Submission to the U.S. Department of Health and Human Services (HHS): Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure
October 19, 2026
World Council for Health (WCH) welcomed the opportunity this week, to respond to the U.S. Department of Health and Human Services’ Request for Information concerning electromagnetic fields (EMFs), radiofrequency (RF) radiation, and wireless radiation exposure.
Please find the full submission below:
WCH is an international health advocacy organisation committed to promoting informed consent, individual health sovereignty, scientific transparency, and the protection of human and environmental health.
We believe that the rapid and largely unrestrained expansion of wireless technologies represents a significant public health and environmental policy concern that warrants urgent, independent and comprehensive scientific scrutiny.
Over recent decades, wireless communications infrastructure has expanded dramatically, introducing increasingly widespread and persistent exposure to man-made electromagnetic fields.
While technological innovation has brought considerable benefits, WCH is concerned that the pace of deployment has outstripped the assessment of potential long-term biological and environmental consequences, particularly in relation to chronic, cumulative and involuntary exposure.
In 2023, WCH published its Policy Brief on the Effects of Unregulated Digitalization, examining the wider implications of rapidly expanding digital and wireless technologies for public health, human rights, democratic accountability and the environment.
This body of work includes the recommendations of the late Dr Arthur Firstenberg, who devoted decades to investigating the biological and ecological effects of electromagnetic fields. His work brought together scientific publications examining possible effects on neurological function, cellular processes, reproduction, wildlife, biodiversity and ecosystem health.
Of particular concern is the extent to which existing RF exposure standards have historically focused on established thermal effects, while questions concerning long-term exposure, non-thermal biological effects, signal modulation, vulnerable populations and ecological impacts remain contested or insufficiently resolved.
WCH believes that public health policy must consider the full breadth of available evidence, including research findings that challenge prevailing assumptions about exposure thresholds and biological safety.
We are particularly concerned about the implications for children, pregnant women, individuals reporting electromagnetic hypersensitivity, and those who have little practical ability to avoid exposure in their homes, schools, workplaces or communities.
The continued expansion of 5G telecommunications and wireless infrastructure including the introduction of new frequencies, network configurations and connected technologies raise further questions about aggregate exposure, long-term health effects and the adequacy of existing safety assessments.
The potential environmental implications must also be considered. The Brief highlights research examining associations between anthropogenic electromagnetic fields and changes in the behaviour, development, reproduction and survival of insects, birds, plants and other organisms. These findings require careful evaluation, including consideration of study limitations and other environmental factors, as part of a comprehensive approach to ecological protection.
WCH therefore calls for an independent, transparent and multidisciplinary review of the scientific evidence, free from inappropriate commercial or regulatory conflicts of interest. Such a review should address thermal and possible non-thermal effects, chronic and cumulative exposure, biological responses to modulation and pulsed signals, and the implications of exposure across the lifespan.
We further urge HHS to consider the precautionary principle, particularly where exposure is involuntary, where vulnerable populations may be affected, and where meaningful opportunities to reduce unnecessary exposure exist.
This includes serious consideration of practical alternatives such as wired communications infrastructure, greater public disclosure of exposure information, improved professional education, and individual choice.
WCH encourages greater coordination between public health authorities, environmental agencies, independent researchers and affected communities, recognising that the potential implications of electromagnetic pollution extend beyond conventional telecommunications regulation.
The protection of public health and the natural environment must remain central to technological policy, and not be treated as secondary considerations after widespread deployment has already occurred.
We believe that responsible technological development must be guided by independent science, transparency, informed consent, the protection of vulnerable populations, and a commitment to safeguarding the health of both present and future generations.
Yours sincerely
Dr Tess Lawrie MBBCh, PhD
Ambassador
World Council for Health
worldcouncilforhealth.org
Supporting Documents
The full references and hyperlinks are contained within the supporting WCH publications.
- WCH — Effects of Unregulated Digitalization on Health and Democracy
- WCH — The Firstenberg Brief on Electrosmog
- WCH — What Is 5G? Health Risks
Additional Information
Notice from the US Health and Human Services Department, request for information:
https://www.federalregister.gov/documents/2026/09/21/2026-19252/request-for-information-on-electromagnetic-fields-emfs-radiofrequency-rf-radiation-and-wireless#open-comment
