HHS-OASH-2026-0397-6144
https://www.regulations.gov/comment/HHS-OASH-2026-0397-6144

Sivani Saravanamuttu, M.Phil., Ph.D.
Independent Researcher and Author; Founder of Project Plain Talk

I submit the following comments on the HHS RFI on Electromagnetic Fields, RF Radiation, and Wireless Radiation Exposure.

My perspective draws on my peer-reviewed 2013 review (Sivani & Sudarsanam, Biology and Medicine) previously filed as Exhibit 19 in FCC ET Docket 13-84, and my book - The Digital Pied Piper Effect (2018) - which treats RF-EMF health questions as a systems problem involving both biological responses and behavioural patterns that increase cumulative exposure, especially in children.

Key points (detailed in the attached PDF):
- Exposure and behaviour are entangled; studies should measure both and attempt to separate their effects.
- Priority needs include real-use dosimetry, longitudinal cohorts from early life and transparent evidence syntheses.
- Individual sensitivity (including EHS/IEI-EMF) requires better methods (e.g., proteomics approaches proposed by Leszczynski) rather than relying solely on self-report or short provocation studies.
- EHS recognition and prevalence data are concentrated in high-income countries; comparative data from other regions are lacking.
- Coordination across FDA, NIH, CDC and related agencies is needed, with attention to non-thermal mechanisms as hypotheses requiring further testing and to practical exposure-reduction options.

The full response, with citations and mapping to specific RFI questions, is attached as a PDF.