HHS-OASH-2026-0397-0729 https://www.regulations.gov/comment/HHS-OASH-2026-0397-0729 Personal statement & Case testimony: Smart meters present a direct hazard to human health. My health was drastically impacted after our utility installed digital smart meters across our block. The day after activation, I experienced severe acute symptoms: * Neurological & Peripheral Distress: I instantly developed cognitive side effects and an aggressive attack on my peripheral nervous system. Within 48 hours, emissions coming from the walls caused such severe disruption that I came close to leg paralysis. * Severe Insomnia: I can no longer sleep in my bedroom. The continuous fields create a sensation like my brain is being 'zapped' and kept awake, resulting in debilitating insomnia. * Whole-House Wiring Radiation: Research and professionals confirmed that the Switch-Mode Power Supply (SMPS) inside these meters injects high-frequency 'dirty electricity' directly onto building power lines. The electrical wiring throughout our house—and electronics plugged into it—now re-radiate harmful fields into living spaces. * Inadequacy of Mitigation: Mitigating this required major changes to living arrangements and expensive filters, which lessen the pollution but cannot eliminate it entirely. EXECUTIVE SUMMARY: Federal guidelines rely on thermal heating limits (ICNIRP) and wireless RF, failing to regulate conducted voltage noise ("dirty electricity") from internal SMPS in digital meters. Testing shows digital/smart meters generate up to 35 times higher conducted noise on household wiring than legacy analogue meters, turning building wiring into an antenna that induces non-thermal biological stress, neurological disruption, and sleep degradation. Federal agencies must close regulatory loopholes, recognize non-thermal biological thresholds, and enact a complete federal ban on all digital and smart electricity meters, mandating a return to passive electro-mechanical analogue metering. TECHNICAL EVIDENCE: CONDUCTED EMISSIONS 35-Fold Noise Increase: Testing of 23 meter models by EMF Consult AS showed modern smart meters (AMS) produce noise levels of 49 dBµV vs ~18 dBµV in older analogue meters—a 31 dBµV (~35-fold) increase in conducted noise on household wiring. Root Cause (SMPS): Analogue meters contain no power electronics, producing zero conducted pollution. Digital/smart meters use active SMPS that chop AC voltage, bleeding high-energy transients onto power lines. Constructive Interference: Multiple digital/smart meters on the same transformer create constructive interference, compounding noise across neighborhoods. BIOLOGICAL MECHANISMS & SCIENTIFIC RESEARCH VGCCs & Oxidative Stress: Transients alter cellular function below thermal thresholds by opening voltage-gated calcium channels (VGCCs), causing overproduction of reactive oxygen species (ROS) and oxidative stress. Piezoelectric Inner Ear Stimulation: The inner ear's tectorial membrane and otoconia convert ultrasonic oscillations into mechanical micro-vibrations, triggering tinnitus, head pressure, and brain hyperexcitability. Stress Biomarkers (Milham & Stetzer 2013): Filtering dirty electricity resulted in significant normalization of urinary dopamine and phenylethylamine levels. Metabolic Disruption (Havas 2006, 2008; Milham 2014): Studies show dirty electricity elevates blood glucose in sensitive individuals ("Type 3 diabetes") and correlates historically with diabetes/obesity epidemics. School Field Trials (Havas & Olstad 2008): Filtering power-line noise by >90% produced significant health improvements in 64% of teachers and improved student focus/behavior. Remission via Analogue Reversion: Court rulings (Oslo Appeal Court, French Linky decision) confirm replacing digital/smart meters with electro-mechanical analogue meters results in rapid symptom remission. CRITICAL REGULATORY GAPS Unregulated 10–150 kHz "Grey Zone": CISPR 32 / EN 55032 standards only measure conducted emissions from 150 kHz to 30 MHz, leaving 10–150 kHz—where SMPS transients concentrate—completely unregulated. Thermal-Only Paradigm: Guidelines fail to account for non-thermal biological signaling or conducted power-line noise. The only biologically safe standard is passive analogue metering. RECOMMENDATIONS FOR FEDERAL ACTION Complete Ban on All Smart Digital Meters: Enact a federal ban on all digital/smart electricity meters (including filtered models), mandating a return to electro-mechanical analogue meters. Free Analogue Reinstallation: Require utilities to reinstall traditional analogue meters free of charge upon request. Close 10–150 kHz Loophole: Expand EMC standards to mandate strict limits down to 10 kHz. Adopt Non-Thermal Thresholds: Update exposure standards to protect against VGCC activation, ROS-induced stress, and electro-hypersensitivity.