Proposed biological mechanisms

Dear Madams and Sirs, I never really worried about EMFs until 5G implementation happened, and even then, only knew that what we are exposed to is non-ionizing and the DNA should be fine, but the other effects only became clear to me when I made friends with two people who call themselves "electrohypersensive". They both told me that after 20 minutes to a few hours in a high Wi-Fi environment, their weakness, headaches, brain fog, depression would climb and they would have to leave to find "quieter" ground to recover. One friend, a 30 year old male middle school teacher, has lived in his car for several years to escape to low EMF areas and can barely keep a job. The other friend, a 65 year old woman, 3 years ago predicted her death in the next year because she knew she was getting sicker and sicker as 5G grew. Her number one complaint was a constant and severe feeling of dehydration. Water, electrolytes, gels, watery vegetables, nothing helped her. Three months later she landed in the hospital, and the doctors were flummoxed by how many saline bags they had to keep giving her for three days before she began her recovery. I can now definitely attest to my own bizarre symptoms that kept increasing over the past 7 or 8 years finally improving after, out of simple peace of mind, I purchase Blushield's C1 and Pi devices for creating "harmonious frequencies" for my cells to attune to, instead of the ambient, chaotic EMFs we're all exposed to. It took about 6 months for me to realize these intense vasovagal storms where my blood pressure would suddenly drop, I'd fall to the floor unable to get up for several hours, diarrhea, vomiting, and terrifying immobility had stopped. My health, energy and mood improved in numerous ways as well. Since owning these devices, I've come to learn from numerous sources, including PubMed, that our cells, the cells of animals, insects, trees are suffering in a multitude of ways like chronic dehydration, cells clumping and sticking, voltage gated ion calcium channels are being overrun by the more powerful EMF voltages, and areas of our DNA that are normally kept "silent" for our own protection are now activating due methylation and acetylation malfunctioning, allowing viruses and retroviruses to wreak havoc on our immune systems. With up to 70% of the American population dealing with chronic illness, our current and rising EMF exposure will only take us down the wrong road. I have read that Big Telecom could alter these fields so they are harmonious to cellular health and life, and still deliver the same things we've come to depend on, our cell phones, internet, streaming and more. Why we don't do is not up to debate. It costs money to change what's in place, but this review on how EMFs have been impacting us is at least a start. Thank you for reading! Sincerely, Asia Real, Newbury Park, California

We know that radio waves affect cellular metabolism through calcium ion channels, and possibly other mechanisms. What we don't know is the long-term effects on human health. This is a huge topic because the RFenvironment that most Americans experience gets denser and more complex by the month. Let's do the health research so that we can expand cell service and wifi with our eyes open.

I am a parent of two elementary-school children, commenting on HHS-OASH-2026-0397. I support wireless technology. I do not support treating the absence of a settled harm finding as if it were a finding of long-term safety for children. Criminal law puts the burden on the state before it punishes a person. Chronic exposure of a whole generation is not that kind of question. Where exposure is widespread, begins in early childhood, and will continue for decades, the burden should be on showing that exposure below current limits is safe enough for developing brains and bodies. That is the precautionary principle, and it is the right standard for this RFI. U.S. radiofrequency limits are built primarily on avoidance of tissue heating and date to 1996. Children now grow up with phones, Wi-Fi, wearables, and nearby infrastructure that did not exist when those limits were set. A child’s head is smaller, the skull is thinner, and the same external field can produce a higher localized absorption than in an adult. That is an exposure fact, not by itself proof of injury. It is enough to reject adult-only limits as a sufficient account of childhood exposure. I am not asking HHS to declare a mechanism or to ban the technology. I am asking the Department to stop leaving parents with reassurance in place of evidence. The questions that matter for my children are still open. What is the evidence, for and against, that long-term radiofrequency exposure below current federal limits affects neurodevelopment, sleep, attention, and mitochondrial function? How should cumulative exposure from phones, routers, school networks, and nearby antennas be added together, rather than assessed one device at a time? Which international guidelines use lower limits or added precaution for children, what evidence those guidelines rest on, and why the United States does or does not follow them? I ask HHS to do four things. First, publish a plain-language comparison of U.S. radiofrequency limits with international guidelines that apply lower limits or additional precaution for children, and state the evidence each standard actually rests on. Second, fund independent research on long-term, low-level exposure in children and adolescents, with sleep, attention, neurodevelopment, and mitochondrial function as priority endpoints. Industry-funded work should be identified as such. Third, issue practical guidance for schools and families that reduces exposure without abandoning the technology: distance from the body, wired connections where feasible, routers and devices out of sleeping areas, and phones off the body and away from the bed. Fourth, treat childhood exposure near schools and in homes as its own assessment, not as a scaled-down version of occupational or adult-phone exposure. My children will live their entire development inside whatever standard this review leaves in place. A limited evidence base is a reason for precaution and better science. It is not a reason to treat the question as closed.

Living with an intolerance to wireless technology (including the author) (*) An increasing number of people live with the difficulties incurred by intolerance to the radiofrequency electromagnetic fields (RF EMF) generated by wireless technology. This ubiquitous ‘Electrosmog’ surrounds us all on a daily basis. EMF expert Dr. Magda Havas estimates that 35% of the population now struggles with symptoms related to exposure to radiofrequency microwaves from wireless devices, such as wi-fi, smartphones, tablets, smartmeters, and mobile phone masts, with 3-10% of people being “hypersensitive” – termed Electrical Hypersensitivity, EHS. Symptoms include: fatigue, headache, insomnia, irritability, lack of concentration (brainfog), cardiac arrhythmias, tinnitus, low mood and other physical and neuropsychiatric effects (1). Historically, it was thought to be a type of Microwave Sickness (2). In addition to tinnitus, there can be unilateral, high frequency hearing loss on the side of mobile phone use (3). Mechanisms include effects on the blood and autonomic nervous system leading to enhanced sympathetic response and downgraded parasympathetic response (ie. ‘fight or flight’) (4) (5). The WHO radioprotection programme multi-national study on the effects of radiofrequency electromagnetic field exposure on cancer in laboratory animals revealed a high certainty of evidence for gliomas, malignant heart schwannomas, and moderate for lung carcinomas, phaeochromocytomas and hepatoblastomas (6). The WHO’s International Agency for Research on Cancer (IARC) designated EMFs a Class IIB carcinogen in 2011, but, following further evaluation, there is now sufficient evidence to reclassify it as a Class I carcinogen – ie similar to tobacco and asbestos (7). Although there exists an ICD-10 code (W90) for exposure to non-ionising radiofrequency radiation, the medical profession often appears unwilling to consider this as a possible environmental trigger for illness in their patients (8). One helpful clue is that patients have sometimes noted that their symptoms are associated with EMF exposure (eg using a mobile phone). They then feel well when away from the device but feel ill again on re-exposure (9), Sometimes EHS sufferers are not taken seriously and there have been cases where the patient has been sectioned under the Mental Health Act for describing such an attribution of their symptoms (10). One might wonder whether irrational acts such as driving into crowds of pedestrians might be influenced by driver irritability from exposure to high levels of in-vehicle wireless technology (11). Whilst not universally medically recognised, EHS is a real, biological phenomenon, not a nocebo reaction. And as doctors we all remember the misclassification of CFS/ME as “all in the head”. Intolerance to RF EMFs occurs not only in radiofrequency radiation workers and the military, but also the general public, who are increasingly surrounded by pulsed, polarised electromagnetic radiation at work, school and home (12). Indeed, the Swedish government has funded shielding in hospitals for patients so affected (13). Let us hope that medical profession is now willing to educate itself on this topic so as to be better able to serve patients. Since ample, good science is available (14) (15), there is no longer any excuse to passively accept the platitudes of the communications industry based on outdated, thermal standards. (1)https://www.sciencedirect.com/science/article/pii/S0891061815000599?via%...) (2) https://academic.oup.com/occmed/article-abstract/51/1/66/1422266?redirec... (3) https://pmc.ncbi.nlm.nih.gov/articles/PMC3918279/ (4) https://pubmed.ncbi.nlm.nih.gov/24192494/ (5)https://www.sciencedirect.com/science/article/abs/pii/S019701861830634X?... (6)https://www.sciencedirect.com/science/article/pii/S0160412025002338 (7)https://pubmed.ncbi.nlm.nih.gov/30196934/ (8) https://icd.who.int/browse10/2019/en#/W85-W99 (9) https://www.onedaymd.com/2023/07/the-unsettling-rise-of-microwave.html (10) Personal communication (11) https://www.bbc.co.uk/news/live/cn5xnlkegz0t (12) https://pubmed.ncbi.nlm.nih.gov/17178584/ (13) https://www.eiwellspring.org/ehs/HospitalAccommodationsOfEHSPatientsInSw... (14) https://bioinitiative.org/research-summaries/ (15) https://pmc.ncbi.nlm.nih.gov/articles/PMC7139347/ (*) https://www.bmj.com/content/390/bmj.r1288/rr-1 Dr Janet Menage M.A. M.B. Ch.B. GP (retired), Wales, UK

I am RF sensitive. RF makes it impossible for me to maintain conversation because I can't connect the dots in the flow of conversation and I cannot recall and verbalize the responses I know I want to make. It makes my brain feel like I've imbibed too much alcohol; it makes my brain feelslike mud, probably because the radiation is opening my calcium channes, flooding calcium into the cell and intoxicating them. I believe, like tobacco smoke, cell phones should not be used in public places. Neither should wi-fi. I believe medical establishments should disallow same. The science is compelling when you remove Big Tech's tobacco science. Do your job to protect Americans.

I am submitting this comment as someone who has experienced a profound sensitivity to electromagnetic environments for many years. I often describe myself as a “canary”—someone whose nervous system seems to register environmental changes more intensely or earlier than the people around me. Living this way has been incredibly difficult. Again and again, people who experience the world more viscerally are told that what we are noticing is imaginary, psychological, or simply “in our heads.” I believe there is an important lesson in listening to the canaries rather than dismissing them. I am not asking regulators to accept every interpretation of electromagnetic sensitivity as established scientific fact. I am asking for serious, independent investigation into the possibility that our rapidly increasing exposure to human-generated electromagnetic fields may have biological consequences that we do not yet fully understand. The question should not only be, “Can we prove that EMFs cause a particular disease?” We should also be asking: What are the cumulative effects of living, sleeping, working, and raising children in environments saturated with increasingly complex electromagnetic signals? Are there populations who are more sensitive? Are there biological effects that occur below the thresholds currently used to define harm? And are our existing standards adequately accounting for long-term, continuous exposure rather than only acute thermal effects? My own experience has led me to think about this in terms of the body’s relationship with its electromagnetic environment. Everything in the human body is ultimately physical, biochemical, electrical, and energetic. Our nervous system, brain, heart, cellular signaling, and biological rhythms all depend upon extraordinarily precise electrical and electromagnetic processes. From a more holistic perspective, I also understand health as a state of coherence and harmony—with our bodies, with one another, and with the natural electromagnetic environment in which human beings evolved. Modern technology has introduced electromagnetic frequencies and patterns of exposure on a scale and continuity that are profoundly different from the environments in which our biology developed. I believe we should be humble about what we may not yet understand about that interaction. For people like me, this is not an abstract debate. When my environment changes, I can experience changes in my ability to rest, regulate, concentrate, and feel at ease in my own body. Whether the eventual scientific explanation validates my interpretation or reveals something different, the experience itself is real and deserves investigation rather than ridicule. And I believe this issue extends far beyond people who identify as electromagnetically sensitive. The absence of an obvious immediate sensation does not necessarily mean the absence of a biological effect. Many environmental exposures have historically been understood only after years of research. The people who notice something first are not necessarily the people who are imagining it; sometimes they are simply the people whose systems are giving an earlier signal. I therefore urge the government to support rigorous, independent, transparent research into the biological effects of both existing and emerging electromagnetic technologies, including long-term and cumulative exposure. Research should consider neurological, cardiovascular, cellular, reproductive, sleep, endocrine, and other potential effects, as well as individual differences in sensitivity. Most importantly, I hope we can create a regulatory environment that does not require people to become sick enough—or scientifically convenient enough—to deserve protection. We have an opportunity to listen to the canaries. Please take seriously the people who are telling you that something in their environment feels different. Investigate it. Measure it. Study it without predetermined conclusions. And allow the science to lead us toward technologies and environments that support human health rather than assuming that everything technologically possible is automatically biologically compatible. Thank you for considering my experience and this perspective.

I am extremely sensitive to EMF radiation. I'm akin to a coal mine canary for this issue. It developed slowly as EMF proliferated with cell towers, cell phones, and other microwave sources over the decades. I can no longer go into large cities. What I experience is overall an immediate sense of devitalization, like I'm losing energy on every level. like my whole body, is going into increasing states of shutdown. As the symptoms progress, I experience headaches, disorientation, even to the point if it's severe enough that I can become non-functional. It can take me days to come back to a balanced state. EMF jams some of the subtle communication systems that the body has outside the central nervous system complex. The science is there if it's investigated. U.S. government regulations don’t restrict low-level, non-ionizing EMFs and don’t consider biological effects like free radical creation, immune system suppression, neurological efects etc. Federal safety guidelines focus on,ionizing radiation (which breaks chemical bonds) and thermal effects (acute tissue) heating from high-intensity fields). Essentially the current EMF standards completely ignore their most pernicious effects. There are ways to mitigate this directly. I utilize technology from https://www.blushield.com which is highly effective. It can be used for homes and also devices that can be carried. Without this my life would be extremely limited. Building Biology Standards are particularly important in analyzing this general health issue, as they include Non-Thermal Biological Mechanisms. Independent scientific literature (such as the BioInitiative Report) compiles studies indicating the myriad of non thermal effects. I highly recommend that you investigate in depth the Bioinitiative 2012 website mentioned just below. Bioinitiative 2012 A Rationale for Biologically-based Exposure Standards for Low-Intensity Electromagnetic Radiation https://bioinitiative.org The credibility of Building Biology's specific low-frequency evaluation guidelines (SBM) sits outside mainstream consensus regulatory bodies, presenting a mixed picture regarding traditional empirical validation. Regulatory vs. Biological Limits: Mainstream regulatory agencies (like the ICNIRP or FCC) base limits strictly on short-term, high-intensity thermal effects (measurable tissue heating). By contrast, Building Biology guidelines are set orders of magnitude lower, targeting unproven or debated chronic non-thermal biological mechanisms. [1, 2] Building Biology guidelines have their basis in the Standard of Building Biology Testing Methods (SBM), built on decades of indoor environmental surveys and measurements insleeping areas, often in collaboration with physicians. [1] Medical Recognition: Professional medical organizations, such as the Austrian Medical Association and the European Academy for Environmental Medicine (EUROPAEM), have historically referenced or adopted Building Biology sleeping area guidelines as sensiblebenchmarks for long-term (over four hours daily) low-intensity exposures. [1] https://ehsciences.org/powerlines-emf-elf-magnetic-fields-health/ I am certain that if you do in-depth research you will find that the current standards are unworkable, and that the placement of many cell towers and other microwave and low frequency EMF sources such as power substations and electrical power lines need to be mitigated. There are ways to do this. I suggest that you talk to some of the experts who have researched these fields. you will more than likely receive extreme resistance from utility companies, companies, cell providers, etc. as this would mean immense overwhelming cost to mitigate this by moving towers, etc. I do not believe this is necessary. I believe other mitigation can be provided by devices such as you will read about if you look at the Blue Shield information above. feel free to contact me if you would like to discuss this further.

Title: Oxidative Stress: The Cause of Autism and Disease in General. Author: Martin T. Moore M.S. Professor of Kinesiology. Institutions: USC, UWM, Dallas College, Tarrant County College. Presented at The Brain Foundation Annual Symposium. August 22-25, 2025. A plethora of triggers can induce oxidative stress. Whether it is related to emotional stress, birth stress, ionizing radiation, non-ionizing radiation (cell phones), or cosmic radiation, high altitude hypoxia, parasites (both tropical and temperate zone) all causes have likely become more prevalent in the last 45 years. Our human body still has to deal with traditional oxidative stress triggers, like bacterial and viral infections as well as accidents. A review of literature indicates that many researchers have confirmed that oxidative stress (OS) not only correlates with neurological disease but may cause disease. (1,2,4). While many individuals that undergo oxidative stress may escape the cellular damage or death which leads to a disorder, it seems to be determined quite often by the activity of HIF (Hypoxia Inducible Factor) (3). The oxidative stress created by mitochondrial dysfunction can affect gene expression and development of the immature brain (20, 21). Oxidative Stress causes are numerous, especially given the changes in lifestyle during the last 45 years. The focus of this paper is the prevention of disease by safeguarding against the triggers of OS detailed in this review. Prospective parents and especially mature adults should become familiar with OS causes and make their best effort to reduce the risk of OS during pregnancy for the mother, in the child post birth, and adults as they age. Testing for OS during illness or testing routinely is a reasonable screen to perform, as detailed in this Pilot Study. Hydrogen Peroxide is a ROS (reactive oxygen species which accompanies OS and inflammation (13,14, 20, 21, 23) and maybe an easy in-home test to perform for a cost of approximately 45 cents per test! Hydrogen Peroxide toxicity is being studied internationally in relationship to DNA mutation and numerous chronic diseases. Harvest saliva with a pipette. Apply to a test strip until saturated. Wait one minute and compare any color change to the chart provided. More than .3 ppm requires immediate medical attention. Color chart measures may vary by manufacturer, so I regard any color change post application as a medical emergency. For more information, bibliographies, and updates on the research, email the author at lockmtm@gmail.com

I 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 parent and health advocate. At sufficiently high exposure levels, RF energy can heat biological tissue and cause harm. The International Agency for Research on Cancer (IARC) classifies RF electromagnetic fields as “possibly carcinogenic to humans” (Group 2B). 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 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 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 an individual/parent/grandparent. Because EMF radiation has affected me so greatly for so many years I have been researching the damages it causes for the past 6 years. I have read 4 books on it ("EMF'd", "Radiation Nation", "Unplug", and "The Non-Tinfoil Guide to EMF Radiation"), plus newsletters and articles from multiple sources. Here is my story: *I first noticed the problem in 2017 when a SmartMeter was installed right outside our bedroom window without our permission. That started disrupting my sleep greatly (couldn't get to sleep at all) so I had to start sleeping in the only bedroom that was not against that wall. *That helped somewhat but then I noticed that something was making my heart race. That is when I started studying the work of Martin Pall about how magnesium would help because it counteracts the VGCC’s (Voltage Gated Calcium Channels) that EMF’s open up. That eliminated the racing heart part as long as I didn't go near any source of EMF radiation after 5:00 p.m. *Then I started waking up every 2 hrs. to go to the bathroom. So my husband and I started turning off our WiFi at night. As long as the WiFi was turned off I could at least go back to sleep each time but waking up every 2 hours is not normal sleep! *It has been that way for the past 8 years until a month ago when I re-discovered something I learned from Dr. Mercola's book "EMF'd": Using molecular hydrogen water has had a PROFOUND effect on my sleep because it stimulates the Nrf2 pathway to neutralize free radicals that can lead to oxidative stress. Apparently my sleep problems were mostly due to the oxidative stress that EMF’s create. Now I only wake up once during the night! Yay! My husband’s story: *My husband used to have night terrors because he was sleeping against the wall where the SmartMeter is. He now sleeps with his head at the foot of the bed and that helped tremendously. He also recently had a mild stroke (called TIA) and the only cause we could trace it back to since he exercises, eats extremely healthy, takes multiple high-quality supplements, his blood work is perfect, we never put our cell phones up to our ears, and we have protective Defender Shield covers on our cell phones, is that: (a) his CPAP machine had been transmitting EMF's (we now use Airplane mode); (b) he had been doing consulting work in front of a computer for hours each day for 6 months; (c) his new hearing aids (purchased last year) had Bluetooth capability so he no longer uses that feature! I have learned from my research that EMF’s can cause blood clots and that oxidative stress can cause strokes! *Other stories from friends & loved ones: kids at school who say that they get terrible headaches after reading at school from an iPad for 3 or more hours each day, or kids who keep waking up during the night since there is an Alexa device near their head. One family friend was diagnosed with dementia at the age of 50 because she worked in front of a computer for 8 hours each day, and then at home she played on her cell phone a lot. Now her diagnosis is that her entire frontal lobe is gone! 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.