HHS-OASH-2026-0397-1654
https://www.regulations.gov/comment/HHS-OASH-2026-0397-1654

This comment is submitted by Cindy Sage, Co-Editor, BioInitiative Reports 2007 and 2012 (and Updates) on behalf of the BioInitiative Working Group.

The BioInitiative Report link is www.bioinitiative.org and is incorporated by reference due to its file size.

The BioInitiative Report is an internationally acclaimed scientific and public health report on potential health risks of electromagnetic fields and radiofrequency/microwave radiation.  In 2007, the BioInitiative Working Group released a 650-page report citing more than 2000 studies that document health effects of EMFs from all sources.  The BioInitiative 2012 Report has been prepared by 29 authors from ten countries*, ten holding medical degrees (MDs), 21 PhDs, and three MsC, MA or MPHs. Among the authors are three former Presidents of the Bioelectromagnetics Society and five full members of BEMS. One distinguished author is the Chair of the Russian National Committee on Non-Ionizing Radiation. Another is a Senior Advisor to the European Environmental Agency.  Membership in the BioInitiative Working Group includes Sweden (6), USA (10), India (2), Italy (2), Greece (2), Canada (2), Denmark (1), Austria (2), Slovak Republic (1), Russia (1)

The BioInitiative Report was produced for publication to the broadest possible audience, hence placed on the Web and offered for free.  Much of the BioInitiative Report content, including updated chapters and new chapters was later published in a special two-volume issue of the journal Pathophysiology to verify the quality of its science (August 2009, Pathophysiology 16: 2,3).   In 2013, the BioInitiative 2012 chapter on Autism and EMF was also published in two parts, in the peer-reviewed journal Pathophysiology. 


The BioInitiative 2012 Report concludes that the evidence for health risks from electromagnetic fields (EMFs) generated by wireless technologies have substantially increased since 2007.  A review of over 1800 new scientific studies indicates current guidelines are inadequate to protect the public from chronic exposure to very low-intensity (non-thermal) electromagnetic fields and radiofrequency radiation (EMF and RFR).  

In twenty-four technical chapters, the BioInitiative 2012 Report discusses the content and implications of about 1800 new studies since 2007.  Overall,  these new studies report abnormal gene transcription (Section 5); genotoxicity and single-and double-strand DNA damage (Section 6); stress proteins because of  the fractal RF-antenna like nature of DNA (Section 7); chromatin condensation and loss of DNA repair capacity in human stem cells (Sections 6 and 15);  reduction in free-radical scavengers - particularly melatonin (Sections 5, 9, 13, 14, 15, 16 and 17); neurotoxicity in humans and animals (Section 9); carcinogenicity in humans (Sections 11, 12, 13, 14, 15, 16 and 17); serious impacts on human and animal sperm morphology and function (Section 18); effects on the fetus, neonate and offspring (Section 18 and 19); effects on brain and cranial bone development in the offspring of animals that are exposed to cell phone radiation during pregnancy (Sections 5 and 18); and findings in autism spectrum disorders consistent with EMF/RFR exposure effects.  Global precautionary actions that have been taken in countries around the world, and recommended by medical and research experts are documented in Section 22.  Use of the Precautionary Principal and its relevance are presented in Section 23.  Key scientific evidence and public health policy recommendations are in Section 24.

Attached file:
Pathophysiology Full Edition.pdf
(August 2009, Pathophysiology 16: 2,3)