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What Happened to “Irradiated”, the Massive EMF Safety Advocacy Document that was Submitted to the FCC?

The FCC Requested Public Comments on Revisions to EMF Exposure Standards

A book sized 416 page document strikingly titled:

IRRADIATED A comprehensive compilation and analysis of the literature on radio frequency fields and the negative biological impacts of non-ionizing electromagnetic fields (particularly radio frequency fields) on biological organisms

was delivered online to the FCC, in response to their request for “Comments on Revisions to EMF Exposure Standards” from the public, which would have bearing on their 5G Fast Plan and proposals, in hopes that its massive “thump factor” (the impressive sound the ample sized document made when thumped down on a table) and obvious large amount of work referencing scientific studies, biological research, personal electo-hypersensitivity stories, not to mention its formidable heart and soul would persuade the FCC to revise their current USA public EMF exposure safety levels in the face of such compelling evidence.

The document/book has achieved archival immortality by its inclusion on the FCC.gov website and, along with all other public comments that were submitted, it will remain part of the public record forever. However it passed through the entire public feedback process without making even the fainest thump in terms of making the positive difference that it set out to do. To understand what went wrong, and why the document did not receive the consideration that many concerned citizens and supporters of EMF advocacy groups thought it merited, a look at the Table of Contents outlining what the document contained is instructive.

When you have time I encourage you to download IRRADIATED” in its entirety and take the opportunity to read its 416 pages more thoroughly. It is a shining example of the efforts of an EMF Advocate Group called Wireless Action, one of the many advocate groups working on behalf of the American public to achieve a safer EMF living environment.

Here, for the convenience of a quick overview, is the four-page Table of Contents of Irradiated, listing what topics were included and discussed in its submission to the FCC during the call for public comment, which was held December 4th 2019 to January 3rd 2020.

  • Table of Contents           2
  • Introduction      9
  • The Tip of the Truth       12
  • The EMF Controversy – Common Misconceptions            13
  • Non-industry studies vs industry studies show vast difference in the harmful effects of microwave radiation  20
  • Wireless radiation causes cancer, according to the latest scientific findings          22
  • Expressions of Concern from Scientists, Physicians, Health Policy Experts & Others              23
  • Scientist replies to Quebec opinion on RF health impacts         29
  • Over 2,000 Studies Confirm TOXIC Effects of EMF From Cell Phones and Household Appliances   33
  • Study Proves Microwave Radiation Directly Affects Your Heart   35
  • Press Release by the Health Protection Agency on 15th Sept 2009 entitled “Scientist probe laptops Wi-Fi Emissions              37
  • Dispelling the Wireless Myths    43
  • The Invisible Threat: Radiofrequency Radiation Risk       47
  • Radiation from Cell Phones and Wi-Fi Are Making People Sick — Are You at Risk?              50
  • Radiation From Cell Phones and Wi-Fi Are Making People Sick — Are We All at Risk?     56
  • Are Cell Phones and Wi-Fi Hazardous to Your Health?    63
  • Canadian Tech Leader Warns of Wi-Fi, Smartphone, Cell Tower Radiation           67
  • Do Cell Phone and Wi-Fi Fields Harm Our Bodies?           69
  • Cell Phones & Wi-Fi – Are Children, Fetuses and Fertility at Risk?              72
  • New report: Wireless technology causes brain damage  82
  • Children’s Health Expert Panel: Cell Phones & Wi-Fi―Are Children, Fetuses and Fertility at Risk?  83
  • Wi-Fi & Cell Phones Pose a Much Greater Danger Than Most People Realize       89
  • Is Your Cordless Phone Harming Your Health?   90
  • Wireless pollution ‘out of control’ as Corp race for 5G gears up       92
  • A 5G Wireless Future     96
  • Medical Director of Switzerland’s Paracelsus Clinic Takes Stand on Hazards of Electromagnetic Pollution ‘Electromagnetic Load’ a Hidden Factor in Many Illnesses             101
  • How to identify and reduce electrosmog             103
  • Another Inconvenient Truth       110
  • Controversy surrounding EMF exposure: Do wireless devices pose dangers?              112
  • Are my toys playing with my DNA?          114
  • What Will Happen When They Know?    120
  • If Wi-Fi and cell phone radiation are safe, why has Belgium’s telecomm boss banned them from his offices?  122
  • Next time you’re on a cellphone looking up at those long lingering plumes spreading across the sky, you might decide to end that call         124
  • The Kids Are Not All Right            128
  • Autism may be Linked to Electromagnetic Radiation Levels In Mother’s Bedroom During Pregnancy           132
  • Autism and EMF? Plausibility of a pathophysiological link – Part I              133
  • Study Uncovers How Electromagnetic Fields Amplify Pain in Amputees   134
  • Krakow’s bold step to curb electromagnetic pollution reflects growing evidence of harm     136
  • The effects of radiofrequency electromagnetic radiation on sperm function              140
  • Microwave frequency electromagnetic fields (EMFs) produce widespread neuropsychiatric effects including depression    141
  • The alteration of spontaneous low frequency oscillations caused by acute electromagnetic fields exposure              142
  • Additive Effects of Millimeter Waves and 2-Deoxyglucose Co-Exposure on the Human Keratinocyte Transcriptome       143
  • Transcriptome Analysis Reveals the Contribution of Thermal and the Specific Effects in Cellular Response to Millimeter Wave Exposure           144
  • Thermal mechanisms of millimeter wave stimulation of excitable cells   145
  • Low power radio-frequency and microwave effects on human electroencephalogram and behavior 145
  • Millimeter wave absorption in the nonhuman primate eye at 35 GHz and 94 GHz              146
  • Increased sensitivity of the non-human primate eye to microwave radiation following ophthalmic drug pretreatment             146
  • Effects of low-intensity extremely high frequency electromagnetic radiation on chromatin structure of lymphoid cells in vivo and in vitro            147
  • Suppression of nonspecific resistance of the body under the effect of extremely high frequency electromagnetic radiation of low intensity           147
  • Effects of millimeter wave on gene expression in human keratinocytes  148
  • Low power radio-frequency and microwave effects on human electroencephalogram and behavior 149
  • Impact of 60-GHz millimeter waves and corresponding heat effect on endoplasmic reticulum stress sensor gene expression              149
  • Experimental studies on the influence of millimeter radiation on light transmission through the lens 150
  • Changes in gap junctional intercellular communication in rabbits lens epithelial cells induced by low power density microwave radiation             150
  • The Neuroinflammatory Etiopathology of Myalgic Encephalomyelitis/Chronic Fatigue Syndrome (ME/CFS)       151
  • EUROPAEM EMF Guideline 2016 for the prevention, diagnosis and treatment of EMF-related health problems and illnesses         152
  • Dirty Electricity and the Link to Cancer   154
  • Wireless Wake-Up Call: A New Paradigm in EMF Science              161
  • EMF Superhero 166
  • Case Study: Actual Measurements, Interpretation, and Comparison of RF Radiation Exposures 170
  • Digital Utility Meters (“Smart” Meters)   178
  • Smart meters and cell damage from pulsed EM radiation – our health at risk?              178
  • Getting Smarter About the Smart Grid   184
  • Electric Smart Meters: Not a Smart Solution for Your Health?      187
  • Smart Meter Radiation 100 Times Greater Than Cell Phones—And Exposure Is Constant, Doctors Warn              191
  • Toxic radiation: So-called ‘SMART METERS’ are anything but smart         193
  • EMF damages chitin – the missing link to bee deaths and monarch butterfly declines?            195
  • Biological Effects from RF Radiation at Low Intensity Exposure, based on the BioInitiative 2012 Report, and the Implications for Smart Meters and Smart Appliances         197
  • Cell Phones & Cell Towers           200
  • Cell Phone Use in Children and Teens Translates To 5 Times Greater Increase in Brain Cancer      200
  • New study reveals 300% Increased brain cancer risk for long-term users of cell phones and cordless phones     202
  • Brain Cancer Top Killer in Kids: Are Cellphones a Factor?              204
  • Why You Need to Stop Carrying Your Mobile Phone in Your Pocket or Bra              207
  • Why Cell Phone Radiation Danger is Serious – Science Tells the Story      211
  • Only ten minutes on a mobile could trigger cancer, scientists believe      214
  • Cell Phones and Health – California Department of Public Health              216
  • How Safe is Your Cell Phone?     218
  • Apple’s new ‘wireless’ headphones emit radiation … right next to your brain              221
  • Major cell phone radiation study reignites cancer debate            223
  • Cell Phone Companies Are Panicking Over New Study Linking Cell Phone Use And Cancer  226
  • New Expert Warning: Claims That Cellphones Are Safe ‘Endanger Public Health’ and Are ‘Ludicrous’        227
  • Children Can Absorb 10x More Radiation In Their Bone Marrow Than Adults              229
  • Your cellphone is killing you: What people don’t want you to know about electromagnetic fields  230
  • Report of Partial Findings from the National Toxicology Program Carcinogenesis Studies of Cell Phone Radiofrequency Radiation in Hsd  235
  • Dangers of living near cell phone towers raised 236
  • Scientific Evidence Shows That Americans’ Brains Are Being Fried By Cell Towers              238
  • Research Findings Presented at International Conference Link Cell Phone Microwave Radiation to Cancer, Low Birth Weight and Sperm Damage  239
  • How this sign put Berkeley in the center of the cellphone safety debate 241
  • iPhone 6 Bendgate: Apple’s Instructions Say Not To Keep Your Phone In Your Pocket Anyway . 245
  • Mobile phones are ‘cooking’ men’s sperm          247
  • The Hidden Dangers of Cell Phone Radiation      251
  • Children Are Endangered by Cell Phone Radiation!          259
  • Cellphone Use Tied to Changes in Brain Activity 262
  • Are wireless phones linked with brain cancer risk?          265
  • Has radiation from cell phones and microwaves caused brain tumor cases to double in Denmark?  267
  • Tree damages in the vicinity of mobile phone base stations        269
  • Study links bee decline to cell phones    270
  • How Your Cell Phone Is Killing Bees And Starving The Planet        271
  • It’s Official – Cell Phones are Killing Bees              272
  • Cell phone signals really are killing the bees, study shows            273
  • Report of Possible Impacts of Communication Towers on Wildlife Including Birds and Bees            274
  • Impacts of radio-frequency electromagnetic field (RF-EMF) from cell phone towers and wireless devices on biosystem and ecosystem – a review      276
  • Cell Phones are the Cigarettes of the 21st Century           277
  • Pediatricians Warn Cell Phone Radiation Poses Cancer Risk to Children  279
  • EEG Changes Due to Experimentally Induced 3G Mobile Phone Radiation              280
  • Effects of radiofrequency electromagnetic fields on the human nervous system              284
  • Evaluation of Mobile Phone and Cordless Phone Use and Glioma Risk Using the Bradford Hill Viewpoints from 1965 on Association or Causation             284
  • Fetal radiofrequency radiation exposure from 800-1900 mhz-rated cellular telephones affects neurodevelopment and behavior in mice      285
  • Prenatal and Postnatal Cell Phone Exposures and Headaches in Children              285
  • Reduction of Phosphorylated Synapsin I (Ser-553) Leads to Spatial Memory Impairment by Attenuating GABA Release after Microwave Exposure in Wistar Rats       286
  • Purkinje cell number decreases in the adult female rat cerebellum following exposure to 900 MHz electromagnetic field        287
  • The 2100MHz radiofrequency radiation of a 3G-mobile phone and the DNA oxidative damage in brain          287
  • Association between number of cell phone contracts and brain tumor incidence in nineteen U.S. States       288
  • Effects of mobile phone radiation (900 MHz radiofrequency) on structure and functions of rat brain     289
  • A Challenging Issue in the Etiology of Speech Problems: The Effect of Maternal Exposure to Electromagnetic Fields on Speech Problems in the Offspring              290
  • Effects of Cell Phone Radiofrequency Signal Exposure on Brain Glucose Metabolism       291
  • 900 MHz electromagnetic field exposure affects qualitative and quantitative features of hippocampal pyramidal cells in the adult female rat 292
  • Chronic prenatal exposure to the 900 megahertz electromagnetic field induces pyramidal cell loss in the hippocampus of newborn rats              292
  • Mobile Phone Use, Blood Lead Levels, and Attention Deficit Hyperactivity Symptoms in Children: A Longitudinal Study       293
  • Effect of low level microwave radiation exposure on cognitive function and oxidative stress in rats   293
  • Cognitive impairment and neurogenotoxic effects in rats exposed to low-intensity microwave radiation      294
  • Maternal mobile phone exposure alters intrinsic electrophysiological properties of CA1 pyramidal neurons in rat offspring 294
  • Neurodegenerative changes and apoptosis induced by intrauterine and extrauterine exposure of radiofrequency radiation         295
  • Effects of radiofrequency radiation exposure on blood-brain barrier permeability in male and female rats               296
  • Effects of prenatal exposure to a 900 MHz electromagnetic field on the dentate gyrus of rats: a stereological and histopathological study             297
  • Effects of prenatal and postnatal exposure to GSM-like radiofrequency on blood chemistry and oxidative stress in infant rabbits, an experimental study  297
  • Mobile phone use and risk for intracranial tumors and salivary gland tumors – A meta-analysis 298
  • Cell phone use and behavioral problems in young children         299
  • Prenatal and postnatal exposure to cell phone use and behavioral problems in children              300
  • The influence of microwave radiation from cellular phone on fetal rat brain              301
  • Possible cause for altered spatial cognition of prepubescent rats exposed to chronic radiofrequency electromagnetic radiation           301
  • Maternal exposure to a continuous 900-MHz electromagnetic field provokes neuronal loss and pathological changes in cerebellum of 32-day-old female rat offspring            302
  • Microwave radiation induced oxidative stress, cognitive impairment and inflammation in brain of Fischer rats      302
  • Wi-Fi     303
  • Wi-Fi Radiation: An Invisible Threat to Your Health?       303
  • 10 Shocking Facts about the Health Dangers of Wi-Fi      304
  • Can Wi-Fi Signals Stunt Plant Growth?    306
  • Oh my…what’s in Wi-Fi?             308
  • Checkout 5 Ways Your Wi-Fi Could be Causing You Harm            310
  • Wi-Fi Radiation Is Killing Trees, New Study Finds              312
  • Wi-Fi radiation from laptops, smartphones is damaging your sperm       313
  • Use of laptop computers connected to internet through Wi-Fi decreases human sperm motility and increases sperm DNA fragmentation              314
  • How Does The iPad Influence Your Health: What You Are Not Being Told is This              315
  • STEALTH CANADA—deep-sixing the science on wireless radiation            316
  • Effects of 2.4 GHz radiofrequency radiation emitted from Wi-Fi equipment on microRNA expression in brain tissue      317
  • Schools 318
  • Inviting Discussion about Safer Tech Use in Schools – Katie Singer            318
  • Message to Schools and Colleges about Wireless Devices and Health      329
  • School officials may be personally liable for exposing children to wireless radiation            332
  • Reykjavik Appeal on wireless technology in schools         333
  • Maryland State Advisory Council Recommends Reducing School Wireless to Protect Children              335
  • Cyprus Removes Wi-Fi from Kindergartens and Halts Wireless Deployment Into Public Elementary Schools          338
  • Radiofrequency Radiation in Communities and Schools Actions by Governments, Health Authorities and Schools Worldwide         340
  • Wi-Fi banned from pre-school childcare facilities in a bold move by French government       341
  • Could Wi-Fi in schools be harming our kids?       343
  • Teen Allergic to Wi-Fi Commits Suicide, Parents Say        346
  • Cell Phone Usage Inside Schools              348
  • Landlines            354
  • Saving Your Landline May Save Your Life             354
  • Mauk said her landline was the only thing working in her house after the 2015 windstorm         355
  • A Landline Might Be Your Best Option during a Storm     357
  • Landlines: The ‘Dinosaur Phone Technology’ That Could Save You in a Crisis              358
  • Electromagnetic Hypersensitivity             360
  • Electrosensitivity: is technology killing us?           360
  • Electromagnetic Hypersensitivity: Evidence For A Novel Neurological Syndrome              368
  • Electromagnetic Field Sensitivity              370
  • Science: Plant and Animal Electromagnetic Sensitivity     374
  • Will We All Become Electrosensitive?     382
  • Corded or cordless: have you made the connection?      383
  • Electromagnetic Hypersensitivity, It is real!         385
  • Further Testimonials & Stories   387
  • Direct Testimony of Joshua Hart              387
  • Collateral Damage: Speaking Out Against Wireless Harm             390
  • On the run …from the silent, invisible foe            392
  • My Life Living 6 Feet Under Cell Phone Towers   394
  • Paul’s EMF Refugee Story            397
  • Additional Resources     404
  • Conclusion         405
  • Appendix A: Measuring Radiation           407
  • Appendix B: Pictures & Diagrams            408
  • Appendix C: Listservs & Support Groups              410
  • Appendix D: Further Resources 411

As complete as the document seems judging by its Table of Contents (copied here as it appears in the FCC archive), it could not be considered by the FCC, simply because it did not follow the protocols for submitting, and without that they have no formal structure with which to draw conclusions, or even to take its contents into consideration.

How could this happen?

When the FCC called for comments they also published the guidelines for submitting comments, which included a specific structure for telling the FCC reviewers basically what to change and why, So, while comments are open to everyone (paraphrased from FCC Docket 13-84 Document 13-39) from “the general public to highly training health and safety agencies to federal and expert organizations”. Open means open, so even if someone off the street submitted their comments the FCC is mandated to handle each comment by the same structure and criteria, respecting each comment without regard to who the commenter was or if he/she are qualified to make suggestions. But similarly, guidelines means guidelines, so all comments are considered according to the structure laid out in the guidelines for commenting.

As fussy, or crazy-making, as that may seem, official regulation setting (i.e. government law making) bodies, in this case the FCC (Federal Communication Commission), and the respected bodies that make EMF standard recommendations to the regulating body, which in the case of the FCC are the IEEE, ICNIRP, FDA, EPA and the general public, can only operate using the same structure applied to all input.

The recommending bodies, (always keep in mind that the general public is a respected part of these), must follow guidelines that are in place to provide the official FCC committee reviewers a consistent format for examining the facts, understanding the rationale, and achieving a basis for making concrete suggestions that are put forward as recommendations for changes to the standards by the committee reviewers to the FCC regulators.

This structure is what forms the basis for the FCC to justify any changes in regulations (laws), because the FCC does not create standards it merely selects them from the information that they are provided with.

Understanding this is key to understanding why the Irradiated document, impassioned though it was, will languish in the FCC Comment archive forever disregarded, at least by this commenting process if not by countless concerned citizens who recognize themselves in page after page.

Taking a look at the FCC’s January 2020 response to the public comments it received tells us how the Irradiated document, and the thousand or so other public documents like it that were reportedly received by the FCC, could have been submitted in order to be regarded, taken into consideration, and produce the changes, or the impetus for change, that it intended. And in the reading of this official response we can learn more about how to follow the guidelines.

The guidelines for commenting serve as a roadmap that all EMF Advocate groups and private concerned citizens alike can follow going forward. Because the good news is that the commenting process is open to the public at regular intervals for exactly this type of input from you, since all USA government agencies dealing with the public must provide means for direct input from the public whom they serve.

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Patricia Young

Patricia Young is the author of several books that you'd find if you were wandering in the self-help section of your bookstore. Among the far ranging subjects her work has covered, one of the most popular topics with her audiences is health self care, which led to her "self-helpful" writings on biological protection from EMF, a lifeline for today's technology users adrift in the rising sea of Electromagnetic exposure.

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