An epidemiologist and engineer prioritizes measured exposure before causal conclusions, proposing nationa…

Re: Docket No. HHS-OASH-2026-0397; Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure; 91 FR 59792 (September 21, 2026); FR Doc. 2026-19252; regulations.gov Document ID HHS-OASH-2026-0397-0001

Perspective (Question 2): I write as a researcher and as a consumer; I file in my individual capacity, with affiliation for identification only, and my response rests on the methodological literature and on professional experience rather than on new data. I am an epidemiologist (Ph.D., University of Minnesota) and a security engineer who has built RF telemetry and software-defined radio sensing systems through two companies I co-founded. The strongest case for this RFI is its order of operations: asking the research community and the public to identify frameworks, evidence, exposure methods, surveillance gaps, and research priorities before any policy move is the correct sequence, the questions are well structured, and the instruction that respondents name the frameworks they rely on and the basis of their evidence is sound. I take no position on whether RF exposure below current limits causes harm. My position is narrower and prior: that question cannot be answered well until exposure is measured, so the most consequential questions in this notice are the exposure-assessment and surveillance questions.

Summary of recommendations: 1. For each exposure framework HHS relies on, state the biological endpoint the limit protects against and the safety factor applied (Question 5). 2. Fund a national measured-exposure program: calibrated personal dosimeters and fixed software-defined radio monitors on a probability-based population panel, recording band-resolved field strength and duty cycle over time with published uncertainty budgets (Questions 7 and 8). 3. Disclose measured field strength at representative use distances, in plain units with stated uncertainty, rather than only a single maximum SAR value (Question 9). 4. Evaluate any new surveillance system against the CDC 2001 attributes before it is built, and give every registry an exposure denominator by linking it to the measured-exposure panel (Question 10). 5. Differentiate exposure assessment for children and for occupational groups because dose, not only field strength, differs (Question 11). 6. Apply symmetric quality criteria to studies finding effects and studies finding none, and prioritize measured-exposure cohorts and replication of the most-cited findings on either side (Questions 12 and 16). 7. Adopt a single federal exposure-measurement data standard and shared repository for FDA, NIH, CDC, and the FCC, coordinated with the FCC's concurrent proceeding (Question 17).

The full comment is attached as a PDF.

Disclosure: I have no financial interest in any vendor or contract involving this request, and I was not compensated for this comment. I co-founded AirCrumbs, Inc., which develops software-defined radio systems for wireless signal attribution, not exposure measurement, and earlier co-founded MTRX, Inc., which built RF telemetry products; I have no financial interest in any wireless carrier, device manufacturer, or exposure-measurement vendor.

Andrew G. Huff, Ph.D., M.S.

Risk Factor Research, LLC, Michigan, USA

contact@andrewhuff.com