Children & vulnerable groups

I am writing as a mother and caregiver in response to this Request for Information. My son is seven months old, and like many parents I make dozens of small decisions every day about the environment he grows up in — including his exposure to wireless radiation. In our home we have taken simple precautionary steps: we keep phones off and away from our bodies, we use air-tube headphones instead of holding a transmitting phone to the head, our e-reader stays in airplane mode, and wireless devices stay out of the rooms where our baby sleeps. I have also looked into EMF-shielding textiles for his sleeping area. I am not a scientist, and I don't claim certainty about specific harms. But the existing exposure standards were designed around adults, and I have not seen clear, modern guidance that accounts for infants and small children — smaller bodies, developing brains, and decades more lifetime exposure ahead of them. That gap is exactly why I am writing. I ask HHS to: (1) develop child-specific, precautionary guidance for families; (2) fund independent research on RF exposure in infants and children; and (3) make the evidence behind any updated standards public and understandable to non-specialists. Thank you for inviting the voices of families and caregivers into this process.

https://www.researchgate.net/profile/Aqeel-Noaman/publication/336671998_Impact_of_Mobile_Phone_Usage_on_Some_Health_Aspects_of_Children_and_Adolescents_Evidence_Based_Review_Article/links/5dab6188a6fdccc99d91fa0f/Impact-of-Mobile-Phone-Usage-on-Some-Health-Aspects-of-Children-and-Adolescents-Evidence-Based-Review-Article.pdf "Impact of Mobile Phone Usage on Some Health Aspects of Children and Adolescents: Evidence Based Review Article" "Eye health Repeated use of the mobile phone for long periods of time harms the visual system of the eye in different ways where it can cause eye tumor due to the high temperature of the eye due to exposure to electromagnetic radiation and close these radiation from the lens of the eye increases the probability of eye exposure to cataract disease later [8]. Bansal and Mahajan, 2018 found in a study of 450 Indian children under 15 years of age in the pediatric department at the teaching for tertiary care that more than one third of them ( 35.7%) were suffering from eye symptoms including eye strain and eye watering (8). In another recent study, which included 177 Saudi students studying at a middle school in the city of Riyadh, their ages ranged 12 to 116 years old, found that using the smartphone for more than 28 hours a week causes visual disturbance [9]. Ear problem Increase the temperature in the ear lobes by approximately 10 degrees Celsius may cause auditory disturbances when using the mobile for a period of 20 minutes continuously and for longer periods because the radiation emitted from the mobile may cause damage to the sensitive parts of the inner ear, as well as people who use phones including children for 2-3 hours a day and for a period of 3-5 years may be exposed to the occurrence of partial deafness and even may eventually exposed to ear tumor or permanent hearing [8]. Neurological effects Neurologically, the microwave radiation emitted from mobile phones through the Wi-Fi device is mostly affects the head region [10]. In a study carried out by Cerutti R, et al (2016) they revealed that exposure the adolescents to some harmful effects like headache attacks and other somatic problems as result to excessive use of mobile devices [11]. And exposure to headache was significantly associated with mobile phone use among Twainish children in another study published in 2015 [6]. Recently, Jo Fowler and Jan Noyes, found that the children aged 11- 14 years in south west of England at risk of muscular skeletal problems due to mobile use [4]. Psychiatric effects In a recent study conducted in South Korea by Seong-Soo Cha and Bo- Kyung Seo revealed that the lethargy and depression were more in risk group (excessive mobile users) than the normal user group, and these findings were tendency to significant difference [12]. But in another study carried out on a group of Japanese young people aged 15-19 years, it revealed that the use of mobile phone for social networking services, and conversation with others for two hours or more is significantly linked to a high risk rate with depression [13]. Some studies indicate that there is a correlation between the use of mobile phones and stress, some of which negate this as it is difficult to interpret and summarize the relationship between them [14]. Some researchers have proven that mobile use causes increased stress and others have proven the opposite [14]. In a study conducted on a group of high school respondents, their mean age was 11.97 years [15]. The reason for this may be that Children may experience various biological and psychological changes during their lifetime for a daily period [15]. As for the correlation between exposure to anxiety and the use of mobile phones, two recent studies proved to have been set forth investigating by Elhai, et al and another by Nassehi, et al [14]. They proved that there is an important correlation between the occurrence of anxiety and the use of mobile phones." Sleep problems and brain tumor info was also mentioned in the article. But they take up more space than I have here.

https://www.researchgate.net/profile/Aqeel-Noaman/publication/336671998_Impact_of_Mobile_Phone_Usage_on_Some_Health_Aspects_of_Children_and_Adolescents_Evidence_Based_Review_Article/links/5dab6188a6fdccc99d91fa0f/Impact-of-Mobile-Phone-Usage-on-Some-Health-Aspects-of-Children-and-Adolescents-Evidence-Based-Review-Article.pdf "Impact of Mobile Phone Usage on Some Health Aspects of Children and Adolescents: Evidence Based Review Article" "Eye health Repeated use of the mobile phone for long periods of time harms the visual system of the eye in different ways where it can cause eye tumor due to the high temperature of the eye due to exposure to electromagnetic radiation and close these radiation from the lens of the eye increases the probability of eye exposure to cataract disease later [8]. Bansal and Mahajan, 2018 found in a study of 450 Indian children under 15 years of age in the pediatric department at the teaching for tertiary care that more than one third of them ( 35.7%) were suffering from eye symptoms including eye strain and eye watering (8). In another recent study, which included 177 Saudi students studying at a middle school in the city of Riyadh, their ages ranged 12 to 116 years old, found that using the smartphone for more than 28 hours a week causes visual disturbance [9]. Ear problem Increase the temperature in the ear lobes by approximately 10 degrees Celsius may cause auditory disturbances when using the mobile for a period of 20 minutes continuously and for longer periods because the radiation emitted from the mobile may cause damage to the sensitive parts of the inner ear, as well as people who use phones including children for 2-3 hours a day and for a period of 3-5 years may be exposed to the occurrence of partial deafness and even may eventually exposed to ear tumor or permanent hearing [8]. Neurological effects Neurologically, the microwave radiation emitted from mobile phones through the Wi-Fi device is mostly affects the head region [10]. In a study carried out by Cerutti R, et al (2016) they revealed that exposure the adolescents to some harmful effects like headache attacks and other somatic problems as result to excessive use of mobile devices [11]. And exposure to headache was significantly associated with mobile phone use among Twainish children in another study published in 2015 [6]. Recently, Jo Fowler and Jan Noyes, found that the children aged 11- 14 years in south west of England at risk of muscular skeletal problems due to mobile use [4]. Psychiatric effects In a recent study conducted in South Korea by Seong-Soo Cha and Bo- Kyung Seo revealed that the lethargy and depression were more in risk group (excessive mobile users) than the normal user group, and these findings were tendency to significant difference [12]. But in another study carried out on a group of Japanese young people aged 15-19 years, it revealed that the use of mobile phone for social networking services, and conversation with others for two hours or more is significantly linked to a high risk rate with depression [13]. Some studies indicate that there is a correlation between the use of mobile phones and stress, some of which negate this as it is difficult to interpret and summarize the relationship between them [14]. Some researchers have proven that mobile use causes increased stress and others have proven the opposite [14]. In a study conducted on a group of high school respondents, their mean age was 11.97 years [15]. The reason for this may be that Children may experience various biological and psychological changes during their lifetime for a daily period [15]. As for the correlation between exposure to anxiety and the use of mobile phones, two recent studies proved to have been set forth investigating by Elhai, et al and another by Nassehi, et al [14]. They proved that there is an important correlation between the occurrence of anxiety and the use of mobile phones." Sleep problems and brain tumor info was also mentioned in the article. But they take up more space than I have here.

https://www.researchgate.net/profile/Santosh-Kesari/publication/263931015_Why_children_absorb_more_microwave_radiation_than_adults_The_consequences/links/53d8fee20cf2631430c38c88/Why-children-absorb-more-microwave-radiation-than-adults-The-consequences.pdf "Why children absorb more microwave radiation than adults: The consequences" "Abstract Computer simulation using MRI scans of children is the only possible way to determine the microwave radiation (MWR) absorbed in specific tissues in children. Children absorb more MWR than adults because their brain tissues are more absorbent, their skulls are thinner and their relative size is smaller. MWR from wireless devices has been declared a possible human carcinogen. Children are at greater risk than adults when exposed to any carcinogen. Because the average latency time between first exposure and diagnosis of a tumor can be decades, tumors induced in children may not be diagnosed until well into adulthood. The fetus is particularly vulnerable to MWR. MWR exposure can result in degeneration of the protective myelin sheath that surrounds brain neurons. MWR-emitting toys are being sold for use by young infants and toddlers. Digital dementia has been reported in school age children. A case study has shown when cellphones are placed in teenage girls’ bras multiple primary breast cancer develop beneath where the phones are placed. MWR exposure limits have remained unchanged for 19 years. All manufacturers of smartphones have warnings which describe the minimum distance at which phone must be kept away from users in order to not exceed the present legal limits for exposure to MWR. The exposure limit for laptop computers and tablets is set when devices are tested 20 cm away from the body. Belgium, France, India and other technologically sophisticated governments are passing laws and/or issuing warnings about children’s use of wireless devices."

https://pubmed.ncbi.nlm.nih.gov/26474271/ "Memory performance, wireless communication and exposure to radiofrequency electromagnetic fields: A prospective cohort study in adolescents" "Abstract Background: The aim of this study is to investigate whether memory performance in adolescents is affected by radiofrequency electromagnetic fields (RF-EMF) from wireless device use or by the wireless device use itself due to non-radiation related factors in that context. Methods: We conducted a prospective cohort study with 439 adolescents. Verbal and figural memory tasks at baseline and after one year were completed using a standardized, computerized cognitive test battery. Use of wireless devices was inquired by questionnaire and operator recorded mobile phone use data was obtained for a subgroup of 234 adolescents. RF-EMF dose measures considering various factors affecting RF-EMF exposure were computed for the brain and the whole body. Data were analysed using a longitudinal approach, to investigate whether cumulative exposure over one year was related to changes in memory performance. All analyses were adjusted for relevant confounders. Results: The kappa coefficients between cumulative mobile phone call duration and RF-EMF brain and whole body dose were 0.62 and 0.67, respectively for the whole sample and 0.48 and 0.28, respectively for the sample with operator data. In linear exposure-response models an interquartile increase in cumulative operator recorded mobile phone call duration was associated with a decrease in figural memory performance score by -0.15 (95% CI: -0.33, 0.03) units. For cumulative RF-EMF brain and whole body dose corresponding decreases in figural memory scores were -0.26 (95% CI: -0.42, -0.10) and -0.40 (95% CI: -0.79, -0.01), respectively. No exposure-response associations were observed for sending text messages and duration of gaming, which produces tiny RF-EMF emissions. Conclusions: A change in memory performance over one year was negatively associated with cumulative duration of wireless phone use and more strongly with RF-EMF dose. This may indicate that RF-EMF exposure affects memory performance."

https://pmc.ncbi.nlm.nih.gov/articles/PMC4190308/ "Association between mobile phone use and inattention in 7102 Chinese adolescents: a population-based cross-sectional study" "Abstract Background The dramatic growth of mobile phone (MP) use among young people has increased interest in its possible health hazards in this age group. The aim of this cross-sectional study was to investigate the association between MP use and inattention in adolescents. Methods A total of 7720 middle school students were involved in this cross-sectional study. Inattention was assessed as defined for the Attention Deficit component of Attention deficit/Hyperactivity disorder (ADHD) by the Diagnostic and Statistical Manual of Mental Disorders (4th ed., text rev. [DSM-IV-TR]). The demographic characteristics and information on MP use were included in the questionnaire. Chi-square tests and logistic regression models were used to analyze the data. Results In total, 7102 (91.99%) valid questionnaires were obtained. After adjusted for confounders, inattention in adolescents was significantly associated with MP ownership, the time spent on entertainment on MP per day, the position of the MP during the day and the mode of the MP at night. The strongest association between inattention and the time spent on the MP was among students who spent more than 60 minutes per day playing on their MP. Conclusions Our study shows some associations between MP use and inattention in Chinese adolescents. Decreasing MP usage to less than 60 minutes per day may help adolescents to stay focused and centered."

https://pmc.ncbi.nlm.nih.gov/articles/PMC3605379/ "Mobile Phone Use, Blood Lead Levels, and Attention Deficit Hyperactivity Symptoms in Children: A Longitudinal Study" "Abstract Background Concerns have developed for the possible negative health effects of radiofrequency electromagnetic field (RF-EMF) exposure to children’s brains. The purpose of this longitudinal study was to investigate the association between mobile phone use and symptoms of Attention Deficit Hyperactivity Disorder (ADHD) considering the modifying effect of lead exposure. Methods A total of 2,422 children at 27 elementary schools in 10 Korean cities were examined and followed up 2 years later. Parents or guardians were administered a questionnaire including the Korean version of the ADHD rating scale and questions about mobile phone use, as well as socio-demographic factors. The ADHD symptom risk for mobile phone use was estimated at two time points using logistic regression and combined over 2 years using the generalized estimating equation model with repeatedly measured variables of mobile phone use, blood lead, and ADHD symptoms, adjusted for covariates. Results The ADHD symptom risk associated with mobile phone use for voice calls but the association was limited to children exposed to relatively high lead. Conclusions The results suggest that simultaneous exposure to lead and RF from mobile phone use was associated with increased ADHD symptom risk, although possible reverse causality could not be ruled out"

wireless radiation exposure is harmful to kids (especially) as well as adults

https://www.sciencedirect.com/science/article/pii/S0891061815000952?via%3Dihub "...Young children and skull thickness is very thin. Therefore, EMF absorption rate is higher in children and adolescents compared to the adults (Fig. 9). The radiation penetrates the skull of adult (25%), young (50%) and a 5 year old (75%)."

As Chief Scientific Officer of Children’s Health Defense, I urge the Department of Health and Human Services (HHS) to prioritize independent, transparent research into the biological and health effects of wireless radiation. As wireless infrastructure expands, we must address critical gaps in scientific understanding, reevaluate outdated federal exposure guidelines, and investigate potential risks to children and other vulnerable populations. Protecting public health requires rigorous science, transparency, and a commitment to following the evidence wherever it leads.