HHS-OASH-2026-0397-0105
https://www.regulations.gov/comment/HHS-OASH-2026-0397-0105

I am submitting this comment because the United States needs to stop confusing regulatory compliance with proof of biological safety.

A wireless device can “pass” an RF exposure test under specified laboratory conditions and still leave unanswered the real public-health question: what happens to living tissue after years or decades of real-world exposure? Real life does not resemble a single-device laboratory test. Children, adults and pets are surrounded by phones, Wi-Fi routers, tablets, laptops, Bluetooth devices, wearables, smart appliances and nearby antennas, often operating simultaneously and for many hours every day.

Current standards do not adequately reflect chronic, cumulative, real-world exposure. Exposure changes with distance, signal strength, device position, frequency, modulation, data transmission and the number of sources present. Yet our regulatory framework has relied heavily on specific absorption rate and power-density limits rather than long-term biological monitoring of actual populations.

The question should not simply be, “Does this device stay below a SAR limit?” It should be, “What happens biologically to cells, tissues, organs and developing nervous systems under realistic exposure conditions?” HHS should independently investigate oxidative stress, cellular signaling, DNA damage, reproductive effects, neurological effects, sleep, development, endocrine effects and cancer. Absence of substantial heating should never be treated as automatic proof that there are no biological effects.

Children deserve special attention. They are not small adults. Their bodies and nervous systems are still developing, and today’s children may experience wireless exposure from infancy through an entire lifetime. Yet the long-term evidence for lifelong exposure beginning in childhood remains limited. That is a serious knowledge gap, not reassurance.

Animals and the environment also deserve attention. Pets spend long periods inside homes near routers and wireless devices. Wildlife, insects, birds and plants are now exposed to an increasingly dense RF environment. The evidence is incomplete and sometimes inconsistent, but that is precisely why rigorous independent research is needed.

The National Toxicology Program reported cancer findings in RF-exposed animals, including malignant heart schwannomas in male rats and some evidence of malignant gliomas. Human studies have produced mixed results. These differences should not be used to declare the issue settled in either direction. “Not conclusively proven harmful” is not the same thing as “proven safe.”

The regulatory process itself also deserves scrutiny. In 2021, the U.S. Court of Appeals for the D.C. Circuit found that the FCC had not adequately explained why its RF exposure limits protected against harmful non-cancer effects and had not sufficiently addressed evidence involving long-term exposure, children and environmental effects. A communications regulator should not be the final authority on complex questions of toxicology, developmental biology, neurology and public health.

Other countries have taken more precautionary approaches. Switzerland applies lower precautionary limits at certain sensitive locations, and France conducts post-market SAR testing of phones. The United States should not assume that decades-old limits remain adequate simply because they are familiar.

HHS should establish a truly independent research program with transparent funding and strict conflict-of-interest protections. Research should examine chronic and cumulative exposure, multiple simultaneous sources, direct body contact, pregnancy, children, pets, vulnerable populations, modern 4G/5G/Wi-Fi technologies, and biological outcomes at the cellular, tissue, organ and whole-body levels.

Public confidence cannot rest on assurances from agencies or industries. It must rest on independent science, transparent data, reproducible findings and standards that reflect how people actually live.

A compliance test is not a safety study. HHS has an opportunity to replace assumptions with modern, real-world health research and to protect children, families, animals and the environment using evidence that reflects actual exposure.