The regulations require amateur operators, whose stations are not categorically excluded, to perform a routine analysis of compliance with the MPE limits. The FCC is relying on the demonstrated technical skill of Amateur Radio operators to evaluate their own stations. The FCC regulations do not require field - strength measurements . Measurements are one way to perform an analysis, but they're very tricky. In untrained hands, errors exceeding 10 dB are likely.
Many factors can confound measurements in the near field.
The FCC encourages flexibility in the analysis, and will accept any technically valid approach. Once an Amateur Radio operator determines that a station complies, operation may proceed. There's no need for FCC approval before operating. At press time, Bulletin 65 is not complete. The ARRL and others have been offering specific comments to the FCC, after reviewing the first draft.