Children & vulnerable groups

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.

Public Comment: Request for Independent Research, Transparency, and Public Health Protections Regarding EMF and Radiofrequency Radiation Exposure To the U.S. Department of Health and Human Services: I urge HHS to conduct a comprehensive, transparent, and scientifically rigorous review of electromagnetic fields (EMFs), radiofrequency (RF) radiation, and wireless radiation exposure. This review should prioritize public health, scientific independence, informed consent, and the protection of all communities. The public should not have to choose between dismissing legitimate health concerns and accepting claims that have not been adequately demonstrated. We need independent research, honest evaluation of conflicting findings, and clear communication about what is known, what remains uncertain, and what further investigation is necessary. I respectfully request that HHS: 1. Review the full body of scientific evidence. Evaluate peer-reviewed studies on potential health effects of RF and EMF exposure, including studies reporting positive findings, negative findings, and inconclusive results. Explain the strength and limitations of the evidence. 2. Investigate real-world exposure. Examine exposure levels, duration, frequency, cumulative sources, and differences between laboratory conditions and everyday environments. Identify research gaps without assuming that cumulative exposure necessarily causes harm. 3. Protect potentially vulnerable populations. Assess whether children, pregnant people, individuals with medical conditions, and other potentially susceptible groups require additional research or protective measures. 4. Ensure scientific independence. Disclose funding sources, conflicts of interest, research limitations, and the methods used to evaluate studies. Support independent replication and research that is not controlled solely by industries with financial interests in the outcome. 5. Investigate reported health concerns objectively. Establish appropriate research and reporting pathways for people who experience symptoms or believe their health is affected by environmental exposures. Such reports should be documented and investigated without automatically assuming either causation or fabrication. 6. Make the findings accessible to the public. Publish the evidence reviewed, research methodology, identified uncertainties, and recommendations in plain language. The public deserves to understand the scientific basis for federal health guidance. 7. Address emerging wireless technologies. Determine whether existing research and exposure standards adequately address evolving technologies, changing patterns of use, and relevant exposure scenarios. Where evidence is insufficient, identify the additional research needed. 8. Provide meaningful public participation. Include independent scientists, public health experts, affected community members, and individuals reporting health concerns in appropriate research and policy discussions. Scientific integrity requires more than telling the public that evidence is insufficient. When evidence is insufficient, the next question must be: What research is needed, who will conduct it independently, and when will the public receive the results? I am asking HHS to take these questions seriously, evaluate the evidence without predetermined conclusions, and establish a clear plan for addressing unresolved scientific questions. Public health decisions should be grounded in transparent evidence, independent research, accountability, and the precaution necessary when important questions remain unanswered. Please include these concerns in the agency’s review and make the resulting findings and recommendations publicly available. Respectfully submitted, Leah Testerman

Comment of Protection of the Educational Rights of Kids (PERK), Amy Bohn, President, in Docket HHS-OASH-2026-0397. Our full comment is attached. It responds to Questions 2, 5(n), 9, 11(a), 12, 13(c), 15(a), 16, and 17 as numbered in the notice. We file as a parent-led organization. Children in American public schools and licensed child care spend six to seven hours a day, roughly 180 days a year, inside wireless infrastructure that their parents were never told about and never asked to approve. That is the parent side of this docket, and it does not depend on how the science comes out. The FCC's exposure limits date to 1996 (11 FCC Rcd 15123). The D.C. Circuit held in 2021 that the FCC had not given a reasoned explanation on children, long-term exposure, and the spread of wireless devices, while taking no position in the scientific debate (Environmental Health Trust v. FCC, 9 F.4th 893). The FCC reopened that record only on September 17, 2026, while a mandamus petition was pending (In re Children's Health Defense, No. 26-1121). The FDA's 2020 literature review addressed cancer only. This notice itself says public concern has risen, particularly around children, schools, and long-term cumulative exposure. When the government cannot say the question is closed, the decision belongs with the parent, and a parent cannot decide without information. What changed since 1996: the FCC funded classroom Wi-Fi through E-Rate Category Two (FCC 14-99; 47 CFR 54.502); 88 percent of public schools now run one-to-one device programs (NCES, 2024-25); and Florida regulates the student's phone during the school day (s. 1006.07(2)(f), Fla. Stat.) but no Florida statute or State Board rule requires a district to tell parents what wireless infrastructure operates in a classroom. The only federal notice requirement attached to E-Rate concerns content, not equipment (47 U.S.C. 254(l)). We ask HHS to do four things. 1. Disclosure (Question 9). Issue a six-item notice format for schools and licensed child care providers: an inventory of transmitters by classroom; the operating schedule; device practices; any measurements taken; wired alternatives and how to request a lower-exposure placement; and a contact. France's 2015 law (Law No. 2015-136, art. 7) and Maryland's 2016 advisory council report already recommend practices of this kind, and Oregon (SB 283, 2019) and New Hampshire (HB 522, 2019) have put the question to study. 2. Guidance (Question 5(n)). Issue practical exposure-reduction guidance for schools and child care providers: wired connections where practical, access points off when not in use for instruction, devices off the body, and no wireless equipment in rooms for the youngest children. School network controllers in common use already support scheduled availability as a standard feature. 3. Measurement (Question 16). Fund a national study of RF levels in occupied classrooms and child care rooms during the school day. No federal agency has published such a dataset. The one government classroom measurement study we found is ARPANSA's 2017 study of 23 Australian schools. Add wireless infrastructure and parent notice questions to CDC's School Health Profiles, which ask nothing on the subject today. State whether the National Toxicology Program's RF research, listed as completed, will resume. 4. Coordination (Question 17). Open a standing channel with the Department of Education and the FCC, and ask that E-Rate Category Two recipients post the equipment disclosure at the internet safety hearing the statute already requires. We also ask the Department to state in its summary of this docket that schools and child care facilities are settings of involuntary, long-duration exposure for children, and that disclosure to parents is warranted on that basis whatever the outcome of the scientific review. PERK's September 2026 filings in Docket HHS-OS-2026-0332 rest on a survey of 664 parents. We offer to run a wireless version of that instrument, measuring notice and consent as parents experience them, with partner organizations across multiple states, and to provide the results to the Department in whatever form it designates. The instrument is available on request. This comment contains no personally identifiable or personal health information. Every factual claim in the attachment is cited to a primary source, with a Sources list at the end. Prepared by Rebekah Ricks, Senior Consultant. Contact: abohn@perk-group.com; Rebekah@PERK-GROUP.com.

I support HHS in taking an active part in researching & then regulating the obvious affects that wireless radiation has on our environment with regard to our children, animals, birds, flora & fauna, etc. The time has come for this issue to be brought out from under the rug & scientifically examined in great depth. Our Mother Earth home deserves that We The People do the right thing by her. Thank you from a mother, grandmother, great grandmother & health freedom activist

World Council for Health (WCH) welcomes the opportunity to respond to the U.S. Department of Health and Human Services' Request for Information. WCH is an international health advocacy organisation committed to promoting informed consent, individual health sovereignty, scientific transparency, and the protection of human and environmental health. We believe that the rapid and largely unrestrained expansion of wireless technologies represents a significant public health and environmental policy concern that warrants urgent, independent and comprehensive scientific scrutiny. Over recent decades, wireless communications infrastructure has expanded dramatically, introducing increasingly widespread and persistent exposure to man-made electromagnetic fields. While technological innovation has brought considerable benefits, WCH is concerned that the pace of deployment has outstripped the assessment of potential long-term biological and environmental consequences, particularly in relation to chronic, cumulative and involuntary exposure. In 2023, WCH published its Policy Brief on the Effects of Unregulated Digitalization, examining the wider implications of rapidly expanding digital and wireless technologies for public health, human rights, democratic accountability and the environment. This body of work includes the recommendations of the late Dr Arthur Firstenberg, who devoted decades to investigating the biological and ecological effects of electromagnetic fields. His work brought together scientific publications examining possible effects on neurological function, cellular processes, reproduction, wildlife, biodiversity and ecosystem health. Of particular concern is the extent to which existing RF exposure standards have historically focused on established thermal effects, while questions concerning long-term exposure, non-thermal biological effects, signal modulation, vulnerable populations and ecological impacts remain contested or insufficiently resolved. WCH believes that public health policy must consider the full breadth of available evidence, including research findings that challenge prevailing assumptions about exposure thresholds and biological safety. We are particularly concerned about the implications for children, pregnant women, individuals reporting electromagnetic hypersensitivity, and those who have little practical ability to avoid exposure in their homes, schools, workplaces or communities. The continued expansion of 5G telecommunications and wireless infrastructure including the introduction of new frequencies, network configurations and connected technologies raise further questions about aggregate exposure, long-term health effects and the adequacy of existing safety assessments. The potential environmental implications must also be considered. The Brief highlights research examining associations between anthropogenic electromagnetic fields and changes in the behaviour, development, reproduction and survival of insects, birds, plants and other organisms. These findings require careful evaluation, including consideration of study limitations and other environmental factors, as part of a comprehensive approach to ecological protection. WCH therefore calls for an independent, transparent and multidisciplinary review of the scientific evidence, free from inappropriate commercial or regulatory conflicts of interest. Such a review should address thermal and possible non-thermal effects, chronic and cumulative exposure, biological responses to modulation and pulsed signals, and the implications of exposure across the lifespan. We further urge HHS to consider the precautionary principle, particularly where exposure is involuntary, where vulnerable populations may be affected, and where meaningful opportunities to reduce unnecessary exposure exist. This includes serious consideration of practical alternatives such as wired communications infrastructure, greater public disclosure of exposure information, improved professional education, and individual choice. WCH encourages greater coordination between public health authorities, environmental agencies, independent researchers and affected communities, recognising that the potential implications of electromagnetic pollution extend beyond conventional telecommunications regulation. The protection of public health and the natural environment must remain central to technological policy, and not be treated as secondary considerations after widespread deployment has already occurred. We believe that responsible technological development must be guided by independent science, transparency, informed consent, the protection of vulnerable populations, and a commitment to safeguarding the health of both present and future generations. Yours sincerely Dr Tess Lawrie MBBCh, PhD Ambassador World Council for Health worldcouncilforhealth.org https://www.worldcouncilforhealth.org/what-is-5g-health-risks/

There are many reasons to research the impact of man-made non-ionizing radiation. First, we’ll start with cellphone and mobile base stations (MBSTS) effects on children (it should be noted these base stations are leased and pay the schools tens of thousands of dollars annually). A study involved parting a non MPBST (mobile phone base station) exposed group to an exposed group and comparing test scores after a period of 2 years’ time (Meo SA et all, 2018). The impact of the radiation showed memory and motor deficiencies of significant value. In the attached report you’ll see a significant difference in the study groups when it comes to learning and memory. I will say that I have measured the radiation from my cellphone in an otherwise zero EMR environment. The zero EMR environment registers 0.2 to .5 mW/cm2 (0.2 microwatts per meter squared), which is considered very safe. Comparatively, when you measure my phone with its Wi-Fi turned on (and no other connectivity signal), I get 189,000 mW/cm2. That’s an incredible difference. Other individuals of concern are those with preexisting medical conditions, especially those with weakened immune systems are more susceptible to the degrading effect EMR has on the blood brain barrier. The BBB is a semipermeable border that moves ions, oxygen and water between the blood and the central nervous system. It serves to block pathogens and toxins from entering the brain and these studies have found correlation between EMR and penetrability of the Blood Brain Barrier. Additionally, IARC (International Agency of Research on Cancer) have found cellphone users have a greater risk of cancer (MSD, 2016). Cumulative exposure is the biggest problem with EMR. It is very hard to determine the cause of issue when so many devices are involved. The various sources of cumulative exposure include 6G, 5G, Wi-Fi and wearable technology. 6G involves THz (Terahertz) frequencies that will have the ability to alter DNA and neurons. It has been determined that 5G and 6G and other high frequency radiation causes tissue and nerve damage (Minar, 2025). The IoT will magnify the effects of EMR as many appliances connect and communicate with each other. Wearable technologies concentrate EMR on the body and range up to 2.4 GHz, which is not advisable to wear and it is not fair to expose others to this device’s radiation (Revolutionhealth, 2025). Unless it is mandatory, wireless medical devices should not be worn (mdasafetech, 2026). It is also known that wireless devices can cause heart issues and it’s extremely ironic they are used to measure heart rate and other general health metrics. As for satellite-based communication, studies need to be made regarding its impact on the environment and biology. The WHO and FCC have already mentioned, in their former studies, that electromagnetic radiation devices are possibly carcinogenic. These same studies are decade’s old and needing review. It should be assumed that at this point, with the massive increase in man-made electrical fields, that scientific evidence is irrefutable and that it does cause harm (Johansson, 2026). Like tobacco and alcohol, outreach/education about the potential harmful impacts of wireless radiation should be readily available with warning labels. At this time, the cellphone and telecommunications companies are largely uninsurable due to the high risks of electromagnetic fields (ehtrust, 2026) (Complete Markets, 2026). Since we are discussing the need for HHS to reevaluate and none of the other branches, we can talk about the need to expand its epidemiological studies to cover the cancer and leukemia issues known to be associated with this as well as harm reduction in classes, libraries, hospitals and public spaces. Every technological product we use has a measurable field. These items should be 3rd party tested and sold with the readings provided and a warning label printed. The packaging should be sold with a label that states its level at microwatts per meter squared (mW/cm2) and each level should be color coded for quick recognition so that we can create a baseline chart that consumers easily understand. Much like the EMR test meters available on the markets, you’ll have Red, Orange, Yellow and Green and these colors correlate to the degree of signal on the object. The FDA will be responsible for labeling and verifying full disclosure is provided to consumers. Public spaces need to be measured and coded as well and if possible, provide Ethernet connections and lower their EMR signal to the minimum necessary. We already have thousands of well researched, published scientific articles online that have spanned 40-50 years. We don’t need to invent the cart; we just need some horses and a destination. Thank you for taking the time to read my comment on man-made electromagnetic radiation and its effects on health. Sincerely, Nicole Stallings

Please see the attached document: my response to the HHS Request for Information on Electromagnetic Fields and Wireless Radiation (HHS-OASH-2026-0397). I am an Electromagnetic Hypersensitive (EHS) person from Israel and an EMF/EMR awareness activist. My life, and my daughter's, have been deeply affected by exposure to EMF/EMR. Since 2006 I have supported EHS people in Israel and worldwide with exposure measurement and reduction, and I run the information site www.norad4u.com. My main points: 1. Many studies show biological and health effects of RF/EMF at levels far below current FCC and ICNIRP limits. 2. EHS is real and is caused and influenced by EMF/EMR exposure. Reducing exposure reduces symptoms. 3. Provocation studies with design flaws (such as Rubin et al., 2006) should not be used to dismiss EHS. 4. Exposure should be measured with fast-sampling meters showing peak values, not averages over minutes. 5. New, health-based exposure guidelines are needed, with special protection for EHS people, children and other sensitive groups. 6. Federal health agencies should track symptoms, EHS cases and exposure, and fund research on how, not if, EMF/EMR causes harm. The attached document answers the RFI questions (Q2–Q17) and includes a numbered list of 134 scientific references. Amir Borenstein Zichron Yaakov, Israel norad4u@gmail.com

Hello - I am asking that the US Government and specifically the HHS organization - ban 5G and take the bold steps to protect the citizens and children on this nation. The EMF's and dirty energy that is present in the automobile industry is causing ill health to many. Attached are some studies that alert you to the KNOW health issues. Protect and provide warnings to the children and citizens who are receiving harm without their kknowledge.

Hello. Thank you for the opportunity to comment on this important issue. I’m the mother of an 8 year old son with severe autism and PANDAS. It’s been a long journey of some terrible, terrifying, dark years. Last year, we invested in bio medical testing and discovered our son had mold and heavy metal toxicity. We live in Minneapolis. MN. We moved out of our moldy house and into temporary housing in a nearby suburb in Eden Prarie. Within a week, all my son’s most difficult symptoms disappeared. He became calm. He wasn’t having melt downs or injuring himself. He was sleeping through the night. He stopped wetting the bed. His bowel movements improved. He became easy going and was smiling and laughing again. Within a month, the change was miraculous. We moved into a new, mold-free apartment in Minneapolis. He wasn’t doing as well. His conatipation returned. He was agitated and struggling with transitions again. I started looking into the differences between the two locations and one possibility was EMF’s. I checked the cell tower maps. The temporary housing had six cell towers within three miles, and they were all at least one mile away. Our house and apartment in Minneapolis have hundreds and several within 1/2 mile radius! We also have solar panels on the roof which I learned is a huge issue. We started mitigating EMF’s in our apartment - hard wiring our phones and computers, and we got him an EMF blocking canopy for his bed. He improved greatly, but it is taking a lot more effort and interventions to maintain and build on what was coming easily in Eden Prarie. There is simply too much exposure living in the city, and with our apartment neighbors all having WIFI and Smart Appliances. This is a growing issue! I can’t even send my son to school because of mold and EMF’s with the cell towers being right on the school property! They don’t belong anywhere near residential areas. I’ve learned that EMF’s exacerbate mold growth and mycotoxin activity uo to 600x. We still have mold colonized in our bodies being activated by the EMF’s. I’ve also learned that if you have high heavy metals (which mold causes), your body attracts more of the radiation. We need legislation stopping this biological warfare.

Devastating for us and our children’s health. I also dont have any birds left in my neighborhood.