# Presentation: 703410

## Suggested Update to RF Standards Related to Wireless Communications

- Bob Curtis
- April 10, 2001

## What is Needed?Site-Specific RF Program

- Work site Safety and Health Programs should include an RF Program if significant exposures are possible.
- A priority, because S&H Programs can be very effective in preventing excessive exposures.

## Basic Requirements

- Implement an RF program where exposures exceed FCC “General Population” or Public limits (see following slides).
- The RF Program must ensure employee exposure does not exceed FCC “Occupational” limits.

## Slide 4

## Slide 5

## Extent of RF Program is Based on Exposure

- Locations are Categorized (I-V) based on potential exposures.
- Many RF exposure situations require no, or a limited RF Safety Program. (Categories I-II)
- More extensive program elements for higher exposure categories.

## Category I Areas

- Locations where RF fields are too weak to cause exposures greater than the FCC general population (public) limits.
- No dependence on controls, including time averaging.
- NO RF SAFETY PROGRAM NEEDED!!

## Category II Areas

- Potential exposures are controlled to ensure compliance with FCC Public limits.
- Must maintain controls, such as time averaging and shielding, to remain below public limits.

## Category III Areas

- Locations where RF fields are too weak to cause exposures greater than the FCC Occupational limits.
- No dependence on controls, including time averaging.

## Category IV Areas

- Potential exposures are controlled to ensure compliance with FCC Occupational limits.
- Must maintain controls, such as time averaging and shielding, to remain below Occupational limits.

## Category V Areas

- Exposure conditions which can not be controlled to comply with FCC Occupational limits.
- Includes surfaces which will cause serious RF burns if contacted.

## Summary Tables of Program Elements Needed for Each Exposure Category

## Administrative

| Policy | NN | Yes | Yes | Yes | Yes |
| --- | --- | --- | --- | --- | --- |
| Accountable Person | NN | Yes | Yes | Yes | Yes |
| Documentation | NN | Yes, for incidents | Yes | Yes | Yes |
| Employee Involvement | NN | No | Opt. | Yes | Yes |
| RF Safety Committee | NN | No | Opt. | Opt. | Opt. |
| Procurement of RF Source Equipment | NN | Yes | Yes | Yes | Yes |

**                   **I        II        III    IV     V

## Identification of Potential Hazards

| Inventory of RF Sources | NN | Yes | Yes | Yes | Yes |
| --- | --- | --- | --- | --- | --- |
| Exposure Assessment | NN | Initial, + after change | Initial, + after change | Yes | Yes |

**                  **I        II         III       IV      V

## Controls/Engineering

| Utilize low exposure Equip. & Site Configuration  | NN | Yes | Yes | Yes | Yes |
| --- | --- | --- | --- | --- | --- |
| Access Restriction | NN | Opt. | Opt. | Opt. | Yes |
| Maintenance of Controls | NN | Yes | Yes
 | Yes
 | Yes
 |

-                        I       II      III      IV     V

## Controls/Administrative

| Use of Signs | NN | Yes | Yes | Yes
 | Yes
 |
| --- | --- | --- | --- | --- | --- |
| Access Restriction | NN | Opt. | NN | Opt. | Yes
 |
| Work Practices | NN | No | Opt. | Opt. | Opt. |
| Control of Source Power (LOTO) | NN | No | No | Opt. | Opt. |

-   I        II       III      IV       V

## Controls/Administrative (cont.)

| Personal Monitors | NN | No | Opt. | Opt. | No |
| --- | --- | --- | --- | --- | --- |
| Incident Response | NN | Yes | Yes | Yes | Yes |
| Medical Devices & Implants | Personal Respon-sibilty | Personal Respon-sibility | Yes, make aware | Yes | Yes |
| Maintenance of Controls | NN | Yes for Public | NN for work.
 | Yes
 | Yes
 |

-                     I            II         III      IV     V

## Personal Protective Equipment

| Selection of PPE | NN | No | No | Opt.  | When used |
| --- | --- | --- | --- | --- | --- |
| Maintenance, Use, & Accessibility  | NN | No  | No | When used | When used |

-                      I      II      III       IV       V

## Training

| Explanation for RF Exposure Limits  | NN | NN | Yes | Yes
 | Yes
 |
| --- | --- | --- | --- | --- | --- |
| Use & Maintenance of Controls | NN  | Yes, for RFSO | Yes
 | Yes
 | Yes
 |
| Recognizing Abnormal Conditions | NN | Yes, for RFSO | Yes
 | Yes
 | Yes
 |
| Sources of Additional Information | NN | Yes, for RFSO | Yes
 | Yes
 | Yes
 |

-  I       II       III       IV     V

## Program Review

| Adequacy of Present Program Design | NN | Yes | Yes
 | Yes
 | Yes
 |
| --- | --- | --- | --- | --- | --- |
| Implementation (Program in use?)  | NN | Yes
 | Yes
 | Yes
 | Yes
 |

- I      II     III     IV     V

## Examples of the RF Safety Program Elements

## Core Program Elements

- Administrative
- Identification of Potential Hazards
- Controls
- Engineering
- Administrative
- Personal Protective Equipment
- Training
- Program Review

## Administrative

-  Policy
- Management Commitment
- Authority to enforce rules
-  Accountable Persons
- Assignment of Duties
-  Documentation
-  Employee Involvement
-  RF Safety Committee
-  Procurement of RF Source Equipment

## Identification of Potential Hazards 

- Inventory of RF Sources
- Exposure Assessment
-  To establish exposure categories.
- To ensure controls are functioning.

## Hazard Assessment Options

- Direct Measurement
- Indirect “Measurement” by comparing to similar sites.
- Model calculations

## Direct Measurement

## PPE and Direct Measurement

## Assess by

- modeling.

## Assess by 

- comparison.
- For example,
- cellulars
- are well
- characterized.
- (See examples
- at end)

## Controls/Engineering

- Utilize low exposure equipment & site configuration
- Use good equipment
- Control hazard areas
- Limit exposures
- Access Restriction
- Maintenance of Controls

## Controls/Administrative

-   Use of Signs
-   Access Restriction
-   Work Practices
-   Control of Power Source (LOTO)
-   Personal Monitors
-   Incident Response
-   Medical Devices and Implants
-   Maintenance of Controls

## Slides of Example Controls

- Lockout/Tag out
- Personal alarm
- Prevent access to hazardous locations (Signs & Fences)
- Administrative control program
- Protective clothing

## Lock Out / Tag Out

## Lock Out / Tag Out Offers Protection for Workers on Tower

## Personal Alarm

## Cooperative RF Program for Shared Tower

## Cooperative RF Program for Multiple Broadcasters

## Fence to Limit Access

## RF Protective Suits

## PPE Must Be Tested for Application

## PPE Must Be Inspected & Maintained

## Example Application of Signs Based on Exposure Category

## Sign at entrance to next exposure Category.

## Notice for Public required by FCC. 

- Sign posted at boundary between Category I & II.

## Optional 

- Notice of Worker-based RF Control Program.
- Posted at access points into Category III.

## Caution workers to use Controls

- Posted at access points into Category IV locations.

## Alert to objects which may cause RF shock if contacted without PPE.

## Alert to objects which will cause RF Burns if contacted without PPE

## Posted to mark prohibited access into Category V without power-down or PPE.

- Note: Wrong symbol.

## Posted to mark prohibited access without power-down. 

- PPE is not sufficient.

## Alert to objects which will cause severe RF Burns if contacted.

- PPE may not be sufficient.

## RF Personal Protective Equipment

-   If PPE is utilized, a PPE Program must ensure its effectiveness, including proper:
-   Selection of RF PPE within tested capabilities.
-  Accessibility, Use, & Maintenance.

## Training:  What to Teach

- Location of sources and potentially hazardous areas.
- Health effects and safety standards.
- Extent of exposures compared to standards and common sources.
- Required SOP’s and controls.
- Emergency procedures.
- How to know when things are “abnormal”.
- Optional controls employees may use.

## Program Review

- Adequacy of Program Design
- Program Implementation
- Interview employees
- What are the hazards and controls?
- What steps have been taken to enforce the rules?
- Determine what to change, add, and delete.

## Possible Non-Mandatory Appendices

- Example RF Safety Program for a communications company which routinely services/installs antennas on rooftops.
- Appendices concerning PPE and signage

## Example Applications

## Category I Locations

- Most people, including workers, are in Category I locations.
- Therefore, most locations do not need an RF Safety Program.

## Receiving Antenna or Dish

## Anti-Theft Device

## Computer Work Station

## Wireless Local AreaNetwork

- Wireless Local AreaNetwork

## Inside Office Building

## RF Exposure Location with Multiple Categories(2 slides)

## Slide 64

## Exposure Locations

## Cell Tower

## ,

## Slide 68

## Slide 69

## Slide 70

## Miscellaneous Slides

## Draft Host Employer’s Responsibilities

- Provide information about hazards, controls, safety and health rules, and emergency procedures to all employers at the workplace
- Ensure that safety and health responsibilities are assigned as appropriate to other employers at the workplace.

## Draft Contract Employer’s Responsibilities

- Ensure that the host employer is aware of the hazards associated with the contract employer’s work and what the contract employer is doing to address them
- Advise the host employer of any previously unidentified hazards that the contact employer identifies at the workplace.

## Slide 74

## Slide 75

## Slide 76

## Slide 77

## Slide 78

## Hazcom Program should exist for “Uncommonly High” Fields, such as:>50 mG whole body ELF>Uncontrolled limits of FCC

## Applicable OSHA Standards

- 23 States have their own OSHA Standards
- Standards must be at least as strict as Feds
- Most copy Federal standards & interpretations
- Some require a Safety and Health Program
- 1910.97 - Non-Ionizing Radiation
- 10 mW/sq.cm, 6 min. average, 10M-100GHz
- No spatial averaging
- Uses voluntary language of 1966 ANSI
- Mandates look of RF Sign

## Applicable OSHA Standards (cont.)

- 1910.268 - **Telecommunication Industry**
- Primarily safety requirements, such as electrical
- Mandates 1910.97 compliance for 1-300 GHz
- Describes “Tagout” of antenna 3-300 MHz
- 1926.54, 20 - **Construction Industry**
- Includes tower erection, repairs and painting
- Limits MW to 10 mW/sq.cm. (no averaging)
- Requires Programs to provide safe work to employees and contractors; includes inspection

## Applicable OSHA Standards (cont.)

- 1910.147 - **Lockout/Tagout of Power**
- Requires lockout or tagout of power during maintenance to prevent excessive exposures
- 1910.132 - **Personal Protective Equipment**
- Requires hazard assessment to select appropriate PPE
- Interpretation letter addresses RF Clothing
- 1910.145, 1926.200 - **Signs and Tags**
- Use signs to warn of hazards

## Applicable OSHA Standards (cont.)

- 1904 - **Record Keeping**
- Log of injuries and illnesses, accidents
- 1910.1020 - **Access to Employee Exposure and Medical Records**
**Section 5(a)(1) of OSH Act**
- Requires a safe and healthful workplace free of recognized serious hazards

## Obviously Outdated

**Exposure Limit **is from 1966 ANSI
- Not frequency dependent
- Does not address induced current limits
- Incomplete on **Hazard Communication**
- Describes RF Sign but not where to use it
- One Warning sign for all conditions
- Incomplete on **RF Safety Program** Elements

## Slide 85

## Slide 86

## Slide 87

## Slide 88

## Slide 89

## Policy Issues

- “Action” Level at FCC or 50% of Maximum