HHS-OASH-2026-0397-5976
https://www.regulations.gov/comment/HHS-OASH-2026-0397-5976

My name is Sarah Aminoff, and I am a member of Safe Tech International, and a San Francisco, California educator. San Francisco has been a key test ground for driverless robotaxis, and being part of that experiment was not what I was thinking during student field trips to Golden Gate park. People are able to opt out of TSA Airport Scanners due to cumulative radiation concerns, but not Waymo robot taxi exposures, yet both use millimeter frequencies.
Since 2024 onwards, it has been hard to reduce exposure to Waymo, given California Public Utilities Commission has also approved expansion. Waymo Robotaxis send out millions of radar sensors to create a 3D picture, using millions of radar millimeter sensors or laser pulses that impinge on an automobile or pedestrian and its a complex EMF soup. The Robocars use three primary sensors: cameras, LIDAR and radar. Radar uses millimeter wave frequencies to provide Waymo with crucial details like an object's distance and speed. LiDAR uses laser beams to create dense, accurate 3D maps. The Waymo 5th Generation, has 29 cameras, six radar sensors tracking larger objects and four LiDAR sensors, which use laser pulses to "see" the car's surroundings in 3D.

To answer HSS question 5n and 8 

 The FCC still fails to capture ubiquitous and aggregate exposures. An aggregate signal analysis has yet to be done for driverless vehicles. Most of the compliance with federal standards are typically claimed for only one set of lights or emitters, as the FCC regulates RFR and Millimeter, yet on the Waymo 5th Generation there are 51 sensors.

 Time averaging dosimetry should not be permitted, especially for mmWaves and RF, as peak exposures that fall within FCC limits when time averaged over 30 minutes, can have serious non-thermal bioeffects at a cellular level potentially inducing reactive oxygen species and DNA, and sperm damage, according to International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF).

With driverless vehicles, radiofrequency radiation (RF) in the MMWave part of the spectrum and near IR poses possible deep thermal heating effects, yet the FCC relies on 30 minute dosimetry, averaging in peak exposures. Environmental Health Trust shares science research around the millimeter frequency concerns, including: 

“A 2021 paper “Millimeter (MM) wave and microwave frequency radiation produce deeply penetrating effects: the biology and the physics” by Martin L Pall PHD reviews the science on how MMwaves can have highly penetrating effects  stating that “in humans, MM-waves have penetrating effects including impacts on the brain, producing EEG changes and other neurological, neuropsychiatric changes, increases in apparent electromagnetic hypersensitivity and produce changes on ulcers and cardiac activity”
 
To answer Question 5

The FCC assessing for one vehicle only, not multiple car exposures is a gap in knowledge. According to Ron Kostoff in his article on radar and cars, ‘If you’re walking on a crosswalk in front of stopped traffic, you….could be exposed directly full body to a million microwatts/square meter.  And, there’s no glass or metal to absorb or block the radiation.  And, that’s with the assumption that you’re being radiated from one car only….what we really need to get are the codes the auto manufacturers use to compute actual radar exposures to car occupants and pedestrians. If some of the radars are mounted on the front bumper, then small children walking a crosswalk are most vulnerable. “

Time Averaging in Evaluating Dosimetry Levels in Smart Vehicles by the FCC is an inherent flaw. Technologies get approved without sufficient pre-market testing is another gap, see John P. Thomas’ article, Health Impact News “Will Driverless Cars Cause DNA Damage and Cancer? April 15, 2018.”  

We need to know Waymo will tag a pedestrian as an ‘object detected” with a velocity vector as a moving target and an obstacle to avoid. People are being mapped with radar, lidar, ultrasonic signals and were also captured on optical cameras that use IR and LED beam lights. The LiDAR, Radar and Camera sensors can detect images from hundreds of meters. These are artificial exposures targeting every square centimeter of the body.

Many autonomous vehicle incident were reported to:

Block traffic

Trap cars at the curb

Enter construction zones

Enter crime scenes, fail to follow directions

Hit a cat and dog, also child

Get in the way of emergency vehicles

And yet, state and federal agencies allow children to ride in robot taxis (Waymo with adult supervision, or parental consent) while the FCC and agencies fail to include children’s unique biology in guidelines. Driverless vehicles have multiple sensors, when children are exposed to Waymo et al, e.g. idling outside schools. A new study from Europe found children have higher RF absorption rates than adults.