HHS-OASH-2026-0397-6951
https://www.regulations.gov/comment/HHS-OASH-2026-0397-6951

Mitch Marchand, BSc. EE
EMF Aware (emfaware.com, emfaware.ca)
Response to HHS-OASH-2026-0397. Full document attached.
Questions addressed: 2, 4, 5n, 5o, 5p, 8, 9, 11 (a, g), 13 (c, e, g, k), 15, 16, 17

PERSPECTIVE (Q2): Service provider. More than 1,000 home EMF assessments since 2011 and involvement in 35+ low-EMF new builds, from tiny homes to $50M+ developments.
DISCLOSURE: I run EMF Aware, a consulting practice. Field observations are from my client work, not controlled studies.

SUMMARY
Much of the RF exposure in homes and schools comes from radios doing nothing useful. HHS can reduce it now, at near-zero cost, without new limits, bans or a causation ruling. [Opinion] FDA already has this duty under FD&C Act section 532(a)(5), which Q5o quotes. [Evidence]

KEY ASKS
1. Off-by-default and persistent-off: radios that are not needed ship OFF and stay OFF through updates and power cycles unless the user turns them on (FDA performance standard or guidance).
2. Wired + disable: stationary appliances/devices, including internet-provider modem/routers, offer a wired connection and a way to turn off all radios.
3. Nighttime protocol: free guidance for families. Phones fully off and away from the bed, and Wi-Fi off at night.
Also proposed: an "all radios off" mode on phones, and Ethernet calling for phones connected by wire.

WHAT THE ATTACHMENT CONTAINS
- Executive summary (one page)
- Why act now: the existing FDA mandate, the NTP study timeline, insurer risk reports
- Part 1, Existing homes: where home RF comes from, why radios stay on, and practical fixes
- Part 2, New buildings, institutions and schools: two cost tiers, the hardwire-first rule, school Wi-Fi settings
- Recommendations table: each action with its owner (FDA, FCC, ED, CDC, NIH, builders), RFI question, cost and evidence basis
- Disclosure, credentials and 23 numbered sources with links