Exposure limits & oversight

Declaration of Heidi Brenneman: I reside in Lewis County, Washington. I did not consent, nor do I consent today, to the continuous, involuntary exposure to pulsed modulated, biologically active electrical and radiofrequency / microwave (RF/MW) radiation. The health effects of such have been widely studied by government agencies including from the US Navy in 1972 and by thousands of scientists worldwide. You need only look so far as the International Appeal to Stop 5G on Earth and in Space which was signed by over 24,000 professionals demanding a response to what can only be called a crisis brought on by lack of proper public policy on wireless technology. Dr Martin Pall, Professor Emeritus from Washington State University, has studied the effects of RF on the body. His work shows that RF radiation causes oxidative stress and leads to the depletion of glutathione which is critical in melatonin production. His overall assessment is that the damages caused by RF radiation are causing a tidal wave of dementia which we are seeing at earlier and earlier ages. I lost my mother, my mother-in-law, my 64 year old sister-in-law, two uncles and now my own husband is in Stage 5 early onset Alzheimers at age 67. This is not genetic. My father died in 2017. He had spent his last few years unable to sleep. My Mom's memory started failing in the early 2010's. I believe both my parents suffered from the installation of a smart meter as neither had a cell phone and they did not have wifi. As a normal consumer and well educated professional, I did not have any clue that the tech I was using in my work and personal life could be harmful. In 2010, the time of the installation of the smart meter on my home in Oregon, I became unable to sleep and became extremely anxious and depressed. These are symptoms caused by exposure to pulsed radiofrequency radiation. I'd get what felt like restless leg syndrome but all over my body. It turns out that response was from an increasing sensitivity to all electronics. The trigger was the new smart meter. At the time, I did not know what was causing my symptoms. I went to my doctor and sought treatment. I'm now on SSDI. I spent two years trying to treat a mental health condition that only existed as the result of the exposure to EMF to which I'd become increasingly sensitive. And the medication could not help an ongoing toxic exposure. It was adding another biological insult to one of the very systems that's electrical in nature and that's damaged by EMF exposure - the nervous system. By 2015, I'd lost the ability to read more than a few paragraphs and I struggled to write my own name. The fatigue was so bad that when I went shopping for groceries, I had to hold onto the cart just to get around the store. At age 46, I had people stop me and ask if I was OK. Any stress resulted in extreme outbursts as EMF exposure symptoms include irritability which isn't surprising because when your body is under constant assault, you are in a high cortisol state. In 2017, we moved to a rural community where I thought I'd be safe. We had no wireless devices. The smart meter was only the kind that could be read once a month by a truck when they drove by taking readings. My health improved. But in 2024, the meters were changed to a constantly pulsing type and my health became absolutely devastated once again. I became unable to leave my home. After a few months, we removed the meter but the damage was done. I'd become so sensitive to all EMF fields, I could no longer tolerate my own home. I moved my old motorhome to my pasture where I measured the lowest fields (RF, AC and magnetic) and I lived out there without running water and with little electricity. After several months, I made the difficult decision to move again which meant packing all of our belongings by myself as my husband could not remember if he was packing or unpacking a box. The process of even looking for another home was so brutal, I had to be helped out of many homes. Because every county surrounding me had moved to smart meters for power, I could not properly evaluate other fields. I finally gambled and settled. Here we pay $35/month for the privilege to not be irradiated by our meter. I still often sleep in the motorhome. My symptoms include burning sensations, screen dermatitis, dizziness, heart palpitations, chronic insomnia, cognitive fog, extreme fatigue, irritability and an inability to concentrate. I have debilitating digestive issues I believe are being caused by over exposure when I do try to live like a normal human being. Everyone including Social Security is now requiring a cell phone for identity verification to access services online. I find it repulsive to have to pay for the technology that's destroying everything I love including me. Technology that is offensive biologically and disabling to a human being should not be a mandatory exposure by design of our infrastructure.

See attached file(s I have been injured by all of the wireless devices starting with the roll out of smart meters in Illinois. You all need to update the safety levels - I was forced to move out of Illinois because your department has failed in keeping up to date with safe wireless frequencies levels. I have been under the care of a medical specialist for years. I can no longer fly on an airplane, or live a normal life - cannot even own a new car with all of the WIFI and other wireless devices. It is a shame that as an American born free citizen I cannot live free in America because of the low levels your department has set as safe. Please follow the Building Biologist guideline for safe level so I can live free again.

We need to expose the radiation of our technology, so people know and can help limit it or reverse it.

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 parent, employee & member of a community where exposure is outside my control. As someone who knows the health impacts of these frequencies, I do not think it is right that we cannot avoid them with our own discernment. I also am appalled that there continues to be rollout without care for the well being of others. There needs to be a stop to rolling out products where impacts have not been studied but if we begin seeing humans harmed in studies, we need to discontinue at all costs. I support HHS taking an active role in examining the health and environmental effects of wireless radiation. Experiences of individuals and families who report being affected should be considered alongside evidence from studies using true scientific process. 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. Thank you for providing individuals and families with an opportunity to be heard.

I have experienced the adverse health effects of EMFs exposure on myself. Example 1: Time ago I had an hour long phone conversation. During the conversation I held the cell phone close to my right ear almost all the time. For the next three days I experienced an inflamed bloated red ear and swollen glands in the neck. I did not seek medical attention. The symptoms faded naturally over time. I became concerned about the potential long term health effects of that exposure. I started using either wired or Bluetooth earphones to talk on the phone. I try to keep the cellphone away from the body as much as possible. Example 2: I have a Wi-Fi router in the home. If I stay close to it longer than 30 or 40 seconds I start feeling dizzy. As soon as I move away from it the dizziness disappears. I imagine there's scientific research about the negative health effects of EMFs exposure. Personally I do not need to see any scientific proof of it, because I already know that EMFs exposure can have adverse health effects. I have personal direct experience of the issue. I know there are people particularly sensitive to EMFs exposure that unfortunately experience harsher symptoms compared to the symptoms I had. Urban environments concern me the most because of the high concentration of EMF emitting devices like cell towers and antennas. I urge the current administration to consider any reasonable measure to limit the exposure of people to EMFs, hoping that public health will be considered (as it should) of higher priority over profit. Thank you for your attention.

Re: Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure — Docket No. HHS-OASH-2026-0397 Submitted by: Charles J Foster II, amateur radio callsign KS0VO, Kansas Perspective (Question 2). I respond as a licensed amateur radio operator and an ARRL Volunteer Examiner — an individual with sustained, hands-on proximity to RF transmitters, and a volunteer who helps administer the licensing examinations through which new operators, including minors, enter the amateur service. My comments rest on operating experience and the published guidance of the amateur service, not on medical or laboratory research. I offer them on the practical questions: how exposure actually occurs, how it is measured, and what the public is told. Questions 5(p) and 8 — exposure assessment should reflect how transmitters are really used. Any classification or assessment system has to account for the characteristics that dominate real exposure: duty cycle, modulation, distance from the source, and cumulative exposure over time. In amateur operation alone, duty cycle runs from near-continuous (FM voice, some digital modes) to roughly a fifth of transmit time (single-sideband voice), and exposure falls off fast with a few feet of separation. Current assessment methods lean on standardized assumptions, and real-world measurement remains weak: a consumer or licensee who wants to characterize the exposure in their own home or around their own station has few affordable, calibrated options and no common standard to measure against. HHS should treat better real-world exposure characterization — including cumulative, multi-source exposure — as a methods and research priority. Questions 5(n) and 9 — disclosure. What should be disclosed, in plain language, is what a non-engineer needs to make sensible choices: a device's transmit power and duty characteristics, the separation distance it was tested at, and what its exposure numbers assume about how it is held and used. Today, SAR values sit in certification filings few consumers ever see, and manuals describe separation distances that ordinary use ignores. Standardized disclosure at the point of sale and in the device itself would cost little and would let families, schools, and employers act on real information instead of reassurance or alarm. Question 11(a) — children. Children merit separate assessment. There is no minimum age for an amateur license, and young operators' first transmitter is typically a handheld radio held at the face. Whatever HHS concludes from the evidence, children differ from the adults the current framework was built around: smaller bodies, developing tissue, and the longest remaining lifetime over which exposure accumulates. The assessment should say so explicitly rather than treating them as small adults. Question 13 — cumulative exposure. Exposure in 2026 is layered: commercial mobile and broadcast services, Wi-Fi, wearables, smart meters and appliances, and — in a home like mine — a licensed amateur station. Each source is assessed largely on its own; nobody's framework describes the total. HHS should characterize cumulative patterns as people actually experience them, including amateur and occupational sources alongside consumer ones. Question 16 — research gaps. The highest priorities from a practitioner's seat: (1) long-term studies using modern waveforms and realistic duty cycles rather than continuous-wave stand-ins; (2) standardized, reproducible dosimetry so studies can be compared and replicated; (3) research on portable devices used at zero separation distance, and on children. Question 17 — coordination. HHS should place its completed assessment into the record of FCC Docket No. 13-84, where the FCC is answering a court remand on these same exposure questions. The FCC is an engineering agency, not a health agency; its remand response should rest on a current, transparent health-agency record rather than on reviews that predate today's exposure environment. Question 18 — closing. Distinguish clearly, as this RFI promises to do, between established evidence, emerging findings, and open questions — and say plainly where the honest answer is "not yet known." That candor is what will make the eventual guidance worth trusting. Respectfully submitted, Charles J Foster II, KS0VO ARRL Volunteer Examiner Belvue, Kansas

I humbly submit the attached technical remark in response to the U.S. Department of Health and Human Services’ Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure, Docket HHS-OASH-2026-0397. My submission is based on more than ten years of professional experience in RF engineering, wireless network design, spectrum management, interference analysis, LTE/5G network optimization, and regulatory engineering compliance. The enclosed study addresses Questions 2, 5-9, 11-13, and 15-18 and concerns RF exposure standards, measurement methods, new 5G/6G technologies, scientific evidence, wireless infrastructure, and federal research goals. I urge that HHS improve uniform exposure assessment, enhance coordination among federal agencies, fund independent research, and analyze emerging scientific data in conjunction with established FCC, IEEE, and international exposure recommendations. My entire engineering analysis, recommendations, and scientific references are in the attached file. I make these opinions in a personal capacity and not as a representative of my employer.

As a family practice physician, I see patients in my practice who present with symptoms of EMR Syndrome. The core problem I face in treating them is that EMR Syndrome is not a recognized medical diagnosis.There is no ICD code, no diagnostic criteria, no clinical guidelines, no biomarker panel, no medical school training. A family physician who takes a patient's EMF-related symptoms seriously has essentially no institutional scaffolding to work with. Here's what HHS could change to help patients: 1. Create a dedicated ICD-10-CM diagnostic code (the single most important step) Right now, PCPs can only code EHS as a workaround: W90 (exposure to nonionizing radiation) + individual symptom codes (R51 headache, R53 fatigue, G43 migraine, etc.) + R68.8 (other specified general symptoms). The Nordic Council did this in 2000; EUROPAEM recommends it in Europe. HHS could: Petition the WHO ICD Steering Committee (as the US representative) to add a new code to ICD-11, which CMS would then map into ICD-10-CM Or, more quickly, issue a CMS national coverage determination that formally recognizes the W90 + R68.8 combination as a valid diagnostic entity for reimbursement purposes Without a code, insurance won't cover extended visits, environmental assessments, or treatment — so the patient is out of pocket and the PCP has no billing pathway. 2. Issue clinical practice guidelines through AHRQ AHRQ (Agency for Healthcare Research and Quality) funds and publishes practice guidelines. HHS could commission an AHRQ-sponsored consensus panel to produce a "Diagnosis and Management of Electromagnetic Radiation Syndrome" guideline that defines: A case definition (e.g., ≥2 of the core symptoms + temporal correlation with EMF exposure) A standardized workup (what tests to order, what to rule out) A treatment algorithm (exposure reduction, symptom management) Documentation requirements for coding and insurance There's already a preliminary Canadian guideline by Dr. Riina Ines Bray (University of Toronto, 2016) that could serve as a starting point. 3. Fund and validate biomarker panels through NIEHS/NIH This is the long game but the one that would make ERS a "real" condition in the eyes of the medical establishment. NIEHS could fund: Multi-center studies validating the most promising candidate markers: HRV (heart rate variability) changes, oxidative stress markers, GSTM1/GSTT1 null polymorphisms (nearly 10× more common in EHS individuals), reduced melatonin, elevated histamine, mitochondrial dysfunction markers If NIEHS publishes a validated biomarker panel, PCPs would have an objective test to order — the equivalent of a blood test for an allergy. 4. Mandate medical education HHS (through the National Library of Medicine / NLM and the AAMC relationship) could require: EMF/ERS in medical school curricula — a module on environmental and electromagnetic health effects in the preclinical or clinical years CME credits for continuing education on EHS diagnosis and management A standardized environmental/EMF exposure history form built into electronic health records (EHRs), similar to the tobacco/alcohol history that's now standard Right now, most PCPs have never heard of EHS or have been taught (via WHO guidance) to treat it as psychosomatic. 5. Reverse the "psychosomatic" framing The WHO's 2009 statement — that EHS should be treated as a psychological condition and that "treatment should not focus on reducing EMF exposure" — is the single most damaging document for clinical practice. HHS could: Issue a formal HHS position statement that acknowledges ERS as a valid clinical entity requiring environmental exposure assessment Fund patient advocacy and education through the National Institute of General Medical Sciences This matters because PCPs who are told by the world's top health agency that the condition is "psychosomatic" will not take it seriously, no matter what the patient describes. 6. Create a federal EHS/ERS clinic network Switzerland launched a national EHS consultation service in 2023. HHS could: Designate a small number of academic medical centers as ERS referral centers (similar to the rare disease center model)portunityp Fund outpatient clinics with environmental medicine specialists, occupational hygienists, and EMF measurement equipment Create a telehealth referral pathway so a PCP in rural America can consult with an ERS specialist without sending the patient 500 miles 7. Create CPT reimbursement codes for environmental health assessments CMS could add new CPT codes or expand existing environmental medicine codes to cover these. Please offer another follow-up comment period like this since many of us are just finding out about this opportunity to share our thoughts and clinical experience.

Response to Questions 5, 8, 9 and 11 I am Erin Finegold, founder and CEO of StingRay Shields Corporation, a company developing passive antenna-related RF structures. My work gives me a direct professional interest in RF-exposure measurement and engineering approaches to reducing exposure. I urge HHS to recommend lower, more protective radiofrequency (RF) exposure limits and stricter Specific Absorption Rate (SAR) compliance requirements. The FCC’s SAR limits were adopted in 1996. Wireless technologies and patterns of use have changed substantially since then. Protective requirements should address prolonged body contact, exposure involving multiple transmitting devices, and children’s use. Recommendations should lead to enforceable improvements in consumer protection, rather than stopping at calls for additional research. HHS should fully assess published findings of adverse biological effects and their relevance to human exposure, drawing on international research and examining funding sources and potential conflicts of interest. Consistent standards of scientific rigor should apply to all evidence. Scientific uncertainty should not be treated as proof that existing protections are sufficient. Compliance testing should include direct-contact body testing wherever such contact is reasonably foreseeable, including phones carried against the body. Any exceptions should be technically justified and publicly disclosed. Reports should distinguish head-contact testing from body testing, identify any separation gap, and explain how direct-contact exposure is addressed. Consumers should not bear responsibility for maintaining separation distances they may not understand or consistently observe. Children’s protection should be an explicit requirement. Test methods and exposure assumptions should account for relevant ages, anatomical differences and patterns of use. Where adult-derived models are used, manufacturers should demonstrate that those models adequately protect younger users. Public reports should document device configuration, operating frequencies, conducted transmit power, antenna placement, device-to-body separation, test methods and measurement uncertainty. Methods and results should be independently inspectable and reproducible, with clear disclosure of the conditions under which compliance was established and any limitations relevant to ordinary use. Consumer protection also requires effective enforcement after devices enter the market. France’s ANFR has required corrective measures, including software updates, market withdrawals and recalls, following findings of SAR noncompliance. I urge HHS to recommend routine independent testing of marketed devices, public disclosure of findings, and prompt mandatory corrective action, including sales restrictions and recalls where necessary. Manufacturers should remain accountable for compliance throughout the product’s marketed life. Stronger requirements should encourage engineering improvements that reduce exposure. Claimed reductions should be independently evaluated alongside their effects on radiated efficiency and communication reliability. Supporting references are provided in the attached PDF.

Thank you for the opportunity to submit information regarding biological effects and potential health hazards of low-level, long-term exposure to radiofrequency radiation (RFR). I am an environmental engineer and scientist. I began my career in 1980 as a groundwater hydrologist and geochemist. Since 2017 I've been researching and writing about the biological effects and potential health hazards of man-made electromagnetic fields (EMF). I am uploading here two technical reports I co-authored in 2019. The first one is a review of the scientific literature regarding potential health hazards of radio towers and cell phone base stations ("cell towers"). The second one is a set of maps we made to display visually the levels of RFR we measured throughout several residential neighborhoods. We provided the reports to the planning commission and the city council in Davis, California, in support of the town's project to update its ordinance governing the siting of mobile phone base stations (cell towers). I hope the two reports will be useful to you, as well as to anyone else who finds them here. The maps contained therein are fairly unique in that they contain many data points. Doing so makes it easy to see clearly the dispersion pattern of radiofrequency radiation around each cell tower. I am also uploading a one-page table outlining certain biological effects and the associated levels of RFR radiation. It helps to provide additional context for the maps.