Research & federal duties

I previously send in two comments on behalf of boardmembers of The Danish EHS Association (mv7-po47-pre3 and mv7-pbqa-zi50). Neither one of the two comments have yet been made publicly available on your website. I have now deleted personally identifiable information in the edited comment below, if that was the reason for it not being posted. If possible, you are welcome to post the comment below: Comment from Danish EHS Association: The information in the comment below is based on personal experiences of boardmembers and boardmembers contact with members of the Association. The Danish EHS Association represents people who experience adverse health effects from a wide variety of EMF and RF-EMF emitting sources. The association currently have around 500 members. Adverse health effects (insomnia, heart palpitations, headache, migraine, restlessness in the body, fatigue, cognitive issues (brain fog, memory issues, etc.), burning skin, nausea, dizziness, joint pain, pain in organs, tinnitus, stress and more) are often reported by members to be related to: - Cell towers - Wi-Fi routers and devices - Bluetooth devices - Cellphones and smartphones - Wireless speakers - Smart meters - High-voltage cables in the ground - PV solar inverters - Robotic lawnmowers with active boundary wires - Induction and microwave cooking - EV charging stations and EV´s - Dirty electricity - Stray currents - "Regular" 50 Hz electrical fields or EMF from wires, household appliances, and electronics such as TVs, stereos, computers, etc. (some members turn everything off at night, or do not have electricity in their homes at all) Members also experience specific settings as being particularly often related to adverse health effects, such as: - Being in crowds in general: cinemas, concerts, family gatherings and more (many people = many cellphones = high exposure) - Using public transport such as buses, trains and boats (a closed metal box + many cellphones = high exposure) - Being in hospitals (WiFi, Bluetooth, DECT phone systems, Wireless medical equipment and many people) - Being in airports (many people with cellphones, wearables, etc. + radar) - Flying - Beaches and harbours with radar nearby Recommendations: - Inform general practitioners that they should register and notify the HHS (e.g. via an online form) when a patient reports adverse health effects related to EMF or RF-EMF exposure. To our knowledge, nothing is being systematically reported or registered when patients discuss these issues with their practitioner. We are sometimes contacted by affected individuals because nurses at clinics recommend contacting us. - Initiate a survey among general practitioners to provide an estimate of how often patients report having EMF or RF-EMF-related issues. - Set up an online form in which people who personally experience adverse health effects related to EMF or RF-EMF exposure can state which symptoms (headache, insomnia, dizziness, etc.) they experience and in which settings (scrolling on a smartphone, staying somewhere close to a cell tower, traveling by bus/train, going to a concert, etc.). - Make general information about how to lower exposure when using a cellphone widely available to the public. On the organisation website (ehsf.dk) the attached brochure with precautionary recommendations when using a cellphone is made publicly available. Thank you for providing individuals, families, health care providers, researchers and scientists an opportunity to be heard on this critical public health issue. EHS-Foreningen - Danish EHS Association ____________________________________________________

I urge HHS to prioritize independent research into the potential long-term health effects of radiofrequency radiation and to transparently evaluate whether current exposure limits adequately protect public health. My concerns include possible cancer risks, exposure beginning in childhood and continuing throughout life, and whether research adequately reflects today’s devices and exposure patterns. There are scientific findings that warrant follow-up. The National Toxicology Program’s studies found clear evidence of malignant heart schwannomas and some evidence of malignant brain gliomas in male rats exposed to radiofrequency radiation. These were high-exposure animal studies using signals associated with 2G and 3G technology; they do not establish that everyday wireless exposure or 5G causes cancer in humans. Nevertheless, they deserve careful investigation. Human research also needs to be represented accurately. The large COSMOS cohort study did not find increased brain-tumor risk among people with the greatest cumulative mobile-phone call time. Reassuring findings should inform policy alongside animal findings and remaining uncertainties. I ask HHS to: • Fund independent, long-term research, including studies of children, contemporary wireless technologies, and well-characterized exposure levels. • Evaluate cancer, reproductive and developmental outcomes, sleep, and neurological symptoms, clearly distinguishing established effects from preliminary findings. • Review exposure standards transparently and explain how they address long-term exposure and potentially vulnerable populations. • Require disclosure of research funding and conflicts of interest. • Offer practical, proportionate guidance for people who wish to reduce exposure, including increasing distance from phones during calls. People reporting symptoms they associate with electromagnetic exposure deserve respectful clinical attention and rigorous investigation without assuming the cause in advance. The public deserves clear information about what is known, what remains uncertain, and what evidence would justify stronger protections.

Response from an individual in Denmark who has been severely and chronically injured by RF/EMF exposure after mobile phone base stations and microwave links were installed 10–12 metres from my home. I am an IT professional with more than 40 years of experience, a public lecturer, and the developer of a GIS system that maps base stations, measured RF power density (mW/m²) and disease data in Denmark. The attached document answers RFI questions 2–18, with question numbers marked in [brackets]. It includes my personal case (Q3), observations from 53 other affected people (Q4), and research-documented effect levels from 0.001 mW/m² up to cancer from 0.7 mW/m², all far below the FCC/ICNIRP limits of 4,500–10,000 mW/m² (Q6, Q12). It also covers a comparison of international exposure standards and protective laws (Q5), documented conflicts of interest and court rulings (Turin Court of Appeal; EHT v. FCC, D.C. Cir. 2021), surveillance proposals (Q10), sensitive populations (Q11), environmental effects (Q14), proximity of infrastructure (Q15) and policy recommendations. Appendices contain 33 studies with measured power density, 93 documented sources and 142 tagged articles, all with active hyperlinks. Main requests: an official diagnosis code (e.g. "Illness caused by microwave radiation"); biologically based power-density limits in addition to SAR; minimum distances between masts and homes and schools (as in Hawaii County, 600 ft); radiation-free zones and restitution homes for the injured; and independent, industry-free research.

inventhealth.care respectfully request The Department of HHS to extend the comment deadline by 30 days. The RFI requests evidence across distinct scientific, technical, public-health, and regulatory issues, including exposure measurement, existing safety standards, vulnerable populations, environmental effects, cumulative exposure, and federal research priorities. It expressly invites supporting studies, datasets, technical reports, and regulatory analyses. The current 30-day period is insufficient to permit interested parties to assemble and verify such materials and submit a technically grounded response. Thirty additional calendar days would permit respondents to verify sources, assess the relevance and limitations of technical evidence, consult appropriate subject-matter experts, and submit better-supported information. The requested extension would provide 60 calendar days in total from publication of the RFI, while leaving the Department free to continue reviewing materials already received. An extension would improve the quality of the record available to the Department before it uses these submissions to inform future recommendations or policies. The request is limited to 30 additional days and does not seek to delay the Department's review of comments already received. Respectfully Submitted, inventhealth.care

Thank you for the opportunity to comment on this very important topic! I have been very concerned about the increasing amount and strength of EMF from all sources, especially the ones that the general population does not have an option to opt out of, like smart meters, cell phone towers, 5G, etc. There are numerous health studies that I have heard about from Europe, where scientists have been studying the effect of man-made radiation on people, and the results are catastrophic. I am especially concerned about children. I myself am sensitive to radiation, and depending on the strength and length of time of the exposure, I get headaches and nose bleeds. I also have a child who had a health issue that is very likely to be at least partially caused by radiation damage, but definitely has been effected negatively by exposure. My child's symptoms range from flu like symptoms to bone and joint pain. I would love if the negative health effect of radiation exposure at any level would be more seriously investigated, and European research and limits would be studied and utilized in the United States as well. Sincerely, a concerned mother and citizen

I am extremely concerned about the rapid expansion of wireless towers near our homes, neighborhoods, and schools. These towers are being installed everywhere, often without families having any meaningful say in how close they are placed to where we live and raise our children. This recently became very personal for me when I learned that a new tower is going up approximately 0.3 miles from my home… my family’s safe space. I am angry and deeply upset that infrastructure transmitting RF radiation can be placed this close to homes without stronger protections for the families who live there. I am especially concerned about children. They spend hours every day at schools and daycares and potentially have an entire lifetime of wireless exposure ahead of them. We need more independent research into long-term and RF exposure, especially in children. There should absolutely be mandatory minimum setbacks between wireless towers and homes, schools, and daycares. I believe they should be at least one mile away or more! Every tower should also be independently tested after installation and regularly thereafter to determine how much RF is actually reaching nearby homes and schools. Those measurements should be publicly available so families know what levels are reaching the places where they spend their lives. Technology is advancing quickly, and our research and protections need to keep up. Parents and homeowners deserve transparency, meaningful community input, independent testing, and the ability to feel safe in their own homes. Please put the health and well-being of our children and communities first.

Thank you for this opportunity to comment. I'm an attorney and I'll get straight to the point. As you may know, in the US, personal‑injury suits against telecom companies for harm from RF/EMF radiation have a very low success rate, and there is no well‑established "winning" strategy. The two walls that defeat most of these cases are (1) proving medical causation — courts require you to show your specific illness was caused by the radiation, and the US scientific record has not met that bar — and (2) federal preemption under Section 704 of the 1996 Telecommunications Act, which bars local/state regulation of towers based on health risk and has been used to preempt state tort claims. Government action is long overdue. There is much the HHS can do to help electromagnetic radiation (EMR) victims in the United States. To wit: 1. Upgrade the NTP carcinogen classification (biggest single lever) The National Toxicology Program (part of HHS) already found in 2018 that RF radiation is "reasonably anticipated to be a carcinogen" — the weakest tier in the Report on Carcinogens, based on a 10-year, ~3,000-animal rat study. If HHS upgraded this to "known" human carcinogen, it would: Give plaintiffs a federally endorsed causal finding to cite at summary judgment, directly attacking the #1 barrier (causation) Support failure-to-warn claims: if the government classified the hazard, defendants can't argue they "didn't know" Be hard for courts to ignore — federal agency findings carry substantial evidentiary weight 2. Fund and publish definitive human epidemiology NIEHS (NIH) could run or commission a large prospective cohort study of RF exposure and specific health outcomes. A published HHS finding of a dose-response relationship would be the strongest possible causation evidence. The current NIEHS position — "the probability that EMF exposure is truly a health hazard is currently small" — is what defense lawyers cite to kill cases. 3. FDA: set lower performance standards + require warnings FDA has authority under 21 CFR Part 1030 over RF-emitting electronic products. It could: Lower MPE limits below current FCC levels (which are based on thermal effects only, not non-thermal) Require warning labels on devices — this is critical because it converts a failure-to-warn theory from speculative to straightforward Require premarket chronic-exposure safety testing for new wireless technologies 4. CDC/ATSDR: issue a formal health advisory A CDC advisory stating that RF-EMF exposure is associated with specific health conditions would create a recognized standard of care that defendants deviated from. It would also give plaintiffs' medical experts a federal source to cite when opining on causation. 5. NIOSH: set occupational exposure limits NIOSH could issue recommended exposure limits for workers near towers and in wireless-intensive jobs. While advisory (OSHA enforces), these limits create a benchmark for what "reasonable" exposure looks like, supporting negligence claims. 6. Medical education and clinical guidelines HHS could direct that: EMF exposure history be taken as part of standard medical intake Clinical guidelines be developed for evaluating patients with RF-sensitivity symptoms Medical school curricula include EMF health effects This helps plaintiffs document their injury in a way courts currently find unconvincing (many plaintiffs' symptoms are dismissed as not medically recognized). The irony to note: Setting specific federal exposure limits could backfire by strengthening the implied preemption defense (courts argue that where the FCC has set a standard, state tort claims are displaced). The sweet spot for HHS would be to issue findings of harm and hazard classification without creating a new, detailed regulatory scheme that defendants can point to as "the FCC already regulated this." Bottom line: The single highest-impact action is upgrading the NTP carcinogen classification combined with FDA-mandated warning labels. Together, they attack both causation and failure-to-warn simultaneously, and they're within HHS's existing statutory authority. I have further thoughts regarding actions the HHS could take and legal strategy. If you'd like to follow up and continue the coversation please email emrlegal@protonmail.com

The US has known for at least since 1971 about the bioeffects of RF wireless radiation exposures from the Naval Medical Research Institute Study titled, “Bibliography of Reported Biological Phenomena and Clinical Manifestations Attributed to Microwave and Radio-Frequency Radiation.” The study listed pages of symptoms resulting from RF exposures that were compiled from over 2,000 global citations on non-ionizing electromagnetic fields proving non-thermal injuries are a common side effect. Many independent studies have been done since then with similar results. There is nothing new under the sun to continue the wait to decide if RF radiation exposures can be harmful. Issue a surgeon general letter warning about RF radiation exposures being a possible carcinogen or harmful to your health with overuse or improper use of any digital device, especially with digital screen time and how it can damage your eyesight. Require labeling to display a similar message on these digital devices just like cigarettes and nicotine. Technology can be beneficial, if it is built, used and taught to be used in a safe and responsible manner. However, overdensification of neighborhoods with 175’ cell towers for Internet of Things, no wired alternative to smart meters and turning vehicles into mobile base stations is going in the wrong direction, consumes too much energy, generates too much electropollution, and makes healthy people chronically ill and/or disabled unnecessarily.

I minimize my exposure to wireless radiation because if I don't, I get debilitating headaches. My house is hard-wired to ethernet, but last year my city (Longmont CO) installed smart meters; the "opt-out" was still a smart meter creating dirty electricity. There are 4 smart meters clustered in my neighbor's yard, very close to my bedroom. I would wake up with a headache daily. I purchased a "Blushield" device to help mitigate the effect of the EMFs and that helped with my headaches. It is unbelievable that we don't have a choice about the enormous amount of EMF exposure and many people are suffering greatly. I am lucky that my symptoms are manageable, but it necessitates limiting my exposure; I cannot be in large public gatherings where everyone has their cellphone on (i.e. sporting events, lectures, concerts, etc); the last time I tried this I experienced vertigo, lightheadedness, dizziness, and nausea. PLEASE STUDY THE EFFECTS OF EMFS ON PEOPLE, especially children, as well as plants, insects (bees), and animals, before we continue into next generation 6G, 7G.

Carcinogenicity of radio-frequency radiation in the occupational and military setting Prepared jointly by: Elihu Richter, ORCID 0000-0003-3218-7765 Michael Peleg, ORCID 0000-0002-7520-8741 peleg.michael@gmail.com A slightly longer and better formated version is attached as a PDF file. We took part in research reported in the papers in the reference list below. The research provides a strong indication of carcinogenicity of Radio-Frequency Radiation (RFR). The research subjects: Groups of young cancer patients previously exposed to RFR in the military and occupational setting. The exposure: The exposure was from radio communication transmitters, from radar and from electronic warfare. The exposure was repetitive, typically over a year or more. The Israeli Defense Forces exposure levels are guided by the occupational standards set by ICNIRP which allow average power higher by a factor of 5 relative to the ICNIRP recommendations for the general population. Importantly, those standards almost do not limit the peak power of radar pulses provided the average power is within the limits. Power concentrated in strong pulses may be more bioactive as explained in the references. Research methods: The primary information was from the patients; most of them were trained operators, technicians and engineers. For small subgroups of patients, we knew the size of the whole exposed population and thus we were able to estimate cancer Risk Ratios (RR) relative to the general population. For most of the patients the size of the exposed population was not available. Therefore we examined also cancer characteristics since cancer characteristics which are very different from those of cancer patients from the general population indicate an additional carcinogen. We examined Percentage Frequencies (PF) of cancer types and proportion of cancer patients suffering from multiple primaries. The main results: The RRs for cancer in the small subgroups were very high, e.g. 8, and statistically significant. The PF of hematolymphoid cancers was about twice the value in the general population and statistically significant. The two results above are consistent with research results of other research groups in different countries, see table 7 and figure 4 in reference (4) and section 3.4 in reference (3). Proportion of patients suffering multiple primaries as reported in reference (3) was higher by a factor of 4.5 than the value expected in the general population. This indicates a potent carcinogen. Such a dramatic rise in multiple primaries was not observed in our next work (4). The latencies in (4) may not have been long enough to develop multiple primaries. Our recommendations: Radio Frequency Radiation (RFR) should be recognized as a human carcinogen. Limit human exposure to low levels, for example 1μW/cm2 average level and 5μW/cm2 peak pulse level. The suggested level is in the range of known community levels. In the military and the occupational settings, reduce exposures to the lowest possible level, striving to the specifications above. Use Faraday barriers to reduce exposures at the source and personal level and any other means required. Document individual exposures and provide this information to all highly exposed humans. Provide the exposed humans with long-term periodical medical surveillance for cancer and for other health effects. Perform epidemiological cancer research on all known personnel exposed to significant levels of RFR. Please see the detailed recommendation section in reference (4). Acknowledgement: We thank the Environmental Health Trust for organizing, in Israel, two international conferences on RFR and EMF health aspects which enabled very useful information exchange among the participants. References: (1) Richter E, Berman T, Ben-Michael E, Laster R, Westin JB. "Cancer in radar technicians exposed to radiofrequency/microwave radiation: sentinel episodes." Int J Occup Environ Health. 2000 Jul-Sep;6(3):187-93. doi: 10.1179/oeh.2000.6.3.187. PMID: 10926722. (2) M. Peleg: "Report on a Cancer Cluster in an Antenna Ranges Facility", International IEEE Conference on Microwaves, Communications, Antennas and Electronic Systems, IEEE COMCAS 2009, Tel Aviv, 9-11 November 2009. (3) Michael Peleg, Or Nativ, Elihu D. Richter: Radio frequency radiation related cancer: assessing causation in the occupational/military setting, Environmental Research, Volume 163, May 2018, Pages 123-133, ISSN 0013-9351 (4) M. Peleg, E. M. Berry, M. Deitch, O. Nativ, E. Richter: On radar and radio exposure and cancer in the military setting, Environmental Research, Volume 216, Part 2, Jan 2023, 114610, ISSN 0013-9351 (5) Peleg M, Berry E M, Deitch M, Nativ O, Richter E. 'Carcinogenicity of Radio-Frequency Radiation: Similarities and Differences Between Outcomes of Two Studies'. Med Discoveries. 2025; 4(7): 1267