“THE RF SAFETY PROGRAM and TRAINING REQUIREMENTS” • Basics for developing an effective Site Health and Safety program for all hazards at RF sites CONFIDENTIAL R.S.I. CORPORATION MEASUREMENTS FOR OSHA COMPLIANT RF PROTECTION PROGRAMS by Bob Curtis, Director for RF Safety, OSHA • “RF Safety and Health training is required to ensure that all employees understand the RF hazards to which they may be exposed and the means by which the hazards are controlled.” (Part of a Written Plan). CONFIDENTIAL R.S.I. CORPORATION OSHA Interpretation (Cont’d) ... “that the FCC require its applicants to implement a Written RF protection Program which appropriately addresses traditional safety and health program elements including training, medical monitoring, protective procedures and engineering controls, signs, hazard assessments, employee involvement, and designated responsibilities for program implementation.” CONFIDENTIAL R.S.I. CORPORATION OSHA Interpretation Letter to FCC - • “ “the uncontrolled environment criteria is an ACTION LIMIT which determines when an RF protection program is required.” (Note NTIA follows OSHA) CONFIDENTIAL R.S.I. CORPORATION FCC Rulemaking mW/cm2 MPE LAW 100 30 10 Controlled =100% 5 Both E&H Below 1 300MHz .2 20% reading is OSHA’S FM AM ACTION LIMIT 0.3 1 3 10 6 Min TWA 20% Uncontrolled 30Min TWA Cellphones 30 100 300 1 3 MHz GHz 10 30 100 Some states now explained what they require WAC 296-6209005 • 2) The employer shall establish and maintain a program for the control and monitoring of non-ionizing radiation hazards. This program shall provide employees adequate supervision, training, facilities, equipment, and supplies, for the control and assessment of non-ionizing radiation hazards. CONFIDENTIAL R.S.I. CORPORATION What does OSHA want? • Site-specific program • Should include an RF Safety Program if potential exposures exceed limits for uncontrolled environments CONFIDENTIAL R.S.I. CORPORATION MPE indicates problem? YES Perform physical RF assessment Perform protective action; raise antennas, lower power, change antenna, until RF exposure is mitigated. Document any changes with MPE evaluation, retain records. YES Perform physical RF assessment MPE indicates problem? Control area Train ALL affected personnel on the hazard. Trainees must exhibit competence after training. -Create RF exposure policy for employees Create site-specific safety plan in regards to the hazard and how to control exposure. FCC License Being a lessee at a site does not relieve you of any of these obligations! check with the owners to see if a master site plan exists. If not, work together to develop one! CONFIDENTIAL R.S.I. CORPORATION Multi-Employer Worksites Rules Updated in 1999 • The creator of the hazard must notify and work with the affected entities to find a way to work safely around the hazard • This is similar to many RF site situations where high-power antennas impact co-located towers or other employees working on or near the site CONFIDENTIAL R.S.I. CORPORATION Power to the antenna must be reduced for as much and as long as necessary to avoid exposing the crew to RF radiation in excess of the guidelines. CGC #525 CONFIDENTIAL R.S.I. CORPORATION CONFIDENTIAL R.S.I. Corporation OET Bulletin 65 Appendix B Edition 97-01, “Legal releases signed by workers willing to accept high exposure levels are not acceptable and may not be used in lieu of corrective measures.” OSHA wants to know: Are you a creating, exposing, correcting, or controlling employer or do you fulfill “multiple roles”? CONFIDENTIAL R.S.I. CORPORATION CONFIDENTIAL R.S.I. CORPORATION Safety 1. 2. Lock-Out/Tag-Out 1. 2. COMPANY SAFETY PLANS AND TRAINING What OSHA says about safety training when employees have exposure • 1910.1020 (c)(13) “Toxic substance or harmful physical agent” non-ionizing radiation. • 1910,1020 (g)(1)Upon an employee’s first entering into employment, and at least annually thereafter, each employer shall inform current employees ….(g)(1)(i) The existence, location, and availability of any records…. Note: The uncontrolled criteria is OSHA’s action limit” CONFIDENTIAL R.S.I. CORPORATION What OSHA says about safety training • It shall consist of on-the-job training or classroom-type training or a combination of both • The employer shall certify the employees are Competent and have been trained by a Qualified person OSHA CFR 1910.268© states CONFIDENTIAL R.S.I. CORPORATION Some states have now explained what they require: NCDOL 13 NCAC 07F .0609 TRAINING • (2) Employers shall ensure that each affected employee who works in an electromagnetic energy environment with potential RF exposure in excess of the general population/uncontrolled MPE limits stated in 47 CFR 1.1310 has access to and understands the specific site information related to the RF energy and RF fields present at each individual site. CONFIDENTIAL R.S.I. CORPORATION RF Health and Safety Protection Programs Identification and Control of RF Hazard Areas. 1. Hazard areas must be identified 2. Workers must be Trained. CONFIDENTIAL R.S.I. CORPORATION IN SUMMATION • There is no “categorical exclusion from FCC/OSHA” for any transmitter that exceeds the FCC MPE LIMITES. RF is a physical hazard. • The only way to have liability protection from fines or law suits (if you are not in compliance with MPE) is to conduct, at a minimum; • an MPE Analysis an onsite assessment (sites now require an “MPE Data Base”), • have a Written Safety Plan for your sites and shops, and • Train Your Workers. CONFIDENTIAL R.S.I. CORPORATION ??? ???