On behalf of the EFEIA Institute (Electropollution-Free Environments International Accreditation Foundati…

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 criteria, university and continuing education for engineers and clinicians, and public guidance tested for comprehension and effects on anxiety before release, so that it builds competence without fear. This section responds to questions 3(b), 4(l), 5, 5(n) to 5(p), 6, 8, 9, 10(b), 10(d), 10(h), 11(a), 11(b), 11(e), 12, 13(a), 13(c), 13(f), 13(k), 15(a), 16 and 17. The attachments are the Section 6 summary and the exhibit that corresponds to it: - Section 6 summary: What the Limits Assume and What the Public Is Told: The Assumptions Behind Current Exposure Assessment, and Electromagnetic Literacy Without Fear (https://doi.org/10.5281/zenodo.23523497). - Exhibit 6A: National Program for Scientific Integration and Professional Education on Electromagnetic Exposure and Health: A Four-Stage Proposal for Evidence Review and Interdisciplinary Consensus (https://doi.org/10.5281/zenodo.23513425). Please accept and consider all attached documents, the Section 6 summary and Exhibit 6A, as part of the public record. Respectfully, J. Joaquín Machado EMR Researcher and Director of the EFEIA Institute