A journalist outlines research gaps in cumulative exposure, measurement, sleep, microbiome, infection, re…
ORIGINAL COMMENT · UNEDITED TEXT
Comment on Docket HHS-OASH-2026-0397, responding to Questions 2, 5, 7, 8, 9, 11, 12, 13, 14, 15, 16 and 18.
Perspective (Q2): I am submitting as an individual, a citizen journalist with 16 years of independent investigative work, the last 10 on electromagnetic radiation and health. I am the author of The Non-Tinfoil Guide to EMFs, host of the Smarter Tech podcast and director of the documentary Body Burden, and I have interviewed more than 100 scientists, physicians and engineers in this field.
My comment focuses on research gaps (Q16). My perspective is that our RF safety standards rest on the wrong assumption, that only tissue heating matters, and that this assumption keeps the gaps open: it created a culture of "no effect" from the public to regulators to researchers, and the topic was systematically defunded. The research is completely inadequate to protect the public, while the technology rolls out faster than our ability to study it. The attached document gives the evidence and full references for each gap below.
1. Combined exposures and the exposome (Q16, Q18, Q5o). Almost all RF research tests one exposure at a time, while people live with RF alongside metals, pesticides and mold. Dr. Ronald Kostoff's work documents how other agents modify EMF effects. Exposome studies should include wireless exposure (ambient RF, home Wi-Fi, smartphone use and position) as a standard variable.
2. Real-world exposure measurement (Q7, Q8, Q5n). The U.S. has no national program measuring actual RF exposure in homes, schools and hospitals, no routine post-market SAR testing of devices in body-contact positions (GAO-12-771), and the FCC has said it lacks the resources to routinely monitor transmitter emissions.
3. Sleep (Q12, Q16). Pulse-modulated RF alters the sleep EEG below current limits. Sleep clinics, which produce our reference data on sleep, are full of Wi-Fi, wireless equipment and phones, so the baseline is polluted. Sleep studies should run with and without wireless, with RF recorded; children sleeping beside phones and routers need study.
4. The microbiome (Q16). A 2024 study found a 5G-band RF field altered the gut microbiome and 258 metabolites in mice. People keep phones, laptops and tablets very close to the abdomen for hours on end, yet human studies do not exist.
5. Antibiotic resistance, tested in hospitals (Q16). Laboratory studies report that Wi-Fi and phone radiation change bacterial antibiotic susceptibility, biofilm formation and gene expression. Hospitals combine resistant pathogens with dense wireless, and no one has studied that setting. This is urgent.
6. Pregnancy (Q11b). Dr. Hugh Taylor's Yale research found in-utero cell phone exposure caused hyperactivity and memory impairment in mice. Prospective birth cohorts with measured exposure are needed.
7. Fertility and phones in pockets (Q5p, Q9, Q11). Frequent phone use is associated with lower sperm concentration. Carrying position cannot be settled because nearly every young man carries a phone against his body. Female fertility is barely studied.
8. Cancers where phones are now carried (Q12, Q11a). If RF is a possible carcinogen at the head (IARC Group 2B), the concern does not stop at the head. Dr. De-Kun Li and Dr. Devra Davis have raised phones in pockets and bras as worth investigating alongside rising early-onset colorectal, testicular and breast cancers. No study has examined carrying position.
9. Devices in the ear and on the head (Q13f, Q11). AirPods and other Bluetooth earbuds, Bluetooth hearing aids, smart glasses and VR headsets place transmitters near the brain for hours a day. Their effects on tinnitus, enlarged lymph nodes, hearing loss, cognition and head and neck cancers are unstudied. Hearing experts should test whether loud sound does more damage when an RF transmitter, a source of oxidative stress, sits in the same ear.
10. Towers near schools, hospitals and sensitive populations (Q15a, Q15b, Q11). Studies in several countries report symptoms, DNA damage and cognitive effects near base stations. They need replication in the U.S. with measured exposure. Chile bars towers near schools and hospitals; Switzerland applies limits ten times stricter at sensitive places.
11. Pollinators and insects (Q14). To my knowledge no RF exposure standard considers wildlife. Insects absorb more RF above 6 GHz, where 5G and 6G are heading, and field research on pollinators is almost absent.
These answers will not come quickly, even with a massive research effort. Hundreds of scientists (the International EMF Scientist Appeal, the 5G Appeal) have asked governments to apply the precautionary principle: minimize exposure now and give the public informed consent. Instead, governments have a financial incentive to speed up wireless deployment. Further development of 6G, the Internet of Things and satellites needs guardrails in place first.
Thank you for opening this question to the public.
Nicolas Pineault, The EMF Guy