{"id":"HHS-OASH-2026-0397-6307","number":"6307","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, national program proposal and letters 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 a proposal prepared by EFEIA in October 2026, my request letter, made together with Dr. Robert Marshall Leal Lue, PhD in clinical psychology, Dr. Pilar Muñoz-Calero and other specialists, and letters from Dr. Pilar Muñoz-Calero, MD, President of Fundación Alborada (Madrid), and Dr. Luis M. Valdés, physician and audiologist. Disclosure: the undersigned is also founder and CTO of NOXTAK Corporation, which develops electromagnetic hygiene products; the 2014-2018 patient cohort described in the proposal evaluated a NOXTAK product among concurrent interventions. The proposal evaluates no product.\n\nWHO recognizes the symptoms of electromagnetic hypersensitivity (EHS, IEI-EMF) as real and potentially disabling, and systematic reviews of blind provocation studies have found no robust evidence that exposure triggers them. We accept that record. Those studies, however, tested a narrower question than the conclusion often drawn from them: most measured conscious detection of a field, or symptoms reported during or soon after short laboratory exposures. A systematic review of 28 provocation studies found selection bias in 82% of them and, in 57%, exposure and assessment times that were not matched to each participant's reported symptom latency. In our clinical experience, from a four-year cohort of 357 patients and more than 1,500 cases reviewed through EFEIA's consultant network, EHS presents as a sensitized and partly conditioned stress response. Short blinded tests with perception as the endpoint cannot separate the environmental trigger, the physiological sensitization and the learned response, and a reaction to an inactive cue does not show that the original trigger was inert. Tinnitus, reported by 50.7% of EHS respondents against 17.5% of controls in a German case-control study, is not yet a defined outcome in this research.\n\nWe urge HHS to convene an independent, publicly funded review of the criteria used to design and interpret EHS studies, and to support a 24-month program that publishes revised criteria, including stratification of participants by conditioned response and physiological sensitization, personalized and prolonged exposures, delayed-response windows, characterized sham conditions and objective physiological endpoints; a blinded multi-site replication of the biomarkers reported to date; tinnitus and sound intolerance as defined outcomes; a clinical pathway of differential assessment before attribution, with professional training; a consented registry with measured exposure; and proportionate precaution in hospitals, schools and care settings. OASH would convene the program; NIEHS would lead exposure assessment and biomarker replication, NIDCD the tinnitus outcome set, CDC case definition, registry methods and clinical guidance with NIEHS, and FDA's Center for Devices and Radiological Health exposure systems and dosimetry for provocation studies.\n\nThis comment responds to questions 4(h) to 4(j), 4(l), 4(m), 5(o), 10(a), 10(d) to 10(f), 11(f), 11(g), 16, 17(a) to 17(c) and 18. The attachments are:\n\n- Additional 5, National Program: National Program for the Review of Research Criteria in Electromagnetic Hypersensitivity: A proposal to revise how studies of electromagnetic hypersensitivity are designed and interpreted, with objective endpoints, a clinical pathway and tinnitus as a defined outcome (https://doi.org/10.5281/zenodo.23545803).\n- Request letter from J. Joaquín Machado, 21 October 2026.\n- Letter from Dr. Pilar Muñoz-Calero, MD, President, Fundación Alborada, 8 October 2026.\n- Letter from Dr. Luis M. Valdés on electromagnetic hypersensitivity and the amplification of tinnitus, 21 October 2026.\n\nPlease accept and consider all attached documents, the Additional 5 proposal and the three letters, 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-2026-0397-6307/attachment_1.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-6307/attachment_3.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-6307/attachment_2.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-6307/attachment_4.pdf"],"attachment_inventory":true,"withheld":false,"source":"https://www.regulations.gov/comment/HHS-OASH-2026-0397-6307","tags":["health-experiences","exposure-places","research-evidence"],"source_hash":"c3d6b6eace2381ede74ef26738996a93ced421a9352e0a2bcd8e5e5a139098fa","slug":"health-experiences-comment-6307","classification":{"id":"HHS-OASH-2026-0397-6307","body_sha256":"50a57a47d96ec6f644c8506b134b4fc07444af0859435c49dc2235b84b396de3","status":"ai_reviewed","primary_topic":"ehs","topics":[{"id":"ehs","evidence":" no product.\n\nWHO recognizes the symptoms of electromagnetic hypersensitivity (EHS, IEI-EMF) as real and potentially disabling, and systematic"},{"id":"research","evidence":" and interpret EHS studies, and to support a 24-month program that publishes revised criteria, including stratification of par"},{"id":"neurological","evidence":"lication of the biomarkers reported to date; tinnitus and sound intolerance as defined outcomes; a clinical pathway of"},{"id":"mechanisms","evidence":"ork, EHS presents as a sensitized and partly conditioned stress response. Short blinded tests with perception as the endpoint cannot sepa"}],"summary":"EFEIA proposes an independently funded program revising EHS study methods, biomarker replication, tinnitus outcomes, clinical pathways and a registry, acknowledges findings from provocation reviews and discloses product-development interests.","reviewed_at":"2026-10-28T23:54:32Z","review_method":"Full comment-text review with exact source evidence; attachments not reviewed","review_source_sha256":"62599dced1a87554f18ea2ccc6acdf4bb1ddd82b8258c2bc43574a9d08611717","source_url":"https://rfsafe.net/hhs-comments/data/catalog.json","scope":"Original comment body; attachments excluded"},"forum_topics":["ehs","research","neurological","mechanisms"],"primary_topic":"ehs","forum_title":"EFEIA proposes an independently funded program revising EHS study methods, biomarker replication, tinnitu…"}