Re: HHS Request for Information on Electromagnetic Fields and RF Radiation My name is Elizabeth Anne Dunlap, MSc. I hold a master's degree in Medical Visualisation and Human Anatomy from the University of Glasgow and Glasgow School of Art. I submit this comment as a medical visualisation specialist and an individual reporting severe electromagnetic sensitivity (ES). 1. Health Experiences and Functional Impairment My experience of ES has profoundly affected my ability to work, travel, obtain healthcare, maintain housing, and participate in society. I experience migraines, stabbing pain, dizziness, nausea, burning sensations, and disrupted sleep that I associate with nearby wireless devices and infrastructure. I have invested in wired Ethernet, removal of wireless equipment, electrical mitigation, and RF shielding. These observations do not establish causation, but the functional limitations warrant clinical investigation. Scientific uncertainty should not justify dismissing patients or overlooking reasonable accommodations. 2. Exposure Standards and Risk Assessment Current RF limits focus on established adverse effects associated with tissue heating. Questions remain about chronic, modulated, and cumulative exposures. The National Toxicology Program (2018) reported clear evidence of carcinogenic activity involving malignant cardiac schwannomas in male rats exposed to high levels of 900 MHz RF radiation. These results cannot be directly extrapolated to everyday human exposure but merit further study. HHS should independently review whether current standards adequately address long-term outcomes and susceptible populations. 3. Exposure Measurement and Surveillance Real-world exposure includes simultaneous sources such as cellular infrastructure, Wi-Fi, smart meters, and connected devices. Measurements should document frequency, power density, field strengths, modulation, duty cycle, duration, and cumulative exposure. HHS should develop protocols combining personal dosimetry, environmental measurements, clinical observations, and longitudinal data. A voluntary ES registry could support epidemiological studies. 4. Potentially Sensitive Populations Children,…
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