On behalf of the EFEIA Institute (Miami, Florida), I submit our organization's attached public comment an…

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 low near-field exposure into buildings, wiring, room layout and communication systems, and the EFEIA evaluation protocol are the operational expression of that position. The review rests on primary-source verification, with its original anchor sources rechecked and roughly 90 further peer-reviewed and institutional sources added. The next step is to study the two bodies of evidence together, and the review sets out the five studies that would do it. We urge HHS, through NIH, to fund them: a blinded, sham-controlled provocation study of sleep EEG, melatonin and heart rate variability in autistic adolescents under pulse-modulated radiofrequency exposure, with a typically developing comparison group, which any environmental-medicine department with a sleep laboratory could run; an environmental-level radiofrequency or ELF exposure study in a validated autism mouse model with autism-domain behavioral endpoints and brain oxidative and cytokine markers; independent replication of the 2025 organoid study (Cakir et al.) with published dosimetry; a prospective birth cohort with objective personal radiofrequency dosimetry and a pre-registered, physician-diagnosed autism endpoint, which could build on the measurement module for the NIH ECHO cohort proposed in Section 3 of EFEIA's dossier; and a randomized, blinded, sham-controlled replication of the 2024 ELF pilot study (Pietramala et al.). We also ask HHS to commission a systematic review of neurodevelopmental outcomes, including autism, at sub-thermal exposure levels. This comment responds to questions 5(o), 10(d), 11(a), 11(b), 11(f), 11(g), 12, 16 and 17(b). The attachment is: - Machado, J. J. Electromagnetic Fields and Autism Spectrum Disorder: Artificial electromagnetic fields as an environmental stressor in autism. Worldwide evidence review. EFEIA Institute, SPECTRA program, September 2026 (https://doi.org/10.5281/zenodo.23519237). Please accept and consider the attached document as part of the public record. Respectfully, J. Joaquín Machado EMR Researcher and Director of the EFEIA Institute