AI summary & topic connections
An epidemiologist and engineer prioritizes measured exposure before causal conclusions, proposing national monitoring, transparent standards, symmetric study appraisal and shared federal data.
- Research & federal duties:
afety factor applied (Question 5). 2. Fund a national measured-exposure program: calibrated personal dosimeters and fixed software-defined radio
- Exposure limits & oversight:
endpoint the limit protects against and the safety factor applied (Question 5). 2. Fund a national measured-exposure progr
- Children & vulnerable groups:
0). 5. Differentiate exposure assessment for children and for occupational groups because dose, not only field strengt
- Occupational exposure:
ate exposure assessment for children and for occupational groups because dose, not only field strength, differs (Question 11). 6.
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…