Click to Download EHT’s Critique of the Oregon Health Authority Review on the Health Effects of Wireless to Schoolchildren

In response to the 2020 Oregon Health Authority Report on Health Effects of Wireless in Schools that seems to conclude the science does not show harm from wireless radiaton, senior scientists from the United States and around the world signed onto a letter sent to Oregon Governor Kate Brown, the State Legislature and OHA’s leadership calling for immediate retraction of the OHA report on the health risks of wireless due to its flaws, inconsistencies and lack of science-based conclusions. The numerous inadequacies and lack of science-based conclusions have been documented in a 100 page report by Environmental Health Trust also referenced in the scientists’ letter.

The scientific letter states, “The report would not pass peer review as it omitted animal and cellular studies and thus it does not provide a comprehensive or systematic review of the relevant literature….The failure of Oregon Health Authority to utilize in their review the significant body of evidence showing harm to animals from wireless radiation exposure is contrary to public health principles and OHA’s own established protocols of using animal studies in many other reviews. By omitting key peer reviewed scientific evidence of adverse effects and downplaying the scientific studies showing impacts to memory and the brain, the OHA review does not comport with the Agency’s mission of protecting and promoting public health.”

Download the 100+ page Critique of the Oregon Report on Wireless here.

Environmental Health Trust: Scientific Problems and Errors of the Oregon Report on Wireless, Children and Health

The Oregon Health Authority 2020 report “Wireless technology health risks report; Senate Bill 283” would not pass peer review as it does not provide a comprehensive or systematic review of the relevant literature, has errors, omits critical research and accordingly does not comply with SB 283 (2019) which called for an investigation into the health effects of exposure to wireless radiofrequency radiation (RFR) to children, especially in the school setting, using “independently funded” peer reviewed scientific studies.

This report documents the errors, inconsistencies and scientific basis underpinning the call to retract the Oregon Health Authority (OHA) 2020 report “Wireless technology health risks report; Senate Bill 283” and the OHA website SB 283 content and OHA SB 283 Factsheet.

The children of Oregon deserve a professional high quality assessment of the hazard posed by wireless radiation.

I. Executive Summary

Scientists, public health professionals and medical experts who study the biological effects and public health impacts from radiofrequency radiation (RFR) exposure are calling for the Legislature to retract the Oregon Health Authority’s Report on Wireless Radiation in Schools released to the Legislature on December 31, 2020 and to reject its determination that there is insufficient evidence to conclude that RFR exposure is harmful to children. A retraction is justified because the Oregon Health Authority (OHA) Report does not provide a comprehensive or systematic review of the relevant literature, has serious errors and accordingly does not comply with SB 283.

The report was prepared for the Oregon State Legislature by the Oregon Health Authority after Senate Bill 283 called upon the OHA to “review peer-reviewed, independently funded scientific studies of the health effects of exposure to microwave radiation, particularly exposure that results from the use of wireless network technologies in schools…”

SB 283 specifically called for “independently funded” research; however, the OHA review included and highlighted several industry funded research studies despite the fact that research shows sponsorship can impact the results when it comes to non ionizing electromagnetic radiation.

SB 283 directed focus to exposure in schools yet OHA did not review research on school setting RFR exposures nor did they attempt to characterize actual RFR exposures with actual measurement.

SB283 was specifically focused on RFR impacts to children. Yet OHA did not present research on children’s unique vulnerability to wireless as documented in numerous research studies. Childrens rapidly developing brains are more sensitive to wireless radiation and children have been found to adsorb proportionately higher RFR than adults.

Best practice recommendations for systematic reviews on human health risks posed by environmental exposures were not implemented in the OHA review. OHA did not define the objectives of the evaluation nor identify the key questions to be addressed. OHA presented no scientific explanation why the scope of the research review omitted animal and in vitro studies. If the objective of the review was to determine if radiofrequency was hazardous, then the scope of the review should have included multiple evidence streams. OHA did not GRADE, rate or weigh the evidence. OHA did not conclude by classifying RFR into hazard identification conclusion categories according to key questions, but merely concluded with a summary statement.

A scientifically defensible investigation into the harmful effects of an environmental agent such as radiofrequency radiation (RFR) by a public health agency should have adhered to good practice recommendations for systematic review methodology.

This report documents fundamental flaws and deficiencies in the OHA Report which include:

No publication or public consultation on scope and review protocols.
The omission of animal and in-vitro research on RFR.
The omission of reference to the classification of radiofrequency radiation as a Class 2B Carcinogen by the World Health Organization International Agency for Research on Cancer (IARC) in 2011.
The omission of research on children’s unique vulnerability to RFR.
The omission of research characterizing school exposures to the multitude of RFR sources students are exposed to in the classroom, including Wi-Fi routers, wireless devices, cell phones and cell towers.

Three principal types of evidence are relevant to evaluating the impact of wireless radiation on children: 1) exposure modeling; 2) toxicological evaluations under controlled conditions; and 3) human studies. By excluding both modeling studies and experimental studies, the final report represents a narrow and highly skewed review of the literature. The lack of transparency and rigor in the development of the scope, flawed methodology and analysis as well as the numerous omissions and inaccuracies cast serious doubt on the validity of the review.

Previously conducted OHA public health assessments did rely upon data from animal studies, referenced U.S. National Toxicology Program studies, referenced the International Agency for Research on Cancer (IARC)/WHO reports and documented children’s unique vulnerability — all of which this OHA investigation on the health risks from children’s wireless exposure rejected.

OHA’s omission of laboratory animal studies is contrary to the scientific consensus on methods to identify a hazard. The world’s leading public health agencies all consider animal research:

The U.S. National Toxicology Program (NTP)
Environmental Protection Agency (EPA)
Food and Drug Administration (FDA)
International Agency for the Research on Cancer of the World Health Organization (WHO/IARC)

Center for Disease Control (CDC)

The failure of Oregon Health Authority to utilize in their review the significant body of evidence showing harm to animals from wireless radiation exposure is contrary to public health principles and OHA’s own established protocols of using animal studies in their own reviews. By omitting key peer reviewed scientific evidence of adverse effects and downplaying the scientific studies showing impacts to memory and the brain, the OHA report does not comport with the Agency’s mission of protecting and promoting public health.

In sharp contrast to the Oregon report, the New Hampshire State Commission on 5G Health and Environmental Effects interviewed numerous experts in a transparent process and issued a final report laying out 15 recommendations to the Governor which include reducing exposure to children in schools by replacing Wi-Fi with wired technology in schools, educating families, creating setbacks for between cell towers and schools and measuring actual RFR levels.

The children of Oregon deserve a professional high quality assessment of the hazard posed by wireless radiation. On behalf of the families of Oregon, the Oregon legislature must reject this report and direct OHA to undertake a more comprehensive scientific review that follows accepted professional best practices and that only reviews studies that are independently-funded, thereby reducing the appearance of scientific bias or undue influence by wireless industry interests.

The children of Oregon deserve a professional high quality assessment of the hazard posed by wireless radiation. The faults and omissions detailed in this report warrant an immediate retraction of the OHA Report on wireless radiation and children.

Click to Download EHT’s Critique of the Oregon Health Authority Review on the Health Effects of Wireless to Schoolchildren

I. Executive Summary

II. Overview

Senate Bill 283
Wireless as an Environmental Exposure in Schools.
Oregon Health Authority (OHA) omitted research on children’s unique vulnerability to radiofrequency radiation despite the fact that PIAs show OHA scientists sharing studies on children’s unique vulnerability to radiofrequency wireless radiation.
OHA omitted research on the vulnerability of the developing pregnancy.
Findings of Public Records Requests to OHA show OHA initially intended to include animal studies (such as the NTP that found cancer and DNA damage) and OHA was going to consider all sources of RFR in schools.
Cancer is increasing in children in the United States.
Letter From Numerous Experts to the Governor and Oregon Health Authority
Letter From Environmental Working Group to the Oregon Health Authority

III. OHA Report Does Not Follow Good Practice Recommendations for Systematic Review

The OHA did not follow best practices for systematic reviews on human health risks posed by environmental exposures.
List of deficiencies related to best practices.
OHA’s search terms are not consistent with the exposure investigated.
Animal studies were omitted.
The National Toxicology Program (NTP) animal study was omitted from the final OHA Report despite the fact that public records request emails show OHA Report authors/reviewers sharing the NTP study with each other.
NTP Results of DNA damage after 14 weeks of RFR exposure were fully omitted despite being circulated by OHA staff in the beginning.
OHA’s omission of animal data is contrary to the scientific consensus on methods to identify a hazard.
Cellular studies- In vitro evidence streams- were omitted.
Flawed scoping resulted in omissions of important human studies in addition to animal and in vitro.
Ignoring animal data and in vitro (cells grown in labs for experimentation) studies in OHA’s investigation of “health effects” means no conclusions can be drawn.
The OHA Report Omits the Monograph of the International Agency for Research on Cancer of the World Health Organization Classifying RFR as a Class 2B Carcinogen.
Flawed scoping resulted in omissions of important human studies in addition to animal and in vitro.
Ignoring animal data and in vitro (cells grown in labs for experimentation) studies in OHA’s investigation of “health effects” means no conclusions can be drawn.
OHA Report omits research or discussion on electromagnetic sensitivity.
The OHA report omits research on vulnerable populations such as the elderly and medically compromised people such as people with cancer.
OHA omits a detailed discussion of data gaps in the scientific literature as well as the limitations of the review as it pertains to the question “Is RFR harmful.”
OHA did not ensure subject matter experts participated in the scope, design or review of the study.

OHA Report Scope and Content does not meet the mandate of SB 283

The OHA Report includes, highlights and seems to give weight to industry funded research.
Example provided as to how industry supported scientists are cited numerous times in the Oregon Report.
Conflicts of industry are a serious challenge in the science of electromagnetic fields.
The OHA Report omits research characterizing RFR exposures in schools.
OHA did not make any attempts to actually measure RFR exposures in Oregon schools.
The OHA omits the positions of public health and medical organizations, many of which recommend children reduce wireless exposures, especially to their brains.
The OHA conclusion that there is insufficient evidence that RFR causes cancer or other health effects is inaccurate due to the flawed design of the investigation.
The OHA summary is an inaccurate summary of the state of science and is a dangerous and misleading report as it creates the illusion that exposure to wireless radiation is safe…even for the most vulnerable among us, our children. The summary contradicts the conclusions of numerous published papers.

OHA Report has scientific errors, misrepresentations, omissions and unqualified conclusions.

The OHA Report conclusion misrepresents the policy positions and research of US federal agencies.
The OHA Report downplays impacts to memory and the brain.
OHA conclusions on effects to reproduction ignore numerous scientific experiments and exemplifies the flaws in the reports handling of the issue.
OHA conclusions on RFR impacts to brain waves lack sophistication.
The OHA Report contains serious errors.
The OHA Report contains unpublished work.
OHA presents outdated and erroneous industry tied information on mechanisms without presenting the latest science on mechanisms.
Published reviews by experts in bioelectromagnetics contradict OHA conclusions.
The January 19, 2020 OHA Website Update and Factsheet on SB 283 has unfactual debunked industry tied information and misleads the public.

The OHA Report is not consistent with OHA’s mission and values nor with previous methods used in OHA investigations.

Lack of transparency and a shroud of secrecy as to study design.
Animal and cell data omitted despite the fact that numerous previous OHA investigations have relied on animal and cell data.
OHA scientists have published research on animal data, yet animal data was not included in the health assessment.
The OHA Report ignores prevention considered the cornerstone of public health.
The OHA ignores the policies regarding the precautionary principle put forward by the American Public Health Association.
The American Public Health Association Public Health Code of Ethics is the roadmap forward.
Environmental justice and health inequities
Transparency
Involve affected stakeholders
Will the report achieve its stated health goals
Systematic, comprehensive data collection and analysis
Safeguards in place so that public health information does not harm communities nor be misinterpreted by decision makers
Collect relevant data
Ensure data validity and account for the limitations of available data
The implications of this report are far reaching and pose serious accountability and liability issues.
Scientific References on Effects of Wi-Fi Radiation

Click to Download EHT’s Critique of the Oregon Health Authority Review on the Health Effects of Wireless to Schoolchildren

Excerpts from EHT’s Critique:

“Children are disproportionately affected by environmental exposures, including cell phone radiation,” stated Thomas K. McInerny, MD, FAAP president of the American Academy of Pediatrics in a letter to the FDA and FCC.

“The average exposure from use of the same mobile phone is higher by a factor of 2 in a child’s brain and higher by a factor of 10 in the bone marrow of the skull,”—The World Health Organization’s International Agency for Research on Cancer’s (IARC) 2011 Monograph on Radio Frequency.

On OHA’s webpage “Toxic-Free Kids Act” OHA states, “Children are more vulnerable than adults to permanent injury from toxic chemicals because: They are going through critical stages of growth and development; Their bodies are smaller than adults, so by comparison their exposure level to toxins is higher.” All of these issues pertain to the issue of RFR and children.

Children are more vulnerable to RFR for the following reasons:

Note: OHA omitted all the studies cited in this section and did not review research on children’s proportionately higher RFR exposures compared with adults and unique vulnerability to their developing brains.

Proportionately deeper penetration of RFR into the brain: Children have smaller heads than adults with shorter distances from their skull to the brain center, resulting in higher RFR absorption extending deeper into the brain compared to an adult (Morris et al., 2015, Ghandi 2015, Ferreira and de Salles 2015, Wiart et. al., 2008 ).
Thinner skulls and higher conductivity of tissues allow higher intensities of RFR into the eye and brain: Scientific modeling finds younger brains absorb proportionally more radiation in the eyes and brain–grey matter, cerebellum and hippocampus (Fernandez et al. 2018, Christ et al., 2010, Mohammed 2017 ).
More active stem cells in their bodies: Research shows that stem cells are more sensitive to microwave radiation, and children have more active stem cells (Belyaev 2010, Williams et al. 2006).
Developing brains are more vulnerable to neurotoxic exposures: Not only do children absorb higher peak doses in the brain than adults, their brain is growing rapidly, subject to different windows of vulnerability, and thus more susceptible to adverse impacts and environmental neurotoxicants. Exposures that take place during fetal development or early childhood may cause permanent brain injury, whereas the same doses may have little impact in adults (Heindel et al., 2015, Weiss 2000, Lanphear 2015, Redmayne and Johansson 2014 and 2015).
Regulations based on an adult head and body: Government regulations were based on a 220-pound man’s head, not a child’s head. This is one reason why the American Academy of Pediatrics has repeatedly written to the FCC and FDA calling for more protective laws (Ghandi 2012, AAP 2012 & 2013).
A lifetime of exposure: Children will receive a greater cumulative exposure than adults (Belpomme et. al, 2018, Miller et al, 2019).

RFR exposures during pregnancy should be considered by OHA. Cabot 2014 simulated the exposure to the developing fetus at different gestational stages and found some simulations exceeded RFR limits for occupational exposure. FCC limits are based on animal studies of short term exposures from decades ago. They were not designed to protect against cancer or reproductive damage. Even if RFR exposures are compliant with FCC limits, this does not guarantee protection from health effects.

“The developing brain is more sensitive to toxins, and it is still developing until over 20 years of age. The greater absorption of RF energy per unit of time, the greater sensitivity of their brains, and their longer lifetimes with the risk to develop a brain tumor or other health effects leaves children at a higher risk than adults from mobile phone radiation,”—Lennart Hardell 2017

In addition to the NTP and Ramazzini study showing a carcinogenic effect, there are numerous additional published animal studies that provide scientific evidence linking non ionizing radiation exposure to biological effects such as (click on link to go to publication) damage to ovaries, uterine oxidative stress, tumor promotion, hepatic injury, DNA fragmentation, alteration of gene expression, altered hematological profiles, increased stress and anxiety, impaired hippocampal learning and spatial memory,cognitive impairment and hippocampal tissue damage, oxidative stress of brain and liver, altered testes development, changes to microRNA expression in brain tissue, cognitive impairment, changes in the morphology and expression of heat shock proteins and glucocorticoid receptors in thymus, heart variability and changes to blood pressure, impacts to growth and pubertal development, impaired spatial memory, apoptosis, DNA oxidation, nitrosative stress, altered melatonin, deoxyribonucleic acid damage, oxidative stress in the kidney, abnormal pregnancy, impacts to cornea, immunohistopathologic effects, thyroid chemistry, thyroid hormones, altered circadian organization, single strand DNA breaks, mutagenic brain responses, blood-brain barrier damage, demyelination in cortical neurons and more.

Yet, all animal research was omitted in the OHA report. OHA is insisting on proof of human harm before taking steps to prevent damage to children’s health.

The OHA report executive summary page 5 states that OHA’s conclusions are “in line with conclusions by the U.S. Food & Drug Administration, the Centers for Disease Control and Prevention, the National Cancer Institute and other agencies that work to protect population health.” OHA’s statement would likely result in the reader erroneously thinking that federal health agencies have researched the issue and concluded there is no scientific evidence. This is an inaccurate assumption. Fact: No US federal public health, environmental or research agency has reviewed the current full body of science on radiofrequency radiation for health effects. None.

OHA’s statement uses footnotes 114 through 116 to substantiate their statement. These footnotes link to web pages, not research reviews, nor safety evaluations. A look at the 3 OHA footnotes (see details below) confirms that there is no US health agency — not the FDA, not the EPA, not the National Cancer Institute, not the CDC, nor any other federal health or safety agency — that has ever reviewed the full body of research on the health effects of wireless radiation in the last three decades. There was no pre-market safety testing before cell phones or Wi-Fi came on the market. There also is no post-market surveillance. The EPA was fully defunded from setting proper safety limits in 1996, despite being tasked to do so, and in 1996 the federal government adopted ‘safety limits’ created by groups dominated by industry. These limits did not consider long-term exposure, and they didn’t incorporate research on health effects to children whose brains are developing. Yet despite over a thousand studies showing harm from no heating effects, FCC wireless radiation limits have not changed since 1996. This is why the Environmental Health Trust filed legal action against the FCC which erroneously decided to maintain their 1996 human exposure limits.

Documentation on OHA Footnotes 114 – 116 Revealing No Research Review

The U.S. Food & Drug Administration (FDA)

OHA references the FDA website OHA citation 114 “Food and Drug Administration (FDA). Scientific Evidence for Cell Phone Safety [Internet]. 2020. Available from: https://www.fda.gov/radiation-emitting-products/ cell-phones/scientific-evidence-cell-phone-safety”

The OHA citation links to the FDA website, majorly updated on February 10, 2020. Although the FDA webpages on cell phones seem to indicate safety, the indisputable fact is that the FDA has not reviewed the full body of research as clearly shown when you consider the documentation provided by the FDA.

Cancer and tumors only: The FDA report cited as documentation is entitled “Review of Published Literature between 2008 and 2018 of Relevance to Radiofrequency Radiation and Cancer, and this report is only about cancer- not for example -brain damage, oxidative stress or reproductive damage. It is not a systematic review of all the research evidence. Furthermore, it is focused on cancer from cell phones, not Wi-Fi. The FDA literature Review states, “here were two main foci for the review: i) epidemiological evidence for the existence of any tumor risk from cell phone usage, and ii) in vivo (animal) studies assessing any causality of tumorigenesis from of RFR exposure.”
Animal cancer findings dismissed: Notably, the FDA dismisses the NTP and Ramazzinni study findings as relevant to humans (as OHA also has done) despite the fact that the FDA asked the NTP to do the cell phone radiation animal study.
FDA Review criticized by experts: The FDA webpage update did not go unnoticed. Numerous scientists including several now retired US government scientists – are calling for the FDA to retract the review as it offers unsubstantiated assurance of safety (EHT 2020). They asked questions and penned a letter to the FDA with several individual statements. So far the FDA has not responded to the specific questions.

Letters which have been sent to the FDA include:

Dr. Ronald Melnick, a 28 year NIH scientist wrote to the FDA:

“I am writing this letter to detail major incorrect statements and omissions of relevant data in the FDAdocument titled “Review of Published Literature between 2008 and 2018 of Relevance toRadiofrequency Radiation and Cancer.” I led the design of the National Toxicology Program’s (NTP) toxicity and carcinogenicity studies on cell phone radiation and I strongly believe that the anonymously written FDA document misrepresents the utility of the NTP study for assessing human health risks. In addition, the report’s casual dismissal of both the mechanistic findings and the numerous results from epidemiological studies that have shown increased cancer risks associated with exposure to radiofrequency radiation (RFR) are inconsistent with the FDA’s stated core mission “to protect and promote the public health.”

“The dismissal of the NTP study results by the FDA is rather peculiar since it was the FDA’s Center for Device andRadiological Health that requested the toxicity and carcinogenicity of RFR in experimental animals (CDRH nomination of RFR) “to provide the basis to assess the risk to human health,” and FDAscientists were fully aware of the exposure methodology that was used in the NTP study long before those studies were begun.”

Confirmation by the GAO: The Government Accountability Report on 5G (GAO 2020) confirmed the fact that the FDA review was very selective stating that the FDA and other organizations “only reviewed a subset of the relevant research” and “The assessment focused on cancer-related animal and human studies of frequencies below 6 GHz.”

Federal Appeals Court Judges: In the January 25, 2021 oral arguments for EHT et al v. the FCC (Transcript) the judges asked pointed questions of the FCC about how in 2019, they determined to maintain the 1996 adopted guidelines. The FCC, like OHA, referred back to the FDA as substantiating their safety determination. However the judges pointed out that the FDA did not show documentation of a comprehensive review outside of a narrow scope related to cell phones and cancer.

Here are some quotes by the judges:

Minute 26.17 There’s so many new devices, and people are using multiple devices…The FDA came back and talked about cellphones and cancer. How was that reasonable for the FCC to rely so heavily on a response from the FDA that there’s no indication relied on this specialized Committee and did not address the very things you asked for information on: other devices, the use of multiple devices, and physical harms other than cancer?” Listen
Minute 28.29: The Honorable Patricia Ann Millet states, “People don’t use their phones… hardly use them for phone calls anymore. They are constantly in the hand— not two centimeters away, they’re constantly in the hand. And the fingers are constantly on them.And so I’m just trying to understand how the FDA coming back and talking about cellphones that are in a holster—where nobody keeps them anymore—or in a purse when they’re not being used is at all… and looking only at cancer is at all relevant to an Inquiry, again, into the effect of this radiation frequency from multiple devices that are used in entirely different ways now, in entirely different volume, and throughout the population, including children who live on iPads.” Listen
Minute 35:02 The FCC says, “we said repeatedly that there was no evidence of any effect—not just cancer, any illness—from, ah, radiofrequency emissions below our existing levels,” and the Honorable Patricia Ann Millet asks the FCC “Sorry, can you point me to that paragraph where it said… where it was addressing cumulative impacts?” and the FCC attorney refers to “scientific conclusions” and “the scientific studies that the FDA and others have looked at,” at which time the judge states, “No, the FDA didn’t. The FDA was only talking about cellphones. That’s my point.” Listen

As the FDA literature review cited by OHA shows, the FDA has not expanded its consideration outside of the issue of the issue of cancer as discussed in the oral argument for EHT et al., v the FCC.

The Centers for Disease Control and Prevention (CDC)

OHA references the CDC website OHA citation 115. “Centers for Disease Control and Prevention (CDC). Frequently Asked Questions about Cell Phones and Your Health [Internet]. 2014. Available from: https://www.cdc.gov/nceh/ radiation/cell_phones._faq.html”

No research review: The OHA report only cites the webpage of the CDC but does not cite a scientific reference for the CDC because there is no research review or report with conclusions by the CDC to cite. The CDC has never done a scientific research review on this issue. There are no reports, no reviews and no documentation that exists showing the CDC did any research review to determine safety of health effects.
Warnings removed: In June 2014 the CDC posted cautionary text about cell phones and health (See the CDC text here). The CDC stated at that time, “along with many organizations worldwide, we recommend caution in cell phone use. More research is needed before we know for sure if using cell phones causes cancer.” This text was removed weeks later. Microwave News and a New York Times January 1, 2016 exposé details how CDC officials retracted these warnings about cell phone radiation.
Industry tied scientist group told the CDC to remove cautionary text. EHT posted 500+ internal CDC emails, obtained as part of our FOIA request, detailing how – in fact- scientists known to have received money from the cell phone industry, sent emails to the CDC directing changes in the CDC website content stating, “Changes are truly needed.”
- See also Microwave News “NCRP Pressured CDC To Remove Cell Phone Safety Advice: You Say “Caution,” We Say “Precaution,” Let’s Call the Whole Thing Off”.

Deleted Information on Children: The CDC also deleted text on children’s vulnerability. On August 18, 2014, the bulk of sentences cautioning the public of the greater risk to children from phone radiation were removed because—according to what CDC officials state in the emails—“We thought the struck language was hard to understand.” (page 397 of internal documents). Although most statements about children were removed in August 2014, the question about children was fully removed by January 2016.

Industry tied consultation: If you go to the CDC website you might think they have done a review as the CDC website seems to indicate experts reviewed the research. In fact, in 2014, the CDC hired an industry consultant to draft and provide subject matter expertise to several web pages related to radiofrequency radiation as detailed in a recent investigation Wireless Hazards by journalist Barbara Koeppel published in the Washington Spectator. Two of the web pages that the consultant (known to receive money from industry) worked on with the CDC were posted (Wearable Technology and Non-Ionizing Radiation) and three were not ever posted (Wireless Networks –Click here to see a CDC draft never published; Power Lines and Electromagnetic Hypersensitivity- Click here to see a CDC draft never published)
Outdated: The CDC webpage OHA cites was last updated in 2014 well before the NTP study and studies were published.

The National Cancer Institute (NCI)

The OHA cites the web pages 116. “National Cancer Institute (NCI). Cell Phones and Cancer Risk [Internet]. 2019. Available from: https://www.cancer.gov/about-cancer/causes-prevention/risk/radiation/ cell-phones-fact-sheet#r14” as if NCI had an opinion based on a comprehensive research review.

However the fact is that the NCI also has never done a scientific research review to determine the safety of RFR to the public. They have not done any published systematic review nor issued any written reports on the matter in the last few decades. Even if scientists had an opinion, they only are focused on cancer, but do not investigate the brain damaging effects or the reproductive damaging effects. NCI has confirmed this repeatedly. Documentation includes:

New Hampshire 5G Commission letter: The NCI confirmed that they have not issued an opinion nor evaluated the safety of RFR in a 2020 letter to New Hampshire 5G Commission Member Denise Ricciardi stating, “NCI does not make recommendations or issue guidelines… The FDA and FCC are the responsible federal agencies with authority to issue opinions on the safety of these exposures. As a Federal research agency, the NCI is not involved in the regulation of radiofrequency telecommunications infrastructure and devices, nor do we make recommendations for policies related to this technology.” (NCI 2020 Letter)
Letter to Scarato: The NCI also confirmed this fact in a 2016 letter to EHT’s Executive Director Theodora Scarato, as well stating that, “Neither the literature reviews, nor the fact sheets, make safety determinations.” (Letter from NCI to Scarato, PDF of Communications)

Other US Agencies

The OHA references “other agencies” but if such findings exist then where are they?

The Environmental Protection Agency (EPA) has not done a research review since 1984.

The EPA has not released any report nor done any review on RFR or EMF since 1984 and has no current funded mandate to research the issue. The EPA confirmed all of these facts in a 2020 letter to EHT Director Theodora Scarato.

Previous to 1996 the EPA conducted robust research on electromagnetic radiation (EPA Letter) and was in development of safety limits for wireless radiation (See EPA Briefing) but just as they were poised to issue these recommendations, the EPA lost all of their research funding and has no funded mandate to do any research since then (See 2020 EPA letter). See EPA reports going back decades here. See a1995 EPA Letter to the FCC on their near completion of EMF Guidelines
Regarding FCC limits, the EPA has officially stated that the 1996 human exposure limits adopted by the FCC were not set to protect against long term exposures, nor did they incorporate scientific understanding of impacts to children. A 2002 letter from Norbert Hankin,of the Radiation Protection Division of the EPA stated, “I believe that it is correct to say that there is uncertainty about whether or not current guidelines adequately treat nonthermal, prolonged exposures (exposures that may continue on an intermittent basis for many years)…Federal health and safety agencies have not yet developed policies concerning possible risk from long-term, nonthermal exposures. When developing exposure standards for other physical agents such as toxic substances, health risk uncertainties, with emphasis given to sensitive populations, are often considered. Incorporating information on exposure scenarios involving repeated short duration/nonthermal exposures that may continue over very long periods of time (years), with an exposed population that includes children, the elderly, and people with various debilitating physical and medical conditions, could be beneficial in delineating appropriate protective exposure guidelines.”
See 1993 EPA Comments to the Federal Communication Commission’s (FCC’s) proposed RF/MW radiation limits 93-142 Guidelines For Evaluating the Non Thermal Effects of Radiofrequency Radiation: The EPA states that certain subgroups are more at risk (pregnant women, children and the elderly) and calls for an updated, comprehensive review that considers the biological effects of RF, specifically pointing to the need to update the NCRP Report 86 (Note: NCRP 86 is still the basis for US regulations according to the FCC and has not been updated to include biological effects). “The FCC should not adopt the 1992 ANSI IEEE standard; there are serious flaws in the standard that call into question whether the proposed use of the 1992 ANSI IEEE is sufficiently protective.” The report also states that “the claim of protection for all persons from all interactive mechanisms” has “not been supported”. Read the letter and comments here.
Read the 1984 US Science Advisory Board (SAB) Recommendation to the EPA To Develop RF Guidelines providing more documentation of how the EPA was tasked to develop safety limits, and was later defunded.

Why didn’t OHA present the findings and policy of other US government agencies such as the National Institutes of Environmental Health that do- in fact- share science showing harm?

National Toxicology Program (NTP)

The NTP website details how the “NTP conducted two-year toxicology studies in rats and mice to help clarify potential health hazards, including cancer risk, from exposure to RFR” and found clear evidence of cancer, DNA damage. NTP Website

National Institutes of Environmental Health (NIEHS)

The NIEHS website details the NTP findings of clear evidence of cancer and DNA damage from RFR exposure and state “the final conclusions represent the consensus between NTP and a panel of external scientific experts who thoroughly reviewed the NTP draft technical reports at a public meeting in March 2018.” NIEHS Website OHA did not cite this webpage nor research study. Why not?

The APHA Public Health Code of Ethics states on page 5 that “Public health practitioners and organizations have an ethical obligation to use their knowledge, skills, experience, and influence to promote equitable distribution of burdens, benefits, and opportunities for health, regardless of an individual’s or a group’s relative position in social hierarchies. Health justice and equity also extend to ensuring that public health activities do not exacerbate health inequities. “

However, the OHA report is void of the reality that exposure to wireless and cell tower radiation is an environmental justice issue with disproportionate impacts to communities.

Cell towers have been found to be more often placed on schools in lower income areas (See Parents Coalition and WJLA News “MCPS places controversial cellular towers at predominantly high-poverty schools, stats show”) . Wealthy communities often immediately organize to halt proposed cell towers at schools as soon as they become aware. As an example, after a meeting where parents and neighbors located in a wealthy community near Washington DC expressed strong opposition to a proposed cell tower for Wootton High School,the proposal was halted the next morning.
Private schools will get private funding to install wired networks and reduce RF exposures.
While often wealthier, educated families inform their children to decrease exposure (like keep the phone away from your brain) and have the financial means to purchase adapters and hardwire computers to minimize Wi-Fi, people with less financial means remain uninformed about wireless radiation and mitigation is not affordable as an iphone.iPad adapter can run over 100 dollars and laptop USB adapters are around 30 dollars. Many families are struggling to get any internet access at all and are not in a privileged position to choose wired technologies over wireless in their home. So for example monthly rental for a wireless hotspot can be under 20 dollars a month but monthly rental for a modem and home internet service starts around 60 dollars a month.
Schools in low income areas are used as test beds for industry to try out new wireless products such as 5G and virtual reality despite no research indicating it will support academic achievement of the students.
Communities with higher environmental exposures to toxic chemicals, heavy metals (such as lead) and air pollution will have disproportionate impacts from RFR exposure as research shows a synergistic effect between EMFs and toxic agents (Kostoff and Lau 2017).
As an occupational health issue, many people have limited ability to reduce RFR without risking losing their jobs.
Racial/ethnic minorities are 1.5 to 2.0 times more likely than whites to have most of the major chronic diseases. Oxidative stress is understood to play a role in the development of many chronic diseases as well as cancer. Research reviews ( Schuermann and Mevissen, 2021, Yakymenko et al. 2016) repeatedly find that non-ionizing EMF exposure can cause oxidative stress by the increase in free radicals.
Research links non-ionizing radiation with diseases that minority communities already have higher rates of such as obesity, asthma and diabetes. As another example, African American women face a significantly higher risks of having a miscarriage and replicated research links non ionizing radiation to increased miscarriage risk.
Health care inequalities will further exacerbate health inequities as people in under-resourced communities will receive unequal care for the damages from chronic disease caused by or exacerbated by RFR and other non ionizing electromagnetic radiation exposure.

In line with the APHA code of ethics, OHA should retract their report, redesign the study to include all streams of evidence, and include a science based section on health inequities, synergistic exposures and the undue impact posed to vulnerable communities already faced with serious environmental exposures.