HHS-OASH-2026-0397-4280 https://www.regulations.gov/comment/HHS-OASH-2026-0397-4280 Docket HHS-OASH-2026-0397 Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure Question 2 – Perspective This comment is submitted by an individual with an interest in evidence-based public health. It draws on peer-reviewed literature, government and international agency assessments, and systematic reviews. Established findings are distinguished from emerging or uncertain evidence. Questions 5, 6, and 12 – Exposure standards, risk assessment, and evidence regarding effects at or below current federal limits Federal health agencies should consider the following established frameworks and evidence: • ICNIRP 2020 guidelines: The only substantiated adverse health effects of RF-EMF are those caused by tissue heating (thermal effects). The guidelines protect against all established adverse effects, including those relevant to 5G and other modern technologies. No adverse effects below the thermal threshold have been consistently substantiated in human populations at typical exposure levels. • U.S. FCC RF exposure limits (47 CFR 1.1310) and FDA assessments: These are based primarily on thermal effects (SAR). FDA has stated that the weight of scientific evidence does not support a causal link between RF exposure below these limits and cancer or other adverse health effects. • WHO-commissioned systematic reviews (2023–2025): Reviews of human observational studies on cancer (including glioma), cognition, reproduction, and non-specific symptoms generally found no or only small effects associated with RF-EMF exposure, with moderate certainty of evidence for the absence of increased brain tumor risk from mobile phone use. Confidence is lower for many other outcomes due to limited high-quality data. • IARC 2011 classification: RF-EMF is Group 2B (“possibly carcinogenic to humans”) based on limited evidence linking heavy mobile phone use to glioma and acoustic neuroma. This classification has not been upgraded. • NTP rodent studies (2018): These reported carcinogenic signals in male rats at high whole-body exposures well above typical human levels. Findings were not consistent across sexes or species, and methodological limitations have been noted by expert bodies. The results do not directly translate to typical human exposures below thermal limits. Established finding: At exposure levels below current thermal-based limits, there is no consistent, high-quality evidence of causal adverse health effects in the general population from everyday RF/EMF sources. Areas of uncertainty: Long-term effects beyond most study follow-up periods; cumulative multi-source real-world exposures; potential subtle non-thermal biological effects; and whether any subgroups experience effects not captured in population-level data. Question 11 – Sensitive populations Children warrant careful consideration due to potentially higher relative absorption in some tissues and longer lifetime cumulative exposure. Current evidence does not demonstrate harm at typical levels, but data specifically addressing developmental stages remain limited. Targeted research with personal dosimetry is warranted. Question 13 – Cumulative exposure patterns 5G, Wi-Fi, IoT, wearables, smart meters, and denser infrastructure create complex multi-source exposure patterns. Average levels generally remain well below thermal limits. Evidence on how these real-world combinations affect cumulative dose or health outcomes is still limited. Improved multi-source exposure characterization is needed. Question 16 – Highest-priority research gaps 1. Long-term prospective cohort studies of children and adolescents with individually measured personal RF exposure. 2. Improved real-world dosimetry for cumulative, multi-source exposures (including 5G characteristics). 3. Independent replication and mechanistic studies of any non-thermal signals using realistic exposure parameters. 4. High-quality blinded investigation of reported electromagnetic hypersensitivity. Question 17 – Coordination HHS (FDA, NIH, CDC) should coordinate with FCC and international bodies (WHO, ICNIRP) to prioritize independent research that can meaningfully update risk assessment. Question 18 – Additional recommendations Maintain clear public communication that distinguishes established thermal effects and the absence of confirmed adverse effects below limits from areas of residual uncertainty. Support practical exposure-reduction options for those who prefer them without implying established harm. Ensure any future guidance is driven by high-quality evidence.