ORIGINAL COMMENT · UNEDITED TEXT
Perspective: Member of the public and parent.
Responding to Questions 10, 11, 16, and 18: historical animal pathology records as an overlooked data source.
I ask HHS to examine a long-running record that, to my knowledge, has never been studied for its relevance to electromagnetic exposure: the autopsy archive of the Philadelphia Zoological Garden.
The zoo's Laboratory of Comparative Pathology (later the Penrose Research Laboratory) was founded in 1901. From 1916 to 1964, directors Herbert Fox and Herbert L. Ratcliffe kept complete autopsy records on more than 13,000 mammals and birds. Their published reviews describe a striking change:
- In 1923, Fox described arterial lesions as "exceedingly rare," found in under 2% of autopsies. By 1964, arteriosclerosis was found in about 25% of mammals and 35% of birds.
- No coronary artery disease appears in the records before 1945. The first heart attacks were recorded in 1955. By 1963, over 90% of mammals and 72% of birds that died had coronary disease. Heart attacks had struck 24% of the mammals and 10% of the birds, often young animals.
- A 1959 Penrose report compared 1901-1934 with 1935-1955. Malignant tumors rose 2- to 20-fold across nine mammal families, and benign tumors rose even more. Among 7,286 birds, malignant tumors rose 2.5-fold and benign tumors 8-fold.
- The changes spanned 45 families of mammals and 65 families of birds.
The investigators considered the usual explanations. Diets were improved in 1935 and then held constant through 1964, yet coronary disease emerged only after 1945. Population density and exercise were reported as stable. Ratcliffe suggested social stress from breeding programs begun in 1940. That cannot explain the arterial disease of the 1930s, or the continued rise in animals that were not being bred. Similar rates were later reported at the London Zoo (1960) and the Antwerp Zoo (1962).
I learned of these records from Arthur Firstenberg's book The Invisible Rainbow. Firstenberg notes that this period coincides with rapid electrification and, after World War II, a large rise in environmental radiofrequency radiation from radar, broadcasting, and industrial RF equipment. The records contain no exposure measurements, and I am not claiming they prove a cause. But they are a rare, consistent, multi-species dataset covering decades in which diet, crowding, and activity were reasonably stable. The main explanation offered at the time does not fit the data. Captive animals do not change their own habits, which makes them valuable sentinels.
Two broader points. First, any population shows a spectrum of responses to an environmental factor. Even if the median person and above notice little effect from RF exposure, safety standards should be built with the most sensitive people in mind, not the average. A limit that protects the typical adult may not protect the bottom quartile.
Second, exposure drops off sharply with distance from the source, so simple awareness goes a long way. Turning off Wi-Fi at night, or simply not keeping a router two feet from your bed, is not Luddite thinking. It is a reasonable, no-cost precaution that most people have never heard of.
My requests:
1. (Q16) Fund a re-analysis of the Philadelphia Zoo pathology archive and comparable long-term zoo and veterinary records. Pair it with historical reconstruction of local electrical and RF exposure, such as power distribution and nearby broadcast and radar installations.
2. (Q10) Treat zoo and wildlife pathology programs as a standing sentinel surveillance system for environmental exposures, including RF, with exposure monitoring at those sites.
3. (Q11) Because the disease in these records so often struck young animals, give particular attention to children's cumulative exposure as wireless devices multiply in homes and schools.
4. (Q9, Q11) Publish plain-language public guidance on reducing exposure through distance and nighttime habits, and make sure exposure standards account for the most sensitive members of the population, not just the average.
References:
Fox H. Disease in Captive Wild Mammals and Birds. Lippincott, 1923.
Ratcliffe HL, Cronin MTI. Changing frequency of arteriosclerosis in mammals and birds at the Philadelphia Zoological Garden. Circulation 1958;18:41-52.
Ratcliffe HL, Yerasimides TG, Elliott GA. Changes in the character and location of arterial lesions in mammals and birds in the Philadelphia Zoological Garden. Circulation 1960;21:730-38.
Lombard LS, Witte EJ. Frequency and types of tumors in mammals and birds of the Philadelphia Zoological Gardens. Cancer Research 1959;19(2):127-41.
Firstenberg A. The Invisible Rainbow: A History of Electricity and Life. Chelsea Green, 2020.