Topics & supporting passages
  • Sensitivity & health experiences: “At non-thermal levels, these standards explicitly restrict themselves to acute effects only, not accepting temporarily annoying effects as harmful effects (e.g., not tinnitus…), nor long term effects (e.g., not cancer, diabetes, …), and only effects objectively observable (e.g., not headache, nausea, , …).”
  • Cancer & tumors: “At non-thermal levels, these standards explicitly restrict themselves to acute effects only, not accepting temporarily annoying effects as harmful effects (e.g., not tinnitus…), nor long term effects (e.g., not cancer, diabetes, …), and only effects objectively observable (e.g., not headache, nausea, , …).”
  • Biological mechanisms & metabolism: “At non-thermal levels, these standards explicitly restrict themselves to acute effects only, not accepting temporarily annoying effects as harmful effects (e.g., not tinnitus…), nor long term effects (e.g., not cancer, diabetes, …), and only effects objectively observable (e.g., not headache, nausea, , …).”
  • Towers, antennas & siting: “The ICNIRP 2020 and ICES C95.1 2019 standards, by which, a.o., 5G deployment were legitimized worldwide, are based on research studies and assessments based on essentially these same methodological elements, and thus flawed, having no predictive value for non-thermal health risk identification.”
  • Exposure limits & testing: “At non-thermal levels, these standards explicitly restrict themselves to acute effects only, not accepting temporarily annoying effects as harmful effects (e.g., not tinnitus…), nor long term effects (e.g., not cancer, diabetes, …), and only effects objectively observable (e.g., not headache, nausea, , …).”
  • Research, evidence & monitoring: “At non-thermal levels, these standards explicitly restrict themselves to acute effects only, not accepting temporarily annoying effects as harmful effects (e.g., not tinnitus…), nor long term effects (e.g., not cancer, diabetes, …), and only effects objectively observable (e.g., not headache, nausea, , …).”

Topics matched to original text; attachment contents excluded. Classification details

ORIGINAL COMMENT · UNEDITED TEXT
Comment in Response to Public Notice DA 26-997, ET Docket No. 13-84 This comment addresses FCC’s methodological criteria for assessments of responses to the mentioned Public Notice as one may interpret from its questions in the FCC Public Notice page 7. These criteria are by and large those used by IEEE ICES and ICNIRP. The methodological criteria used by IEEE ICES and ICNIRP to identify thresholds for RF-EMF caused harmful health effects, are flawed – and so for several reasons detailed in referenced material: 1. At non-thermal levels, these standards explicitly restrict themselves to acute effects only, not accepting temporarily annoying effects as harmful effects (e.g., not tinnitus…), nor long term effects (e.g., not cancer, diabetes, …), and only effects objectively observable (e.g., not headache, nausea, , …). Effects have to be proven by research methods primarily appropriate for identifying thermal effects, even when effects are well demonstrated by acceptable methods not to be thermal. Research proving effects, but not using thermally based methods is regarded as no or poor evidence, hence dismissible. 2. Such thermal methodological criteria and stringent demands for proof may all be traced back to historical contexts of research on ionizing radiation effects and non-ionizing radiation’s thermal effects in which they are defensible. In the context of non-thermal effects of non-ionizing radiation they are not. However, they have been made part of standards in which they function as a bulwark against accepting any effects from RF-EMFs below thermal levels. Using such a thermal methodology produces conclusions of «no health effects found» as an artefact, i.e. as a result of the methodology as such, and is thus without any evidentiary power – just flawed. Such methodology also means dismissing a precautionary approach, as the scope is set far too restrictive. 3. The ICNIRP 2020 and ICES C95.1 2019 standards, by which, a.o., 5G deployment were legitimized worldwide, are based on research studies and assessments based on essentially these same methodological elements, and thus flawed, having no predictive value for non-thermal health risk identification. 4. The assessments carried out by WHO’s The International EMF Project in order to be used as a platform for RF-EMF standard revisions, have been required to use study protocols based on such thermally based methodology, and therefore flawed, too (apart for the one assessment which did not accept using such a thermal protocol). Details underpinning the statements above are found in the following scientific papers and responses to the FCC and HHS Request for Information: Nordhagen EK, Flydal E. WHO to build neglect of RF-EMF exposure hazards on flawed EHC reviews? Case study demonstrates how "no hazards" conclusion is drawn from data showing hazards. Rev Environ Health. 2024 Jul 10;40(2):277-288. doi: 10.1515/reveh-2024-0089. PMID: 38981511. Nordhagen EK, Flydal E. Self-referencing authorships behind the ICNIRP 2020 radiation protection guidelines. Rev Environ Health. 2022 Jun 27;38(3):531-546. doi: 10.1515/reveh-2022-0037. PMID: 35751553. Else K. Nordhagen, Einar Flydal, Cornelia Waldmann-Selsam, and Vibeke Frøkjær Jensen: Comment in Response to FCC Public Notice DA 26-997, ET Docket No. 13-84, Submitted Oct.20.2026. https://bit.ly/4i6XM0h Else Nordhagen, Vibecke Frøkjær, Einar Flydal, Cornelia Waldmann-Selsam, Fiorella Belpoggi: Quality criteria for RF/EMF Health-Risk Assessments, Essential Criteria for Assessing Health Risks from Wireless Radiation, Response to HHS Request for Information, Submitted Oct.20.2026. https://bit.ly/3UCWjFO It follows that the methodology used to assess RF-EMF health effects should be thoroughly revised. As shown in the mentioned references, more relevant methodological frameworks for assessments do exist. Signed by Einar Flydal Oslo, Norway, Oct. 20, 2026 Einar Flydal is a Master of political science from the University of Oslo, Norway, and Master of Telecom Strategy and Technology Management from the Norwegian Polytechnical University (NTNU), Trondheim, Norway. Before retiring, Flydal was a Senior Researcher at Telenor Research & Development. He has also served as a Senior Strategy Adviser in the Telenor corporate management, and, a.o., as adjunct assistant professor at NTNU. Since 2010, he has studied and published, first and foremost for the general public in Scandinavia, on EMFs, health and environmental impacts. He chaired the Norwegian mirror commitee of the development of the ISO 26000 standard on the social responsability of organizations.
Sensitivity & health experiencesCancer & tumorsBiological mechanisms & metabolismTowers, antennas & sitingExposure limits & testingResearch, evidence & monitoring
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