Exposure limits & oversight

I am a retired scientific researcher and strategy adviser having worked mainly in telecom R&D, industry and academia, living in Norway. Only late in my career, around 2010, I became aware of the abounding scientific research indicating health issues from cell phones and other RF-EMFs, as well as of tricks used to build a boolwark against such results. Since then, I have full time studied the scientific results and conveyed them to others, as I find the evidence overwhelming. On the way, I wrote books reviewing the science, translated books, and collected 150 selfreported descriptions of unhealth reactions experienced by electrohypersentive persons mainly from smartmeters, and from some other transmitting equipment. The stories include several in practice blind folded tests, and a wide range of so called "diffuse" acute symptoms, which vanish when away from the transmitting source. The 150 stories are included. (Publication consented.). However, listings of symptoms such as requested here and found in the 150 stories, do only register acute reactions, not long term effects from well documented impact on biosystems, e.g. DNA breaks or opening of the blood-brain-barrier. As unhealth from such effects is stochastic, multifactor and spread on a wide range of possible diagnoses, no valid conclusions can be drawn from registering acute symptoms. One must rely on huge epidemiological studies, realistic lab studies on basic mechanisms, and a precautionary approach. Therefore, as to relevant standards, the present standards from ICES/IIEEE and ICNIRP are irrelevant, as they only accept acute heat effects as proven, and set the recommended exposure maxima accordingly, only to protect against heat effects and demand presize measurements relevant for heat as causation. Such standards are unsuitable for protecting against (athermal) long term effects, and not precaucionary and have no predication value and therefore unusable for public radiation protection. Federal health agencies should in stead consider exposure standards based on experience cum science, and base standards on a precautionary approach. The best and most relevant such guideline and standard with recommended max exposure limits at present is: Belyaev I, Dean A, Eger H, Hubmann G, Jandrisovits R, Kern M, Kundi M, Moshammer H, Lercher P, Müller K, Oberfeld G, Ohnsorge P, Pelzmann P, Scheingraber C, Thill R. EUROPAEM EMF Guideline 2016 for the prevention, diagnosis and treatment of EMF-related health problems and illnesses. Rev Environ Health. 2016 Sep 1;31(3):363-97. doi: 10.1515/reveh-2016-0011. PMID: 27454111. What would improve the assessment, disclosure, and regulation of wireless radiation exposure the most, would be to get the bodies shaping the norms have a balanced representation of industry, independent researchers and government - not only industry and/or personell accepting to work on the premises that heat only effects is all there is to protect, and neglecting all other effects, although very well proven (or even probable only). To include taking advice from the ICBE-EMF (The International Commission on the Biological Effects of Electromagnetic Fields) would be such an important step in the right direction. A very efficient step to develop, test, and evaluate the effectiveness of procedures and techniques for minimizing exposure to electronic product radiation, would be to establish a lab test site and approval system based on measuring oxidative stress in cells from microwave exposure. (This can easily and cost-effectively and fast be measured by standard equipment. Ask prof. em. Martin L Pall for further advice for set up of such a lab.) As effects from RF-EMF are in part acute, in part long term and just one of several vectors, trying to list the risk picture per item is a futile exercise and disturbs real risk assessments. In stead, to Measure Human Exposure and Public Health Surveillance, MDs should start registering and reporting suspected cases of EMF-caused unhealth. Any radiation protection strategy must be based on standard environmental medicine / toxicology procedures as to already present toxic matters: i.e. based on precaution and with a low, not an extremely high, demand for proof as at present, and not demanding sigle factorial proofs. Einar Flydal, cand. polit.; Master of Telecom Strategy, retired from telecom & academia, writer and blogger Oslo, Norway

HHS, I would like to comment on non-ionizing man-made radiation that the citizens of the U.S. are daily exposed to, which negatively impacts our health though they may not be aware of it. I am personally negative impacted with adverse health effects when exposed to man-made radiofrequency (RF) made radiation as I am more sensitive to it than others. As a result of being significantly affected by the non-ionizing radiation produced man-made devices, I found a physician to address to issue and was subsequently diagnosed as having electromagnetic hypersensitivity. (EHS). We are exposed daily by devices such as cell phones, cell towers, Wi-Fis, Wireless Access Points (WAPS), Bluetooth and AirPod devices, etc. In addition, there are low frequency electromagnetic fields (EMFs) produced by wiring and equipment in homes and businesses. Animals and plants are also negatively affected by man-made EMFs and radiation. A huge problem is that the FCC is NOT adequately protecting the citizens of the U.S. based on their old outdated man-made EMF standards based on the heating effect and not the biological effect. The FCC is obviously an industry captured agency and they have so far refused to update their standards even though on August 13, 2021, the United States Court of Appeals for the District of Columbia Circuit ruled in the historic case EHT et al. v. the FCC that the December 2019 decision by the Federal Communications Commission (FCC) to retain its 1996 safety limits for human exposure to wireless radiation was “arbitrary and capricious." On the Children's Health Defense (CHD) website, it says, "In a motion filed today [August 6, 2025] with the Federal Communications Commission (FCC), CHD urged the agency to collaborate with the U.S. Department of Health and Human Services (HHS) to set wireless radiation exposure limits that protect public health." This is an excellent move by the CHD. The HHS should set the man-made radiation standard, not the FCC. Asking the FCC to do it is like having the fox guard the hen house. I am aware of no action yet taken by the FCC to revisit the old EMF radiation standards or that the FCC is collaborating with the HHS to update the EMF radiation standards. It is unconscionable that the FCC is doing nothing as far as I know to help make sure the citizens are not exposed to man-made radiation that negatively impacts their health. The new standards must be based on the biological cellular effect, not on the old outdated heating effect. This new standard, if based on the many scientific studies that are not biased in any way will help increase the U.S. citizens' health as many are negatively affected by man-made EMFs but they do not correlate negative health effects with the EMFs. All of the U.S. government agencies need to do things that prove they are focused on public health issues, not just talk about it. Remember MAHA.

The current technology in LED headlights in automobiles and trucks affect my life profoundly. Due to a lifelong astigmatism in my eyes, these headlights create a white out effect when they are pointed toward me from oncoming traffic at night. It wasn't such a big issue until almost two years ago when they seemed to reach a sort of critical mass on newer vehicles. I have seconds where I'm blinded and I can't see anything but white glare. This is happening while I'm driving a moving vehicle. I'm terrified I'll hurt someone else by not seeing a pedestrian, or having no clue where any curbs or road markings are and crashing into another vehicle. Of course, that would likely be the end of me, too. I can only drive after dark if I can plan nearly all of a route on familiar roadways with no oncoming traffic, like service roads or freeways. The older halogen headlights never did this, and I mostly don't drive after dark now. My life is so much more restricted now. It's limiting and depressing. I know there are a lot of people with astigmatism who must be similarly affected. As I understand it, 21 U.S.C. 360ii requires the FDA to establish and maintain a liaison with NHTSA to test and evaluate LED headlights for their impacts on human health. Isolation, depression, and possibly crashing and loosing our lives are certainly impacts on our health. There has to be some solution, some way to modify the existing headlights, such as a coating or applied film, that mitigates the effects of what are like a multitude of tiny reflecting mirrors. I propose that this is an urgent matter worthy of research and efforts toward a way to make LED headlights safer.

I believe my family has been severely affected by 5G. And I hate that our US government has no regulations and refuses to look at research concerning this. I have read research done by our defense department that shows the classic symptoms of radiation sickness and it seems to me that many people during Covid had radiation sickness, not Covid. Since I assume you have access to the same studies that I’ve read, I don’t find the need to recap them here. The evidence is clear 5G is clearly much more dangerous than 4G and we are running towards 6G which is a globalist terrible awful idea. No one needs 6G and I do not need the government in my body. I am so tired of the idea of all of the censorship that the globalist and our government because our government is full of globalist want to unleash on the free people of America. 5G causes anxiety. It causes sleeplessness. It causes a host of other issues. It is awful that this has been unleashed on us during the pandemic and I figure you will have to start a new pandemic for 6G to hide the radiation damage that that will do. Am I right or will it be a different psyop?

Please, make the FCC take on the health challenges that are before us. We've already experienced many deaths and illnesses from over exposures to wireless radiation. Our children and our futures are at stake. If the FCC cannot follow court orders than the HHS could take up this cause. We are sitting in massive amounts of RF radiation due to the grid/satellites/cell infrastructure/cell phones/baby monitors/ wireless health devices/ Wi-fi and many others. The manufacturers are completely out of control and setting more and more dangerous standards. The most vulnerable in our society are in harms way. Our medical system is not addressing this issue and many are suffering without the cause. This will not only destroy our medical system with tremendous amounts predictable cancers. Needlessly I may say. This will be the 'Wireless Holocaust" if not stopped.

I strongly urge HHS and its selected scientists to review the effects, symptoms, and published studies and report on non-thermal effect and take these into consideration. I have been conducting assessments for AC electric and magnetic fields and wireless radiation (RF) with professional calibrated instrumentation in residential, commercial and institutional buildings for over 30. I can attest that in many cases were individuals reported unspecific health problems and symptoms; once the source was eliminated, exposure reduced or shielded improvements were clearly noted. The current regulatory exposure limited need to be revised and significant reduced, especially in sensitive aeras such as but not limited too kindergartens, schools,...... I am encouraged that 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.

I am a retired environmental attorney and currently a Professional Engineer in Washington and California (RCE). I have participated in proceedings before the FCC regarding the harms to humans and other protected animals of non-ionizing EMF including radiofrequency and wireless radiation. The FCC has been unresponsive to these harms. I greatly appreciate the HHS addressing this issue. These harms are addressed in the attachments submitted as part of this comment. A good summary of these harms is provided in Sage, Cindy (2007-2014) (attached hereto). There has been an International Appeal (2015) (attached hereto) seeking to get reasonable regulation of non-ionizing electromagnetic fields (EMF). I attach other articles that address this issue, including Pall, Martin L. (2015); Yakymenko, Igor (2014); and Levitt, B. Blake (2010). Cell towers not only adversely impact humans, but also have adverse impacts on protected wildlife. Albert Manville is an expert on the adverse impacts to protected wildlife and I attach several articles from a Manville Report that give guidance. Please address mitigation of the harms addressed herein. Thank you. Respectfully Submitted,

The attached published and expert scientific research recommends key policy updates. Current regulations are outdated and do not protect the public. These pertain to Question 5. Please follow recommendations of the published papers attached.

Our government, including HHS have as their first and most important purpose, to secure the rights of the People who created government. We are calling on HHS to protect the People from the harm of EMFs RF Radiation and Wireless Radiation. The FFC has proven incompetent and not impartial. FCC employees are regularly employed in the fields that benefit from their lax regulations and refusal to investigate and research. I have been personally affected by the lax regulations through a smart meter that was forced on me by my utility company that provides power to my home. A smart meter was placed outside my bedroom window. From that month to 2 years after, i suffered many health issues that took over 2 years and 10 health care providers to finally realize that the issue was the radiation. Ultimately the health care providers did not help me as they are not educated on this issue. I had to figure it out through my own diligent research which took hundreds of hours. I finally ran across a podcast about smart meters and remembered a notice from my utility company 2 years before about the smart meter. I emailed them and had it confirmed that the same month my symptoms started was the month the meter was installed outside my bedroom. The worst of my symptoms was full body eczema, hives and welts which I had never experienced in my life. I then had other issues from the stress of it all that piled on, creating a full blown crisis in my body. I had lost my will to live and it was all created by a company that still to this day claims their equipment is safe which obviously is a total fabrication. It is not healthy to have a constant pulse of radiation outside your window. From that point on I have been sensitive to EMFs and other radiation. I see other people struggling in other ways as well because we all have different weakness in our body so we present dis-ease differently. HHS must help regulate these types of exposures. To ignore it any longer is a violation of our right to a healthy environment. It is not right to allow companies and industries to benefit financially from destroying the health of the American People. I have attached a picture of my leg to show how excessive my reaction to the smart meter was. I apoligize for how unsightly it is but it is important for HHS to know how People are suffering and how urgent it is that this issue be addressed. Thank you

I submit this as an individual consumer and family member, relying on peer-reviewed research, federal reports, and court findings cited below (Qs 2, 3). Concern (Qs 5, 6): FCC's RF limits date to 1996 and address only short-term tissue heating, not chronic exposure, pulsed/modulated signals, multi-source cumulative exposure, or children's thinner skulls. In Environmental Health Trust v. FCC (D.C. Cir. 2021), the court found the FCC failed to justify that its limits protect against non-cancer harms, citing unaddressed evidence on children and long-term exposure, and remanded the issue. HHS, not FCC, should lead on the health basis for any standard. Evidence below current limits (Q12): NTP's $30M study (2018) found "clear evidence" of heart schwannomas and "some evidence" of brain/adrenal tumors in RF-exposed rats, with DNA damage reported in a follow-up (Smith-Roe et al. 2020). Italy's Ramazzini Institute independently found the same rare tumor at lower exposures comparable to cell tower emissions (Falcioni et al. 2018). IARC classifies RF-EMF as "possibly carcinogenic" (Group 2B, 2011). Reviews report oxidative stress (Yakymenko et al. 2016), reduced sperm quality (Adams et al. 2014), and DNA strand breaks (Lai & Singh 1995; REFLEX project 2004). Technologies changing cumulative exposure (Q13): 5G/small cells near homes and windows; Wi-Fi transmitting continuously in classrooms; smart meters installed on homes, often without real opt-out, pulsing near bedrooms; satellite broadband (e.g., Starlink) creating a new planet-wide RF source; networked cameras (e.g., Flock) on public poles with cellular modems and no resident notice; wireless earbuds transmitting inside the ear canal for hours daily, especially in teens; EVs producing low-frequency magnetic fields in cabins where children ride (IARC links this field type to childhood leukemia); AI data centers driving new high-voltage lines near communities; LED/"smart" lighting suppressing melatonin (AMA 2016) and adding RF transmitters with little safety study. Environmental effects (Q14): Thielens et al. (2018) found insects absorb more RF above 6 GHz, the direction 5G/6G are heading. Levitt, Lai & Manville (2021–22) reviewed reported effects on birds and insects, noting no federal environmental RF standard exists. Sensitive populations (Q11): Children, pregnant women, and implant recipients need separate risk evaluation. France restricted Wi-Fi for under-3 childcare settings in 2015. Disclosure (Q9): Residents deserve public antenna/exposure maps, advance notice before installations near homes and schools, clear device transmission labeling, and a genuine no-fee smart meter opt-out. Research priorities (Qs 10, 16, 17): Fund independent long-term cohort studies with real exposure measurement, especially in children; commission NTP follow-up at current 5G/mmWave frequencies; build a national RF/EMF environmental monitoring network; create an adverse-event reporting pathway; direct FDA to test consumer devices under realistic body-contact conditions. This research must be free of industry funding. Conclusion (Q18): We have deployed unprecedented, involuntary population-wide EMF exposure without proving it safe. Credible research has found cancer signals, DNA damage, oxidative stress, and reproductive effects. I ask HHS to investigate this independently and thoroughly, and prioritize human and environmental health over the pace of commercial deployment.