HHS-OASH-2026-0397-6904
https://www.regulations.gov/comment/HHS-OASH-2026-0397-6904

On behalf of the EFEIA Institute (Miami, Florida), I submit our organization's attached public comment and supporting scientific research in response to HHS Request for Information, Docket No. HHS-OASH-2026-0397. This comment represents the perspective of a research entity. The attached working paper, co-authored with Dr. Luis M. Valdés, physician and audiologist, is the fifth article in the EFEIA Research Institute's clinical and mechanistic series on tinnitus and electromagnetic fields. Disclosure: the undersigned is also founder and CTO of NOXTAK Corporation, and the school measurements reported in the paper were carried out by the authors' team under the IGEF and the NOXTAK Electromagnetic Research Center.

The paper connects three conditions that share one clinical picture: Havana syndrome (anomalous health incidents, AHI), catastrophic tinnitus and extreme electromagnetic hypersensitivity. All three present with an abrupt intracranial sound or pressure, intense tinnitus, vertigo, headache, and cognitive, sleep and mood disturbance. The National Academies (2020) identified directed, pulsed radiofrequency energy as the most plausible mechanism for the acute phase of AHI, and the microwave auditory (Frey) effect provides an established physical bridge by which pulsed radiofrequency energy is perceived as intracranial sound. Building on this, the authors propose a model of cumulative load plus a triggering peak acting on a susceptible phenotype: the acute episode is the visible outcome of a silent accumulation, and greater stimulation shortens and precipitates critical episodes. This opens a direct civilian line of inquiry, since sudden-onset cases in the general population may follow the same mechanism.

The exposures that could act as triggering peaks are already present and measurable in public space. At Downtown Doral Charter Upper School in 2022, the authors recorded peaks of 200 V/m of ELF electric field and 31 mG of magnetic flux on the sidewalks where children walk and wait, with the highest values between 9:30 and 11:30 a.m., when children were present. Their field work records values on the order of hundreds of V/m and more than 100 mG under high-voltage lines, next to substations and in electrical rooms adjoining bedrooms in universities, hotels and resorts. Across more than 1,000 EHS cases, the authors have observed that higher levels of stimulation shorten and precipitate critical episodes. Characterizing the patient's electromagnetic environment is therefore a practical step to add to the evaluation of sudden-onset tinnitus and new-onset EHS, consistent with the EUROPAEM guideline, which makes exposure reduction the primary measure for EMF-related illness.

We urge HHS to support the five lines of research the paper proposes: a structured clinical comparison of symptoms, audiology, neuroimaging and autonomic biomarkers across AHI, catastrophic tinnitus and extreme EHS cohorts, to test the shared phenotype; systematic urban dosimetry of ELF electric, ELF magnetic and radiofrequency fields in parks, bus stops, school zones and around substations and high-voltage lines, with public exposure maps; screening for the susceptible phenotype (genetic polymorphisms, oxidative load, autonomic profile) in patients with sudden-onset tinnitus or abrupt-onset conditions without a conventional cause; modeling of the trigger threshold between cumulative load, peak magnitude and the probability and latency of a critical episode; and protocols for characterizing the patient's electromagnetic environment as part of the differential evaluation of sudden-onset tinnitus and new-onset EHS. The urban dosimetry line can be carried out within the national monitoring pilot proposed in Section 2 of EFEIA's dossier. As the authors conclude, measuring the electromagnetic load of public spaces and of the patient's environment, and recognizing the susceptible phenotype, can turn an unexplained presentation into a testable hypothesis and, above all, into a preventable exposure.

This comment responds to questions 4(h) to 4(m), 5(p), 8, 10(c), 11(a), 11(f), 11(g), 12, 15(a) and 16. The attachment is:

- Valdés, L. M., and Machado, J. J. From Havana Syndrome to Catastrophic Tinnitus and Extreme Electromagnetic Hypersensitivity: Cumulative Load, Triggering Peaks, and the Susceptible Phenotype. Why Sudden Onset Does Not Rule Out a Common Electromagnetic Mechanism. Working paper, EFEIA Research Institute, 2026 (https://doi.org/10.5281/zenodo.23522254).

Please accept and consider the attached document as part of the public record.

Respectfully,
J. Joaquín Machado
EMR Researcher and Director of the EFEIA Institute