Exposure limits & oversight

Eileen O’Connor Director and Co-Founder EM Radiation Research Trust 16 October 2026 To: U.S. Department of Health and Human Services (HHS) Re: RF/EMF Exposure and Human Health: Response to Request for Information Docket No.: HHS-OASH-2026-0397 Dear Sir or Madam, Please find attached my submission, RF/EMF Exposure and Human Health: Response to the Request for Information, submitted on behalf of the EM Radiation Research Trust. The submission draws on my personal experience, concerns raised by affected communities, scientific literature, and many years of research, public engagement and campaigning on radiofrequency electromagnetic fields (RF/EMF) and human health. It highlights concerns regarding the assessment of health risks associated with RF/EMF exposure, the need for independent research and transparent evaluation of the evidence, and the importance of meaningful public engagement in decisions affecting public health. I am also providing the ECOLOG report (2000) concerning mobile telecommunications and health effects as a supplementary PDF for HHS to consider alongside my submission. Both documents contain references to scientific studies and relevant literature concerning RF/EMF exposure and human health. I respectfully urge HHS to examine these references and consider the research and evidence presented in both documents as part of its review. In light of the serious public health concerns raised and the continuing scientific debate surrounding RF/EMF exposure, I urge HHS to give urgent consideration to the precautionary principle and implement appropriate measures to protect public health. Action to reduce avoidable exposure should not be unnecessarily delayed while further independent research and transparent scientific assessment continue. Protecting the public must remain a priority, with particular attention to potentially vulnerable groups, including children. I respectfully request that both documents, together with the scientific references they contain, be considered as part of the HHS review and included in the relevant public record, in accordance with the applicable submission procedures. Thank you for the opportunity to contribute to this important public health matter. I hope these materials will assist HHS in its consideration of the scientific evidence, the concerns of affected communities, and the urgent need for effective, transparent and precautionary measures to safeguard public health. Yours faithfully, Eileen O’Connor Director and Co-Founder EM Radiation Research Trust www.radiationresearch.org UK registered charity established in 2003 Charity No. 1106304

In 2012 I developed Electromagnetic Radiation Syndrome (EMRS)* after being exposed to high levels of pulsed microwave radiation from two smart meters. To this day when I am exposed to a certain level of microwave radiation (for example, riding in a modern car where the wireless tech cannot be turned off or at an event with a lots of people, hence a lot of phones) I experience debilitating symptoms, such as brain fog, fatigue/exhaustion, pressure in my head, and whole body irritability. Not only has this technology posed very real challenges for me, I am also very concerned for my children and children in general. Kids are now exposed to this technology from the start, 24/7; and who is considering or measuring the amount of radiation children are exposed to in schools. We are in need of robust regulations and updated exposure limits that truly reflect the scientific studies that are available. I have included a number of studies that demonstrate the urgent need to update exposure limits. *https://www.emrsyndrome.org/

I am submitting this comment with my perspectives 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. I am responding from several perspectives: as a software engineer with extensive experience working with technology and electronic systems; as a person who has experienced significant symptoms that I associate with exposure to electromagnetic fields and wireless radiation; and as a professional who has spent the past several years measuring and documenting electromagnetic field exposures in my home and other environments. In January of 2022 I eliminated wireless technologies completely from my personal environment and whenever feasible reduced or distanced myself from electric and magnetic emissions. These changes improved my health and allowed me to reengage with the world. Unfortunately, avoidance of wireless technologies required changes that permanently affected my career, family, and personal life. It is impossible to avoid being exposed to all wireless and electromagnetic emissions. Radio frequency exposures from sources which are not my own continue to aggravate my symptoms and limit my life. I don’t want to feel these symptoms anymore when doing normal things like working in an office, walking into a store with an overpowered mesh / wifi system, going to a concert, restaurant, bar, or visiting family or friends. Over the last few years, I learned more about detection, identification, measurement, and mitigation to electromagnetic emissions. My sister became a Building Biology Institute-certified Electromagnetic Radiation Specialist (EMRS). Together we develop practical methods for detecting, measuring, documenting, and reducing electromagnetic exposures. Using these strategies we have significantly improved my functionality and not only am I back at the computer, but I have developed a web application that shows electromagnetic emissions and measurement statistics spatially. I have become particularly concerned that consumers are uninformed about the specifications of a product’s wireless features and have limited or no control over those features. Technology will continue to develop faster than long-term health research and regulatory processes can reasonably keep pace with it. Additionally, the way RF exposure is evaluated does not always reflect the conditions people experience in their daily lives. I therefore encourage HHS to consider these particularly practical areas for regulatory and technology standards: Wireless devices should provide a genuine, user-accessible means of turning off wireless emissions, rather than merely hiding wireless functionality or placing a device into a mode in which emissions continue. Cellular phones should support calls and text messaging when the phone is connected through a wired Ethernet connection to a router, so that consumers who choose a wired network connection can use their phones for these functions without requiring an active wireless connection. Products should be required to display prominently on the packaging standardized consumer-facing RF exposure information, similar in concept to other standardized product information that allows consumers to compare products and make informed choices. the type, number, frequencies and transmission characteristics of a device; how to reduce unnecessary close-proximity exposure; how to use wired alternatives where available; how to disable wireless functions completely; whether a device continues transmitting while in standby or charging; whether simultaneous transmitters were evaluated; whether children or other populations were specifically evaluated; and what exposure conditions were and were not included in testing. I am particularly concerned about exposure involving children, infants, pregnancy, and other populations that may differ from those of a typical adult. Children may spend many hours in schools and childcare facilities surrounded by multiple wireless transmitters, sometimes at very close distances. Wireless devices are also increasingly incorporated into products used by infants and children. Federal research and exposure assessment should therefore specifically address age-specific and developmental exposure scenarios rather than assuming that adult testing adequately represents all populations. I also believe that federal research priorities should include long-term, independent investigation of cumulative and chronic exposure, children and pregnancy, reproductive and developmental outcomes, neurological and sleep-related effects, cardiovascular and other biological effects, environmental and ecological effects, and exposure associated with evolving technologies such as 5G, future wireless systems, IoT devices, wearables, smart homes, wireless medical devices, and increasingly dense wireless infrastructure. See attached file.

DECLARATION OF Stephen Bonney declares under penalty of perjury as follows: 1. I reside in Fort Gratiot, Michigan. 2. I did not consent, nor do I consent today, to the continuous, involuntary exposure to biologically active RF radiation. 3.My experience with radiofrequency (RF) radiation started about eight years ago when I began feeling a tingling/burning sensation in my hands and forearms. I discovered that staying in different rooms in my house could make the sensation better or worse. I also started getting headaches and lightheadedness. I had no idea the cause. I thought maybe one of my neighbors might be doing something that created some kind of strong field, like maybe a ham radio. I went on the computer and started doing some research. I ended up buying a meter that read electric, RF and magnetic fields. I got high readings but I still couldn't detect where they were coming from. I then hired a couple of building biologists with far more sophisticated meters. They were able to trace the source to a nearby intersection. It was there they found a yagi antenna used for sending communication signals between intersections for fire and emergency response purposes. Since I couldn't do anything about removing this antenna I had to employ blocking measures at my house, which I was able to do well enough to at least keep living there. But I can no longer work in the yard. My physical sensitivities to RF radiation have gotten worse over the years due, I'm sure, to repeated exposures from other sources. I have eliminated as much RF in my personal life as I can : no cell phone, no wireless devices of any kind in my house or car. But I know I'm almost constantly bombarded by RF when I'm out in the world and I feel it's taking a toll on my physical health. We're getting hit with this poison from in front, behind, the sides and above. There's hardly anywhere to escape it. I declare under penalty of perjury that the foregoing is true and correct. Date: 10/12/26 (Name) Stephen Bonney https://pubmed.ncbi.nlm.nih.gov/24192494/ Radiation from wireless technology affects the blood, the heart, and the autonomic nervous system https://pubmed.ncbi.nlm.nih.gov/39108419/ Hypersensitivity to man-made electromagnetic fields (EHS) correlates with immune responsivity to oxidative stress https://pubmed.ncbi.nlm.nih.gov/32289567/ Electromagnetic hypersensitivity (EHS, microwave syndrome) - Review of mechanisms

Question 2: Individual consumer, parent, and health advocate focused on children’s cumulative exposure and the adequacy of current standards. Current U.S. RF/EMF limits address only short-term thermal effects. They do not account for non-thermal mechanisms (voltage-gated calcium channel activation, oxidative stress, glutathione depletion, mitochondrial strain) documented in the majority of experimental studies at intensities below those limits (Pall 2013; Yakymenko et al. 2016). IARC’s Group 2B classification remains in effect. Children face higher relative absorption and lifetime cumulative exposure. Question 5 / Standards: Federal agencies should evaluate ICNIRP/FCC thermal-only guidelines against biologically based approaches and the existing non-thermal evidence base. Thermal-only standards are not adequate for chronic, multi-source, real-world exposure. Question 16 — Highest-priority research gaps (ranked): 1. Oxidative stress and glutathione status (GSH/GSSG, MDA, 8-OHdG) in humans under measured real-world exposure, especially children. 2. Prospective cohort of school-age children with personal RF dosimetry linked to sleep, neurodevelopmental, and oxidative markers. 3. Independent replication of VGCC and mitochondrial effects at non-thermal intensities with full exposure characterization and sham controls. 4. Standardized observation of self-reported intolerance presentations correlated with objective oxidative biomarkers. 5. Intervention studies of exposure reduction (wired classrooms, nighttime shutdown, distance) plus glutathione-support protocols. Questions 7–9: Current SAR testing does not capture multi-source, body-contact, or cumulative exposure. Require real-world dosimetry, plain-language disclosure for schools and residences, and public reporting of infrastructure density near sensitive sites. Immediate actions possible with existing authority: • Redirect a portion of existing research funds to the gaps above with mandatory conflict-of-interest disclosure. • Issue interim guidance: distance from devices, no body-contact use, routers/phones out of bedrooms, prefer wired for fixed high-use applications. • Update federal procurement and school facility guidance to prefer Ethernet/fiber for fixed connections while retaining wireless for true mobility. • Systematically collect clinical observations rather than dismiss them. Preferring wired/fiber for fixed applications does not reduce technological capacity; fiber routinely outperforms wireless on bandwidth, latency, and security for schools and offices. Hybrid designs preserve mobility. Full mechanistic detail, references, and expanded recommendations are in Attachment 1.

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 someone struggling with her own health issues, while seeing others struggle, as well. Also, as someone who is familiar with research suggesting radiation causes harm far in excess of anything paid shills for the industry are willing to admit. On a strictly experiential level: Radiation exposure is a lot like boiling a frog. The frog doesn't know what's happening, but it feels unwell, it has lost and continues to lose function and a baseline sense of well-being, and eventually, unless it's removed from the cooking pot, it will die. When I moved out of an apartment building blighted with a high density of WiFi signals... to a location with fewer WiFi routers per square mile, I started to sleep better, and other issues eased, as well. I'm still being boiled in all the other sources of radiation (cell phones and cell phone masts, smart meters, etc), but even this minor change has made an appreciable difference in my sleep. How much more lost function and productivity (over the past years) might I regain in an environment without all this toxic, weapons-grade radiation… that our own military used to admit was a threat to the health and preparedness of its troops! How many more of my health issues might reverse, if I didn't have to endure radiation levels up to a million times normal background radiation which our bodies and brains have historically been exposed to! How much more functional and healthy and happy might our children be, and all of our society be, without this pervasive and unprecedented toxic exposure! The failure to properly investigate and regulate radiation is nothing short of a crime against humanity. Ecocide, too. One way or another, the truth will come out. Better it come out sooner, to spare us needless suffering, and spare our planet the needless loss and extinction of its most vulnerable species, starting with insects and birds, but including our precious children. The link between radiation and biological harm is established for any who are courageous enough to acknowledge it. I urge HHS to take 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 ALL these experiences AND the scientific evidence, identify gaps in current research, give espeical attention to children and other potentially vulnerable populations, and establish appropriate federal research priorities regarding wireless radiation and public health. Thank you for providing me this opportunity to be heard.

While the Tech is incredible, yes, the EMF is something to consider. It's important we safeguard ourselves and our children's futures moving forward.

Release the information

Public Comment on HHS Request for Information: EMF/RF Exposure and Human Health Docket No. HHS-OASH-2026-0397 I submit this comment as a concerned consumer urging the Department of Health and Human Services (HHS) to put public health, independent science, and informed consent ahead of commercial interests when evaluating radiofrequency electromagnetic field (RF/EMF) exposure from wireless devices and infrastructure. Wireless technology is everywhere, from phones and Wi-Fi to wearables, smart meters, and cellular networks. Consumers cannot assess safety when exposure information is hard to find and testing may be funded by companies that profit from the products. The public deserves transparent answers. I do not claim every RF/EMF exposure causes illness or that every alleged harm is established. HHS should identify what is known and unknown, without treating uncertainty as proof of safety or speculation as proof of harm. Policy must follow transparent, reproducible science, free from commercial or advocacy pressure. I urge HHS to prioritize these actions: 1. INDEPENDENT THIRD-PARTY TESTING. Require qualified labs independent of manufacturers and telecom companies to test devices and infrastructure. Disclose funding, conflicts, methods, calibration, exposure conditions, analyses, and full results. Publish positive and negative findings and make testing reproducible. Industry-funded research must not be the sole basis for declaring a product safe. 2. REAL-WORLD AND CUMULATIVE EXPOSURE. Assess ordinary and high-use scenarios, multiple devices together, and long-term exposure in homes, workplaces, schools, childcare facilities, and neighborhoods. Consider distance, duration, frequency, signal strength, and actual use. Measurements must be independently verifiable and explained plainly. 3. LONG-TERM HEALTH RESEARCH. Fund adequately powered, independently replicated long-term human studies, systematic reviews, and laboratory research on reported concerns involving cancer, cognition, sleep, reproduction, development, cardiovascular outcomes, and other effects. Studies must distinguish correlation from causation, address confounding factors, publish protocols and null findings, and share data when ethical and privacy rules permit. 4. PROTECT VULNERABLE GROUPS. Assess whether added precautions are warranted for children, pregnant people, older adults, people with medical conditions, exposed workers, and users of medical devices. Include schools and childcare facilities. 5. CLEAR CONSUMER DISCLOSURES. Require accessible disclosures of emissions, limits, independent test results, test conditions, limitations, and uncertainty. Explain implications for normal and cumulative exposure. Create a searchable public database of test and adverse-event reports. Marketing must not substitute for evidence. 6. PUBLIC HEALTH MONITORING. Create privacy-protecting systems to report suspected health effects. Investigate credible patterns with validated exposure measurements and clinical assessment. Reports should prompt investigation, not prove causation automatically. Coordinate research and publish findings. 7. ACCOUNTABILITY WHEN HARM IS ESTABLISHED. If reliable evidence shows that a company's product, emissions, concealment, or failure to comply with safety requirements caused or materially contributed to injury, consumers should have meaningful remedies. Congress and regulators should consider requiring responsible companies to cover reasonable medical evaluation, treatment, ongoing care, and appropriate compensation. Companies that knowingly conceal credible safety findings, falsify results, or obstruct required disclosures should face meaningful penalties. Responsibility must be determined fairly, based on evidence, causation, and applicable law. 8. INDEPENDENT OVERSIGHT. Disclose conflicts, publish the basis for conclusions, invite independent peer review, and explain how conflicting evidence is weighed. Review standards as technology and science evolve. Publish who funded studies, what was measured, and why conclusions were reached. Consumers deserve information about possible risks, and should not bear the full financial burden if evidence establishes preventable harm. Transparency encourages safer design, honest communication, and better science. I urge HHS to establish rigorous, independent, publicly accountable RF/EMF research and oversight. Where evidence identifies a risk, take proportionate action. Where evidence is uncertain, fund better research and communicate uncertainty honestly. Where evidence does not support an adverse effect, explain that conclusion and the strength and limits of the research. Commercial confidentiality should never hide information essential to public health. The public deserves independent testing, accessible data, protections for vulnerable populations, and medical and financial remedies when harm is demonstrated.

We are citizens and not to be cooked by microwave radiation. End injurious government.