In announcing this RFI, the Secretary noted that “our science must keep pace” with wireless technology. HHS has asked where federal research is needed most. From the front line, we see what is holding it back.
Nudgr’s co-founders have completed well over 1,000 on-site EMF assessments, mostly in homes. Real-world wireless technology exposure there is multi-source, variable by the minute, and often arrives in short bursts. Much of the evidence base cannot see this. Laboratory studies typically apply one signal from one source. Population studies rely on proxies such as distance or phone-use time. Most instruments were designed to check compliance with heating and nerve-stimulation limits, not to record everyday exposure continuously. Research also moves slower than technology: the NTP study’s final reports on 2G/3G-type signals arrived in 2018, the year millimeter-wave 5G launched and after 3G retirement had been announced.
The fix is to measure the exposure itself, continuously, in the places people live and sleep, with documented accuracy. This strengthens research whether future findings are positive, negative, or null.
We recommend that NIH, with FDA and CDC, fund the development, independent validation, and deployment of real-world wireless technology exposure instrumentation, along with a common data standard linking exposure to health outcomes, through milestone-gated awards. Nudgr is developing such instrumentation (disclosed as a commercial interest; no proprietary information included) and would welcome participating in any HHS workshop on exposure measurement.
The result: researchers, clinicians, and families get answers built on measured exposure, and new technologies such as 6G are characterized as they deploy, not two decades later.
Our attachment answers Questions 2, 4, 5 (5n, 5o, 5p), and 6 through 18. Each section is tagged with the question numbers it answers, and a question index appears at the start of the attachment.e(s)