{"id":"HHS-OASH-2026-0397-6907","number":"6907","name":"","organization":"EFEIA Foundation","posted":"2026-10-28T04:00Z","received":"2026-10-21T04:00Z","body":"On behalf of the EFEIA Institute (Electropollution-Free Environments International Accreditation Foundation, Miami, Florida), I submit our organization's attached public comment and supporting scientific research in response to HHS Request for Information, Docket No. HHS-OASH-2026-0397. EFEIA is a nonprofit research and accreditation foundation; this comment represents the perspective of a research entity.\n\nRelationship disclosure. EFEIA operates within the NOXTAK Corporation ecosystem. NOXTAK develops and markets, as SPIRO, the passive nanocomposite presented in this section, and the undersigned is EFEIA's Director, NOXTAK's founder and CTO, and the named inventor on its patents. EFEIA presents the nanocomposite on the same terms it applies to every product in Section 4: what was tested, by whom, under what standard, with what result, and what remains to be done.\n\nOur submission, Section 5 of EFEIA's six-part evidence dossier, presents what ecosystems show about weak electromagnetic noise and a passive candidate solution. Migratory songbirds lose magnetic compass orientation under weak broadband radiofrequency noise in the nanotesla range, about 1,000 times weaker than current recommended limits as a BfS workshop review notes; honey bees show impaired learning and foraging under 50 Hz magnetic fields and reduced homing under Wi-Fi-band exposure. EFEIA has identified no federal exposure limit or monitoring program for animals, and an antenna or power line that meets the human limits has not been assessed for them. As a candidate solution that does not attenuate the signal, the section presents the SPIRO nanocomposite: in independent, accredited laboratories it produced up to 91% reduction in 10 g-averaged SAR across seven configurations, with antenna performance unchanged within uncertainty on three handsets, and a university-led, open, randomized, placebo-controlled trial recorded changes in heart rate variability. The evidence is organized in six tiers, with its limitations stated.\n\nWe urge HHS to include passive, non-shielding approaches in the research it asks about in question 5(o), with this nanocomposite as the first worked case: a paired SAR and antenna-performance test on current 4G and 5G devices in accredited laboratories, controlled trials in homes and workplaces, and a sham-controlled physiological trial, with the developer supplying units and taking no part in the analysis. We also urge HHS to treat effects on pollinators, migratory birds and livestock under question 14 through a field program led by NIEHS with the Department of the Interior, USDA and EPA, in which the nanocomposite is tested in its own arm and analyzed separately. EFEIA invites a technical discussion with HHS and its agencies on the underlying reports, measurement records and replication conditions.\n\nThis section responds to questions 3(f), 5(n), 5(o), 10(a), 10(c), 12, 13(a), 13(c), 14, 15(e), 16, 17 and 18. The attachments are the Section 5 summary and the exhibits that correspond to it:\n\n- Section 5 summary: Electromagnetic Noise in Living Systems: Evidence from Ecosystems and a Passive Candidate Solution (https://doi.org/10.5281/zenodo.23523495).\n- Integrated technical statement: Passive Nanocomposite Approach to Electromagnetic Risk Management: Integrated Statement of Technical Outcomes and Supporting Observations (https://doi.org/10.5281/zenodo.23513484), the author's own account, prepared for this submission.\n- Exhibits 5-1 to 5-5: the developer's technical documents, submitted unaltered, each behind an EFEIA cover sheet stating its source, evidence grade and the relationship: 5-1, description of the material; 5-2, electromagnetic compatibility and MIMO OTA tests; 5-3, the laboratory SAR summary; 5-4, field records at mobile-device scale; and 5-5, field records in residential and commercial spaces.\n\nPlease accept and consider all attached documents, the Section 5 summary, the integrated technical statement and Exhibits 5-1 to 5-5, as part of the public record.\n\nRespectfully,\nJ. Joaquín Machado\nEMR Researcher and Director of the EFEIA Institute","attachments":["https://downloads.regulations.gov/HHS-OASH-2026-0397-6907/attachment_2.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-6907/attachment_1.pdf"],"attachment_inventory":true,"withheld":false,"source":"https://www.regulations.gov/comment/HHS-OASH-2026-0397-6907","tags":["health-experiences","exposure-places","policy-standards","research-evidence"],"source_hash":"5af0e51fa0ea6ddb53894dd8f2e40e414c219bccbaea2dd2f4f77c66ec3ee82c","slug":"health-experiences-comment-6907","classification":null,"forum_topics":["awaiting-review"],"primary_topic":"awaiting-review","forum_title":"On behalf of the EFEIA Institute (Electropollution-Free Environments International Accreditation Foundati…"}