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A telecommunications workforce organization requests occupational exposure surveillance, worker disclosures, monitor validation and prospective studies, while explicitly not presuming current limits unsafe.
nt from the perspective of workers with occupational RF exposure. Tower and wireless technicians work closer to active trans
orming and multi-band environments; and prospective cohort studies of tower and rooftop technicians using measured rather than
up outcomes; standardized worker-facing exposure disclosure; validation of personal RF monitors in beamforming and mult
The American Telecommunications Guild (ATG), an Arizona nonprofit building workforce standards and credentialing for U.S. telecommunications infrastructure trades, submits the attached comment from the perspective of workers with occupational RF exposure. Tower and wireless technicians work closer to active transmitters, for longer periods and in more complex conditions than the general public, yet occupational exposure is rarely measured at the worker level or linked to health outcomes.
ATG supports evidence-based wireless deployment and does not presume current limits are unsafe. We recommend a national occupational RF exposure-and-event surveillance framework, developed jointly by HHS/NIOSH, FCC, OSHA, and NTIA, that links measured exposure, transmitter configuration, and work task to reported symptoms and follow-up outcomes; standardized worker-facing exposure disclosure; validation of personal RF monitors in beamforming and multi-band environments; and prospective cohort studies of tower and rooftop technicians using measured rather than assumed exposure. The attached response addresses Questions 2, 3, 5–13, and 15–18.
See attached file(s)
A city councilmember and nurse midwife requests review of exposure standards, emphasizing children’s device use, lifelong exposure and studies of absorption and body-contact emissions.
tified Nurse Midwife: 1) the impacts on children, and 2) the ubiquity of wireless devices. One study, Micro
1996 (the date of the FCC’s holding on exposure limits) and 2019, when the FCC held there was no appreciable chang
ed and knowledgeable about the abundant studies since both 1996 (the date of the FCC’s holding on exposure
HHS seeks to update the record on whether the science on the effects of RF radiation has changed since the FCC considered this question in 2019. I herein submit comment as City Councilmember of Monterey, California, representing a constituency very concerned and knowledgeable about the abundant studies since both 1996 (the date of the FCC’s holding on exposure limits) and 2019, when the FCC held there was no appreciable change in the science.
Two areas stand out to me as having changed and as areas of concern as a parent, grandparent, and Certified Nurse Midwife: 1) the impacts on children, and 2) the ubiquity of wireless devices.
One study, Microwave Emissions from Cell Phones Exceed Safety Limits in Europe and the US When Touching the Body (https://ieeexplore.ieee.org/document/8688629) notes that emissions exceed recommended limits when in contact with the body. I have observed babies clutching phones and devices and resting them directly on their bodies. We know that, unfortunately, devices are used as babysitters, replacing humans interacting with infants. We have all seen children as young as one holding and staring at devices powered by radio emissions. These children, in playing with devices, ignore their environment at an age (such as 1 year old) when learning the nuances of human interaction and the rewards thereof are essential milestones in their development and in their ability to survive through social bonding.
Additionally, our children are exposed to higher lifelong levels of radio-wave radiation than we have ever studied. Infants today are exposed to much more than previous generations. Authors AK Lee and HD Choi document that a child’s brain absorbs more cell tower radiation than an adult brain due to such factors as the smaller head of a child and hence less density and due to the thinner skull relative to adults, resulting in higher localized absorption of RF energy (EMF exposure in Korean mobile communication networks. 2023) For the safety of children , we must welcome review of the last 30 years of science. The health of our children depends on review of current science. https://www.sciencedirect.com/science/article/abs/pii/S0160412017319724
Reports severe symptoms associated with wireless devices and electrical noise, extensive mitigation costs and a denied analog-meter accommodation; requests independent research, practical alternatives and respectful clinical attention.
cannot tolerate Wi-Fi or Bluetooth and dirty electricity. I have made costly changes to my home to reduce same, incl
h effects. When I purchased my home, a smart meter was installed. The meter was changed in May 2023. I request
r off FPL. I formally submitted an ADA disability accommodation request supported by my medical documentation. However, FPL
itations, tingling, numbness, worsening tinnitus, and vibrations in my legs when the HVAC runs. The vibratio
nia, difficulty thinking clearly, heart palpitations, tingling, numbness, worsening tinnitus, and vibrations in
he system shuts off. I cannot tolerate Wi-Fi or Bluetooth and dirty electricity. I have made costly chan
anging lighting and wiring, using wired Ethernet, and rerouting HVAC lines through the garage. I am still st
alth and my life. I ask HHS to support independent, thorough research into the potential health effects of radiofrequency radiati
Perspective: Individual consumer and person reporting potential adverse health effects. Questions addressed: 3, 13(k), 16, and 18. I am submitting this comment because I want HHS to hear from people like me who are experiencing serious health problems associated with wireless technology, electromagnetic fields, and electrical exposure. My symptoms exploded after I purchased my Florida home in April 2023 and spent a week there. I have experienced burning skin, sharp head pains, fatigue, insomnia, difficulty thinking clearly, heart palpitations, tingling, numbness, worsening tinnitus, and vibrations in my legs when the HVAC runs. The vibrations stop when the system shuts off. I cannot tolerate Wi-Fi or Bluetooth and dirty electricity. I have made costly changes to my home to reduce same, including replacing appliances, changing lighting and wiring, using wired Ethernet, and rerouting HVAC lines through the garage. I am still struggling. I use a Greenwave meter to measure electrical noise in my home. My readings fluctuate, with approximately 400 mV on the low end and readings as high as 1212. Around 50 mV is what I can tolerate. I want better research into electrical noise and its possible health effects. When I purchased my home, a smart meter was installed. The meter was changed in May 2023. I requested a true analog electromechanical meter, but Florida Power & Light provided a digital meter it describes as non-communicating. My concern is not limited to wireless transmission; it also involves the digital and electronic nature of the meter. I have repeatedly provided FPL with medical documentation requesting an analog electromechanical meter, as recommended by my doctors. I even purchased one that FPL could inspect and install, taking the cost of obtaining the meter off FPL. I formally submitted an ADA disability accommodation request supported by my medical documentation. However, FPL denied my request without acknowledging or addressing it as a disability accommodation, responding instead as though I had made an ordinary customer request. Despite more than 20 attempts to resolve this matter, FPL has refused to provide the analog meter my doctors recommended.…
See attached file(s)
A healthcare provider cites the FCC court remand and research gaps and recommends standardized clinical intake, adverse-event reporting, biomarker research and measured-exposure studies.
provider. The federal limits for human exposure to radiofrequency radiation were adopted by the Federal Com
vent intake comparable to MedWatch; (3) biomarker studies in symptomatic patients following the oxidative-stress find
s in symptomatic patients following the oxidative-stress findings of Irigaray, Caccamo & Belpomme (Int J Mol Med 201
,” had failed to address the impacts on children, long-term exposure, and the ubiquity of wireless devices,
ilure to respond to comments concerning environmental harm.” It noted roughly 200 comments from people reporting illne
2.I am responding as a healthcare provider. The federal limits for human exposure to radiofrequency radiation were adopted by the Federal Communications Commission in 1996. n 2013 the FCC itself asked whether the limits should be revisited. In 2019 it answered: no. Environmental Health Trust, Children’s Health Defense and others sued. On August 13, 2021, the U.S. Court of Appeals for the D.C. Circuit ruled that the FCC’s decision was “arbitrary and capricious.” The court found the Commission had failed to respond to “record evidence that exposure to RF radiation at levels below the Commission’s current limits may cause negative health effects unrelated to cancer,” had failed to address the impacts on children, long-term exposure, and the ubiquity of wireless devices, and had shown “a complete failure to respond to comments concerning environmental harm.” It noted roughly 200 comments from people reporting illness or injury that the agency had not addressed. It sent the matter back to the FCC with instructions to explain itself. (Environmental Health Trust v. FCC, No. 20-1025) 18. (https://greenmedinfo.com/problematic-action/electromagnetic-field-harms) The FCC had relied on the Food and Drug Administration’s assurance that the limits were fine. The court said an agency cannot lean on another agency’s conclusion if that conclusion comes without an explanation. 3g. Five years later, no explanation has been produced. https://greenmedinfo.com/problematic-action/electromagnetic-field-harms Recommendations (m). I recommend (1) a validated clinical intake instrument for suspected RF/EMF-related complaints; (2) a federal adverse-event intake comparable to MedWatch; (3) biomarker studies in symptomatic patients following the oxidative-stress findings of Irigaray, Caccamo & Belpomme (Int J Mol Med 2018, https://pubmed.ncbi.nlm.nih.gov/30015864/); and (4) exposure-measurement studies that do not rely on self-report, following Bogers et al. (Environ Int 2018, https://pubmed.ncbi.nlm.nih.gov/30227317/).12. https://pubmed.ncbi.nlm.nih.gov/31540320/ (Adams et al., Environ Int 2014, https://pubmed.ncbi.nlm.nih.gov/24927498/; Liu et al., Andrology 2014,…
Attributes arterial calcification requiring bypass surgery to years of carrying a phone against the back and recounts a discussion with a surgeon.
piece of calcium had broken of from the main artery that supplies blood to my legs blocking at the junction I h
and told him what I thought caused this calcification. For over 20 years I carried my mobile phone clipped to the
"Here is my story, 12 years ago I awoke in the middle of the night in excruciating pain in my legs, a piece of calcium had broken of from the main artery that supplies blood to my legs blocking at the junction I had to have a double bi-pass, they thought I my loose a leg because of the lack of blood flow. I seen my vascular surgeon and told him what I thought caused this calcification. For over 20 years I carried my mobile phone clipped to the back of my nail bag up against my back that caused the calcification, he's response was "why do you think my phone is way over their" pointing to the table sitting in the corner of his office, then i started to look for conformation of my thoughts and sure enough there is plenty out there like this paper that corelates well with the introduction of the mobile phone in Australia. A week before my experience I had a CT scan and what it showed was calcium build-up at the junction to my legs and the only other bit of calcium build-up was behind my ear."
Attributes a benign meningioma to earlier phone use, reports ongoing monitoring and a spouse’s EHS, and requests updated exposure standards, reduced emissions and public warnings.
c tests. My diagnosis was confirmed of meningioma. I have to have MRIs every 2 years now to monitor the tumo
ellular phones. Also, with my spouses’ EHS, we removed all the sources of EMF in our house. My tumor
. 3a: As to my history with RF/EMF…As a requirement of my job, I was an early adopter of cell phones. I also worked in a
with wi-fi. I lived in a house with a smart meter until we had it removed in 2011. 3b: I was exposed daily to
ion/power that mobile phones can emit - Update the standards for “safe” exposure. The current FCC SAR limits are ridicu
I appreciate the opportunity to share my comments. I have followed the format of your questions.
2: I am responding as an individual injured by RF/EMF. Additionally, my spouse has been severely injured by RF/EMF.
3a: As to my history with RF/EMF…As a requirement of my job, I was an early adopter of cell phones. I also worked in an office environment with wi-fi. I lived in a house with a smart meter until we had it removed in 2011.
3b: I was exposed daily to wireless radiation at work and at home with a smart meter.
3c: As a result of holding a cell phone to my head in the late 1990s, I developed a brain tumor right behind my right ear – exactly where I held my cell phone to my head. Fortunately, it continues to be benign, however it was growing so rabidly that I needed radiation treatment to slow its growth. It is stable now but must be regularly monitored. This is the only health effect that has manifested for me, however it is unknown what other injuries I may have that have not yet been detected.
3d: My brain tumor was discovered in 2000. I immediately stopped holding a cell phone to my head and only used it when absolutely necessary.
3e: I saw multiple neurosurgeons and had many diagnostic tests. My diagnosis was confirmed of meningioma. I have to have MRIs every 2 years now to monitor the tumor. The Mayo clinic sites radiation exposure as a potential cause for this type of tumor. Is it a coincidence that on that spot on my head where I held my phone is where my tumor grew?
3f: I stopped holding a phone to my head and also greatly reduced the usage of cellular phones. Also, with my spouses’ EHS, we removed all the sources of EMF in our house. My tumor has been stable for over 20 years, but because of my injury – I have the ongoing expense of monitoring it.
With regard to recommendations to HHS, I would share the following:
- Regulate the amount of radiation/power that mobile phones can emit
- Update the standards for “safe” exposure. The current FCC SAR limits are ridiculously outdated and the science has been proven that they are not sufficient
- Enforce better notification to the public about the hazards of wireless radiation from all sources (wi-fi, phones, smart meters, smart watches, IoT devices, bluetooth devices, etc.)
I have included some studies that support the science that RF / EMF causes cell disruption that can lead to tumors
See comment attached.
*See attached additional Electromagnetic Field Studies demonstrating harmful effects published since 2019.
Susan Foster, CEO
Rocky Mountains for Safe Technology
Email: susan.foster04@gmail.com
Compound exposure of 2.8 GHz and 9.3 GHz microwave causes
learning and memory impairment in rats
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