Government Regulations Pertaining to Safety.

Radiofrequency and Microwave Radiation Standards
Radiofrequency and Microwave Radiation Standards

CFR 1910.97
OSHA CFR 1910.97: Nonionizing Radiation

1910.268 Telecommunications(p)(3) Protective measures. When an employee works in an area where the electromagnetic radiation exceeds the radiation protection guide, the employer shall institute measures that insure that the employee's exposure is not greater than that permitted by the radiation guide. Such measures shall include, but not be limited to those of an administrative or engineering nature or those involving personal protective equipment.

1926.20 Construction General Safety and Health Provisions
Requires Programs to provide safe work to employees and contractors; (b)(2) includes inspection; (f)(1) employer to provide personal protective equipment; (f)(2) The employer must train each affected employee

1926.54 Nonionizing Radiation
(l) Limits MW to 10 mW/ (NO Time Weighted averaging per OSHA)

CFR 1910.268 (c)
Where training is required, it shall consist of on-the-job training or classroom-type training or a combination of both. The employer shall certify the employees have been trained by preparing a certification record which includes the identity of the person trained, the signature of the employer or the person that conducted the training, and the date the training was completed." With the new RF MPE standards safety training is now required. (Training)

CFR 1910.1020 g 1
Employees are also required to be trained upon first entering into employment and at least annually thereafter. (Training)

CFR 1910.1020 c 13
"Toxic substance or harmful physical agent" means any chemical substance, biological agent, or physical stress (noise, heat, cold, vibration, repetitive motion, ionizing and non-ionizing radiation).(Training)

CPL02-00-124 -
CPL 2-0.124 - Multi Employer Citation Policy. Controlling, correcting, exposing and creating employer all holds equal responsibility. OSHA's multi-employer citation policy is described in compliance directive CPL 2-0.124.1 Under the policy, there are circumstances where more than one employer may be cited for a violation of an OSHA standard, and where an employer may be held responsible for a hazard even though none of its own employees were exposed to it.

OSHA Act of 1970 Sec 5: General Duty
OSHA enforcement actions related to RF exposure of workers are undertaken using OSHA’s "general duty clause," 1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.

29 CFR 1926.500-503 Subpart M
Construction Fall Protection Standard: Must be 100% above 6 foot

The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.

CFR 1910.97
MPE calculation OSHA def of RF

Periodic review
Comprehensive surveys should be performed by people who can bring to your worksite a fresh vision and extensive knowledge of safety, health, or industrial hygiene, i.e., safety professionals, industrial hygienists, ergonomists, etc. Insurance carriers, corporate staffs, private consultants, and the OSHA-funded consultation projects are sources of help in this area.

It is also critical that the Organization’s structure have competent persons available and that they are involved in the implementation and enforcement of the safety program.

1926.21 b 2
The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.

1926 subpart c
Safety Program guidelines

1910.119 App C
Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory). - 1910.119 App C

Bob Curtis
Elements of a Comprehensive RF Protection Program: Role of RF Measurements 

Non-Ionizing Radiation Regulations and Standards
Non-Ionizing Radiation Regulations and Standards

1910.132 - Personal Protective Equipment
(d)(2) Requires hazard assessment to select appropriate PPE ; (f) Training is required

Communication Towers
OSHA information on communication towers.

OSHA's Fall Protection Campaign
OSHA information on Fall Protection.

RF and Microwave Radiation
OSHA information on Radiofrequency and Microwave Radiation.

A Video Message from Dr. David Michaels
This video message was recorded by the Assistant Secretary of Labor for Occupational Safety and Health, Dr. David Michaels. He recorded this message for the National Association of Tower Erectors (NATE) Conference on Feb. 25, 2014.

A Message from James G. Maddux
Memorandum: Protecting the Safety and Health of Communication Tower Workers.

Communication Tower Industry Employer Letter
Communication Tower Industry Employer Letter:

CFR-2010 Title 47: RF Exposure
‘persons are exposed as a consequence of their employment provided those persons are fully aware of the potential for exposure and can exercise control over their exposure’ page 302

Updated Rules on RF Exposure
The FCC's updated rules on RF exposure.
47 CFR Parts 1, 2, and 15

47 CFR Section 1.1306
There are no exceptions. Categorical exclusions are given to those licensees that under most situations would not cause a compliance problem by themselves. They are still bound by the MPE requirements though. As soon as the licensee co-locates with another, the licensee must take into account existing fields caused by these entities. (MPE/HA)

Renewal of license pg 10 worksheet page 14.  Page 33 is signature page"Applicant certifies that grant of this request would not have a significant environmental effect as defined by 47 CFR 1.1307, including compliance for applicable standards for human exposure to radio frequency radiation." The box underneath the above statement on the application form states: "Willful false statements made on this form are punishable by fine and/or imprisonment (U.S.C. Title 18, Sec.1001), and/or revocation of any license or construction permit (U.S.C., Title 47, Sec.503)." (MPE/HA)

47 CFR 1.1307b
In addition to the actions listed  in paragraph (a) of this section, commission action granting construction permits, licenses to transmit or renewals thereof, equipments authorization or modifications in existing facilities, require the preparation of an EA if the particular facility, operation or transmitters would cause human exposure to the level of RF in excess of the limits in 1.1310 and 2.1093 of this chapter (EA)

47 CFR 1.1307b3
actions necessary to bring the area into compliance are the shared responsibility of all licensees whose transmitters produce, at the area in question, power density levels that exceed 5% of the power density exposure limit applicable to their particular transmitter or field strength levels that, when squared, exceed 5% of the square of the electric or magnetic field strength limit applicable to their particular transmitter (HA 5%)

47 CFR 1.1310
The criteria listed in table 1 shall be used to evaluate the environmental impact of human exposure to radiofrequency (RF) radiation as specified in §1.1307(b), (MPE/HA)

 303-s pg 14
Renewal Form. The above categories have been excluded from the RF worksheets not because of a propensity to cause excessive RF radiation, but because a determination of their compliance involves more complex calculations and measurements. (HA)

303-s Renewal
of license page 34 item 6. Environmental Effects. Licensee certifies that the specified facility complies with the maximum permissible radio frequency electromagnetic exposure limits for controlled and uncontrolled environments. Unless the licensee can determine compliance through the use of the RF worksheets in the Instructions to this Form, an Exhibit is required.

303-s Renewal
of license page 39 item 5. Environmental Effects. Licensee certifies that the specified facility complies with the maximum permissible radio frequency electromagnetic exposure limits for controlled and uncontrolled environments.

03-137 Page 14
the OSHA position is that the "uncontrolled" level is strictly an "action" level

47 CFR §1.1307(c) and (d)
§ 1.1307   Actions that may have a significant environmental effect, for which Environmental Assessments (EAs) must be prepared

Telecommunications Act of 1996 
Section 704 page 19 of the hyperlink "No State or local government or instrumentality thereof may regulate the placement, construction, and modification of personal wireless service facilities on the basis of the environmental effects of radio frequency emissions to the extent that such facilities comply with the Commission’s regulations concerning such emissions."

General Info document
Questions and Answers about Biological Effects and Potential Hazards of Radiofrequency Electromagnetic Fields.

04-281 Citation referring to Bulletin 65 pg 12 of link
specifically states that at a multi-user site, such as an antenna farm, actual measurements of the RF field may be necessary to determine whether there is a potential for human exposure in excess of the MPE limits specified by the FCC.

04-281 Commission’s Office of Engineering and Technology 
When considering the contributions to field strength or power density from other RF sources, care should be taken to ensure that such variables such as reflection and re-radiation are considered. In cases involving very complex sites predictions of RF fields may not be possible, and a measurement survey may be necessary.

OET 65 97-01
To meet its requirements under NEPA, the commission has adopted requirements for evaluating the environmental impact of its actions.

OET 65 97-01 page 78
Legal releases signed by employees willing to accept high exposure levels are not acceptable and may not be used in lieu of corrective measures.

C. Caprock
C. Caprock will provide annual training to its employees responsible for environmental compliance to ensure that they are aware of their responsibilities to ensure compliance with environmental requirements by   Caprock. Caprock will oversee any consultant it may employ to ensure compliance with the environmental requirements.

See below, and also note the fact that the Station Mgr did not understand the MPE RF safety law and how to turn off the equipment.

In fact the FCC said  " It is particularly troubling that the station manager is unable to turn off the transmitter given that MBHD’s consulting engineer, who claims that he is the only one who knows how to operate the transmitter, also reports that he has a full-time job maintaining eight major market stations".

Form 601: Application for Wireless
Form 601: Application for Wireless

Transient Individuals
The Commission further notes that the designation of ‘‘transient individual’’ applies to visitors and people traversing the site, not to third- party workers performing maintenance on the site for an extended period.

The National Environmental Policy Act (NEPA) of 1969
requires all the agencies of the Federal government to evaluate the effects of their actions on the quality of the human environment.

PPM Chart
PPM Comparison Chart