NA&TSC’s Response to FCC RF Safety Issue (Part 3)


Hidden and camouflaged antennas pose an unseen danger to fire fighters, 3rd party workers and others

Original Notice of Proposed Rulemaking (Para 186)

While IEEE Std C95.7-2005 is intended as a set of guidelines to avoid potentially hazardous exposures to RF sources and suggests that “other schemes may be equally effective,” we propose to develop a set of specific mandatory rules to establish accountability among licensees and operators of fixed transmitters authorized under our rules so as to protect occupational personnel and the general public from exposure above our limits. We note that fixed radio transmitters are no longer located only on towers or facilities such as utility poles. Radio transmitters and their antennas have been deployed in a wide variety of forms, often designed as trees, chimneys, or panels on a building for aesthetic reasons, and their presence therefore might not be obvious. We realize that each transmitter site is different and that a wide range of exposure environments may exist, and so we seek comment on how to simultaneously provide flexibility and certainty to licensees and site owners while at the same time ensuring enforceable compliance with our exposure limits.

NA&TSC’s Response to Notice of Proposed Rulemaking (Para 186)

The NPRM also correctly seeks comment on how the wide deployment of hidden antennas affects its goal of ensuring worker safety near transmission sites. Specifically, the NPRM states “[r]adio transmitters and their antennas have been deployed in a wide variety of forms . . . as trees, chimneys, or panels on a building for aesthetic reasons, and their presence therefore might not be obvious . . . we seek comment on how to simultaneously provide flexibility and certainty to licensees and site owners while at the same time ensuring enforceable compliance with our exposure limits.”

In the past, the vast majority of transmission sites were located in plain sight in relatively inaccessible locations. Each year, however, an increasing number are located in the facade of buildings, nestled in lighting structures, hidden behind RF-transparent but visually obscured fiberglass walls on rooftops, or designed to look like anything but transmitting antennas. These sites allow licensees to comply with often-strict local antenna siting rules, address communities’ aesthetic concerns and adhere to site owner mandates. But stealth sites also make it significantly more difficult for workers to identify where RF risks exist. There is abundant evidence that electricians, painters, maintenance workers, roofers, sheet-metal workers, HVAC technicians, and others are performing tasks in close proximity to stealth antennas.

The FCC should react to the emergence of these stealth antennas with rules that advance the use of a private sector, neutral third-party to collect and distribute RF safety information related to transmission sites. Such a database would allow workers to identify all RF safety concerns at a location even where visual inspection does not allow effective risk avoidance. In particular, such a system would provide workers with up-to-date RF “maps of the invisible,” keyed to the FCC limits for maximum permissible exposure limits as identified in 47 C.F.R. § 1.1310, prior to entering a property.

American workers and their families support the National Antenna & Tower Safety Center solution.

NA&TSC Full Response to Original FCC Notice of Proposed Rulemaking (PDF)
Original FCC Notice of Proposed Rulemaking (PDF)


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