{"id":"HHS-OASH-2026-0397-6312","number":"6312","name":"","organization":"EFEIA Foundation","posted":"2026-10-28T04:00Z","received":"2026-10-21T04:00Z","body":"On behalf of the EFEIA Institute (Miami, Florida), I submit our organization's attached public comment, evidence summary and supporting proposal in response to HHS Request for Information, Docket No. HHS-OASH-2026-0397. This comment represents the perspective of a research entity. The attachments are an evidence summary and a national plan proposal, both prepared by EFEIA in October 2026. Disclosure: the undersigned is also founder and CTO of NOXTAK Corporation, which develops SPIRO electromagnetic-hygiene products; one source both documents cite evaluates SPIRO in two vehicles, and the 180 cases they describe were received by NOXTAK.\n\nA modern vehicle places traction batteries and power electronics alongside cellular modems, onboard hotspots, Wi-Fi, Bluetooth, ultra-wideband access systems, V2X equipment and radar, including interior radar in the 57 to 64 GHz band for child presence detection and road radar at 76 to 81 GHz, in a small occupied cabin used for repeated daily journeys by children, pregnant women, older adults, professional drivers and people with implanted devices. U.S. drivers spend about an hour a day at the wheel. National campaigns in Germany and Switzerland found low average fields with brief magnetic-field peaks, highest at the feet; in the German federal campaign, the reference values of the 1999 EU Council Recommendation were exceeded locally or briefly in all vehicles but one, while basic restrictions were never exceeded. Existing methods cover parts of this picture: IEC 62764-1 measures low-frequency magnetic fields from 1 Hz to 100 kHz and excludes intentionally transmitting antennas, UN Regulation No. 10 addresses electromagnetic compatibility, and FCC rules address RF exposure from mobile and portable devices and provide for multiple sources. No method yet connects the full installed source inventory, the occupied cabin, and the fields and absorbed energy in each occupant. The 2023 study funded by the Swiss Federal Office of Energy acknowledged temporal and spatial gaps that could have missed short events or the highest field values, and EFEIA's own study of two Tesla Model Y vehicles used instruments limited to frequencies below 6 GHz, which cannot capture 60 GHz or 76 to 81 GHz systems. NOXTAK has received 180 cases of people who attribute symptoms to electric vehicle use and sought help; both documents treat this as an author-reported case count, not a prevalence estimate, and propose a registry and clinical pathway to examine it.\n\nWe urge HHS to support a coordinated 24-month national program with independent laboratory participation and an independent scientific steering process: a reproducible whole-cabin measurement protocol covering every installed band; a version-controlled library of real driving, charging and connectivity scenarios; a validated occupant dosimetry atlas with child, pregnant and adult anatomical models; a consented symptom registry and staged clinical research below established thermal thresholds; a technology-neutral method for evaluating mitigation claims; and recommendations for a whole-vehicle evidence requirement with change control and a complaint reporting channel. HHS and its research agencies would guide the health evidence, with DOT and NHTSA on vehicle integration and transportation safety, the FCC on RF equipment and exposure requirements, and NIST, universities and independent laboratories on measurement traceability.\n\nThis comment responds to questions 4(k), 4(l), 4(m), 5(n), 5(o), 5(p), 7, 8, 9, 10(a), 10(f), 11(a) to 11(f), 12, 13(i), 16, 17 and 18. The attachments are the Additional 4 summary and the national plan that corresponds to it:\n\n  - Additional 4 summary: Modern Vehicles as Occupied Electromagnetic Environments: Measuring What Reaches the Person in the Seat (https://doi.org/10.5281/zenodo.23541753).\n  - Additional 4, National Plan: National Plan for Electromagnetic Biocompatibility in Modern Vehicles: A proposal for whole-vehicle exposure assessment, occupant dosimetry and regulatory development (https://doi.org/10.5281/zenodo.23541733).\n\nPlease accept and consider all attached documents, the Additional 4 summary and the National Plan, as part of the public record.\n\nRespectfully,\n\nJ. Joaquín Machado\n\nEMR Researcher and Director of the EFEIA Institute","attachments":["https://downloads.regulations.gov/HHS-OASH-2026-0397-6312/attachment_2.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-6312/attachment_1.pdf"],"attachment_inventory":true,"withheld":false,"source":"https://www.regulations.gov/comment/HHS-OASH-2026-0397-6312","tags":["child-development","health-experiences","exposure-places","policy-standards","research-evidence"],"source_hash":"e0292b965dba69878958923c5954bc632048e2548c54f2d8f4bd7303f71649dc","slug":"child-development-comment-6312","classification":{"id":"HHS-OASH-2026-0397-6312","body_sha256":"a5747f12c7ef916edb3296e29dc50af1dd5152651938594c30d3ba094c623efd","status":"ai_reviewed","primary_topic":"research","topics":[{"id":"research","evidence":"ne it.\n\nWe urge HHS to support a coordinated 24-month national program with independent laboratory participation and an independent sci"},{"id":"electricity","evidence":"received by NOXTAK.\n\nA modern vehicle places traction batteries and power electronics alongside cellular modems, onboard hotspot"},{"id":"standards","evidence":"mitigation claims; and recommendations for a whole-vehicle evidence requirement with change control and a complaint reporting channel. HHS and i"},{"id":"children","evidence":"s; a validated occupant dosimetry atlas with child, pregnant and adult anatomical models; a consented symptom registry and staged clini"},{"id":"reproductive","evidence":"sed for repeated daily journeys by children, pregnant women, older adults, professional drivers and people with implan"},{"id":"occupational","evidence":"s by children, pregnant women, older adults, professional drivers and people with implanted devices. U.S. drivers spend about an h"}],"summary":"EFEIA proposes independent whole-vehicle measurement, occupant dosimetry, clinical research and reporting, identifies limitations in current methods and case counts, and discloses related product interests.","reviewed_at":"2026-10-28T23:54:32Z","review_method":"Full comment-text review with exact source evidence; attachments not reviewed","review_source_sha256":"af3985a0ba31070d9e9e116d97c25e9923d47893cd4d1690059ea9408b68709e","source_url":"https://rfsafe.net/hhs-comments/data/catalog.json","scope":"Original comment body; attachments excluded"},"forum_topics":["research","electricity","standards","children","reproductive","occupational"],"primary_topic":"research","forum_title":"EFEIA proposes independent whole-vehicle measurement, occupant dosimetry, clinical research and reporting…"}