Proposed biological mechanisms

**SUMMARY FOR HHS DOCKET HHS-OASH-2026-0397 - Full report in attached PDF** I am a French resident exposed to permanent kHz PLC (Power Line Communication) from PLC Cenelec A/B smart metering in a TT earthing system (35-90 kHz, 24/7 injection). Current risk assessments are flawed: they evaluate the meter alone in idealized lab conditions (anechoic chamber, perfect grounding). This is irrelevant. **The real hazard is upstream and in real degraded environments**: - **Real-world exposure, not clean room**: In France, most rural LV networks are legacy TT with degraded neutral, unshielded overhead cables, wet soil. Injecting kHz carriers creates ground potential aberrations, high-frequency circulating currents, and makes the entire wiring a radiating antenna. The human body in the earth loop acts as parasitic antenna. Measurements must be done in-situ, not on test benches. - **TT grounding aberration as amplifier**: My home measurements show ground current loops and body voltage at kHz. This explains chronic symptoms reported: severe asthenia, dysautonomia, non-restorative sleep. - **Biological plausibility - Chang et al. 2022**: Unmyelinated vagus C-fibers are selectively activated by kHz fields, triggering systemic autonomic dysfunction without thermal effect. This matches my clinical picture and is ignored by thermal-only SAR limits. - **Upstream infrastructure fragility - the hidden confusion**: Public authorities maintain confusion between the meter (low hazard by itself) and the upstream reality: cables and distribution transformers never designed for permanent kHz injection. They become fragile, prone to severe failures we observe in the field: transformer explosions, LV board fires, neutral breaks and phase shifts, premature insulation aging. Focusing only on meter emissions is a category error. **Request**: Please evaluate (1) cumulative kHz PLC in real degraded installations, (2) TT ground current amplification, (3) vagal C-fiber kHz activation mechanism, (4) require measurement of ground currents and transformer LV emissions, not just meter box RF. Full technical report, references (Chang 2022, Schwardt) and field evidence are in attached PDF. Respectfully submitted,

Physician of 21 years experience, with past 15 years focusing on practical application of metabolic/physiologic principles toward the discovery of root cause drivers of common diseases and various symptoms. Past 10 years have professionally and personally encountered peculiar, and often very severe, symptoms that must be classified as neuroinflammatory in nature. Concern: our modern world now presents an unplanned, and unprecedented, number of physiologic stressors to the human physiology. There are likely subpopulations who are more vulnerable; likely, individuals who are in developmental phases (from embryo through puberty). Wireless radiation has been introduced to into the homes, schools, and communities of nearly 100% of the population. Therefore, studying the effects of RF on the population is going to be fraught with difficulty. But, we only need to look at the cascade of physical and psychological challenges that seem to be overwhelming our youth to acknowledge that we must pause and think. RF presents a very unqiue situation: we have the neurobiological effects of the various types of radiation and its continuous nature (24hrs/d everywhere) and the media that this RF carries (social media, intense unadulterated "communication"). As physicians, we committed to "first, do no harm." Our government, of the people and for the people, must create regulatory structures that allow individuals, parents, and communities to have confidence that the people they are charged with serving can have freedom to "pursue life, libery, and happiness". The extreme and untested introduction of RF technologies into our communities is irresponsible: this is evidenced by the 1996 Telecommunications Act prohibiting regulation base on "environmental effects", which seem to have been interpreted by courts of law to include health concerns. (Section 704(a). Obviously, our modern economy now relies on telecommunications and to a large extend RF use. Our advanced society can certainly find paths that allow the advancement of technology while protecting the humans who use it. From my personal experience, all 4 of my children began suffering peculiar health problems which became critical in 2017. Fortunately, I had the training and education to discover the drivers of their problems which included the discovery that radiofrequency avoidance was crucial to their health. Prior to moving to a more remote location to protect my family during their developmental period, we lived in the Phoenix region. My oldest son was having severe depression and seizure like activity- serious daily suffering. When I discovered the potential role of RF exposure, I purchased RF blocking fabric and made a tent for him to sleep in. As a physician and scientifically minded professional, I was astonished how much improvement this strange step made. Obviously, we cannot expect ordinary families to know to take, any how to take these steps... instead, their children are being diagnosed with autism, depression, bipolar disorder, or any number of neuropsychiatric diagnoses that are driven by environmental toxins and neuroinflammatory insults to their physiology. It appears the HHS easily discovered the connection between acetaminophen and autism... we can certainly make some sense around the ubiquitous RF exposure to our children (and everyone on the planet) and learn how to properly implement and make productive use of these technologies. Alternatively, we allow science to progress at the expense of a healthy body and mind... and suffer the societal and individual consequences unnecessarily. I am not going to provide redundant information (a simple search of PubMed will reveal at least a decade of discussion; "Havana Syndrome" already proves the point in an extreme manner; we likely already know what is going on since "radar sickness" was immediately identified in the 1970s when the navy introduced radar.

RFI response on 10-20-26 by Dan Harrison refers to Requirements document: https://www.regulations.gov/document/HHS-OASH-2026-0397-0001 This RFI response is based on peer-reviewed research and Engineering knwledge, Executive Summary It’s well known, to EMF Engineers, that Near-field radiation can bring very intense radiation within inches to human organs (i.e. Brain, auditory channel, Eye, etc. ) primarily because being within particular frequency wavelengths and close proximity antennas can concentrate radiated energy to organ structures. In 4-7-2023, Dr. Lai published a paper: Henry Lai* and B. Blake Levitt, Cellular and molecular effects of non-ionizing electromagnetic fields, Environ Health 2024; 39(3): 519–529 { https://doi.org/10.1515/reveh-2023-0023 } . This paper integrates much knowledge gained over several decades in bio-electromagnetic research and points to a likely unifying mechanism which explains both the many adverse and beneficial effects seen with exposure to man-made EMFs. Dr. Lai paper cites many other studies over +44 years Most of the RFI responses (below) reference Dr. Lai paper, which I Dan Harrison felt it necessary to submit this relevant RFI to HHS {HHS–OASH–2026–0397}.

'The number of studies showing adverse effects on living organisms induced by different types of man-made Electromagnetic Fields (EMFs) has increased tremendously. Hundreds of peer reviewed published studies show a variety of effects, the most important being DNA damage which is linked to cancer, neurodegenerative diseases, reproductive declines etc. Those studies that are far more effective in showing effects employ real-life Mobile Telephony (MT) exposures emitted by commercially available mobile phones. The present review - of results published by my group from 2006 until 2016 - compares DNA fragmentation induced by six different EMFs on the same biological system - the oogenesis of Drosophila melanogaster - under identical conditions and procedures. Such a direct comparison between different EMFs - especially those employed in daily life - on the same biological endpoint, is very useful for drawing conclusions on their bioactivity, and novel. It shows that real MT EMFs are far more damaging than 50 Hz alternating magnetic field (MF) - similar or much stronger to those of power lines - or a pulsed electric field (PEF) found before to increase fertility. The MT EMFs were significantly more bioactive even for much shorter exposure durations than the other EMFs. Moreover, they were more damaging than previously tested cytotoxic agents like certain chemicals, starvation, dehydration. Individual parameters of the real MT EMFs like intensity, frequency, exposure duration, polarization, pulsing, modulation, are discussed in terms of their role in bioactivity. The crucial parameter for the intense bioactivity seems to be the extreme variability of the polarized MT signals, mainly due to the large unpredictable intensity changes. The number of published peer review studies showing DNA damage and related effects induced by Radio Frequency (RF)/microwave Electromagnetic Fields (EMFs), especially by Mobile Telephony (MT) EMFs, on a variety of organisms/cell types under different experimental conditions is increased considerably in recent years [1–36], in spite of attempts to dispute some of them [37–39]. Specifically, the damage on reproductive cells of different animals found in several of the above studies explains other findings connecting microwave EMF exposure with insect, bird, and mammalian (including human) infertility [40–48], or reduction in bird and insect (especially bees) populations during the past 10–15 years [49–53]. The effects on DNA and reproduction reported by different labs on a variety of animals demonstrate a remarkable similarity. For example, Sharma and Kumar [47] found a large decrease in reproduction (egg laying) of bees after exposure to mobile phone radiation, which was identically observed before in fruit flies [15,16,41,42] and birds [49–51]. The recorded decreased reproduction is strongly corroborated by very similar effects in amphibians [54,55], rats [17,46], and human sperm [44]. This unique similarity of effects in different organisms found by different research groups can be explained by the observed cell death induction in reproductive cells due to DNA damage found for Drosophila ovarian cells [15,16], human sperm cells [22], mice and rat sperm cells [10,17], and chick embryos [36]. It is evident that such a similarity of findings is not a coincidence. It is important to note that the exposure levels in the majority of the above studies were below the officially accepted exposure limits [56] and only in a few of them [4–6,13] they were slightly exceeding these limits.' [...] https://www.researchgate.net/publication/331661949_Comparing_DNA_Damage_Induced_by_Mobile_Telephony_and_Other_Types_of_Man-Made_Electromagnetic_Fields

insect-pollinated agriculture is about 35% of food crops and include nuts; microwave and cellular/wifi frequencies decrease insect reproduction rates and 5G additionally occurs at a millimeter and centimeter wavelength which can cook insects of that size (and cells) due to a resonance effect. 'A shift of 10% of the incident power density to frequencies above 6 GHz would lead to an increase in absorbed power between 3–370%. This could lead to changes in insect behaviour, physiology, and morphology over time due to an increase in body temperatures, from dielectric heating.' https://www.nature.com/articles/s41598-018-22271-3 'Microwave radiation is known to kill insects and is already being used for insect control in stored grains and other foods. Studies in food and agriculture literature confirm this effect. (Yadav 2014) (Das 2013) (Geveke 2009) (Ponomaryova 2009) (Zhejiang 2004) (Geveke 2003) (Mishenko 2000)' https://mdsafetech.org/5g-telecommunications-science/ 'Sharma and Kumar [47] found a large decrease in reproduction (egg laying) of bees after exposure to mobile phone radiation, which was identically observed before in fruit flies [15,16,41,42] and birds [49–51]. The recorded decreased reproduction is strongly corroborated by very similar effects in amphibians [54,55], rats [17,46], and human sperm [44]. This unique similarity of effects in different organisms found by different research groups can be explained by the observed cell death induction in reproductive cells due to DNA damage found for Drosophila ovarian cells [15,16], human sperm cells [22], mice and rat sperm cells [10,17], and chick embryos [36]. It is evident that such a similarity of findings is not a coincidence.' https://www.researchgate.net/publication/331661949_Comparing_DNA_Damage_Induced_by_Mobile_Telephony_and_Other_Types_of_Man-Made_Electromagnetic_Fields

I'm a very healthy and fit 71yo woman. I take a lot of precautions with regard to EMR exposure, however, the introduction of 5G has obviously been impossible to avoid in public spaces. I've had an unexplained rise in my Hemoglobin A1c, from 5.3 to 5.9 over the past few years. I don't have any risk factors for type 2 diabetes, so wonder if the beta cells in my pancreas are being negatively effected by 5G. I have 2 friends who are in their mid 60's who like me are very health conscious, lean, and fit. They do not take precautions with regard to EMR and both have HgbA1c's in the pre-diabetic range! What's going on in our environment? Please look into this potential connection. Thank you.

Exposed and not grounded circuits can cause electrical bursts in the surrounding area like surround sound speakers projecting alternate directions. These microwave "heat" capable electrical bursts can destabilize cellular make up, cause cancers, sores, and aches by introducing microwave burst nitrogen in a blood stream. Arcing open electrical circuits across and on victims bodies. These microwaves and electrical currents turn a victims body into "fuse amp" abusing tuning fork knowledge to disrupt cellular make up. A cellphones 4 5 or 6g is another frequency of the same microwave capable circuits not being restricted to their destination flowing freely through people and surroundings. Wireless waves are a constant transmission like the others capable of making noise anywhere within transmission by arcing it across itself repeatedly. Radio waves are capable of creating these same forms of vibrations to destabilize cellular make up creating bursts of sound anywhere in transmission. The Radio communications, Emergency Broadcast System, and Marine Band Radio systems are capable of these disruptive electrical and microwave bursts as are the later constructed Sonar Radar towers. Radar and Sonar use sound projection like porpoise to project sound to a location bounce it back and know it's location from the origins. These repeat pings, vibrations, and sounds can be used like a HARP system capable of moving cloud formations. Anything creating vibrational disturbance irregulates cellular makeup and weakens a body. The least amount of electrochemical disturbance that touches a body the healthier one lives. These disturbances are known to be done publically to steal homes and rotate properties by killing the victim residents and causing them turmoil with accidents. Those sounds have been known to "distract" children infront of moving vehicles and find guns to shoot up schools. They use these frequencies like tuning fork sounds to crack teeth and destabilize jaw structure.

[...] '1.2. Microwave EMFs, electro-hypersensitivity, and cancer During the past 15 years several statistical studies indicate a connection between residential exposure to radiation of MT base station antennas (which emit similar radiation with that of mobile phones), and reported symptoms of unwellness usually referred to as “microwave syndrome”, or “electro-hypersensitivity” (EHS). These include headaches, fatigue, sleep disorders, etc. [57–63]. Similar effects that were previously categorized as medically unexplained symptoms (MUS) are recently attributed to chronic stress and inflammation [64]. Recently, in an effort to find objective methods for EHS evaluation, ∼80% of EHS self‑reporting patients were found to present oxidative stress biomarkers in their peripheral blood [65] which is strongly related to DNA damage. At the same time, more and more epidemiological studies indicate an increasing connection between mobile phone use and brain tumors in humans, [66–75]. The time length of cancer development after cellular damage may be many years depending on the animal and the type of cancer. It is called latency period and is defined as the time between the initial causative event and the development of clinically recognizable cancer. The latency period for gliomas (type of brain cancer) is more than 20 years in humans [76]. This probably explains why epidemiological studies only recently have started showing a connection between mobile phone use and cancer. Tumor promotion in experimental animals after long-term RF exposure at levels below the officially accepted limits is also reported [77,78]. In a recent study of the USA National Toxicology Program (NTP) rats were exposed for 2 years, 9 h per day, in a simulated near field of a mobile phone antenna emitting 2nd generation (Global System for Mobile telecommunications - GSM) or 3rd generation (Code Division Multiple Access - CDMA) EMFs. [The CDMA is part of the Universal Mobile Telecommunication System – UMTS]. Exposed rats developed brain cancer (glioma) and heart cancer (malignant schwannoma) for both lower (1.5 W/kg) and higher (3, and 6 W/kg) Specific Absorption Rate (SAR) levels than the current exposure limit (2 W/kg) for the human head [56,79]. An Italian life-span exposure study of rats in a simulated GSM 1800 far field, also found induction of heart schwannomas and brain glial tumors, in agreement with the results of the NTP study [80]. These findings are in agreement with the above reported DNA damage findings, since DNA damage is a main cause of cancer [81,82]. Alternatively, DNA damage may result in cell death, reproductive declines, or neurodegenerative diseases [83,84]. [...] 1.4. Conflict between experimental studies due to unrealistic exposures An extremely important observation is the intense opposition between the results of experimental studies that employ real exposures from commercially available devices (mobile phones or other telecommunication devices), and studies employing simulated exposures from generators or “test” phones with similar but invariant parameters such as intensity, frequency etc. While ∼50% of the studies employing simulated exposures do not find any effects, studies employing real-life exposures from commercially available devices display an almost 100% consistency in showing adverse effects [34–36,84,100–118]. A wide variety of biological and clinical effects are already found to be induced by real-life exposures on a similarly wide variety of animals/biological samples including human volunteers exposed in vivo (19 studies) [19,34,35,100,104,106–109,114,116], human sperm in vitro (2 studies) [23,100], mice or rats or guinea pigs or rabbits in vivo (24 studies) [100,102,103,105,110,111,115,117], Drosophila (11 studies) [15,16,26,31,41,42,100,101,140,141], bees (4 studies) [47,100,118], ants (1 study) [100], chick embryos (3 studies) [36,45,100], quails (1 study) [100], human cells in vitro (2 studies) [100,112], cow brain tissue in vitro (1 study) [113], mouse cells in vitro (1 study), protozoa (1 study), and even purified proteins in vitro (1 study) [100]. From a total of 71 studies reviewed above that employed real exposures 68 recorded significant adverse effects (95.8%) ranging from loss of orientation, kinetic, behavioural, or EEG changes, heart rate changes, effect on cognitive function and memory impairment, effect on cell growth and proliferation, temperature increases in brain tissue, to decrease in male and female reproductive capacity, reproductive declines, molecular changes, changes in enzymatic activity, biochemical changes in the pregnant women and their embryos, DNA damage and cell death, protein damage, and histopathological changes in the brain [34–36,84,100–118].' https://www.researchgate.net/publication/331661949_Comparing_DNA_Damage_Induced_by_Mobile_Telephony_and_Other_Types_of_Man-Made_Electromagnetic_Fields

As the youngest CEO founder age 25 at NYC 1 WTC of a global management advisory firm in biotech, agrotech, clean energy, and IT, the launch of safe technology underscored every strategy I developed and directed globally. 82 countries leading teams onsite Europe-Arab GCC-Africa-Asia; 28 countries remotely. However, the day I moved into a new Mpls apartment on the Mississippi on January 1, 2017 (a mere 50' from a mobile tower, hidden by trees--unbeknownst to me), directly facing my 6th fl apartment window, I suffered painful cardiac arrhythmia, an extremely"hot metal rod" piercing sensation in my chest, and collapsed. Insomnia, cognitive confusion, and severe migraines ensued -- for the first time in my life. For months, I stumbled around in pain; then it occurred to me to test Radio Frequency (RF) / Microwave Radiation by hiring an EMF physicist who, upon entering with his meter immediately stated: "My God! Readings are so high in your apartment, I cant stay to do the test." Begging him to stay to provide me with some metric of the radiation, he showed me his Acoustimeter AM-11 with RF off the top of his handheld device--he declined and left immediately; it took me a year, but I came to understand his decision justified his immediate evacuation for his safety. I became homeless this year, sleeping in friends' garages, basements, and my car. CEO advisor to royals in the Arab Gulf, including Almarai, a startup venture featured in the Financial Times of London as "among the most profitable in the world" for which HSBC in Mayfair London awarded my global strategy--the 1st non-oil Pan-Gulf global export strategy--the #1 "Transparency Award" in Saudi Arabia. Forced to move to a rural location seeking refuge, but untested RF is ubiquitous; therefore have been confined 10 years to living under a Chinese EMF 3G canopy in a 5' by 8' hallway 24/7, wearing hooded shielded clothing, mocked by uneducated local men who have told me to "take your meds" in mockery. Winner of $750,000 in elite US and European private scholarships and fellowships (New College Oxford, France, Italy); Exec Director, Scully Educational Foundation Board of Trustees, Ireland with Prime Minister; youngest National Delegate NY Democratic Presidential Convention Madison Sq Garden. RF cell phones, 5G towers, Wi-Fi routers, Bluetooth devices, microwave ovens ended my career early, as I collapse in their proximity. Dr Martin Paul sent me research on electromagnetic fields' effect on the body's voltage-gated calcium channels, which forces VGCCs open, flooding my system on being hit by RF--collapsing. Fluent in French, I called my attorney Marc-Pierre Stehlin for a briefing on Dr Dominique Belpomme's novel research on the unexamined effects of Electrohypersensitivity (EHS) and Multiple Chemical Sensitivity (MCS), arguing that these conditions are genuine, man-made neurological disorders caused by non-ionizing radiation from wireless tech and power lines; Belpomme French oncologist and professor at Paris V University Hospital, is being cited as a possible nominee for a Nobel Prize. Low level non-ionizing radiation has cost me my career at its height, my freedom to move including taking a daily walk, the ability to fly on a plane. The US is unlikely to ever provide consumer protection or finance requisite research as long as industry capture dictates our 'scientific' findings; Robert Kennedy Jr may be the one to align us with leading countries which have issued precautionary warnings regarding EMFs, as cited by leaders Devra Davis Phd and Joel Moskowitz Phd.

RE: Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure Docket: HHS-OASH-2026-0397 Perspective (Q2): Individual with compound heterozygous MTHFR (C677T + A1298C), elevated homocysteine, atherosclerosis with plaque, osteoarthritis, chronic tinnitus, cardiac issues, hypertension of undetermined cause, and hypersensitivity to medications, chemicals, and environmental factors. I submit this comment to share personal experiences and support research on vulnerable populations. Q3: I experience chronic tinnitus, cardiac issues, hypertension of undetermined cause, elevated homocysteine, atherosclerosis with plaque, and osteoarthritis. I am highly hypersensitive to medications, chemicals, and other exposures. I also have fatigue, sleep disruption, and cognitive difficulties (brain fog, concentration/memory problems). These have not been fully explained by standard evaluations. I am concerned that cumulative or modulated RF/EMF exposures may contribute or exacerbate symptoms given my genetic background and elevated homocysteine. Q11: I am compound heterozygous for MTHFR C677T and A1298C with elevated homocysteine and atherosclerosis. This genotype substantially reduces enzyme activity (~30–50% of normal), impairing methylation, raising homocysteine risk, lowering glutathione, and increasing oxidative stress vulnerability. Elevated homocysteine is a cardiovascular risk factor and can affect NMDA receptors and calcium signaling. Proposed non-thermal RF/EMF mechanisms (voltage-gated calcium channel activation, excess intracellular calcium, nitric oxide/peroxynitrite, and reactive oxygen species) may interact with these vulnerabilities. People with this genotype, elevated homocysteine, chemical hypersensitivity, or cardiovascular disease may be a sensitive subgroup not fully protected by thermal-only limits. Q11 (Children): A 2026 study (Wydaeghe et al., Phys Med Biol 71:175006) found child models had 1.5–1.9× higher whole-body SAR than adults below 6 GHz. Beamforming created local SAR hotspots exceeding limits even when external exposure met reference levels. Q12: Salford et al. (1994) reported increased blood-brain barrier permeability in rats after 915 MHz exposure. Larger studies (NTP, Ramazzini) also found effects at higher levels. Further research is needed on non-thermal effects in susceptible individuals. Q13/Q16: Wireless Body Area Networks operate close to the body in RF bands including 2.4 GHz (Zhong et al., Sensors 2022, 22:3539). Real-world multi-source exposures and 5G beamforming differ from single-source assumptions. Priorities should include genotype-stratified studies (MTHFR compound heterozygotes), people with elevated homocysteine or cardiovascular disease, chemical/electromagnetic hypersensitivity, cumulative exposure methods, and transparent disclosure of device/infrastructure metrics. I urge HHS, FDA, NIH, and CDC to take reports of unexplained tinnitus, cardiac issues, hypertension, elevated homocysteine, atherosclerosis, osteoarthritis, and hypersensitivity seriously; fund independent research on genetic/metabolic modifiers of RF/EMF response; and evaluate whether current standards protect vulnerable groups. Thank you. Supporting references: Wydaeghe et al. 2026 https://doi.org/10.1088/1361-6560/ae97ac Salford et al. 1994 https://pubmed.ncbi.nlm.nih.gov/8012056 Zhong et al. 2022 https://doi.org/10.3390/s22093539