Describes military and FAA radar-maintenance work and requests realistic occupational exposure assessment…

Re: HHS-OASH-2026-0397 — Occupational RF/EMF exposure and radar-maintenance workers I ask HHS to include current and retired radar-maintenance technicians in its evaluation of RF/EMF exposure and health. My Illinois Air National Guard work ran from 1981–1989; my FAA civilian employment ran from 1990–2017. Please consider this comment with both attachments: 1. “01 HHS response - numbered questions.pdf” answers Questions 2, 3, 5, 6, 7, 8, 9, 10, 11, 12, 16, 17 and 18. 2. “02 Supporting attachment - ANG and FAA radar maintenance.pdf” provides a partial maintenance account, historical FAA and AFOSH requirements, reproduced source material, research references, records-access concerns and seven policy recommendations. My work included energized radar and communications equipment, close working positions, simultaneous transmitter operation and troubleshooting under conditions different from ordinary operation. During ANG and FAA work, I removed covers and protective shields and energized equipment for troubleshooting and alignment near exposed high-voltage circuitry, discharge thyratrons, magnetrons, and klystrons. Assessments should represent actual maintenance conditions: worker position, task duration, open cabinets, altered shielding and simultaneous sources. They should also address indoor work in the building nearest the emitters, including possible reflections and standing waves. Equipment and building information and measurements are needed; external antenna calculations alone do not resolve indoor exposure. The RFI concerns non-ionizing RF/EMF. The attachment also addresses possible equipment-generated ionizing X-rays as a separate pathway that may coexist with RF. I ask researchers to evaluate each pathway and possible combined effects. Historical hazard descriptions and my recollections do not establish my individual dose or prove disease causation. I ask HHS to include endocrine outcomes, parathyroid disease and calcium regulation in long-term occupational research. The attachment distinguishes proposed mechanisms and experimental findings from established clinical evidence. Occupational-health processes should connect abnormal findings with appropriate medical evaluation and review of continuing workplace exposures. Written safety and occupational-health programs existed. I recall a Safety and Environmental Compliance Manager, but I do not recall ever receiving medical surveillance related to radiation exposure during my FAA employment. That recollection does not establish that no assessment occurred. The question is how requirements were implemented: what conditions were assessed, how findings were communicated, what monitoring decisions were made, and what referrals or follow-up were provided. Obtaining evidence has itself become a burden. Through FOIA, I have requested RF surveys, equipment configurations, technical manuals, safety training and occupational-health records. Despite multiple requests, follow-ups and an appeal, the records needed to evaluate my maintenance conditions are not readily available to me. An FAA response identified radiation-safety course updates in 2018 and 2023 without supplying those materials. FAA's historical requirements called for radiation-survey data, employee exposure records and related medical evaluations to be retained for employment plus 30 years. Employee exposure records were to be catalogued and readily accessible. I ask HHS to address the difference between required retention and effective worker access. Agencies should identify custodians, locate records and explain documented transfers or disposition. Unavailable evidence should not be treated as proof of no exposure or no harm. I ask HHS to coordinate with FAA/DOT, the Department of Defense, the Air Force, ANG and occupational-health agencies to evaluate actual maintenance exposures, provide relevant records, support long-term research involving retired technicians, clarify medical-referral and follow-up responsibilities, and assess workforce and public-safety consequences where gaps are identified. I also ask HHS to cooperate with Congress on a coordinated compensation pathway for occupational radiation harm. VA permits post service disability claims without a filing deadline; FECA generally has a three-year filing rule, with special provisions for latent disability. Workers with military and federal civilian exposure histories can encounter different rules for the same diagnosed illness. Related claims should receive coordinated or parallel evaluation using shared evidence and clear eligibility and benefit-coordination guidance. Please read both attachments as parts of this response. They provide the experience, evidence, limitations and recommendations supporting these requests.