Children & vulnerable groups

I appreciate HHS undertaking this important inquiry into electromagnetic fields (EMFs), radiofrequency (RF) radiation, and their potential effects on human health. My central concern is that the widespread deployment of wireless technologies has outpaced our understanding of the biological consequences of chronic, cumulative exposure. Compliance with existing exposure standards is not equivalent to demonstrating long-term biological safety. I urge HHS to address the following concerns: 1. Reevaluate safety standards beyond thermal effects. Current RF exposure standards have historically emphasized protection against tissue heating. Yet peer-reviewed research has reported biological effects involving oxidative stress, neurological function, reproductive health, and cellular processes at exposure levels that warrant investigation beyond heating alone. The National Toxicology Program’s 2018 studies reported clear evidence of carcinogenic activity involving malignant heart schwannomas in male rats exposed to certain RF conditions. The Ramazzini Institute independently reported increased heart schwannomas in male rats. Although these findings do not establish cancer risks from ordinary human wireless exposure, they raise legitimate questions requiring further investigation. 2. Investigate cumulative, real-world exposure. Americans experience simultaneous exposure from Wi-Fi, cellular networks, Bluetooth devices, smart meters, and other wireless technologies. Research must examine long-term exposure to multiple sources, including potential effects of duration, frequency, modulation, and cumulative lifetime exposure. 3. Prioritize vulnerable populations. Children, pregnant women, developing fetuses, and individuals with neurological vulnerabilities deserve particular consideration. Children increasingly experience wireless exposure throughout their school day, often without meaningful alternatives. HHS should determine whether existing standards adequately protect developing biological systems rather than assuming uniform safety across populations. 4. Ensure independent research and regulatory transparency. The telecommunications industry has substantial financial interests in maintaining existing infrastructure and exposure standards. HHS should disclose how current limits were established, how conflicting scientific findings have been evaluated, and what role industry-funded research and representatives have played in regulatory decisions. Independent replication, transparent methodologies, and full disclosure of financial conflicts are essential to public trust. 5. Protect informed choice and individual autonomy. Americans deserve understandable information about wireless exposure and practical ways to reduce it. I urge HHS to support wired alternatives in schools and public facilities, greater transparency regarding infrastructure emissions, meaningful community participation, and reasonable accommodations for individuals reporting electromagnetic sensitivity. 6. Apply the precautionary principle. The absence of conclusive evidence of harm must never be misrepresented as conclusive evidence of safety. Reasonable precautionary measures should not require absolute scientific certainty, particularly when exposure is widespread, continuous, and difficult to avoid. Specific Actions Requested I respectfully urge HHS to: 1. Independently reassess existing RF exposure limits, including potential nonthermal biological effects. 2. Commission replication and follow-up studies of significant National Toxicology Program and Ramazzini Institute findings. 3. Fund long-term research examining cumulative exposure from multiple wireless sources. 4. Prioritize research involving children, pregnancy, neurological health, sleep, and reproductive outcomes. 5. Require transparency regarding industry influence, research funding, and regulatory conflicts of interest. 6. Expand public access to real-world exposure measurements and meaningful consumer information. 7. Support wired alternatives and reasonable exposure-reduction measures. 8. Establish a transparent process for periodically updating exposure standards as scientific evidence evolves. Closing Statement Wireless technology provides undeniable convenience, but convenience must never substitute for rigorous public health evaluation. The burden of establishing reasonable safety should not rest entirely upon individuals after a technology has already been deployed throughout their homes, schools, workplaces, and communities. The American public deserves an independent assessment that examines all credible scientific evidence, acknowledges unresolved questions, and places human health above commercial interests. I urge HHS to make this inquiry the beginning of meaningful scientific investigation and regulatory accountability rather than another exercise in reaffirming existing assumptions. Thank you for considering my comments.

I am commenting as a concerned public citizen. Wireless radiation exposure and EMF's, although invisible, just like carbon monoxide, are very harmful. It's common sense that humans, as electrical beings, would be affected. Personally, I have done what I can to shield myself, and am considering more measures. I have Ethernet connections for my laptop and my phone, and shielding paint on one wall because my roommate has WiFi in her room. Since taking these steps I have experienced far less headaches. Also, it has already been demonstrated that cell towers near schools negatively affect young brains. I appreciate that HHS is considering this issue, and I support any actions that can be taken to identify gaps in understanding these dangers and establish appropriate research priorities to protect human health, and especially children's health.

Re: HHS-OASH-2026-0397, Request for Information on EMFs, RF Radiation, and Wireless Radiation Exposure Thank you for asking. Federal RF exposure limits date to 1996, and in 2021 the D.C. Circuit found the FCC had not adequately explained why it kept them. Since then wireless has moved from 3G to 4G to 5G, with 6G planned around 2030: more antennas, closer together, more of the time. It doesn't stop. HHS should give the public, and the FCC, a real health record to work from. 1. Update the limits on modern science. Revisit the 1996 limits using current research, with special attention to children and long-term, close-to-body exposure. HHS should lead the health review and hand the FCC a record that answers the court. 2. Take public reports seriously. Many Americans report real symptoms they connect to wireless exposure. Their experiences should not be dismissed simply because no one has funded a peer-reviewed study to examine them. Absence of funded research is not evidence of safety. HHS should collect these reports systematically and fund independent studies, free of industry money, designed to test them. 3. Review each generation before and after rollout. Every new wireless generation should get an exposure assessment before broad deployment and ongoing monitoring afterward, rather than riding on decades-old assumptions. As another commenter noted, most instruments were built to check heating limits, not to record everyday exposure continuously. HHS should fund continuous, real-world measurement where people live, work, and sleep. 4. Set device efficiency standards. For most people the closest source is their own phone. Push for standards that make phones and wearables connect at lower transmit power, whether to towers or satellites, and publish real-world exposure data for each model. 5. Study satellite connectivity as a lower-exposure path. Satellites with large antenna arrays, paired with more efficient phones, could cover rural and remote America with fewer towers near homes and schools. HHS should study this side by side with dense 5G and 6G networks, including the higher power phones may use to reach orbit, and communities should be able to choose it where it works. 6. Health comes first. More connectivity is not automatically progress. Faster video is not what stands between Americans and abundance; affordable energy, medicine, and housing are. Each new generation should show it is needed and safe before it is built into every neighborhood, and the burden of proof belongs on the deployers, not on families. Please publish the underlying data and keep the review independent. Alec Snelling California This comment was crafted with super intelligence (SI) support.

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 have experienced health problems from wireless radiation exposure. I first experienced problems when cell phones came out, years ago. I had dizziness and feelings of pressure in my head. I thought it was just the phone originally. As more wireless became available in computers and streaming TV, I realized I was continuing to have problems with the head pressure and dizziness. I do not think we know all the dangers associated with these technologies and that the government should do much more research before allowing them. I think children can be especially affected since their bodies are still developing. I support HHS in studying this issue more carefully. Please give particular attention to the research of scientists and any gaps in research. I appreciate your willingness to hear comments from the public.

My name is Sarah Aminoff, and I am a member of Safe Tech International, and a San Francisco, California educator. San Francisco has been a key test ground for driverless robotaxis, and being part of that experiment was not what I was thinking during student field trips to Golden Gate park. People are able to opt out of TSA Airport Scanners due to cumulative radiation concerns, but not Waymo robot taxi exposures, yet both use millimeter frequencies. Since 2024 onwards, it has been hard to reduce exposure to Waymo, given California Public Utilities Commission has also approved expansion. Waymo Robotaxis send out millions of radar sensors to create a 3D picture, using millions of radar millimeter sensors or laser pulses that impinge on an automobile or pedestrian and its a complex EMF soup. The Robocars use three primary sensors: cameras, LIDAR and radar. Radar uses millimeter wave frequencies to provide Waymo with crucial details like an object's distance and speed. LiDAR uses laser beams to create dense, accurate 3D maps. The Waymo 5th Generation, has 29 cameras, six radar sensors tracking larger objects and four LiDAR sensors, which use laser pulses to "see" the car's surroundings in 3D. To answer HSS question 5n and 8  The FCC still fails to capture ubiquitous and aggregate exposures. An aggregate signal analysis has yet to be done for driverless vehicles. Most of the compliance with federal standards are typically claimed for only one set of lights or emitters, as the FCC regulates RFR and Millimeter, yet on the Waymo 5th Generation there are 51 sensors. Time averaging dosimetry should not be permitted, especially for mmWaves and RF, as peak exposures that fall within FCC limits when time averaged over 30 minutes, can have serious non-thermal bioeffects at a cellular level potentially inducing reactive oxygen species and DNA, and sperm damage, according to International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF). With driverless vehicles, radiofrequency radiation (RF) in the MMWave part of the spectrum and near IR poses possible deep thermal heating effects, yet the FCC relies on 30 minute dosimetry, averaging in peak exposures. Environmental Health Trust shares science research around the millimeter frequency concerns, including:  “A 2021 paper “Millimeter (MM) wave and microwave frequency radiation produce deeply penetrating effects: the biology and the physics” by Martin L Pall PHD reviews the science on how MMwaves can have highly penetrating effects  stating that “in humans, MM-waves have penetrating effects including impacts on the brain, producing EEG changes and other neurological, neuropsychiatric changes, increases in apparent electromagnetic hypersensitivity and produce changes on ulcers and cardiac activity”   To answer Question 5 The FCC assessing for one vehicle only, not multiple car exposures is a gap in knowledge. According to Ron Kostoff in his article on radar and cars, ‘If you’re walking on a crosswalk in front of stopped traffic, you….could be exposed directly full body to a million microwatts/square meter.  And, there’s no glass or metal to absorb or block the radiation.  And, that’s with the assumption that you’re being radiated from one car only….what we really need to get are the codes the auto manufacturers use to compute actual radar exposures to car occupants and pedestrians. If some of the radars are mounted on the front bumper, then small children walking a crosswalk are most vulnerable. “ Time Averaging in Evaluating Dosimetry Levels in Smart Vehicles by the FCC is an inherent flaw. Technologies get approved without sufficient pre-market testing is another gap, see John P. Thomas’ article, Health Impact News “Will Driverless Cars Cause DNA Damage and Cancer? April 15, 2018.”   We need to know Waymo will tag a pedestrian as an ‘object detected” with a velocity vector as a moving target and an obstacle to avoid. People are being mapped with radar, lidar, ultrasonic signals and were also captured on optical cameras that use IR and LED beam lights. The LiDAR, Radar and Camera sensors can detect images from hundreds of meters. These are artificial exposures targeting every square centimeter of the body. Many autonomous vehicle incident were reported to: Block traffic Trap cars at the curb Enter construction zones Enter crime scenes, fail to follow directions Hit a cat and dog, also child Get in the way of emergency vehicles And yet, state and federal agencies allow children to ride in robot taxis (Waymo with adult supervision, or parental consent) while the FCC and agencies fail to include children’s unique biology in guidelines. Driverless vehicles have multiple sensors, when children are exposed to Waymo et al, e.g. idling outside schools. A new study from Europe found children have higher RF absorption rates than adults.

See attached file(s) Protect Our Children First: Urgent Call for Updated, Science-Based Wireless Radiation Safety Standards To: Federal Communications Commission (FCC) and U.S. Department of Health and Human Services (HHS) My name is Zen Honeycutt, and I am the Founder and Executive Director of Moms Across America, a national educational nonprofit organization dedicated to empowering mothers and families to create healthy, non-toxic environments for our children. On behalf of Moms Across America, I am calling upon the Federal Communications Commission (FCC), in coordination with the Department of Health and Human Services (HHS), to undertake an immediate, comprehensive, and transparent reassessment of federal radiofrequency (RF) radiation exposure standards, with particular attention to children's developing bodies, long-term exposures, and potential biological effects beyond tissue heating. The FCC's current RF exposure limits were adopted in 1996 and subsequently retained. Although these standards address established adverse effects associated with RF exposure, they have not been comprehensively revised to reflect the enormous changes in wireless technology and patterns of human exposure over the past three decades. Today, children routinely encounter wireless devices in classrooms, homes, and public spaces. They may experience exposures from multiple sources over many years, beginning during prenatal development. The fact is that close and constant exposure to devices such as routers in homes, wireless access points in schools, and hot spots in hospitals harms human health. We believe this exposure environment warrants renewed scientific scrutiny, independent research, and reasonable precautionary protections. The federal courts have already recognized the need for greater accountability. In Environmental Health Trust et al. v. FCC (2021), the U.S. Court of Appeals for the D.C. Circuit found that the FCC had not adequately explained its decision to retain existing RF exposure guidelines with respect to potential harmful effects unrelated to cancer. The court directed the FCC to address several important issues, including: Potential effects of RF exposure on children Pulse variations and possible changes which could reduce harm Health implications of long-term exposure The widespread use of wireless devices and technological developments The adequacy of existing device-testing procedures Potential environmental impacts on trees, animals, aquatic life, and insects This decision provides a compelling legal and public-health basis for renewed review of existing federal protections. We request action. Th ecell phones and router can be made safer by altering the pulse variations. The manufacturers just nee dto be required to do so. Please see the attached comment for further details. Zen Honeycutt

I am opposed to a proposed cell tower installation (Vertical Bridge/ Verizon) across the street from our NH family home of 50+ years for many reasons including: exposure to electro magnetic fields, wireless radiation exposure and radio frequency radiation. I am concerned for the environmental impact of these towers for myself, my family and grandchildren. Thank you for listening!

I have known about my severe Electromagnetic Frequency (EMF)/Electromagnetic Radiation (EMR) sensitivity since 2018. This malady has changed my life in a bad way. It forces me to live the life of a hermit because I cannot be exposed to EMF radiation which happens if I leave my house. I will describe the symptoms that I get when I am exposed to wireless, Wi-Fi, cell towers, antennas, fluorescent lights, LED lights, electrical fields in walls, magnetic fields in walls, Dirty Electricity in Breaker Boxes, household lamps that have metal in them, wireless in automobiles, magnetic fields in electric cars, etc, etc, etc. I have spent tens of thousands of dollars on work to make my house safe for me to live in. I have to spend this money for my life – meanwhile the telecom industry gets to make tons and tons of money to make me sick ….. It is very unfair!!! My symptoms go through a progression – based on the exposure time and the severity of the EMF situation I am in. Also based on the exposure time and the severity of the EMF event, I have a recovery time with different symptoms. My initial symptoms – are a warning from my body - that I had better get out of there ASAP!!! INITIAL PROGRESSION: When I initially get into an EMF situation I get dizzy, foggy, headache, nauseas. When I get these feelings, I immediately leave wherever I am. If I get out of there immediately, my recovery symptoms are minimized. NEXT PROGRESSION STEP: This occurs in stores, friends’ houses, any gathering of multiple people (whom of course all have wireless devices going simultaneously). I quickly progress into a situation where people think I am having a stroke. Although I can think of what I want to say, I am unable to articulate the words. I start slurring speech. missing words, only getting like 1 in 5 words correct. The first time this happened I was at a Thanksgiving event. I was in the living room and started not being able to say the words I could clearly think. When I looked around the room, there were about 20 people in the room, and I counted 8 cell phones and I-Pads out that were being used in the room. When my frantic host drove me home (30 minute drive) – within 15 minutes of leaving her house – I was starting to be able to speak correctly. When we got to my house - 30 minutes away – I was totally fine as far as language was concerned. I did have residual exhaustion, unable to make a decision and brain fog for several days afterwards. WORST CASE SO FAR: The worst case I have had so far has to do with AT&T. I had fought with them for a number of months that I wanted a modem WITHOUT Wi-Fi. They kept saying that I could turn off the Wi-Fi on the web. The problem is that they kept turning the Wi-Fi on from the web. They did it during the day so that when I started getting sick I would go out onto the web and turn off the Wi-Fi and call them again that I wanted a modem WITHOUT Wi-Fi. So one night I woke up in the middle of the night – HUGE symptoms – dizzy, nauseas, I COULD NOT THINK – I was extremely weak. Somehow I had the consciousness and determination to crawl to my office and pull the plug for my modem out of the wall. It was hours before I was able to get back to my bedroom. This was the worst case of residual symptoms I have had - I was unable to function for a week from this experience. After that week, I fired AT&T – I had been a customer of theirs for 42 years. I beg you – please please please pass some laws to rein in the telecommunications industry. Childre are so sensitive to the EMFs – my heart is wrenched when I see a small child with a cell phone near their head. I have heard that the radiation from EMF/EMR is cumulative. I was a computer programmer for IBM for 21 years. We had test floors that were as big as a football field. I suspect that I got a ton of radiation during my years at IBM. I cannot go out to you because of the EMFs. However I do have a PC with wires- and a telephone which is connected to the wall. I am happy to talk to anybody who wants to gather data about real life experiences with EMF sensitivity. Sincerely, Florence Gans

Hi, I am a resident of Wallington, NJ and I live 1,200 feet away from the Hathaway Street Park cell tower. This concerns me as I moved here approximately two years ago with my family of four. I do not wish to share my name at this time, as I work for a government agency and am concerned that a public record such as this, may negatively reflect on my standing. I would appreciate it, if you look into "our" little town (approximately one square mile) and its six antenna installations. From what I have been able to glean, as public record shows, Wallington's own codes do not conform to the town regulations for "cell tower" distance from residences, schools, or parks. Also, there are no yearly Radiofrequency (RF) reading reviews as is mandated by Wallington policies. Furthermore, residents have no discernible way of knowing if they are suffering any adverse health effects from exposure to Electromagnetic Fields (EMFs) or RF Radiation, and no meaningful recourse to mitigating any studies or showings of such thereof. Please, Please, look into these issues as I have two young children and am concerned for my kids health, my families well being, along with "our" communities exposure to adverse health risks. I am not asking for the HHS to muscle compliance. I am simply asking HHS to care enough to give Wallington residents a fair and reasonable response to regulations and safety measures which serve to protect the community and uphold the dignity of Wallington's residence. Especially those that are most vulnerable. Thank you in advance for your care in this matter. Sincerely, Wallington resident, near the Hathaway Street Park cell tower.

I appreciate being asked by HHS for comments on this topic. The FCC has not done so in the thirty years since the Telecommunications Act was enacted in 1996. I do not have reason to believe that I have been injured physically. However, I do not want a Smart Meter on my house and Pennsylvania is the only state that does not allow opting out which is a negation of the liberty given to us in the Constitution: “life, liberty and the pursuit of happiness.” Many studies have been done over a period of many years that show the effects of EMF’s (Electro Magnetic Frequency) on the health of humans, animals and the environment. For any industry to not test their products for more than thirty years is ludicrous and dangerous. The wireless devices available today are completely different from what available in 1996. Smartphones didn’t even exist yet. 4G and 5G were unheard of. Children are particularly vulnerable to this damage as their bodies are smaller and spend more time outside where they can be near sources of EMR (Electro Magnetic Radiation). The FCC clearly only cares about the bottom line and the welfare of the taxpayers who support them. I learned about the dangers of cell phone radiation twenty years ago, not from the industry, but from independent doctors and researchers. It’s time for the wireless industry to prove the safety of their products. Until then, those products are to be viewed as unsafe and the industry to be untrustworthy. Note the following review: Investigation of the Adverse Health Effects of Cell Phone Radiation and Propose Solutions to Minimize Them: A Systematic Review https://pmc.ncbi.nlm.nih.gov/articles/PMC11111148/ Sec. Kennedy has promised the American people, “gold-standard science.” It’s time for the FCC to do the same.