NA&TSC’s Response to FCC RF Safety Issue (Part 5)


FCC lacks the funding to enforce existing RF safety regulations that protect the health and wellbeing of workers near RF transmitting antennas

Original Notice of Proposed Rulemaking (Para 198)

The FCC Enforcement Bureau can initiate cases where it appears that RF exposure limits might be exceeded, and where non-compliance is found, the Bureau can require corrective action and impose fines or other sanctions. An example of a corrective action is an effective physical barrier such as enclosure of an area by a locked six-foot high chain-link fence or securing access to a rooftop by a locked door with signs posted to notify the public not to proceed because of the potential exposure to RF fields (applicable only where our exposure limits could be exceeded). However, besides an absence of signage, some other examples of where the Commission has declared existing control actions to be inadequate include: signs without contact information, signs placed incorrectly, improper types of signs, insufficient barriers, and unsecured entryways. We expect that these proposals throughout this section of the Further Notice will not create a significant new burden for transmitter site operators and licensees, since most high-power fixed licensees already implement RF safety programs, and much of this material is a codification of existing industry practice and standards. Nonetheless, we seek comment on this issue.

NA&TSC’s Response to Notice of Proposed Rulemaking (Para 198)

The NPRM notes that “[t]he FCC Enforcement Bureau can initiate cases where it appears that RF exposure limits might be exceeded, and where non-compliance is found, the Bureau can require corrective action and impose fines or other sanctions . . . . [E]xamples of where the Commission has declared existing control actions to be inadequate include: signs . . . . , insufficient barriers, and unsecured entryways . . . . [W]e seek comment on this issue.”

The FCC’s Office of Engineering and Technology and the Enforcement Bureau have the unenviable task of overseeing RF safety and compliance at the hundreds of thousands of wireless sites across our nation. Although FCC staff is dedicated and able, the Commission is perpetually underfunded and understaffed for such an enormous mission. It is unrealistic to expect the FCC to field inspect any significant portion of the vast number of transmission sites. Furthermore, as the NPRM recognizes, FCC enforcement has been limited to identifying missing signs and barriers. As discussed above, even well-placed signs and barriers do not effectively protect workers, so FCC enforcement has not, and is highly unlikely to, advance the core safety issues identified in the NPRM.

Instead, the Commission should recognize the need for a comprehensive solution that includes: (1) the establishment of a national standardized RF safety protocol that utilizes a living data repository of all wireless antennas; (2) adequate training for the diverse array of workers who encounter transmitting antennas; (3) access to easily understood site specific RF safety protocols and “maps of the invisible”; and (4) confirmation that workers have received sitespecific safety materials prior to performing tasks at wireless sites. Importantly, such a solution must be facilitated by a private sector, neutral third-party to be transparent, effective, and sustainable, and must minimize the burden on licensees and site owners. Such a system would allow the FCC to meet its responsibility of protecting workers in a practical way, to monitor compliance without having to field inspect sites and would provide for effortless regulatory compliance of licensees.

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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