THE RF SAFETY PROGRAM and TRAINING REQUIREMENTS

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“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
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