Eleven documents for the public record: what EFEIA submitted to HHS
On 20 and 21 October 2026, the EFEIA Institute submitted eleven comments to the U.S. Department of Health and Human Services in response to its Request for Information on electromagnetic fields, radiofrequency radiation and wireless exposure. HHS posted all eleven to the public docket on 28 October 2026. Every document, exhibit and plan is also published open access on Zenodo under its own DOI.
An invitation to put evidence on the record
On 17 September 2026 the U.S. Department of Health and Human Services announced a Request for Information on electromagnetic fields, radiofrequency radiation and wireless exposure. The notice ran in the Federal Register on 21 September 2026 (document 2026-19252) under docket HHS-OASH-2026-0397.
An RFI is not a rule. It is an invitation to place evidence, data and proposals on the public record so that an agency can decide what to do next. That is the kind of contribution the EFEIA Institute exists to make. Since 2020 we have measured urban electromagnetic environments, documented the people who report symptoms they associate with exposure, and reviewed the scientific literature with a method that keeps what has been observed apart from what is only hypothesized.
Our submission does not ask HHS to adopt a conclusion. It asks for better measurement, a national record of who is affected, a neutral way to evaluate protection technologies, and professional education that reflects what the limits actually assume.
A word on status. HHS reviewed the eleven comments for posting and published them in the public docket of HHS-OASH-2026-0397 on 28 October 2026. Posting means the documents are now public and can be read and cited by anyone. It is not an endorsement of their content, and HHS has not responded to them or acted on them. Nothing on this page should be read as suggesting otherwise.
Three rules behind every document
Graded evidence
- (a)Peer-reviewed study, standards body, court record or accredited laboratory report.
- (b)Institutional report, preprint, thesis or recognized seal.
- (c)Manufacturer, advocacy or media source.
Every citation carries its grade. We never upgrade a source by paraphrasing it.
Observations apart from hypotheses
Field measurements, case counts and survey answers are reported as what they are. A proposed mechanism is labeled a hypothesis, with the test that would confirm or reject it. The health documents acknowledge what people live with without asserting a cause.
Relationship disclosed
J. Joaquín Machado, EFEIA founder and director, is also founder and CTO of NOXTAK Corporation, which develops SPIRO® products. The relationship is stated in the documents wherever it is relevant, and no document links any product to any health condition.
Complying with the limits does not mean exposure is under control.
The current limits do not consider the artificial polarization of man-made fields, non-thermal effects, the overlapping layers of exposure in modern environments, our dependence on wireless connectivity, or how close and how long personal devices are used, including during sleep. That position runs through all eleven documents.
From what the limits assume to what happens in living systems
Presented in the order of the argument rather than their numbering: what the limits assume, what the instruments miss, what reaches people in the city, who is affected, how protection should be judged, and what happens beyond people.
What the limits assume and what the public is told
The limits most people are told to trust, ICNIRP 2020, IEEE C95.1-2019 and FCC 47 CFR 1.1310, rest on a defined set of assumptions: tissue heating, averaged over a given time and mass, from a single source. Section 6 lays those assumptions out and compares them with the sentence the public usually hears, that the limits protect everyone. It then turns to the professionals who answer the public's questions, from physicians to building inspectors, and to how little formal training most of them have received on non-ionizing exposure.
Our proposal
A National Program for Scientific Integration and Professional Education (Exhibit 6A): bring the science on non-thermal effects, polarization and combined exposure into one body of reference material, and build training for the professions that advise the public, so that what they say matches what the limits actually cover.
Limitations of current electromagnetic instrumentation
An instrument reports what it was built to detect. Section 1 documents what the instruments in common use, in the field and in compliance testing, do not register: bands above their range, the modulation and polarization of the signal, and the combined contribution of many sources at once. A compliance measurement can be correct and still describe only part of the environment a person is standing in.
Our proposal
A Next Generation EMF Instruments Development Plan (Exhibit 1A): specify and build instruments that capture the higher bands, the modulation and polarization characteristics, and the cumulative exposure from many sources, measured at the body rather than at the antenna.
National Urban Electromagnetic Monitoring Program
Section 2 is built on EFEIA's own field work in Miami. Exhibit 2A reports the Brickell measurement campaign from 2020 to 2026, and Exhibit 2C the Doral campaign of 2022. Together they show how the electromagnetic environment of a dense urban district has changed, measured where people live, work and sleep rather than at the source.
Our proposal
A National Monitoring Plan (Exhibit 2B): a standing network of measurement points in U.S. cities, a single method so results can be compared across time and place, and public reporting, so that the exposure people actually receive becomes a documented quantity instead of an assumption.
National Census of EHS and Existing Health Conditions
There is no national record of the people in the United States who report symptoms they associate with electromagnetic exposure, or of the conditions they already live with. Exhibit 3A documents a school case involving fifteen students, presented as observations and the questions they raise, not as proof of cause. The section's purpose is to listen systematically before concluding anything.
Our proposal
A National Census Plan (Exhibit 3B), voluntary and run over 24 months, built on two questionnaires that every participant completes: A on technology habits, proximity and night-time device practices, and B on 25 symptoms, each rated from 0 to 10. It is open to people with and without concerns about exposure, so that the first national baseline on who is affected, and how, can be built on consistent data. Neither questionnaire is validated yet: it is a research initiative, not a diagnostic test.
Shielding, harmonizers and consumer EMF products
People who worry about exposure buy products, and most are sold without any neutral way to evaluate them. Section 4 describes the market and one of its best-documented traps, the shielding paradox: a phone that receives a weaker signal transmits at higher power to compensate, so shielding in the wrong place can raise the exposure it was meant to lower.
Our proposal
A National Framework for EMF Protection Technologies (Exhibit 4A): the same tests, the same evidence grades and the same disclosure rules for every product on the market, whatever its principle of operation, including those connected to this submission's author. Consumers would get comparable information instead of competing claims.
Electromagnetic noise in living systems
Section 5 moves from people to ecosystems. It reviews the evidence on how artificial electromagnetic noise interacts with living systems, with particular attention to pollinators and birds, whose orientation and behavior have been studied under controlled exposure. From that review it describes a passive, non-shielding approach as a candidate solution, with its evidence graded tier by tier in the integrated technical statement and annexes. That candidate is SPIRO®, developed by NOXTAK Corporation, where the author of this submission is founder and CTO. The relationship is disclosed in the document, the evidence is presented with its grades and its acknowledged limitations, and no claim connects the product to any health condition.
Our proposal
A field program for living systems: monitor artificial electromagnetic noise in habitats that matter for pollinators and birds, study its effects under controlled conditions, and evaluate passive approaches to reducing it under the same graded-evidence rules proposed in Section 4.
Specific questions the sections could not cover in full
Havana syndrome, catastrophic tinnitus and extreme EHS
Co-authored with Dr. Luis M. Valdés, the paper places three clinical presentations side by side, the symptoms grouped under "Havana syndrome", severe disabling tinnitus and the most extreme forms of electromagnetic hypersensitivity, and asks whether they share features worth investigating together. It is explicit that this is a hypothesis for research, not a diagnosis or a finding. Four companion working papers by the same authors were published on Zenodo the same day; they are listed with the full set of DOIs at the end of this page.
Bluetooth headphones and RF-EMF in teenage tinnitus
What is known, and what is not, about tinnitus in adolescents and the radiofrequency exposure from wireless earphones worn for hours at a time. The review grades each study, separates acoustic from electromagnetic factors where the literature allows, and names the research needed before any conclusion can be drawn.
Electromagnetic fields and autism spectrum disorder
A map of the published literature that has examined electromagnetic exposure in relation to autism spectrum disorder: what each study measured, what it found and how strong it is. The review builds no causal chain. Its contribution is a clear statement of the gaps.
Modern vehicles as occupied electromagnetic environments
A modern car is a small enclosed space people occupy for hours, with wireless systems operating inches from them. In-cabin radar works between 57 and 64 GHz and road-facing radar between 76 and 81 GHz, while the instruments most used to assess exposure stop below 6 GHz. The document proposes a National Plan for Electromagnetic Biocompatibility in Modern Vehicles, submitted under its own DOI.
National Program for the Review of Research Criteria in EHS
Much of the research on electromagnetic hypersensitivity has used designs that the clinicians who see these patients consider poorly matched to what they observe. The proposal is accompanied by letters from Dr. Pilar Muñoz-Calero of Fundación Alborada, Dr. Luis M. Valdés and the author, describing from clinical experience what a study would need to take into account to be considered valid by the physicians who treat these patients.
Eight proposals, one direction
Each is a program, plan or framework that a federal agency could take up. Together they describe a country that measures what reaches people, records who is affected, evaluates protection on equal terms and trains the professionals who advise the public.
Next Generation EMF Instruments Development Plan
Instruments that register the bands, modulation and polarization current equipment misses.
National Electromagnetic Monitoring Plan
A standing network measuring urban exposure where people live, work and sleep.
National Census Plan
A voluntary national record of technology habits and reported symptoms, built on questionnaires A and B.
National Framework for the Evaluation and Regulation of Electromagnetic Protection Technologies
A neutral evaluation structure for shielding, harmonizers and consumer products.
Passive Nanocomposite Approach to Electromagnetic Risk Management
The integrated technical statement behind the field program for living systems, with its evidence graded tier by tier.
National Program for Scientific Integration and Professional Education
Training for the professionals who answer the public's questions on exposure.
National Plan for Electromagnetic Biocompatibility in Modern Vehicles
Assessment of the vehicle cabin as an occupied exposure environment.
National Program for the Review of Research Criteria in EHS
Research designs that match what clinicians observe in these patients.
The record is open. So is our door.
The comment period closed on 21 October 2026, and HHS posted the eleven comments to the public docket a week later. They are now part of the public record, where agencies, researchers and the public can read and cite them. EFEIA will keep doing what the documents describe: measuring, documenting, reviewing the literature and publishing with DOIs so that the work can be checked. Over the coming weeks we will publish a series of short pieces on our social channels, each on one theme from the submission, linking back to this page.
All 25 open-access records, with DOI and tracking numbers
Each of the eleven comments was filed in docket HHS-OASH-2026-0397 on regulations.gov under the tracking number shown, submitted by EFEIA as an organization, and posted by HHS on 28 October 2026. The tracking number links to the public comment page. The summary of each comment, its exhibits and its plans are published open access on Zenodo under their own DOIs, so every piece can be read and cited on its own.
The six sections
| # | Comment and attachments | DOI | Tracking (links to comment) | Filed · Posted |
|---|---|---|---|---|
| S1 | Section 1. Limitations of Current Electromagnetic Instrumentation: What Today's Instruments Miss in Urban Environments, and the Measurement Capabilities Needed | 10.5281/zenodo.23523487 | mvh-ld0k-7q4b | 20 Oct · 28 Oct 2026 |
| Exhibit 1A. Next Generation Electromagnetic Measurement Instruments | 10.5281/zenodo.23519314 | |||
| S2 | Section 2. A National Urban Electromagnetic Monitoring Program: Radiofrequency, Microwave and Low-Frequency Fields, with Brickell, Miami (2020-2026), and Doral, Florida (2022), as Reference Cases | 10.5281/zenodo.23523489 | mvh-ljln-7rkx | 20 Oct · 28 Oct 2026 |
| Exhibit 2A. Six-Year Trends in Environmental RF Exposure Across Brickell and Downtown Miami: Comparative Measurements from 2020 to 2026 | 10.5281/zenodo.23519320 | |||
| Exhibit 2B. National Electromagnetic Monitoring Plan | 10.5281/zenodo.23519313 | |||
| Exhibit 2C. Environmental Electromagnetic RF/Microwave 5G, Wi-Fi, ELF-LF Exposure in City of Doral 2022 | 10.5281/zenodo.23519306 | |||
| S3 | Section 3. A National Census of Electromagnetic Hypersensitivity (EHS, IEI-EMF), and EMF as a Potential Amplifier of Existing Health Conditions | 10.5281/zenodo.23523491 | mvh-louw-o1qe | 20 Oct · 28 Oct 2026 |
| Exhibit 3A. School Case Study of EHS Related Symptoms in 15 Students | 10.5281/zenodo.23519323 | |||
| Exhibit 3B. National Census Plan, with questionnaires A and B | 10.5281/zenodo.23519310 | |||
| S4 | Section 4. Shielding, Harmonizers and Consumer EMF Products: Protection Claims Without a Test Standard, and the Shielding Paradox | 10.5281/zenodo.23523493 | mvh-lvah-hryj | 20 Oct · 28 Oct 2026 |
| Exhibit 4A. National Framework for the Evaluation and Regulation of Electromagnetic Protection Technologies | 10.5281/zenodo.23519309 | |||
| S5 | Section 5. Electromagnetic Noise in Living Systems: Evidence from Ecosystems and a Passive Candidate Solution | 10.5281/zenodo.23523495 | mvh-m6a8-0wao | 20 Oct · 28 Oct 2026 |
| Integrated technical statement. Passive Nanocomposite Approach to Electromagnetic Risk Management (with annexes 5-1 to 5-5) | 10.5281/zenodo.23519317 | |||
| S6 | Section 6. What the Limits Assume and What the Public Is Told: The Assumptions Behind Current Exposure Assessment, and Electromagnetic Literacy Without Fear | 10.5281/zenodo.23523497 | mvh-mbrm-91pn | 20 Oct · 28 Oct 2026 |
| Exhibit 6A. National Program for Scientific Integration and Professional Education on Electromagnetic Exposure and Health | 10.5281/zenodo.23519304 |
The five additional documents
| # | Comment and attachments | DOI | Tracking (links to comment) | Filed · Posted |
|---|---|---|---|---|
| A1 | Additional 1. From Havana Syndrome to Catastrophic Tinnitus and Extreme Electromagnetic Hypersensitivity: Cumulative Load, Triggering Peaks, and the Susceptible Phenotype. Working paper, Valdés and Machado | 10.5281/zenodo.23522254 | mvh-mhzp-mj83 | 20 Oct · 28 Oct 2026 |
| A2 | Additional 2. Bluetooth Headphones and RF-EMF in Teenage Tinnitus. SPECTRA evidence review | 10.5281/zenodo.23519286 | mvh-mnzk-nr7e | 20 Oct · 28 Oct 2026 |
| A3 | Additional 3. Electromagnetic Fields and Autism Spectrum Disorder. SPECTRA evidence review | 10.5281/zenodo.23519237 | mvh-ms2y-2u6b | 20 Oct · 28 Oct 2026 |
| A4 | Additional 4. Modern Vehicles as Occupied Electromagnetic Environments: Measuring What Reaches the Person in the Seat | 10.5281/zenodo.23541753 | mvi-ltyr-pc3o | 21 Oct · 28 Oct 2026 |
| National Plan for Electromagnetic Biocompatibility in Modern Vehicles | 10.5281/zenodo.23541733 | |||
| A5 | Additional 5. National Program for the Review of Research Criteria in Electromagnetic Hypersensitivity, with letters from Machado, Muñoz-Calero and Valdés | 10.5281/zenodo.23545803 | mvi-lycs-glo8 | 21 Oct · 28 Oct 2026 |
Companion working papers, Valdés and Machado
Published open access on Zenodo on 20 October 2026, alongside Additional 1, as part of the same series on tinnitus, cumulative electromagnetic load and the susceptible phenotype. Each is a working paper: a hypothesis set out for research, with its clinical observations reported as observations.
| Working paper | DOI | Published |
|---|---|---|
| The High-Exposure Bedroom: Habits of Wireless Technology Use, Near-Field Coupling During Sleep, and Sudden-Onset Nocturnal Tinnitus. A Common Denominator in Two Electromagnetic Hypersensitivity Censuses (2017–2025) | 10.5281/zenodo.23522252 | 20 Oct 2026 |
| Central Gain and Phantom Sound: Polarized Electromagnetic Fields as a Neural Stimulus That Amplifies Tinnitus. An Observational Clinical Case of Exposure to Near-Field Dirty Electricity | 10.5281/zenodo.23522244 | 20 Oct 2026 |
| The Redox-Environmental Axis of Tinnitus: Glutathione Elevation and Electromagnetic Hygiene (LEDNA Protocol) as a New Therapeutic Approach | 10.5281/zenodo.23522246 | 20 Oct 2026 |
| From Masking to Redox Rescue: Oxidative and Nitrosative Stress in Tinnitus and Glutathione as the Master Antioxidant Against Non-Ionizing Electromagnetic Aggressors | 10.5281/zenodo.23522242 | 20 Oct 2026 |
Federal Register notice: document 2026-19252, 21 September 2026. Comments posted by HHS on 28 October 2026 (comment IDs HHS-OASH-2026-0397-6307 to -6915). Zenodo records retrieved 27 October 2026.