1. “THE RF SAFETY PROGRAM and TRAINING REQUIREMENTS”
Basics for developing an effective Site Health and Safety program for all hazards at RF sites

2. MEASUREMENTS FOR OSHA COMPLIANT RF PROTECTION PROGRAMS by Bob Curtis, Director for RF Safety, OSHA
“RF Safety and Health training is required to ensure that all employees understand the RF hazards to which they may be exposed and the means by which the hazards are controlled.” (Part of a Written Plan).

3. OSHA Interpretation (Cont’d)
... “that the FCC require its applicants to implement a Written RF 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.”

4. OSHA Interpretation
Letter to FCC -
“ “the uncontrolled environment criteria is an ACTION LIMIT which determines when an RF protection program is required.” (Note NTIA follows OSHA)

5. FCC Rulemaking MPE LAW 20% reading is OSHA’S ACTION LIMIT 100
mW/cm2
MPE LAW
100 30 10
Controlled =100% 5
6 Min TWA
Both E&H
Below 300MHz
20% 1
Uncontrolled
30Min TWA .2
20% reading is OSHA’S ACTION LIMIT AM FM
Cellphones
MHz
GHz

6. Some states now explained what they require WAC 296-62-09005
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.

7. What does OSHA want? Site-specific program
Should include an RF Safety Program if potential exposures exceed limits for uncontrolled environments

10. FCC 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!

11. 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

12. 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 #525

13. CONFIDENTIAL
R.S.I. Corporation

14. OET Bulletin 65 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 creating, exposing, correcting, or controlling employer or do you fulfill “multiple roles”?

15. COMPANY SAFETY PLANS AND TRAINING
CONFIDENTIAL R.S.I. CORPORATION
Safety 1. 2.
Lock-Out/Tag-Out
COMPANY SAFETY PLANS AND TRAINING

16. What OSHA says about safety training when employees have exposure
(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”

17. 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 Competent and have been trained by a Qualified person
OSHA CFR © states

18. Some states have now explained what they require: NCDOL 13 NCAC 07F
Some states have now explained what they require: NCDOL 13 NCAC 07F 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 has access to and understands the specific site information related to the RF energy and RF fields present at each individual site.

19. RF Health and Safety Protection Programs
Identification and Control of RF Hazard
Areas.
1. Hazard areas must be identified
2. Workers must be Trained.

20. IN SUMMATION
There is no “categorical exclusion from FCC/OSHA” for any transmitter that exceeds the FCC MPE LIMITES. RF is a physical hazard.
The only way to have liability protection from fines or law suits (if you are not in compliance with MPE) is to conduct, at a minimum;
an MPE Analysis an onsite assessment (sites now require an “MPE Data Base”),
have a Written Safety Plan for your sites and shops, and
Train Your Workers.

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