HHS-OASH-2026-0397-5769
https://www.regulations.gov/comment/HHS-OASH-2026-0397-5769

HHS should treat low-frequency magnetic emissions from televisions and monitors as an exposure, children's programming first. RF limits rest on heating, specific absorption rate, and power density. They do not describe image-driven magnetic pulses in the band that overlaps the electroencephalogram. A set can meet a heating limit and still emit them. Airborne-speaker limits below 20 Hz answer a different question: magnetic fields pass through tissue and do not depend on a speaker cutoff.

The source is the display and its electronics, driven by ordinary programs. The field comes from image-intensity changes, power circuitry, and, on older tubes, deflection.

Meet the Teletubbies (1:01:43): a soundtrack spectrogram from 0 to 100 Hz, aligned with the picture, showed intermittent and at times dense energy below 50 Hz and below 20 Hz. The strongest sustained cluster below 20 Hz was near minutes 51-54, in insert and outdoor segments. The study does not establish intent or a neurological effect. It is a case for measuring the magnetic field at the set, not only the audio file.

FCC RF rules and the IEEE and ICNIRP guidelines center on heating, SAR, and power density. A pulsed field near 1/2 Hz, 2.4 Hz, or the 6-20 Hz calcium window is a different quantity. Public Notice FCC 74-78, 44 FCC 2d 1016 (Jan. 24, 1974), at 47 CFR 73.4250, calls subliminal broadcasts contrary to the public interest whether or not they work, because they are meant to deceive. That covers a hidden message, not a measurement of the receiver's field.

5(n)-(p). Measure time-resolved flux density at stated distances so picture-locked pulses show, and disclose it first for children's programs. Nothing routine asks whether program and display together make pulses in the lab and patent bands. A spectrogram or a heating calculation will not. Sort by frequency, field strength, modulation, pulse pattern, and duty cycle. Distance, daily hours, and years of viewing are what accumulate. SAR and power density miss the field.

Adey circle, excised brain, not a child watching television. In chick and cat cerebral tissue, a weak electric sine at 6 and 16 Hz cut calcium efflux about 12-15% in a narrow amplitude window; neighboring frequencies and amplitudes did not. A review put the ELF window near 6-20 Hz and about 10-100 V/m. Carriers at 147 and 450 MHz, amplitude-modulated at 6-20 Hz, raised chick-brain calcium efflux about 15% near 1 mW/cm2; unmodulated carriers did not. The low-frequency pattern was treated as active, too weak to heat tissue by a tenth of a degree. Bawin and Adey, PNAS 1976;73(6):1999-2003. Adey, Radio Science 1982;17(5S):149S-157S.

Rat hippocampal slices, 1 Hz sine: 56 and 560 uT rms destabilized intervals of rhythmic slow activity; 5.6 uT did not. The paper ties that rhythm to memory in the slice, not to mood or sleep stage. Bawin et al., Bioelectromagnetics 1996;17(5):388-395.

Loos patents claim weak stimuli at resonances near 1/2 Hz (relaxation, sleepiness, autonomic sensations) and near 2.4 Hz (slower counting, eyes closed). U.S. 6,506,148 B2 (Jan. 14, 2003) claims pulsed images on monitors and TV tubes emit weak fields that can excite them, embedded in a program or at an intensity the patent calls subliminal. Also U.S. 5,935,054 (1999), 6,091,994 (2000), and 6,238,333 B1 (2001). A patent is an inventor's claim, not a replication. No current standard tests that display path.
https://patents.google.com/patent/US6506148B2

Viewing studies do not isolate a field. JAMA Pediatrics 2024: early program viewing and poorer cognition, r = -0.16 (95% CI -0.24 to -0.08), PMID 39102255. JAMA Pediatrics 2019 (Adelantado-Renau et al.): TV viewing and composite academics, effect size -0.19 (95% CI -0.29 to -0.09), plus language and mathematics, PMID 31545344. Observational and multifactorial (content, sleep, household). They justify measuring the field that travels with the program. They do not prove an electromagnetic cause.

Disclosure for parents, schools, childcare, clinicians, and local governments: frequency content, pulse pattern, typical and peak flux density, and picture-lock, comparable across sets. An RF heating statement is not that. Children do not consent and cannot detect the field, and the associations above are in children and adolescents. An adult heating limit does not score a repeated childhood exposure.

Publish the triaxial time series at the seat for children's programs, including Teletubbies. Test 6,506,148-type pulsing and Adey-window fields on a pre-registered endpoint, and report a null if that is the result. Say whether equipment authorization already discloses the emission. FDA can require the measurement under 21 CFR subpart J; receivers are electronic products. NIH should separate content from the field. CDC needs a metric other than hours of screen time. Until the data exist, tell parents and schools that the set's field during these programs has not been characterized in these terms.