Exposure limits & oversight

Dear Department of Health and Human Services: Thank you for listening to the concerns people have about wireless technology. I began suffering from EMR (electromagnetic radiation) Syndrome about 25 years ago. The chronic symptoms I have struggled with over the years include tinnitus, head and facial pain, head fogginess/dizziness, eye and vision problems, nosebleeds. My doctor and I spent years trying to determine the cause of my symptoms. I saw various specialists including an ENT doctor and at least three different neurologists. I had a CT scan and two brain MRIs. I had no success with any of the prescribed treatments, and none of my health care providers could figure out what was going on. Finally, about 10 years ago, I stopped using a cordless phone and took other steps to reduce my RFR (radiofrequency radiation) exposure. In doing so, I experienced a dramatic reduction in my symptoms. The general public needs to be aware that wireless radiation is harmful to human health. I have lost three jobs in the last nine years because my employers refused to provide a safe working environment. In the most recent incident, a WiFi router was located near my desk and I asked for permission to move the router at least 15 feet away. My boss refused to accommodate my request. When I told her that my doctor had advised me not to sit in such close proximity to the router, she terminated my employment. In the United States, we, the public, are not adequately protected by our safety standards. Thousands of peer-reviewed scientific studies, accumulated over decades, report biological effects from exposure to non-thermal, non-ionizing electromagnetic radiation (the kind emitted by cell towers, smart meters, WiFi routers, cell phones, Bluetooth devices, etc.). Our safety regulations do not to consider the bioeffects of wireless radiation at non-thermal levels. Nor do they consider the cumulative effects of long-term exposure over a period of years. The regulations consider only short-term exposure from a single source. They fail to consider exposure from multiple simultaneous sources, such as occurs when you, for example, use a cell phone or tablet near a smart meter in a location covered by multiple WiFi networks. One thing we know about wireless radiation is that, among the many effects seen, a very serious one is the deterioration of the genome (genotoxicity).  Such an effect, if seen in a food item under development or in a potential pharmaceutical drug, would immediately completely ban the product from future marketing and sale. The wireless revolution began more than 25 years ago, and the damage done so far is incalculable. The scientific and medical evidence is clear. Our government agencies need to protect the public from wireless harm, and they need to act now. Please take the time to consider the study conducted by James C. Lin titled “Health and safety practices and policies concerning human exposure to RF/microwave radiation.” https://www.frontiersin.org/journals/public-health/articles/10.3389/fpubh.2025.1619781/full

Re: Docket No. HHS-OASH-2026-0397; Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure; 91 FR 59792 (September 21, 2026); FR Doc. 2026-19252; regulations.gov Document ID HHS-OASH-2026-0397-0001 Perspective (Question 2): I write as a researcher and as a consumer; I file in my individual capacity, with affiliation for identification only, and my response rests on the methodological literature and on professional experience rather than on new data. I am an epidemiologist (Ph.D., University of Minnesota) and a security engineer who has built RF telemetry and software-defined radio sensing systems through two companies I co-founded. The strongest case for this RFI is its order of operations: asking the research community and the public to identify frameworks, evidence, exposure methods, surveillance gaps, and research priorities before any policy move is the correct sequence, the questions are well structured, and the instruction that respondents name the frameworks they rely on and the basis of their evidence is sound. I take no position on whether RF exposure below current limits causes harm. My position is narrower and prior: that question cannot be answered well until exposure is measured, so the most consequential questions in this notice are the exposure-assessment and surveillance questions. Summary of recommendations: 1. For each exposure framework HHS relies on, state the biological endpoint the limit protects against and the safety factor applied (Question 5). 2. Fund a national measured-exposure program: calibrated personal dosimeters and fixed software-defined radio monitors on a probability-based population panel, recording band-resolved field strength and duty cycle over time with published uncertainty budgets (Questions 7 and 8). 3. Disclose measured field strength at representative use distances, in plain units with stated uncertainty, rather than only a single maximum SAR value (Question 9). 4. Evaluate any new surveillance system against the CDC 2001 attributes before it is built, and give every registry an exposure denominator by linking it to the measured-exposure panel (Question 10). 5. Differentiate exposure assessment for children and for occupational groups because dose, not only field strength, differs (Question 11). 6. Apply symmetric quality criteria to studies finding effects and studies finding none, and prioritize measured-exposure cohorts and replication of the most-cited findings on either side (Questions 12 and 16). 7. Adopt a single federal exposure-measurement data standard and shared repository for FDA, NIH, CDC, and the FCC, coordinated with the FCC's concurrent proceeding (Question 17). The full comment is attached as a PDF. Disclosure: I have no financial interest in any vendor or contract involving this request, and I was not compensated for this comment. I co-founded AirCrumbs, Inc., which develops software-defined radio systems for wireless signal attribution, not exposure measurement, and earlier co-founded MTRX, Inc., which built RF telemetry products; I have no financial interest in any wireless carrier, device manufacturer, or exposure-measurement vendor. Andrew G. Huff, Ph.D., M.S. Risk Factor Research, LLC, Michigan, USA contact@andrewhuff.com

Our current regulations are astoundingly outdated... originating when most people did not even know what a cell phone was! Likewise any knowledge of the effects of microwave radiation was an unstudied unknown. We need new, updated, protection!

I am writing to request strong deliberation regarding EMF and RF exposure. The effects are largely similar to many of us- headaches, trouble sleeping, irritability, the list goes on. A government's role is to guard the nation and keep a set of principles that unite us. Installing and supporting the growth of Electromagnetic fields and Radiofrequency Radiation is a danger to the citizens health, I dont think that protects our citizens. If it harms one person it should be enough to rethink. Please consider your actions carefully as these decisions affect the heath of a decent portion of the nation, and even more that just haven't realized the root cause.

My history with this issue began September 2006 when National Grid came to my home and replaced our analog meter without our knowledge or consent with a digital smart meter. I immediately heard something that interfered with my sleeping. I never heard this before. I bought my home in 1999. There was never a problem with hearing a continual noise that never stops. Symptoms followed such as headaches and migraines of which no reoccurring history. I also had nose bleeds, nausea, muscle spasms, fatigue, to name the worst of them. I called the DPU, DPH, DEP, EPA, verizon and national grid hired noise experts electricians, power quality studies in my home with a dranetz. SPL octave band studies for pure tones. Learned in 1990 Barbara Kwetz signed into law pure tone regulations for MA. But to no avail. Our experts were not equipped to provide us with help or had conflict of interest. When the first generation of smart meters were rolled out the costumers of utilities and safe to say most of population were ignorant of what the impact of smart grid technology ie., radio frequency radiation pollution would negatively have on us when exposed. There is no escaping it where this technology is turned. The state did not complete a single test that would identify the problem and mitigate. It was a clown show. They also ignored an affidavit from arlo Guthrie who is a forensic sound engineer who identified pure tones are the source of the grid and telecommunications layer of grid. The agencies never reached out to speak with him. The testing the state planned, for a couple years allowed national grid to test at or property without hiring a disinterested party to watch the wolves in the hen house. National Grid left an SPL meter over night in our home and another outside and both had glitches and produced zero data to complete the testing protocol. Several demand letters later in 2012 in July we finally got our analog meter back. I felt better immediately and the severe symptoms have not come back since removing the digital meter. One thing I predicted would not be mitigated; that being the noise. The pulsed RF signals are causing interference on the uninsulated exposed wires so it is broadcasting 24/7 even during a power outage because of the back up batteries. We are being charged $26.00 a month to have a reader come out to read the meter! This has to be illegal because it is our right to be protected not abused for wanting safety and our health protected.

Regarding: Request for Information on EMF, RF, and Wireless Radiation Exposure Comment by Dan Feidt, Philadelphia resident. [Question 2 & 3] I am an individual consumer and former resident who experienced chronic, close-range exposure (<25 feet) to cell tower mast hardware on a residential building. This exposure was continuous (24/7), highlighting severe gaps in public safety frameworks. Crucially, another resident in my immediate living environment required a cardiac pacemaker during their residency near this specific transmitter array. This observation necessitates formal tracking to investigate if chronic, close-range residential exposure acts as an environmental stressor or accelerant for cardiac electrical dysfunction, even at levels deemed compliant with outdated standards. [Question 5 & 6: Outdated Exposure Standards] I urge federal health agencies to critically re-evaluate the FCC’s General Population/Uncontrolled Exposure framework (47 CFR § 1.1310). The current Max Permissible Exposure (MPE) limits are structurally deficient: 1. Outdated 1996 Baseline: The framework relies on guidelines adopted in 1996, failing to reflect modern 5G/6G densification, multi-frequency arrays, and multi-family rooftop placements. 2. Thermal Precedent Flaw: The 1996 framework protects only against acute thermal tissue heating over short intervals. It entirely ignores the biological realities of chronic, long-term, non-thermal cumulative exposure. 3. Preemption Gaps: The Telecommunications Act of 1996 blocks local municipalities from restricting placements based on environmental health concerns if they meet FCC limits, leaving residents completely vulnerable with no legal recourse or mandatory safety buffers near living spaces. [Question 7, 8 & 9] - 3D Volumetric Spatial Auditing: Compliance frameworks must evolve past single, static center-of-the-room data points. Testing should require a standardized protocol using an extended pole assembly with a calibrated tri-axial probe to systematically plot electromagnetic energy within every individual cubic meter of residential space to map "exposure hot spots" caused by reflections off internal building materials. - Standardized Inflow Auditing: The government must establish standardized protocols using calibrated, tri-axial isotropic antennas to measure the exact RF energy density and electric field strength entering a private residential unit, cross-referencing this against independent, non-thermal biomedical models. [Question 8 & 9 (Cont.): The "Energy Star" Model & Power Logs] - Transparent Disclosure Labels: Federal health agencies should establish a standardized, consumer-facing labeling framework analogous to the Energy Star metrics for device efficiency. Every residential rooftop mast must feature an accessible public registry placard (and QR link) disclosing maximum transmission intensity, active frequency bands, and licensed directional beamforming pathways. - Weather-Variant Disclosures: Regulators must mandate explicit disclosure of how wireless infrastructure alters its transmission intensity under varying conditions. Providers must declare operational ceilings for Automatic Transmit Power Control (ATPC), as dynamic surges used to compensate for "rain fade" (atmospheric attenuation from rain, snow, or fog) significantly escalate localized exposure compared to baseline clear-weather compliance models. - Mandatory 2-Year Historical Logs: Telecom operators must maintain and provide an accessible, rolling 2-year log detailing the exact power variations, intensity fluctuations, and active frequency bands used by any given mast. This allows residents, epidemiologists, and doctors to retroactively audit and map health changes or cardiac anomalies against real, long-term emission trends. [Question 11 & 12] - Medical Device Interoperability: Current risk evaluation frameworks neglect the spatial density of 5G antennas on residential roofs. The government must modernize safety buffer zones around multi-family residential structures to specifically protect individuals with implanted medical devices (such as pacemakers and defibrillators), ensuring localized fields do not cause unmonitored electromagnetic interference (EMI) over prolonged periods. [Question 17] - Inter-Agency Environmental and Cardiac Cross-Referencing: I urge the HHS to establish a collaborative research pipeline between the FDA, CDC, and FCC to cross-reference localized, time-stamped weather data and documented ATPC transmission surges with localized, anonymous emergency department admissions or remote pacemaker telemetry logs. This targeted research is necessary to determine if sudden, weather-induced spikes in localized RF transmission intensity correlate with acute cardiovascular events or electrical anomalies in implanted cardiac devices among residents living in close proximity to rooftop masts. More details attached in txt file. Thanks for consideration.

I’m very concerned about wireless radiation and all of the radiation from “smart” devices. Even if I hard wire. Y home and turn off what I can in my home there are still multiple WiFi systems from my neighbors affecting us. There needs to be much more oversight and regulation of EMF a push to move to hard wiring and limiting the use of “smart” meters by utility companies.

This recommendation focuses on a specific loophole in current standards of electromagnetic exposure that is being exploited by specific foreign-built consumer grade electronics to express a comprehensive approach to ensuring operating safety for the end-user consumer in the United States. Current standards mainly focus on intentional electromagnetic radiators such as smart phones at cellular frequencies or tablets at Wi-Fi frequencies. These intentional radiators are combined with a charger or AC/DC adapter which adhere to a poorly defined and poorly enforced FCC Class B standard for unintentional radiation. The integration of foreign manufactured components into the final consumer product sidesteps individual component testing. Foreign electronics manufacturers intentionally alter the electromagnetic signals emanating from components to prevent accurate measurements from foreign accredited testing laboratories that are selectively testing to low standards. With the recent technological shift to faster switching semiconductors and burst mode charging capability combined with poor end-user habits, emanations from cheap foreign handheld consumer electronics with biologically unsafe signatures create a health risk to Americans.

I am a Licensed Electrician and perform EMF Mitigation for private residences. I received training through the Building Biology Institute and am in process to be certified through BBI as an Electromagnetic Radiation Specialist. For the past 6 years I have measured and mitigated electromagnetic fields in homes with a primary focus on sleeping areas. My work is guided by the Building Biology Evaluation Guidelines, which are based on the precautionary principle and the goal of creating environments that support long-term health rather than merely avoiding acute thermal injury. I appreciate HHS’s initiative to examine RF/EMF exposures, particularly as they affect children and other vulnerable populations. There exists a large gap between U.S. standards and precautionary guidelines. U.S. and ICNIRP standards are based almost exclusively on heating (thermal) effects. A substantial body of peer-reviewed research documents non-thermal biological effects at levels far below those limits. Mechanisms repeatedly discussed in the literature and observed in practice include activation of voltage-gated calcium channels leading to oxidative stress, disruption of melatonin and circadian rhythms, DNA damage, increased blood-brain barrier permeability, and effects on sperm and reproductive tissue. From my professional experience, the most consistent and rapidly reversible effects are on sleep quality and overnight recovery. Clients frequently report improvements in sleep, energy, headaches, heart palpitations, cognitive clarity, and skin sensations after reduction of nighttime exposures, even when daytime exposures remain largely unchanged. These observations align with the emphasis Building Biology places on sleeping areas. Children are of particular concern. Their thinner skulls, higher tissue conductivity, developing nervous and immune systems, and longer cumulative lifetime exposure increase vulnerability. I regularly encounter elevated RF and AC electric/magnetic fields in children’s bedrooms from Wi-Fi routers, baby monitors, cordless phones, cell phones, tablets, gaming devices, smart meters, and poorly designed electrical wiring. Building Biology Evaluation Guidelines for Sleeping Areas: • Radiofrequency: ideally < 0.1–10 µW/m² • AC magnetic fields: < 0.2–1 mG (20–100 nT) • AC electric fields / body voltage: very low (typically aiming for body voltage < 10–100 mV) These levels are orders of magnitude below current FCC public exposure limits. Several European medical associations (e.g., Austrian Medical Association, EUROPAEM) and the BioInitiative reports have recommended substantially lower precautionary limits than those adopted in the United States. To address the current research gaps, the following areas should be prioritized: • Long-term studies of chronic, low-level, pulsed RF exposures typical of real-world environments (Wi-Fi, 4G/5G, DECT, smart meters) rather than short-term, continuous-wave laboratory exposures. • Effects on sleep architecture, melatonin, and overnight recovery in children and adolescents. • Combined exposures (RF + dirty electricity/microsurge electrical pollution + AC electric and magnetic fields). • Identification of susceptible subgroups (including those with electrohypersensitivity/EMR syndrome) and objective biomarkers. • Prospective studies of mitigation effectiveness in homes and schools. Recommendations: 1. Prioritize sleeping areas — Turn off or place Wi-Fi routers in airplane mode at night; keep cell phones and tablets out of bedrooms or in airplane mode; prefer hardwired Ethernet connections. 2. Reduce close-range device use — Encourage speakerphone, wired headsets, or airplane mode for children; avoid carrying phones against the body. 3. Address electrical environment — Identify and correct wiring errors that elevate magnetic fields; consider demand switches or circuit control for bedrooms to reduce AC electric fields during sleep; minimize dirty electricity from dimmers, inverters, and certain electronics. 4. School and institutional settings — Prefer hardwired networks where feasible; locate wireless access points away from classrooms and offices; provide low-EMF options for sensitive students. 5. Siting of infrastructure — Avoid placing cell antennas, small cells, and smart meters in close proximity to homes, schools, and daycare facilities. 6. Education — Provide clear, accessible information so parents, teachers, and clinicians can make informed choices while research continues. I urge HHS to incorporate precautionary considerations for non-thermal effects into its evaluation, especially for children, and to support independent research that examines real-world exposure patterns and mitigation outcomes. Practitioner observations and the existing body of non-thermal research should be weighed alongside the thermal-only framework that currently underpins U.S. standards. Respectfully, William Pursino

I submit this comment as a 27-year-old resident of France who has experienced localized physiological and neurological symptoms associated with ambient and near-field electromagnetic environments since early 2021. My experience highlights the importance of assessing whether current regulatory standards adequately address real-world exposure conditions and individual sensitivities. Firstly of all, current testing protocols often assess wireless devices under controlled conditions that may not fully reflect simultaneous use of GPS, cellular data, and Wi-Fi. Such multi-radio activity can affect device power consumption, heat generation, and exposure levels. I therefore encourage the Commission to evaluate simultaneous transmissions in realistic operating and handling conditions when reviewing Specific Absorption Rate (SAR) and power-density standards. Relevant industry developments, including U.S. Patent No. US20120231784A1, illustrate the technical challenges of managing emissions in multi-radio systems. Secondly, exposure assessments should also consider the broader environmental context. Atmospheric electricity, temperature, low-frequency fields, and device-generated noise may coexist in everyday settings. Although their combined physiological effects require further investigation, I encourage the Commission to support research into potential interactions between environmental factors and neurological responses, including symptoms reported by sensitive individuals. Thirdly, metal enclosures such as trains, subways, elevators, and vehicle cabins can affect signal reception and prompt mobile devices to adjust transmission power. These changing conditions may produce exposure patterns not adequately represented by averaged outdoor measurements. Testing should therefore include realistic indoor and enclosed transport environments, transient transmission peaks, and common device-use positions. Furthermore, building materials, architectural design, and local topography can also influence radiofrequency distribution. Masonry may attenuate signals, while windows, upper floors, and reflections from nearby structures can create variations in indoor exposure. I encourage the FCC to collaborate with architects, engineers, and materials scientists to investigate shielding materials, develop standardized testing methods, and assess practical measures to reduce indoor exposure where appropriate. Finally, disabling wireless interfaces and using wired connections may reduce radiofrequency emissions, but electronic devices continue to generate low-frequency electromagnetic fields, heat, and other electrical emissions. I therefore recommend that regulatory bodies assess these sources alongside radiofrequency emissions, including during close-proximity use of battery-powered and mains-powered electronics. In conclusion, I respectfully encourage regulatory authorities to review existing safety standards in light of realistic device operation, changing environmental conditions, building characteristics, and emissions across different frequency ranges. Further independent research and appropriately precautionary safety margins could help clarify potential non-thermal effects and improve protection for the general public, including individuals reporting heightened sensitivities.