and airline employees and protected the health of the general public at the same time. We are very much in the same situation right now with respect to RF/EMF. The health effects from second-hand cigarette smoke are due to long-term, chronic exposure to this toxic pollutant: it takes 15-20 years to develop cancer from cigarette smoke. Research from Hardell and others has shown that long-term chronic exposure to the toxic pollutant of RF/EMF can lead to increased cancer rates in just 7-10 years: a 500% increase for young people who have been exposed to RF/EMF for 30 minutes a day -- just 1,640 hours of exposure. Employees in public schools today are getting over 1,200 hours or RF/EMF exposure each year, or over 12,000 hours of exposure in ten years. We, as a society, also need to take the important steps to remove the unnecessary sources of RF/EMF from our public schools, public parks and other public places -- using OSHA employee-protection as the mechanism. We can protect the health of teachers and school employees and in doing so also protect the health of the general public at the same time. One issue with our analyses, that is being addressed, is that we have not yet received from Cisco, the manufacturer of the Wireless Access Points (WAPs) in question, the following specifications for the Cisco WAP4410N and Cisco/Meraki MR16 WAPs that pulse data to wirelessly connected laptops and tablets: 1. The frequencies of the pulses (reported in Hz or pulses/second). 2. The duration of each pulse (reported in microseconds). 3. The peak power of each pulse (reported in microwatts/m2 at 12" from the WAP). We have been using 'best guess' assumptions in our analyses to hone our understanding of the problem and the calculations required to determine the total RF/EMF to which one would be exposed in an 8-hour work day. It would be much better to use the specs from the manufacturers of the equipment and actual classroom metered RF/EMF readings of realistic usage scenarios -- something I have been asking my School District to do for months. There are experts in San Francisco with the meters and the training that could complete these measurements for around $1,000. The important thing is for all of us to agree on the correct way to measure and calculate the total RF/EMF to which one would be exposed in an 8-hour work day. I am open to being enlightened on any assumptions or math that is incorrect in the analyses that I forwarded to you. I hope Dr. Lodwick is equally open to correction. Let's see where we agree and where we don't agree. I will highlight any questions in the commentary below like this: From [Parent's] 7/31/13 analysis: ==================================== [A] Power x Time = Work --> Yes, Lodwick and [Parent] agree. [B] Microwave cooking lesson --> Yes, Lodwick and [Parent] agree. [C] Antennas in WAPs and antennas in wireless devices pulse power at regular intervals --> No, Lodwick and [Parent] do not agree; let's rely on the specs from the WAP manufacturer (Cisco) and the device manufacturers (Apple, Dell, HP, Lenovo, Samsung, HTC and others) [D] The power density of the RF/EMF concentrates around the antennas --> Yes, Lodwick and [Parent] agree. [E] (# of pulses/sec.) x (# secs. in 6.5 hrs.) x (power/pulse) = total power delivered over 6.5 hours --> No, Lodwick and [Parent] do not agree. I recognize my error and see that Lodwick's equation is correct: (Power) x (pulse length in seconds) x (# of pulses / 6.5 hours) = Work in 6.5 hours [F] Correct way to calculate the power of each pulse and then to sum the power of each of the pulses --> No, Lodwick and [Parent] do not agree. Lodwick only addressed this partially and makes a false statement: "transmission energy of a device (e.g. laptop) is not affected by amount of data transferred from the device." My measurements and manufacturer specs demonstrate otherwise. [Detail redacted] Regards, [Parent]
These agreed-to calculations are a wedge that can open the door to shed light on the fallacies of our country's current FCC RF/EMF microwave radiation exposure guideline. Newton's law of conservation energy of helps us: his law states that the total Energy of an isolated system cannot change — it is said to be conserved over time. Therefore, Energy may be transformed from one form to another, but it cannot be created or destroyed.
Energy is often a confusing term in this discussion, because our general notion of energy is not consistent with the stricter definition of Energy in physics. People usually think of Energy as something that is being consumed or used up, but according to Newton's Law: Energy is always conserved. Energy in one form is therefore converted into Energy in other forms; it is never used up or consumed.
Energy is an indispensable prerequisite for performing Work. Energy comes in multiple forms: kinetic, potential, thermal, chemical, electromagnetic, and nuclear. Energy is required to do the work and the Energy can only be converted and/or transferred, but never lost or generated anew. Work and Energy are inextricably connected.Let's avoid the term Energy and instead focus on Work, which is the total Power delivered over time.
One has to apply a sufficient amount of Power over time to do any Work:
The FCC maximum public exposure guideline for RF/EMF Microwave Radiation exposure cannot be relied upon because it is not protective, not reflective of current scientific understanding and based on three falsehoods:
This page lays out the argument in an easier to read format. For the more detail-oriented folks, here is the logic for the calculations, above:
Watts are derived units of power: One watt = rate of work done when one ampere (A) of current flows through an electrical potential difference of one volt (V). Joules are units of work: power delivered over time One joule = One watt * 1 second = One watt-second (this is how your utility calculates kilowatt-hours on your utility bill) One microwatt is one-millionth of a watt (a measurement of power at an instant of time) One microjoule is one-millionth of a watt-second (a measurement of power delivered over time)
1 Joule = 1 Watt-second 1 µJ = 1/1,000,000 Joule = 1/1,000,000 Watt-second 1 Watt = 1 Joule per second 1 µW = 1/1,000,000 Joule per second = 1/1,000,000 Watt-second per second
t = the total number of seconds a subject spends in front of a wireless antenna when the antenna is on and operating x = the number of pulses per second that the antenna transmits its beacon signals, per the manufacturer's specs y = far-field peak power density measurement 36" from the antenna(s) (y microwatts per square meter, measured with a GigaHertz Solutions directional antenna, using the meter's peak-hold function) z = duration of each pulse (in fractions of seconds), per manufacturer specs
To calculate R = Total cumulative RF/EMF microwave radiation work (power delivered over time) from the beacon signals from one wireless access point, use the following: Total number of pulses = t * x Power of each pulse = y * z R = (t * x) * (y * z) = Total number of pulses * Power of each pulse Next, assign real values to each variable: t = 21,600 seconds = 60 seconds/minute x 60 minutes/hour x 6 hours x = 100 pulses/second (from mfg. specs) y = 17,500 µW/m2 (from meter reading) z = 2/1000 seconds/pulse (from mfg. specs) Total number of pulses = t * x = 21,600 seconds * 100 pulses/second = 2,160,000 pulses Power of each pulse = y * z = 17,500 µW/m2 * 2/1000 seconds/pulse = 35 µW-seconds/(m2 * pulse) = 35 µJ/(m2 * pulse) R = 2,160,000 pulses * 35 µW-seconds/(m2 * pulse)= 75,600,000 µW-seconds/m2 = 75,600,000 µJ/m2
Once we know the inputs, we can calculate the total cumulative RF/EMF microwave radiation exposure for each wireless device (router, access point, tablet, chromebook and laptop). Importantly, these exposures are additive: the more wireless devices around us, the higher the exposure and the more data transmitted, the higher the exposure. That is why choosing to stream a video wirelessly is the most dangerous RF/EMF microwave radiation choice anyone can make.
In the end, we have Apples (total cumulative power over time) and Oranges (the FCC maximum public exposure guideline):
Apples = 75,600,000 µW-seconds/m2 = the total cumulative amount of RF/EMF power delivered over six hours Oranges = 10,000,000 µW/m2 = an instantaneous measurement of RF/EMF power; it says nothing about cumulative power
It is self-evident to each of us that total exposure over time is what really matters: 30 minutes of unprotected exposure to mid-day sun may give us a sun tan, but several hours of unprotected exposure to mid-day sun would most likely give us a sun burn. Same thing happens when we cook a potato in a microwave oven: 100% power x 5 minutes = one cooked potato and 50% power x ten minutes also = one cooked potato. It doesn't help to know just the instantaneous measurement of power density. That is meaningless. You need to know the total power delivered over time and if this amount of Work (power delivered over time) is sufficient to achieve the effect.
The fact that the FCC guideline has no concept of total power delivered over time is insane. Yes, it sounds as if the guideline deals with time (a nominal 30 minute period for public exposure and a nominal 6-minute period for occupational exposure), but that is merely a convention used to ease the measurement process. Press the FCC on this and they will admit that they view the FCC guideline as an amount of RF/EMF microwave radiation (10,000,000 µW/m2) that one can receive indefinitely, 24/7, forever for each wireless device in the room.
What if there are 24 wireless devices in the room totaling 240,000,000 µW/m2? The FCC guideline does not address this. The FCC RF/EMF microwave exposure maximum public exposure guideline cannot be relied upon to protect anyone from long-term health effects.
75,600,000 is 7.5 times higher than 10,000,000. That's the truth that opens the door to finally shine the light on the fallacies of the FCC maximum public exposure guideline for RF/EMF microwave radiation exposure.