ORIGINAL COMMENT · UNEDITED TEXT
Children should not be treated as small adults in RF/EMF research or risk assessment.
Pregnancy, infancy, childhood, and adolescence are periods of rapid growth including and not exclusive of neurological, immune, endocrine, reproductive, and metabolic development. However, children today are growing up in an electromagnetic environment that is not only fundamentally different from that experienced by previous generations, but are receiving extensive, undocumented and unstudied cumulative exposures. Wi-Fi, cell phones, tablets, Bluetooth devices, smart meters, wireless baby monitors, smartwatches, wireless classrooms, IVs, and increasingly wireless medical devices add to a child's overall exposure beginning very early in life (preconceptually and fetal exposures as well).
The available pediatric research remains inadequate to answer some fundamental questions. A 2022 systematic review by Bodewein and colleagues examined 42 epidemiological and 11 experimental studies involving children and adolescents. Evidence regarding cognition, behavior, and subjective symptoms was judged low to inadequate, while evidence regarding early childhood development, brain activity, cancer, and physiological outcomes was considered inadequate for drawing conclusions. Investigators cautioned that these findings should not be interpreted as demonstrating that RF exposure is safe for children.
An absence of demonstrated harm is not equivalent to demonstrated long-term safety.
Those of us with concerns are neither 'anti-science' or 'anti-technology'. Wireless medical devices such as the continuous blood glucose monitor (CGM) require a more nuanced approach. I care for children with type 1 diabetes who depend upon CGMs. The clinical benefits of these devices are significant and potentially lifesaving. A medically necessary CGM should therefore not be treated as equivalent to a smartwatch simply because both use wireless technology. Looking at comparative dosimetry across common pediatric devices would help clinicians and families make rational decisions based upon actual exposure and benefit rather than fear.
I also encourage HHS to examine exposures in electric and Waymo-type vehicles. A published study measuring extremely low-frequency magnetic fields in the rear seats of ten electric vehicles specifically considered children because their smaller bodies may place them closer to electrical systems beneath the vehicle floor. The measured magnetic fields were far below current international exposure limits, which is reassuring. This does not answer the question of long-term developmental exposure. Research must characterize passenger-compartment exposures by seating position and age, and evaluation the following conditions: acceleration, cruising, regenerative braking, and other real-world operating conditions. Manufacturers should be held to provide consumers and researchers with standardized measurements of the electromagnetic environment inside their vehicles.
The most important research gap is cumulative exposure.
Children do not experience wireless technologies one at a time. A child awakens in a Wi-Fi- home, wears a smartwatch to soccer practice, uses Bluetooth earbuds at the gym (I see this all the time in High Schoolers), carry an iPhone in their back pocket or bra, spend six hours in a wireless school environment, travel in an EV, return to a home containing numerous wireless devices including Alexa, and sleep near a phone or a phone under their pillow. A medically complex child can have additional wireless medical technology as mentioned.
Please prioritize:
-Longitudinal studies during pregnancy, following children through adolescence.
-Pediatric dosimetry that reflects age, body size, individualized physiology, device placement, and real-world use.
-Long-term studies of all physically wireless devices.
-Comparative exposure studies of medically necessary versus discretionary wireless technologies.
-Studies of cumulative RF/EMF exposure across the home, school, transportation, medical, and recreational environments.
-Independent characterization of passenger exposures in electric and Waymo-type vehicles.
-Public health educational programs including the use of nonessentials, like wi-fi baby monitors.
Research examining biological effects below existing federal exposure limits, including mechanistic studies addressing oxidative stress, mitochondrial function, calcium signaling, inflammation, sleep, neurodevelopment, reproductive health, metabolism, and immune function, and effects on the microbiome while clearly distinguishing reproducible findings from preliminary or conflicting evidence.
Precaution does not require panic, fear, or neuroses, nor does scientific uncertainty establish harm. But uncertainty should also not be mistaken for proof of long-term safety.
Thank you for your serious investigation of this issue.
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