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ORIGINAL COMMENT · UNEDITED TEXT
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.
ORIGINAL COMMENT · UNEDITED TEXT
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 free…
ORIGINAL COMMENT · UNEDITED TEXT
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 Foundati…
ORIGINAL COMMENT · UNEDITED TEXT
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 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:
- 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).
- 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.
Please accept and consider all attached documents, the Section 1 summary and Exhibit 1A, as part of the public record.
Respectfully,
J. Joaquín Machado
EMR Researcher and Director of the EFEIA Institute
Please see the attached document for my response to docket HHS-OASH-2026-0397.
ORIGINAL COMMENT · UNEDITED TEXT
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 par…
ORIGINAL COMMENT · UNEDITED TEXT
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 Foundati…
ORIGINAL COMMENT · UNEDITED TEXT
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 pilot.
This section responds to questions 4(l), 5, 5(n), 5(o), 7, 8, 9, 10(c), 11(a), 11(e), 12, 13(a) to 13(e), 13(g) to 13(i), 15(a) to 15(d), 16 and 17. The attachments are the Section 2 summary and the three exhibits that correspond to it:
- Section 2 summary: A National Urban Electromagnetic Monitoring Program: Radiofrequency, Microwave and Low-Frequency Fields, with Brickell, Miami (2020-2026), and Doral, Florida (2022), as Reference Cases (https://doi.org/10.5281/zenodo.23523489).
- Exhibit 2A: Six-Year Trends in Environmental RF Exposure across Brickell and Downtown Miami: Comparative Measurements from 2020 to 2026 (https://doi.org/10.5281/zenodo.23513490).
- Exhibit 2B: National Electromagnetic Monitoring Plan: Independent Assessment of Electromagnetic Exposure in United States Cities (https://doi.org/10.5281/zenodo.23513478).
- Exhibit 2C: an exploratory field assessment of radiofrequency exposure and low-frequency electric and magnetic fields at 45 locations in the City of Doral, 2022 (https://doi.org/10.5281/zenodo.23513464).
Please accept and consider all attached documents, the Section 2 summary and Exhibits 2A, 2B and 2C, as part of the public record.
Respectfully,
J. Joaquín Machado
EMR Researcher and Director of the EFEIA Institute
On behalf of the EFEIA Institute (Electropollution-Free Environments International Accreditation Foundati…
ORIGINAL COMMENT · UNEDITED TEXT
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 questionnaires would first require validation of their reliability, sensitivity and specificity.
This section responds to questions 3(a) to 3(g), 4(h) to 4(m), 5(n), 5(o), 9, 10(a), 10(d) to 10(g), 11(a) to 11(d), 11(f), 11(g), 12, 13(j), 16 and 17, with participant information reported in aggregate only, without PII or PHI. The attachments are the Section 3 summary and the two exhibits that correspond to it:
- Section 3 summary: A National Census of Electromagnetic Hypersensitivity (EHS, IEI-EMF), and EMF as a Potential Amplifier of Existing Health Conditions (https://doi.org/10.5281/zenodo.23523491).
- Exhibit 3A: School Case Study of EHS Related Symptoms in 15 Students: Preliminary Assessment Using the EFEIA Foundation Questionnaire and Environmental Field Measurements, Doral, Florida, 2022 (https://doi.org/10.5281/zenodo.23513500).
- Exhibit 3B: National Census Plan: Technology Habits and Symptoms Associated with Electromagnetic Sensitivity Concerns, with questionnaires A and B (https://doi.org/10.5281/zenodo.23513476).
Please accept and consider all attached documents, the Section 3 summary and Exhibits 3A and 3B, as part of the public record.
Respectfully,
J. Joaquín Machado
EMR Researcher and Director of the EFEIA Institute
I worked at Coastal Pines Technical College from 2029 to 2025. My office was located directly under a rou…
ORIGINAL COMMENT · UNEDITED TEXT
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 Foundati…
ORIGINAL COMMENT · UNEDITED TEXT
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 products in accredited laboratories with published data, to ask the NRC and the CPSC to screen "negative ion" wearables, and to issue consumer guidance that starts with distance and source control.
This section responds to questions 5(n), 5(o), 6, 8, 9, 13(a), 13(c), 13(d), 15(d), 16, 17 and 18. The attachments are the Section 4 summary and the exhibit that corresponds to it:
- Section 4 summary: Shielding, Harmonizers and Consumer EMF Products: Protection Claims Without a Test Standard, and the Shielding Paradox (https://doi.org/10.5281/zenodo.23523493).
- Exhibit 4A: National Framework for the Evaluation and Regulation of Electromagnetic Protection Technologies: Problem Analysis and Proposed Unified Evaluation Protocol (https://doi.org/10.5281/zenodo.23513472).
Please accept and consider all attached documents, the Section 4 summary and Exhibit 4A, as part of the public record.
Respectfully,
J. Joaquín Machado
EMR Researcher and Director of the EFEIA Institute
These are separate official submissions grouped by topic. A comment can appear in more than one board.