BREAKING: HHS Opens the Federal Record on Wireless-Radiation Health Risks * RF SAFE® Radio Frequency Safe

Secretary Robert F. Kennedy Jr. has signed a sweeping federal Request for Information on electromagnetic fields, radiofrequency radiation, and wireless exposure. It reaches far beyond the old question of whether a device heats tissue. HHS is asking about biological effects below current limits, pulse and modulation characteristics, cumulative exposure, children, pregnancy, disease registries, infrastructure near schools, environmental effects, disclosure, exposure reduction, and the future roles of FDA, NIH, and CDC.

For RF Safe, this is the policy opening we have spent more than three decades demanding.

On September 17, 2026, the Department of Health and Human Services placed a notice on public inspection titled Request for Information on Electromagnetic Fields, Radiofrequency Radiation, and Wireless Radiation Exposure. It is scheduled for publication in the Federal Register on September 21, 2026, as document 2026-19252. The notice is signed by HHS Secretary Robert F. Kennedy Jr.

This is not yet a new exposure limit, a completed health assessment, or an enforcement action. It is the opening of a federal evidence record. What enters that record—and what HHS does with it—can shape national research, public-health guidance, product-radiation policy, disease surveillance, school practices, consumer disclosure, and the scientific advice supplied to the FCC.

The immediate action: Submit one evidence-based comment to HHS Docket HHS-OASH-2026-0397. The public-inspection notice says comments are due 30 days after Federal Register publication. If publication occurs as scheduled on September 21, the expected deadline is October 21, 2026; verify the final date on the live docket before filing.

Open the HHS docket on Regulations.gov

Read the complete HHS notice

Why This Notice Is Different

Federal wireless policy has long been trapped inside an artificially narrow frame: prevent excessive short-term heating, express compliance mainly through power density or specific absorption rate, and assume that exposures below the resulting limits are adequately protective.

The new HHS notice does not accept that narrow frame as the only question worth asking. It explicitly requests evidence about:

potential adverse effects at levels below current federal limits;
children, pregnant women, older adults, workers, people with implanted devices, and people with preexisting conditions;
long-term and cumulative exposure;
operating frequency, power density, SAR, electric- and magnetic-field strength;
modulation, pulse characteristics, duty cycle, and beamforming;
simultaneous exposure to multiple frequencies;
distance, near-body use, exposure duration, and real-world use patterns;
5G, 6G, Wi-Fi, satellites, wearables, smart meters, the Internet of Things, smart homes, smart cities, autonomous vehicles, and wireless medical devices;
disease registries, longitudinal cohorts, biomonitoring, adverse-event reporting, exposure monitoring, and illness clusters;
wireless infrastructure near homes, schools, childcare facilities, healthcare facilities, and workplaces;
possible effects on livestock and the environment;
consumer, school, worker, community, and local-government disclosure;
research on procedures and technologies that minimize unnecessary exposure; and
the roles of FDA, NIH, CDC, and other federal health agencies.

That list matters. The federal government is now asking, in one notice, about many of the variables that an acute heating limit cannot resolve.

A signal can remain far below a thermal injury threshold while still possessing a carrier frequency, an amplitude envelope, a pulse-repetition pattern, a duty cycle, sharp transitions, polarization, phase relationships, spatial gradients, and a schedule of exposure and recovery. Those characteristics may be biologically irrelevant in one system and biologically active in another. The question must be tested, not excluded by definition.

Two Federal Doors Are Open at the Same Time

The HHS proceeding arrives only days after the FCC reopened the record in ET Docket No. 13-84. On September 11, 2026, the FCC released Public Notice DA-26-971 seeking comment on the issues returned to it by the D.C. Circuit in Environmental Health Trust v. FCC.

These proceedings are related, but they are not interchangeable.

The FCC record is a targeted response to the 2021 court remand. It concerns portable-device testing, non-cancer effects involving children and long-term exposure, the ubiquity and evolution of wireless technology, and environmental effects.

The HHS record is broader. It asks the health agencies to examine exposure science, vulnerable populations, evidence below existing limits, surveillance, cumulative exposure, research priorities, disclosure, and exposure-reduction methods.

The two agencies also occupy different institutional positions. The FCC manages communications systems and enforces its exposure rules. HHS contains the federal institutions charged with health research, toxicology, disease surveillance, medical-device oversight, and public-health guidance. The FCC itself has historically said that it relies heavily on federal health agencies for health expertise.

The public should therefore file in both proceedings. Comments submitted to HHS do not automatically become part of the FCC record, and comments filed at the FCC do not automatically answer HHS.

Read about FCC Public Notice DA-26-971

File in the FCC Electronic Comment Filing System and enter proceeding number 13-84.

The 2021 Court Decision: What It Did—and What It Did Not Do

In 2021, the U.S. Court of Appeals for the D.C. Circuit held that the FCC had not supplied the reasoned explanation required by administrative law for its treatment of evidence concerning harmful effects unrelated to cancer.

The court directed the FCC to address:

its procedures for testing phones and other portable devices;
effects on children;
the implications of long-term exposure;
the ubiquity of wireless devices and technological changes since 1996; and
environmental effects.

The opinion also discussed the agency’s failure to explain its treatment of pulsation and modulation in connection with non-cancer effects. The court did not decide the scientific controversy or calculate a replacement exposure limit. It held that the FCC could not substitute conclusory assurances for an explanation grounded in the record.

That distinction is important. The decision was not a judicial declaration that every reported RF effect is proven. It was a ruling that the federal regulator had not done the analytical work the law required.

Read the D.C. Circuit opinion

Public Law 90-602: Congress Already Assigned This Duty

The most consequential part of the HHS notice may be what it reawakens.

Congress enacted the Radiation Control for Health and Safety Act of 1968, Public Law 90-602, to protect the public from radiation emitted by electronic products. Its provisions now appear primarily at 21 U.S.C. sections 360hh through 360ss.

The law is not limited to X-rays, ionizing radiation, or devices that produce obvious heat. The statutory definition of electronic product radiation expressly includes ionizing and non-ionizing electromagnetic radiation emitted by an electronic product.

Congress directed the Secretary of Health and Human Services to establish and carry out an electronic-product-radiation control program. The law assigns concrete duties, including:

developing and administering performance standards when necessary to protect public health;
planning, conducting, coordinating, and supporting research and operational work to minimize unnecessary emissions and human exposure;
studying emissions and real conditions of exposure;
developing, testing, and evaluating procedures and techniques for minimizing exposure;
coordinating with other federal and state agencies, professional organizations, labor, industry, and the public;
collecting and publishing research on the nature and extent of hazards and their control; and
making public-health recommendations.

Those duties are codified in 21 U.S.C. section 360ii. The related performance-standard authority in 21 U.S.C. section 360kk requires consideration of the latest scientific and medical data and permits different standards for products with different operating characteristics and uses.

Public Law 90-602 therefore supplies a public-health framework that is much broader than asking whether one phone passes one standardized SAR test. It reaches research, measurement, exposure conditions, product performance, labeling, testing, disclosure, coordination, and practical exposure reduction.

The HHS RFI closely tracks that mandate. It asks whether more research is needed to develop and test techniques for minimizing exposure. It asks how exposure should be characterized. It asks what information should be disclosed. It asks what surveillance systems should exist. It asks what FDA, NIH, and CDC should do.

The RFI is a beginning, not completion of the statute’s mission. Public participation should make clear that the record must lead to a durable program with budgets, timelines, independent investigators, open data, and public accountability.

Robert F. Kennedy Jr.’s Unique Responsibility

Secretary Kennedy is not arriving at this issue without history.

Robert F. Kennedy Jr. appeared on the joint briefs for petitioners in the litigation that produced the 2021 FCC remand. He is now the HHS Secretary whose signature appears on this new RFI. He has moved from helping ask a court to require a reasoned federal response to leading the department Congress charged with electronic-product-radiation health protection.

That creates an unusually direct line of responsibility.

Public Law 90-602 defines the responsible Secretary as the Secretary of Health and Human Services. It tells that office to carry out a radiation-control program, support research, evaluate exposure, develop minimization techniques, publish hazard information, and make recommendations.

HHS does not need to wait for the FCC to become a biomedical research agency. It can build the health record that the FCC lacks. It can restore independent toxicology. It can direct NIH toward mechanisms and vulnerable developmental windows. It can direct CDC toward surveillance and clinician education. It can require FDA to explain how its product-radiation authority will address modern wireless devices and realistic use. It can produce exposure-reduction recommendations that schools and families can use now.

The measure of this RFI will not be the number of comments collected. It will be whether HHS performs the duties Congress assigned and whether its conclusions are transparent enough to withstand scientific and public scrutiny.

The Evidence HHS Must Put on the Record

No single study needs to carry the entire public-health case. The warning arises from convergence across controlled animal toxicology, reproductive findings, mechanistic studies, exposure science, epidemiology, and the failure of the existing limit to function as a lifetime disease-risk standard.

1. National Toxicology Program Cancer Findings

The U.S. National Toxicology Program conducted one of the largest controlled animal studies of cellphone-type RF exposure. Under the conditions tested, NTP reported clear evidence of malignant heart schwannomas and some evidence of malignant brain gliomas in exposed male rats. It also reported other findings, including DNA damage in selected tissues.

The animal exposure system was not identical to ordinary localized cellphone use. That affects quantitative translation; it does not nullify the hazard signal. Controlled animal studies exist precisely because lifetime carcinogenicity questions cannot ethically be tested in people.

Read NTP Technical Report 595

2. Ramazzini Institute Findings at Lower Field Intensities

The Ramazzini Institute conducted a separate lifetime rat study using far-field 1.8 GHz exposure at much lower field intensities. It reported an increased incidence of heart schwannomas in male rats. Differences between the NTP and Ramazzini designs prevent treating them as identical replications, but the appearance of a related rare tumor endpoint in two independent programs is a warning that requires investigation, not dismissal.

Read the Ramazzini Institute study

3. The WHO-Commissioned Animal-Cancer Review

A 2025 WHO-commissioned systematic review of RF exposure and cancer in laboratory animals assigned high certainty of evidence to increased malignant glioma and malignant schwannoma of the heart. Those are the same two tumor types that had driven concern in the NTP findings and that correspond to tumor categories previously identified by IARC as having limited evidence in humans.

Read the WHO-commissioned animal-cancer review

A 2026 commentary from researchers at Germany’s Federal Office for Radiation Protection challenged the original review’s method and produced lower certainty ratings. That disagreement should not be used as an excuse for paralysis. HHS should convene an open technical adjudication, publish the competing models and evidence tables, disclose conflicts and institutional roles, and state exactly why each study is included, excluded, upgraded, or downgraded.

When qualified groups reach materially different certainty ratings from the same animal literature, the public needs transparent resolution and targeted replication—not another blanket assurance.

4. Male Fertility and a Pregnancy-Rate Endpoint

A corrected WHO-commissioned systematic review of experimental male-fertility studies assigned high certainty to a reduction in pregnancy rate after male RF exposure, measured as the proportion of paired females that did not become pregnant. The corrigendum states that the pooled result was substantially influenced by one study conducted at an extremely high SAR. It also concluded that a detrimental effect at exposure levels relevant to the general population remained uncertain.

That caveat controls how the result should be extrapolated; it does not make the endpoint disappear. It identifies the next experiment HHS should fund: rigorous, preregistered, blinded reproductive studies across lower doses, modern waveforms, developmental windows, and recovery periods, with open dosimetry and raw data.

Read the corrected male-fertility review

Precision matters here. A separate WHO-commissioned review of exposure during pregnancy did not classify pregnancy and birth outcomes broadly as high certainty. It reported moderate certainty for a small adverse effect on fetal weight and lower certainty for several other adverse endpoints. The strongest defensible statement is therefore not that every pregnancy endpoint has high-certainty evidence. It is that the WHO-commissioned program now contains high-certainty animal findings for two cancer endpoints and a corrected high-certainty pregnancy-rate finding in the male-fertility literature, alongside additional reproductive and developmental signals that require better-designed low-dose studies.

Read the pregnancy and birth-outcomes review

5. The 2026 Melnick-Moskowitz Risk Assessment

Ronald Melnick, a former National Toxicology Program scientist who helped design the NTP RF study, and Joel Moskowitz of the University of California, Berkeley, applied established risk-assessment methods to the animal cancer and reproductive data.

They compared their estimates with the public whole-body SAR limit of 0.08 watts per kilogram, or 80 milliwatts per kilogram. Their analysis estimated:

cancer risk-based levels of approximately 0.8 to 5 milliwatts per kilogram for a one-in-100,000 excess-risk target; and
male-reproductive reference levels of approximately 3.3 to 10 milliwatts per kilogram.

Under their assumptions, the existing public whole-body limit is 15 to 900 times higher than the cancer risk-based estimates, depending on assumed daily exposure duration, and 8 to 24 times higher than the male-reproductive reference levels.

Those figures are results of a peer-reviewed risk-assessment model; they are not yet an FCC or HHS determination that every compliant exposure carries a particular numerical risk. That is exactly why they belong in this docket. HHS should independently reproduce the calculations, publish sensitivity analyses, state the risk target it considers acceptable, and either adopt protective benchmarks or explain every scientific and policy choice used to reject them.

Read the Melnick-Moskowitz risk assessment

Why a Heating Standard Cannot Answer a Timing Question

The current framework is dominated by how much RF energy is absorbed and whether that absorption produces excessive heating over a specified averaging interval. Absorbed power is a relevant variable. It is not a complete description of a signal.

Biology does not regulate itself only through average energy. It also uses timing.

Cells encode information through membrane voltage, ion-channel opening, calcium pulses, phosphorylation cycles, redox oscillations, mitochondrial gradients, gene-expression rhythms, and circadian phase. Calcium signals can carry different meanings through their amplitude, frequency, duration, localization, phase, and recovery interval. Mitochondria read those signals and alter ATP production, redox state, reactive-oxygen signaling, membrane potential, quality control, and cell fate.

This is not a debate about whether life is bioelectric. It is. The unresolved public-health question is whether particular real-world electromagnetic exposures can perturb that bioelectric control system enough, often enough, and during sensitive enough windows to change health risk.

Use “Waveform,” Not “Wave Function”

Public comments should use precise language. In this context, the relevant engineering term is usually waveform, not wave function. “Wave function” has a specific meaning in quantum mechanics. A wireless-exposure comment should ordinarily discuss:

carrier frequency;
field amplitude and amplitude envelope;
pulse-repetition frequency;
pulse width and duty cycle;
rise and fall times;
peak-to-average ratio;
modulation scheme;
polarization;
beamforming and spatial concentration;
simultaneous carriers and mixed exposures;
distance and orientation relative to the body;
exposure duration, repetition, and recovery time; and
developmental and circadian timing.

Two exposures can deliver the same average SAR while presenting very different temporal and spatial patterns. If biological receivers respond to thresholds, transitions, resonance windows, pulse intervals, or phase relationships, an average-power metric can erase information that matters.

The HHS notice itself recognizes this possibility by asking how classification should account for modulation, pulse characteristics, duty cycle, beamforming, multiple frequencies, proximity, and cumulative exposure. The public should insist that these variables be measured rather than averaged away.

Calcium Timing Is No Longer a Speculative Side Issue

In 2019, researchers reported that low-energy, amplitude-modulated RF fields produced tumor-selective effects in hepatocellular-carcinoma models through CaV3.2 T-type voltage-gated calcium channels and calcium influx. Whatever one concludes about that therapeutic system, it establishes a crucial principle: frequency and modulation can be biologically meaningful, and calcium-channel hardware can translate a field into a cellular response under defined conditions.

Read the CaV3.2 amplitude-modulated RF study

In 2026, a paper in Cell described an engineered electromagnetic-field-responsive gene switch. A CRISPR screen identified cytochrome b5 type B, or CYB5B, as an essential mediator likely acting as an EMF sensor. Most importantly, activation depended on rhythmic oscillatory calcium dynamics rather than generic calcium influx.

Read the 2026 Cell paper

The experiment does not establish that an ordinary Wi-Fi router reproduces the engineered system’s response. It establishes something more fundamental: a defined electromagnetic input can be transduced through identifiable cellular machinery into a calcium rhythm and then into gene-level control.

That makes the right regulatory question unavoidable:

If carefully selected electromagnetic waveforms can write biologically meaningful calcium timing, where is the federal research program testing whether chronic environmental waveforms can add timing error to the same general class of electrically sensitive systems?

The S4-Mito-Spin Framework: A Mechanism Map for Federal Research

RF Safe’s S4-Mito-Spin framework is not offered as a declaration that every link has already been proven for every wireless source. It is a falsifiable map for organizing the research HHS now says it wants.

S4: Voltage-Sensing Membrane Hardware

Voltage-gated ion channels contain charged voltage-sensing structures, commonly centered on the S4 helix, that respond to changes in membrane electric potential. These channels regulate calcium, sodium, potassium, and other ionic flows essential to excitability, secretion, development, contraction, and gene regulation.

The established biology is that S4-containing channels are voltage sensors and calcium waveforms carry information. The research question is whether particular external fields, waveforms, or induced membrane perturbations can bias channel timing under realistic exposure conditions.

The most informative endpoint is not merely total calcium. It is the full calcium waveform: baseline, amplitude, frequency, pulse width, phase, localization, propagation, termination, and recovery.

Mito: Mitochondrial Amplification and Recovery

Mitochondria convert calcium and substrate signals into ATP production, redox signaling, membrane potential, biosynthesis, stress responses, fusion and fission decisions, and mitophagy. A small timing error at the membrane can therefore be amplified into altered energy allocation or recovery.

CYB5B is especially important because it places a redox-active, heme-containing protein at the mitochondrial outer membrane within reach of calcium signaling, lipid metabolism, electron transfer, and mitochondria-ER communication. The 2026 Cell paper makes CYB5B-dependent field transduction a specific experimental target rather than a vague appeal to “electromagnetic sensitivity.”

Spin: Field-Sensitive Reaction Probabilities

Flavins, hemes, iron-sulfur centers, quinones, oxygen radicals, and transient radical pairs participate in mitochondrial and cellular redox chemistry. Spin-selective reactions provide a physical route by which a magnetic field can alter reaction probabilities without first heating bulk tissue.

The existence of spin chemistry does not prove that every environmental RF field produces a harmful effect. It identifies measurable variables: radical lifetime, singlet-triplet conversion, product yield, redox timing, field strength and orientation, static-field background, molecular geometry, and downstream amplification.

The Convergence: Bioelectrical Dissonance

S4, mitochondrial, and spin-sensitive pathways converge on a common systems question: does repeated exposure reduce the precision with which cells sense, decide, act, and recover?

RF Safe calls a persistent mismatch between environmental electromagnetic timing and endogenous biological control bioelectrical dissonance. When recovery becomes incomplete, the organism accumulates recovery debt. The resulting state is low-fidelity biology.

Low-fidelity biology does not mean that every exposed person develops the same disease. It predicts loss of control-layer precision:

calcium pulses become mistimed or incompletely terminated;
mitochondrial ATP and redox responses become less phase-aligned with demand;
membrane-potential recovery becomes less reliable;
damaged mitochondria are repaired, reintegrated, or removed less accurately;
gene-expression programs receive noisier timing inputs;
DNA repair, immune surveillance, apoptosis, and senescence decisions lose precision; and
developmental programs encounter errors during windows when timing is especially consequential.

This is a meta-disease hypothesis. It does not require “RF causes disease X” to be the only acceptable research question. It asks what happens when an environmental factor adds chronic timing noise to systems that maintain biological fidelity.

The predicted population pattern is not one new disease with one simple signature. It is that rare failures become less rare, conditions that usually emerge late appear earlier, susceptible tissues fail first, and other stressors become more consequential because recovery capacity has been reduced.

RF exposure would not operate alone. Air pollution, poor nutrition, sleep and circadian disruption, infection, chemical toxicants, psychosocial stress, medical interventions, and genetic susceptibility can all burden the same recovery systems. That is not an argument for ignoring RF. It is the reason cumulative and combined-stressor research is necessary. A body with lower reserve follows the path of least resistance to failure.

What HHS Should Be Asked to Do

A strong comment should not merely say “wireless is dangerous” or attach an unorganized list of papers. It should ask HHS for specific actions tied to the questions in the notice and to its statutory authority.

1. Fully Implement Public Law 90-602

Ask HHS to publish a formal implementation plan for 21 U.S.C. sections 360hh through 360ss, including responsible offices, appropriations needs, milestones, public reporting, research grants, product testing, exposure-minimization work, and interagency coordination.

2. Restore an Independent National RF Toxicology Program

Ask HHS and NIH to restart long-term RF toxicology after the positive NTP findings. The program should include modern 4G, 5G, Wi-Fi, Bluetooth, DECT, wearable, and mixed-source waveforms; prenatal and juvenile exposure; reproductive and multigenerational endpoints; chronic low-dose conditions; sham controls; blinded pathology; preregistration; independent dosimetry; and open data.

3. Compare Waveforms at the Same Average Absorbed Power

Require experiments that hold average SAR or power density constant while varying modulation, pulse structure, duty cycle, rise time, peak-to-average ratio, beamforming, polarization, and recovery interval. That is how investigators can determine whether average power alone predicts biology.

4. Measure Biological Timing Directly

Ask federal research programs to measure time-resolved cytosolic, ER, and mitochondrial calcium; membrane voltage; mitochondrial membrane potential; ATP/ADP; NADH/FAD redox state; compartment-specific reactive oxygen species; ion-channel activity; gene-expression rhythms; DNA repair; mitochondrial quality control; and post-exposure recovery.

Require CYB5B knockout-and-rescue experiments, voltage-gated-channel perturbations, mitochondrial calcium controls, spin-sensitive controls, and sequencing of events. A proposed mechanism becomes persuasive only when the field-induced molecular event precedes and predicts the downstream biological change.

5. Protect Children and Pregnancy as Distinct Exposure Classes

Children are not small adults. Developing tissues, lifelong cumulative exposure, thinner anatomical barriers in some regions, rapidly changing neural networks, school-day duration, and limited ability to choose their environment justify distinct assessment.

Ask HHS to develop child-specific and pregnancy-specific guidance, exposure metrics, device-use instructions, school infrastructure recommendations, and research priorities. Safety should account for chronic near-body devices, wearables, classrooms, buses, bedrooms, and prenatal exposure—not only a brief compliance test on an adult-sized model.

6. Build Surveillance Before Declaring the Population Reassured

Ask CDC and other agencies to develop:

national exposure surveys with personal dosimetry;
longitudinal cohorts beginning before birth;
occupational registries for high-exposure workers;
linkage to cancer, fertility, pregnancy, neurodevelopmental, sleep, metabolic, and neurological outcomes;
standardized clinician and consumer adverse-event reporting;
geospatial assessment of infrastructure and cumulative neighborhood exposure; and
public access to anonymized data and protocols.

Exposure surveillance must record technology and waveform, not merely ask whether someone “used a cellphone.”

7. Require Useful Disclosure and User Control

Ask for disclosures that describe realistic operating conditions, simultaneous transmitters, antenna locations, body-contact assumptions, adaptive power behavior, peak and average emissions, and practical ways to reduce exposure.

Users should be able to disable individual radios, select wired modes, and understand when a device increases power because of weak reception, obstruction, or a poorly designed accessory. Schools and local governments should receive accessible exposure and infrastructure information rather than being told only that a facility is “compliant.”

8. Make Lower-Exposure Infrastructure a National Objective

The goal is not to ban communication. It is to make high-speed communication possible with substantially less compulsory RF exposure.

Ask HHS to recommend fiber and Ethernet as the fixed backbone, wired connections where mobility is unnecessary, power-over-Ethernet systems where appropriate, and a national mandate for Li-Fi compatibility in devices used in schools, childcare settings, healthcare environments, workplaces, and homes.

Li-Fi will not replace every radio link or solve every exposure problem. It can move large volumes of indoor data onto light-based connections and give families, schools, and institutions a genuine lower-RF choice. Public Law 90-602 expressly contemplates developing and evaluating techniques that minimize unnecessary electronic-product-radiation exposure. Alternatives belong in the health policy, not at the margins of it.

9. Establish Independent Review and Conflict Transparency

Ask HHS to publish authorship, funding, conflicts, institutional affiliations, protocol deviations, excluded evidence, and dissenting analyses for every federal review. Scientific disagreement should be visible and adjudicated on methods. No small, overlapping professional network—whether industry-aligned, standards-aligned, or advocacy-aligned—should be permitted to define the record without transparent external review.

10. Put the HHS Record Into the FCC Record

Ask HHS to file its final evidence assessment and recommendations in FCC ET Docket 13-84, and ask the FCC to explain publicly how it incorporates them. The communications regulator should not be able to say it is waiting for health agencies while the health agencies say exposure limits belong to the FCC.

How to Submit a Strong HHS Comment

Go to Docket HHS-OASH-2026-0397.
Open the docket and click the Comment button when it becomes active.
Submit only one response per person or organization.
Identify your perspective: parent, patient, clinician, researcher, educator, worker, engineer, community member, or organization.
Use the RFI’s question numbers. You may answer only the questions relevant to you.
Link directly to peer-reviewed papers, government reports, datasets, or technical documents.
Separate personal observations from scientific claims.
Do not include personally identifiable information, private medical details, or confidential material. Comments become public.
Save your submission and confirmation for your records.

The most relevant questions for a policy-and-science comment are likely Questions 5, 6, 8 through 13, and 16 through 18. People with personal or clinical experience may also answer Questions 3 and 4 without disclosing private information.

Copy-and-Paste HHS Comment Template

Personalize this text. A specific, sourced comment carries more value than thousands of identical submissions.

Re: HHS-OASH-2026-0397, Request for Information on EMFs, RF Radiation, and Wireless Radiation Exposure

I submit this comment as a [parent / clinician / researcher / educator / worker / engineer / concerned member of the public]. I ask HHS to treat this RFI as the first step toward full implementation of the federal electronic-product-radiation responsibilities established by Public Law 90-602 and now codified at 21 U.S.C. sections 360hh through 360ss.

Questions 5, 6, and 12 — Standards and evidence below current limits: Current FCC limits are organized primarily around avoiding acute thermal effects. They were not developed as lifetime cancer, reproductive, developmental, or neurological risk standards. HHS should independently evaluate the National Toxicology Program findings, the Ramazzini Institute findings, the WHO-commissioned animal-cancer and reproductive reviews including all corrigenda, and the 2026 Melnick-Moskowitz quantitative risk assessment. HHS should reproduce the risk calculations, publish sensitivity analyses, and explain whether the current whole-body public limit is protective across a lifetime.

Questions 5(p), 8, and 13 — Real-world exposure and waveform: Exposure classification should include carrier frequency, field amplitude, pulse repetition, pulse width, duty cycle, rise and fall times, peak-to-average ratio, modulation, polarization, beamforming, simultaneous frequencies, distance, near-body operation, cumulative duration, developmental timing, and recovery interval. Studies should compare different waveforms at the same average SAR or power density. Average absorbed power should not be presumed to capture every biologically relevant characteristic.

Questions 11 and 15 — Sensitive populations and infrastructure: HHS should establish separate assessment and guidance for children, pregnancy, workers, people with implanted devices, and people with preexisting conditions. It should evaluate cumulative exposure in homes, schools, childcare facilities, healthcare settings, workplaces, and neighborhoods with dense antenna deployment.

Questions 10, 16, and 17 — Surveillance and federal research: HHS should restore an independent, long-term RF research program with modern waveforms, prenatal and juvenile cohorts, reproductive and multigenerational endpoints, blinded pathology, preregistration, open data, and independent dosimetry. CDC should develop exposure and health surveillance; NIH should fund mechanisms and replication; FDA should evaluate electronic-product-radiation performance, disclosure, and exposure-reduction options under existing law.

Question 16 — Bioelectric mechanisms: Federal research should measure time-resolved calcium signaling, membrane voltage, mitochondrial membrane potential, ATP and redox dynamics, reactive oxygen species, gene-expression timing, DNA repair, mitochondrial quality control, and post-exposure recovery. The 2026 Cell study identifying CYB5B-dependent EMF transduction through rhythmic calcium oscillations provides a concrete experimental lead. Voltage-gated S4 sensor pathways, mitochondrial amplification, and spin-sensitive redox chemistry should be tested with knockout, rescue, and pathway-specific controls.

Questions 5(o), 9, and 18 — Exposure reduction and alternatives: HHS should develop and test practical methods to minimize unnecessary exposure, as contemplated by 21 U.S.C. section 360ii. Recommendations should prioritize fiber and Ethernet for fixed connections, wired operation where mobility is unnecessary, meaningful radio-off controls, transparent consumer disclosure, and Li-Fi compatibility for indoor high-data applications, especially in schools and healthcare settings.

I also ask HHS to place its completed assessment and recommendations into FCC ET Docket 13-84 so the FCC’s response to the 2021 court remand is informed by a transparent health-agency record. Uncertainty should lead to better research and lower avoidable exposure, not permanent reliance on a 1996 framework.

Also Comment at the FCC

The FCC proceeding is narrower, so adapt your comment to the remand. Focus on:

why current portable-device testing does not represent all realistic use, body contact, simultaneous transmission, or child anatomy;
non-cancer evidence below the current limits;
children and lifelong exposure;
long-term exposure, pulsation, modulation, and technology changes since 1996;
environmental evidence; and
why the FCC must rely on a current, independent HHS assessment rather than conclusory agency assurances.

File through FCC ECFS and enter 13-84 as the proceeding. The FCC notice states that comments are due 30 days after its Federal Register publication; verify the live deadline before submitting.

This Is the Moment to Build the Record

The central issue is larger than whether one model of phone, one frequency, or one disease can be isolated from every other influence.

Modern organisms maintain health through bioelectrical timing: membrane voltage, calcium codes, mitochondrial energetics, redox balance, gene regulation, repair, immune surveillance, and recovery. Our communications environment now overlays those systems with billions of engineered signals that were optimized for data throughput, not biological compatibility.

The public-health question is therefore not limited to whether RF produces enough heat to damage tissue in a short test.

The question is whether chronic, pulsed, modulated, cumulative electromagnetic exposure can reduce the fidelity of biological signaling and recovery—and whether that loss of fidelity makes rare failures less rare and later-life failures arrive earlier.

That question is testable. The tools exist. The animal warning signals exist. The mechanistic leads exist. The statutory authority exists. Lower-exposure communications alternatives exist.

What has been missing is a coordinated federal decision to investigate the entire problem rather than define most of it out of existence.

HHS has now asked the questions. The FCC has reopened its record. Public Law 90-602 already states the duty. Secretary Kennedy has signed the notice.

Now the public must make the record impossible to ignore.

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BREAKING: HHS Opens the Federal Record on Wireless-Radiation Health Risks