NA&TSC’s Response to FCC RF Safety Issue (Part 1)
December 22, 2017
FCC Issue: Supervision of Transient Individuals in a Manner that Provides Licensees with Compliance Certainty (Para. 183) Notice of Proposed Rulemaking (NPRM)
FCC Issue Explanation: The FCC takes issue where first responders and 3rd party workers are not provided with the necessary means to protect themselves from RF radiation
The following is NA&TSC’s solution
In our experience, transient individuals include electricians, roofers, flashers, painters, HVAC personnel, maintenance workers, firefighters, utility workers, and contractors and employees of licensees who are not specially trained on RF safety but must work near RF transmitting antennas. FCC rules require licensees to protect these workers from exposure at each of their sites. As the number of wireless sites increases significantly, the types and locations for these sites change, the number of hidden sites increases, and the licensee’s ability to protect workers from RF radiation has become practically impossible.
Worker near rooftop antennas
Because of the large number of RF transmission sites and the large number of untrained workers at those sites who are not under the control of licensees, the FCC should recognize that licensees alone cannot ensure compliance. Instead, only a comprehensive solution that ensures close coordination between licensees, site owners, workers, and those workers’ employers will achieve the FCC’s goals. It is unrealistic for licensees to somehow control site activity when they have no knowledge of this activity in most cases and no real ability to control access. RF safety must be recognized as the shared responsibility of the entire wireless ecosystem.
The FCC should seek a solution that ensures that the individuals who work on rooftops, lighting structures, or other places where RF transmitting antennas are now common, receive simplified RF training and access to site specific RF safety information prior to site access. The FCC’s policies should advance a standardized site safety protocol that is well understood by a diverse group of workers. If there are too many different safety approaches with information provided to workers in too many different forms accessible in too many different locations, workers will simply not receive the information they need.
National Antenna & Tower Safety Center provides the only solution that fully addresses all the issues the FCC raises regarding RF safety at wireless transmission sites.
The health and wellbeing of the American worker and their families depends on the adoption of NA&TSC’s safety solution. It is time for the wireless industry to do the right thing and protect our Nation’s workers.