An amateur-radio operator calls for realistic cumulative-exposure assessment, transparent device disclosu…

Re: Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure — Docket No. HHS-OASH-2026-0397 Submitted by: Charles J Foster II, amateur radio callsign KS0VO, Kansas Perspective (Question 2). I respond as a licensed amateur radio operator and an ARRL Volunteer Examiner — an individual with sustained, hands-on proximity to RF transmitters, and a volunteer who helps administer the licensing examinations through which new operators, including minors, enter the amateur service. My comments rest on operating experience and the published guidance of the amateur service, not on medical or laboratory research. I offer them on the practical questions: how exposure actually occurs, how it is measured, and what the public is told. Questions 5(p) and 8 — exposure assessment should reflect how transmitters are really used. Any classification or assessment system has to account for the characteristics that dominate real exposure: duty cycle, modulation, distance from the source, and cumulative exposure over time. In amateur operation alone, duty cycle runs from near-continuous (FM voice, some digital modes) to roughly a fifth of transmit time (single-sideband voice), and exposure falls off fast with a few feet of separation. Current assessment methods lean on standardized assumptions, and real-world measurement remains weak: a consumer or licensee who wants to characterize the exposure in their own home or around their own station has few affordable, calibrated options and no common standard to measure against. HHS should treat better real-world exposure characterization — including cumulative, multi-source exposure — as a methods and research priority. Questions 5(n) and 9 — disclosure. What should be disclosed, in plain language, is what a non-engineer needs to make sensible choices: a device's transmit power and duty characteristics, the separation distance it was tested at, and what its exposure numbers assume about how it is held and used. Today, SAR values sit in certification filings few consumers ever see, and manuals describe separation distances that ordinary use ignores. Standardized disclosure at the point of sale and in the device itself would cost little and would let families, schools, and employers act on real information instead of reassurance or alarm. Question 11(a) — children. Children merit separate assessment. There is no minimum age for an amateur license, and young operators' first transmitter is typically a handheld radio held at the face. Whatever HHS concludes from the evidence, children differ from the adults the current framework was built around: smaller bodies, developing tissue, and the longest remaining lifetime over which exposure accumulates. The assessment should say so explicitly rather than treating them as small adults. Question 13 — cumulative exposure. Exposure in 2026 is layered: commercial mobile and broadcast services, Wi-Fi, wearables, smart meters and appliances, and — in a home like mine — a licensed amateur station. Each source is assessed largely on its own; nobody's framework describes the total. HHS should characterize cumulative patterns as people actually experience them, including amateur and occupational sources alongside consumer ones. Question 16 — research gaps. The highest priorities from a practitioner's seat: (1) long-term studies using modern waveforms and realistic duty cycles rather than continuous-wave stand-ins; (2) standardized, reproducible dosimetry so studies can be compared and replicated; (3) research on portable devices used at zero separation distance, and on children. Question 17 — coordination. HHS should place its completed assessment into the record of FCC Docket No. 13-84, where the FCC is answering a court remand on these same exposure questions. The FCC is an engineering agency, not a health agency; its remand response should rest on a current, transparent health-agency record rather than on reviews that predate today's exposure environment. Question 18 — closing. Distinguish clearly, as this RFI promises to do, between established evidence, emerging findings, and open questions — and say plainly where the honest answer is "not yet known." That candor is what will make the eventual guidance worth trusting. Respectfully submitted, Charles J Foster II, KS0VO ARRL Volunteer Examiner Belvue, Kansas