Children & vulnerable groups

Question 18: RE: Neurotoxicity: The current limits on EMF/GSM-like RF exposure on the human population must be re-examined in light of the increasing use of cell phones, Wi-Fi, cell towers and small cells, smart meters, Bluetooth AirPods, 5G, and emerging 6G technologies. Children are reportedly especially vulnerable in that they absorb higher rates of RF radiation. More and more studies are confirming severe neurotoxic effects. See Neurotoxic effects of 3.5 GHz GSM-like RF exposure on cultured DRG neurons: a mechanistic insight into oxidative and apoptotic pathways. Bektas H, Seker A, Ustun R, Dogu S, 2026. The current limits relating to "heating tissue" are insufficient to protect the human population. We need to conduct specific research on the true effects of radiation on humans, animals, and any living tissue. The ever increasing levels of radiation are deleteriously affecting all of us. I request that you take immediate action to protect us from further harm and do whatever is necessary to institute truly safe limits. RE: cell phone towers Balmori, A. (2022). Evidence for a health risk by RF on humans living around mobile phone base stations: From radiofrequency sickness to cancer. Environmental Research, 214, 113851. https://doi.org/10.1016/j.envres.2022.113851 Hardell, L., & Koppel, T. (2022). Electromagnetic hypersensitivity close to mobile phone base stations – A case study in Stockholm, Sweden. Reviews on Environmental Health. https://doi.org/10.1515/reveh-2021-0169 Meo, S. A., Almahmoud, M., Alsultan, Q., Alotaibi, N., Alnajashi, I., & Hajjar, W. M. (2019). Mobile phone base station tower settings adjacent to school buildings: Impact on students’ cognitive health. American Journal of Men’s Health, 13(1), 1557988318816914. https://doi.org/10.1177/1557988318816914 Zothansiama, Zosangzuali, M., Lalramdinpuii, M., & Jagetia, G. C. (2017). Impact of radiofrequency radiation on DNA damage and antioxidants in peripheral blood lymphocytes of humans residing in the vicinity of mobile phone base stations. Electromagnetic Biology and Medicine, 36(3), 295–305. https://doi.org/10.1080/15368378.2017.1350584

I am submitting this comment in response to HHS’s Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure. I am responding from the perspective of a healthcare professional. There is substantial scientific evidence that has been collected for some time about how wireless radiation has deleterious effects on the public, especially on infants and children, whose cells are turning over rapidly, causing a chain reaction of negative effects on their development. The damage also occurs in adults and other life. Some countries have already heeded this information to put into place safety regulations to protect them. I support HHS taking an active role in examining the potential health and environmental effects of wireless radiation using only human and non-animal studies. 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. Thank you for providing individuals and families with an opportunity to be heard.

I am reaching out to offer my experience in the Maine State Legislature. I dealt with this issue in the 2000s, by introducing a bill asking for warning labels on cell phones, especially for children, due to radiation from it entering our brains. The bill past in both houses, but "leadership" brought in lobbyists to finally change enough votes to kill it: I was a Maine State Legislator and did a great amount of work, with wonderful expert supporters. Data Centers send out big radiation today. Ed Friedman, still working that issue, enlightened me on that; it's not just water and electric power. But who is being allowed to know?

I am submitting this comment in response to HHS’s Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure. I am responding from the perspective of a parent and protector of ordinary people. Wireless radiation has affected me and my family personally but also everyone else near a cell tower, 5g, and owners of wifi routers and electronic devices. I support HHS taking an active role in further examining the known 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. Thank you for providing individuals and families with an opportunity to be heard.

Hello, I am submitting this comment in response to HHS’s Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure. I am an Ivy Alumn, and a mother of two teenagers. The wireless radiation bombarding humanity, plants and animals is nothing Earth has ever experienced before. The damaging effects are both palpable in the present, and obvious threats to the future. My family is considered particularly sensitive - we are athletes, we not have allergies, fortunately, however, my children and I can feel the presence of WiFi radiation when we drive past a cell tower, or spend too much time in an airplane. There is a pressure, slight buzzing, change in the air which can create headaches. It is not hard to imagine the long term damage such air pollution can cause. Humans are electrical beings, delicates composed of high frequencies. When altered, our natural rhythms and biometrics are impacted, in this case, adversely. I support 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. Thank you for your consideration.

To: Federal Communications Commission (FCC) Department of Health and Human Services (HHS) / Food and Drug Administration (FDA) Subject: Public Comment Regarding Outdated RF Radiation Exposure Limits, Multi-Device Realities, and Implementation of the EHT v. FCC Court Mandate To Whom It May Concern: I am submitting this comment to formally urge the Federal Communications Commission (FCC) and the Department of Health and Human Services (HHS) to update the United States exposure limits for radiofrequency (RF) electromagnetic fields. The current federal exposure limits were adopted in 1996 and remain rooted in an obsolete thermal model that presumes biological harm occurs only if tissue is acutely heated. In 1996, mobile phones were utilized sporadically and held away from continuous bodily contact. Today, wireless exposure is near-constant, multi-source, and delivered directly against human skin across an expansive ecosystem of personal and commercial devices: 1. Continuous Contact and Body-Worn Devices: The 1996 standards never envisioned hardware engineered to operate in direct, uninterrupted contact with the human body for 16 to 24 hours a day. Millions of Americans now continuously wear smartwatches, fitness trackers, and connected rings, alongside direct-in-ear transmitters like Bluetooth earbuds and wireless headsets. Testing standards based on short-duration, separated-distance models fail to reflect the cumulative biological load of these skin-contact technologies. 2. Dense Multi-Source Living and Work Environments: Current Specific Absorption Rate (SAR) evaluations assess a single isolated device. However, daily environments subject individuals to simultaneous, overlapping fields from: Mobile hardware: High-powered smartphones running simultaneous cellular (5G/4G LTE), Wi-Fi, and Bluetooth radios, frequently carried directly in pants or jacket pockets. Portable computing: Wi-Fi- and cellular-enabled tablets, laptops, and e-readers resting directly on laps or near vital organs during work and education. Household and municipal infrastructure: High-output Wi-Fi 6/7 mesh routers, smart electric and water utility meters, smart TVs, voice-assistant smart speakers, and automated home security hubs broadcasting continuous beacon signals. 3. Non-Thermal and Chronic Low-Level Biological Effects: The assumption that only thermal burns or acute heating warrant safety margins is contradicted by substantial independent, peer-reviewed scientific literature—including research from the National Toxicology Program (NTP). Studies demonstrate cellular oxidative stress, metabolic disruption, and potential neurological impacts from persistent low-level pulsed fields, even when temperatures remain unchanged. 4. Failure to Protect Developing Neurological Systems: Standardized plastic mannequins modeled after adult male dimensions do not account for children or adolescents. Thinner cranial bones, greater fluid conductivity, and smaller body mass mean modern wireless tablets, educational laptops, and phones deliver higher relative doses to children’s developing nervous systems. 5. Mandated Compliance with EHT v. FCC: In Environmental Health Trust, et al. v. FCC (11 F.4th 912, D.C. Cir. 2021), the U.S. Court of Appeals for the D.C. Circuit ruled that the FCC acted arbitrarily and capriciously by terminating its inquiry into its 1996 limits without providing a reasoned explanation regarding non-cancer harms, chronic exposures, and modern children's usage. The FCC, in coordination with HHS and the FDA, must fulfill this legal remand through a transparent, science-based review rather than maintaining reliance on a 30-year-old framework. The federal government must align its regulations with today's multi-device, body-worn reality by updating RF exposure limits to account for continuous, non-thermal, cumulative exposures. Respectfully submitted, Mark Kuether Oostburg WI 53070

I am deeply concerned about the potential long-term health effects of electromagnetic fields (EMFs), radiofrequency (RF) radiation, and the increasing amount of wireless radiation exposure in our everyday environments. As a mother, I am particularly concerned about the cumulative exposure our children experience from an early age through cell phones, Wi-Fi, tablets, wireless devices, and technology in schools and homes. Children are growing up in environments where wireless technology is nearly constant, yet important questions remain about the effects of lifelong exposure. I recognize that current scientific evidence has not established that everyday wireless exposure within existing safety limits causes adverse health effects. However, I believe the remaining scientific uncertainties deserve continued independent investigation, particularly regarding long-term exposure, developing children, pregnancy, sleep, neurological health, and reproductive health. I am also concerned about whether current safety standards adequately reflect modern exposure patterns. People are no longer exposed to just one wireless device at a time. Many of us live and work surrounded by multiple sources of radiofrequency emissions throughout the day. I would like to see more research examining realistic, combined, and prolonged exposure rather than relying solely on short-term assessments. I strongly encourage federal agencies to prioritize transparent, independent, peer-reviewed research, including studies that examine potential effects beyond tissue heating. Research should also consider vulnerable populations and clearly communicate both established findings and areas where evidence remains inconclusive. I believe families deserve accurate information, meaningful choices, and practical ways to reduce unnecessary exposure without fear-based messaging or having to give up essential technology. My request is for greater transparency, stronger long-term research, ongoing evaluation of safety standards, and a precautionary approach where scientific uncertainty remains. Protecting public health, especially the health of future generations, should remain a priority as wireless technology continues to expand.

https://pmc.ncbi.nlm.nih.gov/articles/PMC6435572/ "The Relationship Between Parental Attachment and Mobile Phone Dependence Among Chinese Rural Adolescents: The Role of Alexithymia and Mindfulness" "Mobile phone has experienced a significant increase in popularity among adolescents in recent years. Findings indicate dependence on mobile phone is related to poor parent-child relationship. However, previous research on mobile phone dependence (MPD) is scant and mainly focus on adult samples. In this view, the present study investigated the association between parental attachment and MPD as well as its influence mechanism, in sample of adolescents in rural China. Data were collected from three middle schools in rural areas of Jiangxi and Hubei Province (N = 693, 46.46% female, Mage = 14.88, SD = 1.77). Participants completed the Inventory of Parent and Peer Attachment (IPPA), the twenty-item Toronto alexithymia scale (TAS-20), the Mindful Attention Awareness Scale (MAAS) and the Mobile Phone Addiction Index Scale (MPAI). Among the results, parental attachment negatively predicted MPD and alexithymia were exerting partial mediation effect between parental attachment and MPD. Further, mindfulness acted as moderator of the relationship between alexithymia and MPD: The negative impact of alexithymia on MPD was weakened under the condition of high level of mindfulness. Knowledge of this mechanism could be useful for understanding adolescents’ MPD in terms of the interaction of multiple factors."

About 12 years ago I attended a city council meeting in San Marino, CA, where parents were hoping to get a cell phone tower removed from the playground at their children’s school. I was appalled to learn that the parents could be sued if they expressed any concern that the tower might in some way impair their children’s health. So all they could do was talk about their fear that it could burn, or fall over, or that it looked unsightly, etc. Of course, the tower stayed. This is all you really need to know to realize that those who make and enforce our government's regulations have turned a blind eye to the real probability that our health and the health of plants and animals is likely harmed by some of these increasingly ubiquitous RF/EMF fields. One cannot even ask the question! After learning that I could be sued by the powerful communications industry for expressing concern that cell towers could cause health effects, I tried calling the FCC to ask how they came to the conclusion that RF and microwaves radiating at people were safe. I couldn’t reach a single human being to speak with until I finally selected the choice in the FCC phone menu for those who wanted to buy spectrum. After making this selection, I immediately got an engineer on the line. I explained why I was calling, that I was not buying spectrum but was a concerned citizen, and asked about what research the FCC used to establish safety standards. He told me he felt badly, that likely we needed to study the problem more but it was out of his hands. He told me that there was a group from whom the FCC got their reports on RF and microwave safety. I looked at the website he had mentioned. It described a small firm of 5 women whose mandate was to produce reports which interpreted complex data in their clients’ strategic interests. Wow. We were being sold a bill of goods. I tried to interest people at Caltech, where I was working, in this problem. I was told by my PI in no uncertain terms that if I took any measurements with an RF meter or EMF meter I would not be able to work in the HIV research lab anymore. I was told people would be upset and I must not bring “that device” (a simple cheap Trifield meter) to work ever again. I was later fired for specious reasons, and banned from talking to anyone in the lab. This felt really creepy. It was quite an education. I became more interested in the problem. The more I learned the more appalled I became. I appreciate the opportunity to comment. It is not my job to teach you, dear FCC, what you already know: there is something potentially harmful in these energies, else why can we not ask the question at city hall about whether these cell towers on the playground could be harming our kids? You at the FCC already know that you have been encouraging the rapid spread of this powerful addictive technology at the cost of our health and possibly even our climate. You know that in spite of efforts made by you and others to thwart studying this problem, data exists which casts doubt on microwave safety. Why are there articles entitled "The effect of trees on 5G" instead of articles entitled “The effect of 5G on trees"? At Caltech, before the Covid lockdown, I sat in on a bunch of lectures being given by the sustainability people. No one had incorporated the rapid increase in microwaves in our world in their models of our rapidly warming world. I see evidence around me that cell towers harm and kill trees, and likely, dry the soil, start fires, who knows what. The plethora of satellites that measure the ice depth at the poles shine microwaves in and measure what comes back. The difference apparently tells how thick the ice is. But is this a good thing to do? Could the small amount of microwave energy absorbed by the ice be softening the ice’s surface, changing its albedo, causing more of the sun's energy to be absorbed rather than reflected, leading to further ice melt? Are we in a way opening the oven to make sure the cake hasn't fallen yet when we make these measurements? We need to do better. We need a consortium of biologists, physicists, climate scientists, and engineers who are not influenced by profit or lucrative data collection schemes to work together to understand the impact of these energies (with which we did not co-evolve) on our health and on the health of our living world. Thank you for your time.

I am submitting this comment as a consumer concerned about long-term exposure to wireless radiation from phones, Wi-Fi routers, cell towers, and other connected devices. I urge HHS to conduct a thorough, independent review of whether current exposure limits adequately protect public health. This review needs to consider those most heavily exposed and should examine potential effects beyond tissue heating, including evidence concerning cancer, reproductive health, and children’s development. Please prioritize research that reflects how people actually encounter wireless radiation: repeated exposure over many years, often from multiple sources and devices used close to the body. Assessments should consider signal strength, pulse patterns, duration, and combined exposure. Please consider Melnick and Moskowitz’s 2026 analysis of animal data, which argues that existing exposure limits may inadequately protect against cancer and reproductive harm (https://doi.org/10.1186/s12940-026-01288-6). I also ask HHS to evaluate Lai and Levitt’s review of exposure intensity, duration, and signal modulation (https://doi.org/10.1080/15368378.2022.2065683), and Scarato’s review of US regulatory gaps and proposed reforms (https://doi.org/10.3389/fpubh.2025.1677583). These papers warrant careful consideration alongside the broader evidence, including studies that have not found adverse effects. I ask HHS to: •Assess whether additional protections are needed for children, pregnant women, and other potentially vulnerable groups. •Support long-term research with safeguards against industry conflicts of interest. •Provide clear information about exposure and practical ways to reduce it, including wired alternatives in homes and schools. •Recommend updated standards wherever the evidence shows that existing limits are insufficient. Consumers should not have to navigate these questions alone. Please use this inquiry to advance transparent science, meaningful oversight, and public health protection.