Docket HHS-OASH-2026-0397. Q2 perspective: individual consumer. Answers Q5(o), 5(p), 6, 8, 11(a), 12, 13,…

Docket HHS-OASH-2026-0397. Q2 perspective: individual consumer. Answers Q5(o), 5(p), 6, 8, 11(a), 12, 13, 16. Labels: [GR] government report, [PR] peer-reviewed; status ESTABLISHED, EMERGING or UNCERTAIN. SUMMARY. U.S. limits (FCC, last updated 1996) guard against heating: a 4 W/kg animal threshold cut about 50-fold [GR, ESTABLISHED]. Federal bodies have questioned whether they cover chronic, body-contact or childhood exposure (FDA 1999, GAO 2012, D.C. Cir. 2021). FDA told NTP in 1999 there was "insufficient scientific basis for concluding either that wireless communication technologies are safe or that they pose a risk" [GR]. We believe that remains the honest state of knowledge, and it calls for research and prudence. 1. CELLULAR EFFECTS AT OR BELOW LIMITS (Q6, Q12) [EMERGING] - NCRP Report 86 (1986): athermal interactions "have been demonstrated for fields both strong and weak" [GR]. - Swiss BERENIS (2021): "the majority of the animal and more than half of the cell studies provided evidence of increased oxidative stress" (RF and ELF studies pooled), some "below the regulatory limits"; harm is likelier when redox balance is disturbed "over a long period of time." It notes study weaknesses [GR]. - Volkow, JAMA 2011: 50 min of phone exposure raised brain glucose metabolism near the antenna (P=.004), "of unknown clinical significance" [PR]. - Schmid, J Sleep Res 2012: "both pulse-modulated radio frequency and pulsed magnetic fields affect brain physiology" (sleep EEG) [PR]. Signal pattern, not only power, matters (Q5(p)). - Lerchl, BBRC 2015: in carcinogen-treated mice, liver tumors rose at 0.04 W/kg (half the 0.08 W/kg whole-body limit) and lung tumors at 0.4 W/kg, replicating Tillmann 2010; no dose-response [PR]. - NTP TR-595 (2018): "clear evidence" of heart schwannomas in male rats [GR]; NIEHS cautions the findings "should not be directly extrapolated to human cell phone usage." These are biological signals; whether they cause disease in people is UNCERTAIN. 2. LONG-TERM EXPOSURE IS UNTESTED (Q6, Q16) [ESTABLISHED gap] - FDA 1999: limits "may not be protective against any non-thermal effects of chronic exposures" [GR]. - UK AGNIR 2012: human data "essentially restricted to periods of less than 15 years from first exposure" [GR]. - COSMOS 2024 (264,574 adults) found no glioma link, but median follow-up was 7.12 years [PR]. INTERPHONE's heaviest users: OR 1.40 (1.03-1.89); authors: "biases and error prevent a causal interpretation" [PR]. - D.C. Circuit (EHT v. FCC, 2021) held the FCC's non-cancer reasoning "arbitrary and capricious" and remanded on children and long-term exposure. - NIEHS has "no further plans to conduct additional RFR exposure studies." IARC (2024) made RF re-evaluation a high priority, advised for the latter half of 2025-2029. 3. THE LEVELS WE NOW HAVE (Q8, Q11(a), Q13) - Ambient levels are low: European homes and outdoors average 0.16-0.76 V/m, "substantially below regulatory limits" (Sagar 2018) [PR, ESTABLISHED]. - The highest doses come from devices on the body. France's ANSES (2019): of 272 phones tested touching the body, "206 telephones (76%) had trunk SAR values above 2 W/kg," maximum 7.42 W/kg (European test basis) [GR, ESTABLISHED]. - GAO-12-771: U.S. test practice "could result in RF energy exposure higher than the FCC limit"; its recommendations remain "Closed - Not Implemented" [GR]. - Children: modelled local fields ">3 dB" higher in brain subregions and ">10 dB" in bone marrow (Christ 2010) [PR, modelling]. - Exposures from separate devices are not summed (FCC 19-126, para 23), and limits stop at 100 GHz (85 FR 19117). 4. REQUESTS (Q5(o), Q16), under HHS's duty to minimize "unnecessary" exposure (21 U.S.C. 360ii(a)(2), (a)(5)): a) Fund lifetime and multigeneration animal studies at sub-limit SARs using current 4G/5G signals, replicating NTP and Lerchl, with oxidative-stress and DNA endpoints. b) Fund a prospective child cohort with personal dosimeters and 20+ years of follow-up. c) Ask FDA and FCC to require SAR tests at 0 mm, with child models and summed multi-device exposure. d) Meanwhile, publish plain distance-and-use guidance, especially for children and pregnancy. CONCEDED: Japanese and Korean 2026 rat studies were null, COSMOS was null, ANSES (2025) found it "not possible to conclude" on cancer, and a 2024 systematic review found male-fertility evidence "very uncertain" (Kenny). That uncertainty argues for research and prudence, not complacency. Full references with links in attachment, if accepted.