HHS-OASH-2026-0397-6109
https://www.regulations.gov/comment/HHS-OASH-2026-0397-6109

I am a Licensed Electrician and perform EMF Mitigation for private residences. I received training through the Building Biology Institute and am in process to be certified through BBI as an Electromagnetic Radiation Specialist. For the past 6 years I have measured and mitigated electromagnetic fields in homes with a primary focus on sleeping areas. My work is guided by the Building Biology Evaluation Guidelines, which are based on the precautionary principle and the goal of creating environments that support long-term health rather than merely avoiding acute thermal injury.

I appreciate HHS’s initiative to examine RF/EMF exposures, particularly as they affect children and other vulnerable populations. There exists a large gap between U.S. standards and precautionary guidelines. U.S. and ICNIRP standards are based almost exclusively on heating (thermal) effects. A substantial body of peer-reviewed research documents non-thermal biological effects at levels far below those limits. Mechanisms repeatedly discussed in the literature and observed in practice include activation of voltage-gated calcium channels leading to oxidative stress, disruption of melatonin and circadian rhythms, DNA damage, increased blood-brain barrier permeability, and effects on sperm and reproductive tissue. From my professional experience, the most consistent and rapidly reversible effects are on sleep quality and overnight recovery. Clients frequently report improvements in sleep, energy, headaches, heart palpitations, cognitive clarity, and skin sensations after reduction of nighttime exposures, even when daytime exposures remain largely unchanged. These observations align with the emphasis Building Biology places on sleeping areas.

Children are of particular concern. Their thinner skulls, higher tissue conductivity, developing nervous and immune systems, and longer cumulative lifetime exposure increase vulnerability. I regularly encounter elevated RF and AC electric/magnetic fields in children’s bedrooms from Wi-Fi routers, baby monitors, cordless phones, cell phones, tablets, gaming devices, smart meters, and poorly designed electrical wiring.

Building Biology Evaluation Guidelines for Sleeping Areas: 
•  Radiofrequency: ideally < 0.1–10 µW/m²
•  AC magnetic fields: < 0.2–1 mG (20–100 nT)
•  AC electric fields / body voltage: very low (typically aiming for body voltage < 10–100 mV)

These levels are orders of magnitude below current FCC public exposure limits. Several European medical associations (e.g., Austrian Medical Association, EUROPAEM) and the BioInitiative reports have recommended substantially lower precautionary limits than those adopted in the United States. 

To address the current research gaps, the following areas should be prioritized:
•  Long-term studies of chronic, low-level, pulsed RF exposures typical of real-world environments (Wi-Fi, 4G/5G, DECT, smart meters) rather than short-term, continuous-wave laboratory exposures.
•  Effects on sleep architecture, melatonin, and overnight recovery in children and adolescents.
•  Combined exposures (RF + dirty electricity/microsurge electrical pollution + AC electric and magnetic fields).
•  Identification of susceptible subgroups (including those with electrohypersensitivity/EMR syndrome) and objective biomarkers.
•  Prospective studies of mitigation effectiveness in homes and schools.

Recommendations:
1.  Prioritize sleeping areas — Turn off or place Wi-Fi routers in airplane mode at night; keep cell phones and tablets out of bedrooms or in airplane mode; prefer hardwired Ethernet connections.
2.  Reduce close-range device use — Encourage speakerphone, wired headsets, or airplane mode for children; avoid carrying phones against the body.
3.  Address electrical environment — Identify and correct wiring errors that elevate magnetic fields; consider demand switches or circuit control for bedrooms to reduce AC electric fields during sleep; minimize dirty electricity from dimmers, inverters, and certain electronics.
4.  School and institutional settings — Prefer hardwired networks where feasible; locate wireless access points away from classrooms and offices; provide low-EMF options for sensitive students.
5.  Siting of infrastructure — Avoid placing cell antennas, small cells, and smart meters in close proximity to homes, schools, and daycare facilities.
6.  Education — Provide clear, accessible information so parents, teachers, and clinicians can make informed choices while research continues.

I urge HHS to incorporate precautionary considerations for non-thermal effects into its evaluation, especially for children, and to support independent research that examines real-world exposure patterns and mitigation outcomes. Practitioner observations and the existing body of non-thermal research should be weighed alongside the thermal-only framework that currently underpins U.S. standards.

Respectfully, 
William Pursino