{"id":"HHS-OASH-2026-0397-1288","number":"1288","name":"","organization":"Australian College Environmental Studies","posted":"2026-10-05T04:00Z","received":"2026-10-01T04:00Z","body":"Submission to Docket HHS-OASH-2026-0397: Request for Information on Electromagnetic Fields, Radiofrequency Radiation, and Wireless Radiation Exposure\n\nSubmitted by: Dr Nicole Bijlsma, PhD, Environmental-Health Educator and Researcher, Melbourne, Australia\n\nI am writing as a researcher, educator and practitioner who has spent the past 25 years assessing homes for environmental-health hazards. I have also been personally affected by EMF exposure.\n\nI developed persistent sleep problems within 2 weeks of moving into our first home. I eventually realised (after 7 years and ten miscarriages - no explanation was provided by the medical industry and we didnt qualify for IVF), we were sleeping adjacent to the meter panel. I purchased a triple axis digital gauss meter and found elevated AC magnetic fields on the bed during the early hours of the morning (when the hot water system was in use). We consequently relocated to another bedroom - sleep improved and I successfully carried a twin pregnancy to term. The fix was simple and cost nothing. I subsequently established the Australian College of Environmental Studies in 1999, and have spent the past 25 years teaching students how to undertake home assessments for mould, electromagnetic fields, allergens and toxicants. Poor sleep is one of the most common complaints I see where EMF exposure is a factor. The two sources I find most often are: radiofrequency radiation from Wi-Fi routers and wireless-enabled devices kept in or near bedrooms, often running all night; and AC magnetic fields from meter panels, switchboards and wiring, including where smart meters are installed on the other side of a bedroom wall. Reducing exposure in the bedroom is frequently followed by reports of better sleep. Typical steps are moving the bed, switching off Wi-Fi at night and using wired connections.\n\nI subsequently undertook a PhD in environmental medicine (RMIT) examining the impact of environmental exposures to toxicants and manmade electromagnetic fields, gaps in current exposure standards, and the associated health effects. My dissertation, which asks whether radiofrequency radiation affects sleep, is attached in support of this submission. This involved the first real-world study (double blind, randomised, placebo controlled pilot study) on the impact of a Wi-Fi enabled device on sleep in healthy adults using a baby monitor which was statistically significant (within 7 days). \n\nCurrent exposure standards are designed to prevent short-term heating and nerve stimulation which do not reflect real-world exposure. They do not adequately address chronic, low-level, night-time exposure in the home, which is when the body should be resting and repairing. Nor do they account for vulnerable groups such as children, or those impacted by mould who frequently become sensitive to manmade electromagnetic fields and toxicants. \n\nRecommendations\nRemarkably, the most effective measures are simple and cheap:\n\nDesign-stage solutions. Building codes and planning guidance should require meter panels, switchboards and smart meters to be located away from bedrooms and living areas. They should also encourage hard-wired data connections in new homes. These measures cost almost nothing when planned in at the design stage, but are expensive to retrofit.\n\nMass consumer education. The public needs clear, independent and practical guidance on reducing exposure, particularly while sleeping. This includes turning off Wi-Fi at night, keeping devices out of bedrooms and checking what is behind the bedhead.\n\nA precautionary approach. Exposures should be kept as low as reasonably achievable (ALARA), and research and surveillance on sleep and other non-thermal effects should be funded.\n\nThese recommendations are consistent with the Australian Senate Inquiry into Electromagnetic Radiation (2001) (attached). The Chair's report called for a rigorous precautionary approach to wireless technology, for emissions to be kept as low as reasonably achievable, and for clear, independent public information so people can make informed choices. Twenty-five years on, those recommendations are more relevant than ever.\n\nThank you for the opportunity to contribute.\n\n","attachments":["https://downloads.regulations.gov/HHS-OASH-2026-0397-1288/attachment_3.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-1288/attachment_1.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-1288/attachment_2.pdf"],"attachment_inventory":true,"withheld":false,"source":"https://www.regulations.gov/comment/HHS-OASH-2026-0397-1288","tags":["child-development","health-experiences","sleep-cognition","exposure-places","research-evidence"],"source_hash":"4d2ff9123e6c251ab447a3fb6097b5056fe09a32c92a76073188067452d67d26","slug":"child-development-comment-1288","classification":{"id":"HHS-OASH-2026-0397-1288","body_sha256":"82d0b6cf4453776b56820867ef03211549401dbc56d270c56d0ed39077b48c47","status":"ai_reviewed","primary_topic":"neurological","topics":[{"id":"neurological","evidence":"ted by EMF exposure.\n\nI developed persistent sleep problems within 2 weeks of moving into our first home. I eventu"},{"id":"reproductive","evidence":"me. I eventually realised (after 7 years and ten miscarriages - no explanation was provided by the medical industry "},{"id":"electricity","evidence":" axis digital gauss meter and found elevated AC magnetic fields on the bed during the early hours of the morning (when"},{"id":"wifi","evidence":"ost often are: radiofrequency radiation from Wi-Fi routers and wireless-enabled devices kept in or near bedrooms,"},{"id":"standards","evidence":"e simple and cheap:\n\nDesign-stage solutions. Building codes and planning guidance should require meter panels, swi"},{"id":"optical","evidence":" bed, switching off Wi-Fi at night and using wired connections.\n\nI subsequently undertook a PhD in environmental medi"},{"id":"research","evidence":"double blind, randomised, placebo controlled pilot study) on the impact of a Wi-Fi enabled device on sleep in h"}],"summary":"An environmental-health practitioner reports sleep and pregnancy experiences, cites a Wi-Fi sleep pilot study, and recommends lower bedroom exposures and precautionary standards.","reviewed_at":"2026-10-05T20:06:38Z","review_method":"Full published comment-body review; exact shared paragraphs read once and reused losslessly; distinct official IDs preserved. Attachments and external links not reviewed.","review_source_sha256":"71991287fcbfb8feb786dba0dc1169cb4703a1c1a9072b932eda9db654228544","source_url":"https://rfsafe.net/hhs-comments/data/catalog.json","scope":"Original comment body; attachments excluded"},"forum_topics":["neurological","reproductive","electricity","wifi","standards","optical","research"],"primary_topic":"neurological","forum_title":"An environmental-health practitioner reports sleep and pregnancy experiences, cites a Wi-Fi sleep pilot s…"}