{"id":"HHS-OASH-2026-0397-6909","number":"6909","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 operating within the NOXTAK Corporation ecosystem; this comment represents the perspective of a research entity. The undersigned is also NOXTAK's founder and CTO, and NOXTAK develops a non-attenuating technology of the kind the framework proposed here would evaluate (Section 5).\n\nOur submission, Section 4 of EFEIA's six-part evidence dossier, examines the products and measures sold to reduce electromagnetic exposure: shielding materials, canopies and phone cases, plug-in filters, grounding products, \"harmonizers\" and wearables. No U.S. statute, regulation or consensus standard defines \"EMF protection\" or says how such claims must be tested, so buyers cannot tell tested products from untested ones. Shielding is rated on flat samples in laboratory fixtures, not in occupied homes, and it carries a paradox: a phone raises its uplink power as its link to the network weakens, so blocking a weak distant signal can raise the strongest exposure a person receives, from the phone at the head or on the pillow. The FCC and the FTC have both warned of this effect. Some \"negative ion\" pendants and wearables sold as protection emit ionizing radiation, as the Dutch nuclear regulator and the U.S. Nuclear Regulatory Commission have reported.\n\nWe urge HHS to lead, with NIST, the FTC, the FCC and the CPSC, a National Framework for the Evaluation and Regulation of Electromagnetic Protection Technologies. Every product sold as protection would be classed by the function it claims; tested for physical performance, for effects on its surroundings and on communications and, where a health benefit is claimed, in sham-controlled trials; and recognized only for what was verified. Shielding should be tested by what a person receives before and after installation, including from their own phone. We also ask HHS to fund an independent survey of marketed products in accredited laboratories with published data, to ask the NRC and the CPSC to screen \"negative ion\" wearables, and to issue consumer guidance that starts with distance and source control.\n\nThis section responds to questions 5(n), 5(o), 6, 8, 9, 13(a), 13(c), 13(d), 15(d), 16, 17 and 18. The attachments are the Section 4 summary and the exhibit that corresponds to it:\n\n- Section 4 summary: Shielding, Harmonizers and Consumer EMF Products: Protection Claims Without a Test Standard, and the Shielding Paradox (https://doi.org/10.5281/zenodo.23523493).\n- Exhibit 4A: National Framework for the Evaluation and Regulation of Electromagnetic Protection Technologies: Problem Analysis and Proposed Unified Evaluation Protocol (https://doi.org/10.5281/zenodo.23513472).\n\nPlease accept and consider all attached documents, the Section 4 summary and Exhibit 4A, 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-2026-0397-6909/attachment_1.pdf","https://downloads.regulations.gov/HHS-OASH-2026-0397-6909/attachment_2.pdf"],"attachment_inventory":true,"withheld":false,"source":"https://www.regulations.gov/comment/HHS-OASH-2026-0397-6909","tags":["policy-standards","research-evidence"],"source_hash":"7d58196722c9e06be7659f8772f8f6a14e75a8f4a2ac7e077db1ad150fd70061","slug":"policy-standards-comment-6909","classification":null,"forum_topics":["awaiting-review"],"primary_topic":"awaiting-review","forum_title":"On behalf of the EFEIA Institute (Electropollution-Free Environments International Accreditation Foundati…"}