HHS-OASH-2026-0397-6404
https://www.regulations.gov/comment/HHS-OASH-2026-0397-6404

To the U.S. Department of Health and Human Services:I submit these comments on the HHS Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure (HHS-OASH-2026-0397). I urge HHS to evaluate the substantial evidence of biological effects and potential adverse health outcomes from RF/EMF exposures, including levels below current federal limits, and to identify research gaps and protective recommendations, especially for children and vulnerable populations.Personal ExperienceMy bedroom is about 20 feet from a neighbor’s smart meter. Since its installation I have suffered severe debilitating headaches, muscle spasms, cramps, occasional heart palpitations, and other unusual sensations. These symptoms align with scientific literature on non-thermal biological effects of RF radiation and non-ionizing EMFs.Scientific Evidence (Resources Incorporated by Reference)Electrosensitivity: Functional MRI studies by Dr. Gunnar Heuser et al. (Reviews on Environmental Health, 2017) found abnormal scans in all 10 patients with electromagnetic hypersensitivity after long-term EMF exposure, showing consistent hyper-connectivity in the anterior default-mode network. Conventional MRI was largely normal. The authors proposed fMRI as a diagnostic aid. Prevalence studies in Australia, Canada, and the U.S. further document wireless sensitivity and co-morbidities.Industry acknowledgment of non-thermal effects: Swisscom patent WO2004075583A1 addresses electrosmog as a known health problem, cites non-thermal DNA damage and chromosomal instability in human blood cells linked to cancer risk, and proposes emission-reduction methods. The 2000 ECOLOG Institute review for T-Mobile (over 220 studies) found strong evidence of cancer-initiating/promoting effects, DNA breaks, chromosomal damage, fertility impacts, and teratogenic effects far below then-existing guidelines, and recommended much lower precautionary limits.Comprehensive reviews: The BioInitiative Report (2007/2012 and updates) documents DNA damage, neurological, cancer, reproductive, and immune effects at levels far below FCC/ICNIRP limits and calls for biologically based standards. Additional reviews cover neurological/cognitive effects, male fertility, impacts on children, parotid gland tumors, glioma associations, cell-tower epidemiology, and wildlife effects (bees, birds, etc.).DNA, cancer, and other effects: Studies show DNA damage, oxidative stress, and non-thermal mechanisms. U.S. National Toxicology Program research reported statistically significant tumor increases (including heart schwannomas) with RF exposure. Literature also addresses effects on implanted medical devices.Emerging technologies: Patents and programs on wireless body-area networks, nano-sensors/devices, brain-computer interfaces (including DARPA non-surgical neurotech), and bio-nano systems raise unanswered questions on cumulative health effects, safety data, and informed consent. Havana Syndrome cases among federal employees further highlight the need to evaluate directed-energy and pulsed RF exposures.Regulatory history: Older industry manuals, EPA correspondence, GAO reports, NIOSH materials, and prior FCC documents show longstanding awareness of potential non-thermal effects. Current U.S. limits, largely unchanged since 1996 and based on thermal thresholds, do not adequately address today’s continuous, multi-source, pulsed exposures from phones, Wi-Fi, 5G/6G, IoT devices, and wearables.Key Responses to the RFI
Science and effects below limits: Peer-reviewed evidence, industry patents, and reviews show genotoxic, neurological, reproductive, and immune effects at non-thermal levels. Thermal-only standards are insufficient.
Cumulative exposures: Real-world simultaneous multi-source exposures are not adequately reflected in current testing or limits.
Vulnerable groups: Children, people with electrosensitivity, and those with implanted devices require special attention.
Research gaps: Independent studies are needed on electrosensitivity (with objective markers such as fMRI), long-term low-level and cumulative exposures, nano/bio-interfaces, environmental impacts, and device interactions—free of industry conflicts of interest.
Recommendations: Support biologically based limits with safety margins, real-world testing protocols, transparent public information, wired alternatives where feasible, accommodations for sensitive individuals, and coordinated federal research. The precautionary principle is appropriate given widespread exposure and available risk-reduction options.
I urge HHS to treat this evidence seriously, close research gaps, and develop health-protective recommendations for policymakers, families, schools, and communities. All Exhibits are incorporated by reference in their entirety.

Thank you for the opportunity to comment.

Respectfully submitted,