This commentary evaluates two sets of guidelines for human exposure to radiofrequency (RF) energy, focusing on the frequency range above the "transition" frequency at 3-10 GHz where the guidelines change their basic restrictions from specific absorption rate to incident power density, through the end of the RF band at 300 GHz. The analysis is based on a simple thermal model based on Pennes' bioheat equation (BHTE) (Pennes 1948) assuming purely surface heating; an Appendix provides more details about the model and its range of applicability. This analysis suggests that present limits are highly conservative relative to their stated goals of limiting temperature increase in tissue. As applied to transmitting devices used against the body, they are much more conservative than product safety standards for touch temperature for personal electronics equipment that are used in contact with the body. Provisions in the current guidelines for "averaging time" and "averaging area" are not consistent with scaling characteristics of the bioheat equation and should be refined. The authors suggest the need for additional limits on fluence for protection against brief, high intensity pulses at millimeter wave frequencies. This commentary considers only thermal hazards, which form the basis of the current guidelines, and excludes considerations of reported "non-thermal" effects of exposure that would have to be evaluated in the process of updating the guidelines.