HHS-OASH-2026-0397 | RFI Q2, Q3, Q5, Q7–13, Q15–18 Questions for HHS: What remains uncertain about chroni…

HHS-OASH-2026-0397 | RFI Q2, Q3, Q5, Q7–13, Q15–18

Questions for HHS: What remains uncertain about chronic, multi-source RF/EMF exposure? How can studies test reported sensitivity and possible oxygen-handling effects? What exposure information and practical options should be available in homes, schools, workplaces and vehicles?

I respond as an individual consumer and family member in the UK, not as a clinician or scientist. My attachment, Where Can They Hide?, provides sources. [P] means peer-reviewed research, [G] official/legal material and [L] lived experience.

Imagine a grandchild asking what we did when people reported illness in wireless environments. I cannot say RF/EMF is established as the cause. I ask HHS to listen without prejudging, measure exposure better and fund independent research.

Experiences (Q3) [L]. I associate neurological and mood changes with RF/EMF exposure, particularly disproportionate anger or irritability, including while driving. Family and friends report different symptoms they associate with exposure: neurological problems, severe skin inflammation sometimes cracking or bleeding, eye pain and cardiac symptoms. Some report improvement after suspected sources, including Wi-Fi, were switched off. Friends said their six-week-old baby slept through for the first time after both parents switched off phones and Wi-Fi overnight; a family member reported similar sleep improvement. These uncontrolled reports do not prove causation: exposure was not measured, several sources changed together and other explanations remain possible.

Evidence and uncertainty (Q5, Q6, Q12, Q16) [P/G]. RF heating is established and central to current limits. ICNIRP’s 2020 guidelines reflect the mainstream view that heating is the only substantiated adverse effect in its assessment; this deserves fair consideration. Yet chronic, multi-source exposure and individual responses should be tested. The 2021 Environmental Health Trust v FCC ruling required the FCC to address issues it had not adequately explained; it did not find limits unsafe or decide the science. Controlled human provocation reviews have not established a consistent RF trigger for reported symptoms, but individual-level questions remain.

Oxygen handling (Q12, Q16) [P/O]. Laboratory studies report changes in haemoglobin oxygen affinity or deoxygenation under particular conditions (Mousavy, 2009; Muehsam, 2013; Chowdhury, 2021). A small 2025 wearable study reported differences in estimated overnight oxygen saturation with and without a nearby phone. Neither proves that everyday RF lowers arterial oxygen saturation or causes tissue hypoxia; these endpoints need independent replication. Redmayne’s 2022 newsletter case reported a teenager’s skin improving after Ginkgo biloba, but measured neither RF exposure nor oxygenation. These observations raise a question, not a conclusion.

Priorities (Q7–13, 15–18): (1) Fund preregistered studies co-designed with people reporting sensitivity, using verified exposure/sham conditions, blinding, clinical assessment and independent replication. (2) Test whether frequency, modulation, intensity and duration affect haemoglobin, red-cell function, arterial oxygen saturation or tissue oxygen delivery, distinguishing altered oxygen unloading from oxygen deficiency. (3) Improve real-world personal measurement, including pregnancy/childhood and homes, schools, workplaces, transport and vehicles; record source, frequency, modulation, duty cycle, distance and cumulative exposure; assess environmental/livestock exposure where relevant (Q14–15). (4) Develop privacy-protecting adverse-event/cluster reporting (Q10); publish accessible exposure information (Q9); evaluate wired alternatives and non-essential vehicle transmitter controls that preserve safety (Q13). (5) Transparently compare FCC, ICNIRP, IEEE and other frameworks, coordinate NIH research, CDC surveillance and FDA device testing/information (Q5, Q17), declare conflicts and report positive and null findings.

In EAM v East Sussex County Council [2022] UKUT 193 (AAC), the Upper Tribunal ordered educational provision, including wired internet, for a child whose reported sensitivity was accepted as disabling in that case. This is not a general scientific finding that RF causes EHS or binding on US agencies; it illustrates practical accommodation issues while causation remains contested. Judgment

What measurements could detect a reproducible effect? What fair studies would resolve uncertainty? What practical options can be offered while research proceeds?

When that grandchild asks what we did, I hope we can say we neither presumed danger nor assumed every question was settled. We listened, measured, tested competing explanations and reported findings openly. I ask HHS to make that effort.