CONFIDENTIAL R.S.I. CORPORATION THE RF SAFETY PROGRAM and TRAINING REQUIREMENTS Basics for developing an effective Site Health and Safety program for all.

CONFIDENTIAL R.S.I. CORPORATIONCONFIDENTIAL R.S.I. CORPORATION

““THE RF SAFETY THE RF SAFETY PROGRAM and TRAINING PROGRAM and TRAINING

REQUIREMENTS”REQUIREMENTS”

• Basics for developing an effective Site Health and Safety program for all hazards at RF sites


MEASUREMENTS FOR OSHA COMPLIANT RF

PROTECTION PROGRAMS by Bob Curtis, Director for RF

Safety, OSHA

• ““RF Safety and Health training is RF Safety and Health training is requiredrequired to to ensureensure that that all employees all employees understandunderstand the the RF hazardsRF hazards to which they to which they may be exposed and the means by which may be exposed and the means by which the hazards are controlled.” (Part of a the hazards are controlled.” (Part of a Written Plan).Written Plan).


OSHA InterpretationOSHA InterpretationOSHA InterpretationOSHA Interpretation

(Cont’d)(Cont’d) (Cont’d)(Cont’d)... ... “that the FCC require its applicants to “that the FCC require its applicants to

implement a implement a Written RF protection ProgramWritten RF protection Program which appropriately addresses traditional safety which appropriately addresses traditional safety and health program elements including training, and health program elements including training, medical monitoring, protective procedures and medical monitoring, protective procedures and engineering controls, signs, hazard assessments, engineering controls, signs, hazard assessments, employee involvement, and designated employee involvement, and designated responsibilities for program implementation.”responsibilities for program implementation.”


OSHA InterpretationOSHA Interpretation

• “ “the uncontrolled environment criteria is an ACTION LIMITACTION LIMIT which determines when an RF protection program is required.” (Note NTIA follows OSHA)

Letter to FCC -Letter to FCC -

0.3 1 3 10 30 100 300 1 3 10 30 1000.3 1 3 10 30 100 300 1 3 10 30 100 0.3 1 3 10 30 100 300 1 3 10 30 1000.3 1 3 10 30 100 300 1 3 10 30 100

MHzMHzMHzMHz GHzGHzGHzGHz

100100100100

10101010

1111

5555

30303030

.2.2.2.2

mW/cmmW/cm22

mW/cmmW/cm22

AM FM

MPE LAW

Controlled =100%Controlled =100%

Uncontrolled

FCC RulemakingFCC RulemakingFCC RulemakingFCC Rulemaking

Both E&HBelow 300MHz

6 Min TWA

30Min TWA

Cellphones20% reading is OSHA’S ACTION LIMIT

20%


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

0900509005 • 2) The employer shall establish and

maintain a program for the control and monitoring of non-ionizing radiation hazards. This program shall provide employees adequate supervision, training, facilities, equipment, and supplies, for the control and assessment of non-ionizing radiation hazards.


What does OSHA want?What does OSHA want?

• Site-specific program

• Should include an RF Safety Program if potential exposures exceed limits for uncontrolled environments

Docum ent anychanges w ith

M PE evaluation,reta in records.

Perform protectiveaction; ra ise antennas,low er pow er, change

antenna, until RFexposure is m itigated.

M PEindicatesproblem ?

YES

Performphysical RFassessm ent

-Create RFexposure policyfor em ployees

Controlarea

M PEindicatesproblem ?

YES

Create site-specificsafety plan in regardsto the hazard and how

to control exposure.

T rain ALL affectedpersonnel on the

hazard. T ra inees m ustexhibit com petence

after tra ining.

Performphysical RFassessm ent


FCC LicenseFCC License

Being a lessee at a site does not relieve you of any of these obligations!

check with the owners to see if a master site plan exists.

If not, work together to develop one!


Multi-Employer Worksites Multi-Employer Worksites Rules Updated in 1999

• The creator of the hazard must notify and work with the affected entities to find a way to work safely around the hazard

• This is similar to many RF site situations where high-power antennas impact co-located towers or other employees working on or near the site


Power to the antenna must be reduced for as much and as long as necessary to avoid exposing the crew to RF radiation in excess

of the guidelines. CGC #525CGC #525

CONFIDENTIACONFIDENTIALLCONFIDENTIACONFIDENTIALL

R.S.I. CorporationR.S.I. CorporationR.S.I. CorporationR.S.I. Corporation


OET Bulletin 65 OET Bulletin 65 Appendix B Edition 97-01, Appendix B Edition 97-01,

“Legal releases signed by workers willing to accept high exposure levels are not acceptable and may not be used in lieu of corrective measures.”

OSHA wants to know: Are you a Are you a creatingcreating, , exposingexposing, , correctingcorrecting, or , or controlling controlling employer employer or do you fulfill or do you fulfill “multiple roles”?“multiple roles”?

CCOMPANYOMPANY SSAFETY AFETY PPLANSLANS ANDAND TTRAININGRAINING CCOMPANYOMPANY SSAFETY AFETY PPLANSLANS ANDAND TTRAININGRAINING

SafetySafety1.1.2.2.Lock-Out/Tag-OutLock-Out/Tag-Out1.1.2.2.

CONFIDENTIAL R.S.I. CONFIDENTIAL R.S.I. CORPORATIONCORPORATIONCONFIDENTIAL R.S.I. CONFIDENTIAL R.S.I. CORPORATIONCORPORATION


What OSHA says about safety training when

employees have exposure• 1910.1020 (c)(13) “Toxic substance or harmful

physical agent” non-ionizing radiation.

• 1910,1020 (g)(1)Upon an employee’s first entering into employment, and at least annually thereafter, each employer shall inform current employees ….(g)(1)(i) The existence, location, and availability of any records…. Note: The uncontrolled criteria is OSHA’s action limit”


What OSHA says about safety training

What OSHA says about safety training

• It shall consist of on-the-job training or classroom-type training or a combination of both

• The employer shall certify the employees are CompetentCompetent and and have been trained by a QualifiedQualified personperson

OSHA CFR 1910.268© states


Some states have now Some states have now explained what they require:explained what they require: NCDOL NCDOL 13 NCAC 07F .0609 TRAINING13 NCAC 07F .0609 TRAINING

• (2) Employers shall ensure that each affected employee who works in an electromagnetic energy environment with potential RF exposure in excess of the general population/uncontrolled MPE limits stated in 47 CFR 1.1310 has access to and understands the specific site information related to the RF energy and RF fields present at each individual site.


RF Health and Safety RF Health and Safety Protection ProgramsProtection Programs

RF Health and Safety RF Health and Safety Protection ProgramsProtection Programs

Identification and Control of RF Hazard Identification and Control of RF Hazard

Areas.Areas.

Identification and Control of RF Hazard Identification and Control of RF Hazard

Areas.Areas.

1. Hazard areas must be identified

2. Workers must be Trained.


IN SUMMATIONIN SUMMATION• There is no “categorical exclusion from FCC/OSHA”There is no “categorical exclusion from FCC/OSHA” for for

any transmitter that exceeds the FCC MPE LIMITES. any transmitter that exceeds the FCC MPE LIMITES. RF is RF is a physical hazarda physical hazard..

• The only way The only way to have liability protectionto have liability protection from fines or law from fines or law suits (if you are not in compliance with MPE) is to conduct, suits (if you are not in compliance with MPE) is to conduct, at at a minimuma minimum; ;

• an an MPE AnalysisMPE Analysis an an onsite assessmentonsite assessment (sites now (sites now require an “MPE Data Base”), require an “MPE Data Base”),

• have a have a Written Safety PlanWritten Safety Plan for your sites and shops, and for your sites and shops, and

• Train Your WorkersTrain Your Workers. .

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CONFIDENTIAL R.S.I. CORPORATION THE RF SAFETY PROGRAM and TRAINING REQUIREMENTS Basics for developing an effective Site Health and Safety program for all.

Documents

corporation slide

site slide

rf safety program

osha rf safety

corporation rf health

rf hazards

fcc slide

rf radiation