© 2017 By Radiofrequency Safety International

Over 2 Centuries of RF Experience on Staff

FAQ Answers

70. Do I have to follow the OSHA requirements and does it apply to my group I a small company?

Coverage under the “Act” 

Under the “Act”, an employer is defined as any “person engaged in a business affecting commerce who has employees, but does not include the United States, or any state, or political subdivision of a state”. 

The following are not covered under the “Act”: 

Self-employed persons 
Farms at which only immediate members of the farm employer’s family are employed 
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. 

Standards 

It is the responsibility of OSHA to promulgate legally enforceable standards. It is the responsibility of employers to be familiar with applicable standards and to ensure that employees have and use personal protective equipment (PPE) when required. 

Employees must comply with all rules and regulations, which are applicable to their own actions and conducts. 

Where OSHA has not promulgated specific standards, employers are responsible for following the Act’s general duty clause. 

The general duty clause states that each employer “shall furnish... a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to their employees.” 

Record Keeping and Reporting 

Employers of 11 or more employees must maintain records of occupational injuries and illnesses as they occur (OSHA 300 log or equivalent). These logs must be maintained for a minimum of 5 years at the establishment and must be made available for OSHA.

If an on the job accident occurs that results in the death of an employee or the hospitalization of three or more employees, the accident must be reported in detail to the nearest OSHA office within 8 hours. There are specific OSHA standards, which have additional record keeping requirements. 

71. I have a Radio facility do I need to do a site survey?

Yes your are required to comply per the FCC, and in fact the FCC states that measures ensure compliance. see FCC 96-326 RF Safety Requirements 

6. The Commission has always allowed multiple transmitter sites, i.e., antenna farms, to pool their resources and have only one study done for the entire site. This is very common at sites that have multiple entities such as TV, FM, paging, cellular, etc. In most circumstances, rather than each licensee hiring a separate consultant and submitting a study showing their compliance with the guidelines, one consulting radio technician or radio engineer can be hired by the group of licensees. The consultant surveys the entire site for compliance and gives his recommendations and findings to each of the licensees at the site. 

The licensees can then use the findings to show their compliance with the guidelines. In this way the cost of compliance is minimized as no one licensee has to pay the entire consulting fee, rather just a portion of it. The Commission has determined cost of performing an environmental evaluation is minimal for 87 percent of the businesses required to determine compliance.

Other Compliance Requirements

As was true for the previous rules, there are no specific compliance requirements, as such. Under the Commission’s NEPA rules, applicants and licensees are required to submit an Environmental Assessment (EA) if they do not comply with our RF exposure guidelines (47 CFR  1.1311). An EA is a detailed accounting of the consequences created by a specific action that may have a significant environmental impact, in this case a Commission authorization of a transmitter or facility that exceeds the RF guidelines. An EA would be evaluated by the Commission to determine whether the authorization should be granted in view of the environmental impact. In reality, this leads to a de facto compliance requirement, since most applicants and licensees undertake…measures to ensure compliance before submitting an application in order to avoid the preparation of a costly and time-consuming EA. For this reason EAs are rarely filed with the Commission. This has not changed from the existing rules. 


72. What standard requires me to have a safe work place?

OSHA 

Section 5(a)(1) of the OSH Act, often referred to as the General Duty Clause, requires employers to “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”. Section 5(a)(2) requires employers to “comply with occupational safety and health standards promulgated under this Act”. 

Note: Twenty-four states, Puerto Rico and the Virgin Islands have OSHA-approved State Plans and have adopted their own standards and enforcement policies. For the most part, these States adopt standards that are identical to Federal OSHA. However, some States have adopted different standards applicable to this topic or may have different enforcement policies. 

73. Does OSHA require me to survey and take real RF measurements samples around my RF equipment and antennas?73.

Yes, General Duty Clause, requires employers to “furnish to each of his employees employment and a place of employment which are free from recognized hazards.” 

see http://www.osha.gov/SLTC/samplinganalysis/index.html

Sampling and Analysis

OSHA Standards

Sampling and analysis hazards are addressed in specific standards for the general industry. This page highlights OSHA standards and standard interpretations (official letters of interpretation of the standards) related to sampling and analysis. 

Section 5(a)(1) of the OSH Act, often referred to as the General Duty Clause, requires employers to “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”. Section 5(a)(2) requires employers to “comply with occupational safety and health standards promulgated under this Act”.

Note: Twenty-four states, Puerto Rico and the Virgin Islands have OSHA-approved State Plans and have adopted their own standards and enforcement policies. For the most part, these States adopt standards that are identical to Federal OSHA. However, some States have adopted different standards applicable to this topic or may have different enforcement policies.

Nonionizing radiation. - 1910.97 

Regulations (Standards - 29 CFR) - Table of Contents 

  • Part Number: 1910

  • Part Title: Occupational Safety and Health Standards

  • Subpart: G

  • Subpart Title: Occupational Health and Environment Control

  • Standard Number: 1910.97

  • Title: Nonionizing radiation.

Electromagnetic radiation” - 1910.97(a)(1) 

“Definitions applicable to this paragraph.” 1910.97(a)(1)(i) 

The term “electromagnetic radiation” is restricted to that portion of the spectrum commonly defined as the radio frequency region, which for the purpose of this specification shall include the microwave frequency region.

1910.97(a)(1)(ii) 

“Partial body irradiation.” Pertains to the case in which part of the body is exposed to the incident electromagnetic energy.

1910.97(a)(1)(iii) “Radiation protection guide.” Radiation level which should not be exceeded without careful consideration of the reasons for doing so.

1910.97(a)(1)(iv) 

The word “symbol” as used in this specification refers to the overall design, shape, and coloring of the rf radiation sign shown in figure G-11.

..1910.97(a)(1)(v) 

1910.97(a)(1)(v) 

“Whole body irradiation.” Pertains to the case in which the entire body is exposed to the incident electromagnetic energy or in which the cross section of the body is smaller than the cross section of the incident radiation beam. 

1910.97(a)(2) 

“Radiation protection guide.”

1910.97(a)(2)(i) RSI Note: The newer FCC RF rules 47 CFR 1.1307 replace the older OSHA radiation protection guide listed in (a)(2)(i) and some state have their own standards. For normal environmental conditions and for incident electromagnetic energy of frequencies from 10 MHz to 100 GHz, the radiation protection guide is 10 mW/cm.(2) (milliwatt per square centimeter) as averaged over any possible 0.1-hour period. This means the following: 

Power density: 10 mW./cm.(2) for periods of 0.1-hour or more.
Energy density: 1 mW.-hr./cm.(2) (milliwatt hour per square centimeter) during any 0.1-hour period.

This guide applies whether the radiation is continuous or intermittent. 

1910.97(a)(2)(ii) 

These formulated recommendations pertain to both whole body irradiation and partial body irradiation. Partial body irradiation must be included since it has been shown that some parts of the human body (e.g., eyes, testicles) may be harmed if exposed to incident radiation levels significantly in excess of the recommended levels.

1910.97(a)(3)

 

“Warning symbol.”

1910.97(a)(3)(i) 

The warning symbol for radio frequency radiation hazards shall consist of a red isosceles triangle above an inverted black isosceles triangle, separated and outlined by an aluminum color border. The words “Warning - Radio-Frequency Radiation Hazard” shall appear in the upper triangle. See figure G-11.

..1910.97(a)(3)(ii) 

1910.97(a)(3)(ii) 

American National Standard Safety Color Code for Marking Physical Hazards and the Identification of Certain Equipment, Z53.1-1953 which is incorporated by reference as specified in Sec. 1910.6, shall be used for color specification. All lettering and the border shall be of aluminum color.

1910.97(a)(3)(iii) 

The inclusion and choice of warning information or precautionary instructions is at the discretion of the user. If such information is included it shall appear in the lower triangle of the warning symbol.

1910.97(a)(4) 

“Scope.” This section applies to all radiations originating from radio stations, radar equipment, and other possible sources of electromagnetic radiation such as used for communication, radio navigation, and industrial and scientific purposes. This section does not apply to the deliberate exposure of patients by, or under the direction of, practitioners of the healing arts.

[61 FR 9227, March 7, 1996]

 

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

http://www.osha.gov/SLTC/radiofrequencyradiation/elem_com.html Robert A. Curtis, Director 

US DOL/OSHA Health Response Team

ABSTRACT OSHA recognizes that its most effective activities, including inspections, are those which encourage employers to implement their own comprehensive safety and health program. For work sites involving potentially hazardous radio frequency radiation, OSHA compliance officers should evaluate the RF protection component of the overall program. This presentation outlines the elements of a comprehensive RF Protection Program. These include the implementation of appropriate protective policies based on the potential for excessive RF exposures. Therefore, RF exposure assessments, often requiring direct measurement, are performed to evaluate the effectiveness of RF controls; to ensure proper maintenance of RF radiating equipment; to develop work practices to minimize exposures; to obtain information to be used in training workers regarding their potential hazards and how they are controlled; to identify “RF Hazard” zones and other areas requiring signs and training: 

Element 2: RF hazard identification and periodic surveillance by a competent person who can effectively assess RF exposures. 

Screening measurements are normally sufficient to identify potentially hazardous RF areas which will require some control strategy, such as to determine where a fence should be located. More complex measurements are necessary if the employer intends to allow exposures to employees approaching RF standards. For example, detailed measurements are necessary if whole-body and/or time-weighted averaging of exposures is necessary to bring exposures into compliance. 

RF fields can induce currents in nearby conducting objects, such as a metal barrier or fence used to restrict access to RF hazard areas. These must be evaluated to ensure they do not constitute RF shock and burn hazards. Although detail measurements can be made, the “measurement” of startling/annoying RI spark discharge can usually be made by a quick touch. 

74. Why does RSI perform detailed measurement when they survey RF sites?

OSHA and FCC require safe work practice procedures at RF site in fact Robert A. Curtis, Director, US DOL/OSHA Health Response Team states:

Element 4: Implementation of controls to reduce RF exposures to levels in compliance with applicable guidelines (e.g., ANSI, ICNIRP), including the establishment of safe work practice procedures. 

Reliance on averaging is normally not recommended when establishing basic control strategies because it obligates the employer to conduct “measurement” of employee activity to ensure the averaging is applicable, such as timing an employee’s access inside an area which can not be occupied for 6 minutes without exceeding the allowable time-weighted exposure. Where possible, controls should be establish under the assumption that standards are not time-weighted, i.e., assume the standards are ceiling limits which are not to be exceeded. 

Measurements are necessary during the development of work practices to ensure the practices are effective in preventing excessive exposures. Detailed measurements are required if exposures are approaching guideline limits as discussed above. 

Appropriate work practices must be followed during the repair and maintenance of RF equipment. Occasionally, cabinet panels must be removed by service personnel to allow access for maintenance. Failure to replace a panel properly may result in excessive RF leakage. RF screening measurements can be used to determine which panels can be removed during operation (assuming other hazards, such as electrical shock, are controlled), and to ensure the shielding is reinstalled properly. 

To develop work practices to minimize exposures; to obtain information to be used in training workers regarding their potential hazards and how they are controlled; to identify “RF Hazard” zones and other areas requiring signs and training: to determine the need for medical surveillance; as an alternative or enhancement of Lockout/Tagout procedures; to evaluate the effectiveness of RF personal protective equipment; and as a periodic audit of the effectiveness of the RF Protection Program. http://www.osha.gov/SLTC/radiofrequencyradiation/elem_com.html 

75. What training does OSHA require of my employees?

https://www.osha.gov/Publications/osha2254.pdf

76. I am a Federal Employee, what are my training requirements?

Federal Employee Programs Training Requirements The following training requirements have been excerpted from Title 29, Code of Federal Regulations Part 1960. Note that in addition to these requirements, Part 1910, relating to general industry, also contains applicable training standards.

Financial Management 1960.7(c)(1)

(c) Appropriate resources for an agency’s occupational safety and health program shall include, but not be limited to:

(1) Sufficient personnel to implement and administer the program at all levels, including necessary administrative costs such as training, travel, and personal protective equipment.

Qualifications of Safety and Health Inspectors and Agency Inspectors 1960.25(a)

(a) Executive Order 12196 requires that each agency utilize as inspectors “personnel with equipment and competence to recognize hazards.” Inspections shall be conducted by inspectors qualified to recognize and evaluate hazards of the working environment and to suggest general abatement procedures. Safety and health specialists as defined in 29 CFR 1960.2(s), with experience and/or up-to-date training in occupational safety and health hazard recognition and evaluation are considered as meeting the qualifications of safety and health inspectors. For those working environments where there are less complex hazards, such safety and health specializations as cited above may not be required, but inspectors in such environments shall have sufficient documented training and/or experience in the safety and health hazards of the workplace involved to recognize and evaluate those particular hazards and to suggest general abatement procedures. All inspection personnel must be provided the equipment necessary to conduct a thorough inspection of the workplace involved.

Safety and Health Services 1960.34(e)(1)

(e) Safety and health services. The General Services Administration (GSA) will operate and maintain for user agencies the following services: 

(1) Listings in the “Federal Supply Schedule” of safety and health services and equipment which are approved for use by agencies when needed. Examples of such services are: Workplace inspections, training, industrial hygiene surveys, asbestos bulk sampling, and mobile health testing. Examples of such equipment are: Personal protective equipment and apparel, safety devices, and environmental monitoring equipment.

Agency Responsibilities 1960.39(b)

(b) Agencies shall provide all committee members appropriate training as required by subpart H of this part.

Training of Top Management 1960.54

Each agency shall provide top management officials with orientation and other learning experiences which will enable them to manage the occupational safety and health programs of their agencies. Such orientation should include coverage of section 19 of the Act, Executive Order 12196, the requirements of this part, and the agency safety and health program.

Training of Supervisors 1960.55(a) and (b)

(a) Each agency shall provide occupational safety and health training for supervisory employees that includes: supervisory responsibility for providing and maintaining safe and healthful working conditions for employees; the agency occupational safety and health program; section 19 of the Act; Executive Order 12196; this part; occupational safety and health standards applicable to the assigned workplaces; agency procedures for reporting hazards; agency procedures for reporting and investigating allegations of reprisal; and agency procedures for the abatement of hazards, as well as other appropriate rules and regulations.

Training of Safety and Health Specialists 1960.56(a) and (b)

(b) This supervisory training should include introductory and specialized courses and materials which will enable supervisors to recognize and eliminate, or reduce, occupational safety and health hazards in their working units. Such training shall also include the development of requisite skills in managing the agency’s safety and health program within the work unit, including the training and motivation of subordinates toward assuring safe and healthful work practices.

Training of Safety and Health Inspectors 1960.57

(a) Each agency shall provide occupational safety and health training for safety and health specialists through courses, laboratory experiences, field study, and other formal learning experiences to prepare them to perform the necessary technical monitoring, consulting, testing, inspecting, designing, and other tasks related to program development and implementation, as well as hazard recognition, evaluation and control, equipment and facility design, standards, analysis of accident, injury, and illness data, and other related tasks. 

Training of Collateral Duty Safety and Health Personnel and Committee Members 1926.58

(b) Each agency shall implement career development programs for their occupational safety and health specialists to enable the staff to meet present and future program needs of the agency.

Each agency shall provide training for safety and health inspectors with respect to appropriate standards, and the use of appropriate equipment and testing procedures necessary to identify and evaluate hazards and suggest general abatement procedures during or following their assigned inspections, as well as preparation of reports and other documentation to support the inspection findings.

Within six months after October 1, 1980, or on appointment of an employee to a collateral duty position or to a committee, each agency shall provide training for collateral duty safety and health personnel and all members of certified occupational safety and health committees commensurate with the scope of their assigned responsibilities. Such training shall include: the agency occupational safety and health program; section 19 of the Act; Executive Order 12196; this part; agency procedures for the reporting, evaluation and abatement of hazards; agency procedures for reporting and investigating allegations of reprisal; the recognition of hazardous conditions and environments; identification and use of occupational safety and health standards, and other appropriate rules and regulations.

Training of Employees and Employee Representatives 1960.59(a) and (b)

(a) Each agency shall provide appropriate safety and health training for employees including specialized job safety and health training appropriate to the work performed by the employee, for example: Clerical, printing, welding, crane operation, chemical analysis, and computer operations. Such training also shall inform employees of the agency occupational safety and health program, with emphasis on their rights and responsibilities.

(b) Occupational safety and health training for employees of the agency who are representatives of employee groups, such as labor organizations which are recognized by the agency, shall include both introductory and specialized courses and materials that will enable such groups to function appropriately in ensuring safe and healthful working conditions and practices in the workplace and enable them to effectively assist in conducting workplace safety and health inspections. Nothing in this paragraph shall be construed to alter training provisions provided by law, Executive Order, or collective bargaining arrangements.

Training Assistance 1960.60(a) through (d)

(a) Agency heads may seek training assistance from the Secretary of Labor, the National Institute for Occupational Safety and Health and other appropriate sources.

(b) After the effective date of Executive Order 12196, the Secretary shall, upon request and with reimbursement, conduct orientation for Designated Agency Safety and Health Officials and/or their designees which will enable them to manage the occupational safety and health programs of their agencies. Such orientation shall include coverage of section 19 of the Act, Executive Order 12196, and the requirements of this part.

(c) Upon request and with reimbursement, the Department of Labor shall provide each agency with training materials to assist in fulfilling the training needs of this subpart, including resident and field training courses designed to meet selected training needs of agency safety and health specialists, safety and health inspectors, and collateral duty safety and health personnel. These materials and courses in no way reduce each agency’s responsibility to provide whatever specialized training is required by the unique characteristics of its work.

(d) In cooperation with the Office of Personnel Management, the Secretary will develop guidelines and/or provide materials for the safety and health training programs for high-level managers, supervisors, members of committees, and employee representatives.

Role of the Secretary 1960.85(b)

(b) The Secretary shall provide leadership and guidance and make available equipment, supplies, and staff services to the Field Federal Safety and Health Councils to assist them in carrying out their responsibilities. The Secretary shall also provide consultative and technical services to field councils. These services shall involve aid in any phase of developing and planning programs; and in sponsoring, conducting, or supporting safety and health training courses.

Objectives of Field Councils 1960.87(d) 

(d) To promote coordination, cooperation, and sharing of resources and expertise to aid agencies with inadequate or limited resources. These objectives can be accomplished in a variety of ways. For example, field councils could organize and conduct training programs for employee representatives, collateral duty and professional safety and health personnel, coordinate or promote programs for inspections, or, on request conduct inspections and evaluations of the agencies' safety and health programs. 

77. Why do Federal and state government groups now all use the FCC exposure limits?

This statement is from page 12 of the FCC’S OET 56

The FCC considered a large number of comments submitted by industry, government agencies and the public. In particular, the FCC considered comments submitted by the EPA, FDA, NIOSH and OSHA, which have primary responsibility for health and safety in the Federal Government. The guidelines the FCC adopted were based on the recommendations of those agencies, and they have sent letters to the FCC supporting its decision and endorsing the FCC’s guidelines as protective of public health. 

In its 1996 Order, the FCC noted that research and analysis relating to RF safety and health is ongoing and changes in recommended exposure limits may occur in the future as knowledge increases in this field. In that regard, the FCC will continue to cooperate with industry and with expert agencies and organizations with responsibilities for health and safety in order to ensure that the FCC’s guidelines continue to be appropriate and scientifically valid. 

78. Does OSHA require PPM usage?

1910.268(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 ensure 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.

1910.268(e) 

Tools and personal protective equipment -- Generally. Personal protective equipment, protective devices and special tools needed for the work of employees shall be provided and the employer shall ensure that they are used by employees. Before each day’s use the employer shall ensure that these personal protective devices, tools, and equipment are carefully inspected by a competent person to ascertain that they are in good condition.

NCDOL RFR standard and other states also requires it sometimes.

Hawaii

(d) Wherever the use of personal protective equipment is deemed appropriate or necessitated by exposure to toxic materials or harmful physical agents, employers shall provide this equipment and it shall be used and maintained in a sanitary and reliable condition. 

(e) All employers shall measure, monitor, and record employee exposure to toxic materials or harmful physical agents. The measurement shall determine if any employee may be exposed to concentrations of the toxic materials or harmful physical agents at or above the permissible exposure limit. The determination shall be made each time there is a change in production, process, or control measures which could result in an increase in concentrations of these materials or agents. A written record of the determination shall be made and shall contain at least:

Minnesota Training and information requirements for harmful physical agents 

Step 1. Identify all physical agents 
Ionizing/non-ionizing radiation:

  • identity of sources;

  • exposure limits;

  • health effects of exposure;

  • emergency procedures;

  • safety procedures and control measures;

  • personal protective equipment.

NCDOL13 NCAC 07F .0606 NON-IONIZING RADIATION 

(C) If the transmitter power level can not be reduced or eliminated, an employer may permit its employees to access areas where the occupational/controlled MPE values stated in 47 CFR 1.1310 are exceeded if it implements engineering or administrative controls that comply with the FCC’s regulations concerning such exposure, including limiting the duration of the exposure and utilizing monitoring equipment, RF protective clothing and other related PPE; or NCDOL Training

(g)RF Training.

(1) All employees exposed in excess of the general population/uncontrolled MPE limits stated in 47 CFR 1.1310 shall receive RF hazard awareness training by or under the supervision of a qualified person in the following areas:


(A)MPE Limits for occupational/controlled exposure;
(B)Recognition of RF exposure sources in communication tower work;
(C)Proper use and interpretation of RF exposure;
(D)Work procedures to avoid excessive RF exposure;
(E)Proper use of RF protective clothing and other related PPE;
(F)Symptoms and health issues related to RF exposure; and,
(G)RF exposure first-aid procedure 

79. Do the MPE and other EA rules apply to BPL systems?

Yes and they also must not cause major interference problems [for HF and Ham operators]. BPL systems can operate from 3 MHz to 70 MHz on some new of the newer systems. Some technology notches ranges like the ham bands. Systems have been known to run up to 5000 watts per mile. Power Line workers and home owners will all ask about the safety of BPL so surveys should be done to show compliance. 

Now Direct TV is partnered with Current Technologies to use BPL for home TV BPL in now a bigger issue. 

80. Can't I just install RF warning signs at my site to be in compliance?

Signage alone DOES NOT equal compliance and is not sufficient enough to achieve that compliance. In fact anyone working on sites with a caution or warning signs must be trained per OSHA. And any competent person who has been trained will ask for the site measurements in % of MPE before they enter that site. 

81. Do Co-located operations have anything to with my antennas?

Every RF source counts and for compliance just doing calculations for your antennas at a Co-located site will not provide you with the real RF exposure levels. To meet FCC/OSHA compliance and overall safety, the RF for all antennas must be considered, (even nearby facilities and towers may affect your site). Measurements have the advantage of incorporating the effects of all the RF sources and providing you with the real MPE RF exposure level for your site. 

83. I rent RF suits for my employees to use. That takes care of the RF exposure issues!

According to the OSHA standard 1910.132, the employer must perform and document a workplace assessment to determine if PPE is required, if so the type of PPE. The employer must then train the employees regarding the use, limitations, maintenance, and storage of the equipment, how to don/doff the equipment. The employer must also train on how to inspect the garment prior to each use and ensure that this is accomplished. The employees must demonstrate a full understanding of the required training.

With the RF suit not only would the assessment have to include actual reading in the area of concern but also weigh these and the frequencies against the suit manufactures published data. Additionally if the suit is being worn on a tower the employer must ensure that it has been tested with the use of other PPE required. 

There is also an OSHA interpretation letter stating the RF suit is a “fully encapsulating” suit which requires additional training and in use monitoring. 

84. I just rented an RF suit to climb an AM tower, so I do need to power down?

Most of the RF suits are not designed nor rated to work at AM frequencies and may in fact increase the potential hazard substantially. 

88. What if I have a hazard assessment and it shows I'm out of compliance? What do I need to do?

You need to make the changes to get the site into compliance because by having the hazard assessment you know there is an issue and are admitting guilt if you don’t correct it. 

89. If I want to be Qualified, what do I need to do to teach RF to my staff?

You need to have a combination of experience, safety training, and RSI’s Train the Trainer™ course.

90. I am hiring a temp worker from a staffing agency, am I responsible for their training?

YES! You are responsible for the temps training. Any employer utilizing temporary employees must be aware that no matter what its contract states as to the temporary employee provider responsibility to conduct OSHA safety and health training, the host employer will still be responsible for ensuring that its temporary employees have been properly trained and aware of all safety and health hazards at the worksite. This is especially true if the host employer is supervising the temporary employees, Also, under the OSHA multi-employer citation policy, the host employer will not likely be considered the controlling employer and may be cited for safety and health violations created by the temporary employees. This is a complex issue and employees utilizing a temporary employee provider should look closely at the contract with the provider to And possibly seek legal guidance. Best management practices would established approved training providers which you use for both your company and the temp agency. 

News Release: OSHA launches initiative to protect temporary workers 

91.  Are written Hazcom Programs required by OSHA?

Yes OSHA states “a written hazard communication program” 1910.1200(e)(1) 

Employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified in paragraphs (f), (g), and (h) of this section for labels and other forms of warning, safety data sheets, and employee information and training will be met, and which also includes the following:

1910.1200(e)(1)(i)


A list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet (the list may be compiled for the workplace as a whole or for individual work areas); and,

1910.1200(e)(1)(ii)
The methods the employer will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and the hazards associated with chemicals contained in unlabeled pipes in their work areas. 

99. Does The National Association of Tower Erectors (NATE) still have a partnership with OSHA?

All OSHA partnerships are under rigorous review by OSHA at this time. In fact RSI is in the NATE/OSHA partnership, and we were told to just hold on to our 2009 cards and that we should be receiving new ones later.

the NATE-OSHA partnership was replaced by the STAR program effective October 2011. 

101. I am in Canada, what rules apply to me?

http://www.hc-sc.gc.ca/ewh-semt/consult/_2014/safety_code_6-code_securite_6/final_finale-eng.php

111. I had an OSHA audit and I had no violations so why do I need electromagnetic energy radiation compliance if even the OSHA inspector didn't note a deficiency?

Because 1910.1020(c)(13) notes EMR as a physical agent: “Toxic substance or harmful physical agent” means any chemical substance, biological agent (bacteria, virus, fungus, etc.), or physical stress (noise, heat, cold, vibration, repetitive motion, ionizing and non-ionizing radiation, hypo - or hyperbaric pressure, etc.) 

The OSHA inspector may have been called out on another concern or may have not fully reviewed each and every possible infraction. This doesn’t mean that the next agent wouldn’t find you in violation. This is the same as for noise sampling. If OSHA actually comes out and does a noise study this is a big problem as you should have already had a study for this and any other hygiene issues including Electromagnetic Energy Radiation. 

112. Why do I need an Industrial Electromagnetic Energy Radiation assessment or sampling?

1910.1020 requires it. it is RSI’s hope that you are within guidelines and no problems are found. If this is the case, then the report would be used to provide a baseline and to document compliance. However if issues are found, then a program can be formulated to become compliant based upon the report. Documentation is required and must be provided in employees as electromagnetic energy radiation is a physical agent. 

113. What should you do if you have RFR devices in your work place?

Per the state of Alaska:

Radiofrequency and microwave radiation are both forms of energy called electromagnetic radiation. Sunshine contains three other forms of electromagnetic radiation: ultraviolet rays, infrared (heat) waves, and visible light waves.

These forms of energy are transmitted by waves. The distance between wave peaks is the “wavelength”. The number of wave peaks passing a given point in one second is the “frequency”.

Radiofrequency or radiowaves have a range of frequencies and wavelengths. Very High Frequency (VHF) radiowaves are used for TV and FM radio. Medium Frequency (MF) radiowaves are used for AM radio. Radiofrequency is used in heat sealers and glue driers.

Microwaves are actually just radiowaves of higher frequencies. Microwaves are used for radar and satellite communications, for telephone and TV transmissions, for microwave ovens, and for diathermy in medical clinics.

Electromagnetic radiation can interact with objects (or people) in three different ways. The energy waves can pass through an object without being changed, like light through a window. It can be reflected, like light off a mirror, or it can be absorbed and cause the object to heat up, like a sidewalk in the sun.

The health hazards of electromagnetic radiation are related only to the absorption of energy. The effects of absorbed energy depend on many different factors such as its wavelength and frequency, its intensity and duration. Different materials also absorb energy differently.

Health Hazards
When microwaves or radiowaves are absorbed by body tissues, localized or spot heating can occur. The increased temperature can damage tissues, especially those with poor temperature control such as the lens of the eye.

Cataracts, clouding of the lens of the eye, may occur at the very high energy levels encountered close to radiating radar antennas. Heat damage to tissues is caused by high levels of exposure for short periods of time.

The health effects of low levels of exposure to radiowaves or microwaves for long periods of time are much harder to find and to prove. Some scientific studies show health effects from long-term, lowlevel exposure, other studies do not.

The following list includes health effects which some researchers suspect may be related to excessive radiofrequency/microwave exposure:
- Psychological changes, e.g., insomnia, irritability, mood swings,depression
- Headaches
- Nervous system abnormalities
- Hormonal changes
- Miscarriages and birth defects
- Male Infertility
- Altered immunity
- Leukemia


Of course, many of these health effects are relatively common, and most people having these problems have NOT had excessive exposure to radiofrequency/microwave radiation.

Safety and Health Precautions


Employers who have people working around devices which produce radiofrequency/microwave radiation need to be sure that those devices are properly shielded to prevent leakage of radiation. Safety information regarding proper use and shielding of those devices can usually be obtained from owner/operators manuals, manufacturers, and the Alaska Department of Labor Occupational Safety and Health Section.

Radiofrequency sealers and heaters have been among the major sources of employee exposure to radiofrequency/microwave radiation. When these machines are used, employees should use mechanical or electrical devices that allow them to stay as far away form the source of radiation as possible. Whenever possible, these sealers should be turned off when not being used. Maintenance and adjustment of this type of equipment should be performed only by trained technicians and only when the machines are turned off.

Warnings should be posted to keep everyone away from the source of radiation except for those workers who are absolutely essential to performing the job. 

People who are regularly exposed to significant levels of radiofrequency/microwave radiation should have preemployment and annual physical exams. The doctors should pay careful attention to the eyes to look for cataracts, to the nervous system for any abnormalities to the blood, to detect any early evidence of leukemia, and to the reproductive system to detect any abnormalities. Information concerning the frequency and intensity of the radiation exposures and duration of exposures should be provided to the physician.

In work areas where there is known or suspected to be significant amounts of radiofrequency/microwave radiation present, specialists should measure the amounts of radiation present. If excessive radiofrequency/microwave radiation is detected, modifications in the workplace should be made to reduce radiation exposure of workers. Afterwards, additional measurements should be made to determine if the radiation exposure has been reduced.

Permissible Exposure Limits
The State of Alaska’s permissible exposure limit is specified in Article I of Subchapter 4, Occupational Health and Environmental Control Code [04.0106(a)], Alaska Occupational Safety and Health Standards. For normal environmental conditions and for incident electromagnetic energy of frequencies from 10 MHz to 100 GHz, the radiation protection guide is 10 mW/cm (milliwatts per square centimeter) as averaged over any possible six-minute period.

Further information can be obtained from the Alaska Department of Labor, Occupational Safety and Health Section.

Microwave Cooking Ovens
Microwave ovens used for heating food, when used in accordance with manufacturer’s instructions, do not expose personnel to microwave radiation.

Microwave ovens do not need to be included in an employer’s Hazard Communication program. 

114. Is yearly electromagnetic energy radiation compliance required?

Federal run OSHA states make it a cumbersome to find the answer to this question. You must fully understand several sections of the OSHA requirements and then refer back to the pertinent section to arrive at your answer. Also you must understand that RF could be call: EME/RFE/RFR/non-ionizing and several other labels but they all mean the same thing! The answer is Annual non-ionizing radiation training is required but the below will give you specific as to how to get this answer. 1910.268 (c) highlights training requirements and c (1) states harmful physical substance. In 1910.1020 requires right of access to relevant exposure records if an employee is subjected to a toxic substance or harmful physical agent in the course of employment. 1910.1020(e)(2)(i)(A)(1) requires a record which measures or monitors the amount of a toxic substance or harmful physical agent to which the employee is or has been exposed (this would be the RSI hazard assessment). 1910.1020(g)(1) states: Upon an employee’s first entering into employment, and at least annually thereafter, each employer shall inform current employees covered by this section. 1910.132 (d) require a workplace hazard assessment to determine if hazards are present, or likely to be present, and select the appropriate type of PPE. OET 65 page 9 list the two tiers of exposure which are the controlled and uncontrolled. The FCC states on Page 12 “all transmitting facilities and devices regulated by this Commission that are the subject of an FCC decision or action are expected to comply with the appropriate RF radiation exposure guidelines.”

1910.1020 (g) (1) mandates providing the information to the employees yearly. Even if the site is in compliance, ongoing and yearly sampling is required to prove exposure levels and compliance. 1910.1020(e)(2)(i)(A)(1) This is the same requirement as noise or other particulates. Yearly sampling is needed as changes could have occurred that you are aware of or not aware of. Such things as shields/guards being removed, detuning, leaks, dye changes, line speed variations, new equipment, grounding, element changes, ambient condition changes, voltage changes, peak loads, other process changes all of which could affect spurious radiation and therefore must be reviewed at least annually or when a known change has been made.

Many state run OSHA states have specific requirements and make it easy to see RF training is required annually. For Example: MN states it in their Right to know section. Since most companies work in multiple states industry best management practices dictate the yearly requirement. Also many major carriers require yearly training. Not all OSHA States make it easy to understand that annual RF training is required but luckily RSI industry experts are able knowledgeable and can interpret the OSHA standards for you. Realize annual training is a minimum, but may not be enough, as training is to be provided as often as necessary to provide a safe workplace. The FCC recently issued a consent decree with a major carrier and a requirement of the compliance plan is yearly training. This reiterates that Annual training is required.