Environmental Health Trust calls for science-based federal policy updates, stronger exposure limits and r…

Since its founding in 2007, Environmental Health Trust and numerous experts and expert groups have repeatedly advised governments, through docket filings and briefings of Federal Communications Commission (FCC), Food and Drug Administration (FDA), and other officials, that science-based policy updates are urgently needed to reduce microwave-radiation exposure, especially for young children and the environment. According to Common Sense Media, forty percent of U.S. two-year-olds own some form of two-way microwave-radiating tablet. Outdated 20th century approaches such as those relied on by ICNIRP cannot provide valid means for evaluating fast-moving 21st century technologies.

At the same time, the recent issuance of separate requests for information by both HHS and the FCC highlights the lack of a coherent federal policy framework. It also reflects the ongoing tension between the Department of Commerce's technology leadership, which is tasked with accelerating wireless deployment, and HHS and FDA officials, who are responsible for evaluating the evidence, supporting research on potential health risks, and advising the FCC on appropriate regulatory policies.

Microwave-radiating devices can provide social, safety, and economic benefits, but their risks have not been adequately considered in standards governing manufacture, testing, use, surveillance, and disposal.

Consequently, billions experience repeated, avoidable RF radiation through lifetime use of simultaneously operating phones, tablets, personal monitors, and other two-way microwave-radiating devices, increasing risks of chronic illnesses documented over five decades, much of the research conducted outside the U.S. We therefore welcome the Department of Health and Human Services (HHS) and FCC Request for Information (RFI) on health and environmental impacts.

This compendium of selected recent studies (2020-26) on the impact of microwave radiation on human health and the environment completed since the U.S. Circuit Court for the District of Columbia ruled in Environmental Health Trust et al. v. FCC, 2021, in response to queries within the RFI from HHS.

In response to question 5, we note that current standards for cell phones and other two-way microwave-emitting devices are based largely on studies conducted to avoid heating a small number of rats and mice more than 30 years ago. These outdated standards primarily seek to prevent thermal (heating) effects in the body of a tall adult male and do not reflect exposure patterns experienced by billions of children and smaller-bodied individuals worldwide. They also do not account for the substantial body of research showing adverse effects of microwave radiation on plants, insects, birds, migratory species, mammals, and the ecosystems on which life depends.

Phonegate Alert contends that current phone radiation tests, like diesel-engine tests, are fraudulent. We concur. As a result of these efforts, the European Union recently changed its test protocol to 0mm distance from the body. We advise that more stringent exposure limits in high tech nations is evidence per se of the need to update 3-decade old U.S. standards.

Response to HHS Request for Information

HHS-OASH-2026-0397, HHS-OASH-2026-0397-0001, 2026-19252

Devra Davis PhD, MPH, Fellow American College of Epidemiology, Fellow Collegium Ramazzini, Founder and Acting President, Environmental Health Trust, former Honorary Professor Medicine, London School of Hygiene and Tropical Medicine, former Professor of Medicine, Mt. Sinai School of Medicine and elsewhere

Introduction

Since its founding in 2007, Environmental Health Trust and numerous experts and expert groups have repeatedly advised governments, through docket filings and briefings of Federal Communications Commission (FCC), Food and Drug Administration (FDA), and other officials, that science-based policy updates are urgently needed to reduce microwave-radiation exposure, especially for young children and the environment. According to Common Sense Media, forty percent of U.S. two-year-olds own some form of two-way microwave-radiating tablet. Outdated 20th century approaches such as those relied on by ICNIRP cannot provide valid means for evaluating fast-moving 21st century technologies.

Consequently, billions experience repeated, avoidable RF radiation through lifetime use of simultaneously operating phones, tablets, personal monitors, and other two-way microwave-radiating devices, increasing risks of chronic illnesses documented over five decades, much of the research conducted outside the U.S.

This compendium of selected recent studies (2020-26) on the impact of microwave radiation on human health and the environment completed since the U.S. Circuit Court for the District of Columbia ruled in Environmental Health Trust et al. v. FCC, 2021, in response to queries within the RFI from HHS.