HHS-OASH-2026-0397-0875
https://www.regulations.gov/comment/HHS-OASH-2026-0397-0875

Docket No. HHS-OASH-2026-0397

To Whom It May Concern;

My full comment is attached as a PDF. This note summarizes it.

I am a retired paramedic and firefighter with over thirty years of service. I worked in fire stations that had commercial wireless antenna arrays mounted on the building. I am not reporting an adverse health effect and I have no diagnosis to attribute to that exposure. What I am submitting is an exposure characterization and a research gap.

Career fire service personnel do not visit the station, they live in it. They sleep there, in a fixed location, for twenty-four and forty-eight hour shifts, across careers measured in decades. Where a commercial base station sits on that building, the result is a continuous, fixed-geometry, decades-long exposure to a population that occupies the structure far more hours per year than an ordinary workplace and is unconscious for a large share of them. They fall under the general public exposure limit, which was built around a public assumed to be passing through. Under Section 704 of the Telecommunications Act of 1996 their employer is barred from declining the installation on health grounds.

In August 2004 the International Association of Fire Fighters adopted Resolution No. 15, asking the federal government for a study "with the highest scientific merit and integrity" contrasting firefighters housed in stations with towers against firefighters without that exposure. It committed the organization to set policy in accordance with whatever the study found. The study was never funded and no federal agency has conducted it. I held elected office in that organization on both sides of that date, and no study came.

The federal fire service assessment answering that request, the U.S. Fire Administration's 2008 Executive Fire Officer paper, rests on an evidence base that predates the IARC Group 2B classification of 2011, the National Toxicology Program's finding of clear evidence of carcinogenic activity in 2018, the Ramazzini Institute's independent base-station-model replication in 2018, and the D.C. Circuit's 2021 holding in Environmental Health Trust v. FCC that the Commission failed to justify retaining its 1996 exposure limits. It has not been revisited in eighteen years.

I am asking the Department to fund and conduct that cohort study, to characterize aggregate occupational RF dose across the fire and EMS environment, to assess the ambulance patient compartment as an RF environment with attention to implanted cardiac devices, and to recommend mandatory pre-activation and post-activation RF survey with disclosure to the personnel assigned to those buildings.

The attached comment answers Questions 2, 3, 4, 5, 11, 12, 15, 16 and 17, with citations.

Thank you for the opportunity to comment.

Michael T. Wilson
Carson City, Nevada
Retired Paramedic and Firefighter