HHS-OASH-2026-0397-5461
https://www.regulations.gov/comment/HHS-OASH-2026-0397-5461

Dear HHS Team,

Re: your question No. 5, I co-founded Hilltown Health (hilltownhealth.org), a safe technology advocacy organization in Western MA, more than a decade ago following my wife's developing electromagnetic radiation syndrome (EMR-S) in 2010. 

We made a film about the above experience, under the auspices of the theatre company we co-founded in 2004 called "Canary in a Gold Mine" which was released several years ago (ptco.org/canary)

In short, Hilltown Health has been collaborating with local planning boards to strengthen and update telecom by-laws as well as advocating for more transparency about RF/EMF health effects given the recent rollout of "smart" meters by our utilities, Eversource and National Grid. We have also reached out to school administrators about the involuntary exposure of school age children in classrooms.

There are decision makers who receive evidence of harm (for example, the National Toxicology Program cell phone study: https://ntp.niehs.nih.gov/research/topics/cellphones or this review of health effects on children and pregnant women:
https://www.frontiersin.org/journals/public-health/articles/10.3389/fpubh.2026.1915745/full) and are concerned enough to take action. However, many people in decision making positions, for a wide variety of reasons, have not taken any protective measures on behalf of the people for whom they are responsible.

Perhaps the most significant reason for inaction is that the concerned federal agencies have generally indicated that the current exposure standards are protective. The majority of the public thinks the wireless devices they are buying (or installing in the case of educational institutions) have undergone some kind of government testing to ensure that long term exposures are safe.

Of course, there has been no such testing. The technology is still too new to fully understand the cradle to grave impacts of 24X7, 365 days a year exposure. And the current "safety standards" were based on a test of one hour or less on a group of animals in the 1980's (see slide 19 of Dr. Kent Chamberlin's public talk in Greenfield, MA entitled "Smart Meters: Health, Safety and Opting-Out" given on November 13, 2025 just before smart meters were installed in Western MA with most residents either not knowing that opting out was an option, not realizing there was any cause for concern about wireless exposure from the meter or accompanying infrastructure or simply not being able to afford the opt out fee despite not wanting to be harmed in their home: https://www.hilltownhealth.org/wp-content/uploads/2025/11/Chamberlin-Slides.Smart-Meter-Presentation.Greenfield.pdf

This has created a wild west atmosphere with huge amounts of money at stake and led to public comments, for example by a designer of the smart grid for one of our state utilities that he is not aware of any "credible research" indicating health impacts. 

We know there are thousands of studies going back to the US Navy research in the 1970's documenting health impacts: https://zoryglaser.com/

But the lack of any clear government guidance beyond a general denial / dismissal on the part of the FCC of there being any health effects emboldens those who have been charged by their corporations to maximize profit. In other words, there is a large scale game of "passing the buck" as in, "if you are concerned, take it up with the FCC." And the FCC saying that they rely on organizations like the International Commission on Non-Ionizing Radiation Protection (ICNIRP) comprised of industry-funded scientists as is well documented in the documentary "Microwaves, Science and Lies": https://vimeo.com/89144337

Meanwhile, my wife's life and the lives of many, many others have been decimated or simply lost in the case of victims of cell phone induced glioma: https://ehtrust.org/science/cell-phone-radiation-linked-to-brain-cancer-and-tumors-published-science/

Thank you for taking prompt action to rectify this inhuman situation which so closely resembles many other US public health disasters fueled by profits and captured agencies, ie, tobacco, Agent Orange, lead, the automobile industry before Nader, DDT, etc.

In addition to updating the safety standards, thank you for considering, the design of "off ramps" for stakeholders who are justifiably concerned about massive losses in class action suits if they were to acknowledge wireless injury. Just as auto makers wound up competing on safety, the wireless industry is very capable of doing the same in the context of a thoughtful policy environment. In the long term, they will be grateful for your help. The engineers and PR people doing the day to day work @ Big Tech are not motivated by the opportunity to harm. But most people are not eager to lose their employment which is currently the bind any potential whistleblower would find themselves in. 

And thank you for your service.