RF Safe has never claimed that the science is “settled” in the sense of proving specific human disease causation from typical cell-phone use. We do not publish “cell phones cause X in humans” as a blanket statement.
What we do say is “settled” is narrower—and it is the point MBFC keeps blurring:
Thermal-only safety rules are not sufficient to protect biology, because there is now high-certainty evidence of non-thermal biological interaction in key experimental endpoints. That makes safety standards based on “no heating = no harm” logic inadequate as a comprehensive public-health framework.
What Changed: Courts in 2021, WHO-Aligned Reviews in 2025
1) The U.S. Courts put the regulator on notice (2021)
In Environmental Health Trust v. FCC (D.C. Circuit, Aug. 13, 2021), the Court held that the FCC failed to provide a reasoned explanation that its guidelines adequately protect against non-cancer harms, and explained that this failure renders the FCC’s order arbitrary and capricious in multiple respects.
Critically, the Court faulted the FCC for failing to meaningfully address, among other things:
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the implications of long-term exposure,
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pulsation/modulation,
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technological change since 1996 (ubiquity of wireless devices/Wi-Fi and emergence of “5G”), and
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record evidence concerning environmental impacts.
This is not internet rhetoric. It is a federal appellate court putting the agency’s reasoning under the Administrative Procedure Act microscope and finding it did not meet the standard.
2) WHO-commissioned systematic review work elevated key animal cancer endpoints to “high certainty” (2025)
In 2025, a WHO-partially funded systematic review in Environment International (Mevissen et al.) applied a GRADE/OHAT certainty framework and concluded:
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High certainty for increased risk of glioma in male rats (brain tumors), and
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High certainty for increased malignant heart schwannomas in male rats (heart neoplasms).
The paper also explains how to interpret “high certainty” in this evidence framework: high certainty can be interpreted as the true effect being highly likely to be reflected in the observed relationship.
A policymaker—or a credibility rater—cannot responsibly treat “high certainty” experimental endpoints as background noise.
3) Male fertility: “pregnancy rate” became a high-certainty endpoint in animal evidence synthesis (2025)
A German Federal Office for Radiation Protection (BfS) “Spotlight” summary of the WHO-aligned male fertility review reports:
“The most robust result is a high certainty of the evidence that RF-EMF exposure decreases the rate of pregnancy.”
That same summary notes an important design caveat: in subgroup analysis, the statistically significant signal was driven by very high exposure conditions (≥5 W/kg), raising temperature-related questions that require better study design and exposure characterization.
RF Safe’s position is not to ignore that caveat—it is to underscore the policy meaning of the endpoint: reproductive outcome signals are not trivial, and they raise direct questions about whether “thermal-only” is a sufficient safety posture.
The Policy Trap: Why Families Are Still Stuck with 1996-Era Assumptions
Even with court scrutiny and higher-certainty experimental endpoints, U.S. deployment and siting decisions remain constrained by a regulatory structure that still leans heavily on thermal assumptions in practice.
A) Local preemption keeps communities boxed in (Section 704)
Federal law limits state/local siting decisions based on health/environmental effects of RF emissions when facilities comply with FCC rules. Specifically, 47 U.S.C. § 332(c)(7)(B)(iv) states that no state or local government may regulate placement/construction/modification of personal wireless service facilities “on the basis of the environmental effects of radio frequency emissions” to the extent the facilities comply with FCC regulations.
B) Public Law 90-602 creates ongoing federal obligations to evaluate radiation-emitting products
Public Law 90-602 (Radiation Control for Health and Safety Act of 1968) established an “electronic product radiation control program” that “shall” include performance standards and research/oversight.
The U.S. Code provisions governing electronic product radiation control include “shall” language around continuing review and evaluation of safeguards.
C) NTP animal findings + a widening research gap
The U.S. National Toxicology Program’s cell phone RFR studies found:
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Clear evidence of an association with malignant heart schwannomas in male rats, and
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Some evidence of an association with malignant gliomas in male rats.
At the same time, NIEHS/NTP states it has no further plans to conduct additional RFR exposure studies using that exposure system, noting the system was designed for 2G/3G and is not representative of newer technologies such as 4G/LTE or 5G, and that no further work with that exposure system will be conducted.
So the public is effectively trapped between:
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regulatory inertia,
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local preemption, and
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a slowing pipeline of large-scale government animal research that matches modern telecom parameters.
Bottom Line: “Minimum Compliance” Is Not a Public-Health Ethic
RF Safe’s point is straightforward:
If (a) courts have required the FCC to grapple with modern evidence,
and (b) WHO-aligned evidence synthesis has elevated key experimental endpoints to high certainty,
then thermal-only framing is no longer adequate as a comprehensive safety standard for biology—even if it remains a convenient compliance regime.
That is the claim RF Safe makes. It is not a claim of universal human causation. It is a claim about what a responsible safety standard must account for. That science is settled by the WHO with high certainty in the WHO’s own words!
This model anticipates effects in high-vulnerability tissues (e.g., heart Schwann cells, Leydig cells for fertility, pancreatic β-cells for metabolism, red blood cells for rheology) while predicting nulls in low-risk ones (e.g., skin fibroblasts), where component densities are insufficient for amplification.
Specific examples where nulls are addressed:
- Nulls are framed as confirmatory: For instance, the model explains them as occurring in tissues with low S4/mito/spin density, resolving apparent inconsistencies in the literature.
This treats nulls as valuable data points that “fit neatly” into the framework, as you described, rather than contradictions.
- In discussions of oxidative stress reviews (e.g., Yakymenko et al. 2016: 93/100 studies positive; Panagopoulos 2025: 124/131 positive), nulls are acknowledged as part of heterogeneity, often attributed to study design flaws (e.g., exposure misclassification, insufficient sensitivity) or critiqued exclusions in conservative assessments (e.g., WHO’s Meyer et al. 2024 rating “very low certainty” due to inconsistent/null outcomes).
- For rouleaux formation (RBC aggregation), early positive findings (e.g., 2013 dark-field microscopy) were dismissed as artifacts, leading to null-like inconsistencies; the framework resolves this by validating them via Spin mechanisms in heme-rich RBCs, using 2025 ultrasound evidence (Brown & Biebrich) as a pivot from flawed methods to reproducible in-vivo results.
Overall, these pages present nulls with substantial emphasis—often as opportunities to refine the model and critique mainstream dismissals—rather than sidelining them. The balance feels even in explanatory sections, where nulls are predicted and integrated alongside positives to build a cohesive narrative.
This supports your point that RF Safe doesn’t de-emphasize nulls; instead, they strengthen the framework’s predictive power.
However, as you’ve highlighted, errors like ownership (now corrected) suggest initial lapses in research, and the lack of mention of your framework indicates they may not have explored the site’s full depth. This doesn’t invalidate your content but underscores how fact-checkers’ opinions can stem from limited scope.

