- Edited
I'm very happy to report that there is a way to report our health issues with LED lights and/or screens to the U.S. Food and Drug Administration and I encourage everyone who can to please do so. They welcome your reports even if you’re not in the United States.
Since the replacement of fluorescent lights in February 2022 with very triggering LEDs with ~100% flicker in the NYC Public School where I had been working, I've been reaching out to every city, state, and federal agency I could think of to simply ask how I could report that these lights had so badly affected my health that I couldn't safely enter the school building anymore (and I am very concerned about the potential impact on any sensitive children among the million NYC public school children). Every agency, including initially the FDA, told me they wouldn't even accept a report because there aren't any regulations for LED lights yet. However, I learned in the process that in general, the FDA oversees light-producing devices (which they group with other radiation-producing devices, since visible light is a type of radiation).
A report that I sent in anyway to what I knew was the wrong place at the FDA by snail mail, eventually fortuitously made it to the right office. A representative contacted me and we've talked on the phone and been emailing for the past couple of weeks (I've leaned heavily on my scientific credentials and discussed the lack of good science around LED products and health). I truly believe they are open to helping if they receive evidence of a need.
The FDA Center for Devices and Radiological Health accepts reports of health issues involving any light-producing devices, regardless of whether those devices are subject to current regulations. They can make recommendations when there are health issues with products. While they currently don't have regulations that can help us (as we know), they will study it - to do so effectively they need our reports. My initial report sent through the wrong channel was the very first report they've received from any individual or manufacturer about health issues associated with LED products. For individuals, I assume this is because it isn't obvious that "FDA" and "radiation" are the right keywords and not even representatives in other divisions at the FDA or representatives at the EPA working with lighting products knew about this reporting avenue. So it's up to us to spread the word now, including to people with milder health issues than what many of us experience.
We are supposed to file an "Accidental Radiation Occurrences (AROs) form (Form 3649)." Please don't let the fact that this form was obviously not designed with us in mind put you off from filing. Manufacturers are required to use this system to immediately relay any reports of health issues with their products to the FDA (regardless of whether there are regulations) and the form implies a single isolated incident. Please fill in parts of the form relevant to you - note that LED products are the last item in the Product Information list - and attach any supporting information you'd like to attach when you submit the form. For example, you might include a narrative describing your situation/supplementing the form or any supporting information that you think could be helpful to researchers at the FDA. If you don’t have a US address, just write in your actual address even though the form was designed for US addresses. I asked how we should handle needing to report that all or most LED lights/screens are harmful to us and how to handle that we might not know manufacturer information for LED products in public places and they responded:
If the complaint/report is about a general issue with a wide variety of LED products, that could be one ARO, and only one single form needs to be completed/submitted.
If someone has problems with a known specific LED product, we would also like to know about it. So, a separate ARO report for a specific product would be appreciated.
I asked about privacy and was told "information of submitters will remain confidential and we won’t share them with anyone outside the agency."
I'm going to share as much as I can with the FDA about my experiences generally and with select products, including correspondence I've had directly reporting to manufacturers. I'm going to report my health issues with both LED lights and with screens, even though I don't completely understand exactly which hardware and software aspects create my issues with LED screens. I'm going to specifically highlight LEDs in schools and other areas that I think are key from a public health perspective. However, if all you are able to do is to send in a very brief, general report, that would also be helpful so the FDA can get a better sense of the scope of the issue.
I hope that if we can use and spread the word about this reporting system, enough momentum will build to support rigorous scientific research, public health studies, calls for manufacturers to actually share health reports with the FDA, and eventually appropriate regulations. In addition to all of us adults experiencing significant challenges, I'm even more concerned about trying to protect sensitive children who may be unaware of the cause of health or learning issues.
The Accidental Radiation Occurrence Report form is in section 6 of this webpage:
Radiation-Emitting Products Industry Assistance: Walk-through | FDA
or available directly through this link: https://www.fda.gov/media/79866/download
Reports may either be emailed to [RadHealthCustomerService@fda.hhs.gov](mailto:RadHealthCustomerService@fda.hhs.gov) or sent by mail using the address on the form.
Thank you so much for your help with this!
If anyone knows of comparable government agencies in other countries that actually accept reports of health issues from LED products, that would also be helpful to know.
Jenny
P.S. I'm going to add this info to FlickerSense.org within a couple days to create a dedicated webpage.