Device accessibility – progress and next steps

The International Day of Persons with Disabilities is a good opportunity before the end of the year to look at what we have achieved in device accessibility this past year and where to direct our energies in the next months. 

 

In the first half of 2023, we published the outcomes of the sixth GARI feature review and began implementing the changes. This review process yet again confirmed the collaborative approach inherent within the GARI project, which combines consumer, government and industry views into a list of accessibility features that can be matched against devices - with the objective of helping consumers select devices that best fit their needs. 

 

Throughout the year, members of the MWF have been involved in the Hearing-Aid Compatibility (HAC) Task Force in the US, contributing to the proposal of a Waiver for an alternative testing methodology for volume control for two years, which was recently granted by the FCC. It also resulted in a draft Notice of Proposed Rule Making (NPRM) on how to move towards 100% hearing-aid compatibility for wireless devices, likely to be finalized and published in 2024. 

 

In the second half of the year, the MWF mapped the accessibility features listed in GARI against the requirements in Annex 1 of the European Accessibility Act (EAA) and the Web Accessibility Standard EN 301 549. This comparison of accessibility requirements and available features within devices, is the foundation for the MWF’s proposal for an interim solution for compliance reporting under the EAA until the harmonized standards arrive. The intention of this proposal is to provide legal certainty for the manufacturers on one hand and clear, practical information for consumers on the other hand. 

 

For 2024, the MWF is looking forward to continuing to promote device accessibility, including through our video series and continuing our discussions with stakeholders to better understand the diversity of needs and how devices can best address them.

e-labelling – let’s take the step into the digital age with our labels

21 countries and 60% of consumers – 21 countries around the world have replaced traditional labels with the option to use electronic labelling for mobile phones and other ICT equipment, and 60% of consumer electronic sales revenue worldwide is derived from markets allowing e-labelling. The MWF’s e-labelling initiative explains what Europe can gain from following suit.

In April 2022, the MWF launched the e-labelling initiative. Its purpose is to build alliances and support in Europe for allowing electronic labelling to replace the current requirements for printed labels on the device and packaging as well as compliance, regulatory and safety information in print form. E-labelling on the other hand is a digital depiction of logos, marks and labels within the device that fulfils the same purpose and can go far beyond it, accompanied by a QR code on the packaging that leads to the same information. 

A triple-win

A win for the environment: an estimated 48 million sheets of A4 paper could be saved every year from smartphone packaging alone, if required information was allowed in electronic format. This would result in 480 million litres of water and over a 1000 tonnes of CO2 emissions saved. 

A double-win for the consumer: the information can be made more accessible and remains available throughout the lifetime of the device in contrast to the existing system where the information is lost or discarded and is inaccessible to some users with a disability.

Following international best practice

Europe would not be the first to opt for e-labelling. Currently, 21 countries around the world have replaced traditional labelling requirements with the option to use electronic labelling for mobile phones and other ICT equipment, such as tablets, wearables and laptops. These 21 countries represent around 60% of consumer electronic sales revenue worldwide, and include the EU’s major trading partners: the United States, China, Japan, South Korea and Taiwan.

A 2018 study by VVA furthermore shows that the introduction of e-labelling has no impact on market surveillance authorities and might even result in lowering their operational costs, while quick and easy access to the information is ensured for customs. 

A recently published MWF White Paper finally outlines how the European Commission has already supported e-labelling in other sectors and that a broader implementation of e-labelling in Europe does not need to be complex. Rather, it involves a simple amendment to the relevant directive that would allow for existing requirements to also be met through digital display.

For more information, have a look at the MWF video series on e-labelling: 

• E-Labelling Overview: https://www.youtube.com/watch?v=HrwgxOoZBr8
• MWF E-Labelling Sustainability: https://www.youtube.com/watch?v=_F4FO2FbTRE
• MWF E-Labelling Accessibility: https://www.youtube.com/watch?v=TFvdFIklgQQ 

The MWF White Paper on “Why the European Union should adopt e-labelling”: https://www.elabellinginitiative.org//docs/eng/MWF_E-labelling%20White%20Paper_Mar2022.pdf 

The website of the MWF’s e-labelling imitative: https://www.elabellinginitiative.org 

mmWaves, 5G network measurements, cumulative exposure from IoT…. MWF research in 2021

In 2021, the MWF carried out research projects with the Universities of Ghent, l’Aquila and Aalborg, as well as Rohde & Schwarz and Telstra, investigating exposure in 5G networks, simulation of reverberation chambers for animal exposure studies, exploring the behaviour of incident and absorbed power densities in different frequency ranges, and cumulative exposure of IoT devices. 

Since its creation in 1998, the funding and promotion of research in view of science-based standards for safety and compliance testing has been one of the core activities of the Mobile & Wireless Forum (MWF). Since then, we have moved on to 5G and the practical implementation of this new generation of mobile technology has required data as the basis for safety and compliance standards. 

For this reason, the MWF worked in 2021 with three universities and two companies on five research projects. These include, a project with the Ghent University on “EMF exposure measurements of a 5G commercial network”. In a previous MWF project, the team developed a new method to assess exposure to radiofrequency (RF) electromagnetic fields (EMF) emitted by 5G New Radio (NR) base stations (published in December 2019). The objective of the 2021 project was the validation of the measurement procedure in commercial networks and gathering of actual EMF exposure levels in a 5G commercial network. One week of measurements in a commercial 5G network in Switzerland showed that the highest average field value measured was only 0.46 V/m, which corresponds to 0.006% of the ICNIRP exposure limits. Overall, the 5G network was found to have only very limited impact on the environmental RF-EMF exposure levels. The findings were published in a scientific paper: In Situ Assessment of 5G NR Massive MIMO Base Station Exposure in a Commercial Network in Bern, Switzerland (Ghent/IMEC): https://www.mdpi.com/2076-3417/11/8/3592

With the University of l’Aquila the MWF has a research project on “Simulation of a reverberation chamber exposure with Sim4Life”. The goal is to simulate a large group of animals (96 animals) and to compare the results with those of the NTP Study (120 animals). The team looked at the correlation between the electric field, magnetic field and SAR. It seems that the whole-body SAR is more correlated with the magnetic field than the electric field. This is a new insight. The analysis also looked at different rat models over a whole day of exposure to verify the standard deviation, and reproduced a number of simulations with different positioning and different rat models to investigate possible bias through positioning of the animal cages. The research outcomes were presented at the BioEM Conference 2021 and two research papers are under preparation for publication in scientific journals. 

With Aalborg University, the MWF has started a research project looking at new restriction above 6 GHz for localized exposure as outlined in the ICNIRP 2020 guidelines. This project compares the matrix of the incident power density and absorbed power density and how they behave in different frequency ranges. Insights from this work will feed into the development of simulation and measurement standers for absorbed power density. 

In conjunction with Australian network operator Telstra, the MWF undertook a project on the compliance of Internet of Things (IoT) systems made up of many different devices, which mirror typical use cases. The study focused on EMF measurements of a range of smart home IoT wireless devices with Wi-Fi and Bluetooth connections with the aim to determine the time-averaged exposure form the IoT devices under typical conditions of use. A wide range of devices was selected, including security and doorbell cameras, kitchen scales, smart Wi-Fi LED globes, smart Wi-Fi power strips, Smart Home hubs, hot spot routers etc. Wi-Fi tended to be the main way of connection between the devices. Based on the outcomes of this work, the MWF is currently developing a “Smart Home Walkthrough” tool, which will allow consumers to understand what kind of exposure they might have in their own homes with multiple RF devices emitting at the same time. The data will also be used as basis for a research paper. 

Finally, the MWF worked with Rohde & Schwarz GmbH & Co. KG to manufacture antennas according to the specification of IEC 63195-1, to validate the reference values for incident power density and to identify gaps in the antenna design specifications. In future projects, these antennas might also be used to do measurements of absorbed power density. One of the papers coming out of this research: Zhekov et al. “Test Reduction for Power Density Emitted by Handset mmWave Antenna Arrrays”, IEEE Access, Jan 28, 2021 

Throughout the years, the MWF has developed and worked through a comprehensive research agenda, which resulted in many peer-reviewed publications and contributed substantial data as basis for the technical discussions in the standardisation committees. 

For its 20th anniversary, the MWF summarised these research efforts in a 56-page document: http://www.mwfai.org/docs/eng/2018_05_MWF_20YearsofResearch.pdf 

What is SAR?

The SAR value is often mentioned in regard to mobile phones and exposure of users to electromagnetic fields emitted from wireless devices.

SAR stands for Specific Absorption Rate, where “specific” indicates the quantity of tissue mass, “absorption” the amount of electromagnetic energy absorbed into that mass and “rate” indicates the rate of time at which this is happening.

The use of SAR as a value to assess exposure from electromagnetic fields was first discussed in 1975 and was officially adopted in the ANSI C95.1-1982 standard.

This standard established the whole-body SAR of 4 W/kg as a threshold  - which was then divided by 10 for a whole-body exposure limit for workers (0.4W/kg) and divided by a further factor of 5 to create a whole-body limit for the general public (0.08 W/kg).  

These reduction factors - also commonly referred to as ‘safety margins’ - have been maintained in subsequent updates to the standard and are also reflected in the ICNIPR guidelines, which the majority of countries in the world base their exposure limits on. 

“Not enough research on 5G, “ they say

Is it true that 5G is the big unknown? That there is no research we can build our risk assessment on? That we are facing a completely new type of technology never seen or heard of before? The short answer: no, it’s not true. We have a wealth of research we can build on. In the following a short overview. 

 

Of course, there is always room for more research and as our knowledge evolves, we come up with more refined approaches in exploring any given subject. In regard to 5G though, we do already know a lot. We have used the frequency ranges the new technology will use for a long time and know how they interact with the human body. And whilst 5G is starting to be  rolled out, the research efforts also continue. 

 

Research up to now 

 

Initially, 5G will use parts of the radiofrequency spectrum that has already been used for  other applications (e.g. the 700 MHz band and the 3.4-3.8 GHz band were used earlier for terrestrial broadcasting in different countries). 

 

Therefore, rather than starting anew, we have more than 60 years of research upon which to rely on. Starting back in the 1950’s with studies into military radar, TV and radio we now have more than 28,000 published scientific articles on the biological and health effects of electromagnetic fields (EMF). These include 2,500 studies on mobile communications.[1]

 

Among these 2,500 studies, about 350 studies look at higher frequency bands in the range of 24 GHz, often called mmWaves[2], which is another part of the radiofrequency spectrum that 5G is going to be using.

 

In regard to radiofrequencies and technological use of it, the World Health Organization (WHO) has stated: 
 
“In the area of biological effects and medical applications of non-ionizing radiation approximately 25,000 articles have been published… Despite the feeling of some people that more research needs to be done, scientific knowledge in this area is now more extensive than for most chemicals.” ^[3]

 

Also, as the the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) has stated recently^[4] it “is important to note that higher frequencies does not mean higher or more intense exposure. Higher frequency radio waves are already used in security screening units at airports, police radar guns to check speed, remote sensors and in medicine and these uses have been thoroughly tested and found to have no negative impacts on human health".

 

 

As an international association of the wireless industry, the Mobile & Wireless Forum (MWF) has actively contributed to this research effort since its creation in 1998. A summary of these research activities can be found in the 2019 publication ’20 Years of Research’. The booklet gives a glimpse at the intensive ongoing research in this area and shows that the mobile and wireless industry continues to build on the solid foundation of scientific knowledge built over decades. 

 

 

Resources: 

 

MWF’s “20 Years of Research’ booklet: 

http://www.mwfai.org/docs/eng/2018%5F05%5FMWF%5F20YearsofResearch%2Epdf

 

 

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[1] EMF Portal: https://www.emf-portal.org/en

[2] Although strictly speaking mmWaves begin at 30GHz. 

[3] WHO “What are Electromagnetic Fields” Key Point 6: https://www.who.int/peh-emf/about/WhatisEMF/en/index1.html

[4] https://www.arpansa.gov.au/news/misinformation-about-australias-5g-network

Some facts about 5G – short, concise, in 4 languages

A lot of information circulates about 5G – from wild rumors and hear-say to detailed technical descriptions. But rare are short, concise and factual explanations about the most discussed aspects of the new generation of mobile communications.

In our continued effort to provide good and fact-checked information on wireless technologies, the MWF has started a series of short video clips that try to get to the point.

The first few videos are already online – most of them not only in English but also with German, Spanish and Portuguese translation:

What is 5G? 
5G and Coronavirus: Real Fake News
Expert Opinions on 5G Safety 

New videos will be added regularly to the MWF’s publication section: https://www.mwfai.org/publications.cfm?cat=Video

Or you can also directly follow the MWF’s Youtube channel: https://www.youtube.com/channel/UCvwTMEqvWD3BWx2tmxYGDUA

ICNIRP’s new exposure guidelines for telecommunications – what changes?

After a thorough revision of the last 20 years of international research, the safety guidelines for electromagnetic field exposure (EMF) from EM emitting sources such as smartphones, mobile devices and network antennas remain largely unchanged and continue to provide protection for the whole population. While the 1998 guidelines already covered 5G frequencies, changes have been made in the frequencies above 6 GHz which are also relevant for 5G. 

In March 2020, the International Commission on Non-Ionizing Radiation Protection (ICNIRP), an independent body of experts, published a revision of their radio-frequency (RF) EMF exposure guidelines. These guidelines set exposure limits for non-ionizing radiation, including electromagnetic fields (EMF) emitted from Wi-Fi and telecommunications, which “provide protection against adverse health effects to humans under realistic exposure conditions” (1).
                                   
The review of the research carried out over the last 20 years in this area, confirmed that the guidelines first set in 1998 are still valid and protect the whole population, including more vulnerable groups such as children, pregnant women and the elderly, from established health risks. Changes have been made in the 2020 guidelines to the frequencies above 6 GHz which are also relevant for 5G.

“We know parts of the community are concerned about the safety of 5G and we hope the updated guidelines will help put people at ease. The guidelines have been developed after a thorough review of all relevant scientific literature, scientific workshops and an extensive public consultation process. They provide protection against all scientifically substantiated adverse health effects due to EMF exposure in the 100 kHz to 300 GHz range,” said Dr Eric van Rongen, Chairman of ICNIRP, when the new guidelines were published.

ICNIRP was very clear on that there is ‘no evidence that RF-EMF causes such diseases as cancer’ and ‘no evidence that RF-EMF impairs health beyond effects that are due to established mechanisms of interaction’ (2). This statement fits with the large number of statements published over the past months by health authorities and national regulators around the world to stem the wild speculations and conspiracy theories circulated about 5G (3).

The only established hazards from RF EMF exposures relate to increases in local or whole-body temperature. The exposure limits are therefore set with substantial reduction factors to ensure that heating is within normal body ranges. This means that the limits are highly conservative and set in a way that they will remain protective unless they are exceeded by a substantial margin.

ICNIRP’s guidelines include different categories of exposure restrictions depending on the body region that is exposed to EMF – either the whole body or only parts of the body (Head, Trunk, Limbs), as well as on the duration of exposure – from instantaneous to long-term (24/7) exposure.

What has changed in the guidelines?

The guidelines were updated to also refine the limits for frequencies above 6 GHz which will be relevant for 5G. The main changes include:

• the addition of a restriction for exposure to the whole body 
• the addition of a restriction for brief (less than 6‐minute) exposures to small 
• regions of the body (e.g. through mobile devices)
• the reduction of the maximum exposure permitted over a small region of the 
• body

Overall improvements to the guidelines include:

• greater transparency to make the logic and scientific basis of the guidelines easier for the health protection community to engage with
• additional means of assessing compliance with the guidelines; and
• greater specification of how to assess complicated exposure scenarios

The SAR limits for mobile phones operating in frequencies below 6 GHz remain unchanged, only above 6 GHz a new absorbed power density limit is introduced that will apply to exposures close to the body (e.g. from mobile phones). The reason is that at higher frequencies the energy absorption occurs primarily at the body surface.

A timely publication 

The MWF welcomes the publication of the revised ICNIRP guidelines as they are based on an additional 20 years of research knowledge, improve scientific accuracy, accommodate changes in the frequencies above 6 GHz which are also relevant for 5G and still ensure a high level of protection for all.

Resources: 

• (1) ACEBR’s Science & Wireless December 2nd, 2019, Rodney Croft: ICNIRP Radiofrequency Guidelines, Public Consultation version,: https://documents.uow.edu.au/content/groups/public/@web/@socs/@psyc/documents/doc/uow262922.pdf
• (2) Media Release, New Guidelines Released by the International Commission on Non-Ionizing Radiation Protection (ICNIRP), 11 March 2020: https://www.icnirp.org/cms/upload/presentations/ICNIRP_Media_Release_110320.pdf 
• 5G conspiracy: Hundreds of articles now debunking it: http://mobile-wireless-forum.blogspot.com/2020/05/5g-conspiracy-hundreds-of-articles-now.html
• Media Release, New Guidelines Released by the International Commission on Non-Ionizing Radiation Protection (ICNIRP), 11 March 2020: https://www.icnirp.org/cms/upload/presentations/ICNIRP_Media_Release_110320.pdf 
• More information about ICNIRP: https://www.icnirp.org