Comments to the Environmental Protection Agency on Electromagnetic Fields and Indoor Air Quality in Buildings – Environmental Health Trust


Environmental Health Trust submitted comments to the Environmental Protection Agency on December 6, 2022 regarding Indoor Air Quality Management to Help Reduce Disease.

The study Building science and radiofrequency radiation: What makes smart and healthy buildings  was submitted in addition to numerous publications it states,.” There is an urgent need to implement strategies for no- or low-RFR emitting technologies, and shielding, in building design and retrofitting. These strategies include installing wired (not wireless) Internet networks, corded rather than cordless phones, and cable or wired connections in building systems (e.g., mechanical, lighting, security). Building science can profit from decades of work to institute performance parameters, operationalizing prudent guidelines and best practices. The goal is to achieve RFR exposures that are ALARA, “As Low As Reasonably Achievable.”

“Impaired brain development and cognitive function, as well as addictive behaviors in children and adolescents are observed with exposure to RFR [71,81]. In a study of exposure to RFR in schools, 18 teachers wore “exposimeters” to continuously record exposures to a spectrum of RFR. Mean exposure levels varied widely according to activities in the classroom, but peak measures were up to 83,000 μW/m2 [81]. The highest levels occurred when students were streaming video, and the lowest occurred when the teacher had a wired Internet connection in a classroom far from Wi-Fi access points and students’ laptops were in airplane/flight mode [81].”

Clegg, F. M., Sears, M., Friesen, M., Scarato, T., Metzinger, R., Russell, C., Stadtner, A., & Miller, A. B. (2020). Building science and radiofrequency radiation: What makes smart and healthy buildings. Building and Environment, 176, 106324.

Document Type: Notice
Title: Better Indoor Air Quality Management to Help Reduce Disease Transmission in Buildings: Technical Assistance Needs and Priorities to Improve Public Health
Document ID: EPA-HQ-OAR-2022-0794-0001

Non ionizing electromagnetic radiation is an environmental pollutant impacting air quality and human and wildlife health. The EPA has not developed health standards and must initiate activities to adress this pollutant urgently. Without a science based evaluation of the up to date science the EPA cannot make a determination on air quality as this exposure will be ignored. See attached with research and science regarding the issue of non ionizing radiation.

Uploaded File(s):
Some thoughts on the possible health effects of electric and magnetic fields and exposure guidelines.pdf
University of Pittsburgh Law Article FDA FCC.pdf
Expert Letters Filed to FCC Calling For Record Refresh Wireless Radiation .pdf
EMF and Wildlife Part 2.pdf
New Scientific Developments in Radiofrequency Radiation FCC EHT Remand-5.pdf
Risks to Health and Well-Being From Radio-Frequency Radiation Emitted by Cell Phones and Other Wireless Devices davis copy 4.pdf
Thermal and non-thermal health effects of low intensity non-ionizing radiation- An international perspective*.pdf
The Lancet Review EMF Carpentar Bandara .pdf
ICBE-EMFScientifc evidence invalidates health assumptions underlying the FCC and ICNIRP exposure limit determinations for radiofrequency radiation- implications for 5G .pdf
American Academy Pediatrics Letters to FCC and FDA.pdf
The Effect of Electromagnetic Radiation Transmitted from Routers on Antibiotic Susceptibility of Bacterial Pathogens.pdf
Healthy Buildings Wireless EMF Clegg Article .pdf
The roles of intensity exposure duration and modulation on the biological effects of radiofrequency radiation and exposure guidelines lai .pdf
Panagopoulos2019Comparing DNA damage induced by mobile telephony and other types of man-made electromagnetic fields.pdf
PANAGOPOULOS 2021Review .pdf
Cell towers Review Balmori Env Res 2022.pdf

Document Type: Notice
Title: Better Indoor Air Quality Management to Help Reduce COVID-19 and Other Disease Transmission in Buildings: Technical Assistance Needs and Priorities to Improve Public Health
Document ID: EPA-HQ-OAR-2022-0794-0001

The widespread use of wireless technology is rapidly increasing children’s exposure to radiofrequency radiation (RFR), a type of electromagnetic field. There is now substantial published, peer-reviewed scientific evidence indicating that wireless radiation can have a variety of harmful effects–even at exposure levels that meet governments wireless radiation limits. Hundreds of research studies have linked wireless RFR to numerous effects, including impacts to memory, brain development, reproduction, behavior, emotional problems, headaches, and DNA, as well as increased thyroid cancer and brain tumor risk. Studies show that children absorb more intense levels of wireless radiation deeper and more intensely into their brain compared to adults because they have thinner skulls, smaller heads and a higher water content in their brains. More importantly, children are more vulnerable to wireless radiation because their rapidly developing brains are more sensitive. Even very “low level” toxic exposures at a critical time in development can result in serious effects later in life. Today’s children will have a higher lifetime exposure to wireless radiation than previous generations and their exposures begin during pregnancy. The American Academy of Physicians has long called for an update to cell phone radiation regulations because research finds children can absorb up to 10 or more times higher radiation than adults into their brain, eyes and bone marrow. World Health Organization’s International Agency for Research on Cancer In 2011, radiofrequency electromagnetic fields (RF-EMF) were classified as a Group 2B possible carcinogen by the World Health Organization’s International Agency for Research on Cancer (WHO/IARC). The WHO/IARC scientists clarified that their determination was for RF-EMF from any source be it cell phones, wireless devices, cell towers or any other type of wireless equipment. Since 2011, the published peer-reviewed scientific evidence associating RF-EMF (also known as RF-EMR and RFR) to cancer and other adverse effects has significantly increased. A large-scale animal study published in Environmental Research found rats exposed to cell tower emission RF levels had elevated cancers, the very same cancers also found in the US National Toxicology Program animal study of cell phone level RF that found “clear evidence” of cancer in carefully controlled conditions Falcioni 2018. In 2019, the WHO/IARC advisory committee recommended that radiofrequency radiation be re-evaluated as a “high” priority in light of the new research. The date of the re-evaluation has not been set. Currently, several scientists conclude that the weight of currently available, peer-reviewed evidence supports the conclusion that radiofrequency radiation is a proven human carcinogen (Hardell and Carlberg 2017, Peleg et al. 2022, Miller et al. 2018). European Parliament requested a research report “Health Impact of 5G” which was released in July 2021 and concluded that commonly used RFR frequencies (450 to 6000 MHz) are probably carcinogenic for humans and clearly affect male fertility with possible adverse effects on the development of embryos, fetuses and newborns. A review entitled “Evidence for a health risk by RF on humans living around mobile phone base stations: From radiofrequency sickness to cancer reviewed the existing scientific literature and found radiofrequency sickness, cancer and changes in biochemical parameters (Balmori 2022).

Uploaded File(s):
35 – Mobile Phone Base Stations and Risk of Type 2 Diabetes.pdf
The Health Argument against Cell Phones and Cell Towers.pdf
21 – What is radiation level before 5G – Lopez – 2021.pdf
14 – Epidemiological Evidence for a Health Risk from Base Stations.pdf
High Antennas Close to People- Environmental Res 2022 copy.pdf
Wireless SilentSpring Santa Clara Medical Association Oct 2 2018.pdf
A 5G Future-Will it Give Us a Smart Nation or Contribute to an Unhealthy One_ SCCMA Bulletin 6_4_2017 PDF copy.pdf
RF Increases Pro inflammatory- Black Carbon .pdf
Immune Responses to Multi-Frequencies of 1.5 GHz and 4.3 GHz Microwave Exposure in Rats- Transcriptomic and Proteomic Analysis.pdf
European Parliament Report Health Risks of 5G .pdf
Exposure to cell phone radiofrequency changes corticotrophin hormone levels and histology of the brain and adrenal glands in male Wistar rat.pdf
Hinrikus et al 2016 – RF diffusion mechanism.pdf
Resolution 1815 European Assembly .pdf
EPA Hankin Letter .pdf
Evidence that Electromagnetic Radiation is Genotoxic-.pdf
Lerchl Tumor promotion by exposure to radiofre…ure limits for humans. – PubMed – NCBI.pdf
Martin Pall Literature review_wifi and health impacts copy.pdf
5G and Cell Tower Radiation Briefing PDF.pdf