Research & federal duties

A Detailed analysis of hundreds of EMF studies with recommendations and current state of research with suggested paths forward for better understanding and exploration: Executive Overview: Many questions remain unanswered related to Non-Native EMF (nnEMF) and the biological effects that result from exposure. The USA is the sickest it has been in decades. Photos of people on US beaches in the 1970s compared to 2020s shows a drastic difference. Obesity is prevalent. Early research indicates health impacts are coming food sources and other aspects of the standard American lifestyle, however not all are being given the same level of review. nnEMF is one of the areas of research that has been neglected. Some research exists but is by no means comprehensive. Established studies show that heat from high-power radiofrequency energy is real, and Federal exposure limits exist because of it. Across whole populations, the best pooled studies show no overall rise in brain cancer as phone use became nearly universal, however the benchmark of testing positive for having brain cancer, or any cancer should not be the benchmark for a negative health impact. nnEMF has become so ubiquitous that it makes study challenging due to every day exposure, but this does not mean the research is not essential. Leaded gasoline was another universal exposure that was later deemed to be dangerous and phased out. Wi-Fi, 5G and other cellphone bands, Electric Vehicles, Home appliances with AC currents, bluetooth, are sources of exposure every day. If discoveries are made that these devices do impact human biology in a substantive manner, then considerations around how hospitals and healthcare institutions adopt and utilize these technologies in the patient journey should also be considered. A 1% or 5% or 10% impact on overall longevity (aging sooner) with impacts to memory, behavior, IQ, fertility, that may go unseen because cancer does not present would still be a major revelation. The net impact from a 5% increase in adult working years would have a massive benefit to US GDP, strengthening national security and economic security. Healthy people create less economic drag for tax payers as they age. The field of biological nnEMF impacts deserves to be studied in pursuit of the MAHA goals of overall wellness improvements for Americans. Studies indicate that nnEMF research has not yet been explored to completion. First, the National Toxicology Program, a research program, found "clear evidence" of a rare malignant heart tumor in male rats exposed to high whole-body levels of 2G/3G-type radiation. A 2025 review commissioned for the World Health Organization rated the animal evidence high certainty for that heart tumor and for malignant gliomas, while warning that moving from animal tumor results to human risk is unusually difficult. Second, and separately, a 2016 count found oxidative-stress effects reported in 93 of 100 low-intensity studies, but the 2024 WHO-commissioned systematic review rated the oxidative-stress literature very-low certainty: most of the studies were small and at high risk of bias. And no cohort has yet followed heavy phone users from a young start through a full adult lifetime. Three conclusions match the evidence: everyday exposure is low, a health effect at ordinary levels has not been established, and the missing studies are worth doing.

HHS should treat low-frequency magnetic emissions from television and monitor displays as an exposure in this docket, with children's programming first. Current radiofrequency limits are built on heating, specific absorption rate, and power density. They do not describe image-driven magnetic pulses in the band that overlaps the electroencephalogram. Laboratory work by W. Ross Adey and colleagues found frequency-specific changes in calcium binding in brain tissue at field levels that do not heat tissue. U.S. patents to Hendricus G. Loos claim that pulsed images on monitors and television tubes can excite sensory resonances near 1/2 Hz and 2.4 Hz. An observational analysis of the soundtrack of *Meet the Teletubbies* found intermittent energy below 20 Hz, strongest near minutes 51–54. That analysis does not establish a neurological effect or an intent. It does establish a concrete children's-media case. Speaker limits on airborne infrasound do not answer the magnetic-field question. I ask HHS, with FDA and in coordination with the FCC, to require measurement and disclosure of these emissions, to test them under realistic viewing, and to review whether subliminal-content policy covers the physical display. The source is the television or monitor and its associated electronics, driven by ordinary program material. The population I ask HHS to put first is children watching commercial programming, including *Meet the Teletubbies*. The quantity of concern is the extremely-low-frequency magnetic field produced by the display process: image-intensity changes, power circuitry, and, on older tubes, deflection systems. A common objection is that television speakers cannot produce meaningful airborne sound below 20 Hz. That objection answers a different question. Magnetic fields pass through tissue, induce electric fields in the body, and do not depend on the speaker's acoustic cutoff. An observational study of the full program *Meet the Teletubbies* (running time 1:01:43) built an ELF spectrogram of the soundtrack from 0 to 100 Hz and aligned it with the picture. Magnitude below 50 Hz and below 20 Hz was intermittent and at times dense. The strongest sustained cluster below 20 Hz fell near minutes 51–54, during insert and outdoor segments. The study states that these findings do not by themselves establish intent or a neurological effect. They document a children's-program case that should be followed with controlled measurement of the magnetic field at the set, not only of the audio file. Report: https://esui.cc/detail.php?slug=case-observations-sub-audible-elf-signatures-in-meet-the-teletubbies Exposure of this kind is repeated, often daily, during a period of high neural plasticity. A child cannot detect a magnetic pulse and cannot opt out of it. Parents are not given a measurement. I am not submitting a personal symptom diary or any personal health information for this comment.

I submit this comment as healthcare professional Question 14 What scientific evidence exists regarding potential adverse environmental effects associated with RF radiation? Observation and documentation of trees in the vicinity of over 1,500 mobile phone base stations (2005 to 2026) and studies (2016, 2021) suggest a causal relationship between RF radiation and tree damage. The reason for the tree observation: After the Bamberg Appeal was published in 2004 – in which 130 medical doctors warned against expanding mobile phone networks – many residents living near mobile phone base stations contacted the initiative for help with health issues. We visited affected individuals at home, documented their symptoms, and took RF radiation measurements. We learned that many people became sick far below the legal limits. We urged all responsible authorities to start health investigations of the long-term-exposed residents. One example (see attached): https://mdsafetech.org/wp-content/uploads/2021/04/cell-tower-letter-2005-dr.-cornelia-waldmann-selsam-to-german-state-chancellery-.pdf But the desperately needed investigations have not been carried out. During our visits, the affected residents showed us that changes and damage to the trees started around the same time as their symptoms appeared. People and trees got sick at the same time! The tree damage was visible. Because we hoped to be able to show quickly the causal relationship between RF radiation and tree damage we started to document trees around mobile phone base stations. Please see the whole comment attached. Dr. med. Cornelia Waldmann-Selsam, Germany

Online businesses run websites selling fear of EMF. Googling “electrosmog” reveals many such revenue generators, all of which make baseless claims of alleged health effects and feature a prominent “DONATE” button. They do real harm by distracting from actual dangers (e.g., global warming). These sites most often focus on “opinion” studies with no dosimetry (no measurement of actual EMF exposure, just self-reported recollection of subjective proximity to devices) and no clinical assessment of very common symptoms they attribute without evidence to EMF. Claims of health effects with no actual dose measurements or clinical assessment is not credible. Some people believe they are “hypersensitive” to EMFs, but there’s no evidence to back it up; Rubin, G. James; Hillert, Lena; Nieto-Hernandez, Rosa; van Rongen, Eric; Oftedal, Gunnhild (December 2011). "Do people with idiopathic environmental intolerance attributed to electromagnetic fields display physiological effects when exposed to electromagnetic fields?". Bioelectromagnetics. 32 (8): 593–609). Bioeffects from exposure to very high levels of microwave radiation are well understood (tissue heats up – basis of microwave cooking). Levels to which members of the public are exposed are far too low to have any effects. The recognized exposure limits adequately protect the public. Actual exposures are well below the exposure limits. See e.g., Bushberg JT and Butcher MJ. Measurement of ambient millimeter wave exposures levels around small base stations (January 2025). Health Physics 128(2):1-7. Those running “electrosmog” sites point to the “NTP study” as a scientific basis of their claims that cell phone radiation causes cancer. They refer to the 2018 National Toxicology Program Report on mice [https://ntp.niehs.nih.gov/go/tr596] and rats [https://ntp.niehs.nih.gov/go/tr595] exposed to RF used by cell phones. Rodents were exposed to levels near the public exposure limits for 9 hours a day, 7 days a week, for 2 years. These studies showed no statistically significant effects on female mice, male mice, or female rats, and a HUGE increase in life span for the exposed male rats. Thermal effects can explain the significant effects in the rats. See e.g., Kuhne J, Schmidt JA, Geschwentner D, Pophof B, Ziegelberger G. Thermoregulatory Stress as Potential Mediating Factor in the NTP Cell Phone Tumor Study. Bioelectromagnetics. 2020 Sep;41(6):471-479 [https://pmc.ncbi.nlm.nih.gov/articles/PMC7522680/]. The NTP study also found a small number of rare heart tumors in the warmed male rats, but not in the mice or female rats. The NTP researchers did not control for warming the male rats (i.e., the controls were not heated the way the exposed rats were), so the most obvious explanation for the tiny number of excess heart tumors is that the exposed male rats heated up more than the mice or female rats. The study’s own peer reviewers noted “…panelists agreed that information to specifically rule out a thermal or non-thermal effect was insufficient.” (NTP TR595 p. 420). A review of the NTP study by internationally-recognized scientific experts on RF effects noted “…substantial limitations preclude conclusions being drawn concerning RF EMFs and carcinogenesis” and “…a preponderance of reported effects in the male rats, whose body core temperature would have increased more than either the female rats or either male or female mice (due to their smaller surface area-to-mass ratio), which would have put them under greater metabolic stress due to their greater thermoregulatory requirements.” ICNIRP Note on recent animal carcinogenesis studies (2018) [https://www.icnirp.org/cms/upload/publications/ICNIRPnote2018.pdf] John Bucher, the lead writer on the NTP report, noted that he is not changing his cellphone use or asking his family to, and that the findings of the rare nerve-tissue tumor found in the hearts of male rats does not mean humans should be worried. [https://learningenglish.voanews.com/a/health-lifestyles-researchers-say-no-cancer-from-cellphone-use/4244699.html] Far from being clear evidence, the NTP study shows no effect on mice and most significantly a huge increase in male rat lifespan. The tiny number of heart tumors in the exposed rats could most rationally be explained by tissue heating. Electrosmog sites claim cell phones cause cancer and point to the International Agency for Research on Cancer (IARC) 2011 classification of radiofrequency as “possibly carcinogenic” [https://www.iarc.who.int/wp-content/uploads/2018/07/pr208_E.pdf], without mentioning that IARC’s “possibly” category has the lowest certainty of any IARC rating (below “probable” and “known” carcinogen categories), and that the “possible” rating includes things like aloe vera and ginkgo biloba. See attached file for full response

Tissue studies have already been concluded but if further detail studies would be conducted to understand functional parts per- tissue then a fuller assesment could be established. Concurrently higher frequencies above gigahertz levels will cause membrane collage to loosen and become less dense making tissues more suseptable to hemorraging, deterioation or abraision from less strain or stress in inter operability of the domains of different tissues. Higher the frequency becomes the more disfunctional the capability of the tissue to be a more durable collegiate structure in order to membrane it's coinciding structure to itself. That is all concluded according to the fetal developmental studies in Stanford (coordinates in brain tissue studies). I recommend to encourage further studies further internally to the individual tissue units itself for fuller integralatical inference in the components of difference according to the nominal environmental factors of hundreds of different tissue and the biological factory gland tissues and interworking symbiosis of workers such as red and white blood, macrophages, immune workers and their underlying tissue structures as well ect.

There needs to be a database containing location and activation date of 5g nodes down to the neighborhood pole level. Without that, it's impossible to correlate sudden onset of novel symptoms to activation of a local small cell node.

Wireless radiation gives me headaches and tinnitus, and I would like their detrimental effects looked into further and better regulated. Thank you.

Esposto a radiazioni da emittenti radiotv soffro di insonnia da decenni e come sondaggista ho verificato che la maggior parte degli abitanti di Volturino (FG) accusa lo stesso problema, con conseguenze sulla pressione arteriosa e aspettativa di vita più bassa del 60% rispetto a 2 paesi vicini più distanti a 2 km. Se l'insonnia è causa di caduta delle difese immunitarie è evidente che le persone si ammalano prima e muoiono prima. Ed ecco testimoniato il risultato della mortalità prematura a Volturino. Mortalità prematura a Volturino-FG esposta a radiazioni elettromagnetiche tra 2-6 V/m propagate da oltre 200 antenne radiotv rispetto a due comuni vicini, più distanti dalle antenne. anni 1990 - 2025 ALBERONA + MOTTA M.NO ab 1531 Anni - Decessi 40/49 7 50/60 20 61/70 67 tot. 94 VOLTURINO ab 1590 40/49 24 +243% 50/60 36 +80% 61/70 90 +34% tot.150 (+60%) Antonio Gagliardi presidente e sondaggista Ipsos-Doxa

Please follow the many studies, including those by the NIH, about the harm and DNA damage that wireless radiation, RF radiation from Smart Meters, and EMFs can cause especially to children, when making decisions about how these are implemented and often forced on citizens. In my state of Massachusetts our utility companies are able to charge us unrestricted fees if we choose to not have a dangerous Smart Meter installed. This is wrong. We should not be charged several hundred dollars per year to opt out of dangerous radiation. Thank-you.

Public Comment on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Exposure Docket No. HHS-OASH-2026-0397 I urge the Department of Health and Human Services (HHS) to support independent research into potential health effects of long-term, real-world electromagnetic field (EMF) and radiofrequency (RF) exposure, take reports of symptoms seriously, and identify practical ways to reduce unnecessary exposure while scientific questions remain unresolved. Personal Experience and Residential Exposure I live in San Mateo, California, within approximately 500 feet of two Crown Castle wireless facilities. The City of San Mateo Public Works Department confirmed that the facility at 239–249 Elm Street (permit WC-2023-000082) was issued a permit on May 19, 2023, and the facility at 200 N. San Mateo Drive, on Monte Diablo Avenue (permit WC-2023-000127), was issued a permit on June 16, 2023. Both facilities completed construction, passed City inspection, and received final signoff. I noticed increased sleep problems, headaches, and physical agitation when the facilities were energized. By physical agitation, I do not mean simply worry or anxious thoughts. I mean feeling physically unsettled, keyed up, and unable to fully relax. I have also noticed less physical agitation when I am away from home. I cannot establish that RF exposure caused these symptoms, and my experience alone cannot prove causation. However, the timing of these changes and the difference I notice when away from home concern me. My home should be a place where I can rest comfortably, yet I have become concerned about how I feel in my own residential environment. I cannot readily control the presence or operation of nearby wireless infrastructure. I share this experience not as proof of causation, but because firsthand reports can help identify questions that warrant scientific investigation. Research and Public Health HHS should prioritize independent, rigorous research into potential non-cancer effects of long-term, repeated, real-world RF and EMF exposure. Research should examine possible effects on sleep, headaches, neurological and other physiological functions, and overall well-being. It should consider prolonged exposure under everyday conditions, not just short-term exposure scenarios. HHS should transparently assess the strengths and limitations of existing studies, including conflicting findings, identify gaps in the evidence, and determine what additional research is needed. Research should investigate possible biological mechanisms and whether certain populations, including children, may be more vulnerable. People reporting symptoms they associate with RF or EMF exposure should neither be dismissed because causation is uncertain nor assumed to have established causation. Researchers should consider symptom patterns, exposure circumstances, timing, changes when circumstances change, and other possible contributing factors. These observations can help generate testable hypotheses. Medical Evaluation, Disability, and Accessibility HHS should distinguish between recognizing symptoms and functional limitations, investigating possible medical causes, and addressing accessibility barriers. These are related but distinct issues. An approach focused only on accommodating functional limitations risks leaving questions about possible biological or medical causes unanswered. People whose symptoms affect sleep, daily activities, or quality of life deserve both practical consideration and serious scientific investigation. Recommendations I respectfully ask HHS to: Support independent research into potential non-cancer effects of long-term, real-world EMF and RF exposure. Identify research gaps and prioritize investigation of sleep, neurological and physiological effects, and potentially vulnerable populations. Develop balanced ways to document and investigate reported symptoms without assuming or dismissing causation. Evaluate practical ways to reduce unnecessary exposure in homes, schools, and communities, including wired alternatives where feasible. Communicate clearly about established findings, conflicting evidence, and remaining uncertainties. Ensure that investigating possible medical causes is not displaced by an approach focused solely on accessibility or functional impairment. My purpose is to ensure that the experiences of people who report health concerns associated with wireless infrastructure are considered alongside the broader scientific evidence. I urge HHS to conduct a thorough, independent, and transparent assessment of potential health effects, identify research priorities, and recommend proportionate measures to protect public health while uncertainties remain.