HHS-OASH-2026-0397-6569
https://www.regulations.gov/comment/HHS-OASH-2026-0397-6569

Research shows that EHS affects up to 5% or more of the population, with approximately 0.65% experiencing such severe symptoms that participation in everyday social life becomes impossible. 
Despite the significant impact on those affected, adequate support, healthcare, and protection remain lacking. This is partly due to ongoing uncertainty among authorities regarding the causal relationship between exposure to electromagnetic fields (EMFs) and reported health effects. However, there is sufficient scientific evidence that NIR have non-thermal biological effects 

Exposure Standards and Risk Assessment
Current exposure limits are designed to prevent excessive heating. However, people report experiencing effects from EMFs at exposure levels well below the official limits.
Current official standards consider only the frequencies and intensity of NIR. Knowledge of the effects of specific EMF characteristics, such as modulation, and of long-term exposure is limited, and these factors are not taken into account. Yet they do matter. Many scientific studies do not clearly describe the characteristics of the EMFs used.
Based on many years of experience, building biologists have drawn up practical guidelines When people with EHS adhere to these guidelines by avoiding and shielding themselves from sources of EMF, their symptoms disappear or are alleviated.
The European Academy of Environmental Medicine (EUROPAEM) has also developed guidelines on EMFs based on scientific findings. EUROPAEM aims to provide preventive measures and protective strategies against the potential health risks of electromagnetic fields. 
We also would like to refer to the contribution uploaded by Else Nordhagen PhD on this subject:  ‘Quality criteria for RF/EMF Health-Risk Assessments’. As attached

Measuring Human Exposure and Public Health Surveillance
Technical and exposure-related information should be disclosed, including the peak values. As the official standards presume only the heating of tissue and the mean values of NIR has importance, peak values are ignored, while many studies precisely clarify the great importance of these peak values and long-term exposure.
Radiation levels vary constantly, especially when beamforming techniques, as used in 5G, are applied. These variations are so wide-ranging that measurement techniques need to be adapted.
Exposure information is also needed to protect vulnerable people in public spaces, such as hospitals, medical facilities, nursing homes, daycare centers, and schools.

Existing Evidence
Much research has been done to establish the effects of NIR. Many scientists found adverse effects and several scientific appeals have been done in vain to the authorities to take this into account before applying new generations of wireless technologies.   
Many well-conducted scientific studies show adverse health effects, while others do not. See the uploaded files including Central and Eastern Europeanstudies, showing two fundamentally different approaches. When focussing on just studies using real life exposure, the results are convincing. However, in studies using sources with undefined characteristics or model of exposure, the results vary widely. Recognising the importance of applying real-life exposure with the true characteristics in this research might resolve the difference in opinion about the risks caused by NIR. This difference may also lead to the design of EMFs limiting or even without health consequences.
In 2007 the Bio Initiative Report already mentions the importance of modulation for the biological impact of EMFs. Scientific studies mention the importance for biological effects of extreme and ultra-low-frequency components of EMFs.
The official institutions responsible for assessing the health risks of NIR also regularly state that, if harmful effects occur, the mechanisms by which NIR affects organisms are unknown. Yet multiple replicated studies have found that NIR causes oxidative stress, which is considered in science to be a cause of many diseases.

Federal Research Priorities
Additional Information
ALARA principle by design. The technical system should be designed to minimise the radiation levels, not to maximise the reach. Wireless applications should be minimised and preference should be given to wired solutions. 

Europeans for Safe Connections was founded in 2023 in response to inadequate protection against NIR (non-ionizing radiation) and the growing number of people suffering from electromagnetic hypersensitivity (EHS). ESC is an umbrella organisation in Europe representing national organisations and individuals aware of the health risks of EMFs