Proposed biological mechanisms

https://link.springer.com/article/10.1007/s12011-013-9836-z "Wi-Fi (2.45 GHz)- and Mobile Phone (900 and 1800 MHz)-Induced Risks on Oxidative Stress and Elements in Kidney and Testis of Rats During Pregnancy and the Development of Offspring" "Abstract The present study was designed to determine the effects of both Wi-Fi (2.45 GHz)- and mobile phone (900 and 1800 MHz)-induced electromagnetic radiation (EMR) on oxidative stress and trace element levels in the kidney and testis of growing rats from pregnancy to 6 weeks of age. Thirty-two rats and their 96 newborn offspring were equally divided into four different groups, namely, control, 2.45 GHz, 900 MHz, and 1800 MHz groups. The 2.45 GHz, 900 MHz, and 1,800 MHz groups were exposed to EMR for 60 min/day during pregnancy and growth. During the fourth, fifth, and sixth weeks of the experiment, kidney and testis samples were taken from decapitated rats. Results from the fourth week showed that the level of lipid peroxidation in the kidney and testis and the copper, zinc, reduced glutathione (GSH), glutathione peroxidase (GSH-Px), and total antioxidant status (TAS) values in the kidney decreased in the EMR groups, while iron concentrations in the kidney as well as vitamin A and vitamin E concentrations in the testis increased in the EMR groups. Results for fifth-week samples showed that iron, vitamin A, and β-carotene concentrations in the kidney increased in the EMR groups, while the GSH and TAS levels decreased. The sixth week results showed that iron concentrations in the kidney and the extent of lipid peroxidation in the kidney and testis increased in the EMR groups, while copper, TAS, and GSH concentrations decreased. There were no statistically significant differences in kidney chromium, magnesium, and manganese concentrations among the four groups. In conclusion, Wi-Fi- and mobile phone-induced EMR caused oxidative damage by increasing the extent of lipid peroxidation and the iron level, while decreasing total antioxidant status, copper, and GSH values. Wi-Fi- and mobile phone-induced EMR may cause precocious puberty and oxidative kidney and testis injury in growing rats"

https://www.mdpi.com/1648-9144/59/1/71 "Effects of Prenatal and Postnatal Exposure to 50-Hz and 3 mT Electromagnetic Field on Rat Testicular Development" "Abstract Background and objectives: It has been shown that electromagnetic fields (EMFs) have negative effects on the reproductive system. The biological effects of EMF on the male reproductive system are controversial and vary depending on the frequency and exposure time. Although a limited number of studies have focused on the structural and functional effects of EMF, the effects of prenatal and postnatal EMF exposure on testes are not clear. We aimed to investigate the effects of 50-Hz, 3-mT EMF exposure (5 days/wk, 4 h/day) during pre- and postnatal periods on testis development. Materials and Methods: Pups from three groups of Sprague-Dawley pregnant rats were used: Sham, EMF-28 (EMF-exposure applied during pregnancy and until postnatal day 28), EMF-42 (EMF-exposure applied during pregnancy and until postnatal day 42). The testis tissues and blood samples of male offspring were collected on the postnatal day 42. Results: Morphometric analyses showed a decrease in seminiferous tubule diameter as a result of testicular degeneration in the EMF-42 group. Follicle-stimulating hormone (FSH) and luteinizing hormone (LH) levels were decreased in the EMF-42 group. Lipid peroxidation levels were increased in both EMF groups, while antioxidant levels were decreased only in the EMF-28 group. We found decreased levels of vascular endothelial growth factor (VEGF) and insulin-like growth factor-1 (IGF1) in the EMF-42 group, and decreased levels of the SRC homology 3 (SH3) and multiple ankyrin repeat domain (SHANK3) in the EMF-28 group in the testis tissue. Conclusions: EMF exposure during pre- and postnatal periods may cause deterioration in the structure and function of testis and decrease in growing factors that would affect testicular functions in male rat pups. In addition to the oxidative stress observed in testis, decreased SHANK3, VEGF, and IGF1 protein levels suggests that these proteins may be mediators in testis affected by EMF exposure. This study shows that EMF exposure during embryonic development and adolescence can cause apoptosis and structural changes in the testis"

https://www.mdpi.com/1648-9144/59/1/71 "Effects of Prenatal and Postnatal Exposure to 50-Hz and 3 mT Electromagnetic Field on Rat Testicular Development" "Abstract Background and objectives: It has been shown that electromagnetic fields (EMFs) have negative effects on the reproductive system. The biological effects of EMF on the male reproductive system are controversial and vary depending on the frequency and exposure time. Although a limited number of studies have focused on the structural and functional effects of EMF, the effects of prenatal and postnatal EMF exposure on testes are not clear. We aimed to investigate the effects of 50-Hz, 3-mT EMF exposure (5 days/wk, 4 h/day) during pre- and postnatal periods on testis development. Materials and Methods: Pups from three groups of Sprague-Dawley pregnant rats were used: Sham, EMF-28 (EMF-exposure applied during pregnancy and until postnatal day 28), EMF-42 (EMF-exposure applied during pregnancy and until postnatal day 42). The testis tissues and blood samples of male offspring were collected on the postnatal day 42. Results: Morphometric analyses showed a decrease in seminiferous tubule diameter as a result of testicular degeneration in the EMF-42 group. Follicle-stimulating hormone (FSH) and luteinizing hormone (LH) levels were decreased in the EMF-42 group. Lipid peroxidation levels were increased in both EMF groups, while antioxidant levels were decreased only in the EMF-28 group. We found decreased levels of vascular endothelial growth factor (VEGF) and insulin-like growth factor-1 (IGF1) in the EMF-42 group, and decreased levels of the SRC homology 3 (SH3) and multiple ankyrin repeat domain (SHANK3) in the EMF-28 group in the testis tissue. Conclusions: EMF exposure during pre- and postnatal periods may cause deterioration in the structure and function of testis and decrease in growing factors that would affect testicular functions in male rat pups. In addition to the oxidative stress observed in testis, decreased SHANK3, VEGF, and IGF1 protein levels suggests that these proteins may be mediators in testis affected by EMF exposure. This study shows that EMF exposure during embryonic development and adolescence can cause apoptosis and structural changes in the testis"

https://pubmed.ncbi.nlm.nih.gov/28458069/ "Postnatal development and behavior effects of in-utero exposure of rats to radiofrequency waves emitted from conventional WiFi devices" "Abstract The present work investigated the effects of prenatal exposure to radiofrequency waves of conventional WiFi devices on postnatal development and behavior of rat offspring. Ten Wistar albino pregnant rats were randomly assigned to two groups (n=5). The experimental group was exposed to a 2.45GHz WiFi signal for 2h a day throughout gestation period. Control females were subjected to the same conditions as treated group without applying WiFi radiations. After delivery, the offspring was tested for physical and neurodevelopment during its 17 postnatal days (PND), then for anxiety (PND 28) and motricity (PND 40-43), as well as for cerebral oxidative stress response and cholinesterase activity in brain and serum (PND 28 and 43). Our main results showed that the in-utero WiFi exposure impaired offspring neurodevelopment during the first seventeen postnatal days without altering emotional and motor behavior at adult age. Besides, prenatal WiFi exposure induced cerebral oxidative stress imbalance (increase in malondialdehyde level (MDA) and hydrogen peroxide (H2O2) levels and decrease in catalase (CAT) and superoxide dismutase (SOD) activities) at 28 but not 43days old, also the exposure affected acethylcolinesterase activity at both cerebral and seric levels. Thus, the current study revealed that maternal exposure to WiFi radiofrequencies led to various adverse neurological effects in the offspring by affecting neurodevelopment, cerebral stress equilibrium and cholinesterase activity"

https://pmc.ncbi.nlm.nih.gov/articles/PMC6781513/ This is a Swedish study, that mentions various other studies. Among others a swiss study on RF causing symptoms in children. And it refers to studies on other health effects. "...A cohort study on Swiss adolescents showed that there was an association between whole body cumulative RF radiation dose from mobile phone talk, internet use and sent SMS and symptoms like headache and exhaustibility and also a decrease in figural memory (14,15). Many research studies have shown effects from RF radiation exposure on animals below current safety levels with opened blood brain barrier and neuronal damage (16,17), oxidative stress with increased production of reactive oxygen species (18,19), DNA-damage especially in the memory center hippocampus in the brain and increase in pro-inflammatory cytokines (20). Apart from animal studies research studies on people living near mobile phone base station show augmented indications on health risks. Adverse effects have been seen on neurotransmitters in the brain (21), on hormones like cortisol, ACTH and from the thyroid, decreased levels of testosterone in men and prolactin in young women and also increase in salivary cortisol (22,23). Other studies have shown lowered antioxidant levels and induced DNA damage in blood lymphocytes (10,24) as well as health complaints. Symptoms like sleep disturbances, headache, fatigue, dizziness, cardiovascular symptoms depression and difficulties with memory and concentration have been reported from people living near mobile phone base stations (25,26)." Of note they also mentioned that the window surfaces may reflect some of the RF from the outside. I think this would mean indoor RF bounces off of windows too. "...Lower levels were detected also in the vicinity of the windows. This indicates a notable screening effect by the contemporary heat-reflecting windows..."

https://pmc.ncbi.nlm.nih.gov/articles/PMC6781513/ This is a Swedish study, that mentions various other studies. Among others a swiss study on RF causing symptoms in children. And it refers to studies on other health effects. "...A cohort study on Swiss adolescents showed that there was an association between whole body cumulative RF radiation dose from mobile phone talk, internet use and sent SMS and symptoms like headache and exhaustibility and also a decrease in figural memory (14,15). Many research studies have shown effects from RF radiation exposure on animals below current safety levels with opened blood brain barrier and neuronal damage (16,17), oxidative stress with increased production of reactive oxygen species (18,19), DNA-damage especially in the memory center hippocampus in the brain and increase in pro-inflammatory cytokines (20). Apart from animal studies research studies on people living near mobile phone base station show augmented indications on health risks. Adverse effects have been seen on neurotransmitters in the brain (21), on hormones like cortisol, ACTH and from the thyroid, decreased levels of testosterone in men and prolactin in young women and also increase in salivary cortisol (22,23). Other studies have shown lowered antioxidant levels and induced DNA damage in blood lymphocytes (10,24) as well as health complaints. Symptoms like sleep disturbances, headache, fatigue, dizziness, cardiovascular symptoms depression and difficulties with memory and concentration have been reported from people living near mobile phone base stations (25,26)." Of note they also mentioned that the window surfaces may reflect some of the RF from the outside. I think this would mean indoor RF bounces off of windows too. "...Lower levels were detected also in the vicinity of the windows. This indicates a notable screening effect by the contemporary heat-reflecting windows..."

https://www.cell.com/cell-reports/fulltext/S2211-1247%2825%2901009-5 This study mentions autism like behaviour in animals exposed to EMF. And that ASD associated gene expression in cortical neurons and dendritic spine density seems to increase with RF exposure. Suggesting a link between autism development and RF exposure. "...No major neurodevelopmental defect has been linked with RF exposure, mainly due to its relatively weak energy compared with X-rays or gamma rays.40 However, emerging evidence suggests that prolonged RF exposure may have subtle neurodevelopmental implications. Recent studies in animal models exposed chronically to RF have shown autism-like behaviors, raising concerns about the impact of RF on neurodevelopment.41 For instance, behavioral changes such as hyperactivity and cognitive deficits observed in animal models highlight the need for further exploration into the neurodevelopmental consequences of RF exposure in humans. Although decades’ worth of studies have reported a broad range of adverse impacts from RF on human health, RF-mediated dysregulation of human brain development has remained largely unknown. In this study, we showed the detrimental effects of RF exposure to cortical organoids.42 The perinatal period in neurogenesis encloses a distinctive window embodying diverse molecular and cellular processes required for proper development.5 Though prenatal brain development comprises high plasticity, it is vulnerable to internal and external perturbations. Thus, environmental insults, including chemicals, drugs, pollution, stress, and even prolonged ultrasound wave exposure, can permanently impact brain development and subsequent behavior.43,44 Our findings revealed that RF-exposed cortical neurons exhibited increases in ASD-associated gene expression and dendritic spine density, characteristics of patients on the autism spectrum.45 Furthermore, the parallels drawn from in utero RF exposure in animal models, which have demonstrated behavioral changes such as hyperactivity and memory deficits, underscore the relevance of our findings in a human context.41,46 These findings suggest a potential shared mechanism by which RF exposure may contribute to neurodevelopmental disorders across species. Altered morphology and transcriptome driven by RF exposure in hCOs further lead to aberrant and enhanced neuron firing. In fact, in utero RF exposure in mice models results in behavioral and cognitive changes such as hyperactivity and memory deficit.41 Notably, we showed that physical barrier protection or chemical treatment could attenuate the RF-induced damage during cortical organoid development. Here, we have thoroughly examined the effects of RF exposure and demonstrated RF-induced changes associated with ASD in the transcriptomics, morphology, and function of cortical neurons. This addition to the literature is particularly significant given that most studies have historically focused on genetic causes of ASD, while environmental factors, particularly RF exposure, have been understudied. By utilizing induced pluripotent stem cell (iPSC)-derived hCOs, our research offers insights that bridge the gap between animal models and human neurodevelopment. The use of human organoids enables us to detail the specific impacts of RF exposure on human neuronal cells, which may differ from findings observed in animal models. Our findings also point to the potential involvement of BET proteins in the regulation of neurodevelopmental pathways affected by RF treatment. We propose that BET proteins may be altered in RF-treated hCOs, similar to how they are affected in Rett syndrome model organoids with MeCP2 mutations.29 It remains to be determined whether BET proteins are significantly downregulated in RF-treated organoids. If so, the inhibition of BET proteins could serve as a therapeutic strategy to rescue delayed differentiation in these organoids. This interaction raises the question of whether RF exposure and BET regulation function in an epistatic relationship or operate independently"

Both my wife and I are electrosensitive in that we avoid wi-fi, solar panels and do not use smart phones etc. We are both in our early seventies and have been aware of this issue for much of our lives. One aspect that is rarely given any attention is the role of water in electrosensitivity. Water conducts electricity and this is affected by increases in pH, and the higher or more alkaline the pH the more the mineral content. Electrosensitvity can be assisted by decreasing the mineral content and pH of drinking water. The chemical treatment of drinking water must surely also have some impact on sensitivity. Does ultraviolet filtering have any adverse effects on drinking water for the sensitive individual? In our experience it has a negative effect. Elecrically and chemically sensitive individuals can greatly benefit from an organic diet with wholegrains and full fat dairy and the avoidance of processed foods and all vegetable oils. I would also recommend the filtering of all household water with a large filter with catalytic carbon (standard carbon filters are inneffective against chloramines)

On behalf of the EFEIA Institute (Miami, Florida), I submit our organization's attached public comment, national program proposal and letters in response to HHS Request for Information, Docket No. HHS-OASH-2026-0397. This comment represents the perspective of a research entity. The attachments are a proposal prepared by EFEIA in October 2026, my request letter, made together with Dr. Robert Marshall Leal Lue, PhD in clinical psychology, Dr. Pilar Muñoz-Calero and other specialists, and letters from Dr. Pilar Muñoz-Calero, MD, President of Fundación Alborada (Madrid), and Dr. Luis M. Valdés, physician and audiologist. Disclosure: the undersigned is also founder and CTO of NOXTAK Corporation, which develops electromagnetic hygiene products; the 2014-2018 patient cohort described in the proposal evaluated a NOXTAK product among concurrent interventions. The proposal evaluates no product. WHO recognizes the symptoms of electromagnetic hypersensitivity (EHS, IEI-EMF) as real and potentially disabling, and systematic reviews of blind provocation studies have found no robust evidence that exposure triggers them. We accept that record. Those studies, however, tested a narrower question than the conclusion often drawn from them: most measured conscious detection of a field, or symptoms reported during or soon after short laboratory exposures. A systematic review of 28 provocation studies found selection bias in 82% of them and, in 57%, exposure and assessment times that were not matched to each participant's reported symptom latency. In our clinical experience, from a four-year cohort of 357 patients and more than 1,500 cases reviewed through EFEIA's consultant network, EHS presents as a sensitized and partly conditioned stress response. Short blinded tests with perception as the endpoint cannot separate the environmental trigger, the physiological sensitization and the learned response, and a reaction to an inactive cue does not show that the original trigger was inert. Tinnitus, reported by 50.7% of EHS respondents against 17.5% of controls in a German case-control study, is not yet a defined outcome in this research. We urge HHS to convene an independent, publicly funded review of the criteria used to design and interpret EHS studies, and to support a 24-month program that publishes revised criteria, including stratification of participants by conditioned response and physiological sensitization, personalized and prolonged exposures, delayed-response windows, characterized sham conditions and objective physiological endpoints; a blinded multi-site replication of the biomarkers reported to date; tinnitus and sound intolerance as defined outcomes; a clinical pathway of differential assessment before attribution, with professional training; a consented registry with measured exposure; and proportionate precaution in hospitals, schools and care settings. OASH would convene the program; NIEHS would lead exposure assessment and biomarker replication, NIDCD the tinnitus outcome set, CDC case definition, registry methods and clinical guidance with NIEHS, and FDA's Center for Devices and Radiological Health exposure systems and dosimetry for provocation studies. This comment responds to questions 4(h) to 4(j), 4(l), 4(m), 5(o), 10(a), 10(d) to 10(f), 11(f), 11(g), 16, 17(a) to 17(c) and 18. The attachments are: - Additional 5, National Program: National Program for the Review of Research Criteria in Electromagnetic Hypersensitivity: A proposal to revise how studies of electromagnetic hypersensitivity are designed and interpreted, with objective endpoints, a clinical pathway and tinnitus as a defined outcome (https://doi.org/10.5281/zenodo.23545803). - Request letter from J. Joaquín Machado, 21 October 2026. - Letter from Dr. Pilar Muñoz-Calero, MD, President, Fundación Alborada, 8 October 2026. - Letter from Dr. Luis M. Valdés on electromagnetic hypersensitivity and the amplification of tinnitus, 21 October 2026. Please accept and consider all attached documents, the Additional 5 proposal and the three letters, as part of the public record. Respectfully, J. Joaquín Machado EMR Researcher and Director of the EFEIA Institute

Thank you for the opportunity to submit information regarding biological effects and potential health hazards of low-level, long-term exposure to radiofrequency radiation (RFR). I am providing here some personal comments regarding that topic, as well as some scientific evidence. Part One: Personal Comments (1) I have always kept myself in good physical condition. It was a bit surprising, then, that beginning in mid-2009 I began to experience frequent ringing in the ears and strange, repetitive lower-GI symptoms. (2) In 2014 I began experiencing neuropathy in both feet. Shortly thereafter both hands went numb. My feet began to be cold all the time. I consulted my doctor. He suggested Raynaud's Syndrome as a tentative diagnosis. (3) In 2016 new symptoms began. In addition to ringing in the ears and neuropathy in hands and feet, I had intermittent night sweats, urinary urgency, occasional severe eye pain, intermittent tachycardia, and rapid development of varicosity in the veins of both lower legs. (4) After researching my strange array of symptoms, I hypothesized that they might be caused by high-frequency sounds emanating from motorized equipment atop a building a few blocks away. I sound-proofed my bedroom. That didn't help. I tried sleeping in a different room on the other side of the house where I seemed to be less symptomatic. That did help, yet I couldn't imagine why. (5) In 2017 I learned that pulsed microwaves from wireless communications technology can induce some or all of the symptoms I was experiencing. I purchased a meter for measuring RFR as well as one for measuring AC magnetic and electric fields. We switched off our WiFi-enabled Internet router, opting instead for wired-only (Ethernet) connectivity. We shielded a wall in my bedroom where WiFi was coming in from the house next door. (6) Most of the newer, more concerning symptoms dropped away within a few months after implementing our mitigation measures. No more tachycardia. No more night sweats. No more severe eye problems. No more numbness in my hands—I could sign my name again! (7) Since 2018 I continue to have varicose veins in my legs. (Once contorted, veins cannot return to normal.) Recent tests reveal I have "chronic venous insufficiency" in both legs. (8) By experimenting with different environments and measuring the levels of RFR that “trigger" my symptoms, I've discovered that any space, indoor or outdoor, where RFR peaks at more than about 300 microwatts per square meter is unhealthy for me. Lingering for more than about 15 minutes in such a place can cause a feeling of malaise involving fatigue and lower GI discomfort, plus "brain fog" and possibly a headache. I also typically experience "buzzing" or burning sensations in my lower legs. Essentially, I am now sensitive to all forms of wireless communication technology. I am also triggered by AC magnetic fields emanating from home appliances that have fairly powerful electrical motors (vacuum cleaners, refrigerator, clothes washer). (9) I discovered a couple of years ago that PG&E installed "smart" (RFR-emitting) electricity meters in our neighborhood in January of 2009. Perhaps those are the original inciting stressors. (10) Our use of WiFi from 2011 to 2017, as well as our neighbor's adoption of WiFi beginning in 2014, may have caused the amplification of my symptoms during those years. Part Two: Scientific Evidence Regarding Biological Effects and Potential Health Effects Together with two colleagues, in 2018 I measured ambient levels of RFR in four residential neighborhoods in Davis, California. Our goal was to find out how much RFR exists and what frequencies are present. The essence of what we learned is this: (i) the level of RFR varies greatly, from a low of just 2 to as much as 20,000 microwatts per square meter, (ii) all neighborhoods are "saturated" with RFR from mobile phone base stations (cell towers). In 2021 and 2022 I participated in a worldwide RFR-measuring campaign. The results may be viewed at the website GlobalEMF.net. The project revealed that power density of RFR along streets in the downtown areas of many cities exceeds 10,000 or even 100,000 microwatts/m2. Unfortunately, environmental levels of RFR peaking above about 1,000 microwatts/m2, and especially those peaking above 10,000 microwatts/m2, are associated with biological effects of a neurological, cardiovascular, or neuroendocrine origin. Various peer-reviewed papers published since the late 1980s, and especially since about 2000, together reveal that the pathophysiological symptoms are of biochemical and biophysical origin. The mechanism of action involves nitric oxide and peroxynitrite and various complex and interconnected biochemical pathways intrinsic to the human body (and to other forms of life). I'm uploading a 2007 review paper by Pacher, Beckman, and Liaudet that aids in understanding the breadth of the potential pathophysiological symptoms. Also provided: an outline.