{"id":"HHS-OASH-2026-0397-5425","number":"5425","name":"Sarah A","organization":"","posted":"2026-10-27T04:00Z","received":"2026-10-21T04:00Z","body":"As an American physician, I am deeply concerned that U.S. electromagnetic field (EMF) exposure standards have not been updated since 1996 and address only thermal effects. In a rapidly evolving wireless environment, outdated guidelines warrant rigorous reassessment. Current permitted exposure levels exceed recommendations from building biologists and most other countries. As cell towers, 5G, Wi-Fi, Bluetooth, smart meters, electric vehicles, and other wireless technologies proliferate, finding places with reduced exposure is increasingly difficult for sensitive individuals. Dismissing validated non-thermal effects simply because this radiation is non-ionizing ignores biologically important interactions.\nMy own experience with electrohypersensitivity (EHS), since 2017, has included insomnia, migraines, lightheadedness, trigeminal neuropathy, and tinnitus, associated with nearby Bluetooth devices, cell towers or transformer stations. I reduce exposure to cope: avoiding housing near towers, limiting Bluetooth, using wired headphones and computer peripherals, keeping devices on airplane mode, disabling Wi-Fi overnight. I have had to leave certain hotels and forgo modern conveniences such as smart-home devices and electric vehicles. Even ordinary appliances increasingly incorporate unnecessary and unavoidable wireless or bluetooth connectivity (air filters, electric toothbrushes, etc), making exposure reduction difficult.\nThe expansion of data centers is concerning due to EMFs from the facilities themselves and associated high-powered electrical infrastructure. Public participation in decisions about cell towers, power lines, and data centers is extremely limited (my own community fighting a data center build with the guise of public input,) leaving residents with little control over exposures.\nMy patients have described a range of concerning experiences: man in his 40s with occupational exposure linked radiation-associated cancer; mid-aged female with cognitive decline and severe EHS after a transformer was installed near her home; a veteran whose military exposures have forced him into homelessness and food insecurity in Minnesota's winters as he can't tolerate electricity; and a couple with sudden insomnia after a smart meter was installed outside their bedroom, resolved after its relocation. In my clinical experience, commonly reported symptoms include insomnia, headaches, neuralgias and arrhythmias, which can substantially affect quality of life. These accounts warrant compassionate care and further investigation, not the ridicule and diagnosis of \"functional\" symptoms that have accrued.\nSpecific absorption rate (SAR), commonly used to assess radiofrequency exposure, has serious limitations. Standardized testing doesn't represent real-world conditions- device position, body shape, tissue density, age, or differences between men, women and children. Furthermore, the cumulative effects of living in a highly connected environment remain insufficiently characterized. Exposure can come from multiple sources simultaneously, including phones, 5G infrastructure, Wi-Fi, Bluetooth, computers, televisions, smart meters, electric vehicles, chargers, and electrical systems. Compliance with individual-device limits does not necessarily resolve questions about combined, long-term exposure.\nInternational exposure standards vary, and some countries impose magnitudes of power greater restrictions on EMF exposure limits and wireless infrastructure near sensitive locations such as schools and hospitals. National Toxicology Program animal studies have brought concerns of chronic cell-phone radiation exposure and cancer risk, the need for additional human research, and the outdated nature of U.S. standards. Resources such as Physicians for Safe Technology discuss these issues as well.\nBiological mechanisms of harm include changes in oxidative and nitrosative stress, mitochondrial dysfunction, blood-brain barrier permeability, genotoxicity, immune-system effects, cell-membrane signaling, voltage-gated calcium-channel activity, inflammatory pathways, magnesium depletion, nitric oxide signaling, changes in neurotransmitters and receptors, including NMDA, dopamine, and serotonin, microbiome alterations, hepatic lipid metabolism and blood glucose regulation, mast-cell activation, depletion of antioxidants such as glutathione, oxidation of LDL cholesterol and altered prenatal brain development and fertility. These proposed mechanisms could have implications for neurological, cardiovascular, hormonal, metabolic, immune, and reproductive health. \nI urge updated, independent, and transparent reviews of standards regarding long-term, cumulative, and real-world exposures. Protecting public health requires neither dismissing patients' experiences nor the scientific data that exists. It requires rigorous science and standards that evolve alongside technology and it's unfathomable that no meaningful updates have been made in 30 years. ","attachments":["https://downloads.regulations.gov/HHS-OASH-2026-0397-5425/attachment_1.pdf"],"attachment_inventory":true,"withheld":false,"source":"https://www.regulations.gov/comment/HHS-OASH-2026-0397-5425","tags":["cancer-tumors","child-development","health-experiences","sleep-cognition","biology-metabolism","exposure-places","policy-standards","research-evidence"],"source_hash":"09bb43515dca57d57156bfb4267f8bffb8186e3c22b0ebe6d73505a5f8202ff4","slug":"cancer-tumors-comment-5425","classification":{"id":"HHS-OASH-2026-0397-5425","body_sha256":"fb18e6295ab04d5d30e90aed22cc604e1d78ca11b0d5eb66900b70cbdb8dc4ac","status":"ai_reviewed","primary_topic":"standards","topics":[{"id":"standards","evidence":"I urge updated, independent, and transparent reviews of standards regarding long-term, cumulative, and real-world exposures."},{"id":"ehs","evidence":"My own experience with electrohypersensitivity (EHS), since 2017"},{"id":"neurological","evidence":"insomnia, migraines, lightheadedness, trigeminal neuropathy, and tinnitus"},{"id":"mechanisms","evidence":"Biological mechanisms of harm include changes in oxidative and nitrosative stress, mitochondrial dysfunction"},{"id":"electricity","evidence":"EMFs from the facilities themselves and associated high-powered electrical infrastructure."},{"id":"research","evidence":"the need for additional human research"}],"summary":"A physician reports personal EHS and patients’ exposure-related experiences, questions thermal-only standards and real-world testing, and outlines proposed biological mechanisms. Requests independent review of cumulative exposure, updated limits and compassionate investigation of patients’ symptoms.","reviewed_at":"2026-10-27T19:20:49Z","review_method":"Full comment-text review with exact source evidence; attachments not reviewed","review_source_sha256":"0f395d146e18e62667a710691b247079ccf2e0357444dc405b94997e646acc61","source_url":"https://rfsafe.net/hhs-comments/data/catalog.json","scope":"Original comment body; attachments excluded"},"forum_topics":["standards","ehs","neurological","mechanisms","electricity","research"],"primary_topic":"standards","forum_title":"A physician reports personal EHS and patients’ exposure-related experiences, questions thermal-only stand…"}