© 2017 By Radiofrequency Safety International

Over 2 Centuries of RF Experience on Staff

FAQ Answers

40. Why is lockout required by OSHA when I'm working at some RF sites, and what is it?

Energy-Control Procedure (paragraph (c)(4)(i)). With limited exception, employers must document the procedures used to isolate from its energy source, and render inoperative, equipment prior to servicing, maintenance, or repair by employees. RSI note: RF safety (RF burns, shocks and heating), capacitors, power supplies, and AC/DC power could be hazardous, no RF safety plan is complete without an energy control procedure. These procedures are necessary when activation, start up, or release of stored energy from the energy source is possible, and such release could cause injury to the employees. 

Paragraph (c)(4)(ii) states that the required documentation must clearly and specifically outline the scope, purpose, authorization, rules, and techniques employees are to use to control hazardous energy, and the means to enforce compliance. The document must include at least the following elements: A specific statement regarding the use of the procedure; detailed procedural steps for shutting down, isolating, blocking, and securing machines or equipment to control hazardous energy, and for placing, removing, and transferring lockout or tagout devices, including the responsibility for doing so; and requirements for testing a machine or equipment to determine and verify the effectiveness of lockout or tagout devices, as well as other energy-control measures. The employer uses the information in this document as the basis for informing and training employees about the purpose and function of the energy-control procedures, and the safe application, use, and removal of energy controls. In addition, this information enables employers to effectively identify operations and processes in the workplace that require energy-control procedures. 

Periodic Inspection (c)(6)(ii). Under paragraph (c)(6)(i), employers are to conduct inspections of energy-control procedures at least annually. An authorized employee (other than an authorized employee using the energy-control procedure that is the subject of the inspection) is to conduct the inspection and correct any deviations or inadequacies identified. For procedures involving either lockout or tagout, the inspection must include a review, between the inspector and each authorized employee, of that employer’s responsibilities under the procedure; for procedures using tagout systems, the review also involves affected employees, and includes an assessment of the employees’ knowledge of the training elements required for these systems. Paragraph (c)(6)(ii) requires employers to certify the inspection by documenting the date of the inspection, and identifying the machine or equipment and the employee who performed the inspection. RSI can conduct inspections and certify the documentation, see. Hazard Assessments 

Training and Communication (c)(7)(iv). Paragraph(c)(7)(i) specifies thatemployers must establish a training program that enables employees to understand the purpose and function of the energy-control procedures, and provides them with the knowledge and skills necessary for the safe application, use, and removal of energy controls. According to paragraph(c)(7)(ii), employers are to ensure that: Authorized employees recognize the applicable hazardous-energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control; affected employees obtain instruction in the purpose and use of the energy-control procedure; and other employees who work, or may work, near operations using the energy-control procedure receive training about the procedure, as well as the prohibition regarding attempts to restart or reactivate machines or equipment having locks or tags to control energy release. RSI can provide you with these training means, see Safety Training 

When the employer uses a tagout system, thetraining program must inform employees that: Tags are warning labels affixed to energy-isolating devices, and therefore do not provide the physical restraint on those devices that locks do; they are not to remove tags attached to an energy-isolating devices unless permitted to do so by the authorized employee responsible for the tag, and they are never to bypass, ignore, or in any manner defeat the tagout system; tags must be legible and understandable by authorized and affected employees, as well as other employees who work, or may work, near operations using the energy-control procedure; the materials used for tags, including the means of attaching them, must withstand the environmental conditions encountered in the workplace; tag evoke a false sense of security, and employees must understand that tags are only part of the overall energy-control program; and they must attach tags securely to energy-isolating devices to prevent removal of the tags during use. Note: tag alone do not replace the use of locks. Tags are required as part of the lockout program when locks are used. 

Paragraph (c)(7)(iii) states that employers must retrain authorized and affected employees when a change occurs in: Their job assignments, the machines, equipment, or processes such that a new hazard is present; and the energy-control procedures. Employers also must provide retaining when they have reason to believe, or periodic inspection required under paragraph(c)(6) indicates, that deviations and inadequacies exist in an employee’s knowledge or use of energy-control procedures. The retraining must reestablish employee proficiency and, if necessary, introduce new or revised energy-control procedures. 

Under paragraph (c)(7)(iv), employers are to certify that employees completed the required training, and that this training is up-to-date. The certification is to contain each employee’s name and the training date. 

RSI can certify that your employees are trained. 

Training employees to recognize hazardous-energy sources and to understand the purpose and function of the energy-control procedures, and providing them with the knowledge and skills necessary to implement safe application,use, and removal of energy controls, enables them to prevent serious accidents by using appropriate control procedures in a safe manner to isolate these hazards. In addition, written certification of the training assures the employer that employees receive the training specified by the Standard, at the required frequencies. 

Notification of Employees (paragraph (c)(9)). This provision requires the employer to notify affected employees prior to applying, and after removing, a lockout or tagout device from a machine or equipment. Such notification informs employees of the impending interruption of the normal production operation, and serves as a reminder of the restrictions imposed on them by the energy-control program. In addition, this requirement ensures that employees do not attempt to reactivate a machine or piece of equipment after an authorized employee isolates its energy source and renders it inoperative. Notifying employees after removing an energy-control device alerts them that the machines and equipment are no longer safe for servicing, maintenance, and repair.(1) 

Outside Personnel (Contractors, etc.) (paragraph (f)(2)(i)). When the onsite employer uses an offsite employer (e.g., a contractor) to perform the activities covered by the scope and application of the Standard, the two employers must inform each other regarding their respective lockout or tagout procedures. This provision ensures that onsite employers know about the unique energy-control procedures used by an offsite employer; this knowledge prevents any misunderstanding regarding the implementation of lockout or tagout procedures, including the use of lockout or tagout devices for a particular application. 

Disclosure of Inspection and Training Certification Records (paragraphs(c)(6)(ii) and (c)(7)). The inspection records provide employers with assurance that employees can safely and effectively service, maintain, and repair machines and equipment covered by the Standard. These records also provide the most efficient means for an OSHA compliance officer to determine that an employer is complying with the Standard, and that the machines and equipment are safe for servicing, maintenance, and repair. The training records provide the most efficient means for an OSHA compliance officer to determine whether an employer has performed the required training at the necessary and appropriate frequencies. RSI can provide you with these training records. 

41. I did my RF calculations and the general public is ok, so I should be in compliance right?

Wrong! per the FCC: “Some licensees have determined, by calculations or by other means, that they comply with the limits for the general public and have then assumed that they are fully compliant with our (FCC) exposure limits or otherwise categorically excluded from further action ( See FCC 03-137) . In these cases, licensees have often not considered their responsibilities to ensure compliance for workers who may have access to areas in closer proximity to antenna sites. With respect to fixed transmitters, we have found in implementing our RF exposure guidelines over the past several years that in some cases licensees have failed to take note of the fact that they are responsible for compliance with both the occupational/controlled limits as well as the general population/uncontrolled limits. To make it easier for our licensees and grantees to interpret their responsibilities, we propose to explain in a note to Section 1.1310 of our rules that “fully aware” means that an exposed individual has received written and verbal information concerning the potential for RF exposure and has received training regarding appropriate work practices relating to controlling or mitigating his or her exposure (RSI Note: OSHA also states this per CFR 1910.1020) ...for instance, appropriate signage. We propose to specify that “exercise control” means that an exposed individual is able to reduce or avoid exposure by administrative or engineering work practices, such as use of PPE or time-averaging of exposure”. 

Also the FCC states: For purposes of developing training programs for employees, we (FCC) note that several resources are becoming available to provide guidance on appropriate RF safety programs. These resources include services provided by commercial vendors.

 

42.  All FCC Forms ask about EA/NEPA

Both FCC Form 600’s (Application for Mobile Radio Service Authorization) and FCC Form 854 (Application for Antenna Structure Registration) contain question 28, which asks whether the licensee's proposed action may have a significant environmental effect requiring an EA. If the licensee indicates "NO" to this question, no environmental documentation is required to be filed with the Commission. However, the licensee should maintain all pertinent records and be ready to provide documentation supporting its determination that an EA was not required for the site, in the event that such information is requested by the Bureau pursuant to section 1.1307(d).

If, after consulting the NEPA rules, a licensee determines that its proposed construction does fall under one of the listed categories in section 1.1307(a) or (b), the licensee is required to notify that fact to the Bureau. The licensee must answer “YES” to question 28 on either FCC Forms 600 or 854, and attach an EA to the form filing. Once this question is answered “YES”, the filing is treated as a “major environmental action.” 

43.  Does OSHA require employers with Industrial Heating Equipment and MRIs to do RFR safety training for their employees?

OSHA requires training for any employee exposed to work place hazards. OSHA determined that RFR or non-ionizing radiation is a physical hazard as long ago as 1972. The Federal Communications Commission (FCC) issued new rigorous regulations pertaining to exposure to RF became final in Sept 1, 2000. The FCC is now doing site inspections and enforcement of these rules, all RF Heating units are also controlled by the FCC, they are FCC Type accepted or approved. The new FCC standards are as much as fifty times more stringent than the old OSHA guidelines.

This means that employers with employees who may be exposed to RF above the uncontrolled levels must train those employees in hazard recognition, and hazard avoidance. This training is required in order to provide a safe work environment for your workers as well as yourself. 

44. Who needs an RF Hazard Assessment at an industrial site?

Any company operating heat induction units, heat sealers, RF dryers, hospitals, MRI machines, RF steel tempering, RF soldering or welding.

An RF hazard assessment at an industrial site is similar in some respects to a telecommunications site but very different in other aspects. Equipment is one of the major concerns. RF meters and probes for telecom sites usually have a frequency range from about 300 KHZ to over 50 GHZ, however at industrial sites some equipment runs at below 1KHZ so the equipment is very different. RSI has the only EFA3 (Wandel & Goltermann) in the U.S. at the time of this writing. This unit reads electric and magnetic fields down to 5 Hz. The assessment techniques are similar to those at a telecom site but the procedures are different with each site and type and manufacture of RF equipment. This is due to the widely varied uses of this equipment, the frequency ranges, and the power levels. Example: A steel soldering unit may run 7.5K W at 27 MHZ while a unit for heating pie may run 3 MW at 290 Hz. 

RSI has personnel who have dealt with these types of units for over 20 years and has on staff accredited technicians for these types of units. 

45. What is the NTIA?

The NTIA (National telecommunications and Information Administration) controls all Federal Government radio systems, like the FCC does all private, broadcasting, state and, local government systems. NTIA as a rule must follow all NEPA and OSHA rules also. 

46. Do you need to know where to post your required FCC tower number?

https://www.fcc.gov/help/antenna-structure-registration-asr-help

47. How long can I be in the work area?

The amount of exposure and time is dependent on FCC’s MPE standard and the amount of documented training the personal has had. With training, one can work unabated in the (YELLOW ZONE) up to the FCC's control limits (WARNING RED ZONE). Above the control limits, time averaging can be used only after full on-site assessments of the levels of exposure and an effort to reduce or avoid exposure by administrative or engineering work practices. Be aware, since Sept 2000 that each site user must also meet requirements with respect to “on-tower” or other exposure by workers at the site (including RF exposure on one tower caused by sources on another tower or towers). These requirements include, but are not limited to the reduction or cessation of transmitter power when persons have access to the site, tower, or antenna. Such procedures must be coordinated among all tower users. From FCC Form 303

From FCC viewpoint, licensees and applicants are generally responsible for compliance with both the occupational/controlled exposure limits and the general population/uncontrolled exposure limits in Table 1 as they apply to transmitters under their jurisdiction. Licensees and applicants should be aware that the occupational/controlled exposures limits apply especially in situations were workers may have access to areas in very close proximity to antennas where access to the general public may be restricted.

The Commission’s RF guidelines incorporate two tiers of exposure limits, one for the general public (“general population/uncontrolled” exposure) and another, less restrictive, tier of limits for workers (“occupational/controlled” exposures). The occupational exposure limits are set well below the threshold considered by experts to be potentially harmful, but are higher than those for the general population. The difference in the acceptable exposure levels is based on the premise that workers are aware of their exposure and have the knowledge and means to effectively control their exposure and also on the greater potential for continuous exposure on the part of the public.

The occupational/controlled limits in our rules apply “in situations in which 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.” The limits for occupational/controlled exposure also apply “in situations when an individual is transient through a location where occupational/controlled limits apply provided he or she is made aware of the potential for exposure.” 

The phrase exercise control means that an exposed individual is allowed to reduce or avoid exposure by administrative or engineering work practices, such as use of personal protective equipment or time averaging of exposure.

From the OSHA viewpoint of compliance, OSHA expects all employers to perform hazard assessments of the workplace to determine ALL hazards present, not just RF exposure hazards. In fact, if the company or contractor plans to use any type of Personal Protective Equipment (PPE), the hazard assessment is mandated, per 29CFR 1910.132. In several other sections of the CFR (ex. CFR 1926.28) the regulation requires employers to require “the wearing of appropriate PPE” in hazardous areas. Further more employees who are required to wear such PPE shall be trained on the hazards and use of said PPE. The employer shall verify that affected employees have received and understand the required training through written certification. Where training is required, it shall consist of on-the-job training or classroom-type training or a combination of both. 29CFR 1910.268(c) 

48.  Can I use my Personal Protection Monitor to do time averaging?

The personal protection monitor device is not intended, nor should it be used for direct RF power density measurements. The LED display is provided as a guide to assist in determining which direction to proceed to vacate a hot zone. As with all personal protection monitors, worker training is mandated. Complete familiarization to RF Safety and specific device training is the only way to assure proper operation and safe work practice around sources of RF radiation.

The RadMan is the only personal protection monitor on the market that incorporates both an E (electrical) field and H (magnetic) field sensor. The H (magnetic field) sensor will often alert to hot guy wires or metal objects that are carrying the H field from nearby broadcasters along with E field (electric field) readings (Note: The U.S. RadMan does not work below 3MHz). Also a 100% alarm does not mean that you have six minutes in the area, 100% means it is over the work limit in fact it could be over 1000%! 

49. RF Safety signs Update on Comm Tower Rules - What do the signs mean?

Most all of the Wireless operators and Tower site owner groups and many states are using this outline for installing RFR safety signs. Some older sites still have signs posted under the old 10 mw under OSHA CRF 1910.97 old standard posting the Warning sign at 10mw (Note: This is ten times higher in some cases that the new FCC worker standard and they should be updated). The new FCC standard is down to .2mw for the general population, now there are two standards workers and the General population exposure limits, the following outline and color coding works better to warn workers of the Dangers. Anytime you work above the worker standard there is Danger of RFR. The workers must be “know” before they go into that area of the RFR Danger, they must be warned so the can control the hazard. The time is less than six minutes at that point. Color coding at the site is easy: Blue Signs, you must have permission to be in the area “No Trespassing”, there also could be RF leaks or other signs warning you of higher levels.

OSHA's CRF 1910.145 Specifications for accident prevention signs and tags. 

YELLOW IS A CAUTION AREA 
(i) Caution signs shall be used only to warn against potential hazards or to caution against unsafe practices. 
NOTE: The Uncontrolled Limit is OSH’s action limit. Note: This area is above the general public standard and you must be trained to work in this area under caution.

WARNING (DANGER) SIGNS ARE RED. (i) There shall be no variation in the type of design of signs posted to warn of specific dangers and radiation hazards. NOTE: Above the Controlled Worker Standard. You can not stay in this area more than six minutes.

RSI Note: See the word doc and the MP3 video clip we did with the FCC/OSHA a few years ago. The site used in this RSI video is the Denver site that the FCC uses for training and follows this outline for signage. It's easy to train people with this outline and makes good since, (Yellow signs are always caution areas and Red signs are Stop signs, Danger areas).

(a) Scope. (1) These specifications apply to the design, application, and use of signs or symbols intended to indicate and, insofar as possible, to define specific hazards of a nature such that failure to designate them may lead to accidental injury to workers or the public, or both, or to property damage. These specifications are intended to cover all safety signs except those designed for streets, highways, railroads, and marine regulations.
(2) All new signs and replacements of old signs shall be in accordance with these specifications.
(c) Classification of signs according to use -- (1) Danger signs (Red). (i) There shall be no variation in the type of design of signs posted to warn of specific dangers and radiation hazards. NOTE: Above the Controlled Worker Standard.
(2) Danger signs(WARNING signs). The colors red, black, and white shall be opaque & glossy.
(ii) All employees shall be instructed that danger signs indicate immediate danger and that special precautions are necessary.(ie safety plans and training)
(2) Caution signs. (i) Caution signs shall be used only to warn against potential hazards or to caution against unsafe practices. 
RSI NOTE: The Uncontrolled Limit is OSHA's action limit.


(ii) All employees shall be instructed that caution signs indicate a possible hazard against which proper precaution should be taken. 

Blue NOTICE signs should be posted at the point of access to the site such as at the site entrance gate or near the door to the equipment rooms, as under certain circumstances the RF emissions at the site or in the equipment room MAY exceed the uncontrolled/general population exposure limits.

Yellow CAUTION signs should be posted in areas where the RF assessment has determined RF emissions exceed the FCC Uncontrolled/General Population exposure limits. These may include areas such as at the bases of communications towers where if personnel were to climb may find themselves in RF fields that exceed the FCC Uncontrolled/General population limits, but are less than the Controlled/Occupational limits. 
Note: OSHA has stated that the uncontrolled criteria is the action limit for which a safety program should be implemented.

Red WARNING signs should be posted in advance of the areas that have been determined to have RF emissions levels that exceed the Controlled/Occupational RF limits or borderline Controlled-Occupational/Above Controlled areas. This would include those areas with high power broadcast or paging or areas within a few feet of most other antennas. Note: Personnel that require access to areas where the RF emissions exceed the controlled limits should have a higher level of training in how to control their exposure and limit excursions into the field to 6 minutes for 100% controlled limits, 3 minutes for 200% controlled limits, and 1 minute for 600% controlled limits. An RF safety plan with training is mandated for these environments.

Red WARNING signs Induced or contact current signs, should be placed at any sites with the potential for induced current, i.e. broadcasting sites or industrial facilities with RF heating equipment “Danger areas” (Note don't use metal signs in these areas, they can burn you!)

FOR SIGNS SEE: Safety Signage 

50. I'm not the only licensee, what are my obligations?

Further, the FCC’s rules require that if the MPE limits are exceeded in an accessible area due to the emissions of any transmitters, that 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.”
(FCC 04-281)

It is the unique intention of Section 1.1310 that the contribution of one station alone may not violate the rule, while that station, when joined by the RF contribution of other stations whose total RFR contributions exceed the MPE limits, may find itself in violation. 
(FCC 04-281) 

51. Why would each licensee be required to pay a fine?

It is the unique intention of Section 1.1310 that the contribution of one station alone may not violate the rule, while that station, when joined by the RF contribution of other stations whose total RFR contributions exceed the MPE limits, may find itself in violation. Consequently, we require licensees to work together to ensure compliance. As each of the Mt. Wilson Licensees contributed over 5% of the total RFR exceeding the MPE limits, each of the licensees is equally responsible for bringing the area into compliance, according to Section 1.1307 of our Rules. Because the Mt. Wilson Licensees failed to bring the area into compliance, each is liable for an individual $10,000 forfeiture, because of its contribution, pursuant to Section 1.1307(b), to the violation of Section 1.1310 of our Rules. By allocating the full forfeiture amount to each of the Mt. Wilson Licensees, we again remind all licensees at multi-user sites that they may be responsible for the full amount of a public safety forfeiture if they do not comply with Sections 1.1307 and 1.1310 of our Rules. (FCC 04-281) 

52. Why measurements instead of calculations? 

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.

Bulletin 65 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. We therefore find that the calculations made by Telemundo in December 2003 do not disprove measurements made by the field agents in July 2002. Where public safety is at issue, we prefer actual measurements to calculations at multi-user antenna sites. (FCC 04-281)

Additionally, some states such as NC require that;
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.

(d) RF Safety Program. When employees are exposed to RF fields in excess of the general population/uncontrolled MPE limits established in 47 CFR 1.1310 as a consequence of their employment, the employer shall develop, implement, and maintain a written safety and health program with site specific procedures and elements based on the electromagnetic radiation hazards present, in accordance with 13 NCAC 07F .0609(g). 

53. Where could I find RF hazards?

Anywhere there is RF equipment being used, like the processing and cooking of foods, heat sealers, vinyl welders, high frequency welders, induction heaters, flow solder machines, communications transmitters, radar transmitters, 802.11 wireless, ion implant equipment, microwave drying equipment, sputtering equipment and glue curing. 

54. Are all the readings going to be the same each time they are taken?

The FCC States that Obtaining different contribution levels at different points in time is expected at sites (multi-user site RFR violations at Mt. Wilson) that include daily changes in the RF environment based on what main or auxiliary transmitters are operating at any given time at variable power levels. It is precisely this type of publicly accessible, complex, multi-user site that warrants licensee cooperation to ensure the public is protected from exposure to RFR levels above the MPE limit.

All of the (Mt. Wilson Licensees) were also required to submit sworn statements describing their plans to ensure that the fences surrounding the area are shut and that the gates are locked. Each of the four Mt. Wilson Licensees exceeded the five percent limit, therefore each share in the responsibility to bring the area into compliance102 and make the non-compliant area inaccessible to the public.

http://www.fcc.gov/eb/Orders/2004/FCC-04-281A1.html 

55. Why are Tower Site RF Hazard Assessments required?

As of September 2000 tower sites that are collocated must perform an on-site assessment for existing licenses, new license and license renewal. FCC clarified this requirement on the FCC 351A and B Broadcast licenses which requires the power be shut down to safe occupational exposure limits at any time work is being preformed (Instructions - 4/30/03 for FCC form 303-S) April 30 2003 for applicants, licensees, and tower owners. An on-site assessment at telecommunication sites will detect the ambient levels of electromagnetic energy (radiofrequency radiation). There are two parts to meeting FCC requirements. The first part, the more stringent general population or public exposure limits apply in situations in which the general public may be exposed, or in which persons that are exposed as a consequence of their employment may not be fully aware of the potential for exposure or cannot exercise control over their exposure.[1] The second is occupational.

The occupational exposure limits apply in situations in which 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.[2] 

The limits of occupational exposure also apply in situations where an individual is transient through a location where the occupational limits apply, provided that he or she is made aware of the potential for exposure. The FCC 351A and B Broadcast forms requires the power be shut down to safe occupational exposure limits at any time work is being performed.

-------------------------------------------------

[1] 47 C.F.R. § 1.1310, Note 2 to Table 1.

[2] 47 C.F.R. § 1.1310, Note 1 to Table 1. 

3 Id. at 13520-21; 47 C.F.R. § 1.1307(b)(3). 

56. How does the New North Carolina Fall Standard affect RSI?

The New North Carolina fall standard is now law as of Jan. 3, 2005: We received a copy the week of Jan 10.

RSI CORP must follow all sub parts.

13 NCAC 07F.0601

States that the standards applies even during the inspection of communication towers (unlike CFR 1926 sub part M under with inspections are exempt from the sub part).

This means that all work above 6 feet requires at least two employees including at least one competent person.

Any RSI work on rooftops, electrical transmission tower, church steeples, or water towers will require you to build this cost into the bid.

The Client also needs to know that they must hire inspectors that follow this standard (they must follow it with their own employees also) or they are in violation of the law under the NC Standard to. Ground level surveys do not require this, or rooftops with 42 inch or higher guard rails (we don't know if they have them until we go to most sites). 

The good part is that all sites in NC are required to have a hazard assessment analysis before any work. 

There is also a record keeping part, 13 NCAC 07F.068 states that non-ionizing radiation exposure records related to each analysis are to be use as part of the required training. (g) (2) States that: employees shall have access to and understands the specific site information related to RF energy and RF fields present at each individual site. The employer shall certify that employee has been trained by preparing a certification record. The certification record shall be prepared at the completion of the required training. The most current certification record shall be kept available for review by OSHA. 

57. My radio station is going through a voluntary FCC inspection through our State's Alternative Broadcast Inspection Program (ABIP). This inspection is sometimes referred to as ABI Proram. Doesn't this inspection measure and address my stations's RF exposure concerns?

No. Phrases such as, “neither this Agreement nor the inspection will cover inspection of, or analysis for, compliance with the laws, rules, regulations or policies of the FCC or of any other federal, state or local governmental authority relating to environmental matters, including, but not limited to, RF exposure”, are stated in most ABIP agreements. 

The inspection is conducted in the same manner and uses the same procedures as the Standard FCC Enforcement Bureau’s full station inspection. The inspection generally covers review of the public information files, station license, the emergency alert system, and daily and monthly transmitter logs. Verification of proper transmitter power, tower lighting, and tower sign postings may also be a part of the inspection. 

58. On Towers with detuning wires and broadcast towers, what are the hazards, and why is the Safety Climb Cable Hot on some towers?

RSI investigates many RF burns from these types of sites. These sites have a strong potential to induce electrical current in nearby conductive, or metal objects that may lead to RF burns.

NOTE: The tower could also be a mile or more from your site. Explosion of flammable vapors may also occur in fields of high RF. 

RF burns from the safety climb cables and guy wires from high power FM, TV, paging and two-way radio is also a big issue (RSI has found the safety climb cable burned into and laying on the ground). Physical elements, that when combined in a certain manner, may induce a spark sufficient enough to ignite flammable gasses. Contact currents cannot be predicted at all times under certain conditions high currents are possible with low MPE'S reading.

The FCC law says under 47 C.F.R. § 73.49 - Transmission System Fencing Requirements. Antenna towers having radio frequency potential at the base (series fed, detuned, folded unipole, and insulated base antennas,) must be enclosed within effective locked fences or other enclosures. However, individual tower fences need not be installed if the towers are contained within a protective property Fence. The site must be built to prevent RF burn to all personnel including climbers who may be work by detuning wires. 

NOTE: THE FCC IS NOW HANDING OUT LARGE FINES FOR NOT MEETING THIS CFR REQUIREMENT

OSHA Standards 1926.550, Any conductive (metal) object in close proximity of high power RF fields can exhibit the potential for a strong shock or burn.

1926.550(a)(15)(vii): States, Prior to work near transmitter towers where an electrical charge can be induced in the equipment or materials being handled, the transmitter shall be de-energized or tests shall be made to determine if electrical charge is induced on the crane or cables. (an RF MPE survey would not test for induced or contact current for safety you need to also check for hot spots). 1926.550(a)(15)(vii)(c) Combustible and flammable materials shall be removed from the immediate area of these prior to operations.

See Hazard Assessments

The purpose is to prove employees a right of access to relevant exposure

1910.1020 c (5) (I) Requires: Workplace monitoring or measuring of harmful physical agent relevant to interpretation of the results obtained

1910.1020 c 8 Exposure or exposed means that an employee is subjected to harmful physical agent in the course of employment through any route of entry (contact or absorption), and includes past exposure and potential exposure Whenever an employee requests access, the employer shall provide data 

RF contact current is the current induced onto the body when contact is made with a hot metallic object that is in the vicinity of high-level emitters.

Induced current is the current that is induced into the entire body when an individual is standing in a field created by high power operations.

Any conductive (metal) object in close proximity of high power RF fields can exhibit the potential for a strong shock or burn. If you have a crane, or for that matter any object that could be induced with a charge, you must do testing on it in order to verify that there is not a buildup of current that could pose a shock or burn hazard. per OSHA 1926.550(a)(15)(vii) The FCC rule imposed no limits on induced current or contact current (But the Fencing Requirements is a must). OSHA, however, adopted the ANSI/IEEE C95.1 standard for human exposure to RF which allows only100 milliamps (mA) of induced current in working environments and it must be tested.

Testing for RF current requires a High Level of INDUSTRIAL HYGIENE TRAINING and RF understanding. Workers and the public have the both the need and the Right to Know about RF hazards (Some States list it under their OSHA Hazcom Program). Compliance is now mandated by both OSHA and FCC/NTIA. 

59. I am a government entity what regulations do I need to follow?

The most recent regulation is FCC 47 CFR 1.1310. This is the regulation most government entities are following and the one NTIA has said it will use. Under the consensus standards the government uses the most current standards adopted by a federal agency. One difference, the government entities (NTIA) are also using the ANSI standard for induced and contact current.

Working conditions regulated by other federal agencies under other federal statutes Even when another federal agency is authorized to regulate safety and health working conditions in a particular industry, if it does not do so in specific areas, then OSHA standards apply. 

Under the “Act” federal agency heads are responsible for providing safe and healthful working condition for their employees. The “Act” requires agencies to comply with standards consistent with those OSHA issues for the private sector. 

Federal agency heads are required to operate comprehensive occupational safety and health programs, provide training to employees, and conduct self-audits to evaluate the effectiveness of their programs, and ensure compliance with OSHA. OSHA also conducts comprehensive evaluations of these programs. 

OSHA's federal sector authority is different from that in the private sector in that OSHA cannot impose monetary penalties against another federal agency for failure to comply with OSHA standards. Instead, compliance issues not resolved at local levels are raised to higher levels until resolved. 

State and Local Governments 

OSHA provisions do not apply to state and local governments in their role as employers. The Act does provide that any state desiring to gain OSHA approval for its private sector occupational safety and health programs must provide a program for its state and local government workers that is at least as effective as its program for private employees. State plans may also cover the public sector employees. 

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

60. What is the best type of fence for an AM station?

The law says under 47 C.F.R. § 73.49 – Transmission System Fencing Requirements. Antenna towers having radio frequency potential at the base (series fed, detuned, folded unipole, and insulated base antennas,) must be enclosed within effective locked fences or other enclosures. However, individual tower fences need not be installed if the towers are contained within a protective property Fence. 

A wood fence is ok if it is built strong and high enough. Court cases show that six foot is a good height. As long as you cannot easily pull the boards off the fence it should be ok. Also you must make sure that people and kids can not go under the fence. Induce and contact current safety is the main issue. 

61. Do in building radio system using BDAs have to follow the FCC rules?

Yes: A BDA is used to get cell phone (or other two way radio services) coverage inside of buildings and they are subject to all the FCC and EA rules.

They can cause harmful interference. If this is the case, the RF MPE could be over the General public level also. All equipment must meet the MPE standard. The only way to know if a BDA is in compliance is to measure inside the building. The FCC is starting to do field enforcement actions on these systems. 


http://www.fcc.gov/eb/FieldNotices/2003/DOC-266448A1.html 

62. Does MPE Modeling meet OSHA requirements for worker safety on a site above the MPE level?

You can not blatantly ignore the OSHA safety standards and its required procedures.

A poster child case in Arizona (Aug. 2006), shows the importance of this when the president of the company was convicted of negligent homicide. The tragic result of treating safety laws as optional can harm employees. He failed to provide proper onsite safety testing equipment and training. The company was fined $1.7 million for the death of two workers in a confined space where the company ignored OSHA’S requirements to always do onsite testing to protect worker. OSHA stated that “they treated safety as optional”. The attorney for the president argued that he was not on the job site and did not commit any act to cause the workers deaths. Those arguments however did not prevent him from being convicted of negligent homicide in violating this basic safety standard.

This case should certainly give any company officials pause when they consider not doing onsite testing, and providing lockout tagout, training and equipment to their employees.

This can be applied to Com sites with RF levels above the safe levels and where no onsite testing has been done and not having a good lockout program as required by OSHA under CFR 1910.147, (modeling will not meet this OSHA long standing requirement).

SEE Aug. 2006 CA Worker Comp Alert page 7. 

63. Do any states have specific RF regulations?

Alaska, Minnesota, Hawaii, North Carolina, Massachusetts, and Washington all have specific requirements in their state OSHA programs. New Jersey has requirements for industrial applications in their environmental regulations. Michigan and other states are in the process of writing new programs or updating current programs. 

64. Where are safety Plans required?

OSHA 29 CFR 1926.20(b) 

Accident prevention responsibilities.

1926.20(b)(1) 

It shall be the responsibility of the employer to initiate and maintain such programs as may be necessary to comply with this part.

1926.20(b)(2) 

Such programs shall provide for frequent and regular inspections of the job sites, materials, and equipment to be made by competent persons designated by the employers.

Additionally1926.21(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.

In addition to the federal standards the states of California, Hawaii, Michigan, Minnesota, Nevada, and Washington have specific regulations. 

65. Aren't all 10 Hour classes the same?

RSI conducts specific training and RSI has trainers who “Know RF Telecommunication Sites” from the top of the tower to the inside of the equipment and the studio. 

The most rewarding classes for students are the ones which they can relate to, because the trainer uses examples, pictures and scenarios that come from the students own work environment. RSI has trainers who “Know RF Telecommunication Sites” from the top of the tower to the inside of the equipment and the studio. RSI’S 10 and 30 hour classes are different than a standard run-of-the-mill OSHA 10 hour Construction class. OSHA requires specific training on the hazards that the employees many find at their job site, anyway. RSI just combines this standard OSHA requirement with the 10 hour outreach training in one class! Even if you have a 10 card the RSI is going to help you do your job safer. 

Many Companies and OSHA programs are now requiring Specific 10 hour training also SEE FAQ: #27

NATE/OSHA partnering companies must have their crews and supervisory directors meet specific levels of training. All onsite tower personnel must receive OSHA 10-hour or equivalent training. The focus of that training must be specifically tower safety. Supervisory personnel for tower crews must obtain OSHA 30-hour training or its equivalent. Again the training is to be specific to the factors facing tower workers.

Also Training FAQ No. 4, 10, 11, 12, 13, 14, 15, 19, 20, 22, 23, 24, 28, 38

And Worker's Right to Know: No. 7, 14, 20, 24, 29, 32, 33, 37, 40, 45, 47, 49 

66. What do I have to do to ensure worker safety at my plant?

Survey it: FCC statement: Some licensees have determined, by calculations or by other means that they comply with the limits for the general public and have then assumed that they are fully compliant with our exposure limits or otherwise categorically excluded from further action. In these cases, RF equipment users have often not considered their responsibilities to ensure compliance for workers who many have access to areas in close proximity to RF equipment.

With respect to fixed RF equipment, we (the FCC) have found in implementing our RF exposure guidelines over the past several years that in some users have failed to take note of the fact that they are responsible for compliance with both the controlled limits as well as the general population/uncontrolled limits. ( the General population applies until worker receive training.

Because RF energy is now recognized as a physical hazard,(See OSHA CFR 1910.97) you must consider worker’s and the public’s exposure when planning operation at any location using RF equipment sites, or for that matter, any location where RF energy may be present. 

Therefore to meet FCC and OSHA standards actual hazard assessments must take place. If it is found that the RF is over the limits outlined in the government standards, action must be taken. This may include equipment changes, an environmental assessment, and/or a safety plan. Companies, contractors, government, shops, and sites are all included in having to comply. A general safety plan must be formulated, and employees must be trained. Also, if employees are exposed to RF radiation at any time as part of their employment, they must know the potential hazards associated with RF as part of the OSHA “Right to Know” concept.

If over the levels a safety plan and training is needed

The Occupational Safety and Health Administration (OSHA) has jurisdiction over Federal regulations dealing with worker safety and health. In its comments, OSHA generally endorses our proposal to update our RF exposure guidelines by adopting the new ANSI/IEEE guidelines. OSHA also requires RF users to implement a written RF exposure 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. It notes that the exposure limits in the ANSI/IEEE guidelines may be useful in determining when specific elements of an RF safety program should be implemented. OSHA finds it unacceptable that employees may be subjected to a higher level of risk than the general public simply because they “are aware of the potential for exposure as a concomitant of employment.” Rather, OSHA proposes that we adopt the uncontrolled environment criteria as an “action limit” which determines when an RF protection program will be required. That is, under OSHA's persons who are exposed in excess of the limits specified for uncontrolled environments would be protected by a program designed to mitigate any potential increase in risk. see FEDERAL COMMUNICATIONS COMMISSIONFCC 96-326 Washington, D.C. 20554 In the Matter of ) ) Guidelines for Evaluating the Environmental ) ET Docket No. 93-62 Effects of Radiofrequency Radiation ) ) REPORT AND ORDER 

 

I am a government entity or testing center what regulations do I need to follow?

The most recent regulation is FCC 47 CFR 1.1310. This is the regulation most government entities are following and the one NTIA has said it will use. Under the consensus standards the government uses the most current standards adopted by a federal agency. One difference, the government entities (NTIA) are also using the ANSI standard for induced and contact current. 

67. What would a wireless internet provider and hard line phone companies benefit the most from our services?

Wireless Internet providers still must meet FCC and OSHA requirements, and they also have workers doing the installs so they need all types of required OSHA safety training (from Hazcom, small tools to RF). Many sites they are installing equipment at, already have other high power RF units on the air. The Hard line phone groups are installing T1 and Standard phone lines for wireless, cell, paging, two way radio and broadcasters their workers enter these sites daily. 

General safety training, fall protection, Hazcom, etc., Also they may need assessments but it’s doubtful that they would think so. Assessments would be for places where they may be providing services such as a hotel with BDA’s or leaky coax, WiFi hotspots etc. 

68. Do Electric transmission line towers with Cell/PCS antennas installed on them need to meet the RF safety requirements?

In certain cities across the United States, increasingly common sites are the well recognized yet seldom noticed electric transmission line towers that traverse the cityscapes with not-so-recognized additions. These additions are the ubiquitous cellular phone or PCS phone base station antennas. Due to the fact that many municipalities have set a moratorium on the construction of new cellular/PCS tower sites, many telecommunications companies are looking to preexisting tall structures to mount their much-in-demand base antennas in order to provide ever-expanding coverage for their cellular or PCS phone customers. 

Since the transmission towers are already there, the carrier’s cost of erecting a cellular tower can be saved and those monies allocated for new site acquisitions. This also allows the utility to glean a significant amount of revenue from the telecommunications carriers for joint pole use. 

With the benefits of leasing transmission tower space comes a degree of responsibility on the part of the utility company. The addition of emitters of radiofrequency energy to an already potentially hazardous environment creates an additional problem when it comes to electrical worker safety.

If a lineperson comes into close proximity to the cellular or PCS antennas, and lingers in front of the antennas for too long a time, RF overexposure can occur. Some symptoms of RF overexposure (based on thermal, or heating effects) include confusion or vertigo, nausea and headache among others. Should a lineperson suffer any of these symptoms in an already hazardous work environment, such as changing out insulators or working on transformers or shield wires, the RF overexposure could lead to a lapse in judgment and impact the worker's safety. 

RF exposure can be reduced significantly with an increase in distance from the antennas. RF power density quickly dissipates to a safe level at a certain distance from the antenna. This is similar to the wakes coming off a boat’s propeller. The rapid churning of the water near the propeller is synonymous with the near field or danger area of an antenna, where the homogenous waves that form the wakes in the water is synonymous with the far field of the antenna, where the power density is lowered substantially and poses little if any heating effect. Unfortunately, there is no one set distance one can apply to antennas, as the gain and watts into antennas of different types vary greatly. Even two panel antennas that look exactly alike can have significantly different power levels. The only way to determine minimum safe distances from antennas is through the use of a maximum permissible exposure evaluation. The MPE is derived from an algebraic equation. Again, however, minimum safe distances are not “across the board” like the 10 foot stand-off distance for energized power lines. The distances can vary greatly depending on the power to the antenna. 

After performing an MPE study on the antennas or having performed an actual field strength measurement, the information should be used to create a safety program for line personnel. Properly drafted safety plans should include lock out/tag out procedures if needed as well as any other applicable subjects, i.e., minimum safe distances, accident notification protocol. Classroom and/or hands-on RF safety awareness training that provide the trainee with the necessary information for working around RF energy sources should accompany the plan. The program should probably include the use of RF emissions Personal Protection Monitors (PPM, photo 3.) that warn the wearer when RF emissions exceed the federal limits through a combination of beeps and LCD displays. The RF PPM requires a higher level of training so that workers do not get a false sense of security and rely too heavily on their use. 

For utilities that have their own communications system, such as microwave or land-mobile communications, an MPE evaluation is mandated by the FCC. Though the MPE may indicate there is no harmful RF emanating from the antenna and impacting work or public areas, this information must be discerned and the resulting document kept on file with the FCC transmitter license. 

69. E or H what do I check and can I use calculations near the antennas?

The FCC states very clearly in OET 65 that both E & H fields must be determined if equipment below 300MHz is in use at the site, and if in the near field you should measure to ensure the actual MPE levels. 

  • All electromagnetic emissions have an Electric and Magnetic component (E & H) 

  • The energy (power) of these components are measured in their intensity that passes through a unit area 

  • For RF safety the Power Density must be checked the value understood by the worker (MPE is mW/cm2)