RF Hazard Assessment Tower – Ground Level & Vertical Woodward, OK Prepared for RSI Sales Department Copy ____ of _____ By ______ This is a controlled document. Unauthorized reproduction without the express written consent of RSI is strictly prohibited Radiofrequency Safety International Corporation 1310 Main Kiowa, Kansas 67070 Phone 888-830-5648 Fax 866-825-4324 (toll free) February 17, 2016 Electromagnetic Energy Emissions Hazard Assessment Report And FCC/OSHA Compliance Recommendations for the RSI Sales Department Tower Communication Site Site Location: 3 miles southeast on hwy 183/270 on Road E0440 Southeast of Woodward, OK FCC Tower Registration Number: 010101010 Prepared For: RSI Sales Department 1310 Main St. Kiowa, KS 67070 ABSTRACT At the time of the assessment1, RF emissions in assessed areas at ground level were below the FCC Uncontrolled/General Population limit for human exposure to Radiofrequency energy as outlined in 47 CFR §1.1301 through §1.1319. RF emission readings in the equipment room were below the applicable limits as well. RF emission readings taken on the tower exceeded the FCC Uncontrolled/General Population limit and the FCC Controlled/Occupational standard at certain points. Assessment also meets the OSHA definition of “survey” as defined in §1910 Subpart I App B 1910.140 (3) (a) Survey. Conduct a walk-through of the areas in question. The purpose of the survey is to identify sources of hazards to workers and co-workers. 1 INTRODUCTION RSI is a University based safety service organization. Our reports have been reviewed by and are on record with the FCC and other government agencies. This report is a safety and NEPA compliance report as required by the agencies, and is not intended to be an engineering document. An engineering report would not reflect the various safety issues that are encountered at many sites. RSI uses competent and qualified safety professionals and OSHA authorized trainers to review and develop programs. This document reflects this expertise Tower-GL & Vertical Communication Site RF Emissions Hazard Assessment. Original Document 1 The electromagnetic energy emissions (EME) assessment for the communications site was completed following recommendations of the Federal Communications Commission (FCC) Office of Engineering and Technology and the Occupational Safety and Health Administration (OSHA). The purpose of the EME hazard assessment at the communications site was to determine the ambient levels of electromagnetic energy (EME) in areas of concern. In addition, the assessment was conducted in order to detect and document whether EME fields present at the site are above FCC standards for human exposure to radio frequency (RF) emissions. The assessment also determines what areas should be defined as “hot” zones, or areas that contain RF levels above occupational/controlled limits. EXECUTIVE SUMMARY The report is divided into six sections: The first section explains why the assessment was performed, describes the site’s and the vicinity’s overall characteristics, clarifies the methods of data collection, the instrumentation used, and provides a description of what the collected data means in terms of compliance to RF and other safety issues. The second section is a map that indicates where the site is located. The third section contains photographs of the site, equipment and associated rooms or structures. They show what areas were assessed and document what was found at the site in terms of hazards at the time of the assessment. The fourth section contains computer-aided renderings of the layout of the site, which show the orientation of the antennas and related appurtenances to their surroundings. The fifth section shows the readings at the site expressed in computer-assisted rendering format. The sixth and final section includes all report exhibits; certificates of calibration of the RF measuring equipment used at the site, color-coded map indicating levels of RF emissions. Measurement Values The measurements were taken at specific points throughout the site, around the various structures and vertically on the tower. The readings were taken directly from the data the RF measurement instrumentation displayed at the given measurement point. Readings were taken by extending the probe to arm’s length, pointing it in the direction of the RF source and moving the probe up and down while oscillating the wrist and sampling RF emissions. The rotation of the probe and the action of pointing the probe at the RF source eliminates the isotropic response and ellipse ratio that could increase the shaped electric probe’s deviation factors. The readings taken from the shaped electric field probe are expressed in percent of FCC controlled/occupational standard. Due to the fact that the electric field instrument’s probe is a shaped electric field probe, it has the ability to take into account a wide range of frequencies at the site and express their RF emission in percent of controlled standard for the electric component of the electromagnetic field. Tower-GL & Vertical Communication Site RF Emissions Hazard Assessment. Original Document 2 Electric field emissions sampled are taken in percent of FCC controlled/occupational standard. The RF emissions assessment instrumentation used by RSI shows the readings on an LCD display in percent of FCC controlled standard. The Federal E-field limit for occupational/controlled workers is 100% of the controlled standard. The FCC uncontrolled standard is one-fifth (1/5th) of the Controlled standard. This is displayed as 20%. "Uncontrolled" persons, or the general population, cannot be exposed to RF emissions at 20% or above for more than thirty minutes. Therefore, if the instrumentation measures an area where the RF emissions are reading 27.0%, the uncontrolled standard has been exceeded by 35 percent. Magnetic (H-field) field emission readings are expressed in milliwatts per square centimeter (mW/cm2). The FCC standards are frequency dependent and the most stringent range is from 30 to 300 megahertz. The standards in this frequency range are 0.20 mW/cm2 for the Uncontrolled/General Population and 1.00 mW/cm2 for Controlled/Occupational persons. Transmitters utilizing this frequency range are present at the site. Peak readings were recorded during the assessment. For most safety programs, OSHA requires that the most conservative action be taken when determining hazards. This is what is indicated on the color-coded site map in this report. The use of peak readings documentation provides the most conservative approach to RF emissions safety compliance. The use of peak reading documentation provides a margin a safety, which may otherwise be overlooked using averaging techniques (i.e. microwave signals, duty cycle changes, re-radiation, etc.) Due to changes in weather conditions such as temperature and humidity, the RF emissions that were sampled on the day of the assessment may not represent the RF emissions on days of differing weather conditions. However, any variation would be minimal due to the methodology of data collection at the time of the assessment. All significant contributors (as defined by the FCC) are responsible for insuring the applicable standards are adhered to. When performing an evaluation for compliance with the FCC’s RF guidelines all significant contributors (5%) to the ambient RF environment should be consider, including those otherwise excluded from performing routine RF evaluations, and applicants are expected to make a good-faith effort to consider these other transmitters. The FCC states “we can see no easy way to define a “site” or to specify some arbitrary radius around antennas at which compliance must be evaluated.” The FCC standard permits time averaging of RF exposure. Reliance on the time-averaging provision of the standard for non-trained workers per OSHA would require precise knowledge of the exposure level at all times as determined by precise scientific instrumentation and a higher level of worker training. Therefore, such mitigation measures are not recommended in this report. Tower-GL & Vertical Communication Site RF Emissions Hazard Assessment. Original Document 3 SITE DESCRIPTION Location The site is located approximately three miles to the southeast of Woodward, Oklahoma in a rural area. The tower is east of State Highway 270/183 on Road E0440 on the south side. Construction The site tower is a guyed tower approximately 480 feet in height. Access The site is enclosed within a locked security fence topped with barbed wire. There is a “no trespassing” sign posted on the fence. RF equipment Antennas on the tower include omnidirectional whip, folded dipoles and multi-distribution service broadcast tube antennas at the top. There are satellite dish antennas mounted at ground level. The equipment shelter at the site is a 25’ x 32’ concrete block and brick structure located to the south of the tower. There is a blue “NOTICE” sign posted at the site gate along with chemical hazard signage. A yellow “CAUTION” sign and the tower registration number are posted at the tower base. METHODOLOGY AND INSTRUMENTATION The EME assessment was conducted following sound scientific principles as outlined in the RSI Superior Survey Techniques manual. See the measurement values section above for data collection techniques. Instrumentation used in the collection of data is calibrated to factory specifications and maintained in good working condition in order to provide the best data collection available. Mr. Ken Wagenbach and Mr. Gary Gerber performed the assessment on January 23, 20XX. The site assessment began at 11:00 a.m. and concluded at 3:15 p.m. The weather conditions at the beginning of the assessment were sunny and windy with a temperature of 50o Fahrenheit and a relative humidity of 65%. The weather conditions at the conclusion of the assessment were unchanged with a temperature of 67o Fahrenheit and a relative humidity of 55%. The following instrumentation was used: Narda Microwave – East Electromagnetic Radiation Survey Meter Model Number: 8718-10 Serial Number: 01610 Narda Microwave – East Electric Field Probe Tower-GL & Vertical Communication Site RF Emissions Hazard Assessment. Original Document 4 Model Number: A8722D Serial Number: 05007 Frequency Range: To 50 GHz Narda Microwave – East Magnetic Field Probe Model Number: A8732D Serial Number: 05007 Frequency Range: To 200 MHz Palomar Engineers RF Current Meter Model: PCM-1 Model A-0145 Wandel & Goltermann ESM-20 Shaped RF/EME Safety Monitor for E and H fields. Frequency range 3MHz-1GHz H field, 3 MHz-18 GHz E field. RESULTS RF emission readings taken on the tower exceeded the FCC Uncontrolled/General Population standard and the FCC Controlled/Occupational limit. RF emission readings taken at ground level were all below the FCC Uncontrolled/General Population standard. The following recommendations are meant to act as a guide for the managers/owners of the site to pursue compliance and due-diligence to FCC and OSHA regulations regarding human exposure to electromagnetic radiation as well as other safety related issues. Only observances from photographs or the assessor’s notes were used to make assumptions for compliance. It should be noted that the following recommendations are meant as a general guide to compliance. Management for the site may have already addressed certain conditions. Current programs in place have not been reviewed and may be sufficient. It is the responsibility of the management and owners of the site to determine if any of the following recommendations are indeed applicable: SAFETY CONCERNS/RECOMMENDATIONS 1. The site owner/manager should prepare a comprehensive written safety program and train workers on that program so that all company personnel that may be affected by the real or potential hazards in the workplace are aware of their potential exposure to the hazards and have the necessary intellectual and physical tools to allow them to control or mitigate their exposure. As OSHA deems RF energy a physical hazard, the written program must include a section on human exposure to radiofrequency energy for those areas with RF emissions that exceed the applicable limits. Tower-GL & Vertical Communication Site RF Emissions Hazard Assessment. Original Document 5 2. Personnel that require access in close proximity to the antennas should employ LockOut/Tag-Out procedures to isolate the RF source prior to servicing equipment 29 CFR 1910.147(a)(3)(i) This section requires employers to establish a program and utilize procedures for affixing appropriate lockout devices or tagout devices to energy isolating devices, and to otherwise disable machines or equipment to prevent unexpected energization, start up or release of stored energy in order to prevent injury to employees. 1910.147(a)(3)(ii) When other standards in this part require the use of lockout or tagout, they shall be used and supplemented by the procedural and training requirements of this section. Definitions applicable to this section: Affected employee: An employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed. Authorized employee: A person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment. An affected employee becomes an authorized employee when that employee's duties include performing servicing or maintenance covered under this section. Capable of being locked out: An energy isolating device is capable of being locked out if it has a hasp or other means of attachment to which, or through which, a lock can be affixed, or it has a locking mechanism built into it. Other energy isolating devices are capable of being locked out, if lockout can be achieved without the need to dismantle, rebuild, or replace the energy isolating device or permanently alter its energy control capability. Energized: Connected to an energy source or containing residual or stored energy. Energy isolating device: A mechanical device that physically prevents the transmission or release of energy, including but not limited to the following: A manually operated electrical circuit breaker; a disconnect switch; a manually operated switch by which the conductors of a circuit can be disconnected from all ungrounded supply conductors, and, in addition, no pole can be operated independently; a line valve; a block; and any similar device used to block or isolate energy. Push buttons, selector switches and other control circuit type devices are not energy isolating devices. Energy source: Any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy. Lockout: The placement of a lockout device on an energy isolating device, in accordance with an established procedure, ensuring that the energy isolating device and the equipment being controlled cannot be operated until the lockout device is removed. Lockout device: A device that utilizes a positive means such as a lock, either key or combination type, to hold an energy isolating device in the safe position and prevent the energizing of a machine or equipment. Included are blank flanges and bolted slip blinds. Servicing and/or maintenance: Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming of machines or equipment and making adjustments or tool changes, where the employee may be exposed to the unexpected energization or startup of the equipment or release of hazardous energy. Tagout: The placement of a tagout device on an energy isolating device, in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed. Tower-GL & Vertical Communication Site RF Emissions Hazard Assessment. Original Document 6 Tagout device: A prominent warning device, such as a tag and a means of attachment, which can be securely fastened to an energy isolating device in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed. 29 CFR 1910.147(c)(1) Energy control program. The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative. Personnel that require access in close proximity to the antennas that cannot be locked out/tagged out for maintenance or installation purposes must have the proper training to allow them to control their exposure. 3. Personnel that require access in close proximity to the antennas that cannot be locked out/tagged out for maintenance or installation purposes must have the proper training to allow them to control their exposure. In addition, the use of RF Personal Protection Monitors (PPM) that match all frequencies at this site should be mandated. Personnel must be trained to the point of Competent and Qualified in the use of these monitors. 4. Any personnel that require access to any tower to a height above six (6) feet must be fully trained in climbing techniques and personal fall arrest systems that meet OSHA specification. 100% tie-off and body harnesses are required per the OSHA Fall Protection Standard. 5. A Red “WARNING” sign should be posted at the base of the tower and indicate at what point RF emissions exceed the FCC Controlled/Occupational standard. 6. The Material Safety Data Sheet for the batteries should be referred to in order to determine if fifteen (15) minutes continuous flushing ability is required for the eyewash station per ANSI Standard 2358.1-1990. 7. 29 CFR §1910.268 (b) (3) Medical and first aid. First aid supplies recommended by a consulting physician shall be placed in weatherproof containers (unless stored indoors) and shall be easily accessible. Each first aid kit shall be inspected at least once a month. Expended items shall be replaced. 29 CFR §1910.151 (b) In the absence of an infirmary, clinic, or hospital in near proximity to the workplace, which is used for the treatment of all injured employees, a person or persons, shall be adequately trained to render first aid. First aid supplies approved by the consulting physicians shall be readily available. 8. 29 CFR §1910.303 (f) Identification of disconnecting means and circuits. Each disconnecting means required by this subpart for motors and appliances shall be legibly marked to indicate its purpose, unless located and arranged so the purpose is evident. Each service, feeder, and branch circuit, at its disconnecting means or overcurrent device, shall be legibly marked to indicate its purpose, unless located and arranged so the purpose is evident. These markings shall be of sufficient durability to withstand the environment involved. Tower-GL & Vertical Communication Site RF Emissions Hazard Assessment. Original Document 7 9. 29 CFR §1926.150 Fire Protection (c) Fire extinguishers must be provided for each 3,000 square feet of the protected building area, or major fraction thereof. Travel distance from any point of the protected area to the nearest fire extinguisher shall not exceed 100 ft. (viii) Portable extinguishers shall be inspected periodically and maintained in accordance with Maintenance and Use of portable fire extinguishers, NFPA No. 10A-1970. Additionally, 29 CFR §1910.157(e)(1 - 3) The employer shall be responsible for the inspection, maintenance and testing of all portable fire extinguishers in the workplace. Portable extinguishers or hose used in lieu thereof under paragraph (d)(3) of this section shall be visually inspected monthly. The employer shall assure that portable fire extinguishers are subjected to an annual maintenance check. Stored pressure extinguishers do not require an internal examination. The employer shall record the annual maintenance date and retain this record for one year after the last entry or the life of the shell whichever is less. The record shall be available to the Assistant Secretary upon request. 10. Un-terminated coaxial cable or hardline should be removed from the site or capped in order to lessen the possibility of RF emissions re-radiating along the cable and entering the equipment room. Any un-terminated lines may constitute an unintentional emitter of RF energy that may introduce RF emissions above the FCC uncontrolled/general public standard into the equipment room. CONCLUSION RF emission readings taken at ground level at the site were below the FCC Uncontrolled/General Population limit for human exposure to Radiofrequency energy as outlined in 47 CFR §1.1301 through §1.1319. However, RF emission readings taken on the tower were above the FCC Uncontrolled/General Population limit and the FCC Controlled/Occupational standard. Only personnel that have been properly trained and that are properly equipped should be allowed to access the upper portion of the tower until a program can be put in place to insure that personnel on the tower on not exposed to RF emissions above federally mandated levels. RF emission readings in the equipment shelter were below the applicable limits. Should transmitter or antenna characteristics at the site change an additional RF hazard assessment would be warranted. The RSI corporate safety staff reviewed this report. For additional information regarding RF safety & compliance visit www.rfcomply.com. Should questions arise concerning any portion of this report, or further information is requested, inquiries should be forwarded to the following: RSI Corporation 1310 Main Kiowa, KS 67070 (888) 830-5648 Fax (866) 825-4324 Tower-GL & Vertical Communication Site RF Emissions Hazard Assessment. Original Document 8 CERTIFICATION The data and information in this report is certified by RSI to be true and correct on this date. I have thoroughly reviewed this site compliance report and believe it to be accurate. Respectfully, Greg Kechter, CUSA Operations Manager RSI Corporation Tower-GL & Vertical Communication Site RF Emissions Hazard Assessment. Original Document 9 Limited Warranty & Disclaimer RSI Corp. disclaims all other warranties either express or implied, including, but not limited to, implied warranties of merchantability and fitness for a particular purpose. This limited warranty gives you specific legal rights. You may have others, which vary from state to state. RSI Corp’s entire liability and your exclusive remedy shall be return of the price paid to RSI Corp. for the assessment. In no event will RSI Corp. be liable for damages, including any loss of profits, lost savings, or other incidental or consequential damages arising out of your use or inability to use the assessment. Because some states do not allow the exclusion or limitation of liability for consequential or incidental damages, the above limitation may not apply to you. RSI Corp. will not be responsible for any matters of legal nature that affect the property or area being assessed on the basis of it being under the responsible ownership or that our client has the legal right to conduct business at this site. RSI Corp. has no control over the area and will not be responsible for any hazards or conditions that exist or for any cost to make repairs, engineering, testing or changes to the site. RSI Corp. does not assume any responsibility for the accuracy of any items of information furnished by others. This is a technical document and may contain minor grammatical and/or spelling errors. Tower-GL & Vertical Communication Site RF Emissions Hazard Assessment. Original Document 10