{"id":"HHS-OASH-2026-0397-5966","number":"5966","name":"Silke Josten","organization":"","posted":"2026-10-28T04:00Z","received":"2026-10-21T04:00Z","body":"Greetings!\nConcerning question 18:\n1) A better measurement for rf-EMF is necessary, since SAR lumps together situations with extremely different potential for biological effects: \nSAR measures simply the absorbed energy over 6 minutes in standard cubicles of different sizes. It ignores peaks and modulations of the signal.\nThe problem with that is that modulations might lead to resonance-like effects in biological molecules like Proteins (ion channels, enzymes,) even DNA. The peak intensities in suitable modulation and orientation in space might be responsible for „throwing the switch“ in those molecules, leading to ion influx and disturbed signalling in cells, or impaired mitochondrial funcion. Effects on voltage gated ion channels or the respiratory chain could explain the symptoms of people with EHS to a great extent.\nPanagopoulos states that in studies with real mobile telephony-exposure, over 95% of the studies find biological effects even below current limits where as continuous-wave exposure with the same SAR, and even „simulated exposure“ with highly repetetive modulation yield ambiguous results. He states that the polarisation and the variability and the modulation in the ELF/VLF-range are responsible for the biological effects, not the SAR. (as stated in the european parliament-workshop).\nPanagopoulos tested the hypothesis in Drosophila oogenesis and did find different results in different exposure settings with similar SAR.\n\nIt is deeply concerning that public agencies like the BfS are caught in the circulatory reasoning that due to difficulties with dosimetry in real-mobile-telephony-settings, those studies are excluded for methodological flaws. Therefore, only studies with a small likelyhood of biological effects are considered, which acts as confirmation that there is no danger at all at this SAR. Therefore, no further exploratory research seems necessary.. \n\n2) When testing for electrohypersensitivity (EHS) in provocation studies, it is crucial to take into account: In almost all EHS people, reliable symptom onset is delayed, sometimes by hours, and more so in high-adrenaline-situations like a provocation study. \nLikewise, symptom-offset is extremely delayed, often by a day or longer.\nThis makes provocation studies hard to do: Required would be: max 1 test per day, without need to travel through traffic or public spaces or places with higher EMF, a daylong reporting-window, and several days of recovery are needed, as well as using real signals as described above.\n \nSome backup for my requests:\nThe inadequacy of SAR can be seen when comparing exposure with the same SAR but different signal charactersistics as seen here: https://doi.org/10.1016/j.mrrev.2019.03.003 (bigger numbers would be nice, but funding seems to be hard to come by).\n\nA very good source of information is this workshop of the European Parliament (4 hours): (english starts after a few seconds) https://www.youtube.com/watch?v=s1Kn7pGy3CI \nBoth Panagopoulos (talking about the above points) and Yael Stein provide important insights, if you have only limited time to skim.\nYael Stein is a md and proposes different stages of sensitivity - the early stages are characterized by late onset of symptoms and light symptoms overall, the later stages of late offset of symptoms even hours after the exposure has ended, and the symptoms are severe.\n__ \nThat effects can occur even theoretically can be seen in this preliminary model: (autoimmune d) - this also points to a lack of funding for testing the effects of shielding during sleep on autoimmune disease in a double blind study. This does not take away from the simulation of the vit D-receptor and the result that at least in theory, mobile phone radiation might lead to functional vit D deficiency in humans in general, with very small SAR values. Models like this for the voltage gated ion channels (sodium an calcium might be of highest interest) could be very useful, but so far we don’t have a complete model of those channels (according to the German Bundesamt für Strahlenschutz/FCC-equivalent).\nSome personal motivation: \nI know several people who are extremely sensitive to Wifi and mobile phones in use and phone masts, which has led me to look into possible reasons for their reactions (headaches, brainfog, fatigue, clenched muscles, altered circulation in the face - red and white spots). From my experience with them, I can rule out nocebo, since in a place where we had measured extremely low fields, they both had symptoms without expecting them (when they insisted, we measured again and found a switched-off IPAD with strong intermittent signals for location when lost, which had been brought in after the first measurement). \nI'm afraid the technology also hurts nature and the normal population.(see athem3, bee-fi). \nThank you for your consideration. People with EHS suffer greatly and unnecessarily, and might be the canary in the coal mine for the rest. \n","attachments":["https://downloads.regulations.gov/HHS-OASH-2026-0397-5966/attachment_2.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-5966/attachment_9.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-5966/attachment_7.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-5966/attachment_6.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-5966/attachment_5.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-5966/attachment_4.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-5966/attachment_1.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-5966/attachment_1.txt","https://downloads.regulations.gov/HHS-OASH-2026-0397-5966/attachment_10.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-5966/attachment_3.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-5966/attachment_8.pdf"],"attachment_inventory":true,"withheld":false,"source":"https://www.regulations.gov/comment/HHS-OASH-2026-0397-5966","tags":["health-experiences","sleep-cognition","biology-metabolism","exposure-places","policy-standards","research-evidence"],"source_hash":"f0ddc013e73db5769d888411558bc3c47562b304da3ccaab13515f9155c4ce04","slug":"health-experiences-comment-5966","classification":{"id":"HHS-OASH-2026-0397-5966","body_sha256":"5db7786edffa1afae1e8515e8c20987877a556bc48a67178c6ab1360d72009d0","status":"ai_reviewed","primary_topic":"standards","topics":[{"id":"standards","evidence":"Greetings!\nConcerning question 18:\n1) A better measurement for rf-EMF is necessary, since SAR lumps together situations wit"},{"id":"research","evidence":"testing for electrohypersensitivity (EHS) in provocation studies, it is crucial to take into account: In almost all EHS people, r"},{"id":"ehs","evidence":"arch seems necessary.. \n\n2) When testing for electrohypersensitivity (EHS) in provocation studies, it is crucial to take into account"},{"id":"mechanisms","evidence":"r impaired mitochondrial funcion. Effects on voltage gated ion channels or the respiratory chain could explain the symptoms of people wi"},{"id":"neurological","evidence":"k into possible reasons for their reactions (headaches, brainfog, fatigue, clenched muscles, altered circulation in the face - re"}],"summary":"Requests improved dosimetry and EHS study designs that account for signal modulation and delayed symptoms, proposes cellular mechanisms, and describes observations of sensitive acquaintances.","reviewed_at":"2026-10-28T16:50:58Z","review_method":"Full comment-text review with exact source evidence; attachments not reviewed","review_source_sha256":"f3c24386ea2b3a985d8d66a30767dd208e639826a0ea8dcc608eddabfe55edd1","source_url":"https://rfsafe.net/hhs-comments/data/catalog.json","scope":"Original comment body; attachments excluded"},"forum_topics":["standards","research","ehs","mechanisms","neurological"],"primary_topic":"standards","forum_title":"Requests improved dosimetry and EHS study designs that account for signal modulation and delayed symptoms…"}