NA&TSC’s Response to FCC RF Safety Issue (Part 1)
Fire fighters, 3rd party workers and others are not provided with the necessary means to protect themselves from RF radiation injuries
Original Notice of Proposed Rulemaking (Para 183)
Averaging time is an intrinsic part of the existing exposure limits, and as such, our intent is that averaging time may be used whenever there is adequate control over time of exposure. As we have proposed here for transient exposure, where the general population limit is exceeded (but not the occupational limit) and adequate controls are in place, averaging time may be used to comply with the general population limit. For example, a transient individual walking in a controlled area may be exposed above the general population limit in one location and below this limit in another location, but the average over any 30-minute time period should be compliant with the general population limit. We seek comment on all of these proposals to better define transient exposure conditions beyond what has already been adopted in the Order herein. Specifically, we solicit comment on the expected cost associated with requiring supervision of transient individuals, where licensees would benefit from compliance certainty. We encourage interested parties to comment on both the relative costs as well as the benefits of the proposed changes in this section, as well as those of alternative approaches.
NA&TSC’s Response to Notice of Proposed Rulemaking (Para 183)
The NPRM seeks comment on the FCC’s approach to “exposure of untrained individuals in controlled environments for short periods of time. In our experience, such workers 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. Commission rules require licensees to protect these workers from exposure at each of their sites. We have seen firsthand that as the number of wireless sites increases significantly (including co-location), 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 is practically impossible in the absence of a new approach. The Commission, therefore, properly solicits “comment on the expected cost associated with requiring supervision of transient individuals, where licensees would benefit from compliance certainty in an effort to ensure compliance in a manner that is effective but avoids an unnecessary burden for licensees that are toiling to meet the public’s overwhelming demand for all things wireless.
First, because of the large number of RF transmission sites and the large number of untrained transient individuals at those sites who are not under the control of licensees, the Commission 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 functional ability to control access. If the FCC and all other entities desire to successfully protect workers rather than simply assign blame, RF safety must be recognized as the shared responsibility of the entire wireless ecosystem.
Second, the Commission should seek a solution that ensures that the wide variety of individuals described above 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, recognizing that it simply is not possible for all of these individuals to receive the fulsome training needed for the FCC to classify them as RF safety trained workers.
Third, the Commission’s policies should advance a uniform site safety protocol that is well understood by the diverse set of workers described above. 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.