EMFIS welcomes the opportunity to respond to the U.S. Department of Health and Human Services’ Request fo…

EMFIS welcomes the opportunity to respond to the U.S. Department of Health and Human Services’ Request for Information concerning high-frequency and electromagnetic-field exposure and human health. Our full response in the attached PDF. In particular, EMFIS recommends that federal health agencies consider indoor exposure benchmarks that integrate the research, guidance, and regulatory approaches of the national and international authorities discussed above with practical experience from on-site measurements in occupied buildings. EMFIS was established because no comprehensive framework then existed that combined protective, measurable, and practically achievable exposure limits specifically for indoor environments. The EMFIS exposure limits were developed through this combined approach: reviewing established scientific and technical frameworks, such as Baubiologie SBM 2015 and EuropaEM, evaluating field-measurement data, and focusing on values that can be distinguished reliably from the measurement system’s noise threshold. This approach supports protective targets that are technically measurable and realistically implementable in places where people spend meaningful periods of time, including homes, schools, workplaces, healthcare facilities, and hospitality settings. In EMFIS’s view, this building-centered approach can improve federal assessment and disclosure by supplementing source-specific compliance limits with transparent measurements of actual indoor conditions. Such assessments should document relevant frequencies, typical and peak levels, source locations, operating conditions, measurement methods, instrument sensitivity, the applicable noise threshold, uncertainty, and the cumulative contribution of multiple sources. Regulatory frameworks should also encourage practical exposure reduction through source management, distance, wired alternatives, system optimization, shielding where appropriate, and post-intervention verification. EMFIS believes that its exposure limits provide the most suitable framework for indoor environments because they combine precautionary protection, technical measurability, and practical feasibility. This position should be evaluated through independent comparison, transparent validation, and continued research. We therefore encourage federal agencies to examine the EMFIS limits and assessment methodology as a potential model for voluntary indoor guidance, building-level disclosure, standardized measurement protocols, and future research.