“THE RF SAFETY
PROGRAM and TRAINING
REQUIREMENTS”
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

(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

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

mW/cm 2
MPE LAW
100
30
10
5
1
Controlled =100%
6 Min TWA
Both E&H
Below
300MHz
20%
Uncontrolled
30Min TWA
AM FM
Cellphones
ACTION LIMIT
0.3 1 3 10 30 100 300 1 3 10 30 100
MHz GHz

Some states now explained what they require
WAC 296-62-
09005
• 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

•
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
Control area
-Create RF exposure policy for employees
MPE indicates problem?
Train ALL affected personnel on the hazard. Trainees must exhibit competence after training.
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
Safety
1.
2.
Lock-Out/Tag-Out
1.
2.
R.S.I. CORPORATION
C
OMPANY
S AFETY P LANS AND
T RAINING

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

• 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

Identification and Control of RF Hazard
Areas.
1.
Hazard areas must be identified
2. Workers must be Trained.
CONFIDENTIAL R.S.I. CORPORATION

• 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

???
???