2. I am submitting this Comment to the HHS hoping that positive change can be effected through informed, …

2. I am submitting this Comment to the HHS hoping that positive change can be effected through informed, ethical policy-making; and revised Radiofrequency/Electromagnetic Fields standards that prioritize and protect human health and the natural environment on which we rely. I write as an individual functionally disabled by EMR-S with a metal hip for whom there is currently no guidance on safe exposure levels to rf/microwave/emfs radiation. 11d. Individuals with implanted medical devices – metal implants - see attached file for references People with metal implants should be considered a ‘significant, high risk population’ rather than a “sensitive’ one. Nearly a third of US adults aged 40+ have a metal implant inside the body and the numbers are increasing. 1 There are implications for the wider population using/wearing/carrying metals: tatoos (metal inks), spectacles, 2 jewellery, clothing, hearing aids, keys & coins. Implant metals act as antennas and amplifiers of pulsed rf/emf radiation to varying degrees depending on their conductivity rate; absorption of, and re-emittance of rf/microwaves; accumulated exposure time to emfs/rf; resting periods between exposures. They create hotspots; produce galvanic reactions; resonate at different frequencies from human tissue; and multiple metals at the same or different sites set up body micro-currents. Unlike chemicals which are blocked by the blood-brain-barrier, metal ions can traverse it. A dental research paper notes: “In biological dentistry, every metal in the body is regarded as a kind of antenna for microwaves and other electromagnetic fields (EMF) …”The standard absorption of emfs can be increased 400-700 times simply by using a mobile phone (ringing or SMS reception) in combination with metals in the mouth.” 3 Analysis of rf/emf radiation exposure on a human head with metallic implants states: “Metallic implants significantly alter the spatial distribution of hotspots in the head resulting in enhanced energy localization and deeper penetration in surrounding tissues.” 4 So, given the dangers of metallic implants why are people with metal implants excluded from IEEE Standards & ICNIRP Guidelines on rf/emf radiation used by the FCC; & why does there continue to be a failure to communicate risk & issue a public health warning to those with these implants? ICNIRP’s ‘Guidelines for limiting exposure to electromagnetic fields’ have been adopted by some European Union countries as a ‘Standard’ although they remain ‘Guidelines.’ I.C.N.I.R.P.’s relationship with and influence on the F.C.C. has been reviewed by the International Commission on the Biological Effects of Electromagnetic Fields who maintain “the assumptions underlying the FCC’s and ICNIRP’s exposure limits are invalid and continue to present a public health harm.” For example, “The exposure limits … do not account for any impact of differing signal characteristics, such as carrier wave modulations or pulsing of the signal.” 5 Nor, unbelievably have ICNIRP’s “scientific experts” 6 ever sought to include people with metal implants in their dosimetry for ‘recommended’ safe rf/microwave radiation exposures. In ‘Guidelines’ published (1996,7a 2010 7b & 2020 7c) they stated the issue of interference with or effects on “metallic prostheses … is beyond the scope of the present document.” An U.K. barrister confirmed for people with metal implants the “2020 [ICNIRP] guidelines expressly do not cater for their safety.” 8 The IEEE’s position has also been to exclude metallic implants from their standard adding: “The recipient and provider of these devices should be aware of the potential for hazards and precautions that may be necessary with such devices.” 9 ICNIRP and the IEEE employ the SAR as a means of determining thermal risk from exposure to rf/emfs but How relevant is the Specific Absorption Rate (SAR) as a means of assessing biological risk? Professor Andrew Marino states that the SAR was created by those “interested in developing microwave ovens, and in understanding how to cook meat” and so has no relevance to a “live brain… because mobile phone fields have nothing to do with heat… it makes no sense to say, “I have a really great way of measuring heat” when the measurement of heat is irrelevant to understanding health risks.” 10 So, what is a safe exposure level for people with metal implants? What is the best way biologically to measure it? How much more pulsed rf/emf radiation will be absorbed by metal implants if existing SAR measurements are taken at 0 distance from the body instead of a way off? 11