Carriers Alone Cannot Fully Protect Workers from RF Radiation at Cell Sites

In 2013, the FCC released a Notice of Proposed Rulemaking (NPRM), in part, to “ensure that [the FCC’s] measures are compliant with [the FCC’s] environmental responsibilities and requirements and that the public is appropriately protected from any potential adverse effects from RF exposure….” Comments were solicited from the wireless industry and the public to better inform the rulemaking changes.  Rather than recommending precautions to help protect more people, several comments from the carriers recommend removing liability through “safe harbor” as they admit that protecting third party workers at certain sites is out of their control, even though it is their FCC obligation.


Third party workers such as first responders, roofers, HVAC technicians, electricians, painters, window washers, sheet metal workers, and utility workers among others maintain structures that can house RF transmitting antennas. Yet, third party workers, or “transient workers,” as described by carrier comments, pose a safety problem that carriers themselves admittedly cannot resolve.

Verizon remains committed to – and in fact does operate – safe and effective transmitters, but there are limits to our ability to control the actions of third parties.

Andre Lachance Verizon Assistant General Counsel

In comments sent to the FCC, Verizon notes that “carriers alone cannot control transient individuals nor employees of others that may access areas surrounding transmitters at these sites for occupational reasons…. [T]he current rules and guidance are unworkable to the extent there is no action carriers can take…to be certain that they are compliant.” In addition to stating a solution is not workable, Verizon states “the Commission should adopt minimum ‘safe harbor’ requirements,” meaning carriers would no longer have the same level of liability and instead be judged based on “best efforts” to keep people safe. (Verizon Reply Comments to FCC, Verizon FCC Ex Parte 1, Verizon Ex Parte 2, Verizon Ex Parte 3)

AT&T echoes similar comments stating that “licensees making reasonable efforts to educate and warn third parties about potential exposure risks and mitigate those risks should not be subject to enforcement action if exposure occurs despite those efforts.” What exactly is “reasonable efforts” when it comes to someone’s health?

We explained that Verizon sometimes encounters obstacles when trying to restrict access or provide appropriate notifications on transmitter sites.

Tamara Preiss Verizon VP Federal Regulatory Affairs

Third party workers risk their health and wellbeing by maintaining structures that house wireless transmitting antennas. Their health should be protected and championed by a $188.5 billion industry that benefits from their work. Yet, comments from carriers try to remove liability and reduce responsibility to “best effort,” rather than having a meaningful and comprehensive RF safety solution. Just because a solution is difficult does not mean worker safety can be sacrificed.

National Antenna & Tower Safety Center (NA&TSC) has solved the challenges to worker RF safety that Verizon and AT&T outlined in their comments. As evidence of the solution, global insurers have vetted the patented process, protocols, and system, and have partnered with NA&TSC to offer RF Indemnity Shield™, an RF safety insurance product.

We do not have to trade an expansion of the wireless network for safety. Rather, I want our industry to lead the way.

Gil Amelio former CEO of Apple Computer

Worker safety can no longer be disregarded, especially now that a solution exists to the industry challenges. We owe it to the workers and their families to ensure that they are protected from the hazards of RF radiation at their job sites.

The health and wellbeing of the American worker and their families depends on the timely adoption of NA&TSC’s RF radiation solution.

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