A researcher recommends studying exposure and behavior together, real-use dosimetry, early-life cohorts, …

Sivani Saravanamuttu, M.Phil., Ph.D. Independent Researcher and Author; Founder of Project Plain Talk I submit the following comments on the HHS RFI on Electromagnetic Fields, RF Radiation, and Wireless Radiation Exposure. My perspective draws on my peer-reviewed 2013 review (Sivani & Sudarsanam, Biology and Medicine) previously filed as Exhibit 19 in FCC ET Docket 13-84, and my book - The Digital Pied Piper Effect (2018) - which treats RF-EMF health questions as a systems problem involving both biological responses and behavioural patterns that increase cumulative exposure, especially in children. Key points (detailed in the attached PDF): - Exposure and behaviour are entangled; studies should measure both and attempt to separate their effects. - Priority needs include real-use dosimetry, longitudinal cohorts from early life and transparent evidence syntheses. - Individual sensitivity (including EHS/IEI-EMF) requires better methods (e.g., proteomics approaches proposed by Leszczynski) rather than relying solely on self-report or short provocation studies. - EHS recognition and prevalence data are concentrated in high-income countries; comparative data from other regions are lacking. - Coordination across FDA, NIH, CDC and related agencies is needed, with attention to non-thermal mechanisms as hypotheses requiring further testing and to practical exposure-reduction options. The full response, with citations and mapping to specific RFI questions, is attached as a PDF.