Research & federal duties

Comment of Protection of the Educational Rights of Kids (PERK), Amy Bohn, President, in Docket HHS-OASH-2026-0397. Our full comment is attached. It responds to Questions 2, 5(n), 9, 11(a), 12, 13(c), 15(a), 16, and 17 as numbered in the notice. We file as a parent-led organization. Children in American public schools and licensed child care spend six to seven hours a day, roughly 180 days a year, inside wireless infrastructure that their parents were never told about and never asked to approve. That is the parent side of this docket, and it does not depend on how the science comes out. The FCC's exposure limits date to 1996 (11 FCC Rcd 15123). The D.C. Circuit held in 2021 that the FCC had not given a reasoned explanation on children, long-term exposure, and the spread of wireless devices, while taking no position in the scientific debate (Environmental Health Trust v. FCC, 9 F.4th 893). The FCC reopened that record only on September 17, 2026, while a mandamus petition was pending (In re Children's Health Defense, No. 26-1121). The FDA's 2020 literature review addressed cancer only. This notice itself says public concern has risen, particularly around children, schools, and long-term cumulative exposure. When the government cannot say the question is closed, the decision belongs with the parent, and a parent cannot decide without information. What changed since 1996: the FCC funded classroom Wi-Fi through E-Rate Category Two (FCC 14-99; 47 CFR 54.502); 88 percent of public schools now run one-to-one device programs (NCES, 2024-25); and Florida regulates the student's phone during the school day (s. 1006.07(2)(f), Fla. Stat.) but no Florida statute or State Board rule requires a district to tell parents what wireless infrastructure operates in a classroom. The only federal notice requirement attached to E-Rate concerns content, not equipment (47 U.S.C. 254(l)). We ask HHS to do four things. 1. Disclosure (Question 9). Issue a six-item notice format for schools and licensed child care providers: an inventory of transmitters by classroom; the operating schedule; device practices; any measurements taken; wired alternatives and how to request a lower-exposure placement; and a contact. France's 2015 law (Law No. 2015-136, art. 7) and Maryland's 2016 advisory council report already recommend practices of this kind, and Oregon (SB 283, 2019) and New Hampshire (HB 522, 2019) have put the question to study. 2. Guidance (Question 5(n)). Issue practical exposure-reduction guidance for schools and child care providers: wired connections where practical, access points off when not in use for instruction, devices off the body, and no wireless equipment in rooms for the youngest children. School network controllers in common use already support scheduled availability as a standard feature. 3. Measurement (Question 16). Fund a national study of RF levels in occupied classrooms and child care rooms during the school day. No federal agency has published such a dataset. The one government classroom measurement study we found is ARPANSA's 2017 study of 23 Australian schools. Add wireless infrastructure and parent notice questions to CDC's School Health Profiles, which ask nothing on the subject today. State whether the National Toxicology Program's RF research, listed as completed, will resume. 4. Coordination (Question 17). Open a standing channel with the Department of Education and the FCC, and ask that E-Rate Category Two recipients post the equipment disclosure at the internet safety hearing the statute already requires. We also ask the Department to state in its summary of this docket that schools and child care facilities are settings of involuntary, long-duration exposure for children, and that disclosure to parents is warranted on that basis whatever the outcome of the scientific review. PERK's September 2026 filings in Docket HHS-OS-2026-0332 rest on a survey of 664 parents. We offer to run a wireless version of that instrument, measuring notice and consent as parents experience them, with partner organizations across multiple states, and to provide the results to the Department in whatever form it designates. The instrument is available on request. This comment contains no personally identifiable or personal health information. Every factual claim in the attachment is cited to a primary source, with a Sources list at the end. Prepared by Rebekah Ricks, Senior Consultant. Contact: abohn@perk-group.com; Rebekah@PERK-GROUP.com.

I support HHS in taking an active part in researching & then regulating the obvious affects that wireless radiation has on our environment with regard to our children, animals, birds, flora & fauna, etc. The time has come for this issue to be brought out from under the rug & scientifically examined in great depth. Our Mother Earth home deserves that We The People do the right thing by her. Thank you from a mother, grandmother, great grandmother & health freedom activist

World Council for Health (WCH) welcomes the opportunity to respond to the U.S. Department of Health and Human Services' Request for Information. WCH is an international health advocacy organisation committed to promoting informed consent, individual health sovereignty, scientific transparency, and the protection of human and environmental health. We believe that the rapid and largely unrestrained expansion of wireless technologies represents a significant public health and environmental policy concern that warrants urgent, independent and comprehensive scientific scrutiny. Over recent decades, wireless communications infrastructure has expanded dramatically, introducing increasingly widespread and persistent exposure to man-made electromagnetic fields. While technological innovation has brought considerable benefits, WCH is concerned that the pace of deployment has outstripped the assessment of potential long-term biological and environmental consequences, particularly in relation to chronic, cumulative and involuntary exposure. In 2023, WCH published its Policy Brief on the Effects of Unregulated Digitalization, examining the wider implications of rapidly expanding digital and wireless technologies for public health, human rights, democratic accountability and the environment. This body of work includes the recommendations of the late Dr Arthur Firstenberg, who devoted decades to investigating the biological and ecological effects of electromagnetic fields. His work brought together scientific publications examining possible effects on neurological function, cellular processes, reproduction, wildlife, biodiversity and ecosystem health. Of particular concern is the extent to which existing RF exposure standards have historically focused on established thermal effects, while questions concerning long-term exposure, non-thermal biological effects, signal modulation, vulnerable populations and ecological impacts remain contested or insufficiently resolved. WCH believes that public health policy must consider the full breadth of available evidence, including research findings that challenge prevailing assumptions about exposure thresholds and biological safety. We are particularly concerned about the implications for children, pregnant women, individuals reporting electromagnetic hypersensitivity, and those who have little practical ability to avoid exposure in their homes, schools, workplaces or communities. The continued expansion of 5G telecommunications and wireless infrastructure including the introduction of new frequencies, network configurations and connected technologies raise further questions about aggregate exposure, long-term health effects and the adequacy of existing safety assessments. The potential environmental implications must also be considered. The Brief highlights research examining associations between anthropogenic electromagnetic fields and changes in the behaviour, development, reproduction and survival of insects, birds, plants and other organisms. These findings require careful evaluation, including consideration of study limitations and other environmental factors, as part of a comprehensive approach to ecological protection. WCH therefore calls for an independent, transparent and multidisciplinary review of the scientific evidence, free from inappropriate commercial or regulatory conflicts of interest. Such a review should address thermal and possible non-thermal effects, chronic and cumulative exposure, biological responses to modulation and pulsed signals, and the implications of exposure across the lifespan. We further urge HHS to consider the precautionary principle, particularly where exposure is involuntary, where vulnerable populations may be affected, and where meaningful opportunities to reduce unnecessary exposure exist. This includes serious consideration of practical alternatives such as wired communications infrastructure, greater public disclosure of exposure information, improved professional education, and individual choice. WCH encourages greater coordination between public health authorities, environmental agencies, independent researchers and affected communities, recognising that the potential implications of electromagnetic pollution extend beyond conventional telecommunications regulation. The protection of public health and the natural environment must remain central to technological policy, and not be treated as secondary considerations after widespread deployment has already occurred. We believe that responsible technological development must be guided by independent science, transparency, informed consent, the protection of vulnerable populations, and a commitment to safeguarding the health of both present and future generations. Yours sincerely Dr Tess Lawrie MBBCh, PhD Ambassador World Council for Health worldcouncilforhealth.org https://www.worldcouncilforhealth.org/what-is-5g-health-risks/

There are many reasons to research the impact of man-made non-ionizing radiation. First, we’ll start with cellphone and mobile base stations (MBSTS) effects on children (it should be noted these base stations are leased and pay the schools tens of thousands of dollars annually). A study involved parting a non MPBST (mobile phone base station) exposed group to an exposed group and comparing test scores after a period of 2 years’ time (Meo SA et all, 2018). The impact of the radiation showed memory and motor deficiencies of significant value. In the attached report you’ll see a significant difference in the study groups when it comes to learning and memory. I will say that I have measured the radiation from my cellphone in an otherwise zero EMR environment. The zero EMR environment registers 0.2 to .5 mW/cm2 (0.2 microwatts per meter squared), which is considered very safe. Comparatively, when you measure my phone with its Wi-Fi turned on (and no other connectivity signal), I get 189,000 mW/cm2. That’s an incredible difference. Other individuals of concern are those with preexisting medical conditions, especially those with weakened immune systems are more susceptible to the degrading effect EMR has on the blood brain barrier. The BBB is a semipermeable border that moves ions, oxygen and water between the blood and the central nervous system. It serves to block pathogens and toxins from entering the brain and these studies have found correlation between EMR and penetrability of the Blood Brain Barrier. Additionally, IARC (International Agency of Research on Cancer) have found cellphone users have a greater risk of cancer (MSD, 2016). Cumulative exposure is the biggest problem with EMR. It is very hard to determine the cause of issue when so many devices are involved. The various sources of cumulative exposure include 6G, 5G, Wi-Fi and wearable technology. 6G involves THz (Terahertz) frequencies that will have the ability to alter DNA and neurons. It has been determined that 5G and 6G and other high frequency radiation causes tissue and nerve damage (Minar, 2025). The IoT will magnify the effects of EMR as many appliances connect and communicate with each other. Wearable technologies concentrate EMR on the body and range up to 2.4 GHz, which is not advisable to wear and it is not fair to expose others to this device’s radiation (Revolutionhealth, 2025). Unless it is mandatory, wireless medical devices should not be worn (mdasafetech, 2026). It is also known that wireless devices can cause heart issues and it’s extremely ironic they are used to measure heart rate and other general health metrics. As for satellite-based communication, studies need to be made regarding its impact on the environment and biology. The WHO and FCC have already mentioned, in their former studies, that electromagnetic radiation devices are possibly carcinogenic. These same studies are decade’s old and needing review. It should be assumed that at this point, with the massive increase in man-made electrical fields, that scientific evidence is irrefutable and that it does cause harm (Johansson, 2026). Like tobacco and alcohol, outreach/education about the potential harmful impacts of wireless radiation should be readily available with warning labels. At this time, the cellphone and telecommunications companies are largely uninsurable due to the high risks of electromagnetic fields (ehtrust, 2026) (Complete Markets, 2026). Since we are discussing the need for HHS to reevaluate and none of the other branches, we can talk about the need to expand its epidemiological studies to cover the cancer and leukemia issues known to be associated with this as well as harm reduction in classes, libraries, hospitals and public spaces. Every technological product we use has a measurable field. These items should be 3rd party tested and sold with the readings provided and a warning label printed. The packaging should be sold with a label that states its level at microwatts per meter squared (mW/cm2) and each level should be color coded for quick recognition so that we can create a baseline chart that consumers easily understand. Much like the EMR test meters available on the markets, you’ll have Red, Orange, Yellow and Green and these colors correlate to the degree of signal on the object. The FDA will be responsible for labeling and verifying full disclosure is provided to consumers. Public spaces need to be measured and coded as well and if possible, provide Ethernet connections and lower their EMR signal to the minimum necessary. We already have thousands of well researched, published scientific articles online that have spanned 40-50 years. We don’t need to invent the cart; we just need some horses and a destination. Thank you for taking the time to read my comment on man-made electromagnetic radiation and its effects on health. Sincerely, Nicole Stallings

Please see the attached document: my response to the HHS Request for Information on Electromagnetic Fields and Wireless Radiation (HHS-OASH-2026-0397). I am an Electromagnetic Hypersensitive (EHS) person from Israel and an EMF/EMR awareness activist. My life, and my daughter's, have been deeply affected by exposure to EMF/EMR. Since 2006 I have supported EHS people in Israel and worldwide with exposure measurement and reduction, and I run the information site www.norad4u.com. My main points: 1. Many studies show biological and health effects of RF/EMF at levels far below current FCC and ICNIRP limits. 2. EHS is real and is caused and influenced by EMF/EMR exposure. Reducing exposure reduces symptoms. 3. Provocation studies with design flaws (such as Rubin et al., 2006) should not be used to dismiss EHS. 4. Exposure should be measured with fast-sampling meters showing peak values, not averages over minutes. 5. New, health-based exposure guidelines are needed, with special protection for EHS people, children and other sensitive groups. 6. Federal health agencies should track symptoms, EHS cases and exposure, and fund research on how, not if, EMF/EMR causes harm. The attached document answers the RFI questions (Q2–Q17) and includes a numbered list of 134 scientific references. Amir Borenstein Zichron Yaakov, Israel norad4u@gmail.com

I have a friend who is sensitive to wireless, she can feel it, and is unable to sleep near any RF like cell towers, wifi routers, cellphones, and more. I have seen this have a huge negative impact on her life and health, and she is unable to travel much and often has to drive distances to do normal activities. I am very concerned for the lack of science, studies and protocols to protect the public’s health, and that no real third party testing, science or disclosure about health has been done or shared for over 30 years. It’s hard to believe that we have been in the dark about safety, health and wireless exposure all this time, and that needs to change right now. There are people who are at risk most for health issues including children, and more research and transparency is needed now. Please make current testing, funding and appropriate scientific research required starting now, and public health conversations mandatory and mainstream. Corporations shouldn’t decide what’s safe for us, science and health should be the main focus, and the public process should be the priority. We need to closely examine non-ionizing wireless radiation and all RF. European and Scandinavian countries have done this- they prohibit cell towers near schools and homes for a reason. We need to follow their example. Put science and safety first before profit. Thank you. I am attaching relevant articles and studies: https://www.frontiersin.org/journals/cardiovascular-medicine/articles/10.3389/fcvm.2025.1499499/full https://bioinitiative.org/research-summaries/ ttps://www.techsafeschools.org/science https://www.babysafeproject.org/science https://mdsafetech.org/conversion-and-exposure-limits-EMREMF/

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 patient. I have been exposed to EMFs, RFs, and Wireless Radiation for years as a Police Dispatcher from the frequencies produced by the Centracom and multiple computers. I then was exposed at my current employer as the 5G Cell Tower sits right next to my building. I am suffering from Baroreflex Syndrome as my Baroreflex Receptors have been damaged from Radiation exposure. I now have dangerously low blood pressure that will spike at any moment. There is no cure for it. 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.

This public comment addresses legal scope, notice clarity, and preservation of objections. HHS describes the RFI as voluntary and nonbinding and may conduct public-health research. See 42 U.S.C. § 241(a); 21 U.S.C. §§ 360ii, 360jj. The solicitation alone is not necessarily ultra vires or reviewable final agency action. 1. CORRECT THE AUTHORITY CITATION. The notice says HHS is proceeding “under 21 CFR subpart J.” 91 Fed. Reg. 59792. The linked eCFR page resolves to 21 C.F.R. Chapter I, Subchapter A, Part 1, Subpart J (food-recordkeeping), not radiological health. The relevant radiological-health grouping is 21 C.F.R. Chapter I, Subchapter J. HHS should correct the link and identify the statutory and delegated authority actually relied on, including as applicable 42 U.S.C. § 241(a) and 21 U.S.C. §§ 360hh, 360ii, 360jj, and 360kk. This defect alone does not invalidate the voluntary RFI, which is not proposed rulemaking. 2. ENVIRONMENTAL HEALTH TRUST IS A LIMITED FCC REMAND, NOT AN HHS MANDATE OR SCIENTIFIC FINDING. In Environmental Health Trust v. FCC, 9 F.4th 893 (D.C. Cir. 2021), the court remanded the FCC’s 2019 order for a reasoned explanation on portable-device testing; children, long-term exposure, wireless ubiquity and technological developments; and environmental effects. The panel took “no position in the scientific debate”; it did not find injury below FCC limits, order new limits, vacate FCC rules, or direct HHS to issue this RFI. HHS’s authority must rest on HHS statutes. The FCC’s 2026 proceeding is limited by the FCC’s remand; that restriction does not automatically limit HHS’s independent research authority. 3. RESEARCH POWER IS NOT UNBOUNDED REGULATORY POWER. Sections 360ii and 360jj authorize an electronic-product radiation program, studies, information, and recommendations. Section 360kk permits electronic-product performance standards, but requires a regulation, APA procedures, statutory scientific and technical considerations, consultations, and committee consultation. This RFI cannot itself impose a standard or replace those procedures. Any ambient-exposure limit untethered to a defined electronic product, infrastructure operating rule, facility-siting restriction, or compulsory measure outside § 360kk must identify a separate affirmative statutory basis. The FCC does not displace all HHS authority; see 21 U.S.C. § 360hh note. 4. CLARIFY THE SCIENTIFIC AND LEGAL SCOPE. Ordinary 50/60-Hz fields from power systems are power-frequency/extremely-low-frequency fields, not RF. HHS should separately assess power-frequency fields; RF from handheld/body-worn devices; RF from fixed infrastructure; occupational exposures; and medical-device compatibility. Distinguish measured from modeled exposure, source proximity from dose, and association from causation. Question 6 asks about health effects “caused by current exposure limits.” HHS should clarify whether it means effects associated with exposure at or below current limits—not effects caused by a regulatory limit. 5. MAINTAIN EVIDENTIARY DISTINCTIONS. Self-selected symptom reports may generate hypotheses but do not alone establish causation or population risk. A synthesis should distinguish reports, diagnoses, biological effects, hazard classification, and quantified risk; address dosimetry, confounding, replication, study quality, null findings, and uncertainty. The notice cautions against submitting PII/PHI; it should not imply identifiable medical records are required. REQUEST. HHS should: (i) correct the citation/link and identify its legal basis; (ii) confirm that the RFI itself imposes no compulsory requirement and is not a substitute for future rulemaking; (iii) not characterize Environmental Health Trust as a scientific finding or delegation to HHS; (iv) clarify Question 6 and separate exposure categories; (v) identify materials materially relied upon in any future consequential assessment to the extent required by law; and (vi) allow supplemental comment if a correction materially changes the stated legal basis or scope. See full file attached

I am submitting this comment to share my personal experience and urge the Department of Health and Human Services to investigate the potential health effects of radiofrequency (RF) radiation and exposure to wireless infrastructure. Around 2020, I began experiencing tremors throughout my body while driving on highways. It took me some time to recognize a pattern. I noticed that these episodes seemed to occur when I was driving near cell phone towers. This raised serious concerns for me about whether my proximity to these towers might be contributing to the symptoms I was experiencing. My functional doctor told me that EMS sensitivity and fragrance sensitivity are common in people exposed to mold. Genetic tests show mitochondrial dysfunction. In 2024, my workplace relocated to a place directly across from a massive cell phone tower. After this relocation, I experienced debilitating symptoms, including intense headaches, difficulty sleeping, and an inability to concentrate effectively at work. I felt that my ability to think clearly, focus, and function as I normally would was being affected. These symptoms interfered with my daily activities and my ability to perform my job. Thankfully, my workplace's Human Resources Department was able to transfer me to another location because of the debilitating symptoms I reported in connection with working near the cell phone tower. I am grateful that my concerns were taken seriously enough for an accommodation to be made. I am sharing this experience because I believe that people who report potentially serious symptoms associated with environmental exposures deserve to be heard, taken seriously, and included in scientific research. I recognize that personal experience alone cannot establish the cause of a medical condition. However, I believe that these experiences warrant careful, independent investigation rather than dismissal without further examination. I urge HHS to support rigorous, independent research into the potential health effects of radiofrequency radiation, including possible neurological symptoms, headaches, sleep disturbances, and difficulties with concentration. Research should also examine individual differences in susceptibility, cumulative exposures, long-term effects, and potential impacts on children and other potentially vulnerable populations. People should not have to struggle to maintain their health and livelihoods without clear, evidence-based answers about the environmental exposures they encounter in their daily lives. I hope my experience will contribute to a broader effort to better understand these questions, protect public health, and ensure that future policies are guided by transparent, independent scientific evidence. Please review regulations to protect citizens and stop the permitting of cell phone towers a few meters away from residential homes, schools, and parks. It is scary the amount cell phones towers in the DFW area, especially in North Texas. Thank you for the opportunity to share my experience and concerns.

I am submitting this comment in response to the HHS request for information on electromagnetic fields (EMF), radiofrequency (RF) radiation, and exposure to wireless radiation. I am responding from the perspective of a patient and a concerned member of the public. I am a 37-year-old man who is athletic and leads a healthy lifestyle. I have been suffering from electromagnetic hypersensitivity for nearly 5 years and had no specific medical issues prior to that. I had to do my own research and go through a two-year medical odyssey before realizing that this condition was linked to artificial electromagnetic waves. It all began in November 2021. I had previously been suffering from tinnitus, ringing in the ears, sleep disturbances, and dizziness amid a state of generalized anxiety, which led to cognitive problems, short-term memory issues, difficulty concentrating, and intermittent headaches. At first, I started by taking a step back and slowing down my pace of life. Despite this, I suffered an episode in October 2025 that left me unable to engage in any public activities. From anxiety attacks to chronic inflammation, along with breathing difficulties and poor blood circulation, I felt a general weakness and imbalance affecting my muscles, nerves, joints, and so on. In addition, I was prescribed medications such as neuroleptics (hypnotic antihistamines) and benzodiazepines. Since I’m not a fan of synthetic chemicals, after three months I began a detox and an intensive regeneration regimen to break out of this downward spiral. The list of health issues associated with that period could go on and on… Today, after nearly nine months, I’ve almost returned to normal thanks to this rigorous approach: targeted supplementation, an organic diet, chemical and electromagnetic detoxification (eliminating the most impactful sources), remineralization, and alternative, natural, and holistic medicine. Having escaped from that hell—which could have led to a much more serious, irreversible illness or even death—I wanted to share my story as an average French citizen whose life was suddenly turned upside down, but who, as a result, has become much more aware of environmental issues. This has helped foster and strengthen my resilience. I support the active involvement of the Department of Health and Human Services (HHS) in examining the potential effects of wireless radiation on health and the environment. Issues related to human health should be addressed by federal agencies with the appropriate expertise in medicine, biology, epidemiology, and public health, and the testimonies of individuals and families who report being affected should be given the same consideration as scientific data. I urge HHS to carefully evaluate these experiences and the scientific data, identify gaps in current research, pay particular attention to children and other potentially vulnerable populations, and establish appropriate federal research priorities regarding wireless radiation and public health. Thank you for giving individuals and families the opportunity to be heard.