The engineering firm takes no position on RF health effects and calls attention to the lack of a standard…

Waterford Consultants, LLC submits the attached comments in response to the Request for Information on Electromagnetic Fields, Radiofrequency Radiation, and Wireless Radiation Exposure, Docket No. HHS-OASH-2026-0397. Waterford is a radiofrequency engineering and compliance firm. For more than twenty years our principal business has been the practical measurement and assessment of radiofrequency exposure in the field, and we also develop engineering software used across the industry for predictive exposure assessments. We take no position on the health effects of radiofrequency exposure. Our comments address the availability and quality of exposure data. The central issue we raise is the absence of a standardized, longitudinal record of measured radiofrequency environmental conditions in the United States, what such a record must carry to be scientifically usable, and three recommended actions. The attached document addresses questions 2, 5, 7, 8, 9, 10, 13, 15, 16, 17 and 18. Contact: regulatory@waterfordconsultants.com, telephone (703) 596-1022, extension 140.