{"id":"HHS-OASH-2026-0397-5353","number":"5353","name":"","organization":"StingRay Shields Corporation","posted":"2026-10-27T04:00Z","received":"2026-10-21T04:00Z","body":"Response to Questions 5, 8, 9 and 11\n\nI am Erin Finegold, founder and CEO of StingRay Shields Corporation, a company developing passive antenna-related RF structures. My work gives me a direct professional interest in RF-exposure measurement and engineering approaches to reducing exposure.\n\nI urge HHS to recommend lower, more protective radiofrequency (RF) exposure limits and stricter Specific Absorption Rate (SAR) compliance requirements. The FCC’s SAR limits were adopted in 1996. Wireless technologies and patterns of use have changed substantially since then. Protective requirements should address prolonged body contact, exposure involving multiple transmitting devices, and children’s use. Recommendations should lead to enforceable improvements in consumer protection, rather than stopping at calls for additional research.\n\nHHS should fully assess published findings of adverse biological effects and their relevance to human exposure, drawing on international research and examining funding sources and potential conflicts of interest. Consistent standards of scientific rigor should apply to all evidence. Scientific uncertainty should not be treated as proof that existing protections are sufficient.\n\nCompliance testing should include direct-contact body testing wherever such contact is reasonably foreseeable, including phones carried against the body. Any exceptions should be technically justified and publicly disclosed. Reports should distinguish head-contact testing from body testing, identify any separation gap, and explain how direct-contact exposure is addressed. Consumers should not bear responsibility for maintaining separation distances they may not understand or consistently observe.\n\nChildren’s protection should be an explicit requirement. Test methods and exposure assumptions should account for relevant ages, anatomical differences and patterns of use. Where adult-derived models are used, manufacturers should demonstrate that those models adequately protect younger users.\n\nPublic reports should document device configuration, operating frequencies, conducted transmit power, antenna placement, device-to-body separation, test methods and measurement uncertainty. Methods and results should be independently inspectable and reproducible, with clear disclosure of the conditions under which compliance was established and any limitations relevant to ordinary use.\n\nConsumer protection also requires effective enforcement after devices enter the market. France’s ANFR has required corrective measures, including software updates, market withdrawals and recalls, following findings of SAR noncompliance. I urge HHS to recommend routine independent testing of marketed devices, public disclosure of findings, and prompt mandatory corrective action, including sales restrictions and recalls where necessary. Manufacturers should remain accountable for compliance throughout the product’s marketed life.\n\nStronger requirements should encourage engineering improvements that reduce exposure. Claimed reductions should be independently evaluated alongside their effects on radiated efficiency and communication reliability.\n\nSupporting references are provided in the attached PDF.","attachments":["https://downloads.regulations.gov/HHS-OASH-2026-0397-5353/attachment_1.pdf"],"attachment_inventory":true,"withheld":false,"source":"https://www.regulations.gov/comment/HHS-OASH-2026-0397-5353","tags":["child-development","exposure-places","policy-standards","research-evidence"],"source_hash":"7313b8ee7e6c0ca7e6508e44da6b3c9911aa568f7419ab51e8633cdf23266a00","slug":"child-development-comment-5353","classification":{"id":"HHS-OASH-2026-0397-5353","body_sha256":"a137def43ba47c39c14ab33a4ecb5604c44810bfcc3ea5266411e3447676473f","status":"ai_reviewed","primary_topic":"standards","topics":[{"id":"standards","evidence":"tive radiofrequency (RF) exposure limits and stricter Specific Absorption Rate (SAR) compliance requirements. The FCC’s SAR limits were adopted"},{"id":"children","evidence":"may not understand or consistently observe.\n\nChildren’s protection should be an explicit requirement. Test methods and exposure ass"},{"id":"research","evidence":"t calls for additional research.\n\nHHS should fully assess published findings of adverse biological effects and their relevance to human expos"}],"summary":"An RF-engineering company founder requests lower exposure limits, direct-contact SAR testing, child-specific protections, public reporting and stronger post-market enforcement.","reviewed_at":"2026-10-27T19:20:49Z","review_method":"Full comment-text review with exact source evidence; attachments not reviewed","review_source_sha256":"50b84eea55beba84609f8d0c529436eacd40ea23fd36c14a0e83e8f843b8b064","source_url":"https://rfsafe.net/hhs-comments/data/catalog.json","scope":"Original comment body; attachments excluded"},"forum_topics":["standards","children","research"],"primary_topic":"standards","forum_title":"An RF-engineering company founder requests lower exposure limits, direct-contact SAR testing, child-speci…"}