HHS-OASH-2026-0397-6992
https://www.regulations.gov/comment/HHS-OASH-2026-0397-6992

While it is important for HHS and other federal agencies to re-examine exposure guidelines and assessment methods for what the general public thinks of when it comes to RF and wireless radiation exposure - cell phones/towers, WiFi, smart meters, etc - we believe there is a more critical issue to examine. Kilohertz frequencies in the range of 2-150 kHz, commonly known as dirty electricity and dubbed supraharmonics by IEEE, are a ubiquitous pollutant on our nation's electrical grid. These frequencies are generated by modern electronic devices (non-linear loads) and superimposed on the nominal 60 Hz electrical waveform supplying our homes, businesses, schools, and government buildings with electricity. In about 2013, IEEE recognized this range of frequencies as supraharmonics, noting their deleterious effects on utility and consumer equipment and devices. Long before this - going back to at least the 1890s - scientists and government agencies had studied the biological effects of these and other frequencies. The scientific literature is not lacking in findings of physiological harm caused by exposure to electrical signals, whether conducted, transmitted, or radiated, and at levels far lower than the out-of-date exposure standards in place in the US. For example, Specific Absorption Rate (SAR) for transmitted RF only accounts for the amount of energy it takes to heat human cells, completely ignoring other physiological responses that may (and do) occur at comparatively miniscule exposures. Setting more reasonable and more cautious exposure standards, especially for kilohertz frequencies in the 2-150 kHz range, is paramount to the health of our nation's citizens. A reasonable approach to limiting conducted kilohertz frequencies is enforcing strict standards on electrical and electronic device manufacturers. Simple, cheap harmonic filtration circuits built into any device internally generating kilohertz frequencies should be employed to prevent such frequencies from exiting the device whereby they propagate on electrical wiring in homes and other buildings, as well as the utility electrical grid at large. The proliferation of non-linear loads should have been accompanied by stiffening of utility neutral conductors on the US electrical grid. This was never done by most utilities, and never broadly adopted as standard practice, despite studies showing its effectiveness at eliminating numerous issues on utility systems. The information HHS is requesting herein has a much broader scope than it may anticipate. We offer our services to HHS and other federal agencies should they find further information is required as this investigation moves forward. Please feel free to contact us. See attached files.