Children & vulnerable groups

Re: Docket No. HHS-OASH-2026-0397; Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure; 91 FR 59792 (September 21, 2026); FR Doc. 2026-19252; regulations.gov Document ID HHS-OASH-2026-0397-0001 Perspective (Question 2): I write as a researcher and as a consumer; I file in my individual capacity, with affiliation for identification only, and my response rests on the methodological literature and on professional experience rather than on new data. I am an epidemiologist (Ph.D., University of Minnesota) and a security engineer who has built RF telemetry and software-defined radio sensing systems through two companies I co-founded. The strongest case for this RFI is its order of operations: asking the research community and the public to identify frameworks, evidence, exposure methods, surveillance gaps, and research priorities before any policy move is the correct sequence, the questions are well structured, and the instruction that respondents name the frameworks they rely on and the basis of their evidence is sound. I take no position on whether RF exposure below current limits causes harm. My position is narrower and prior: that question cannot be answered well until exposure is measured, so the most consequential questions in this notice are the exposure-assessment and surveillance questions. Summary of recommendations: 1. For each exposure framework HHS relies on, state the biological endpoint the limit protects against and the safety factor applied (Question 5). 2. Fund a national measured-exposure program: calibrated personal dosimeters and fixed software-defined radio monitors on a probability-based population panel, recording band-resolved field strength and duty cycle over time with published uncertainty budgets (Questions 7 and 8). 3. Disclose measured field strength at representative use distances, in plain units with stated uncertainty, rather than only a single maximum SAR value (Question 9). 4. Evaluate any new surveillance system against the CDC 2001 attributes before it is built, and give every registry an exposure denominator by linking it to the measured-exposure panel (Question 10). 5. Differentiate exposure assessment for children and for occupational groups because dose, not only field strength, differs (Question 11). 6. Apply symmetric quality criteria to studies finding effects and studies finding none, and prioritize measured-exposure cohorts and replication of the most-cited findings on either side (Questions 12 and 16). 7. Adopt a single federal exposure-measurement data standard and shared repository for FDA, NIH, CDC, and the FCC, coordinated with the FCC's concurrent proceeding (Question 17). The full comment is attached as a PDF. Disclosure: I have no financial interest in any vendor or contract involving this request, and I was not compensated for this comment. I co-founded AirCrumbs, Inc., which develops software-defined radio systems for wireless signal attribution, not exposure measurement, and earlier co-founded MTRX, Inc., which built RF telemetry products; I have no financial interest in any wireless carrier, device manufacturer, or exposure-measurement vendor. Andrew G. Huff, Ph.D., M.S. Risk Factor Research, LLC, Michigan, USA contact@andrewhuff.com

Health effects from wireless radiation are not always obvious, but the cumulative burden could be far greater than we realize. Please help us find out how to minimize the harm. I am glad HHS is 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 investigating this important issue.

I am a mother in Arizona his children have been impacted by emfs and Wireless Communications. My son is so sensitive even to microwaves and it impacts his health I know a lot of us have toxic overload of everything in our environments maybe it's not one thing but it's two or three things that are breaking the Children's Health. Please do the research on this and limit it from our communities

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

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 friend. Wireless radiation has affected someone I care about. Her experiences have affected daily life and relationships terribly. Wireless radiation isn't safe and HHS should address this issue. 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 providing individuals and families with an opportunity to be heard.

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.

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 patient. I have experienced several health related issues that were improved by reducing exposure to wifi and cell phone usage: 1. Our family got wifi around 2015. We had employed ethernet cables for internet up until then. Around 2017 I noticed my A1C levels had increased to 5.7 (up from 5.2-5.3.) I was 58 years old at the time and attributed it to my increasing age. In 2022 my A1C reached 5.8 despite efforts on my behalf- use of supplements, intermittent fasting and dietary modifications to keep my glucose levels down and regular exercise. At the time a friend recommended getting rid of wifi in our home or reducing the amount of time it is turned on. We began only having wifi turned on when we were actively using it. In a short time, a matter of months, my levels returned to 5.7. Several months later, we moved from the city of Lancaster to a rural setting in the county. We continued only turning on wifi when actively using it. Between moving out of an urban area and reducing wifi exposure in our home, my A1C levels returned to 5.3 in a matter of three months!! A year or so later a large warehouse was constructed within a mile and a half of our home, and I noticed a dramatic increase in the number of "available" wifi accounts when signing onto our computer. Sadly, after a period of at least 6 months (when I'd had them checked again...) my A1C levels were returned to 5.7 and have tenaciously remained there over the past year. 2. I have rheumatoid arthritis. My right knee was becoming increasingly stiff and sore so that it was becoming difficult to walk. Someone asked if I was in the habit of "wearing" my cell phone. I daily wore the phone in my righthand, front pocket. I stopped carrying the phone on my body and the symptoms nearly disappeared! I still experience stiffness in all my joints whenever the wifi is left "on" overnight or all day in our house. It makes a remarkable difference in my ability to move and I also experience accompanying discomfort. I have begun educating myself about the effects of cell phone and wifi radiation on the body in the wake of these experiences, which demonstrated to me in a very tangible way the reality of the effects these unseen waves and energy fields have on the human body. I have particular concern for the most vulnerable of our populations: pregnant women and their babies, children, the elderly and the seriously ill. For your own knowledge and more information on research findings, I would recommend interested persons to read: "Electromagnetic Fields of Wireless Communications: Biological and Health Effects" by Dimitris J Panagopoulos. 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 providing individuals and families with an opportunity to be heard.

I am submitting this as a concerned member of the public. We have a right to know what we are being exposed to. Current wireless radiation (RF/EMF from cell phones, Wi-Fi, 5G/6G, smart meters, cell towers, and everyday devices) is treated as if it is fully understood and safely managed. It is not. People cannot give informed consent when the information is incomplete, outdated, or buried. What must be made public and easy for ordinary people to access: Real-world exposure levels (not just laboratory SAR numbers), including cumulative and simultaneous exposure from multiple sources in homes, schools, workplaces, and public spaces. Clear, plain-language disclosure of potential biological and health effects reported in the scientific literature, including effects at levels below current FCC limits, especially for children, pregnant women, and other vulnerable groups. Exact locations, power levels, and frequencies of cell towers, small cells, and other wireless infrastructure near homes, schools, and playgrounds—updated in real time and without requiring FOIA requests. Independent (non-industry-funded) research summaries and the full underlying data, so the public can see what is known, what is uncertain, and where the gaps are. Practical ways people can reduce exposure, and the option to choose wired alternatives without penalty or loss of service. No one should be forced into continuous, involuntary exposure without transparent information and meaningful choice. Public health requires the precautionary principle when the science is still evolving and the exposure is universal. Please prioritize full disclosure, independent research, and genuine consent over industry convenience. Thank you for opening this process.

Here is what I know: if you take even minimal steps to reduce wi-if in the school, kids will be calmer and healthier. If health risks that doctors/scientists and thousands of studies do indeed exist, then we owe it to our children. We are bioelectrical beings, and wi-fi and cellular signals interfere with our cell-to-cell communication. Studies show wi-fi causes the cell membrane to leak, which produces a very destructive free radical and can contribute to cancer. Wi-Fi also has been shown to interfere with melatonin's ability to clean up free radicals. Other damages shown in the 1000s of studies performed: compromising the blood-brain-barrier (which keeps toxins out of the brain); cellular communication interference; damage to cell metabolism; single-and double-strand DNA damage; loss of DNA repair capacity in human stem cells; reduction in free-radical scavengers (particularly melatonin); abnormal gene transcription; neurotoxicity; carcinogenicity; damage to sperm morphology and function; and effects on behavior. This causes real damage to accumulate, especially in the small bodies of children. U.S. wireless radiation standards (set 20 years ago) based on a 6-foot, 200 pound healthy male? Why have no field studies been performed on children - and the child brain overall absorbs twice as much radiation as that of an adult, and their bone marrow absorbs 10x that of an adult. The following experts have said: • Dr. David Carpenter, M.D., public health physician educated at Harvard Medical School: "RF penetration is greater relative to head size in children, and they have a greater absorption of RF energy in the tissues of the head at WI-FI frequencies because their skulls area thinner, their brains are smaller, and their brain tissue is more conductive than that of adults since it has a higher water content and ion concentrations….Thus it is important that all of us, and especially children, restrict our use of cell phones, and limit exposure to background levels of WI-FI.” • Dr. Keith Black, Neurosurgeon, Cedars-Sinai Medical Center: “In children, the microwave radiation can penetrate deeper into the brain, and their cells are dividing at a much faster rate so the impact can be much larger.” As a side note, WiFi systems in school districts are usually much higher in strength than home systems because they are designed to operate hundreds of computers simultaneously and can be up to three times more powerful than a phone mast outside a school. This will be the first generation ever to spend 6-8 hours each day for years in industrial strength WiFi environment. Dr. George Carlo, who was the cell phone industry's Director of Research and was hired to run their $28 million dollar, 7 year research program to find out if cell phones were dangerous, is now an outspoken advocate of informing the public and calling for more research. We all love wireless. It has connected us, made life so much easier, and has brought information to our fingertips. I know the ease of cell phones, and the money behind cell phone companies is a powerful entity to fight, but if Dr. Carlo did the right things, so can we. Please I beg of you: we need strong leaders who care about the health of our children to step forward and protect them. Thank you for your time. Lauren Heller 74 Green Street, unit 1 Brookline, MA 02446

1. & 2. I am responding as: an individual 3a. Type of wireless or RF/EMF sources involved (e.g., mobile phones, Wi-Fi, smart meters…) Mobile phones 3b. Nature, duration, frequency, and approximate timing (e.g., years):When people use their mobile phones to access cellular data, the initial signal is very strong while the phone is connecting to a tower. It is about 20 seconds long and gives me symptoms. This has been happening to me for six years. 3c. Adverse health effect(s) experienced:Wakes me up from sleep, heart palpitations, and headaches. 3d. Time from first exposure to first appearance of adverse health effects; and did a change in exposure coincide with the onset of adverse effects: 4 years. A change of exposure (to additional EMF) greatly increased the symptoms. 3e. Was medical evaluation or treatment sought? (Optionally:) Was there a diagnosis? Medical treatment was sought, but unsuccessfully. 3f. Were steps taken to reduce or eliminate exposure, and were there subsequent changes in the effects? Yes. This involved removing all wireless devices from the home and moving to a different house away from neighbors. Additionally, because of the proximity of neighbors' wireless devices, it necessitated sleeping in the basement. 3g. Any supporting documentation? This includes Scientific Reports, exposure measurements, or other relevant information: Apple iphones, when "wifi assist" is turned on, default to the cell tower for internet access. When I first started waking up 5x a night with heart palpitations, my baby in the other room would wake up 10 seconds later, screaming. This happened on the hour and the half hour. It turned out that this was directly correlated with our neighbor using her cell phone between TV programs. (She stayed up later than we did.) When she turned off "wifi assist" so her cell phone accessed the internet through her own wifi router, the night waking ended immediately. Unfortunately, this was just the beginning of realizing I had become EMF sensitive and eventually I had to move. Additional Details you would like to share about your experiences of adverse health effects you believe to be associated with exposure to wireless radiation or EMF's:I was mildly sensitive to EMF, but it was not enough to notice, until I moved to a different house. This house, we later learned, was bordering on the right-of-way of a high voltage power line (69kV). Additionally, a smart meter was installed after we moved in. After a pregnancy, I had a situation that required a chest CT scan, which, of all medical imaging, has the highest amount of radiation. I think this overexposure created the perfect storm to make me very EMF sensitive.