On behalf of the EFEIA Institute (Electropollution-Free Environments International Accreditation Foundation, Miami, Florida), I submit our organization's attached public comment and supporting scientific research in response to HHS Request for Information, Docket No. HHS-OASH-2026-0397. EFEIA is a nonprofit research and accreditation foundation operating within the NOXTAK Corporation ecosystem; this comment represents the perspective of a research entity.
Our submission, Section 3 of EFEIA's six-part evidence dossier, addresses people who report symptoms they attribute to electromagnetic exposure (electromagnetic hypersensitivity, EHS, or IEI-EMF) and people whose existing health conditions may change how exposure affects them. WHO recognizes that these symptoms are real and can be disabling, and surveys place self-reported EHS at 1.5% in Stockholm County and 3.2% of California adults; yet the United States has no diagnostic pathway, no clinical guidance and no systematic collection of information on these people, who enter the federal record only as testimony. EFEIA recognizes this suffering without asserting a causal link that has not been consistently shown. The exposure limits were derived from tissue heating and do not refer to long-term duration, proximity during sleep or the health of the person exposed: in EFEIA's EHS Global Census 2025, which enrolled 286 people in more than 20 countries, 37.8% of 283 respondents sleep with the phone under the pillow or very close at least some nights.
We urge HHS to convene and fund, through OASH with NIEHS and CDC, a voluntary National Program for the Characterization of Electromagnetic Hypersensitivity based on EFEIA's National Census Plan and its questionnaires A and B, conceived as a characterization and research initiative and not as a diagnostic test; to issue clinical guidance on assessment, differential diagnosis, care and accommodation; to create a federal intake that pairs case reports with measured exposure; to add a radiofrequency and ELF measurement module to the NIH ECHO cohort; and to name older adults and people with cardiac implants as groups to assess separately. Any clinical screening use of the questionnaires would first require validation of their reliability, sensitivity and specificity.
This section responds to questions 3(a) to 3(g), 4(h) to 4(m), 5(n), 5(o), 9, 10(a), 10(d) to 10(g), 11(a) to 11(d), 11(f), 11(g), 12, 13(j), 16 and 17, with participant information reported in aggregate only, without PII or PHI. The attachments are the Section 3 summary and the two exhibits that correspond to it:
- Section 3 summary: A National Census of Electromagnetic Hypersensitivity (EHS, IEI-EMF), and EMF as a Potential Amplifier of Existing Health Conditions (https://doi.org/10.5281/zenodo.23523491).
- Exhibit 3A: School Case Study of EHS Related Symptoms in 15 Students: Preliminary Assessment Using the EFEIA Foundation Questionnaire and Environmental Field Measurements, Doral, Florida, 2022 (https://doi.org/10.5281/zenodo.23513500).
- Exhibit 3B: National Census Plan: Technology Habits and Symptoms Associated with Electromagnetic Sensitivity Concerns, with questionnaires A and B (https://doi.org/10.5281/zenodo.23513476).
Please accept and consider all attached documents, the Section 3 summary and Exhibits 3A and 3B, as part of the public record.
Respectfully,
J. Joaquín Machado
EMR Researcher and Director of the EFEIA Institute