Children & vulnerable groups

I am an individual citizen who has had several adverse health events from EMFs. I include information on behalf of my wife, who has also been impacted. I hold a Ph.D. in computer science (artificial intelligence, cognitive architecture), with an undergraduate background in computer science, math, and physics. I have also grown up in the medical research world as someone with a rare metabolic bone disease (X-Linked Hypophosphatemia, "XLH"), am comfortable reading many types of medical literature, and currently work in the healthcare sector. I am willing to be contacted by the DoH for further conversation on what I am reporting in this comment. I am not able to fit all relevant details in the space allowed. Background: My own symptoms are noticeably worse (but not gone) when my phosphorous is low due to my genetic condition. At first I attributed my symptoms to my XLH, until I learned I could remove them by removing EMFs. (My XLH doctor is interested in learning more about the potential links between electrolyte processes impacted by XLH and EMFs, but he has no time to look into it. My PCP only cares about cholesterol.) After years of living with reduced EMFs, my sensitivity is lower than it used to be, but it still impacts daily life. Most symptoms are immediate and subside when the source is removed, though often they take time to fully subside. Building Biology recommended EMF levels align w/ my own experience. Useful resources are emfdata.org and mdsafetech.org. a) RF (most kinds of cell signal, WiFi, and Bluetooth) a.1) Headache - At my most sensitive I could tell when some 5G phones received a text before they gave the notification, feeling the individual RF pings as sharp stabs in my head. - Some kinds of RF, especially some Bluetooth speakers, can give a slow-onset hyper-intense headache that persists up to 24hr even w/ Tylenol. a.2) Brain fog (difficulty concentrating or holding attention) a.3) Gut pain (short stabs) - More common with newer 5G phones a.4) Restless leg while falling asleep ("phantom itching") - Follows most kinds of EMF exposure from earlier in the day if I don't discharge before bed. - I can remove the feeling either by exercise (unreliable) or by grounding myself barefoot outside for 10-15m (very reliable). - The effect is reduced if I prop my torso up. - My hypothesis: EMF-induced clumped blood cells (rouleaux formation) lead to itching in contracting leg blood vessels as I fall asleep. Propping myself up increases blood volume in my legs and reduces the stricture effect. a.5) Insomnia (lack of feeling sleepy) - Even if there are no other symptoms, RF usually prevents/impairs feeling drowsy, even if in need of rest. - Turning on a wireless device reliably wakes me up, no longer feeling tired. a.6) Raynaud’s syndrome - If in the presence of lots of RF AND cold. Cold but no RF is usually no problem. a.7) Dread - My wife felt unexplainable dread whenever in a particular room. Once I disabled a smart-home garage door motor transmitter nearby, the feeling stopped permanently. b) Magnetic fields b.1) Headache b.2) Gut pain - With all RF features disabled on a Macbook Pro, being within ~6ft of it while charging induced instant, intense gut and head pain. On battery I could use it from ~3ft away. b.3) Ring-worm-like spots - Back when I used my Macbook point-blank, these appeared near where the Macbook lined up at my desk. They did not itch and did not move. The doctor prescribed anti-fungal cream, which I applied faithfully for months to no effect. Then I randomly changed my desk setup so that my laptop was higher relative to my abdomen, and then the spots moved to the new height and disappeared from the old. When I distanced the laptop using a USB keyboard the spots disappeared. c) Electric fields c.1) Headache (buzzed feeling) c.2) Tingling/cold feeling - Touch screens / fingerprint readers will usually induce this in my fingers. d) Dirty Electricity / EMI d.1) Headache + brain fog d.2) Digestive issues - When I used a USB keyboard for my work computer, my stool would be pale and contain undigested food. After I switched to an IR-remote keyboard, these symptoms disappeared (and headache/fog reduced as well). The tethered keyboard acted like an antenna for EMI from the ethernet connection to my laptop. - Other forms of EMF might induce this symptom as well, but I had already removed most of those from my home by the time I changed this variable. d.3) Panic attacks - My wife as an adult was diagnosed with anxiety/panic attacks and prescribed medications, which did reduce symptoms. She was able to wean off meds when we married and she adopted my low-EMF lifestyle. Later we moved to a house that had high EMI on its power supply, and we were able to repeatedly, controllably, instantly induce her old "panic" symptoms by toggling a circuit at the circuit panel, even if she didn't know it was being switched.

I strongly urge HHS and its selected scientists to review the effects, symptoms, and published studies and report on non-thermal effect and take these into consideration. I have been conducting assessments for AC electric and magnetic fields and wireless radiation (RF) with professional calibrated instrumentation in residential, commercial and institutional buildings for over 30. I can attest that in many cases were individuals reported unspecific health problems and symptoms; once the source was eliminated, exposure reduced or shielded improvements were clearly noted. The current regulatory exposure limited need to be revised and significant reduced, especially in sensitive aeras such as but not limited too kindergartens, schools,...... I am encouraged that HHS taking an active role in examining the potential health and environmental effects of wireless radiation. Questions about human health should be addressed by federal agencies with appropriate expertise in medicine, biology, epidemiology, and public health, and the experiences of individuals and families who report being affected should be considered alongside the scientific evidence. I urge HHS to carefully evaluate these experiences and the scientific evidence, identify gaps in current research, give particular attention to children and other potentially vulnerable populations, and establish appropriate federal research priorities regarding wireless radiation and public health.

When the country got locked down and education (if that's what you want to call it) went online, persons might have noticed themselves holding their breathe and having to remind themselves to literally breathe! or perhaps there was tingling or 'asleep' sensations in their extremities, especially experienced after periods of nonmovement, for example upon waking. It would persist longer, in recurrence of days and in length of sensation per day. Upon children returning to in class, there were many observations that seem to differ from pre lockdown such as heightened anxiousness and hindrance in concentration ability. Prior to lockdown but well into integrating more technology into children's lives, the incidence of patience or not blurting out amidst other's conversations was markedly noticeable compared to the previous decades that classrooms of children were observed.

I have an acoustic neuroma for to 5G radiation. My head pain started while watching the towers go up around me. My neighbour who shared a common wall has exactly the same thing. Six hours of neurosurgery and 90 mins of gamma knife radiation, I still have it but hopefully the cells are no longer active. I had a terrible few years of suffering and pain. These need to go worldwide!! They're all over and harming kids, adults and animals. I can't sleep when I'm near one and start shaking and having neurological issues. Hear pain, nausea, dizziness, brain fog and general malaise. Just awful.

Wireless radiation has defined my existence and my families existence for at least the last 11 years. When we started noticing symptoms that turned off an on with exposure to wireless radiation we had to stop using electricity because it was provided only via a smart type meter which put out levels of radiation which prevented me from sleeping and from being within the house with out abdominal pain and cramping and head pain. My three children also experienced knee pain as well as various pains. The exposure we received from being in a social setting due to most people carrying cell phones and nearby cell phone towers made every social experience one that had swift and severe health consequences. Sometimes it would be effecting me for days after a several hour exposure. My employment possibilities were severely impacted, as was my social life and where I could live or travel! I am so disgusted with the lack of honer given to the thousands of studies that demonstrate the impacts to all life forms from wireless radiation. It is currently classified as a Class B probable Carcinogen, but that "Probable" designation is just to keep us from drawing the definite conclusions that science shows in relation to the increase of health outcomes especially since 2015 or so when most people started carrying a cellphone daily.

I submit this as an individual consumer and family member, relying on peer-reviewed research, federal reports, and court findings cited below (Qs 2, 3). Concern (Qs 5, 6): FCC's RF limits date to 1996 and address only short-term tissue heating, not chronic exposure, pulsed/modulated signals, multi-source cumulative exposure, or children's thinner skulls. In Environmental Health Trust v. FCC (D.C. Cir. 2021), the court found the FCC failed to justify that its limits protect against non-cancer harms, citing unaddressed evidence on children and long-term exposure, and remanded the issue. HHS, not FCC, should lead on the health basis for any standard. Evidence below current limits (Q12): NTP's $30M study (2018) found "clear evidence" of heart schwannomas and "some evidence" of brain/adrenal tumors in RF-exposed rats, with DNA damage reported in a follow-up (Smith-Roe et al. 2020). Italy's Ramazzini Institute independently found the same rare tumor at lower exposures comparable to cell tower emissions (Falcioni et al. 2018). IARC classifies RF-EMF as "possibly carcinogenic" (Group 2B, 2011). Reviews report oxidative stress (Yakymenko et al. 2016), reduced sperm quality (Adams et al. 2014), and DNA strand breaks (Lai & Singh 1995; REFLEX project 2004). Technologies changing cumulative exposure (Q13): 5G/small cells near homes and windows; Wi-Fi transmitting continuously in classrooms; smart meters installed on homes, often without real opt-out, pulsing near bedrooms; satellite broadband (e.g., Starlink) creating a new planet-wide RF source; networked cameras (e.g., Flock) on public poles with cellular modems and no resident notice; wireless earbuds transmitting inside the ear canal for hours daily, especially in teens; EVs producing low-frequency magnetic fields in cabins where children ride (IARC links this field type to childhood leukemia); AI data centers driving new high-voltage lines near communities; LED/"smart" lighting suppressing melatonin (AMA 2016) and adding RF transmitters with little safety study. Environmental effects (Q14): Thielens et al. (2018) found insects absorb more RF above 6 GHz, the direction 5G/6G are heading. Levitt, Lai & Manville (2021–22) reviewed reported effects on birds and insects, noting no federal environmental RF standard exists. Sensitive populations (Q11): Children, pregnant women, and implant recipients need separate risk evaluation. France restricted Wi-Fi for under-3 childcare settings in 2015. Disclosure (Q9): Residents deserve public antenna/exposure maps, advance notice before installations near homes and schools, clear device transmission labeling, and a genuine no-fee smart meter opt-out. Research priorities (Qs 10, 16, 17): Fund independent long-term cohort studies with real exposure measurement, especially in children; commission NTP follow-up at current 5G/mmWave frequencies; build a national RF/EMF environmental monitoring network; create an adverse-event reporting pathway; direct FDA to test consumer devices under realistic body-contact conditions. This research must be free of industry funding. Conclusion (Q18): We have deployed unprecedented, involuntary population-wide EMF exposure without proving it safe. Credible research has found cancer signals, DNA damage, oxidative stress, and reproductive effects. I ask HHS to investigate this independently and thoroughly, and prioritize human and environmental health over the pace of commercial deployment.

European Parliament requested a research report “Health Impact of 5G” which was released in July 2021 and concluded that commonly used RFR frequencies (450 to 6000 MHz) are probably carcinogenic for humans and clearly affect male fertility with possible adverse effects on the development of embryos, fetuses and newborns. Radiofrequency radiation is emitted by cell towers. This review paper concludes that “Based on the evidence reviewed it is our opinion that IARC’s current categorization of RFR as a possible human carcinogen (Group 2B) should be upgraded to Carcinogenic to Humans (Group 1).”

European Parliament requested a research report “Health Impact of 5G” which was released in July 2021 and concluded that commonly used RFR frequencies (450 to 6000 MHz) are probably carcinogenic for humans and clearly affect male fertility with possible adverse effects on the development of embryos, fetuses and newborns. Radiofrequency radiation is emitted by cell towers. This review paper concludes that “Based on the evidence reviewed it is our opinion that IARC’s current categorization of RFR as a possible human carcinogen (Group 2B) should be upgraded to Carcinogenic to Humans (Group 1).”

European Parliament requested a research report “Health Impact of 5G” which was released in July 2021 and concluded that commonly used RFR frequencies (450 to 6000 MHz) are probably carcinogenic for humans and clearly affect male fertility with possible adverse effects on the development of embryos, fetuses and newborns. Radiofrequency radiation is emitted by cell towers. This review paper concludes that “Based on the evidence reviewed it is our opinion that IARC’s current categorization of RFR as a possible human carcinogen (Group 2B) should be upgraded to Carcinogenic to Humans (Group 1).”

I am submitting this comment as a concerned member of the public urging HHS to undertake a comprehensive, independent investigation into the potential human and environmental health effects of the rapidly expanding electromagnetic environment created by modern technology. My concern is not based on the assumption that every wireless technology has been proven harmful. Rather, it is that society has dramatically increased the intensity, density, duration, proximity, and variety of electromagnetic exposures while the long-term biological consequences of this cumulative exposure remain incompletely understood. Today, people can be exposed simultaneously and continuously to Wi-Fi, 4G/5G and future 6G infrastructure, cell towers and small cells, Bluetooth and wireless headphones, smartphones, smart meters, wireless cameras and security systems, wearables, smart-home devices, connected and electric vehicles, wireless medical devices, satellite communications such as Starlink, and the rapidly expanding infrastructure supporting AI and data centers. The central question should therefore not simply be whether each individual device complies with an existing exposure limit. HHS should determine whether current standards adequately address real-world, cumulative, lifelong exposure from multiple sources operating simultaneously. I respectfully ask HHS to investigate potential effects on: sleep and circadian biology; hormonal and endocrine function; reproductive health and fertility; pregnancy and fetal development; neurological and cognitive function; immune and metabolic function; oxidative stress and cellular signaling; DNA integrity, repair and epigenetic processes; cancer and other chronic diseases; and children and other potentially vulnerable populations. Research should specifically examine effects that may occur below existing exposure limits and should evaluate frequency, power density, modulation, pulsing, duty cycle, beamforming, proximity to the body, duration, and simultaneous exposure to multiple frequencies. HHS itself identifies these factors as important areas for investigation. I am particularly concerned about involuntary residential exposure. Smart meters, nearby wireless infrastructure, small cells, and other continuously operating devices can expose people inside their own homes regardless of whether they personally choose to use wireless technology. Americans should have meaningful information and reasonable options for reducing unnecessary exposure in their homes, schools, workplaces, and communities. HHS should also investigate the rapidly changing exposure environment created by 5G, future 6G, satellite networks, IoT devices, autonomous vehicles, wireless charging, electric vehicles, smart cities, and other emerging technologies before assuming that older exposure research adequately represents these systems. The investigation should extend beyond human health. HHS should coordinate with appropriate federal agencies to examine potential effects on wildlife, birds, insects, pollinators, livestock, plants, and ecosystems. HHS specifically requests information concerning environmental effects and wireless infrastructure near homes, schools, childcare facilities, workplaces, and livestock. Independent research is essential. Federal research should be transparent, independently replicated, and protected from conflicts of interest. Long-term studies should measure actual exposure rather than relying solely on estimates of device use. The government should develop standardized methods for measuring individual and neighborhood exposure and consider longitudinal health studies, environmental monitoring, occupational monitoring, disease registries, biomonitoring, and adverse-event reporting. I also urge HHS to improve public transparency. Consumers, parents, schools, workers, and communities should have understandable information about the emissions and realistic exposure characteristics of wireless devices and infrastructure. The scientific evidence contains established findings, conflicting findings, emerging research, and significant uncertainty. That uncertainty is not a reason to dismiss public concern; it is a reason to investigate more rigorously. We should neither assume that modern wireless technology is harmless nor assume that every health problem attributed to EMF has been scientifically proven to be caused by EMF. We should measure the exposures, study the biology, monitor health outcomes over time, investigate potential risks, and make the evidence publicly available. The unprecedented proliferation of wireless and electrically powered technology should be matched by an equally serious commitment to understanding its long-term consequences for human health and the environment. I urge HHS to make cumulative, real-world EMF/RF exposure and its potential biological effects a significant federal research priority.