Proposed biological mechanisms

The attached submission draws on several complementary sources of evidence including peer-reviewed research, my own research and reports from government and intergovernmental bodies. These include the U.S. National Toxicology Program (NTP), the Federal Communications Commission (FCC) and Australian Radiation Protection and Nuclear Safety Agency (ARPANSA), the International Agency for Research on Cancer (IARC) and the World Health Organization (WHO). It also draws on an independent scoping review and evidence map of the RF-EMF genotoxicity literature, an independent assessment of the evidence concerning RF-EMF and cancer using the Bradford Hill viewpoints, and a comparative analysis of approaches adopted by two international radiation protection authorities. The submission further incorporates an analysis of public submissions to the 2019-2020 Australian Parliamentary Inquiry on 5G. Symptoms reported by respondents to that inquiry are compared with symptoms reported in two smart-meter datasets: Lamech 2014, a peer-reviewed case series, and Halteman 2011, a survey report. Finally, the submission draws on my broader research into epistemic issues in evidence interpretation and the governance of scientific uncertainty. These analyses examine how differences in evidentiary frameworks, assumptions and approaches to uncertainty may contribute to divergent interpretations of the same body of evidence. Full citations are provided in the consolidated, numbered reference list at the end of the attached submission. Overview The United States Human Health Services (HHS) has released an RFI that is effectively asking the following question: What does the evidence actually show about RF-EMF and human health, and are current RF-EMF guidelines/standards, surveillance systems and research priorities adequate? This submission answers this question from a position that will be unfamiliar to HHS in one respect: it does not treat the reassurance of ICNIRP, the WHO International EMF Project, or the FCC as a reliable proxy for “the science.” Those bodies are one set of institutional actors among several. The evidence set out below, includes animal carcinogenicity data, mechanistic and genotoxicity research, an analysis of a selection of WHO-commissioned systematic reviews (SRs) in 2024-25, the documented influence of funding sources on reported outcomes, and the history of how the WHO/IARC World Cancer Report has treated this evolving literature. Overall, it indicates that their settled position of safety reassurance is unjustified and that the evidence has not been treated as a neutral body of findings to be weighed impartially. Instead, the selection, characterization and relative weighing appear to have been influenced by the prevailing institutional interpretation of RF-EMF health risks in order to maintain regulatory status quo. Importantly, this submission does not claim that RF-EMF is a proven, established human carcinogen in the sense that tobacco smoke and ionizing radiation are proven carcinogens. It is a claim that the totality of the evidence, considered across animal, mechanistic, and epidemiological domains, and without deferring automatically to the institutions that have minimized it, is substantially stronger than “no evidence of harm”. It is also a claim that the governance structures that are currently responsible for setting limits are not well suited to registering that strength. The attached submission contains sections organized around the RFI’s own numbered questions and integrates two bodies of my own independent research: an evidence assessment of the RF-EMF cancer and genotoxicity literature, and an analysis of the governance and institutional dynamics that have shaped how the evidence has been used, or not used, in setting federal policy. Where both analyses converge on the same underlying point, for example, that funding source and institutional affiliation are more predictive of a study’s reported findings than its methodological quality, the evidence and the governance analysis are presented together rather than repeated separately, because the pattern is the same pattern viewed from two directions.

I, Chad Ryan, am submitting this comment in response to HHS’s Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure. I am responding from the perspective of a patient, parent, concerned member of the public. From terrible insomnia, gut imbalances, exacerbated mold issues both in the house and in the body, terrible tinnitus, to hearing EMF pulses through my implant tooth made of a titanium rod and a multi-metal crown lattice (I.e. an antenna!), the horrific quantity of EMF is overwhelming. I was in tech from 1996-2012 when I quit Microsoft due to EMF from computers, wifi, and cellular. First effects of sweaty hands, brain fog, energy drain started as early as 2000 and only got worse with time. I quit tech in 2003 for health reasons, but felt forced for financial reasons to return in 2004 until I officially quit and moved to small town California to escape EMF (outskirts of Grass Valley where the nearest cell tower was over a mile away). Note battles continue to today 2026 to keep cell towers off a elementary school and people's homes <1 mile of my house. After much research and trial and error I removed wifi completely from my house and felt immediate relief. I then had to clean up the dirty sine wave electricity coming to my house and generated by my own electronics using Stetzerizer electrical filters. I got my EMF sampling down to -62 decibels steady. Urban settings are around -42 decibels. A cell phone can pulse to -10 decibels within 3 feet. I found peace finally in my rural setting, but suffered every-time I went to town, stayed at a hotel/motel, on took a plane where everyone now uses wifi in a metal cage (the plane) which keeps all the wifi contained and absorb by the human body, and we wonder why traveling in cars or planes is so tiring now? It didn't used to be that way! Did you know that microwaves are pure sine waves called carrier waves that is, until you add the data onto them that create all kinds of bumps and eddies on the wave? If you study dirty electricity how pure sine waves become jagged and distorted by machines and electronics converting AC to DC, causing erratic magnetic fields that to the body are irritating and hard to balance, not to mention oxidative damage (stress)? Well same with microwaves with data added on them. Not to mention microwaves especially 2.4mHz that literally shakes water molecules violently in a microwave causing heat and splits DNA strand? Those microwaves can carry those erratic waves directly to every cell in your body! You are made of 72% water! Did you know that stem cell differentiation in bone marrow actually uses the frequency range that includes 2.4mHz to determine if the stem cell becomes blood, muscle, or nerve? Leukemia cancer, common near cell towers like the San Fransisco tower, is a cell differentiation problem! Why is that not talked about? I can go on, but clearly the ridiculous notion that heat is the only problem caused by our use of EMF waves must be overcome. When china--who has very little concern for its individual inhabitants--has a 10x better (more stringent) standard for EMF exposure than the United States, clearly industry has captured yet another so called regulatory agency in the FCC. I support HHS 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 (cranial bone thinness) 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.

the people should have the right to know how much we are exposed at all times and the cancer risk or degenerative cellular bombardment rates due to that exact exposure level. maybe there could be an app developed which triangulates the user's location and distance to the High EMF/RF/WIFI radiation and calculates exposure dangers.

I want a published federal evidence review of the existing literature, with a timetable for completion. I want my grandkids and their kids protected from emf harms such as cancer, damaged immune systems, and chromosome dmage. Link to studies at GreenMedInfo https://greenmedinfo.com/abstracts/use-bed-insulating-system-electromagnetic-fields-improves-immune-function-redo https://greenmedinfo.com/abstracts/electromagnetic-radiation-has-significant-genotoxic-action-human-cells https://greenmedinfo.com/abstracts/radiofrequency-radiation-induces-wide-range-adverse-health-effects-substantiat https://greenmedinfo.com/abstracts/long-term-exposure-low-density-elf-emf-may-cause-decrease-adaptive-immune-resp

See attached file(s) Your ‘Attach Files’ below DOES NOT allow a PDF file to be attached. Please advise. I can send a PDF by email if necessary to explain in more detail. Please remember I am the ONLY. Person on Planet Earth who can prove Electromagnetic Fields (EMFs), Radio-frequency (RF) Radiation, and Wireless Radiation Exposure is HARMFUL to cause Cancer, Dementia, Alzheimer’s, Parkinson’s, the list is endless. My research was requested by the British Government to eradicate Covid-19 using AI, February 2020, yet was influenced by the multi-trillion-dollar Pharma Industry & the World Health Organisation for a ‘flawed ‘vaccine-only-solution’ that gave long-covid, severe reaction or death! Cancer is caused (‘triggered’ to stimulate the cell to mutate and manifest into a cancerous growth or tumour) by Harmful-Schumann-Resonance from where you sleep, sit, dine, work, rest if ‘in-situ’ for hours at a time, verified and used by NASA! Meaning: Cancer can be PREVENTED using New Personal-AI-Technology!

To the respectful and understanding reader, First of all, please don’t judge my English, as this is my secondary language. When I was young, my father working in the broadcasting industry, gave our family the love of technology. He believed, like everyone was told, that nnEMF were safe. Having seen a housing opportunity, our whole family moved to a house near huge electric pylons. I lived there for about 10 years. However, I started having health problems on the 5th years. Unfortunately, my father passed away on the 13th year and my mother a bit later, after moving away from this house. A few years later, I started having a permanent headache that wouldn’t go away. I would go to sleep with a headache, then wake up with a headache. I went for a CT Scan and they told me everything was "fine". But it wasn’t fine. Fortunately, I started to have some clues: - My permanent headache went away only when going in the forest, and came back gradually while reentering the city. It occured a few time, but couldn’t understand the link between my headache and the forest. - A long lasting power outage of 5 days, which affected the whole block: no headaches during that time. Headaches came back as soon as the power went back on. This is the moment I understood my headache was linked to electricity, somehow. I wasn’t sure, though, having been told again and again that non-ionizing EMFs were totally harmless. Anyhow, having a better idea of the problem, I tried to get help from professionnals. I thought they would know better than me. After getting next to no help from my doctor and about 7-8 health specialists, that is when I tried to find answers by myself. This led me to a long and enduring path of discovery toward the truth, both for personal and professional reasons. Being a product designer, I use a scientific, neutral and intuitive approach on almost all subjects. So, I did what I normally do when doing research: checking both sides of the argument and trying to spot inconsistencies and biases. I also learned in my career that if you cannot measure it, you cannot improve it. So I started buying various and increasingly expensive EMF meters, covering different frequencies. This led me to understand that there were wiring errors in my house. I also discovered how "noisy" are WiFi and Bluetooth devices. I then tried to turn those antennas off. My headaches went away almost immediately after. Fortunately, I was making progress. Since then the beginning of my then permanent headache, I did more than 3000 hours research of the subject of EMF of many ranges and sources in order to understand the subject thoughly. From my understanding so far, the problem isn’t necessarily nnEMF themselves, but their overabundance. We call that "electrosmog". Don’t get me wrong: I LOVE technology and wouldn’t want to quit my day to day job. It has just became very hard to practice under those conditions. So, my long term goal is to get to know and understand the subject as much as possible in order to create safer products that are respectful of biology, including humans, animals and plants, as I know now that those are affected too. Most of us just aren’t aware. In one line: all lifeforms runs on electricity. Electricity is data. Any change of frequency, energy and vibration is affecting cell at microscopic levels. Under weak non-ionizing nnEMF (WiFi, BT, 60Hz powerline, among others), it first affect blood cells (rouleau formation) after just 10 minutes of exposure but resolves by itself when it stops or if the subject is moving enough to activate blood circulation. However, if someone stand still while using those devices and that it happens all days over a year, bigger problems start appearing. That’s why most lab tests are failing to find evidence: their tests aren’t lasting nearly long enough to find those. Another problem: all cells phones are tested for SAR. Their levels are tested against the FCC rules and they pass it before the product gets released to the public. This is fine by itself. However, when you go inside a cramped bus or subway, those numbers are suddenly going though the roof. Nobody is checking for exposure in those areas. Before concluding, I also met many people having the same problem as me, which was a relief. I must admit though that it wasn’t all good. Many people, including some close friends, didn’t want to believe my story. I had to insist to the point of this health problem nearly breaking our friendship. Thanksfully, I had more listening ears around me than judging ones. Many people are downright hostile toward this unknown problem, as you might have noticed. From what I’ve found so far, what we were told since the 60’ hasn’t evolved much in the public mindset. It even developed as a stigma for many people which will defend heavily wrong theories and assumptions about scientific conclusions driven by the money of the telecom industry. Thanks for caring.

For approximately the past ten years, beginning around 2015, I have experienced significant neurological and physical health challenges, including chronic headaches, debilitating migraines, persistent dizziness, vertigo, cognitive dysfunction, and overwhelming fatigue. These symptoms have profoundly affected my quality of life and ability to function independently. I am particularly concerned about the possibility that electromagnetic field (EMF) exposure may contribute to or exacerbate my neurological symptoms. My concerns have been heightened by genetic testing that identified four single-nucleotide polymorphisms (SNPs) within my CACNA1C gene. This gene encodes a component of the CaV1.2 voltage-gated calcium channel, which plays an important role in neuronal signaling, cellular calcium regulation, and nervous system function. The interpretation of my genetic testing suggested that these findings could indicate increased susceptibility to the biological effects of electromagnetic exposure. Although the relationship between CACNA1C variants and sensitivity to everyday electromagnetic fields has not been clinically established, I believe this is an important area deserving further scientific investigation. My experience raises questions about whether genetic variations affecting calcium-channel function could influence individual responses to environmental exposures, particularly among people already experiencing neurological dysfunction. Over the past decade, my headaches, dizziness, and other neurological symptoms have substantially interfered with my daily activities, physical endurance, cognitive functioning, and overall well-being. I am asking the Department of Health and Human Services to investigate whether genetic differences, including variations in genes involved in calcium-channel regulation, may contribute to individual susceptibility to electromagnetic exposures. I believe that research examining potential interactions between environmental electromagnetic fields, genetic predispositions, and neurological health could provide valuable information for patients like me who have spent years searching for answers. I respectfully request that federal health agencies recognize the importance of investigating these questions through independent research, including studies that evaluate genetic variation, long-term exposure patterns, and neurological outcomes.

Very sensitive to WiFi/cell. Started by getting welts and torso skin burning when I used my phone after getting Nest doorbell and thermostat. I was unable to sleep for years, body visibly twitches. I didn't get any sleep signal so I was awake mobilized with heart racing all night. My melatonin release was suppressed and my nervous system was being stimulated. Always slept ok away from the city. Bought emf meter and it's around 1-3V in the home even with modem off. Bought a silver thread shielding canopy to sleep in, instant good sleep from night one! In 2023 though I injured my hip area, what should have healed in 4 weeks is still an issue 3 years later. In my home, at work and/or when an event comes to town (a fair or boat show etc), or in certain stores/places my muscles seize up randomly and violently, much worse at the site of injury. Any injury site has inflammation which I was told is a lighting rod for emf, and mast cells degranulate faster etc. I can go from unable to walk at all in a store, body all stiff and locked up, drive half hour away and walk in the canyons for hours or swim in a lake without issue. Then come back home and be unable to walk again. I started wearing a shielding hoodie all day long, with hood up, and it attenuates the response considerably and almost instantly. But it's embarrassing to have to wear. Recently many new cells (small and medium plus 2 large towers) have gone up a few blocks from my home. When events are on I can tell because my skin starts crawling, itching, burning, the hoodie isn't enough to block all the extra. I need to leave home during those times, go into the canyons, and then I'm fine. It's bizarre, and also crippling and expensive, and unsustainable.

Hello, my name is Lisa. I am a mother of 3 living in a Chicago suburb in IL. We live in a house next to a water tower with 5G and everyday I consider moving to protect my children from radiation. I think it’s unlawful to be exposed to 5G and other EMF without consent — knowing that it causes cellular harm/damage. Please help us by regulating where 5G can go and regulation of emf “safe” thresholds. Sincerely, A mom just trying to raise the next healthy generation.

Personal Testimony and Call for Research and Protection for People Reporting Electromagnetic Hypersensitivity (EHS) Public Comment — HHS-OASH-2026-0397 To the U.S. Department of Health and Human Services, I live in Israel and have practiced complementary and integrative healthcare for approximately 28 years. I write both as a practitioner and as someone whose life was profoundly changed by a severe health crisis that I attribute to prolonged, cumulative exposure to electromagnetic fields (EMF). For years, my symptoms were mild and seemed insignificant. Then, within a few months, my health deteriorated rapidly. I experienced weakness, a choking sensation, elevated blood glucose, and other unexplained symptoms. As my condition worsened, I began noticing a recurring association between EMF exposure and my symptoms. I describe this through the “bucket theory”: drops accumulate unnoticed for years until the bucket overflows. For me, symptoms then appeared in an unbearable cascade, like a house of cards collapsing. During this crisis, I also developed severe multiple chemical sensitivity (MCS). About five years ago, the crisis affected multiple body systems. Alongside severe symptoms, I experienced measurable physiological changes: increased blood glucose, hemoglobin (Hb), blood pressure, and heart rate. My recovery continues today. My quality of life, daily functioning, and freedom of movement remain severely restricted. Ordinary activities require planning, environmental adjustments, and major sacrifices. From my own experience, the exposure–symptom connection is clear to me. I recognize that a causal relationship is not established scientific consensus. This gap between patients’ experiences and established knowledge makes rigorous, independent research open to new findings essential. People reporting EHS often describe similar experiences despite diverse symptoms. Reported responses may differ by frequency, exposure type, and over time. These patterns deserve investigation. I urge HHS to take the following steps: 1. Expand existing research: Support independent genetic, physiological, clinical, and epidemiological studies, collaborating with EHS researchers in Europe and elsewhere. 2. Investigate biomarkers: Examine and replicate findings concerning the nervous system, inflammation, and possible myelin damage, alongside blood markers, heart rate, blood pressure, and autonomic function. Identify reliable indicators and potential patient subgroups. 3. Study individual susceptibility: Investigate genetic and physiological differences that might explain reported reactions at exposures below current limits. 4. Reassess exposure standards: Study possible non-thermal effects and prolonged, combined exposure from multiple sources. 5. Review mobile-phone emissions and inform the public: In independent measurements I conducted about five years ago, I recorded 50–70 mW/m² near my phone. Today, during calls on that same phone, I measure pulses of 150–300 mW/m², peaks exceeding 1,800 mW/m², and readings above 2,000 mW/m² near newer smartphones, under broadly similar conditions. The 2012 BioInitiative Report discusses reported biological effects at 0.03 mW/m². These observations warrant investigating changes in exposure over time, reviewing standards, transparently informing the public, and developing safer communication technologies. Reference: BioInitiative Report (2012), Conclusions: https://bioinitiative.org/conclusions/ 6. Reduce environmental exposure and protect basic rights: Reconsider antenna deployment, including relocating transmitters away from residential areas, reducing small-cell and 5G installations, and promoting wired communication. Evaluate public warnings about mobile phones and other wireless technologies. Establish dedicated recovery spaces with electromagnetic exposure as close to zero as technically possible, minimizing both radiofrequency and power-frequency fields for people in severe health crises. Protect freedom of movement, health, and access to essential services, including for those who may develop sensitivity in the future. 7. Train healthcare professionals: Ensure respectful care, thorough medical evaluation, and support without dismissing patients’ symptoms. 8. Include people reporting EHS in research: Involve them in study design and research priorities. Lack of scientific consensus about causation does not justify disregarding symptoms, physical findings, or the need for appropriate medical care and research. I hope this initiative advances recognition, meaningful research, and practical solutions for people reporting EHS worldwide. I am willing to share my experience, provide relevant medical information confidentially with my consent, and participate in suitable studies. Thank you for considering my testimony.