Proposed biological mechanisms

Docket HHS-OASH-2026-0397 Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure Question 2 – Perspective This comment is submitted by an individual with an interest in evidence-based public health. It draws on peer-reviewed literature, government and international agency assessments, and systematic reviews. Established findings are distinguished from emerging or uncertain evidence. Questions 5, 6, and 12 – Exposure standards, risk assessment, and evidence regarding effects at or below current federal limits Federal health agencies should consider the following established frameworks and evidence: • ICNIRP 2020 guidelines: The only substantiated adverse health effects of RF-EMF are those caused by tissue heating (thermal effects). The guidelines protect against all established adverse effects, including those relevant to 5G and other modern technologies. No adverse effects below the thermal threshold have been consistently substantiated in human populations at typical exposure levels. • U.S. FCC RF exposure limits (47 CFR 1.1310) and FDA assessments: These are based primarily on thermal effects (SAR). FDA has stated that the weight of scientific evidence does not support a causal link between RF exposure below these limits and cancer or other adverse health effects. • WHO-commissioned systematic reviews (2023–2025): Reviews of human observational studies on cancer (including glioma), cognition, reproduction, and non-specific symptoms generally found no or only small effects associated with RF-EMF exposure, with moderate certainty of evidence for the absence of increased brain tumor risk from mobile phone use. Confidence is lower for many other outcomes due to limited high-quality data. • IARC 2011 classification: RF-EMF is Group 2B (“possibly carcinogenic to humans”) based on limited evidence linking heavy mobile phone use to glioma and acoustic neuroma. This classification has not been upgraded. • NTP rodent studies (2018): These reported carcinogenic signals in male rats at high whole-body exposures well above typical human levels. Findings were not consistent across sexes or species, and methodological limitations have been noted by expert bodies. The results do not directly translate to typical human exposures below thermal limits. Established finding: At exposure levels below current thermal-based limits, there is no consistent, high-quality evidence of causal adverse health effects in the general population from everyday RF/EMF sources. Areas of uncertainty: Long-term effects beyond most study follow-up periods; cumulative multi-source real-world exposures; potential subtle non-thermal biological effects; and whether any subgroups experience effects not captured in population-level data. Question 11 – Sensitive populations Children warrant careful consideration due to potentially higher relative absorption in some tissues and longer lifetime cumulative exposure. Current evidence does not demonstrate harm at typical levels, but data specifically addressing developmental stages remain limited. Targeted research with personal dosimetry is warranted. Question 13 – Cumulative exposure patterns 5G, Wi-Fi, IoT, wearables, smart meters, and denser infrastructure create complex multi-source exposure patterns. Average levels generally remain well below thermal limits. Evidence on how these real-world combinations affect cumulative dose or health outcomes is still limited. Improved multi-source exposure characterization is needed. Question 16 – Highest-priority research gaps 1. Long-term prospective cohort studies of children and adolescents with individually measured personal RF exposure. 2. Improved real-world dosimetry for cumulative, multi-source exposures (including 5G characteristics). 3. Independent replication and mechanistic studies of any non-thermal signals using realistic exposure parameters. 4. High-quality blinded investigation of reported electromagnetic hypersensitivity. Question 17 – Coordination HHS (FDA, NIH, CDC) should coordinate with FCC and international bodies (WHO, ICNIRP) to prioritize independent research that can meaningfully update risk assessment. Question 18 – Additional recommendations Maintain clear public communication that distinguishes established thermal effects and the absence of confirmed adverse effects below limits from areas of residual uncertainty. Support practical exposure-reduction options for those who prefer them without implying established harm. Ensure any future guidance is driven by high-quality evidence.

Does your house have a constant frequency noise 24/7 so loud that you can't sleep at nice or read quietly during the daytime. Has your mitochondria and memory affected without understanding what has happened to your energy? EMF's, RF's and wireless radiation have affected my health and lifestyle. This happens when I travel in my car, stay at a hotel and visit another state and stay at a family members home. The frequency is relentless.

I am submitting this comment as a licensed Professional Engineer (environmental engineering master’s degree), U.S. Navy veteran, and concerned citizen. Current federal exposure guidelines for RF/EMF from wireless devices, Wi-Fi, and 5G infrastructure are outdated, based primarily on thermal effects, and fail to adequately protect public health—especially children, pregnant women, and those with electromagnetic hypersensitivity. Independent research, including the National Toxicology Program animal studies and multiple peer-reviewed papers, has shown clear evidence of biological effects at levels well below current FCC limits, including increased cancer risk, oxidative stress, DNA damage, and reproductive harm. These findings have been dismissed or minimized while industry-funded studies and captured agencies continue to claim “no proven harm.” This pattern mirrors other failures of public health agencies that prioritize corporate interests over independent science. I urge HHS to: Commission and fund truly independent research that examines non-thermal effects, cumulative exposure, and real-world chronic low-level RF from 5G small cells and densified networks. Update safety standards to account for biological effects, not merely heating of tissue. Require transparent disclosure of conflicts of interest in all studies relied upon by the agency. Support a precautionary approach: pause further dense 5G deployments near homes, schools, and hospitals until safety is demonstrated, and prioritize wired alternatives where feasible. Investigate and publicly report on the health impacts of the existing nationwide 5G infrastructure that has been rolled out with insufficient long-term data. The public has a right to accurate information and protection from involuntary exposure. Continuing to rely on 1990s-era thermal-only limits while saturating the environment with pulsed RF is not acceptable. I call on HHS to put human health ahead of industry expansion. Shelly Arnoldi Licensed PE | Navy Veteran | Virginia resident

Public Comment to the U.S. Department of Health and Human Services (HHS) Subject: EMF Sensitivity, Mold Exposure, Genetic Testing, and Chronic Inflammatory Response Syndrome (CIRS) Submitted by: Shana Placenti New Hampshire, United States To the U.S. Department of Health and Human Services, My name is Shana Placenti, and I am sharing my personal experiences with electromagnetic field (EMF) sensitivity, mold exposure, and Chronic Inflammatory Response Syndrome (CIRS). I have been battling CIRS since 2018, following prolonged exposure to a water-damaged, mold-contaminated home. Over the past eight years, I have experienced severe neurological, cognitive, and physical symptoms that have significantly affected my health and quality of life. Approximately five years ago, I underwent extensive genetic testing involving roughly 200,000 genetic markers. According to the interpretation provided with my results, I was identified as having what the report described as "double EMF sensitivity." When I am around what I believe to be sources of electromagnetic fields, I experience intense buzzing and vibrating sensations throughout my body. At times, it feels as though my entire nervous system is buzzing. These sensations can become extremely uncomfortable and overwhelming, particularly when I am already experiencing neurological symptoms. Following my mold exposure, I experienced severe dizziness, balance disturbances, cognitive difficulties, impaired temperature regulation, and changes in bladder function. At one point, my neurological symptoms were so debilitating that I struggled to walk and maintain my balance. I have also experienced multiple concussions, further complicating my neurological health. I am concerned about whether individuals with chronic inflammatory illnesses following mold exposure may experience heightened sensitivity to other environmental factors, including electromagnetic fields. I am also concerned about the potential relationship between electromagnetic fields and mold-related toxicity. I encourage HHS to investigate whether EMF exposure can influence fungal growth, mycotoxin production, or the biological effects of mold exposure, particularly among individuals living with chronic inflammatory and neurological conditions. I respectfully encourage HHS to investigate possible relationships between EMF exposure, mold-related illness, neurological conditions, and genetic susceptibility. I would particularly welcome research examining whether certain genetic variations are associated with reported EMF sensitivity and whether these associations can be scientifically validated. I also encourage research into the combined effects of environmental exposures on individuals living with complex chronic illnesses. In addition to my personal experiences, I am the founder and administrator of MOLD/CIRS/LYME/TOXINS Healing and Recovery Group, an international Facebook community with more than 7,200 members representing over 50 countries. Through this community, I raise awareness, share educational resources, and provide support for individuals navigating mold exposure, CIRS, Lyme disease, EMF sensitivity, and other environmental health concerns. I have connected with individuals who report symptoms they associate with EMF exposure. These experiences have reinforced my belief that patients deserve to be heard and that their experiences should help inform future research priorities. My purpose in submitting this comment is to share my lived experience and advocate for greater awareness, independent research, and improved understanding of reported environmental sensitivities. I recognize that my genetic report does not independently establish a medically validated diagnosis of EMF sensitivity. However, I believe my experiences raise important questions worthy of further scientific investigation. Thank you for providing Americans with an opportunity to share their experiences. I sincerely hope continued research will improve our understanding of reported EMF sensitivity, potential interactions with mold exposure, and the challenges faced by individuals living with chronic inflammatory and neurological conditions. Respectfully, Shana Placenti New Hampshire, United States Environmental Health Advocate

I was on the Planning and Zoning board for a small New Mexico Village who had to contend with the wireless tower providers replacing the tower. The entire system was rigged. We had to rubber stamp everything or the threat of being sued by these massive companies would have destroyed us. We were given no meaningful choices. I even discovered later that they bribed the Chair of the Committee- oh here's $$ for Village projects that will make you look like a big man but naturally we won't discuss this until after the tower is in- he's now the mayor of course. They forced us to hire a "Village Representative" to go between the Village and the Tower, but that guy was a complete wolf in sheep's clothing and of course the wireless company paid for that. The corruption upon corruption upon corruption was sickening and we could't stop it. They hired attractive soft-spoken women to front the whole thing- weak women who just wanted their paycheck and made it seem like they all cared so much. At the public comment session before "approval"- they admitted within the decade they could put short burst wireless on your land on every lamppost- near your house- ubiquitous. They Do Not Care about health. The science of disruption of calcium channels- the confusion created by the effect on human electrical systems is 100% not okay. This cartel must be taken DOWN and human health put #1. Anything they offered could simply and perfectly be executed via glass fiber. It's not lack of knowledge, it's that the cartel wants it this way, and government has allowed this for decades now. Please stop them.

One major gap in EMF research is that we keep asking what electromagnetic frequencies do to human cells while largely ignoring what they may do to the microbes living inside the human body. Humans are not biologically sterile. We carry complex communities of bacteria, fungi, viruses & other microorganisms throughout the gut, lungs, mouth, skin & other tissues. These organisms influence immune function, inflammation, metabolism, neurotransmitter activity, barrier integrity & overall biological stability. If electromagnetic exposure can alter microbial growth, metabolism, oxidative stress responses, gene expression, biofilm behavior or fungal activity, then EMFs may affect human health indirectly as well as directly. That creates a much larger biological pathway: EMF exposure → microbial stress response → altered microbial metabolism & behavior → altered metabolites, inflammatory signaling & oxidative stress → immune dysregulation, neurological effects & systemic illness. This may be especially important with fungi because fungi respond dynamically to environmental stress & are capable of producing powerful secondary metabolites, including mycotoxins. Research should examine whether chronic RF/EMF exposure can influence fungal growth, sporulation, biofilm formation, virulence or secondary metabolite production both inside the human body & within water-damaged indoor environments. The human body should therefore be studied as a complete biological ecosystem, not as isolated human cells. We may actually be looking at two systems being exposed simultaneously: the human host & the microbial ecosystem living within that host. Those systems continuously interact. A relatively weak environmental signal would not necessarily need to directly destroy human tissue to create a substantial biological effect if that signal changes the behavior of organisms capable of replication, communication, biofilm formation & chemical production. This is why HHS should investigate the intersection of bioelectromagnetics, microbiology, mycology, mycotoxicology, neuroscience, immunology & microbiome science. The question should no longer be only: “What do electromagnetic fields do to human cells?” We also need to ask: “What do electromagnetic fields do to the microorganisms living inside us, & what do those microorganisms then do to the human body?” Until that interaction is properly investigated, we may be studying only half of the biological picture.

I am submitting this comment in response to HHS’s Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure. You likely know about the Clinton administration's 1992 Telecommunication Act. Prior to it being passed, telecommunication companies were prohibited from building cell towers within close proximity of schools, hospitals, medical clinics, day care and senior care centers. Why? Because strong Wi Fi (RF radiation) is not healthy. It is radiation. Human bodies perceive it as a foreign body and our immune system responds. Eventually our immune system fatigues and our bodies inflammatory response leads to disfunctions like diabetes and cancers. The passing of the 1992 Telecommunication Act rescinded that protection. How is it we knew to put protections in place, for our most vulnerable populations, and then pretended we did not know? Politics, greed and ignorance. You see the ill effects of strong Wi Fi (RF radiation) in your friends, families and neighbors every day. RF radiation stresses the nervous system, the immune system and eventually erodes good health. The statistics of alarming numbers of what were rare cancers are indisputable. There are volumes of reliable independent research on the damaging effects of RF radiation. If we do not have our good health nothing else matters. You were put in the position to act on behalf of yourself, your family, friends and country in this serious matter. I pray that you have the clarity, courage and wisdom to put reasonable safeguards in place. Thank you for taking an active role in examining the potential health and environmental effects of wireless radiation. Questions about human health should be addressed by federal agencies with appropriate expertise in medicine, biology, epidemiology, and public health, and the experiences of individuals and families who report being affected should be considered alongside the scientific evidence. I urge HHS to carefully evaluate these experiences and the scientific evidence, identify gaps in current research, give particular attention to children and other potentially vulnerable populations, and establish appropriate federal research priorities regarding wireless radiation and public health. Thank you for providing individuals and families with an opportunity to be heard.

I do not believe enough thought goes into the impacts on health with EMF. for instance AirPods. They are t tested properly and go into one’s ears. That should be mandatory. We know frequency impacts human cells. We are electric magnetic beings after all. If I’m in a Tesla for long periods I always get a headache and feel nauseous. These effects must be looked into. There is big money involved and when that’s the case safety falls to the very bottom. Like. We need more studies. Prior to 5G being deployed there were very concerning studies brought to attention but sadly it went ignored. I also think when there is an opportunity for public comment there should be commercials alerting the public to this opportunity. Please do the studies and let the science lead were it may. If it’s not safe we shouldn’t use it.

Microwave radiofrequencies, 5G, 6G, graphene nanomaterials: Technologies used in neurological warfare https://pmc.ncbi.nlm.nih.gov/articles/PMC11618680/ It was already known & was pushed through anyway. I would get migraines in my own house and my daughter had rashes and heat. It was affecting me so much that it was part of the reason I left my marriage of 30 years. My family would not believe me about what was impacting my health or read the documentation that I researched. I went to school board meetings, county meetings, state meetings & very few decision makers would take anything seriously even when presented with studies. After my divorce, I eventually purchased an older home and do not own a TV nor do I have WiFi. The new subdivisions being built with smart everything affected me when touring open houses. I don’t like going out much anymore. Cities have too many frequencies interfering with my biofield and grocery shopping is especially annoying. I know insurance companies refused to insure telecommunication companies over this, so what does that say?

Hello - I will be providing information to the effects of these catastrophic frequencies and radiation exposures and I demand that the FCC and HHS release their findings on this as well to the public. It has been presented before but shoved off as "We don't deal with humans, only frequencies." There is so much proof out there it is absurd that our government and the tech companies keep slowly killing the global populations with these weapons; that is what they are. See below info and any attachments on this. The peer-reviewed and human evidence submitted to federal regulators establishes that exposure to electromagnetic fields (EMFs), radiofrequency radiation (RFR) and wireless radiation produces a wide range of measurable biological harms—not merely theoretical thermal risks. As documented in the FCC docket, filings contained "peer-reviewed studies showing radiofrequency radiation contributing to cell damage, DNA damage, infertility, carcinogenicity, cognitive deficits, and cardiovascular disruption, among a wide array of negative health effects". This body of evidence—over 11,000 pages—was dismissed by the FCC, whose representative reportedly told an injured petitioner, "We don't deal with humans, only frequencies". Cancer Risk and Official Recognition The World Health Organization's International Agency for Research on Cancer classifies RF radiation as "possibly carcinogenic to humans". Professor Lennart Hardell is responsible for this classification based on evidence linking wireless radiation to increased risk for glioma and acoustic neuroma [A-2]. The National Toxicology Program's own study found "clear evidence linking cell phone use to heart tumors in rats, with some evidence also linking it to brain and adrenal tumors" [A-1]. A review led by Linda Birnbaum, former director of the National Institute of Environmental Health Sciences, concluded there is "substantial scientific evidence" that RFR causes "cancer, endocrine, and neurological problems, as well as many other negative health effects". The Causal Mechanism: Oxidative Stress At the cellular level, the primary mechanism of harm appears to be oxidative stress. According to Children's Health Defense, the evidence identified a "causal mechanism of harm" found in 203 out of 225 studies: oxidative stress, "which can lead to cancer, non-cancer conditions, and DNA damage". Professor Martin Pall, Professor Emeritus of Biochemistry at Washington State University, confirmed that "current EMFs can cause lowered fertility, neurological/psychiatric effects, DNA damage, apoptosis, oxidative stress, endocrine effects, cancer, genetic and epigenetic changes, inflammation, mitochondrial dysfunction, and cardiac effects". Children Are Disproportionately Vulnerable Children face heightened risk. Research has found that "children's brains absorb 2-3 times more radiation than an adult's". This vulnerability is compounded by the fact that substantially more children are using cell phones from younger ages. The 5G Escalation The rollout of 5G represents a dramatic escalation. Unlike previous technologies, 5G uses "frequencies between 24 GHz and 100 GHz, known as millimeter-wave frequencies". Israeli researchers found that "our sweat ducts act as antennas for millimeter waves, meaning we would absorb more energy into our bodies". Professor Pall warned that "5G will inevitably produce universal or almost universal very early-onset Alzheimer's dementia and may cause near-universal autism" . Critically, "there are no safety studies on 5G", and Senator Richard Blumenthal concluded after a Senate hearing, "So there really is no research ongoing. We're kind of flying blind here, as far as health and safety are concerned". Brain, Sleep and Mitochondrial Effects The evidence further shows effects on the brain, "including impaired blood flow and damage to the blood-brain barrier, cognitive and memory problems, and effects on sleep, melatonin production, and mitochondrial damage". These findings are especially significant because mitochondrial dysfunction is central to chronic degenerative disease processes. Dr. Erica Mallery-Blythe emphasized that "the relationship between radiation intensity and biological effects is not linear," and that EMFs interact with chemicals, genetics, nutrition, and stress in ways that "can exponentially worsen these biological effects". Conclusion The evidence is clear: EMF, RFR and wireless radiation exposure produces oxidative stress, DNA damage, cancer, neurological harm, reproductive damage, and mitochondrial dysfunction.