Proposed biological mechanisms

I am writing to formally request stricter regulations on anthropogenic electromagnetic fields (EMFs) and to advocate for the official medical recognition of Electromagnetic Hypersensitivity (EHS). Current public exposure standards fail to account for non-thermal, biological effects that severely impact human health. Scientific evidence proves that EHS is a definitive neurological disorder characterized by oxidative stress, neuroinflammation, and objective physiological biomarkers. Furthermore, recent molecular research highlights that chronic EMF exposure triggers genetic toxicity and impairs vital cellular repair mechanisms. To support this urgent need for tighter biological safety limits, I submit the following peer-reviewed scientific studies: 1. On DNA Damage and Genetic Toxicity: Sonzogni L, Al-Choboq J, Combemale P, et al. Skin Fibroblasts from Individuals Self-Diagnosed as Electrosensitive Reveal Two Distinct Subsets with Delayed Nucleoshuttling of the ATM Protein in Common. International Journal of Molecular Sciences. 2025;26(10):4792. doi: 10.3390/ijms26104792. This crucial study confirms that individuals with EHS suffer from a delayed or impaired cellular response to DNA double-strand breaks when exposed to EMFs, providing clear evidence of genetic vulnerability and organic pathology. 2. On the International Scientific Consensus: Belpomme D, Carlo GL, Irigaray P, et al. The Critical Importance of Molecular Biomarkers and Imaging in the Study of Electrohypersensitivity. A Scientific Consensus International Report. International Journal of Molecular Sciences. 2021;22(14):7321. doi: 10.3390/ijms22147321. This consensus report officially classifies EHS as a neurological disorder involving altered cerebral blood flow, oxidative stress, and elevated inflammatory markers such as histamine. 3. On Population Prevalence and Global Health Impact: McCredden JE, McLean L, Steinemann A. Wireless sensitivity and co-morbidities: A prevalence study in Australia, Canada, and the United States. Next Research. 2026;8:101577. doi: 10.1016/j.nexres.2026.101577. This recent epidemiological research indicates that up to 12.6% of the general population across the US, Canada, and Australia reports sensitivity to wireless radiation, representing millions of citizens experiencing EMF-related health barriers. I urge the HHS to adopt the Precautionary Principle, revise current guidelines to include non-thermal biological thresholds, and establish dedicated healthcare protocols to protect the rights and lives of medically vulnerable EMF-sensitive individuals. Sincerely Italia

10 years ago in Sept 2016 I was a healthy 24 year old who just found out I was expecting my first baby. That month my small office sold my parking spot for a big cell tower to be built. That next month my health completely plummeted. A rash completely took over my face, arms, neck, and chest and I soon miscarried the baby (blighted ovum) took me years to fully recover. Interesting in my small office about half of the people had a health crisis that month. The secretary walked in one day, got to work and then couldnt stand up again. She had to get wheeled out in her office chair and was diagnosed with some sort of fungal infection. Took her months of rehab to walk again. My boss had a terrible diverticulitis flair and another person had a mini stroke. Other factors I wonder about is the susceptibility of those with hEDS or those with additional mold exposure as these other factors for me. I'm very suspicious that it was a combination of these factors. And that's why not everyone experiences the same reactions.

• U.S. National Toxicology Program (NTP): A $30 million large-scale rodent study reported "clear evidence" of malignant schwannomas in the hearts of male rats exposed to high levels of 2G/3G radiofrequency radiation (RFR), alongside some evidence of brain gliomas and DNA damage in certain tissues. • Ramazzini Institute: A large rodent study mirrored findings from the NTP, observing similar heart and brain tumor increases at lower exposure levels that closely mimic environmental cell tower exposures. • Cellular and DNA Research: Multiple in vitro and animal studies (including reviews indexed via PubMed) suggest that RF radiation can increase oxidative stress, trigger cellular inflammation, or cause single- and double-strand DNA breaks under specific experimental conditions. Here are two studies, one from the National Cancer Institute and the other from the National Institute for Health. https://pmc.ncbi.nlm.nih.gov/articles/PMC6701402/ https://www.cancer.gov/about-cancer/causes-prevention/risk/radiation/cell-phones-fact-sheet

EMF from WiFi Router Caused SLEEP DISTURBANCE. My child had always been a light sleeper until I found out how wireless radiation from WiFi routers could suppress melatonin production. When I turned off our WiFi router at night, my child began to sleep soundly throughout the night. My sleep quality also improved after turning off our WiFi router. There are studies that show melatonin supplementation may offset the harmful effects of non-ionizing EMF radiation. References: 1. https://pubmed.ncbi.nlm.nih.gov/14690281/ 2. https://pubmed.ncbi.nlm.nih.gov/34635042/

There are numerous studies demonstrating the damage that radio frequencies do on a cellular level. You have access to them. Use them to regulate these harmful radio waves. The so called 5G is a biological weapon. What are you going to do to protect all life on this planet from this invasive weapon?

I am responding to items 2, 3, 5, and 5.o-p. Perspective Individual consumer and patient. Personal experience In summer 2012 I temporarily lived in a basement apartment where a large Wi-Fi panel serving the floors above was located in a closet. I collapsed with a 106 F flu-like illness, dizziness, severe head pain, and loss of appetite. An integrative physician treated it as a severe flu with high-dose vitamin C, chiropractic care, and acupuncture. After about five days of fever therapy the fever broke, but I then could not eat solid food without severe nausea. I returned to my regular apartment, which had far less Wi-Fi exposure. My physician diagnosed Lyme disease based on symptoms despite no known tick bite or rash and inconclusive testing. Over the next six years symptoms progressed (severe gut intolerance limited to meat only, fatigue, bone and muscle pain, head pain, dizziness, auditory hallucinations, tremors, seizures, catatonia, double vision, memory and speech problems, panic attacks, internal electrical-shock sensations, and progressive difficulty walking) despite multiple infusions, hyperbaric oxygen, and other integrative treatments. Following advice from Dr. Jack Kruse—remove home Wi-Fi, ground outdoors daily, watch sunrise, and receive natural light without glasses or contacts—the acute symptoms resolved on the first day. I regained the ability to eat normally, walk, and have energy. In the nine years since I have not relapsed. I use only wired connections, cellular (no Wi-Fi) on my phone, and prioritize outdoor device use, daily sunrise, grounding, and natural light. Limited Wi-Fi is now tolerable if I remediate promptly outdoors. The large Wi-Fi panel appears to have been a significant factor. Removing the exposure and restoring natural light and grounding produced lasting recovery that prior treatments had not. Exposure evaluation should begin with the frequencies human biology is adapted to. Earth's natural electromagnetic field is approximately 7.4-8.2 Hz. Non-native EMFs (nnEMFs) fall outside this range. Technology should either operate near these low frequencies or include safeguards against excess exposure. This is not opposition to progress; it is a call to design for biological compatibility. Fiber optics are often proposed as lower-exposure alternatives, yet emission concerns remain at attachment and conversion points. 5.o-p A key knowledge gap is the degree to which health depends on alignment with natural electromagnetic, light, and circadian cues. Most chronic illness can be framed as mitochondrial dysfunction. nnEMFs can impair mitochondrial function and desynchronize the circadian clock; a disrupted clock further harms mitochondria. Restoring circadian alignment (natural light timing, grounding, reduced nighttime artificial light and nnEMF exposure) supports recovery. Federal research and standards should treat biophysics and circadian biology as central variables in assessing real-world RF/EMF exposure. References Becker, Robert O. Cross Currents: The Perils of Electropollution, The Promise of Electromedicine (1990). Becker, Robert O., and Andrew A. Marino. Electromagnetism and Life (1982). Becker, Robert O., and Gary Selden. The Body Electric: Electromagnetism and the Foundation of Life (1985). These works on bioelectromagnetics and non-thermal effects of electromagnetic fields informed this comment.

Re: HHS-OASH-2026-0397 — Occupational RF/EMF exposure and radar-maintenance workers I ask HHS to include current and retired radar-maintenance technicians in its evaluation of RF/EMF exposure and health. My Illinois Air National Guard work ran from 1981–1989; my FAA civilian employment ran from 1990–2017. Please consider this comment with both attachments: 1. “01 HHS response - numbered questions.pdf” answers Questions 2, 3, 5, 6, 7, 8, 9, 10, 11, 12, 16, 17 and 18. 2. “02 Supporting attachment - ANG and FAA radar maintenance.pdf” provides a partial maintenance account, historical FAA and AFOSH requirements, reproduced source material, research references, records-access concerns and seven policy recommendations. My work included energized radar and communications equipment, close working positions, simultaneous transmitter operation and troubleshooting under conditions different from ordinary operation. During ANG and FAA work, I removed covers and protective shields and energized equipment for troubleshooting and alignment near exposed high-voltage circuitry, discharge thyratrons, magnetrons, and klystrons. Assessments should represent actual maintenance conditions: worker position, task duration, open cabinets, altered shielding and simultaneous sources. They should also address indoor work in the building nearest the emitters, including possible reflections and standing waves. Equipment and building information and measurements are needed; external antenna calculations alone do not resolve indoor exposure. The RFI concerns non-ionizing RF/EMF. The attachment also addresses possible equipment-generated ionizing X-rays as a separate pathway that may coexist with RF. I ask researchers to evaluate each pathway and possible combined effects. Historical hazard descriptions and my recollections do not establish my individual dose or prove disease causation. I ask HHS to include endocrine outcomes, parathyroid disease and calcium regulation in long-term occupational research. The attachment distinguishes proposed mechanisms and experimental findings from established clinical evidence. Occupational-health processes should connect abnormal findings with appropriate medical evaluation and review of continuing workplace exposures. Written safety and occupational-health programs existed. I recall a Safety and Environmental Compliance Manager, but I do not recall ever receiving medical surveillance related to radiation exposure during my FAA employment. That recollection does not establish that no assessment occurred. The question is how requirements were implemented: what conditions were assessed, how findings were communicated, what monitoring decisions were made, and what referrals or follow-up were provided. Obtaining evidence has itself become a burden. Through FOIA, I have requested RF surveys, equipment configurations, technical manuals, safety training and occupational-health records. Despite multiple requests, follow-ups and an appeal, the records needed to evaluate my maintenance conditions are not readily available to me. An FAA response identified radiation-safety course updates in 2018 and 2023 without supplying those materials. FAA's historical requirements called for radiation-survey data, employee exposure records and related medical evaluations to be retained for employment plus 30 years. Employee exposure records were to be catalogued and readily accessible. I ask HHS to address the difference between required retention and effective worker access. Agencies should identify custodians, locate records and explain documented transfers or disposition. Unavailable evidence should not be treated as proof of no exposure or no harm. I ask HHS to coordinate with FAA/DOT, the Department of Defense, the Air Force, ANG and occupational-health agencies to evaluate actual maintenance exposures, provide relevant records, support long-term research involving retired technicians, clarify medical-referral and follow-up responsibilities, and assess workforce and public-safety consequences where gaps are identified. I also ask HHS to cooperate with Congress on a coordinated compensation pathway for occupational radiation harm. VA permits post service disability claims without a filing deadline; FECA generally has a three-year filing rule, with special provisions for latent disability. Workers with military and federal civilian exposure histories can encounter different rules for the same diagnosed illness. Related claims should receive coordinated or parallel evaluation using shared evidence and clear eligibility and benefit-coordination guidance. Please read both attachments as parts of this response. They provide the experience, evidence, limitations and recommendations supporting these requests.

Comment of Dr. Dimitris J. Panagopoulos, PhD, EMF biophysicist, Choremeion Research Laboratory, Medical School, National and Kapodistrian University of Athens, Greece. Submitted on his behalf and with his written permission by Nicolas Pineault, citizen journalist and author. The content is Dr. Panagopoulos's own published work and his written interview, attached without alteration. Q2 (perspective): research entity. Basis: peer-reviewed research, cited with links. Questions addressed: 5(p), 6, 12, 16. Q5(p), signal characteristics a classification system should account for. All digital wireless communication signals are emitted as on/off pulses repeated at extremely low frequency (ELF) rates, with intense variability in amplitude, shape, duration and repetition frequency; they are not continuous-wave radiofrequency carriers. These ELF pulsations were recorded directly from a Wi-Fi router and from 4G and 5G phones in Panagopoulos, Litovsky and Chamberlin 2026 (Electromagnetic Biology and Medicine, https://doi.org/10.1080/15368378.2026.2654072; response to comments: https://doi.org/10.1080/15368378.2026.2707966). Human-made fields are also fully polarized and coherent, unlike natural fields (Panagopoulos, Johansson and Carlo 2015, Scientific Reports, https://doi.org/10.1038/srep14914). Modulation, pulse characteristics, duty cycle, polarization and low-frequency variability therefore belong in any exposure classification. Q6 and Q12, evidence of effects below current limits, and a mechanism. In human peripheral blood lymphocytes, a 15-minute exposure to real mobile phone emissions at a power density about 136 times below the current ICNIRP limit was genotoxic by itself and significantly enhanced the chromosomal damage induced by gamma radiation, beyond the sum of the two exposures (Panagopoulos 2024, General Physiology and Biophysics, https://doi.org/10.4149/gpb_2023036). Related findings: synergy with a high caffeine dose (2020, https://doi.org/10.4149/gpb_2020036) and comparison of DNA damage from mobile telephony versus power-line fields in Drosophila cells (2019, https://doi.org/10.1016/j.mrrev.2019.03.003). The Ion Forced Oscillation and Voltage-Gated Ion Channel mechanism explaining how these fields trigger oxidative stress and DNA damage is set out in Panagopoulos et al. 2021 (International Journal of Oncology, https://doi.org/10.3892/ijo.2021.5272) and 2025 (Frontiers in Public Health, https://doi.org/10.3389/fpubh.2025.1585441), both open access. Q16, research priorities. Combined exposure to wireless fields with other stressors (ionizing radiation, chemicals) produced more damage than the sum of the separate exposures in the studies above. Research on combined exposures, and standardized measurement of the ELF components of wireless emissions, are the gaps these results point to. The attached interview (Pineault, September 18, 2024, https://theemfguy.com/emf-dangers-panagopoulos) sets out Dr. Panagopoulos's views on these questions in his own words. Attached: the interview; PDFs of the cited papers. Edited volume: Electromagnetic Fields of Wireless Communications: Biological and Health Effects, CRC Press, 2022, https://www.routledge.com/Electromagnetic-Fields-of-Wireless-Communications-Biological-and-Health-Effects/Panagopoulos/p/book/9781032061764. Full publication list: https://www.researchgate.net/profile/Dimitris-Panagopoulos-3

Chinese medicine practitioners who specialize in pulse diagnosis have been tracking a quality linked to EMF damage over the last 2 decades. Though he started his career as a Cornell-educated psychiatrist, Dr. Leon Hammer began studying Chinese medicine in the early 70’s and focused heavily on cultivating the art of Chinese pulse diagnosis. What he learned over the course of his career was alarming and my husband was tracking it along side him. The Leather-Hard pulse quality (representing the damage from heat ultimately drying out the vessel and creating rigidity) was an exceedingly rare finding prior to the late 2000s - only seen in a few people who were undergoing radiation treatment for cancer. But beginning in 2008, my husband began noticing this quality in a broader population, and over time in younger and younger people. Not only does this track with the advent of iPhones, but the growth pattern tracks with the ubiquity of "smart" everything. While this is observational and not proof of anything, patterns generally matched lifestyles with high EMF exposure and symptoms were consistent with EMF damage. In some cases, my husband could identify where on someone's body they consistently carried their phone based on what came up on the pulse. Here is Dr. Hammer discussing his findings in 2015: https://youtu.be/Gv5h-lDWvnI?si=sUGUcifCjhAmQwWC&t=559 Here is the paper Dr. Hammer and my husband wrote on their early findings: https://wellspringofhealth.com/wp-content/uploads/2015/06/The-Pulse-the-Electronic-Age-and-Radiation-Early-Detection.pdf

How safe is the increasing emfs? When studied by one signal alone it may not make a difference, but if not regulated how many devices are used in an area, does this accumulate the effects? Are we slowly cooking ourselves, affecting our DNA, combined with other enviromental factors causing more cancer, other health issues?