HHS-OASH-2026-0397-5304
https://www.regulations.gov/comment/HHS-OASH-2026-0397-5304

U.S. Department of Health and Human Services

Re: Public Comment on Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure

Docket No.: HHS-OASH-2026-0397

To Whom It May Concern:

I am sharing my experience as HHS considers whether research and federal safety standards adequately address exposure to electromagnetic fields (EMFs), radiofrequency (RF) radiation, and wireless technologies.

In 2015, at age 33, I began experiencing blurred vision. I suspected my LASIK surgery from three years earlier might be reverting. I scheduled an appointment with Dr. J. James Rowsey, a pioneering refractive surgeon at St. Michael's Eye and Laser Institute in Largo, Florida.

Dr. Rowsey helped develop laser treatments for myopia beginning in 1988 and previously chaired Ophthalmology at the University of South Florida. Following examinations, including a visual field test, he suspected a brain lesion. An MRI confirmed a pituitary tumor pressing against my optic nerve and causing blurred vision.

Dr. Rowsey referred me to neurosurgeon Dr. Carrie Shulman, who trained at Walter Reed Medical Center, served as a U.S. Army neurosurgeon, and was Neurosurgical Director during Operation Iraqi Freedom. Her experience gave me confidence before surgery.

During an office visit before my transsphenoidal endoscopic resection of the tumor, I asked Dr. Shulman whether she had any theories about its cause. Medical literature indicated that the causes of pituitary tumors were largely unknown, although some research suggested approximately 10% of the population might have them, often without symptoms.

Dr. Shulman's response has stayed with me for more than a decade.

She believed the next ten years would bring greater awareness of the potential health effects of cellphone radiation, comparing it to the evolving understanding of cigarette smoking and its consequences. She explained that cellphones emit RF radiation and expressed her personal belief that exposure could contribute to tumor development.

She also shared her precautions: never holding a cellphone against her head during conversations, avoiding wireless earbuds, and keeping her phone in another room while sleeping.

In the years that followed, as Dr. Shulman predicted in 2015, several studies raised questions about the potential carcinogenic effects of RF radiation. These included the U.S. National Toxicology Program's Toxicology and Carcinogenesis Studies in Rats Exposed to Cell Phone Radiofrequency Radiation (2018); Falcioni et al.'s Report of Final Results Regarding Brain and Heart Tumors (Ramazzini Institute, 2018); Carlberg and Hardell's Evaluation of Mobile Phone and Cordless Phone Use and Glioma Risk (2017); Choi et al.'s Cellular Phone Use and Risk of Tumors: Systematic Review and Meta-Analysis (UC Berkeley collaboration, 2020); and Mevissen et al.'s Effects of Radiofrequency Electromagnetic Field Exposure on Cancer in Laboratory Animal Studies: A Systematic Review (2025).

Notably, the 2018 NTP study reported increased pituitary adenomas in some RF-exposed male rats. Though classified as equivocal evidence, it still warrants further investigation.

In 2017, the California Department of Public Health issued guidance acknowledging that studies raised concerns about possible links between long-term cellphone RF radiation exposure and certain cancers and other health effects. It recommended precautions to reduce exposure. Additionally, the World Health Organization's International Agency for Research on Cancer classified radiofrequency electromagnetic fields as possibly carcinogenic to humans (Group 2B) in 2011.

Cellphone technology has benefited society over the past 30 years, transforming communication, business, information access, and emergency response. These benefits should not prevent investigation of potential long-term health consequences.

I believe telecommunications companies and cellphone manufacturers should take a more proactive role in addressing potential health risks through independent research, technologies that minimize unnecessary RF exposure, and clear consumer information about possible risks and precautions.

Through God's grace and the God-given skills of physicians like Dr. Rowsey and Dr. Shulman, I am here today to share my experience. Eleven years after surgery, I am thankful to report no recurrence of my pituitary tumor since 2019—seven years of encouraging post-op results.

I respectfully encourage HHS to investigate long-term RF exposure, potential cancer risks, and effects on children and vulnerable populations, while examining whether existing safety standards and consumer disclosures adequately reflect these potential risks.

Thank you for considering my experience. I sincerely hope it contributes to a better understanding of RF exposure and helps protect the health and well-being of the American public.

Respectfully,

Rich Fernley