HHS-OASH-2026-0397-3852
https://www.regulations.gov/comment/HHS-OASH-2026-0397-3852

Dear HHS Leadership,

Thank you for seeking public input on the biological and health impacts of radiofrequency electromagnetic fields (RF-EMF), including 5G, Wi-Fi, and personal wireless devices. As technology density grows in homes and schools, federal guidelines must urgently account for the heightened biological vulnerability of children.

We request that HHS incorporate the following science-based protections into its safety evaluation and public guidance:

Child-Specific Absorption Modeling: Current federal guidelines are based on adult male anatomical models. Research demonstrates that children—due to thinner skulls, smaller head dimensions, and higher tissue water content—absorb up to twice as much RF radiation into their brain tissue and up to ten times as much into bone marrow compared to adults.

Impacts on Developing Neural and Cellular Systems: Review peer-reviewed evidence showing that non-thermal RF exposure can induce oxidative stress, mitochondrial dysfunction, and altered intracellular signaling in rapidly dividing, developing tissues.

Public Warnings and Device Labelling: Issue clear public health warnings regarding cell phones and wireless devices. Recommend practical limits, such as keeping devices away from the body during transmission, using speakerphone, and avoiding cell phone use directly against a child's head.

School and Childcare Environment Limits: Establish guidelines for educational settings, including favoring wired ethernet over Wi-Fi in early childhood centers, turning off Wi-Fi routers when not in active use, and restricting small-cell deployment directly adjacent to school grounds.

We urge HHS to align U.S. policy with international precautionary standards and provide clear, actionable guidance to protect developing children.

Sincerely,
Abigail Crowe