{"id":"HHS-OASH-2026-0397-6915","name":"","organization":"EFEIA Foundation","posted":"2026-10-28T04:00Z","received":"2026-10-21T04:00Z","body":"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.\n\nOur 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.\n\nWe 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.\n\nThis section responds to questions 4(l), 5(n), 5(o), 5(p), 7, 8, 13(a), 13(c), 16 and 17. The attachments are the Section 1 summary and the exhibit that corresponds to it:\n\n- Section 1 summary: Limitations of Current Electromagnetic Instrumentation: What Today's Instruments Miss in Urban Environments, and the Measurement Capabilities Needed (https://doi.org/10.5281/zenodo.23523487).\n- Exhibit 1A: Next Generation Electromagnetic Measurement Instruments: Engineering Development and Validation Plan (https://doi.org/10.5281/zenodo.23513482), a 24-month plan for a modular family of research instruments. EFEIA has not developed or validated a new instrument and does not claim one; the plan's figures are preliminary engineering targets.\n\nPlease accept and consider all attached documents, the Section 1 summary and Exhibit 1A, as part of the public record.\n\nRespectfully,\nJ. Joaquín Machado\nEMR Researcher and Director of the EFEIA Institute","source_hash":"c7de92785ea4823f0ccd99a2707a067816c0c378ff7ba3143e0a43f42c8defb2","filing_type":"","proceedings":"","captured_at":"","source_name":"","number":"6915","withheld":false,"attachment_inventory":true,"capture_reviewed":false,"source":"https://www.regulations.gov/comment/HHS-OASH-2026-0397-6915","slug":"exposure-places-comment-6915","tags":[],"attachments":["https://downloads.regulations.gov/HHS-OASH-2026-0397-6915/attachment_2.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-6915/attachment_1.pdf"],"attachment_names":{"https://downloads.regulations.gov/HHS-OASH-2026-0397-6915/attachment_2.pdf":"Next_Generation_EMF_Instruments_Development_Plan_EN","https://downloads.regulations.gov/HHS-OASH-2026-0397-6915/attachment_1.pdf":"Section_1_Limitations_of_Current_Electromagnetic_Instrumentation_EN"},"classification":null,"supplied_classification":null,"attachment_metadata":{"https://downloads.regulations.gov/HHS-OASH-2026-0397-6915/attachment_2.pdf":{"title":"Next_Generation_EMF_Instruments_Development_Plan_EN","mime":"application/pdf","source":"https://downloads.regulations.gov/HHS-OASH-2026-0397-6915/attachment_2.pdf","upstream_key":"fac823a9af5bd8f5a29a9461ca4cb467b4360343fba7bf3e48b07946c6eef223","key":"fac823a9af5bd8f5a29a9461ca4cb467b4360343fba7bf3e48b07946c6eef223"},"https://downloads.regulations.gov/HHS-OASH-2026-0397-6915/attachment_1.pdf":{"title":"Section_1_Limitations_of_Current_Electromagnetic_Instrumentation_EN","mime":"application/pdf","source":"https://downloads.regulations.gov/HHS-OASH-2026-0397-6915/attachment_1.pdf","upstream_key":"17f40db0d3587595b3d3bd47a9cc1a2409238f9cb97cacf1f286eb62029d453d","key":"17f40db0d3587595b3d3bd47a9cc1a2409238f9cb97cacf1f286eb62029d453d"}},"mirror_fingerprint":"826e7308897f1100e5fb9a6a14122fd0da2dbece920b6eb21b398eca81f8b320","seo_modified":"2026-10-29T15:28:52Z","forum_topics":["awaiting-review"],"primary_topic":"awaiting-review","forum_title":"On behalf of the EFEIA Institute (Electropollution-Free Environments International Accreditation Foundati…"}