by: Miranda Allen
Of course you have a roof but the big question is: Do You know how to be safe on your roof? With today’s telecommunications lease explosion, many rooftops have cellular phone and broadcast towers, PCS antennas, specialized mobile radios, fixed wireless services, paging services and even satellite dishes.
Many building owners are taking an economic advantage of this growing market, but have no idea how to follow the laws and comply with the OSHA and FCC requirements especially when dealing with the exposure to Radio Frequency (RF) Radiation.
With today’s fast-growing RF technology, safety training is not just for engineers and tower climbers but is essential to anyone
(including building owners and managers) who might be working around antennas located on or around building rooftops. Rooftop workers such as painters, window washers, HVAC vendors, roofers, building and maintenance personnel can be exposed to RF and must be trained to meet OSHA requirements.
Before ANYONE can enter your rooftop they will need protection from RF radiation that is emitted from those antennas on the rooftop.
I would venture that the majority of people fall into one of these categories:
1.
They don’t know anything about RF and didn’t even know they should be cautious;
2.
They know some about RF, but what they learned is wrong or now obsolete;
3.
They are too macho to worry about their safety; or
4.
They understand RF and can work around it safely.
RF is not to be taken lightly, and it is an element of the job that is dangerous because it is a safety issue that is often not realized until over-exposure occurs.
RF is a physical hazard. Training is required so that workers can recognize the hazard and control their exposure. Once a worker is trained and deemed competent and qualified by their employer, they can work legally and safely all day in an area under 100% of the human exposure limit determined by the Federal
Communications Commission (FCC).
People are exposed to RF radiation all the time and don’t know it; if RF levels are below the uncontrolled standards, there is no reason for them to be trained. The FCC Office of Engineering and
Technology (OET) defines two tiers of radiation exposure: uncontrolled and controlled. OET Bulletin 65 97-01 states, “To meet its responsibilities under NEPA (the National Environmental
Policy Act), the commission has adopted requirements for evaluating the environmental impact of its actions. One of several environmental factors addressed by these requirements is human exposure to RF energy emitted by FCC-regulated transmitters and facilities.”1
Many workplaces are guilty of “signage overkill.” Every year a new sign goes up, but no one ever bothers to remove the out of date signs. How are workers to know which sign is current and best specifies the appropriate level of protective equipment?
Photo courtesy RSI Corporation
The FCC allows exposure in Section 1.1310 and states, “general population/uncontrolled exposures apply in situations in which the general public may be exposed, or in which persons exposed as a consequence of their employment may not be fully aware of the potential for exposure or cannot exercise control over their exposure.” 1
A locked door and signs are not enough to prevent exposure, and FCC rulings reiterate this fact. If anyone who is not fully aware of the danger and cannot exercise control has access to the site, the FCC considers this an uncontrolled area. If the maintenance
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crew, building owner/manager, roofers, HVAC workers, grass cutter, weed sprayer, electrician, or the like are not trained in RF safety but can get on the site, it is an uncontrolled area and the uncontrolled standard applies.
The FCC MPE chart shown on page 3 has two tiers: controlled and uncontrolled. Those who work in RF fields will see this chart often. It’s important to note that there are two levels: controlled/occupation, and uncontrolled/general population. The 30–300 MHz frequency range is the most stringently regulated, as the frequency waves in this range more closely resemble the height of a human and, therefore, absorption is easier/faster. All you need to know about this chart is what percentage of the standard you are exposed to.
If you are trained and can exercise control over your exposure, you can be exposed up to 100% of the standard and work in that area all day. If you are not trained, you can only be exposed to 20% of the controlled standard, represented by the yellow line.
Most rooftop workers have not yet been trained, as their employers do not realize the requirements for training or the dangers of RF radiation. When work is needed on the roof no one is thinking about RF, they are handling the situation at hand, so now is the time to ensure training has occurred and proper RF Safety Monitors (personal protection monitors or PPM) are utilized. If potential exposure environments exceed the uncontrolled limit, the companies should have a written statement of policy as to the organization’s expectations regarding the control of human exposure to RF fields.
I often hear, “Well, I won’t be in an area where RF is above the uncontrolled limit.” The key thing to remember is the potential to exceed this limit. If you are on a rooftop that has transmitters, there is the potential for RF to be over uncontrolled levels. As stated earlier, RF is a physical hazard, so the Occupational Safety and Health Administration
(OSHA) expects a plan to be in place, training to have been done, and personal protection monitoring to be in use.
In its 2013 RF exposure update, the FCC made it clear that “individuals must receive written and/or verbal information and notification (for example, using signs) concerning their exposure potential and appropriate means available to mitigate their exposure…individuals exposed as a consequence of their employment must have appropriate training regarding work practices that will ensure that exposed persons are ‘fully aware’ of the potential for exposure and can exercise control over their exposure.”
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The federal register goes on to note that education is the key to a successful RF compliance program.
It’s important for workers who enter a rooftop to understand that signage in a potentially hazardous area may refer to RF by a number of other names, including electromagnetic emissions
(EME), radiofrequency emissions (RFE), radiofrequency radiation (RFR) or non-ionizing radiation—these all mean the same thing. OSHA requires annual training in non-ionizing radiation and has put forth regulations defining training requirements and listing RF radiation as a harmful physical substance.
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In response to this danger, OSHA requires right-of-access to exposure records if an employee is subjected a toxic substance or harmful physical agent. These records, or hazard assessments, would measure the level of RF exposure the employee was subjected to. By law, employers are required to inform all employees of such hazards upon their initial employment and at least annually thereafter. A workplace hazard assessment will determine if hazards are present and Conducting a RF Hazard Assessment on your roof is one determine the appropriate signage and personal protective equipment
(PPE) to be used in the area. All transmitting facilities and devices way workers can know the exposure limits and be protected from dangerous levels of radio frequency regulated by the FCC are expected to comply with the appropriate
RF radiation exposure guidelines.
3 radiation. That’s why the FCC and OSHA have mandates in place for signage and access levels to protect workers and the public.
The U.S. Department of Labor (which includes OSHA) mandates ongoing and yearly sampling to prove exposure level compliance.
The regulation calls for yearly samplings because changes can occur in building structure from to year. Shields/guards being removed, detuning, leaks, dye changes, line speed variations, new equipment, grounding, element changes, ambient condition changes, voltage changes, peak loads and other process changes can all affect radiation.
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For personnel who work on or near the antennas, annual training is the minimum, but it
may not be enough to guarantee recognition of the hazard and proper usage of
PPE. Personal protection
monitors are critical to any fully functioning RF safety plan. Monitors must have a wide frequency range to ensure coverage at all potential frequencies. Monitors should be isotropic, and—as simple as it sounds—it’s important that they are used correctly.
Employees must be trained on the monitor before use and must be deemed competent and qualified to use it.
Best management practices dictate the RF personal protective monitor has precedence above all other precautions, such as signage and barriers. The RF monitor is taking real-time readings, while signage and barriers were placed using previously determined RF levels that could be up to a year old (or more if the workplace is non-compliant).
Remember: things change quickly on telecom sites. Also, there is no standard signage policy, so different FCC licensees post signs differently. Many times you will see a rooftop door with several signs. It can be difficult to tell which sign is correct, and that is why the personal protection monitor (PPM) is critical.
PPMs are not designed for, nor should they be used to take measurements. Use of monitors requires proper training of personnel, and OSHA reminds workers that a PPM does not protect you from the hazard; it only provides you with a means of warning. An RF monitor can be a useful tool, but it may give you a false sense of security. You should never totally rely on an RF monitor, but instead you must use it in conjunction with your knowledge of RF safety.
High RF could interfere with the signals of communication equipment, thereby affecting the ability to communicate with other team members. It could also interfere with back-up sensors or reverse video monitors leading to an accident. OSHA director of construction James Maddux recently sent a letter to all regional administrators stating that when recording communication tower incidents, it’s important to find out if ambient RF is present. “Were employees wearing any measuring or warning devices to protect against ambient RF?” Maddux asks.
The EME Guard from Microwave Vision Group is an extra-small broadband RF safety monitor that continuously measures electromagnetic fields and alerts the user when pre-set thresholds are exceeded.
Photo courtesy RSI Corporation
RF is a very real and present danger to the workers in the field and on rooftops. Knowledge is power. Training and following safe RF practices is critical. To find more information on RF, training and additional experiences by workers and management regarding RF, visit www.rsicorp.com or email info@rsicorp.com.
MIRANDA ALLEN is a safety professional and CEO of Radiofrequency Safety International (RSI). A published author and national speaker, she is a passionate advocate for safety. Allen serves on the National Association of Tower Erectors’ Member Service Committee and is a member of the American Society of Safety Engineers. She holds an MBA from the University of Colorado.
REFERENCES
1.
FCC OET. (August 1997) Evaluating compliance with FCC guidelines for human exposure to radiofrequency electromagnetic fields. OET Bulletin 65 . Retrieved on March, 27, 2015, from transition.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet65/oet65.pdf.
2.
FCC. (June 4, 2013) Federal Register Vol. 78, No. 107, Part IV. Retrieved on March 27, 2015, from rfcomply.com/pc/fcc_rfr_update.pdf.
3.
OSHA (n.d.) Regulations (Standards – 29 CFR). Retrieved on March 27, 2015, from osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=STANDARDS&p_toc_level=1&p_keyvalue=1910 .
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