# Presentation: 698645

## OSHA REGULATION FOR RF RADIATION EXPOSURE

**Bob Curtis**
**US OSHA Directorate of ****Technical Support**

## Current OSHA RF Standards

**General Industries **(1910.97)
- 10 mW/cm2, 6 min TWA (1966 ANSI)
- Design of RF Warning Sign
- Voluntary Language - Not Enforceable
**Telecommunications **(1910.263)
- Recognizes PPE Controls
**Construction**
- 10 mW/cm2, no averaging time

## Obviously Outdated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

## “Modifications” to OSHAStandards

- OSHA Directives to Inspectors and Official Interpretation Letters
- Acceptance of newer ANSI RF sign
- ANSI Laser Standard Recommended in lieu of outdated OSHA standard.
- Guidance for using RF PPE
- Education of Employers, Employees, and Compliance Staff

## Enforcement of Consensus Standards

- Guidance for Enforcement of OSHA  Standards (e.g., How to measure RF)
- Support and Criteria for Citations of OSHA’s General Duty Clause
- Establishes Criteria for Safety and Health Programs When Required

## General Duty ClauseOSH Act Section 5(a)(1)

-    Employers shall provide work which is free from recognized hazards that are causing or are likely to cause death or serious physical harm.

## General Duty Clause Criteria

- At Least One Employee Exposed
- There is a Recognized Serious Hazard
- There Are Feasible Means to Correct
- The Employer Knew (or should have known with reasonable diligence)
- Rely Heavily on **Consensus Standards**
**Even if in Conflict with Existing Standards**

## Establishing Employer Knowledge and Feasible Controls

- Common Industry Practice
- Consensus Standards
- “5(a)(1) Letter” to Employers
- Usually based on Consensus Standards
- e.g., ANSI, TLV’s

## Existing Generic Standards

- Hazard Communications
- Hazardous Waste & Emergency Response
- Construction Safety & Health Plan
- Personal Protective Equipment
- Lock Out/Tag Out (of Hazardous Energy)
*All of These Could be Cited Based on Violation of Consensus Standards*

## Safety & HealthPrograms

- OSHA Working to Require Safety & Health Programs
- Many State OSHAs Already Require
- Required for Federal Agencies
- Required by International Standards (ISO)
- Good Employers will Implement Regardless of OSHA

## RF Protection Program

- Utilization of RF source equipment which meet applicable RF standards when new and during its lifetime.
- RF hazard identification and periodic surveillance by a competent person.
- Identification and Control of RF Hazard Areas.

## RF Protection Program (cont.)

- Implementation of controls and SOP’s to reduce RF exposures to levels in compliance with applicable guidelines.
- RF safety and health training to ensure that all employees understand the RF hazards and control methods used.
- Employee involvement in the structure and operation of the S&H Program.

## RF ProtectionProgram (cont.)

- Implementation of an appropriate medical surveillance program
- Periodic (e.g., annual) reviews of the program to identify and resolve deficiencies
- Assignment of responsibilities, including adequate authority and resources to implement and enforce the program.

## 1997 Law PromotesConsensus Standards

- Agencies to Adopt Applicable Consensus Standards Rather Than Developing Their Own
- Agencies Must Justify Exceptions
- “Consensus” Standard Implies Open Discussions and All Views Considered
- Agencies Encouraged to Participate in Developing Consensus Standards

## Role of Regulators in Consensus Standards Development

- Ensure All Stakeholder’s Views Are Heard
- Promote Worker Safety Through Justifiable and Rational Requirements
- Ensure Public and Open Process of Standards Development.
- Provide Credibility to the Final Product
- Provide Technical Expertise

## RF Priority Needs

- ISO Standards which prescribe RF Safety Program Elements, such as the Ionizing Radiation and Laser Safety Programs
- ISO Standards which support specific RF Program Elements, such as for testing of RF Protective Clothing
- Implementation of RF Safety Programs