Exposure limits & oversight

World Council for Health (WCH) welcomes the opportunity to respond to the U.S. Department of Health and Human Services' Request for Information. WCH is an international health advocacy organisation committed to promoting informed consent, individual health sovereignty, scientific transparency, and the protection of human and environmental health. We believe that the rapid and largely unrestrained expansion of wireless technologies represents a significant public health and environmental policy concern that warrants urgent, independent and comprehensive scientific scrutiny. Over recent decades, wireless communications infrastructure has expanded dramatically, introducing increasingly widespread and persistent exposure to man-made electromagnetic fields. While technological innovation has brought considerable benefits, WCH is concerned that the pace of deployment has outstripped the assessment of potential long-term biological and environmental consequences, particularly in relation to chronic, cumulative and involuntary exposure. In 2023, WCH published its Policy Brief on the Effects of Unregulated Digitalization, examining the wider implications of rapidly expanding digital and wireless technologies for public health, human rights, democratic accountability and the environment. This body of work includes the recommendations of the late Dr Arthur Firstenberg, who devoted decades to investigating the biological and ecological effects of electromagnetic fields. His work brought together scientific publications examining possible effects on neurological function, cellular processes, reproduction, wildlife, biodiversity and ecosystem health. Of particular concern is the extent to which existing RF exposure standards have historically focused on established thermal effects, while questions concerning long-term exposure, non-thermal biological effects, signal modulation, vulnerable populations and ecological impacts remain contested or insufficiently resolved. WCH believes that public health policy must consider the full breadth of available evidence, including research findings that challenge prevailing assumptions about exposure thresholds and biological safety. We are particularly concerned about the implications for children, pregnant women, individuals reporting electromagnetic hypersensitivity, and those who have little practical ability to avoid exposure in their homes, schools, workplaces or communities. The continued expansion of 5G telecommunications and wireless infrastructure including the introduction of new frequencies, network configurations and connected technologies raise further questions about aggregate exposure, long-term health effects and the adequacy of existing safety assessments. The potential environmental implications must also be considered. The Brief highlights research examining associations between anthropogenic electromagnetic fields and changes in the behaviour, development, reproduction and survival of insects, birds, plants and other organisms. These findings require careful evaluation, including consideration of study limitations and other environmental factors, as part of a comprehensive approach to ecological protection. WCH therefore calls for an independent, transparent and multidisciplinary review of the scientific evidence, free from inappropriate commercial or regulatory conflicts of interest. Such a review should address thermal and possible non-thermal effects, chronic and cumulative exposure, biological responses to modulation and pulsed signals, and the implications of exposure across the lifespan. We further urge HHS to consider the precautionary principle, particularly where exposure is involuntary, where vulnerable populations may be affected, and where meaningful opportunities to reduce unnecessary exposure exist. This includes serious consideration of practical alternatives such as wired communications infrastructure, greater public disclosure of exposure information, improved professional education, and individual choice. WCH encourages greater coordination between public health authorities, environmental agencies, independent researchers and affected communities, recognising that the potential implications of electromagnetic pollution extend beyond conventional telecommunications regulation. The protection of public health and the natural environment must remain central to technological policy, and not be treated as secondary considerations after widespread deployment has already occurred. We believe that responsible technological development must be guided by independent science, transparency, informed consent, the protection of vulnerable populations, and a commitment to safeguarding the health of both present and future generations. Yours sincerely Dr Tess Lawrie MBBCh, PhD Ambassador World Council for Health worldcouncilforhealth.org https://www.worldcouncilforhealth.org/what-is-5g-health-risks/

There are many reasons to research the impact of man-made non-ionizing radiation. First, we’ll start with cellphone and mobile base stations (MBSTS) effects on children (it should be noted these base stations are leased and pay the schools tens of thousands of dollars annually). A study involved parting a non MPBST (mobile phone base station) exposed group to an exposed group and comparing test scores after a period of 2 years’ time (Meo SA et all, 2018). The impact of the radiation showed memory and motor deficiencies of significant value. In the attached report you’ll see a significant difference in the study groups when it comes to learning and memory. I will say that I have measured the radiation from my cellphone in an otherwise zero EMR environment. The zero EMR environment registers 0.2 to .5 mW/cm2 (0.2 microwatts per meter squared), which is considered very safe. Comparatively, when you measure my phone with its Wi-Fi turned on (and no other connectivity signal), I get 189,000 mW/cm2. That’s an incredible difference. Other individuals of concern are those with preexisting medical conditions, especially those with weakened immune systems are more susceptible to the degrading effect EMR has on the blood brain barrier. The BBB is a semipermeable border that moves ions, oxygen and water between the blood and the central nervous system. It serves to block pathogens and toxins from entering the brain and these studies have found correlation between EMR and penetrability of the Blood Brain Barrier. Additionally, IARC (International Agency of Research on Cancer) have found cellphone users have a greater risk of cancer (MSD, 2016). Cumulative exposure is the biggest problem with EMR. It is very hard to determine the cause of issue when so many devices are involved. The various sources of cumulative exposure include 6G, 5G, Wi-Fi and wearable technology. 6G involves THz (Terahertz) frequencies that will have the ability to alter DNA and neurons. It has been determined that 5G and 6G and other high frequency radiation causes tissue and nerve damage (Minar, 2025). The IoT will magnify the effects of EMR as many appliances connect and communicate with each other. Wearable technologies concentrate EMR on the body and range up to 2.4 GHz, which is not advisable to wear and it is not fair to expose others to this device’s radiation (Revolutionhealth, 2025). Unless it is mandatory, wireless medical devices should not be worn (mdasafetech, 2026). It is also known that wireless devices can cause heart issues and it’s extremely ironic they are used to measure heart rate and other general health metrics. As for satellite-based communication, studies need to be made regarding its impact on the environment and biology. The WHO and FCC have already mentioned, in their former studies, that electromagnetic radiation devices are possibly carcinogenic. These same studies are decade’s old and needing review. It should be assumed that at this point, with the massive increase in man-made electrical fields, that scientific evidence is irrefutable and that it does cause harm (Johansson, 2026). Like tobacco and alcohol, outreach/education about the potential harmful impacts of wireless radiation should be readily available with warning labels. At this time, the cellphone and telecommunications companies are largely uninsurable due to the high risks of electromagnetic fields (ehtrust, 2026) (Complete Markets, 2026). Since we are discussing the need for HHS to reevaluate and none of the other branches, we can talk about the need to expand its epidemiological studies to cover the cancer and leukemia issues known to be associated with this as well as harm reduction in classes, libraries, hospitals and public spaces. Every technological product we use has a measurable field. These items should be 3rd party tested and sold with the readings provided and a warning label printed. The packaging should be sold with a label that states its level at microwatts per meter squared (mW/cm2) and each level should be color coded for quick recognition so that we can create a baseline chart that consumers easily understand. Much like the EMR test meters available on the markets, you’ll have Red, Orange, Yellow and Green and these colors correlate to the degree of signal on the object. The FDA will be responsible for labeling and verifying full disclosure is provided to consumers. Public spaces need to be measured and coded as well and if possible, provide Ethernet connections and lower their EMR signal to the minimum necessary. We already have thousands of well researched, published scientific articles online that have spanned 40-50 years. We don’t need to invent the cart; we just need some horses and a destination. Thank you for taking the time to read my comment on man-made electromagnetic radiation and its effects on health. Sincerely, Nicole Stallings

Please see the attached document: my response to the HHS Request for Information on Electromagnetic Fields and Wireless Radiation (HHS-OASH-2026-0397). I am an Electromagnetic Hypersensitive (EHS) person from Israel and an EMF/EMR awareness activist. My life, and my daughter's, have been deeply affected by exposure to EMF/EMR. Since 2006 I have supported EHS people in Israel and worldwide with exposure measurement and reduction, and I run the information site www.norad4u.com. My main points: 1. Many studies show biological and health effects of RF/EMF at levels far below current FCC and ICNIRP limits. 2. EHS is real and is caused and influenced by EMF/EMR exposure. Reducing exposure reduces symptoms. 3. Provocation studies with design flaws (such as Rubin et al., 2006) should not be used to dismiss EHS. 4. Exposure should be measured with fast-sampling meters showing peak values, not averages over minutes. 5. New, health-based exposure guidelines are needed, with special protection for EHS people, children and other sensitive groups. 6. Federal health agencies should track symptoms, EHS cases and exposure, and fund research on how, not if, EMF/EMR causes harm. The attached document answers the RFI questions (Q2–Q17) and includes a numbered list of 134 scientific references. Amir Borenstein Zichron Yaakov, Israel norad4u@gmail.com

Hello - I am asking that the US Government and specifically the HHS organization - ban 5G and take the bold steps to protect the citizens and children on this nation. The EMF's and dirty energy that is present in the automobile industry is causing ill health to many. Attached are some studies that alert you to the KNOW health issues. Protect and provide warnings to the children and citizens who are receiving harm without their kknowledge.

This public comment addresses legal scope, notice clarity, and preservation of objections. HHS describes the RFI as voluntary and nonbinding and may conduct public-health research. See 42 U.S.C. § 241(a); 21 U.S.C. §§ 360ii, 360jj. The solicitation alone is not necessarily ultra vires or reviewable final agency action. 1. CORRECT THE AUTHORITY CITATION. The notice says HHS is proceeding “under 21 CFR subpart J.” 91 Fed. Reg. 59792. The linked eCFR page resolves to 21 C.F.R. Chapter I, Subchapter A, Part 1, Subpart J (food-recordkeeping), not radiological health. The relevant radiological-health grouping is 21 C.F.R. Chapter I, Subchapter J. HHS should correct the link and identify the statutory and delegated authority actually relied on, including as applicable 42 U.S.C. § 241(a) and 21 U.S.C. §§ 360hh, 360ii, 360jj, and 360kk. This defect alone does not invalidate the voluntary RFI, which is not proposed rulemaking. 2. ENVIRONMENTAL HEALTH TRUST IS A LIMITED FCC REMAND, NOT AN HHS MANDATE OR SCIENTIFIC FINDING. In Environmental Health Trust v. FCC, 9 F.4th 893 (D.C. Cir. 2021), the court remanded the FCC’s 2019 order for a reasoned explanation on portable-device testing; children, long-term exposure, wireless ubiquity and technological developments; and environmental effects. The panel took “no position in the scientific debate”; it did not find injury below FCC limits, order new limits, vacate FCC rules, or direct HHS to issue this RFI. HHS’s authority must rest on HHS statutes. The FCC’s 2026 proceeding is limited by the FCC’s remand; that restriction does not automatically limit HHS’s independent research authority. 3. RESEARCH POWER IS NOT UNBOUNDED REGULATORY POWER. Sections 360ii and 360jj authorize an electronic-product radiation program, studies, information, and recommendations. Section 360kk permits electronic-product performance standards, but requires a regulation, APA procedures, statutory scientific and technical considerations, consultations, and committee consultation. This RFI cannot itself impose a standard or replace those procedures. Any ambient-exposure limit untethered to a defined electronic product, infrastructure operating rule, facility-siting restriction, or compulsory measure outside § 360kk must identify a separate affirmative statutory basis. The FCC does not displace all HHS authority; see 21 U.S.C. § 360hh note. 4. CLARIFY THE SCIENTIFIC AND LEGAL SCOPE. Ordinary 50/60-Hz fields from power systems are power-frequency/extremely-low-frequency fields, not RF. HHS should separately assess power-frequency fields; RF from handheld/body-worn devices; RF from fixed infrastructure; occupational exposures; and medical-device compatibility. Distinguish measured from modeled exposure, source proximity from dose, and association from causation. Question 6 asks about health effects “caused by current exposure limits.” HHS should clarify whether it means effects associated with exposure at or below current limits—not effects caused by a regulatory limit. 5. MAINTAIN EVIDENTIARY DISTINCTIONS. Self-selected symptom reports may generate hypotheses but do not alone establish causation or population risk. A synthesis should distinguish reports, diagnoses, biological effects, hazard classification, and quantified risk; address dosimetry, confounding, replication, study quality, null findings, and uncertainty. The notice cautions against submitting PII/PHI; it should not imply identifiable medical records are required. REQUEST. HHS should: (i) correct the citation/link and identify its legal basis; (ii) confirm that the RFI itself imposes no compulsory requirement and is not a substitute for future rulemaking; (iii) not characterize Environmental Health Trust as a scientific finding or delegation to HHS; (iv) clarify Question 6 and separate exposure categories; (v) identify materials materially relied upon in any future consequential assessment to the extent required by law; and (vi) allow supplemental comment if a correction materially changes the stated legal basis or scope. See full file attached

I am submitting this comment to share my personal experience and urge the Department of Health and Human Services to investigate the potential health effects of radiofrequency (RF) radiation and exposure to wireless infrastructure. Around 2020, I began experiencing tremors throughout my body while driving on highways. It took me some time to recognize a pattern. I noticed that these episodes seemed to occur when I was driving near cell phone towers. This raised serious concerns for me about whether my proximity to these towers might be contributing to the symptoms I was experiencing. My functional doctor told me that EMS sensitivity and fragrance sensitivity are common in people exposed to mold. Genetic tests show mitochondrial dysfunction. In 2024, my workplace relocated to a place directly across from a massive cell phone tower. After this relocation, I experienced debilitating symptoms, including intense headaches, difficulty sleeping, and an inability to concentrate effectively at work. I felt that my ability to think clearly, focus, and function as I normally would was being affected. These symptoms interfered with my daily activities and my ability to perform my job. Thankfully, my workplace's Human Resources Department was able to transfer me to another location because of the debilitating symptoms I reported in connection with working near the cell phone tower. I am grateful that my concerns were taken seriously enough for an accommodation to be made. I am sharing this experience because I believe that people who report potentially serious symptoms associated with environmental exposures deserve to be heard, taken seriously, and included in scientific research. I recognize that personal experience alone cannot establish the cause of a medical condition. However, I believe that these experiences warrant careful, independent investigation rather than dismissal without further examination. I urge HHS to support rigorous, independent research into the potential health effects of radiofrequency radiation, including possible neurological symptoms, headaches, sleep disturbances, and difficulties with concentration. Research should also examine individual differences in susceptibility, cumulative exposures, long-term effects, and potential impacts on children and other potentially vulnerable populations. People should not have to struggle to maintain their health and livelihoods without clear, evidence-based answers about the environmental exposures they encounter in their daily lives. I hope my experience will contribute to a broader effort to better understand these questions, protect public health, and ensure that future policies are guided by transparent, independent scientific evidence. Please review regulations to protect citizens and stop the permitting of cell phone towers a few meters away from residential homes, schools, and parks. It is scary the amount cell phones towers in the DFW area, especially in North Texas. Thank you for the opportunity to share my experience and concerns.

Oct 21, 2026 I am writing this at the deadline so it is abbreviated. There is NO question the RF has increased EVERYWHERE even at my rural residence in the woods. I am sensitive to wireless and moved out here to get relief. Unfortunately over the years unaware neighbors have moved in and they automatically use wireless when it's clear they can be hardwired saving themselves and others from over exposure to RF. The Federal goverment needs to encourage hardwiring WHENEVER POSSIBLE and mandate much lower RF maximum power and frequency from the manufacturers of wireless products, mainly routers. The US standards should be in line with the Europeans and the US based Building Biology Institute of less than 10 uW/m2 as the goal!! (www.buildingbiology.com) Another serious problem is malicious people using Wifi repeaters, commercial routers like ATEL and other devices to harass and harm others. They point these devices at unsuspecting people and their residences and pulsing them with harmful microwaves, disrupting their sleep, concentration and productivity completely contrary to how the manufacturer intended the device to be used. I am experiencing this now by someone LOCALLY in my neighborhood. Even though it's against the law, malicious actors know how difficult it can be to first of all understand what's happening, obtain an RF meter, document the evidence, contact an attorney and obtain some shielding to get some relief. Many of these devices can be modified to hack into computers using Tempest attacks and other means. There needs to be a whole police department established by the HHS and/or the FCC to investigate and enforce any current and future RF/EMF standards and laws including seizing equipment that violates those laws at the RESIDENTIAL level not just commercial. The harmful health effects are not just a result of power transmitted but by PULSE and FREQUENCY. The disruption to humans can be caused by low power but a negative pulse rate (frequency). This needs to be considered for any new laws. These harmful RF/EMF not only affect people but animals both domestic and wild. I can tell my cats are affected and try to ground themselves by laying on the dirt to get away from the negative RF. I've noticed how the bees and ants have almost disappeared in my yard. This is a serious problem that affects EVERY LIVING thing and the US needs to investigate the hundreds of studies that have proven this to be true and take ACTION to protect the American people. Thank you.

**Good morning,** My name is Ida Gally, I am 60 years of age and reside in Northern Italy. I suffer from electromagnetic hypersensitivity and chemical sensitivity. As a consequence of these conditions, I have been compelled to relocate to an extremely secluded setting, with serious repercussions for my day-to-day life. My home is quite literally situated in the middle of the woods. And yet, over the past year or so, I have observed a deterioration in my symptoms, which I attribute specifically to the raising of the maximum permitted exposure limits for electromagnetic fields (EMFs) and radiofrequency (RF) radiation. This has given rise to a whole host of difficulties, affecting not only my personal life, but also my practical circumstances and financial well-being. I would respectfully urge you to give rather more careful consideration to the decision to raise these limits yet further. Such a course of action could have profoundly serious consequences for those living with electromagnetic hypersensitivity, but the implications extend well beyond this group. Healthy individuals, too, may be affected by the consequences of increased exposure. It is surely worth remembering that concerns surrounding excessive electromagnetic exposure should not be dismissed lightly. The absence of immediately apparent symptoms does not, in itself, establish the absence of risk, and the potential long-term implications merit the utmost consideration. I would therefore ask you, in the interests of public health and the well-being of all concerned, to exercise due caution before proceeding with any further increase in these limits. Thank you for your time and consideration. Yours faithfully, **Ida Gally**

I have a long history, medically documented of severe EMR Syndrome, (www.emrsyndrome.org). It is difficult for me to go out. I have trouble walking due to a mobility impairment. The neighbor’s WiFi, wireless security systems, especially the newer ones, exacerbate my disability. The smart meters are especially difficult for me because our houses are so close to each other. I cannot tolerate using a computer and have asked Pennsylvanians for Safe Technology to submit my comment. Please work for a safer FCC guideline, for analog meters and to allow me to keep my landline, it is my lifeline. I am isolated. At a time when everyone has a communication device strapped to their fingertips, I am not able to do that, and they are planning to take away my only way to communicate with those outside my house, my landline. With my disability it is so unthinkable to not have a way to communicate, to make a simple phone call, even in an emergency. Here are a few medical references to support my case: • a 2025 review: Panagopoulos DJ, Yakymenko I, De Iuliis GN and Chrousos GP (2025) A comprehensive mechanism of biological and health effects of anthropogenic extremely low frequency and wireless communication electromagnetic fields. Front. Public Health 13:1585441. doi: 10.3389/fpubh.2025.1585441. https://www.frontiersin.org/journals/public-health/articles/10.3389/fpubh.2025.1585441/full • Panagopoulos, D. ed. (2021). Electromagnetic fields of wireless communications: Biological and Health Effects. CRC Press. http://dx.doi.org/10.1201/9781003201052. • 2021 petition to HHS/FDA: https://manhattanneighbors.org/alert-petition-filed-for-imminent-hazard-rulemaking-by-the-u-s-department-of-health-and-human-services-hss-over-fcc-wireless-technology-exposure-guidelines/

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.