PUBLIC COMMENT — HHS DOCKET HHS-OASH-2026-0397 Submitted by: Slowphone Brasil Slowphone Brasil advocates …

PUBLIC COMMENT — HHS DOCKET HHS-OASH-2026-0397 Submitted by: Slowphone Brasil Slowphone Brasil advocates for healthier and safer use of technology. We urge the US Department of Health and Human Services (HHS) to reassess electromagnetic field (EMF) exposure standards, consider the scientific evidence already available, and prioritize public health and the protection of life over commercial interests. 1. REASSESS EXPOSURE LIMITS Current radiofrequency (RF) exposure standards should be independently reassessed in light of peer-reviewed research reporting biological effects and potential health concerns below existing guidelines. The review should address voltage-gated calcium channels, oxidative stress and peroxynitrite pathways, blood-brain barrier permeability, and tumors, including gliomas and schwannomas. HHS should evaluate the US National Toxicology Program studies and the Ramazzini Institute's 2018 findings alongside epidemiological research, systematic reviews and subsequent evidence. Animal findings and proposed mechanisms should be distinguished from proven human causation, without dismissing relevant evidence because scientific uncertainty remains. 2. ENSURE SCIENTIFIC INDEPENDENCE HHS should examine conflicts of interest, funding sources, professional affiliations and evidence-selection methods in organizations whose recommendations inform exposure standards, including ICNIRP. Relevant concerns should be assessed through verifiable documents, declarations of interest and transparent review procedures. Independent experts should evaluate the full body of evidence, including findings that challenge existing assumptions. 3. ADOPT MORE PROTECTIVE INTERNATIONAL BENCHMARKS We propose an international outdoor RF reference level of 100,000 µW/m² (0.1 W/m²) for consideration and scientific evaluation. HHS should compare US standards with current regulations in Austria, Belgium, Switzerland, France, Poland, Italy and Israel, identifying more protective approaches and the rationale behind them. Comparisons must specify frequency, averaging periods, measurement conditions and whether values are binding limits or precautionary targets. 4. REDUCE EXPOSURE AT SOURCE HHS should promote a comprehensive strategy to reduce unnecessary exposure while maintaining essential communications. Wireless routers should provide effective low-emission modes, adjustable transmission power and automatic reduction of unnecessary transmissions. JRS ECO technology may serve as a technical reference, subject to independent testing. Public institutions, schools, hospitals, childcare facilities and workplaces should prioritize wired Ethernet connections where practical, reducing dependence on Wi-Fi in locations occupied for long periods. Wireless networks should be deployed only where needed, with access points configured to avoid unnecessary transmission power. Consumers should have access to mobile phones with low specific absorption rates (SAR), transparent and comparable exposure information, and easy-to-use settings that reduce unnecessary transmissions. Hands-free use, speakerphone use and keeping active devices away from the body when practical should be encouraged. HHS should also evaluate exposure from cellular infrastructure, small cells, Internet of Things devices, wearables, smart meters and emerging wireless technologies. Infrastructure planning should consider exposure in homes, schools and other sensitive locations. 5. PROTECT CHILDREN AND SENSITIVE SETTINGS Public-health guidance should give particular attention to children, pregnancy and fetal development. Schools and childcare facilities should favor wired connections where feasible and adopt practical exposure-reduction measures. Public procurement policies should consider low-emission connectivity options and transparent technical specifications. 6. ADDRESS DIRTY ELECTRICITY HHS should support independent, reproducible research on high-frequency electrical noise conducted through wiring, sometimes called dirty electricity. Proposed filters should be assessed through standardized measurements before and after installation; health benefits should not be presumed without reliable evidence. Measurement methods and units must be clearly defined. 7. WARN AND INFORM THE PUBLIC HHS should consider prominent graphical health-information labels on RF-emitting devices and products, inspired by tobacco warnings. Labels should explain that exposure and scientific uncertainty exist and provide practical ways to reduce unnecessary exposure. A broad public-awareness campaign, drawing on documented initiatives in Cyprus, should explain exposure sources, research findings, uncertainties and preventive options. Environmental measurements should be publicly accessible and report RF in µW/m², electric-field strength in V/m, and magnetic-field strength in nT. Dirty electricity requires separate, clearly defined measurement methods. 8. GLOBAL ACTION AND TRANSPARENCY The United States should encourage international cooperation on independent research, standardized environmental monitoring, public disclosure of measurement results and periodic reassessment of exposure limits. Publicly funded research should disclose conflicts of interest and funding sources, publish results regardless of outcome, and enable independent verification. OUR PRINCIPAL REQUESTS 1. Reassess existing RF exposure limits and evaluate an international outdoor reference level of 100,000 µW/m². 2. Implement a broad public-awareness campaign and promote practical exposure-reduction measures worldwide. 3. Introduce prominent graphical warnings on RF-emitting products and strengthen protections in schools and other sensitive settings. Public health and the protection of life must take precedence over commercial interests. HHS should act on existing evidence, improve scientific transparency and advance proportionate preventive measures without waiting for every uncertainty to be resolved. REFERENCES IARC. Non-Ionizing Radiation, Part 2: Radiofrequency Electromagnetic Fields. Monographs, Volume 102 (2013). https://publications.iarc.who.int/126 US National Toxicology Program. Technical Reports 595 and 596 (2018). https://ntp.niehs.nih.gov/research/apptoxres/cartox Italy. Law No. 36 of 22 February 2001. https://www.parlamento.it/parlam/leggi/01036l.htm