Exhibit A–Q: The MBFC Rating’s Evidentiary Failures ⋆ QuantaDose Far-UV/UVC Light and Detection

MBFC’s RF Safe entry assigns a “Medium Credibility” rating while simultaneously conceding that RF Safe is “Mostly Factual” and that RF Safe links to legitimate studies. The downgrade is then justified primarily through broad labels—“selective citation,” “one-sided interpretation,” “alarmist framing,” and a “potential conflict of interest”—plus “conflict” with major health authorities such as the FDA, CDC, and WHO.

If a credibility rating is going to function as a quasi-fact-check for the public, it has to be anchored to stable, verifiable references and claim-level analysis—not shifting institutional web copy, generalized narrative objections, or conjecture about motives. The record MBFC itself publishes does not meet that bar. The evidentiary chain breaks at multiple points.

Below are Exhibits A–Q, presented as a structured, blog-ready record of those failures.

Exhibit A — MBFC identifies no IFCN-backed failed fact-checks

MBFC explicitly states: “No specific failed fact checks by IFCN-approved organizations were identified.”
This matters because credibility downgrades should ordinarily be tethered to falsified claims or documented, repeated factual errors. MBFC offers none.

Exhibit B — MBFC concedes RF Safe is “Mostly Factual” and links to legitimate studies

MBFC’s own summary reads: “We rate RF Safe as Mostly Factual because it links to real scientific studies and engages with legitimate research questions.”
That admission is incompatible with a “credibility penalty” that is left largely ungrounded in specific, demonstrable misrepresentation.

Exhibit C — The downgrade rests on conclusory labels, not claim-level refutation

MBFC’s justification for “Medium Credibility” is framed as: “selective citation, one-sided interpretation of evidence, alarmist framing,” and product-related concerns.
But MBFC does not identify (in the entry) a concrete set of representative RF Safe claims that are false, trace the primary literature, and show where RF Safe misstates results. The critique is primarily a narrative judgment, not a substantiated fact-check.

Exhibit D — MBFC’s “consensus” framing is asserted, not evidenced

MBFC argues RF Safe’s public-health framing conflicts with a “broader scientific consensus historically reflected” by major institutions.
But MBFC does not operationalize what “consensus” means in evidence-grade terms (systematic review methods, risk-of-bias weighting, outcome stratification, exposure characterization, and certainty grading). Without that, “consensus” becomes rhetoric rather than an evidentiary standard.

Exhibit E — WHO-linked evidence has moved to high certainty for key animal cancer endpoints

A 2025 systematic review in Environment International (part of a special issue on WHO RF-EMF systematic reviews) reports high certainty of evidence (CoE) for increased risk of glioma (male rats) and malignant heart schwannomas (male rats), while also finding that many organs show no or minimal evidence—i.e., a heterogeneous evidence landscape.
This is not “settled safety.” It is exactly the kind of mixed-pattern record where mechanistic modeling—and serious handling of nulls—matters.

Exhibit F — The same systematic review flags that core policy assumptions remain scientifically unsettled

The same review explicitly notes that, without better mechanistic understanding, questions like whether SAR is the appropriate dose metric “may be critical,” alongside issues like exposure metric choice, intensity vs. cumulative exposure, and whether a monotonic dose–response holds.
That is a direct challenge to the idea that thermal-only framing is sufficient or that “major authority alignment” can substitute for ongoing scientific uncertainty.

Exhibit G — MBFC treats FDA positioning as a credibility benchmark, yet the FDA pages MBFC relies on are no longer stable

MBFC explicitly cites “institutions such as the CDC and WHO,” and discusses the FDA’s posture, including FDA’s “recent withdrawal of its public safety language.”
But credibility scoring cannot rest on institutional web pages that are subsequently removed, redirected, or rewritten—especially when those pages are used as the “concrete example” of why an outside evaluator is allegedly “one-sided.”

Exhibit H — The FDA URL now redirects, meaning MBFC’s cited authority is not even the same document anymore

The FDA page historically associated with “Scientific Evidence for Cell Phone Safety” now redirects to the FDA’s broader “Cell Phones” landing page.
Likewise, the “Do Cell Phones Pose a Health Hazard?” URL now redirects to that same landing page.
A credibility argument anchored to “what the FDA page says” becomes non-verifiable when the cited page no longer exists at the referenced URL.

Exhibit I — The archived FDA page contained categorical reassurance language now only verifiable via archive

Archived FDA content (captured with “Content current as of: 06/30/2025”) stated that “the weight of scientific evidence has not linked” cellphone RF exposure with health problems at or below FCC limits.
The same archived page included thermal-centric framing, including: “no categorical proof of any adverse biological effects other than tissue heating.”
When MBFC used FDA’s categorical assurances as a yardstick for judging RF Safe’s “one-sidedness,” it relied on language that has since been functionally removed from public view at the original URL.

Exhibit J — The current FDA “Cell Phones” page is labeled “Content current as of: 05/13/2021”

The FDA “Cell Phones” landing page (the new redirect destination) prominently features short-form reassurance sentences and is labeled “Content current as of: 05/13/2021.”
This undermines any argument that “the current FDA page” represents a fresh, definitive scientific endpoint suitable for downgrading external critics.

Exhibit K — Reuters confirms the FDA removed older “not dangerous” webpages while HHS announced a new study

Reuters reported that the FDA “took down old webpages saying cellphones are not dangerous,” quoting an HHS spokesperson explaining the removal as part of reassessing “old conclusions” while HHS undertakes a new study to identify gaps in knowledge.
This corroborates the core point: MBFC’s reliance on FDA web assurances as a credibility yardstick was time-fragile and quickly outpaced by federal actions.

Exhibit L — MBFC’s own entry acknowledges the FDA withdrawal—yet keeps the same downgrade logic intact

MBFC now acknowledges “the FDA’s recent withdrawal of its public safety language” and characterizes it as “an administrative reassessment rather than new scientific findings.”
That is not a fact-check; it is MBFC’s interpretation of administrative intent. And it does not repair the core problem: MBFC still uses “authority alignment” as a scoring mechanism while the referenced authority record itself is unstable and contested.

Exhibit M — RF Safe’s “selective citation” charge is hard to square with RF Safe’s own claimed archive scale

RF Safe publicly describes its research archive as linking to more than 4,000 peer‑reviewed EMF and RF‑bioeffects studies.
A claim as serious as “selective citation” requires MBFC to demonstrate systematic omission or distortion—not merely to assert that RF Safe emphasizes risk-relevant findings.

Exhibit N — The S4–Mito–Spin framework explicitly integrates null results as expected boundary conditions

RF Safe’s S4–Mito–Spin “talking points” page states: “The framework predicts that some combinations will show effects and some won’t; null results are expected in parts of the parameter space.”
That is the opposite of cherry-picking by design: it is a stated methodological posture that treats nulls as informative constraints, not inconvenient data to discard.

Exhibit O — The D.C. Circuit faulted the FCC for failing to address long-term exposure and modulation/pulsation—issues central to non-thermal debates

In Environmental Health Trust v. FCC (D.C. Cir. 2021), the court identifies, among the petitioners’ arguments, that the FCC failed to discuss “the implications of long‑term exposure” and “RF pulsation or modulation.”
The court further held the FCC order was “arbitrary and capricious” for failing to respond to record evidence that RF exposure below limits may cause negative health effects unrelated to cancer.
This matters because MBFC’s “major authorities say X” shorthand ignores that those authorities have been legally compelled to account for precisely the kinds of non-thermal and modulation-dependent issues RF Safe emphasizes.

Exhibit P — The U.S. formally withdrew from WHO citing concerns about independence and political influence

HHS announced completion of U.S. withdrawal from WHO, citing (among other reasons) WHO’s “inability to demonstrate independence from the inappropriate political influence of WHO member states.”
Regardless of one’s view on the withdrawal, MBFC’s credibility heuristic—“conflicts with WHO therefore less credible”—becomes a weaker public yardstick when the U.S. itself publicly frames WHO independence as a material concern.

Exhibit Q — What an evidence-based correction would actually look like

If MBFC wants to keep a credibility rating that functions as more than an opinion label, it should do at least four things:

Replace labels with claim-level analysis: identify specific RF Safe claims, quote them, trace to primary sources, and show where RF Safe misstates results (if it does).
Stop using unstable authority webpages as “proof”: when the FDA URLs redirect and archived pages are the only record of prior categorical language, MBFC must acknowledge the “authority anchor” is not a stable document.
Update “consensus” framing to reflect systematic-review outcomes and uncertainty: including the 2025 Environment International review’s high CoE findings for specific tumors, and its explicit callouts about mechanism and SAR metrics.
Treat null-handling honestly: if RF Safe’s framework explicitly anticipates nulls, MBFC must either (a) acknowledge that and revise “selective citation” language, or (b) provide concrete examples where RF Safe ignores nulls in practice.