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I always use a wired computer and try to avoid using my cell phone. This is because when I got a new router sometime during the last decade, I asked the company not to set me up for wireless, but to give me a safe, wired connection. It was obvious to me that the person lied, because that evening I was sitting just a few feet from my TV and router, and I started to have heart palpitations and later had terrible insomnia, which are major symptoms of RF radiation and EMF sensitivity. I only use my computer wired, period. There needs to be an immediate movement towards the safety of cellphones and wireless. The Europeans are way ahead of us on this. I purposely tried to find a phone with less power than most. When it comes to 4 G or 5 G, it's all dangerous, especially cell towers that infringe on populated areas and make people sick. It's well past time for updated FCC regulations, which haven't been touched since the mid-1990s. It's time to finally err on the side of caution and protect human health by updating the regulations that are vastly outdated. Because I need to wear hearing aids, I only use them in airplane mode. If I fail to do that, the wireless affects my thinking and thus my brain. This is serious business that needs to be addressed. People with hearing loss should have a choice about whether they use wireless hearing aids, which are usually paired with a phone or not. It's definitely problematic for many people. Please look at these issues and know that you have the potential to hurt or help people in this country. There are many people who are sensitive to EMFs and RF Radiation, and there are probably many who aren't aware of what is causing some of their health problems. Please do the right thing for our people.

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; this comment represents the perspective of a research entity. Relationship disclosure. EFEIA operates within the NOXTAK Corporation ecosystem. NOXTAK develops and markets, as SPIRO, the passive nanocomposite presented in this section, and the undersigned is EFEIA's Director, NOXTAK's founder and CTO, and the named inventor on its patents. EFEIA presents the nanocomposite on the same terms it applies to every product in Section 4: what was tested, by whom, under what standard, with what result, and what remains to be done. Our submission, Section 5 of EFEIA's six-part evidence dossier, presents what ecosystems show about weak electromagnetic noise and a passive candidate solution. Migratory songbirds lose magnetic compass orientation under weak broadband radiofrequency noise in the nanotesla range, about 1,000 times weaker than current recommended limits as a BfS workshop review notes; honey bees show impaired learning and foraging under 50 Hz magnetic fields and reduced homing under Wi-Fi-band exposure. EFEIA has identified no federal exposure limit or monitoring program for animals, and an antenna or power line that meets the human limits has not been assessed for them. As a candidate solution that does not attenuate the signal, the section presents the SPIRO nanocomposite: in independent, accredited laboratories it produced up to 91% reduction in 10 g-averaged SAR across seven configurations, with antenna performance unchanged within uncertainty on three handsets, and a university-led, open, randomized, placebo-controlled trial recorded changes in heart rate variability. The evidence is organized in six tiers, with its limitations stated. We urge HHS to include passive, non-shielding approaches in the research it asks about in question 5(o), with this nanocomposite as the first worked case: a paired SAR and antenna-performance test on current 4G and 5G devices in accredited laboratories, controlled trials in homes and workplaces, and a sham-controlled physiological trial, with the developer supplying units and taking no part in the analysis. We also urge HHS to treat effects on pollinators, migratory birds and livestock under question 14 through a field program led by NIEHS with the Department of the Interior, USDA and EPA, in which the nanocomposite is tested in its own arm and analyzed separately. EFEIA invites a technical discussion with HHS and its agencies on the underlying reports, measurement records and replication conditions. This section responds to questions 3(f), 5(n), 5(o), 10(a), 10(c), 12, 13(a), 13(c), 14, 15(e), 16, 17 and 18. The attachments are the Section 5 summary and the exhibits that correspond to it: - Section 5 summary: Electromagnetic Noise in Living Systems: Evidence from Ecosystems and a Passive Candidate Solution (https://doi.org/10.5281/zenodo.23523495). - Integrated technical statement: Passive Nanocomposite Approach to Electromagnetic Risk Management: Integrated Statement of Technical Outcomes and Supporting Observations (https://doi.org/10.5281/zenodo.23513484), the author's own account, prepared for this submission. - Exhibits 5-1 to 5-5: the developer's technical documents, submitted unaltered, each behind an EFEIA cover sheet stating its source, evidence grade and the relationship: 5-1, description of the material; 5-2, electromagnetic compatibility and MIMO OTA tests; 5-3, the laboratory SAR summary; 5-4, field records at mobile-device scale; and 5-5, field records in residential and commercial spaces. Please accept and consider all attached documents, the Section 5 summary, the integrated technical statement and Exhibits 5-1 to 5-5, 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 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

*See Attached: Non-thermal Electromagnetic Field studies demonstrating harmful effects.

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 attached working paper, co-authored with Dr. Luis M. Valdés, physician and audiologist, is the fifth article in the EFEIA Research Institute's clinical and mechanistic series on tinnitus and electromagnetic fields. Disclosure: the undersigned is also founder and CTO of NOXTAK Corporation, and the school measurements reported in the paper were carried out by the authors' team under the IGEF and the NOXTAK Electromagnetic Research Center. The paper connects three conditions that share one clinical picture: Havana syndrome (anomalous health incidents, AHI), catastrophic tinnitus and extreme electromagnetic hypersensitivity. All three present with an abrupt intracranial sound or pressure, intense tinnitus, vertigo, headache, and cognitive, sleep and mood disturbance. The National Academies (2020) identified directed, pulsed radiofrequency energy as the most plausible mechanism for the acute phase of AHI, and the microwave auditory (Frey) effect provides an established physical bridge by which pulsed radiofrequency energy is perceived as intracranial sound. Building on this, the authors propose a model of cumulative load plus a triggering peak acting on a susceptible phenotype: the acute episode is the visible outcome of a silent accumulation, and greater stimulation shortens and precipitates critical episodes. This opens a direct civilian line of inquiry, since sudden-onset cases in the general population may follow the same mechanism. The exposures that could act as triggering peaks are already present and measurable in public space. At Downtown Doral Charter Upper School in 2022, the authors recorded peaks of 200 V/m of ELF electric field and 31 mG of magnetic flux on the sidewalks where children walk and wait, with the highest values between 9:30 and 11:30 a.m., when children were present. Their field work records values on the order of hundreds of V/m and more than 100 mG under high-voltage lines, next to substations and in electrical rooms adjoining bedrooms in universities, hotels and resorts. Across more than 1,000 EHS cases, the authors have observed that higher levels of stimulation shorten and precipitate critical episodes. Characterizing the patient's electromagnetic environment is therefore a practical step to add to the evaluation of sudden-onset tinnitus and new-onset EHS, consistent with the EUROPAEM guideline, which makes exposure reduction the primary measure for EMF-related illness. We urge HHS to support the five lines of research the paper proposes: a structured clinical comparison of symptoms, audiology, neuroimaging and autonomic biomarkers across AHI, catastrophic tinnitus and extreme EHS cohorts, to test the shared phenotype; systematic urban dosimetry of ELF electric, ELF magnetic and radiofrequency fields in parks, bus stops, school zones and around substations and high-voltage lines, with public exposure maps; screening for the susceptible phenotype (genetic polymorphisms, oxidative load, autonomic profile) in patients with sudden-onset tinnitus or abrupt-onset conditions without a conventional cause; modeling of the trigger threshold between cumulative load, peak magnitude and the probability and latency of a critical episode; and protocols for characterizing the patient's electromagnetic environment as part of the differential evaluation of sudden-onset tinnitus and new-onset EHS. The urban dosimetry line can be carried out within the national monitoring pilot proposed in Section 2 of EFEIA's dossier. As the authors conclude, measuring the electromagnetic load of public spaces and of the patient's environment, and recognizing the susceptible phenotype, can turn an unexplained presentation into a testable hypothesis and, above all, into a preventable exposure. This comment responds to questions 4(h) to 4(m), 5(p), 8, 10(c), 11(a), 11(f), 11(g), 12, 15(a) and 16. The attachment is: - Valdés, L. M., and Machado, J. J. From Havana Syndrome to Catastrophic Tinnitus and Extreme Electromagnetic Hypersensitivity: Cumulative Load, Triggering Peaks, and the Susceptible Phenotype. Why Sudden Onset Does Not Rule Out a Common Electromagnetic Mechanism. Working paper, EFEIA Research Institute, 2026 (https://doi.org/10.5281/zenodo.23522254). 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

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: as the review itself states, the undersigned is founder and CTO of NOXTAK Corporation, maker of SPIRO electromagnetic-hygiene products, and no external grant funding was received for the review. Since late 2016, true wireless earbuds have placed a continuous, bilateral radiofrequency source inside the ear canal, 20 to 30 mm from the cochlea, for hundreds of millions of young people, in addition to the acoustic dose the same devices deliver. Over the same decade, clinicians in EFEIA's network and the professionals it trains have seen a visible rise in adolescents and young adults presenting with tinnitus, most of them with normal audiograms and most of them heavy users of in-ear wireless devices. In the United States, 7.5% of NHANES participants aged 12 to 19 reported tinnitus (Mahboubi et al., 2013). The review identifies radiofrequency exposure from in-ear wireless devices as a complementary environmental toxin candidate alongside the established acoustic axis. Adolescents who develop tinnitus show a well-characterized vulnerability profile: cochlear synaptopathy that precedes audiometric loss, reduced sound-level tolerance, elevated central gain, and disturbed sleep and stress physiology. Non-thermal RF-EMF perturbs several of these same systems in animal models, with supporting signals in human provocation studies, and the convergence is strongest for oxidative stress and sleep. Where the two overlap, RF-EMF is a plausible and modifiable load on an already stressed auditory periphery. Existing studies measured phone-to-ear call time; the exposure profile of chronic earbud wear, continuous, bilateral and canal-resident, is the open research frontier, and it is the exposure young people actually receive. ITU-T H.870 already sets weekly sound allowances for these devices and can be extended to their radiofrequency emission. The review recommends a precautionary posture until direct epidemiology on this exposure profile exists. We urge HHS to fund the review's research agenda: a repeated, school-based teenage tinnitus surveillance series with a fixed case definition that records in-ear wireless wear time from the first wave; a prospective cohort of 2,000 adolescents aged 12 to 15 with in-ear acoustic dosimeters and worn RF exposimeters, with pre-registered tinnitus and hearing outcomes at two and four years; an animal study counting inner-hair-cell synapses under chronic 2.4 GHz Bluetooth-modulated exposure at earbud-representative SAR, with and without noise; a crossover sleep study of nighttime earbud use; an exposome-first clinical tinnitus registry that records acoustic dose, wireless wear time and ambient RF-EMF at first visit; and independent SAR and field-strength dosimetry of current earbud models in child and adolescent head phantoms. Surveillance fits CDC, the cohort, sleep and animal studies fit NIH, and independent dosimetry fits FDA's Center for Devices and Radiological Health. We also ask HHS to support adding an RF-EMF characterization requirement to ITU-T H.870 through ITU-T Study Group 16 and WHO Make Listening Safe. The review sets out when the response should escalate from precautionary monitoring to active advisory: a positive synapse study, a replication of the earlier tinnitus signal in an earbud-dominated cohort, or an IARC reclassification of RF-EMF above Group 2B. This comment responds to questions 4(m), 5(o), 5(p), 7, 8, 10(a), 10(d), 11(a), 12, 13(f), 16 and 17(a) to 17(c). The attachment is: - Machado, J. J. Bluetooth Headphones and RF-EMF in Teenage Tinnitus: Chronic in-ear wireless exposure as a complementary environmental toxin candidate. An Environmental Physiology evidence review. EFEIA Institute, SPECTRA program, September 2026 (https://doi.org/10.5281/zenodo.23519286). 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

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

*See Attached: Non-thermal Electromagnetic Field studies demonstrating harmful effects.

I practiced clinical neurosurgery in Tucson, Arizona, from 1992 until 2023, treating a wide array of neurosurgical disorders that included malignant brain tumors, complex spine and skull base tumors. I attended medical school at the University of Louisville School of Medicine and finished in 1985, and trained at the Barrow Neurological Institute from 1986 through 1992, in addition to completing a skull base fellowship at the University of Cincinnati. I became aware of cell phone radiation since its infancy and have been intrigued and wary of the developing technology that I saw progress over the years of my career. After my wife was diagnosed with electrohypersensitivity syndrome, I became extremely interested in the issues of electromagnetic fields well over 15 years ago. I now serve on the board of the Environmental Health Trust and have given nationwide presentations and published in this field. It is without question that, during my career, it became readily apparent that the use of cell phones that my patients exhibited was in no way benign. I saw a direct link between scalp infections, post-cranial surgery, and even spine infections as a result of cell phone exposure. It was not uncommon for me to find many of my patients in bed in the postoperative phase with a cell phone and computer in the bed, in immediate proximity to their surgical wounds. It is now well documented in the literature that the electromagnetic fields that are produced by wireless devices clearly affect tissue healing, affect the voltage-gated calcium channels, and produce oxidative stress. There was a clear connection between those patients who develop wound infections postoperatively and their cell phone use. It is also without question that those patients who developed glioblastomas invariably had a high correlation between the laterality of the tumor and the side of the head where they use their cell phone most frequently. The literature is replete with evidence of multiple harmful effects electromagnetic radiation involving occupational exposures, military participants and workers, and everyday children and housewives. Included below are resources that document higher rates of: - testicular cancer - infertility - miscarriage - leukemia - cognitive dementia - neurodegenerative diseases - colon cancer - cerebro- vascular disorders, such as stroke, that now occur with high incidence in young people - significant psychiatric disorders, such as depression and even suicide. The literature is so convincing that any literate person with a curious mind can do a search on pubmed.gov that clearly delineates the harmful effects of cell towers, cell phones, i-watches, Wi-Fi devices, Bluetooth devices, etc. Yes, there are studies that show no correlation, but invariably these are industry-sponsored studies that can be traced back to institutions with conflicts of interest. There's no hiding the fact that the telecom lobby spends millions of dollars per year lobbying our elected officials. In many ways, we have several lost generations now of children and individuals who can no longer express themselves freely without using some AI bot and clearly have lost the ability of independent thought. In many ways, even our adult brains have become rewired with these ongoing exposures, where people never give themselves a wireless digital break. I cannot tell you the number of times that I would see young adolescents, millennials, teenagers, and Gen Z individuals that would come in complaining of nonspecific headaches or mental status disorders when a primary care identified a bright spot of unknown origin on their MRI. A simple electromagnetic frequency survey revealed that none of these individuals ever break from the connection with their wireless devices. They eat, breathe, sleep, and even go to the bathroom with them. I am of the firm belief that the only hope to salvage our humanity going forward and to allow generations to develop with their own ideas and independent thoughts will only happen if there are industry regulations and safety warnings, just as there were with cigarettes and pesticides. The situation could never be more dire, and I encourage this committee to give my comments and all those of my colleagues serious consideration because our future is at stake!

'In fact, the EPA [Environmental Protection Agency] began the process of developing exposure guidelines but then never finished it as funding was cut off. The EPA drafted stage 1 RF exposure guidelines and sent them to comment prior to release in 1996. Stage 1 was only for thermal effects. The EPA announced that Stage 2 would protect against non thermal effects and would be ready in 1998. Then the Telecommunications Industry Association lobbied Congress to prohibit the EPA from releasing any guidelines. The 1996 Appropriations Bill that Congress passed defunded the EPA’s work in this area and contained language specifically prohibiting the EPA from increasing its regulations stating that “… EPA should not engage in EMF activities”. The 1996 Telecommunications Act gave authority over the health effects of wireless technology to a non-health agency–the FCC. The US Government Accountability Office published a report in 2012 urging the U.S. Federal Communications Commission to revisit the outdated safety standards for the exposures from wireless devices. The 2012 report states, “The Federal Communications Commission’s (FCC) RF energy exposure limit may not reflect the latest research, and testing requirements may not identify maximum exposure in all possible usage conditions.” The American Academy of Pediatrics, which represent over 62,000 pediatricians in the US has repeatedly called on the government to update its regulations stating that “Current FCC standards do not account for the unique vulnerability and use patterns specific to pregnant women and children." The California Medical Association (which is the California branch of the AMA), which represent over 40,000 physicians. passed a Wireless Resolution that states: Whereas peer reviewed research has demonstrated adverse biological effects of wireless EMF including single and double stranded DNA breaks, creation of reactive oxygen species, immune dysfunction, cognitive processing effects, stress protein synthesis in the brain, altered brain development, sleep and memory disturbances, ADHD, abnormal behavior, sperm dysfunction, and brain tumors; and…Resolved, That CMA support efforts to implement new safety exposure limits for wireless devices to levels that do not cause human or environmental harm based on scientific research.' https://ehtrust.org/policy/fcc-safety-standards/ 'In contrast to the dozens of EMF scientists who support the ICNIRP [International Commission for Non-Ionizing Radiation Protection] EMF exposure guidelines, more than 240 EMF scientists from 42 nations who published peer-reviewed research on EMF and biology or health totaling over 2,000 papers have signed the International EMF Scientist Appeal. The Appeal calls on the WHO, the United Nations and all member nations to adopt much stronger EMF exposure guidelines that protect humans and other species from sub-thermal levels of EMF exposure and to issue health warnings about the risks of EMF exposure.' https://www.saferemr.com/2018/07/icnirps-exposure-guidelines-for-radio.html