Proposed biological mechanisms

Public Comment — HHS-OASH-2026-0397 I hold a PhD in Biomedical Sciences (Molecular Medicine) from the University of Iowa and a BSc in Biology from Tufts University. My background includes over three years of medical training in an MD/PhD program, biomedical research, and environmental health research development. My current work focuses on real-time indoor fungal monitoring and citizen-science approaches to understanding environmental exposures and health. I have personally experienced significant illness associated with water-damaged, mold-affected indoor environments. I cannot establish that electromagnetic fields (EMFs) contributed to my illness, nor am I reporting confirmed electromagnetic hypersensitivity. My experience has nevertheless reinforced the importance of investigating poorly characterized environmental exposures before preventable harms become widespread. Biological mechanisms: Non-ionizing radiation lacks sufficient photon energy to directly ionize molecules, but that distinction does not establish biological inertness. Human physiology depends on membrane potentials, ion transport, and electrochemical signaling. Under appropriate conditions, external electric and time-varying magnetic fields induce currents and affect excitable tissues, as demonstrated by medical applications such as transcranial magnetic stimulation. These established effects do not prove that everyday wireless exposures cause neurological harm. They do justify evaluating specific frequencies, field strengths, modulation patterns, and durations rather than treating non-ionizing status alone as a safety determination. Environmental interactions: I encourage HHS to examine whether EMFs can influence indoor fungal physiology, including growth, sporulation, allergen production, oxidative-stress responses, or secondary metabolism. This is a hypothesis, not an established explanation for mold-related illness. Evidence that ordinary household wiring, Wi-Fi, or cellular signals increase mold virulence or toxicity is insufficient. Controlled studies should compare realistic exposures with sham conditions and measure fungal outcomes while controlling for moisture, temperature, substrates, and ventilation. Low-frequency electrical fields and radiofrequency wireless exposures should be evaluated separately. Exposure assessment: Better personal and building-level measurements are essential to identifying meaningful exposure-health relationships. I recommend validated, time-resolved monitoring of relevant exposure characteristics, combined with building data, objective health outcomes, and carefully designed longitudinal or citizen-science studies. Studies should address confounding, exposure misclassification, selection bias, privacy, and reproducibility. Clinical research: Individuals reporting symptoms they attribute to EMFs deserve respectful care and rigorous investigation. Blinded provocation studies have generally not established a consistent causal link between everyday RF exposure and reported electromagnetic hypersensitivity symptoms. Future research should investigate symptoms and potential contributing factors without presuming either causation or dismissal, and should consider populations with distinct exposure or health vulnerabilities. I ask HHS to prioritize: (1) independent, reproducible mechanistic studies at environmentally relevant exposure levels; (2) improved electromagnetic dosimetry and longitudinal exposure assessment; (3) exploratory research on EMF interactions with indoor microbiology; (4) interdisciplinary collaboration across neuroscience, biophysics, environmental epidemiology, microbiology, and building science; and (5) accessible, evidence-based public guidance that clearly distinguishes established risks from uncertainty. The absence of conclusive evidence of harm is not proof of safety; equally, plausible mechanisms and reported symptoms are not proof of causation. Preventative public health depends on investigating uncertainty with rigor and transparency, so individuals can understand their environments and make informed decisions. Rebecca Lesan, PhD Biomedical and Environmental Health Researcher Zürich, Switzerland

Digital meters were put on our homes in Oklahoma in 2014 and my husband died in early 2017 diagnosed with bulbar ALS and mononeuritis multiplex. He could not talk, eat, drink. after he died i added a sine tamer filter to our home circuit box and home stetzer readings were 50 until this year when i changed internet to fiberoptic. readings were 1999 (the max the stetzerizer meter reads). the router is dirty and was not filtered or shielded and added lot of dirty electricity to my home wiring. my home is 40 years old and does not work well with corrosive microwave radiation. i bought shielded surge protectors and only turn router on when using and have it in a faraday cages. home outlet readings are about 250-300 now (25-50 normal). Spent 3 days in Maine at 3 major hotels that all read 1999 on stetzerizer meter and the rooms all had loud locust sound from acoustic nature of fiberoptics. came home and did labs.my nitrotyrosine was double over the max value and my iron saturation very low as well and other values not normal. i took molecular hydrogen to fix the iron and NAC with selenium and molybdenum for nitrotyosine for 2 months and other supplements like glutathione and coQ10 that help with the electron transport system. i take supplements every day to try to stay detoxed. i truly believe that by not testing labs completely for nitrotyrosine (very difficult to do in the USA) and nitric oxide and do complete thyroid and not just TsH /T4 (also not done in USA like should be) if body temperature lower than 98.6 then take tyrosine and iodine (T4 wont fix it) cause reversible T3 needs fixing and thyroglobulins affected)) and do complete iron and correcting it with molecular hydrogen and lactoferrin cause the charge needs fixing back to Fe4 electron transport from Fe3 storage. iron is paramagnetic and emf causes rouleaux effect and affects the charge and then iron gets stuck at neuromuscular junction at motor cortex and cant change from chemical to electrical so does not function as it should as iron and enzymes systems wont work. pilots are exposed to nonionizing and ionizing radiation. My husband flew a lot. must protect pilots because they sleep in these toxic hotels and are becoming suicidal more. plus just their occupation has cumulative effect and they should be tested annual for nitrotyrosine levels and detox. test complete thyroid and iron level and fix their tyrosine and iodine levels and body temperature and filter and shield these dirty electricity hotel rooms. look at zinc/copper ratio- magnesium cause calcium goes intracellular thru calcium voltage gates causes Blood brain barrier capillary leak issue and neurodegenerative diseases (use vit D, K2, Omega 3) Do a complete amino acid profile annual and fix those. Taurine detoxes myeloperoxidase, histidine for RA, sulforaphane for NRF2 activation, citrulline and beets for nitric oxide, glutathione and blueberry for glutamate, SOD superoxide dismutase major antioxidant for free radicals, pregnenolone for myelin sheath, CoQ10 and PQQ for electron transport system, methylated B Complex with C to help recharge body battery. For areas with high emf, look at dentist offices, the malls, pharmacies with pharmacists standing in front of laser printers and pharmacists losing babies, perhaps use of faraday cages in order, airports and scanners and planes and pilots. look at hard wiring home instead of wifi but harder now to buy a laptop with ethernet connection, its our world blanketed in emf/ rfr /wireless so we must protect ourselves and call these problems that come with it what it is. start testing and treating it for what it is before we all die. i really miss John.

1. & 2. I am responding as: an individual 3a. Type of wireless or RF/EMF sources involved (e.g., mobile phones, Wi-Fi, smart meters…)Since 2008 a lot of exposure to WiFi and mobile phones (work). Last year: New cell phone tower on neighbor building 3b. Nature, duration, frequency, and approximate timing (e.g., years):New >3Ghz cell phone tower (European non-nanometer 5G), since over one year. 3c. Adverse health effect(s) experienced:Bad sleep quality, high stress level, constantly feeling exhausted, chronic issues worsened 3d. Time from first exposure to first appearance of adverse health effects; and did a change in exposure coincide with the onset of adverse effects:It was noticeable in the days after the new cell phone sender/receiver was installed 3e. Was medical evaluation or treatment sought? (Optionally:) Was there a diagnosis?Yes, no clear diagnosis, symptoms were attributed to high stress level (flare up) 3f. Were steps taken to reduce or eliminate exposure, and were there subsequent changes in the effects?I bought an expensive device to "neutralize" the negative effects of the EMF and it did help to a degree where I could get somewhat decent sleep again. I am now in the process of moving out of this apartment. 3g. Any supporting documentation? This includes Scientific Reports, exposure measurements, or other relevant information:I have an "e-Spion" meter, an analog HF meter. It was basically impossible to measure anything as the EMF level was way beyond the maximum range of the meter. That was the case before already, so I could not tell a difference from before/after as the device is too sensitive for the intensity in this apartment. Additional Details you would like to share about your experiences of adverse health effects you believe to be associated with exposure to wireless radiation or EMF's:I believe there is a connection between chronic infections (EBV, Bartonella, Lyme, Helminths...), heavy metals and EMF. That combination seems to be especially detrimental to health. And possibly when adding spike protein – it becomes a very toxic mix. B1a. Sources you experience as causing you Adverse Effects:Holding a phone in the hand while charging has directly noticeable effect. B1b. Sources you can sense, but don't seem to harm you:When adding certain "neutralizers" to a cell phone, I can 'feel' a difference. And as I am highly skeptical of such devices, I doubt it's a placebo effect. B1c. Sources you can use without sensing or being harmed: B1d. Sources that seem to provide benefit (i.e., electrotherapy): B2a. Health conditions you think may contribute to your sensitivity to EMFs including wireless:Chronic infection (EBV, Bartonella, mold toxins) B2b. Health conditions you don't necessarily associate with your sensitivity to EMFs including wireless, but might be relevant: B3. For each subquestion please list up to 5 drugs or therapies or home remedies (if any) B3a. That you recommend, as they helped you tolerate or recover from EMF exposure:Toxopheresis (INUSpherese) to get rid of heavy metals. B3b. That you recommend, but you’re not positive that they help:GABA, Theanine, NAC, Glutathione, Apigenine and other plant extracts. Reducing EMF by using shungite powder mixed in wall paint (only one room, but that already made a difference). B3c. That helped you but you don’t recommend. (e.g., the benefit did not last long or the side effects were too harmful): B3d. Treatments that had no effect:Generally: Detoxing too fast or when dealing with LPS carrying bacteria, killing those off too quickly B3e. Treatments that made your sensitivity worse:35-44 B4. What is your age range?35-44 B5. What year did you become aware of your sensitivity to wireless radiation or electromagnetic fields?2010 B6. What country, state, province, or major city were you living in when you first noticed your sensitivity to wireless or electromagnetic fields?Germany, Mannheim

SUPPLEMENTAL COMMENT: RADAR MAINTENANCE, ELF FIELDS, X-RAYS, AND PARATHYROID DISEASE This supplements my prior HHS comments on radar maintenance, RF exposure, deficient monitoring, medical surveillance, latency, and accountability. I request investigation of extremely low-frequency (ELF) magnetic fields from numerous transformers and a Power Conditioning System (PCS) inside an ASR-11/MSSR equipment shelter, alongside RF and possible incidental X-rays. SWEDISH OCCUPATIONAL STUDY: Hakansson et al., "Arc and resistance welding and tumours of the endocrine glands," Occupational and Environmental Medicine 2005;62:304-308; DOI 10.1136/oem.2004.015479, examined 67 parathyroid tumor cases. Adjusted odds ratios were 3.3 (95% CI 1.6-6.9) for any welding, 4.3 (1.7-10.6) for arc welding, and 2.6 (0.9-7.1) for resistance welding. The authors considered ELF magnetic fields a possible explanation. Welding has other exposures; the association does not prove ELF causation. It does justify targeted research among electrical and radar technicians. ASR-11/MSSR SHELTER: Commissioned at my FAA facility in 2007, the installation placed numerous energized transformers and a PCS IN THE SAME ROOM where technicians routinely worked, often at close range. Transformer leakage flux, load currents, conductor routing, and power electronics can produce spatially variable 60 Hz magnetic fields, harmonics, and switching-frequency fields. These sources differ from radar RF emissions. HHS should examine equipment ratings, locations, loads, technician proximity and work duration, and any ELF surveys. RF SHIELDING IS NOT ELF PROTECTION: Metal cabinets and enclosures effective against radar RF cannot be assumed to attenuate 60 Hz magnetic fields. Ordinary conductive RF shielding may offer little attenuation at power frequency. Actual protection depends on magnetic permeability, thickness, geometry, frequency, and source arrangement. Some steel structures reduce ELF fields; effectiveness requires measurements or engineering analysis. RF compliance does not establish ELF safety. IONIZING RADIATION LITERATURE: "The Parathyroid as a Target for Radiation Damage," New England Journal of Medicine 2011; DOI 10.1056/NEJMc1104982, reported signs of primary hyperparathyroidism in 15 of 61 Chornobyl cleanup workers following substantial radiation exposure. "Dose-response relationships for radiation-induced hyperparathyroidism" (PMID 7829622) identified 36 confirmed cases among 2,555 people irradiated in childhood and a significant dose-response. "Parathyroid tumors in atomic bomb survivors in Hiroshima" (PMID 1762105) reported a radiation-associated trend. "Therapeutic radiation and hyperparathyroidism" (PMID 2764660) provides further case-control evidence. A 2024 UK vascular surgeon radiation-safety survey (DOI 10.54522/jvsgbi.2024.155) reported one parathyroid adenoma, an observation that does not prove causation. These exposures differ from mine, but justify investigating occupational ionizing radiation and long latency. MEDICAL CHRONOLOGY: I maintained military radar/electronics beginning in 1982 and FAA systems through 2017. Original laboratory records show calcium 8.8 mg/dL in 2002; subsequent values include 9.0 (2004), 8.9 (2005), 9.8 (February 2007), 10.0 (2011), 10.2 (2016), 10.6 (December 2017), and 10.8 (March 2018). PTH was 174 pg/mL in January 2018. A parathyroid adenoma was removed April 23, 2021. This documents evolving biochemical findings, not proven disease onset or causation. The 2007 installation merits scrutiny without excluding earlier exposures. DISTINCT EXPOSURE PATHWAYS: Some legacy high-voltage radar electron tubes can generate incidental ionizing X-rays under certain conditions. X-rays, radar RF/microwaves, and ELF magnetic fields require separate exposure assessments. Neither RF compliance nor lack of personal dosimetry proves that other exposures were absent. Proposed mechanisms involving oxidative stress, calcium signaling, or endocrine-cell proliferation should be studied, not presumed established. I REQUEST THAT HHS: (1) review and commission follow-up to the Swedish parathyroid findings; (2) evaluate transformer and PCS magnetic fields at actual FAA technician positions, including shielding effectiveness; (3) establish long-term FAA ATSS and military radar-maintainer cohorts tracking calcium, PTH, parathyroid adenomas, hyperplasia, and hyperparathyroidism; (4) preserve equipment drawings, transformer/PCS specifications, maintenance procedures, shielding records, and RF/ELF/X-ray surveys; and (5) independently reconstruct exposures, evaluate latency, and investigate failures of medical surveillance. Missing measurements are not proof of no exposure. Federal radar technicians deserve rigorous investigation of their COMPLETE maintenance environment.

Since my comment exceeds 5000 characters, I´m sending it as an attached file. It collects my personal experience on how electromagnetic fields have affected my physical and mental health. The thesis I defend, supported by different scientific research, is that there is a direct cause-effect relationship between radiofrequency and central sensitivity illnesses (fibromyalgia, myalgic encephalomyelitis/chronic fatigue syndrome, fibromyalgia, myalgic encephalomyelitis/chronic fatigue syndrome, multiple chemical sensitivity, electrohypersensitivity). These illnesses, only recently on scene, affect millions of people all over the world. If the research proves that these illnesses are caused by inadequate limits for wireless technologies, the human, working, economic and social costs can be huge.

There are a lot of myths out there that will make EMF exposure worse such as earthing or painting entire rooms with a conductive paint that is grounded. This practice creates an antenna for supraharmonics and is responsible for capacitive coupling with the human body. Yet it's promoted by a group called Building Biology. This group is self certified and has been touted as an authority but in reality it's quite the opposite. Unfortunately many people have been harmed. Many comments have revealed this problem as the suffering people are blaming cell phones and WiFi and have not been educated about the most biologically active frequencies radiating from their walls, ceiling, and sometimes floors. To make matters worse they have been taught to attach themselves to them via earthing or grounding.

I remember my first cell phone. My parents bought it for me when I was in fifth grade. It was a pink Razr Motorola flip phone. Little did I know at the time that a few years later, I would start working for an environmental health non-profit organization on Long Island where I’d learn about the seriously disturbing health effects linked to wireless radiation exposure emitted by devices like cell phones, WiFi routers, and even those big cell towers that we see on highways and near homes across America. On the first day of my internship with the non-profit, the organization’s Executive Director sat me down at the office dining room table and dropped a couple of three-inch binders, each overflowing with paper, right in front of me. The table shook due to the weight of the binders. She told me that every piece of paper in each binder was just a sliver of the scientific literature about the biological effects of wireless radiation exposure. DNA damage. Sperm damage. Oxidative stress. Cancer. The list of terribles went on. My eyes widened. I had been, and continue to be, a health-conscious person. I want a healthy family, and I want to live a long, happy life. It greatly angered me to realize to realize that I had handled wireless devices in a potentially unsafe way -- especially during some of my most important developmental years -- because I just didn’t know better. Before that day in the office, nobody had ever told me that wireless radiation is a health hazard. Where would I have learned such information? From the non-existent warning label on my cell phone? From health class? From the FCC -- a revolving door for telecom lobbyists and former industry insiders? From the media outlets that get their advertising money from Verizon and AT&T and T-Mobile? After years of working in the non-profit sector and learning as much as I could as quickly as I could about the wireless telecommunications industry and the scientifically documented adverse biological impacts of RF radiation, I became a staunch advocate for the responsible and thoughtful placement of wireless telecommunications infrastructure. But that wasn’t enough. I couldn’t just be an advocate. I needed a law degree. So, I went to law school so I could teach municipalities about the powers they have to enact wireless telecommunications ordinances that prioritize public safety and smart infrastructure siting. And I still enthusiastically do that work today with my brilliant father who has practiced law for over 43 years. I am genuinely encouraged that HHS has issued this RFI. I hope this marks the beginning of a fundamental shift in how our federal government addresses the health and environmental implications of wireless radiation. The FCC has had ample time to act, and its record speaks for itself. Clearly, it cannot do its job. HHS must now take a leading role in investigating the health effects of wireless radiation and ensure that public health drives federal policy. This is HHS’s big moment to be on the right side of science and history. Please seize it. Thank you for your consideration of my comments.

Comment on: Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure (HHS–OASH–2026–0397) Intro: The purpose of this comment is to both share my experiences and suggest new RF/EMF research priorities. Personal experiences: I have experienced several health effects that may be tied to mobile phone usage. While using a 4g phone to connect to the Internet I have experienced the following: numbness in the fingers of each hand, digestive disturbances after holding the phone near my abdominal area for extended periods of time, a sensation of warm-tingling in my thigh and groin area when the phone was set on automatic update and carried in my front pocket, and irritability at times following using the device. I have also noticed irritability in others such as family members or coworkers after device use. I believe the effects I have experienced personally or noticed in others have a biological basis and aren't just psychosomatic. Future research: I have an advanced biology degree and have been interested in following the RF/EMF debate for years. I am aware that some research suggests no RF/EMF health effects. However, other research has concluded there are enough measurable health effects to warrant additional studies (1,2,3). I would like to suggest a research area that the U.S. Department of Health and Human Services (HHS) may not have considered. I believe HHS funding of the research area below would greatly advance our understanding of RF/EMF health effects. Research Priority 1: Effects of RF/EMF on the Human Microbiome. Background: The human Microbiome is a mixture of body inhabiting microorganisms. These microorganisms outnumber human cells by a factor of 10 and a factor of 150 when comparing the number of bacterial genes to human genes (4). The Microbiome has and still is being researched to understand its influence on disease states, mental health, intelligence, and other behaviors (5,6,7). Research has shown RF/EMF fields can also exert influence on bacterial growth characteristics, gene expression and gut metabolite formation (8,9). Thus, RF/EMF interactions with the human Microbiome may influence human health, intelligence, mental illness, and other behaviors. Areas for study: It would be helpful to: I. Systematically research and catalog changes in gene expression when the human Microbiome is exposed to RF/EMF fields. (Especially gene expression of gut microbes.) Ii. Systematically research and catalog any epigenetic changes that occur when the human Microbiome is exposed to RF/EMF fields. (Studying the epigenetic changes may also allow a way to determine past exposures to RF/EMF fields.) Iii. Systematically research and catalog metabolite alterations when the human Microbiome is exposed to RF/EMF fields. (Especially any metabolites that would influence mental or physical health.) References: 1 Non-ionizing Radiation, Part 2: Radiofrequency Electromagnetic Fields. - IARC Monographs on the Evaluation of Carcinogenic Risks to Humans. Volume 102. https://publications.iarc.who.int/Book-And-Report-Series/Iarc-Monographs-On-The-Identification-Of-Carcinogenic-Hazards-To-Humans/Non-ionizing-Radiation-Part-2-Radiofrequency-Electromagnetic-Fields-2013 2. More from Lai-Singh on ELF EMFs and DNA Breaks. https://microwavenews.com/news-center/more-lai-singh-elf-emfs-and-dna-breaks 3. ACS Responds to New Study Linking Cell Phone Radiation to Cancer. https://pressroom.cancer.org/NTP2016 4. Taxonomy in the age of genomics. https://www.sciencedirect.com/topics/immunology-and-microbiology/human-microbiome 5. Gut Bacteria Might Guide The Workings Of Our Minds. https://www.npr.org/sections/health-shots/2013/11/18/244526773/gut-bacteria-might-guide-the-workings-of-our-minds 6 The secret to human intelligence? It might be in our gut. https://www.sciencedaily.com/releases/2026/01/260105165806.htm 7. The gut–brain connection: microbes’ influence on mental health and psychological disorders. https://www.frontiersin.org/journals/microbiomes/articles/10.3389/frmbi.2025.1701608/full 8. The response of human bacteria to static magnetic field and radiofrequency electromagnetic field. https://link.springer.com/article/10.1007/s12275-017-7208-7 9. Effects of radiofrequency field from 5G communication on fecal microbiome and metabolome profiles in mice. https://www.nature.com/articles/s41598-024-53842-2.pdf

RFI response on 10-20-26 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 felt it necessary to submit this relevant RFI to HHS {HHS–OASH–2026–0397}.

I have the worst digestive issues and I have exponential exposure to emf through the phone, hotspot, and through the electric towers on the powerline that I'm only 100 ft from. I generally don't have stomach issues when I'm out and about so much unless it's something really bad, but when I'm anywhere with high emf, my digestive symptoms are increased. I also had a infectious step bacteria in a building that had ungrounded/faulty outlets I could feel something funky in the building like it was buzzing. The strep became resistant to all antibiotics. Also was right next to several businesses and police precinct that most likely was using radio waves and advanced wifi. I can note that my symptoms are much less when I am away from everything out in the woods or away from a bunch of electronics, and when I leave my phone in the other room I do seem to have better stomach and digestive ability. I would like to know more about the possibility of the emf contribu to my quite disabling digestive disease, and what could actually block or limit the exposure if it is contributing to destroying my biota and enhancing bad bacteria?!