Researchers summarize occupational and military cancer findings, recommend recognizing RF as a human carc…

HHS public comment #5499 · HHS-OASH-2026-0397 · 2026-10-27

#1Researchers summarize occupational and military cancer findings, recommend recognizing RF as a human carc…by Michael Peleg » 2026-10-27
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Researchers summarize occupational and military cancer findings, recommend recognizing RF as a human carcinogen, and call for lower average and peak exposures, monitoring and further epidemiology.

  • Cancer & tumors: cy Radiation (RFR) should be recognized as a human carcinogen. Limit human exposure to low levels, for example 1μW/cm2 average
  • Occupational exposure: er patients previously exposed to RFR in the military and occupational setting. The exposure: The exposure was from radio communication transm
  • Exposure limits & oversight: it human exposure to low levels, for example 1μW/cm2 average level and 5μW/cm2 peak pulse level. The suggested level is in the range of known community levels.
  • Research & federal duties: cancer and for other health effects. Perform epidemiological cancer research on all known personnel exposed to significant levels of RFR. Ple

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Original comment · unedited text

Carcinogenicity of radio-frequency radiation in the occupational and military setting

Prepared jointly by:

Elihu Richter, ORCID 0000-0003-3218-7765

Michael Peleg, ORCID 0000-0002-7520-8741 peleg.michael@gmail.com

A slightly longer and better formated version is attached as a PDF file.

We took part in research reported in the papers in the reference list below. The research provides a strong indication of carcinogenicity of Radio-Frequency Radiation (RFR).

The research subjects:

Groups of young cancer patients previously exposed to RFR in the military and occupational setting.

The exposure:

The exposure was from radio communication transmitters, from radar and from electronic warfare. The exposure was repetitive, typically over a year or more. The Israeli Defense Forces exposure levels are guided by the occupational standards set by ICNIRP which allow average power higher by a factor of 5 relative to the ICNIRP recommendations for the general population. Importantly, those standards almost do not limit the peak power of radar pulses provided the average power is within the limits. Power concentrated in strong pulses may be more bioactive as explained in the references.

Research methods:

The primary information was from the patients; most of them were trained operators, technicians and engineers. For small subgroups of patients, we knew the size of the whole exposed population and thus we were able to estimate cancer Risk Ratios (RR) relative to the general population. For most of the patients the size of the exposed population was not available. Therefore we examined also cancer characteristics since cancer characteristics which are very different from those of cancer patients from the general population indicate an additional carcinogen. We examined Percentage Frequencies (PF) of cancer types and proportion of cancer patients suffering from multiple primaries.

The main results:

The RRs for cancer in the small subgroups were very high, e.g. 8, and statistically significant.

The PF of hematolymphoid cancers was about twice the value in the general population and statistically significant.

The two results above are consistent with research results of other research groups in different countries, see table 7 and figure 4 in reference (4) and section 3.4 in reference (3).

Proportion of patients suffering multiple primaries as reported in reference (3) was higher by a factor of 4.5 than the value expected in the general population. This indicates a potent carcinogen. Such a dramatic rise in multiple primaries was not observed in our next work (4). The latencies in (4) may not have been long enough to develop multiple primaries.

Our recommendations:

Radio Frequency Radiation (RFR) should be recognized as a human carcinogen.

Limit human exposure to low levels, for example 1μW/cm2 average level and 5μW/cm2 peak pulse level. The suggested level is in the range of known community levels.

In the military and the occupational settings, reduce exposures to the lowest possible level, striving to the specifications above. Use Faraday barriers to reduce exposures at the source and personal level and any other means required.

Document individual exposures and provide this information to all highly exposed humans. Provide the exposed humans with long-term periodical medical surveillance for cancer and for other health effects.

Perform epidemiological cancer research on all known personnel exposed to significant levels of RFR.

Please see the detailed recommendation section in reference (4).

Acknowledgement:

We thank the Environmental Health Trust for organizing, in Israel, two international conferences on RFR and EMF health aspects which enabled very useful information exchange among the participants.

References:

(1) Richter E, Berman T, Ben-Michael E, Laster R, Westin JB. "Cancer in radar technicians exposed to radiofrequency/microwave radiation: sentinel episodes." Int J Occup Environ Health. 2000 Jul-Sep;6(3):187-93. doi: 10.1179/oeh.2000.6.3.187. PMID: 10926722.

(2) M. Peleg: "Report on a Cancer Cluster in an Antenna Ranges Facility", International IEEE Conference on Microwaves, Communications, Antennas and Electronic Systems, IEEE COMCAS 2009, Tel Aviv, 9-11 November 2009.

(3) Michael Peleg, Or Nativ, Elihu D. Richter: Radio frequency radiation related cancer: assessing causation in the occupational/military setting, Environmental Research, Volume 163, May 2018, Pages 123-133, ISSN 0013-9351

(4) M. Peleg, E. M. Berry, M. Deitch, O. Nativ, E. Richter: On radar and radio exposure and cancer in the military setting, Environmental Research, Volume 216, Part 2, Jan 2023, 114610, ISSN 0013-9351

(5) Peleg M, Berry E M, Deitch M, Nativ O, Richter E. 'Carcinogenicity of Radio-Frequency Radiation: Similarities and Differences Between Outcomes of Two Studies'. Med Discoveries. 2025; 4(7): 1267

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