{"id":"HHS-OASH-2026-0397-2298","number":"2298","name":"Elizabeth Dunlap","organization":"","posted":"2026-10-10T04:00Z","received":"2026-10-09T04:00Z","body":"Re: HHS Request for Information on Electromagnetic Fields and RF Radiation\n\nMy name is Elizabeth Anne Dunlap, MSc. I hold a master's degree in Medical Visualisation and Human Anatomy from the University of Glasgow and Glasgow School of Art. I submit this comment as a medical visualisation specialist and an individual reporting severe electromagnetic sensitivity (ES).\n\n1. Health Experiences and Functional Impairment\n\nMy experience of ES has profoundly affected my ability to work, travel, obtain healthcare, maintain housing, and participate in society. I experience migraines, stabbing pain, dizziness, nausea, burning sensations, and disrupted sleep that I associate with nearby wireless devices and infrastructure. I have invested in wired Ethernet, removal of wireless equipment, electrical mitigation, and RF shielding.\n\nThese observations do not establish causation, but the functional limitations warrant clinical investigation. Scientific uncertainty should not justify dismissing patients or overlooking reasonable accommodations.\n\n2. Exposure Standards and Risk Assessment\n\nCurrent RF limits focus on established adverse effects associated with tissue heating. Questions remain about chronic, modulated, and cumulative exposures. The National Toxicology Program (2018) reported clear evidence of carcinogenic activity involving malignant cardiac schwannomas in male rats exposed to high levels of 900 MHz RF radiation. These results cannot be directly extrapolated to everyday human exposure but merit further study.\n\nHHS should independently review whether current standards adequately address long-term outcomes and susceptible populations.\n\n3. Exposure Measurement and Surveillance\n\nReal-world exposure includes simultaneous sources such as cellular infrastructure, Wi-Fi, smart meters, and connected devices. Measurements should document frequency, power density, field strengths, modulation, duty cycle, duration, and cumulative exposure.\n\nHHS should develop protocols combining personal dosimetry, environmental measurements, clinical observations, and longitudinal data. A voluntary ES registry could support epidemiological studies.\n\n4. Potentially Sensitive Populations\n\nChildren, pregnant women, older adults, people with implanted devices, occupationally exposed workers, and individuals reporting ES warrant focused study. Clinical evaluations should be multidisciplinary and respectful, investigating alternative explanations without dismissing symptoms.\n\n5. Biological Mechanisms and Scientific Evidence\n\nHuman tissues are intrinsically bioelectrical. Membrane potentials, ion gradients, and endogenous electric fields are fundamental to cardiac and neurological activity, cellular communication, and homeostasis. This does not establish that environmental RF causes injury, but supports investigation of possible interactions.\n\nResearch should examine membrane electrophysiology, ion channels, oxidative stress, autonomic regulation, blood-brain barrier integrity, and cellular homeostasis. Anatomically registered medical visualisation could help integrate exposure data with physiological measurements.\n\n6. Federal Research Priorities\n\nHHS should coordinate NIH, NIEHS, FDA, and CDC to:\n\n1. Fund independent, reproducible studies of biological effects, including exposures below current limits.\n2. Standardise clinical assessment of reported ES.\n3. Support prospective studies combining dosimetry, physiological measurements, symptoms, and appropriate controls.\n4. Investigate chronic and mixed-source exposures.\n5. Evaluate wired telecommunications and non-transmitting utility alternatives as accommodations.\n6. Publish methods, findings, funding sources, and conflicts of interest.\n\nConclusion\n\nScientific uncertainty must not become institutional indifference. For affected individuals, these questions concern housing, employment, healthcare, and participation in society. HHS should pursue rigorous, independent research that distinguishes established findings from hypotheses while taking functional impairment seriously. The objective is neither to presume harm nor presume safety, but to develop evidence-informed public health policy.\n\nElizabeth Anne Dunlap, MSc\nColorado, USA\n\nReference: National Toxicology Program (2018), Toxicology and Carcinogenesis Studies in Sprague Dawley Rats Exposed to Whole-Body Radio Frequency Radiation at 900 MHz, NTP TR 595. https://doi.org/10.22427/NTP-TR-595","attachments":[],"attachment_inventory":true,"withheld":false,"source":"https://www.regulations.gov/comment/HHS-OASH-2026-0397-2298","tags":["cancer-tumors","child-development","health-experiences","sleep-cognition","biology-metabolism","exposure-places","policy-standards","research-evidence"],"source_hash":"32ff3567bc724eae7b0953c7ad042443704b0a3a661749617c6b7766b228ca48","slug":"cancer-tumors-comment-2298","classification":{"id":"HHS-OASH-2026-0397-2298","body_sha256":"c5340169d5e09fe1b30830cd16363c9dcd7907f8b52766897543b1ae92a5747c","status":"ai_reviewed","primary_topic":"ehs","topics":[{"id":"ehs","evidence":"list and an individual reporting severe electromagnetic sensitivity (ES).\n\n1. Health Experiences and Functional Impairment\n\nMy "},{"id":"access","evidence":"ity to work, travel, obtain healthcare, maintain housing, and participate in society. I experience migraines, stabbi"},{"id":"research","evidence":"e NIH, NIEHS, FDA, and CDC to:\n\n1. Fund independent, reproducible studies of biological effects, including exposures below current li"},{"id":"standards","evidence":"Exposure Standards and Risk Assessment\n\nCurrent RF limits focus on established adverse effects associated with tissue"},{"id":"mechanisms","evidence":"uld examine membrane electrophysiology, ion channels, oxidative stress, autonomic regulation, blood-brain barrie"},{"id":"neurological","evidence":"nd participate in society. I experience migraines, stabbing pain, dizziness, nausea, burning sensations, and "},{"id":"optical","evidence":" and infrastructure. I have invested in wired Ethernet, removal of wireless equipment, electrical mitigation, and "},{"id":"children","evidence":"\n\n4. Potentially Sensitive Populations\n\nChildren, pregnant women, older adults, people with implanted device"},{"id":"occupational","evidence":" adults, people with implanted devices, occupationally exposed workers, and individuals reporting ES warrant focused study. Clinic"},{"id":"cancer","evidence":"ogram (2018) reported clear evidence of carcinogenic activity involving malignant cardiac schwannomas in male rats expose"}],"summary":"A medical visualisation specialist describes severe electromagnetic sensitivity and barriers to work, housing and care, and proposes independent research, exposure monitoring and accommodations while distinguishing personal observations from established causation.","reviewed_at":"2026-10-11T14:25:48Z","review_method":"Complete published comment-body review with neutral attributed summaries and exact topic evidence; external attachments and links not reviewed.","review_source_sha256":"d7e777d9f30b0c2c0f0b334385a352142bfcc3587fff94c27de1481ba06c476b","source_url":"https://rfsafe.net/hhs-comments/data/catalog.json","scope":"Original comment body; attachments excluded"},"forum_topics":["ehs","access","research","standards","mechanisms","neurological","optical","children","occupational","cancer"],"primary_topic":"ehs","forum_title":"A medical visualisation specialist describes severe electromagnetic sensitivity and barriers to work, hou…"}