NA&TSC’s Response to FCC RF Safety Issue (Part 4)

Signs and barriers have been proven ineffective in protecting workers from RF radiation injuries

Original Notice of Proposed Rulemaking (Para 190)

We propose to adapt the four IEEE Std C95.7-2005 categories as follows: Category One – locations where operational characteristics of sources would not cause the exposure limit for the general population to be exceeded; Category Two – locations where the exposure limit for the general population would be exceeded but not the exposure limit for occupational personnel; Category Three – locations where the exposure limit for occupational personnel would be exceeded and has the potential to exceed this limit by up to a factor of ten; Category Four – locations where the exposure limit for occupational personnel would be exceeded by at least a factor of ten or where there is a possibility for serious contact injury such as a severe burn, permanent tissue damage, or electrocution. For a visual depiction of these proposed categories and a general summary of the corresponding signage symbology, refer to Figure 1 below, adapted from IEEE Standards C95.7-2005 and C95.2-1999, since these categories have been amended slightly from their definition in IEEE Std C95.7-2005 to establish clearly enforceable boundaries. As further elaborated in our proposal, we seek to unambiguously define boundaries between each category based on the maximum time-averaged power over the appropriate time averaging period (six minutes for occupational or 30 minutes for general population). We seek comment on our proposed mitigation requirements. Specifically, we request comment on anticipated costs related to implementing this proposal for clear definition of compliance boundaries, given that most sites already likely comply with these proposed requirements, and we intend to allow sufficient time for licensees to inspect each of their sites for compliance if there may be any uncertainty.

NA&TSC’s Response to Notice of Proposed Rulemaking (Para 190)

The NPRM also states “that accurate placement of appropriate signage is important.” In RF CHECK’s experience, RF safety signs are only effective as a last line of defense against hazards. Trade workers unaffiliated with licensees are the most vulnerable to RF injuries at wireless sites, and signs by themselves are not effective for this community. Without knowledge of how RF works and how to avoid being over-exposed to RF radiation, workers are at risk even in the presence of signs. The constant change that characterizes the wireless industry means that antenna sites change, power levels change, licensees change, and contact numbers change – but once a sign is hung, it never changes.

Signs can only be effective in conjunction with a comprehensive, standardized database system in place, where workers will then be able to access the site specific RF safety protocol and “maps of the invisible” to obtain the necessary information to complete the job safely.

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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