All HHS comments · page 9

In my practice as a children's doctor I have seen profound adverse effects of non-ionizing radiation in children. The good news is that these adverse effects in some cases can be negated by decreasing overall exposure. Unfortunately there are few physicians and politicians that understand this problem so many children are not currently receiving the help they need. For example a 10 year old boy with non-verbal autism and aggression improved his behavior and started to talk once the wi-fi router was turned off at night and cordless phones and cellphones were turned off. This despite them living on a military airforce base. Another child had slept poorly for 2 years and behaved hyper at night wanting to play, eat and move rather than sleep and ending up in Mom and Dad's bed each night. Everyone was exhausted. The same decrease in wireless radiation as described above was done and he was able to sleep soundly in his own bed. When school started up again that fall his teachers reported that he had improved 2 grade levels in 2 months! They wanted to know what kind of medication he was on. (None) Later that year he again became hyper and didn't sleep. It turns out his older sister had turned the wi-fi router back on. Once the router was hardwired he returned to his healthy baseline again. Another child complained of a chronic severe headache that would improve when he had recess outdoors. Indoors at school near all the smart boards his headache would return. These children are under diagnosed and misdiagnosed and not receiving the help they so sorely need. In 2024 I was asked by the American Academy of Pediatrics if there was a topic they should work on that was not being adequately addressed at that time. I composed a Resolution with support from the AAP Chapter 1 in San Francisco which I will attach with references for your reading pleasure. It was adopted and sent to the national level for consideration for the top 10 .

Please See The Attached Comment

I submit this comment regarding electromagnetic fields, radiofrequency radiation, and wireless exposure. I am a person with disabilities who experienced significant health problems that I associate with a wireless smart meter installed in my home. I ask HHS to consider my experience and barriers to obtaining an analog meter. This is not simply a preference or convenience. My home has become inaccessible because I cannot obtain the accommodation I need. People with disabilities need a meaningful process to request alternatives when they believe wireless devices affect their health and ability to live at home. PERSONAL EXPERIENCE After a wireless smart meter was installed, I experienced migraines, insomnia, tinnitus, ear pain, heart palpitations, confusion, agitation, and rouleaux formation. These symptoms led me to seek medical attention several times. After the meter was removed, my symptoms resolved. The meter was later reinstalled. My experience alone does not establish scientific causation, and I do not ask HHS to treat it as proof. I ask that it be documented and considered with similar reports. The change in my symptoms after removal is relevant to research and accommodation needs. MEDICAL REQUESTS AND ACCESS TO MY HOME Several doctors requested an accommodation because of my symptoms and their effects on my disability. Despite those requests, I could not obtain a lasting accommodation from the Pennsylvania Public Utility Commission or West Penn Power. The meter was reinstalled, leaving me without the alternative I need. What happens when medical documentation supports an accommodation but there is no effective way to obtain a different meter? Accepting requests without meaningful review or relief leaves no practical solution. I have two small children and limited income. Moving to another state is not realistic: I would lose family support and leave medical specialists my family and I need, while facing financial and logistical hardship. I should not have to choose between remaining in my home and seeking a disability-related accommodation. I need an analog electric meter. REQUESTED ACTION I ask HHS to recommend a federal approach that gives people with…

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Dear Secretary Kennedy and Others at HHS -

Thank you for this opportunity to weigh in on this important topic. My offering comes from an unusual perspective, but I hope it will be useful to you. Please see the attached PDF with my comments.

Deborah E Moore, PhD

Please see the attached document for my response to docket HHS-OASH-2026-0397.

I was cancelled in 2020 as a beloved Utah news anchor for telling my community to "look out for your freedoms," but that simply put me on a bigger mission. Figuring out how the whole media system was interconnected with the whole machine opened my eyes and I found key leaders from every sector, who were also aware, and would like to share solutions. I became trained in Frequency Specific Microcurrent medical technology, as well as took my yoga and meditation training into shamanism and spiritual/vibrational science. I have been documenting my discoveries in frequency and it is my recommendation that every citizen becomes aware of their Life Force Energy, and that the external systems and technology work with BioGeometry to harmonize the radiation into frequencies that actually benefit the human bioelectrical field. Studies referenced in attachments, and I know the expert to talk to. We can all win. Thank you for your work. I'm so grateful to you and would love to support in any way I can. Quick note: My cat is so sensitive to the slightest sound; horses are sensitive to a fly landing on their backs; it makes so much sense to explore the effects of what seems innocuous. There is also entire fields of study emerging such as NeuroAesthetics, and biophillic building, that can assist us in creating environments that we don't have to tolerate, and that actually allow us to thrive (affordably). Thank you. - Amandha Q. Zhane

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 1 of EFEIA's six-part evidence dossier, documents what current radiofrequency and microwave instruments miss in urban environments and the measurement capabilities needed. Every exposure figure inherits the limits of the instrument that produced it. Personal exposimeters measure fixed bands up to about 6 GHz, leaving out 6 GHz Wi-Fi and millimeter-wave 5G; a broadband probe that reaches 90 GHz detects nothing below 0.7 V/m, the order of the median measured across New York City; and at the same site, changing the instrument class or the network traffic state changed results by up to 12.28 dB and 43 dB respectively, against the ±3 dB uncertainty most studies state. Current instruments and protocols were designed to check compliance with limits averaged over 6 or 30 minutes, not to characterize exposure, and a value below the limit does not show that exposure is under control. We urge HHS to adopt, with NIST, EPA and accredited laboratories, a measurement requirements specification for urban exposure assessment; to fund an independent U.S. inter-comparison of all instrument classes under declared traffic states, run alongside the monitoring pilot proposed in Section 2; to assign calibration traceability and 6 GHz and millimeter-wave metrology to NIST; to define a traceable human-exposure metric for the 2-150 kHz range, which today has none; and to require a minimum reporting standard for federally funded studies that records peaks, duty cycle and expanded uncertainty beside time averages. We also propose that a classification system record exposure by descriptors and proximity class, as question 5(p) asks, rather than as a single compliance percentage. This section responds to questions…

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Please see the attached document for my response to docket HHS-OASH-2026-0397.

I am submiting to the docket a brochure from the Arizona Statewide Independent Living Council made in partnership with the Arizona Department of Health Services titled "Ensuring Health Care Access for People with Environmental Illness." The brochure cites the Americans with Disabilities Act (ADA), stating that Environmental Illness is a disability and includes symptoms triggered by "Electromagnetic Fields and Wi-Fi" along with chemicals, mold and other environmental toxins. To eliminate barriers to health care, it advises health services to "Shut off and unplug non-essential electronics, Wi-Fi, Bluetooth devices (including wearables). Limit cell phone use. Be prepared to use monitors that are wired, not wireless."

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 2 of EFEIA's six-part evidence dossier, proposes an independent national electromagnetic monitoring program for U.S. cities, covering the radiofrequency and microwave fields of telecommunications and the 50/60 Hz electric and magnetic fields of urban electrical infrastructure. We found no federal program that measures ambient radiofrequency exposure over time, and the last national magnetic-field survey dates from 1998. EFEIA's own field records serve as reference cases. In Brickell, Miami, between the July 2024 and September 2026 surveys, the median rose 12.4%, the 95th percentile 70.1% and the maximum 57.8%, and signals at 24 to 40 GHz went from not detected to detected. In Doral, Florida, in 2022, spot magnetic-field maxima reached 3.11 µT at a substation and 2.76 µT in a public dog park, while IARC classifies these fields as possibly carcinogenic and no federal limit or program covers them in homes, schools or hospitals. The Brickell values remain well below the FCC limits, and they still rose: limits designed to prevent heating do not show that exposure is characterized or under control. We urge HHS to name urban electromagnetic monitoring, radiofrequency and low-frequency, as a federal priority; to convene EPA, NIST, NTIA, the FCC and NIEHS on its governance, with operators and utilities providing data but not performing, funding or publishing the measurements; and to support a 12-month pilot in Miami and two to four other U.S. cities. Schools, childcare centers, clinics and neonatal units should be measured first, and results published as open data so that residents and local governments can see what is near them. EFEIA offers to serve as technical collaborator from design to…

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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…

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I worked at Coastal Pines Technical College from 2029 to 2025. My office was located directly under a router, and I developed physical symptoms including a raw sensation inside both ears that I attribute to EMF exposure. I reported these issues to my supervisor Karen Scott and Katrina Howard (HR director ) repeatedly and they were dismissed. Katrina Howard told me that my job involves computers so they can't help. I saw multiple doctors including a ENT physician named Dr. Conley in Florida who wanted to perform exploratory surgery instead of investigating the cause, and when I refused, he would not provide medical documentation to work from home. I also measured the radiation in my room (see images) which indicated the presence of external frequencies that made me ill. My supervisor ignored that as well. The device would ping whenever the exposure was high. I resigned because I couldn’t tolerate being ignored by my employer and

doctors. I recently moved to North Carolina. I now live in a building miles away from towers. Yet, I am still managing my sensitivity to EMF.

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. The undersigned is also NOXTAK's founder and CTO, and NOXTAK develops a non-attenuating technology of the kind the framework proposed here would evaluate (Section 5). Our submission, Section 4 of EFEIA's six-part evidence dossier, examines the products and measures sold to reduce electromagnetic exposure: shielding materials, canopies and phone cases, plug-in filters, grounding products, "harmonizers" and wearables. No U.S. statute, regulation or consensus standard defines "EMF protection" or says how such claims must be tested, so buyers cannot tell tested products from untested ones. Shielding is rated on flat samples in laboratory fixtures, not in occupied homes, and it carries a paradox: a phone raises its uplink power as its link to the network weakens, so blocking a weak distant signal can raise the strongest exposure a person receives, from the phone at the head or on the pillow. The FCC and the FTC have both warned of this effect. Some "negative ion" pendants and wearables sold as protection emit ionizing radiation, as the Dutch nuclear regulator and the U.S. Nuclear Regulatory Commission have reported. We urge HHS to lead, with NIST, the FTC, the FCC and the CPSC, a National Framework for the Evaluation and Regulation of Electromagnetic Protection Technologies. Every product sold as protection would be classed by the function it claims; tested for physical performance, for effects on its surroundings and on communications and, where a health benefit is claimed, in sham-controlled trials; and recognized only for what was verified. Shielding should be tested by what a person receives before and after installation, including from their own phone. We also ask HHS to fund an independent survey of marketed…

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I always use a wired computer and try to avoid using my cell phone. This is because when I got a new router sometime during the last decade, I asked the company not to set me up for wireless, but to give me a safe, wired connection. It was obvious to me that the person lied, because that evening I was sitting just a few feet from my TV and router, and I started to have heart palpitations and later had terrible insomnia, which are major symptoms of RF radiation and EMF sensitivity. I only use my computer wired, period. There needs to be an immediate movement towards the safety of cellphones and wireless. The Europeans are way ahead of us on this. I purposely tried to find a phone with less power than most. When it comes to 4 G or 5 G, it's all dangerous, especially cell towers that infringe on populated areas and make people sick. It's well past time for updated FCC regulations, which haven't been touched since the mid-1990s. It's time to finally err on the side of caution and protect human health by updating the regulations that are vastly outdated. Because I need to wear hearing aids, I only use them in airplane mode. If I fail to do that, the wireless affects my thinking and thus my brain. This is serious business that needs to be addressed. People with hearing loss should have a choice about whether they use wireless hearing aids, which are usually paired with a phone or not. It's definitely problematic for many people. Please look at these issues and know that you have the potential to hurt or help people in this country. There are many people who are sensitive to EMFs and RF Radiation, and there are probably many who aren't aware of what is causing some of their health problems. Please do the right thing for our people.

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; this comment represents the perspective of a research entity. Relationship disclosure. EFEIA operates within the NOXTAK Corporation ecosystem. NOXTAK develops and markets, as SPIRO, the passive nanocomposite presented in this section, and the undersigned is EFEIA's Director, NOXTAK's founder and CTO, and the named inventor on its patents. EFEIA presents the nanocomposite on the same terms it applies to every product in Section 4: what was tested, by whom, under what standard, with what result, and what remains to be done. Our submission, Section 5 of EFEIA's six-part evidence dossier, presents what ecosystems show about weak electromagnetic noise and a passive candidate solution. Migratory songbirds lose magnetic compass orientation under weak broadband radiofrequency noise in the nanotesla range, about 1,000 times weaker than current recommended limits as a BfS workshop review notes; honey bees show impaired learning and foraging under 50 Hz magnetic fields and reduced homing under Wi-Fi-band exposure. EFEIA has identified no federal exposure limit or monitoring program for animals, and an antenna or power line that meets the human limits has not been assessed for them. As a candidate solution that does not attenuate the signal, the section presents the SPIRO nanocomposite: in independent, accredited laboratories it produced up to 91% reduction in 10 g-averaged SAR across seven configurations, with antenna performance unchanged within uncertainty on three handsets, and a university-led, open, randomized, placebo-controlled trial recorded changes in heart rate variability. The evidence is organized in six tiers, with its limitations stated. We urge HHS to include passive, non-shielding approaches in the research it asks about in question 5(o), with this nanocomposite as the first worked case: a paired SAR and…

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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 6 of EFEIA's six-part evidence dossier, examines the assumptions on which the FCC, ICNIRP and IEEE radiofrequency limits rest and how exposure is explained to the public. The limits are designed to prevent tissue heating and derive from 1980s studies in which 5 monkeys and 8 rats were exposed for 40 to 60 minutes: an apparent threshold of 4 W/kg, divided by 50 for the public limit of 0.08 W/kg. A peer-reviewed commentary by ICBE-EMF identifies fourteen assumptions behind these limits and cites evidence against each, and HHS's own National Toxicology Program found clear evidence of malignant heart schwannomas in male rats at 1.5, 3 and 6 W/kg. Federal public information consists mainly of statements that devices comply, and EFEIA found no evaluation of any U.S. exposure message for comprehension, behavior or anxiety. Because the FCC's 1996 limits rest primarily on the recommendations of federal health agencies, HHS's assessment carries directly into the remanded rule. We urge HHS, through FDA CDRH and NIEHS, to state for each assumption whether current evidence supports it, does not, or leaves it open, and to send that assessment to the FCC for the remand record. Where an assumption does not hold, the test or limit built on it should change: device testing at body contact and with child and pregnant anatomical models, limits for brief pulses, assessment of combined exposures, and protection for workers and pregnant women, including NIOSH surveillance of occupational exposure. We also ask HHS to convene EFEIA's four-stage National Program for Scientific Integration and Professional Education on Electromagnetic Exposure and Health: evidence synthesis, consensus review of assessment…

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*See Attached: Non-thermal Electromagnetic Field studies demonstrating harmful effects.

On behalf of the EFEIA Institute (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. This comment represents the perspective of a research entity. The attached working paper, co-authored with Dr. Luis M. Valdés, physician and audiologist, is the fifth article in the EFEIA Research Institute's clinical and mechanistic series on tinnitus and electromagnetic fields. Disclosure: the undersigned is also founder and CTO of NOXTAK Corporation, and the school measurements reported in the paper were carried out by the authors' team under the IGEF and the NOXTAK Electromagnetic Research Center. The paper connects three conditions that share one clinical picture: Havana syndrome (anomalous health incidents, AHI), catastrophic tinnitus and extreme electromagnetic hypersensitivity. All three present with an abrupt intracranial sound or pressure, intense tinnitus, vertigo, headache, and cognitive, sleep and mood disturbance. The National Academies (2020) identified directed, pulsed radiofrequency energy as the most plausible mechanism for the acute phase of AHI, and the microwave auditory (Frey) effect provides an established physical bridge by which pulsed radiofrequency energy is perceived as intracranial sound. Building on this, the authors propose a model of cumulative load plus a triggering peak acting on a susceptible phenotype: the acute episode is the visible outcome of a silent accumulation, and greater stimulation shortens and precipitates critical episodes. This opens a direct civilian line of inquiry, since sudden-onset cases in the general population may follow the same mechanism. The exposures that could act as triggering peaks are already present and measurable in public space. At Downtown Doral Charter Upper School in 2022, the authors recorded peaks of 200 V/m of ELF electric field and 31 mG of magnetic flux on the sidewalks where children walk and wait, with the highest values between 9:30 and 11:30 a.m., when children were present. Their field work records values on the order of hundreds of V/m and more than 100 mG under…

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On behalf of the EFEIA Institute (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. This comment represents the perspective of a research entity. The attachment is an evidence review prepared under EFEIA's SPECTRA research program in September 2026. Disclosure: as the review itself states, the undersigned is founder and CTO of NOXTAK Corporation, maker of SPIRO electromagnetic-hygiene products, and no external grant funding was received for the review. Since late 2016, true wireless earbuds have placed a continuous, bilateral radiofrequency source inside the ear canal, 20 to 30 mm from the cochlea, for hundreds of millions of young people, in addition to the acoustic dose the same devices deliver. Over the same decade, clinicians in EFEIA's network and the professionals it trains have seen a visible rise in adolescents and young adults presenting with tinnitus, most of them with normal audiograms and most of them heavy users of in-ear wireless devices. In the United States, 7.5% of NHANES participants aged 12 to 19 reported tinnitus (Mahboubi et al., 2013). The review identifies radiofrequency exposure from in-ear wireless devices as a complementary environmental toxin candidate alongside the established acoustic axis. Adolescents who develop tinnitus show a well-characterized vulnerability profile: cochlear synaptopathy that precedes audiometric loss, reduced sound-level tolerance, elevated central gain, and disturbed sleep and stress physiology. Non-thermal RF-EMF perturbs several of these same systems in animal models, with supporting signals in human provocation studies, and the convergence is strongest for oxidative stress and sleep. Where the two overlap, RF-EMF is a plausible and modifiable load on an already stressed auditory periphery. Existing studies measured phone-to-ear call time; the exposure profile of chronic earbud wear, continuous, bilateral and canal-resident, is the open research frontier, and it is the exposure young people actually receive. ITU-T H.870 already sets weekly sound allowances for these devices and…

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On behalf of the EFEIA Institute (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. This comment represents the perspective of a research entity. The attachment is an evidence review prepared under EFEIA's SPECTRA research program in September 2026. Disclosure: the undersigned is also founder and CTO of NOXTAK Corporation, which develops electromagnetic hygiene products. HHS asks for particular attention to children and other potentially vulnerable populations. The review examines radiofrequency fields from wireless devices, extremely low-frequency fields from power systems and dirty electricity on building wiring as an environmental stressor for autistic people, in the same category as acoustic noise, artificial light, chemical exposures and sleep loss, which are already documented stressors for this population. Autistic individuals carry a meta-analytically confirmed vulnerability profile across oxidative stress, mitochondrial function, immune and neuroinflammatory activation, calcium-channel biology, autonomic and stress-axis regulation, sensory processing, sleep and seizure susceptibility, and EMF perturbs several of these same systems in animal, in vitro and human experimental work. The convergence is strongest for oxidative stress, cortical excitability and sleep. Sleep is the most direct pathway. Autistic people have a baseline sleep disturbance of 50 to 80%, reduced melatonin and a demonstrated link between sleep loss and symptom severity, and the sleep-EEG effect of pulse-modulated radiofrequency exposure is reproducible in healthy adults, with marked differences in individual susceptibility. Therapeutic stimulation studies show that autistic nervous systems are responsive to applied electromagnetic fields. The review concludes that EMF is a candidate environmental stressor for autistic people, plausible on mechanism and modifiable at low cost, and that exposure reduction is a reasonable component of environmental management, in the same way that acoustic treatment of a classroom is. EFEIA's LEDNA principle, which designs…

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