HHS-OASH-2026-0397-6824
https://www.regulations.gov/comment/HHS-OASH-2026-0397-6824

'The number of studies showing adverse effects on living organisms induced by different types of man-made Electromagnetic Fields (EMFs) has increased tremendously. Hundreds of peer reviewed published studies show a variety of effects, the most important being DNA damage which is linked to cancer, neurodegenerative diseases, reproductive declines etc. Those studies that are far more effective in showing effects employ real-life Mobile Telephony (MT) exposures emitted by commercially available mobile phones. 
The present review - of results published by my group from 2006 until 2016 - compares DNA fragmentation induced by six different EMFs on the same biological system - the oogenesis of Drosophila melanogaster - under identical conditions and procedures. Such a direct comparison between different EMFs - especially those employed in daily life - on the same biological endpoint, is very useful for drawing conclusions on their bioactivity, and novel. It shows that real MT EMFs are far more damaging than 50 Hz alternating magnetic field (MF) - similar or much stronger to those of power lines - or a pulsed electric field (PEF) found before to increase fertility. 
The MT EMFs were significantly more bioactive even for much shorter exposure durations than the other EMFs. Moreover, they were more damaging than previously tested cytotoxic agents like certain chemicals, starvation, dehydration. Individual parameters of the real MT EMFs like intensity, frequency, exposure duration, polarization, pulsing, modulation, are discussed in terms of their role in bioactivity. The crucial parameter for the intense bioactivity seems to be the extreme variability of the polarized MT signals, mainly due to the large unpredictable intensity changes.

The number of published peer review studies showing DNA damage and related effects induced by Radio Frequency (RF)/microwave Electromagnetic Fields (EMFs), especially by Mobile Telephony (MT) EMFs, on a variety of organisms/cell types under different experimental conditions is increased considerably in recent years [1–36], in spite of attempts to dispute some of them [37–39].
Specifically, the damage on reproductive cells of different animals found in several of the above studies explains other findings connecting microwave EMF exposure with insect, bird, and mammalian (including human) infertility [40–48], or reduction in bird and insect (especially bees) populations during the past 10–15 years [49–53].
The effects on DNA and reproduction reported by different labs on a
variety of animals demonstrate a remarkable similarity. For example, Sharma and Kumar [47] found a large decrease in reproduction (egg laying) of bees after exposure to mobile phone radiation, which was identically observed before in fruit flies [15,16,41,42] and birds [49–51]. 
The recorded decreased reproduction is strongly corroborated by very similar effects in amphibians [54,55], rats [17,46], and human sperm [44]. This unique similarity of effects in different organisms found by different research groups can be explained by the observed cell death induction in reproductive cells due to DNA damage found for Drosophila ovarian cells [15,16], human sperm cells [22], mice and rat sperm cells [10,17], and chick embryos [36]. It is evident that such a similarity of findings is not a coincidence.

It is important to note that the exposure levels in the majority of the above studies were below the officially accepted exposure limits [56] and only in a few of them [4–6,13] they were slightly exceeding these limits.'
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https://www.researchgate.net/publication/331661949_Comparing_DNA_Damage_Induced_by_Mobile_Telephony_and_Other_Types_of_Man-Made_Electromagnetic_Fields