Exposure limits & oversight

This comment is submitted by Cindy Sage, Co-Editor, BioInitiative Reports 2007 and 2012 (and Updates) on behalf of the BioInitiative Working Group. The BioInitiative Report link is www.bioinitiative.org and is incorporated by reference due to its file size. The BioInitiative Report is an internationally acclaimed scientific and public health report on potential health risks of electromagnetic fields and radiofrequency/microwave radiation. In 2007, the BioInitiative Working Group released a 650-page report citing more than 2000 studies that document health effects of EMFs from all sources. The BioInitiative 2012 Report has been prepared by 29 authors from ten countries*, ten holding medical degrees (MDs), 21 PhDs, and three MsC, MA or MPHs. Among the authors are three former Presidents of the Bioelectromagnetics Society and five full members of BEMS. One distinguished author is the Chair of the Russian National Committee on Non-Ionizing Radiation. Another is a Senior Advisor to the European Environmental Agency. Membership in the BioInitiative Working Group includes Sweden (6), USA (10), India (2), Italy (2), Greece (2), Canada (2), Denmark (1), Austria (2), Slovak Republic (1), Russia (1) The BioInitiative Report was produced for publication to the broadest possible audience, hence placed on the Web and offered for free. Much of the BioInitiative Report content, including updated chapters and new chapters was later published in a special two-volume issue of the journal Pathophysiology to verify the quality of its science (August 2009, Pathophysiology 16: 2,3). In 2013, the BioInitiative 2012 chapter on Autism and EMF was also published in two parts, in the peer-reviewed journal Pathophysiology. The BioInitiative 2012 Report concludes that the evidence for health risks from electromagnetic fields (EMFs) generated by wireless technologies have substantially increased since 2007. A review of over 1800 new scientific studies indicates current guidelines are inadequate to protect the public from chronic exposure to very low-intensity (non-thermal) electromagnetic fields and radiofrequency radiation (EMF and RFR). In twenty-four technical chapters, the BioInitiative 2012 Report discusses the content and implications of about 1800 new studies since 2007. Overall, these new studies report abnormal gene transcription (Section 5); genotoxicity and single-and double-strand DNA damage (Section 6); stress proteins because of the fractal RF-antenna like nature of DNA (Section 7); chromatin condensation and loss of DNA repair capacity in human stem cells (Sections 6 and 15); reduction in free-radical scavengers - particularly melatonin (Sections 5, 9, 13, 14, 15, 16 and 17); neurotoxicity in humans and animals (Section 9); carcinogenicity in humans (Sections 11, 12, 13, 14, 15, 16 and 17); serious impacts on human and animal sperm morphology and function (Section 18); effects on the fetus, neonate and offspring (Section 18 and 19); effects on brain and cranial bone development in the offspring of animals that are exposed to cell phone radiation during pregnancy (Sections 5 and 18); and findings in autism spectrum disorders consistent with EMF/RFR exposure effects. Global precautionary actions that have been taken in countries around the world, and recommended by medical and research experts are documented in Section 22. Use of the Precautionary Principal and its relevance are presented in Section 23. Key scientific evidence and public health policy recommendations are in Section 24. Attached file: Pathophysiology Full Edition.pdf (August 2009, Pathophysiology 16: 2,3)

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 concerned member of the public. Besides the fact that a good amount of research I have seen shows that current allowable levels of RF and EMFs from devices may not be safe, I have heard stories from people about how they are negatively affected by today's tech devices and I believe their voices need to be heard and their stories investigated. I know of people getting fatal cancers after living near cell towers. I have heard people say they feel sick when they around routers, cell phones and other devices, and especially cell towers. I have heard people say they get headaches, heart palpitations, dizziness, insomnia and other symptoms from exposure to these things, but that the symptoms go away when they get away from them. I understand every BODY is different, and what affects one person one way may not affect someone else the same way (up to a certain threshold at least). However, some people serve as canaries in the coal mine--their experiences warning the rest of us that something might be more harmful to everyone than we realize. With Alzheimer's and especially cancer on the rise, I think the FCC and HHS have a duty to do a deep dive into these people's stories and make sure the RFs and EMFs we are all exposed to daily, everywhere, are not harming people. And if they find that they are, to do something about it immediately for the safety of the general public. To do otherwise would be a dereliction of duty and gross betrayal of the American people. Thank you for your time and consideration

I am submitting this comment as a consumer concerned about long-term exposure to wireless radiation from phones, Wi-Fi routers, cell towers, and other connected devices. I urge HHS to conduct a thorough, independent review of whether current exposure limits adequately protect public health. This review needs to consider those most heavily exposed and should examine potential effects beyond tissue heating, including evidence concerning cancer, reproductive health, and children’s development. Please prioritize research that reflects how people actually encounter wireless radiation: repeated exposure over many years, often from multiple sources and devices used close to the body. Assessments should consider signal strength, pulse patterns, duration, and combined exposure. Please consider Melnick and Moskowitz’s 2026 analysis of animal data, which argues that existing exposure limits may inadequately protect against cancer and reproductive harm (https://doi.org/10.1186/s12940-026-01288-6). I also ask HHS to evaluate Lai and Levitt’s review of exposure intensity, duration, and signal modulation (https://doi.org/10.1080/15368378.2022.2065683), and Scarato’s review of US regulatory gaps and proposed reforms (https://doi.org/10.3389/fpubh.2025.1677583). These papers warrant careful consideration alongside the broader evidence, including studies that have not found adverse effects. I ask HHS to: •Assess whether additional protections are needed for children, pregnant women, and other potentially vulnerable groups. •Support long-term research with safeguards against industry conflicts of interest. •Provide clear information about exposure and practical ways to reduce it, including wired alternatives in homes and schools. •Recommend updated standards wherever the evidence shows that existing limits are insufficient. Consumers should not have to navigate these questions alone. Please use this inquiry to advance transparent science, meaningful oversight, and public health protection.

I am submitting this comment as a consumer concerned about long-term exposure to wireless radiation from phones, Wi-Fi routers, cell towers, and other connected devices. I urge HHS to conduct a thorough, independent review of whether current exposure limits adequately protect public health. This review needs to consider those most heavily exposed and should examine potential effects beyond tissue heating, including evidence concerning cancer, reproductive health, and children’s development. Please prioritize research that reflects how people actually encounter wireless radiation: repeated exposure over many years, often from multiple sources and devices used close to the body. Assessments should consider signal strength, pulse patterns, duration, and combined exposure. Please consider Melnick and Moskowitz’s 2026 analysis of animal data, which argues that existing exposure limits may inadequately protect against cancer and reproductive harm (https://doi.org/10.1186/s12940-026-01288-6). I also ask HHS to evaluate Lai and Levitt’s review of exposure intensity, duration, and signal modulation (https://doi.org/10.1080/15368378.2022.2065683), and Scarato’s review of US regulatory gaps and proposed reforms (https://doi.org/10.3389/fpubh.2025.1677583). These papers warrant careful consideration alongside the broader evidence, including studies that have not found adverse effects. I ask HHS to: •Assess whether additional protections are needed for children, pregnant women, and other potentially vulnerable groups. •Support long-term research with safeguards against industry conflicts of interest. •Provide clear information about exposure and practical ways to reduce it, including wired alternatives in homes and schools. •Recommend updated standards wherever the evidence shows that existing limits are insufficient. Consumers should not have to navigate these questions alone. Please use this inquiry to advance transparent science, meaningful oversight, and public health protection.

I am submitting this comment as a consumer concerned and someone who is on the board of a nonprofit organization where we research the effects of toxins in our food and environment on child development, about long-term exposure to wireless radiation from phones, Wi-Fi routers, cell towers, and other connected devices. Cell Towers should not be legally allowed to be on schoolgrounds across America, yet they are in my town. I joined the School Health Advisory Council to address this issue as the head of the Student Environmental Health Subcommittee. However, it's an uphill battle, but if you make a law that cell towers can't be on school grounds, then the school district would have no choice but to take these cell towers down. I urge HHS to conduct a thorough, independent review of whether current exposure limits adequately protect public health. This review needs to consider those most heavily exposed and should examine potential effects beyond tissue heating, including evidence concerning cancer, reproductive health, and children’s development. Please prioritize research that reflects how people actually encounter wireless radiation: repeated exposure over many years, often from multiple sources and devices used close to the body. Assessments should consider signal strength, pulse patterns, duration, and combined exposure. Please consider Melnick and Moskowitz’s 2026 analysis of animal data, which argues that existing exposure limits may inadequately protect against cancer and reproductive harm (https://doi.org/10.1186/s12940-026-01288-6). I also ask HHS to evaluate Lai and Levitt’s review of exposure intensity, duration, and signal modulation (https://doi.org/10.1080/15368378.2022.2065683), and Scarato’s review of US regulatory gaps and proposed reforms (https://doi.org/10.3389/fpubh.2025.1677583). These papers warrant careful consideration alongside the broader evidence, including studies that have not found adverse effects. I ask HHS to: •Assess whether additional protections are needed for children, pregnant women, and other potentially vulnerable groups. •Support long-term research with safeguards against industry conflicts of interest. •Provide clear information about exposure and practical ways to reduce it, including wired alternatives in homes and schools. •Recommend updated standards wherever the evidence shows that existing limits are insufficient. Consumers should not have to navigate these questions alone. Please use this inquiry to advance transparent science, meaningful oversight, and public health protection.

I am concerned about the massive proliferation of LED lights in all areas of our lives, but particularly with respect to automobile headlights and street/outdoor lighting. The harsh blue-white color temperature of these LEDs (say, 6000K and above) is dazzling to the eye at night. When I drive past cold white headlights, my vision takes longer to return to normal than when driving past even bright halogen headlights. In addition, my area has mostly replaced sodium street lighting with bright white LEDs. Rather than casting a diffuse glow that makes it easy to discern shapes at night, LED streetlights provide a bright area of light, while the area beyond if not illuminated as well appears even darker in comparison because the eye has to adjust to the bright and harsh LED lighting. Next, bright white LED street lighting shines through (my) residential windows at night and makes it impossible for me to sleep without an eye mask, meaning I can no longer wake up to sunlight because I need to cover my eyes to block the bright light from the street lights. Harsh/bluish lighting has already been proven to disrupt the circadian rhythm of humans and wildlife alike. Automotible headlights now are extremely bright to the point of causing temporary blindness at night. I feel far more unsafe driving at night now than I did ten years ago. I also am frequently blinded as a pedestrian when cars shine their headlights on me. I'm also under 30 with 20/20 vision. This is not a problem limited to those with poor eyesight. I have also noticed that even when LEDs in public aren't necessarily too bright, they are often very intense light sources coming from small points that tend to be dazzling/blinding when you look directly at them. Street and vehicle lighting should, in my opinion, not only have a limit on the color temperature and brightness of lighting, but there should be a surface intensity light emission limit as well. For the same overall amount of light, a larger light fixture or one with a diffuser will be far easier on the eyes and less blinding than a light fixture or headlight that emits the same amount of light from a very small surface area.

I am submitting this comment as a consumer concerned about long-term exposure to wireless radiation from phones, Wi-Fi routers, cell towers, and other connected devices. I urge HHS to conduct a thorough, independent review of whether current exposure limits adequately protect public health. This review needs to consider those most heavily exposed and should examine potential effects beyond tissue heating, including evidence concerning cancer, reproductive health, and children’s development. Please prioritize research that reflects how people actually encounter wireless radiation: repeated exposure over many years, often from multiple sources and devices used close to the body. Assessments should consider signal strength, pulse patterns, duration, and combined exposure. Please consider Melnick and Moskowitz’s 2026 analysis of animal data, which argues that existing exposure limits may inadequately protect against cancer and reproductive harm (https://doi.org/10.1186/s12940-026-01288-6). I also ask HHS to evaluate Lai and Levitt’s review of exposure intensity, duration, and signal modulation (https://doi.org/10.1080/15368378.2022.2065683), and Scarato’s review of US regulatory gaps and proposed reforms (https://doi.org/10.3389/fpubh.2025.1677583). These papers warrant careful consideration alongside the broader evidence, including studies that have not found adverse effects. I ask HHS to: •Assess whether additional protections are needed for children, pregnant women, and other potentially vulnerable groups. •Support long-term research with safeguards against industry conflicts of interest. •Provide clear information about exposure and practical ways to reduce it, including wired alternatives in homes and schools. •Recommend updated standards wherever the evidence shows that existing limits are insufficient. Consumers should not have to navigate these questions alone. Please use this inquiry to advance transparent science, meaningful oversight, and public health protection.

I am submitting this comment as a consumer concerned about long-term exposure to wireless radiation from phones, Wi-Fi routers, cell towers, and other connected devices. I urge HHS to conduct a thorough, independent review of whether current exposure limits adequately protect public health. This review needs to consider those most heavily exposed and should examine potential effects beyond tissue heating, including evidence concerning cancer, reproductive health, and children’s development. Please prioritize research that reflects how people actually encounter wireless radiation: repeated exposure over many years, often from multiple sources and devices used close to the body. Assessments should consider signal strength, pulse patterns, duration, and combined exposure. Please consider Melnick and Moskowitz’s 2026 analysis of animal data, which argues that existing exposure limits may inadequately protect against cancer and reproductive harm (https://doi.org/10.1186/s12940-026-01288-6). I also ask HHS to evaluate Lai and Levitt’s review of exposure intensity, duration, and signal modulation (https://doi.org/10.1080/15368378.2022.2065683), and Scarato’s review of US regulatory gaps and proposed reforms (https://doi.org/10.3389/fpubh.2025.1677583). These papers warrant careful consideration alongside the broader evidence, including studies that have not found adverse effects. I ask HHS to: •Assess whether additional protections are needed for children, pregnant women, and other potentially vulnerable groups. •Support long-term research with safeguards against industry conflicts of interest. •Provide clear information about exposure and practical ways to reduce it, including wired alternatives in homes and schools. •Recommend updated standards wherever the evidence shows that existing limits are insufficient. Consumers should not have to navigate these questions alone. Please use this inquiry to advance transparent science, meaningful oversight, and public health protection.

I am submitting this comment as a consumer concerned about long-term exposure to wireless radiation from phones, Wi-Fi routers, cell towers, and other connected devices. I urge HHS to conduct a thorough, independent review of whether current exposure limits adequately protect public health. This review needs to consider those most heavily exposed and should examine potential effects beyond tissue heating, including evidence concerning cancer, reproductive health, and children’s development. Please prioritize research that reflects how people actually encounter wireless radiation: repeated exposure over many years, often from multiple sources and devices used close to the body. Assessments should consider signal strength, pulse patterns, duration, and combined exposure. Please consider Melnick and Moskowitz’s 2026 analysis of animal data, which argues that existing exposure limits may inadequately protect against cancer and reproductive harm (https://doi.org/10.1186/s12940-026-01288-6). I also ask HHS to evaluate Lai and Levitt’s review of exposure intensity, duration, and signal modulation (https://doi.org/10.1080/15368378.2022.2065683), and Scarato’s review of US regulatory gaps and proposed reforms (https://doi.org/10.3389/fpubh.2025.1677583). These papers warrant careful consideration alongside the broader evidence, including studies that have not found adverse effects. I ask HHS to: •Assess whether additional protections are needed for children, pregnant women, and other potentially vulnerable groups. •Support long-term research with safeguards against industry conflicts of interest. •Provide clear information about exposure and practical ways to reduce it, including wired alternatives in homes and schools. •Recommend updated standards wherever the evidence shows that existing limits are insufficient. Consumers should not have to navigate these questions alone. Please use this inquiry to advance transparent science, meaningful oversight, and public health protection.

I am submitting this comment as a consumer concerned about long-term exposure to wireless radiation from phones, Wi-Fi routers, cell towers, and other connected devices. I urge HHS to conduct a thorough, independent review of whether current exposure limits adequately protect public health. This review needs to consider those most heavily exposed and should examine potential effects beyond tissue heating, including evidence concerning cancer, reproductive health, and children’s development. Please prioritize research that reflects how people actually encounter wireless radiation: repeated exposure over many years, often from multiple sources and devices used close to the body. Assessments should consider signal strength, pulse patterns, duration, and combined exposure. Please consider Melnick and Moskowitz’s 2026 analysis of animal data, which argues that existing exposure limits may inadequately protect against cancer and reproductive harm (https://doi.org/10.1186/s12940-026-01288-6). I also ask HHS to evaluate Lai and Levitt’s review of exposure intensity, duration, and signal modulation (https://doi.org/10.1080/15368378.2022.2065683), and Scarato’s review of US regulatory gaps and proposed reforms (https://doi.org/10.3389/fpubh.2025.1677583). These papers warrant careful consideration alongside the broader evidence, including studies that have not found adverse effects. I ask HHS to: •Assess whether additional protections are needed for children, pregnant women, and other potentially vulnerable groups. •Support long-term research with safeguards against industry conflicts of interest. •Provide clear information about exposure and practical ways to reduce it, including wired alternatives in homes and schools. •Recommend updated standards wherever the evidence shows that existing limits are insufficient. Consumers should not have to navigate these questions alone. Please use this inquiry to advance transparent science, meaningful oversight, and public health protection.