A telecommunications workforce organization requests occupational exposure surveillance, worker disclosur…

The American Telecommunications Guild (ATG), an Arizona nonprofit building workforce standards and credentialing for U.S. telecommunications infrastructure trades, submits the attached comment from the perspective of workers with occupational RF exposure. Tower and wireless technicians work closer to active transmitters, for longer periods and in more complex conditions than the general public, yet occupational exposure is rarely measured at the worker level or linked to health outcomes. ATG supports evidence-based wireless deployment and does not presume current limits are unsafe. We recommend a national occupational RF exposure-and-event surveillance framework, developed jointly by HHS/NIOSH, FCC, OSHA, and NTIA, that links measured exposure, transmitter configuration, and work task to reported symptoms and follow-up outcomes; standardized worker-facing exposure disclosure; validation of personal RF monitors in beamforming and multi-band environments; and prospective cohort studies of tower and rooftop technicians using measured rather than assumed exposure. The attached response addresses Questions 2, 3, 5–13, and 15–18.