The cell phone radiation SAR test has 23 different ways to screw up the result of the FCC-required compliance test.

Take a look at all the things that the FCC admits can go wrong during a SAR test!!  (What’s SAR?)

The text below (in italics labeled “Measurement Uncertainties”) is copied right out of the FCC’s own SAR compliance testing document, Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields: Supplement C (Edition 01-01) to OET Bulletin 65 (Edition 97-01).

This FCC document identifies 23 different ways the cell phone radiation (SAR) test results can be corrupted by a testing facility.  How disturbing to find out that this vital consumer safety testing procedure is likely to result in “measurement uncertainty!

Manufacturers (e.g.; RIM, maker of all BlackBerrys) are also allowed by the FCC to use the faulty procedure to test cell phone radiation in their own labs and report the results using an “honor system.”  Talk about allowing the fox to guard the hen house!  Also requiring a ridiculously complex compliance test that provides 0% confidence that the results are representative of the actual radiation effect on consumers…..what kind of regulatory oversight is that?!

The FCC is required by federal law to regulate a cell phone’s microwave radiation impact on a consumer’s body during a call.

The upper limit of absorption for heating parts of the brain and organs of a simulated human body during the test is 1.6 SAR.  The CTIA (powerful cell phone industry lobby) and FCC claim that as long as a cell phone’s SAR test result is under this 1.6 limit, it is deemed “safe”.  Well, given all the errors and uncertainties inherent in the SAR test, how can a consumer be guaranteed their cell phone’s max SAR test result IS actually below 1.6?

The actual text from the FCC’s testing document followed by all cell phone manufacturers seeking compliance appears below.  See for yourself:



Measurement uncertainties are calculated using the tolerances of the instrumentation used in the measurement, the measurement setup variability, and the technique used to perform the SAR evaluation.

The overall uncertainty is calculated in part by identifying uncertainties in the instrumentation chain used in performing each of the procedures in the evaluation. Methods for evaluating and expressing measurement uncertainties can be found in the NIST Technical Note 1297 (TN1297)24, entitled ”Guidelines for Evaluating and Expressing the Uncertainty of NIST Measurement Results”. Another source of reference is the NIS 81 document, entitled “The Treatment of Uncertainty in EMC published by the National Physical Laboratory of the United Kingdom.

(NOTE:  later in the document)…..


A. Assessment Error (measurement system)

I.   Probe Calibration Error

1. Axial Isotropy Error

2. Hemispherical Isotropy Error

3. Spatial Resolution Tolerance

4. Boundary-effects Error

5. Linearity Error

6. Sensitivity Error

7. Response Time Error

8. Integration Time Error

II.  Readout Electronics Error

III. Errors from RF Ambient Conditions

IV. Probe Positioner Calibration Error (absolute)

V.  Probe Positioning Error with respect to the Phantom Shell

VI. Errors from the Extrapolation, Interpolation and Integration Algorithms

B.  RF Source Error (test device)

I.  Test Sample Output Power Drift Error

II. SAR Variation due to Performance Tolerance of the Test Sample

III. SAR Variation due to Tolerance of Production Units

C. Test Device Positioning Error

I.   Test Sample Positioning Error

II.  Device Holder or Positioner Tolerance

D. Phantom and Setup Errors (See Reference[19])

I. Phantom Production Tolerance (shape and thickness)

II. Target Liquid Conductivity Tolerance

III. Measured Liquid Conductivity Error

IV. Target Liquid Permittivity Tolerance

V. Measured Liquid Permittivity Error

BlackBerry users are told to carry their cell phones in their pockets!

RIM’s radiation testing engineers know that encouraging consumers to carry their cell phone in their pocket is in direct violation of federal compliance guidelines.  The FCC requires RIM to warn all users to never carry or use a phone closer than 1″ to the body when connected to a network or they will be exposed to radio frequency emissions that exceed the federal limit.  RIM currently includes this FCC required radiation warning in all user guides, although they continue to hide it in fine print technical jargon in a section of the user guide that no one will ever see.

Warning consumers about the 1 separation distance is a federal compliance requirement by the FCC…. to disregard this radiation testing compliance directive is a blatant violation of 47 CFR Part 15.

RIM is also ordered by the FCC Office of Engineering and Technology in its compliance testing grant documents that “End-users must be informed of the body-worn operating requirements for satisfying RF exposure compliance.”

Yet, RIM’s marketing department displays the following tagline on their website to entice BlackBerry Pearl users to tuck the phone in their pocket:

“BlackBerry Pearl – Carry Your Friends in Your Pocket”


So, RIM continues to tell us that it’s OK to carry your phone in your pocket, even if doing so exposes our bodies to radiation levels that exceed maximum federal safety limits.

How about RIM’s Pocket Pouch?  Nope, it’s in violation of federal compliance guidelines, too!

Leave it to RIM’s marketing department to come up with another way to ignore federal regulatory radiation guidelines.  If positioning the cell phone in a pocket against the body, the pouch does NOT provide the 1″ separation distance as required by FCC law, so it is therefore not a compliant use.  To encourage their customers to use their products in a potentially unsafe manner is not an ethical marketing practice.