A forensic engineer requests reproducible real-world exposure assessment and disclosure, questions newer …

Perspective (Q2): State-licensed professional engineer; forensic engineer and expert witness. Background I am a state-licensed Professional Engineer, B.S. Civil Engineering. I perform forensic investigations and evidence collection for causation analysis, and have prepared expert reports and been cross-examined on them. In 30 years of construction and civil engineering experience, I have managed the handling, cleanup, and legal disposal of a wide variety of environmental toxins, including PCBs, lead, asbestos, hazardous chemicals, and special waste. I have U.S. NRC radiation training and have performed engineering work at U.S. nuclear power facilities. Performed close interval surveys (CIS) and direct current voltage gradient (DCVG) surveys to determine elevated voltage potentials and stray current along utility corridors. Managed pipeline current mapping (PCM) projects using RF equipment to determine current leakage and pipe construction defects. Analyzed EMF field surveys, electromagnetic modeling, counterpoise design, and corrective actions by the local power provider and railway operator to mitigate induced AC voltages on commuter railroad tracks during repair and replacement operations, protecting railway worker health and safety. Managed development and installation of devices at nuclear power plants used to monitor buried pipe networks for cathodic protection effectiveness under NRC and industry integrity programs. Performed field evaluations at nuclear power plants and other industrial sites of piping systems for electrochemical corrosion and stray current using radio frequency and electrical resistance testing equipment. Q5(p), Q7, Q8: Exposure characterization Real-world RF/EMF exposure varies continuously in power, duty cycle, pulse modulation, and compounding multi-source overlap. Most lab and animal studies, including NTP, used artificial signals from laboratory signal generators at fixed parameters, not real device emissions. Time-averaged power density and whole-body SAR do not capture peaks, pulse characteristics, duty cycle, or cumulative multi-source exposure. Assessments should measure and report them. Industry-funded RF/EMF exposure surveys and compliance testing, including cell phone carrier site compliance reports, should disclose the instrument, bandwidth, detector type (RMS vs. peak), averaging time, calibration, uncertainty, and measurement locations. Reports that omit these cannot be independently reproduced or verified. HHS should give them no weight until raw data are available for third-party review. Power-frequency magnetic fields: developers and permitting agencies cite ICNIRP’s 2010 guideline (2,000 mG) as health-based. It protects only against acute nerve stimulation, not long-term exposure. IARC classified these fields Group 2B (2002) on childhood leukemia associations near 3-4 mG, about 500 times lower. It also does not protect implanted medical devices: ICNIRP states compliance “may not necessarily preclude interference with... cardiac pacemakers and implanted defibrillators.” Q6, Q12, Q16: Weighting negative studies In forensic practice, a test that could not have detected a condition does not prove its absence. Absence of evidence from an insensitive design is not evidence of absence. The 2026 Japan and Korea “validation” studies fail that test. They departed from the NTP design in three important ways (Melnick et al., Environ Health 25, 66, 2026): Omitted high dose. They tested a single exposure level (4 W/kg) and dropped NTP’s highest level (6 W/kg), where its carcinogenic effects were most pronounced. Departed from FDA and OECD guidelines. Both require at least three dose levels plus a control for dose-response trend analysis. A single-dose design cannot detect a dose-dependent trend. Overlooked signal. Despite limited power, the Korean study found heart schwannomas in 3% of exposed rats versus 0% of controls, matching NTP’s incidence at 3 W/kg, yet the authors dismissed it. These studies cannot override the 2018 NTP two-year study (TR-595), which found “clear evidence” of malignant heart schwannomas in male rats and “some evidence” of brain gliomas and adrenal tumors. HHS should not treat a study as refuting a positive finding unless it matches or exceeds the original’s sensitivity: same animal model, comparable group sizes, multiple doses, and documented statistical power. Q16, Q17: Research priorities Fund new animal studies that repeat NTP at equal or larger scale with three or more exposure levels, run by scientists with no financial ties to the wireless industry or to the bodies that set the limits being tested. Fund exposure studies that replicate real-world conditions: variable signals from actual phones, routers, and towers, and compounding exposure from many simultaneous devices in high-occupancy settings such as classrooms. Require studies HHS relies on to disclose who funded and advised them.