rulemaking proceeding underway at the FCC could mean more signage
around radio facilities and more training for tower workers, but
experts believe it’s unlikely to result in any major changes for
the way most broadcasters operate.
Crest above Albuquerque, N.M., is one of the nation’s biggest
multi-user FM/TV sites. Shown are examples of RF signage at the gate
areas. Photo by Scott Fybush.
really a mass of little corrections and changes,” said Lawrence
Behr, chairman of LBA Group Inc., speaking about the FCC Report and
Order published in the Federal Registerin June.
report comes nearly a decade after the commission opened a proceeding
in 2003 to investigate proposed changes in its rules concerning
“Human Exposure to Radiofrequency Electromagnetic Fields.” That
proceeding lingered at the commission until just a few weeks ago,
when the FCC issued the R&O along with a Further Notice of
Proposed Rulemaking in the original docket (ET Docket 03-137) and a
new Notice of Inquiry that opens a fresh docket, ET Docket 13-84.
split enables the agency to consider two topics. In the original
docket, the NPRM will examine how the FCC determines compliance with
its existing RF exposure limits, while the new docket will examine
whether those limits are still appropriate “in light of more recent
developments.” (Some changes, like clarification of existing rules,
specifically for RF safety training, become effective Aug. 5.)
this all sounds like the sort of obscure FCC process that can yield
unexpected headaches for stations, Behr said that’s not the case
this time around. “For broadcasters, there’s very little here
that will have any impact, and in the current revision even less so.
There’s virtually nothing here that isn’t a technicality.”
duTreil Jr., principal at the consulting firm duTreil, Lundin and
Rackley, said the proceeding hasn’t been on his radar much, saying
the FCC’s rule changes mainly “concern the way RF is measured
from mobile devices.”
why should radio engineers be paying attention at all?
there’s any reason to be concerned, according to experts, it may be
the possibility of new rules stemming from that new docket and from
the further rulemaking in the original docket. Among issues for which
the FCC is seeking public input are transmitter site signage,
transient exposure limits and the possibility of “contact current”
injuries from construction crews working in close proximity to AM
have had to have signs already,” says David Maxson, chief executive
officer of Isotrope LLC and head of RFSigns.com, which sells those
familiar red “DANGER,” orange “WARNING” and yellow “CAUTION”
to Maxson, “For the first time, though, the FCC is specifying what
good practice is and not relying on other agencies.”
will be a little more interactivity between the FCC standards and
OSHA,” said Behr, “only to the extent that the rules seem to be
heading toward tightening up licensee responsibility.”
specific proposal on which the FCC seeks comment would use a modified
version of IEEE’s standards to specify exactly where “NOTICE,”
“CAUTION” and “WARNING” signs should be placed at a
transmitter site. The commission also is taking a harder look at the
question of “transient” exposure, where members of the general
public may be passing through areas of higher RF in areas such as
hiking trails that run in proximity to multiple-user mountaintop FM
and TV sites.
request comment on anticipated costs related to implementing this
proposal for clear definition of compliance boundaries, given that
most sites already likely comply with these proposed requirements,”
the FCC states in the notice. “We intend to allow sufficient time
for licensees to inspect each of their sites for compliance if there
may be any uncertainty.”
radio operators may want to pay attention, too; the proposed new
rules would take away the blanket exemption that formerly saved ham
licensees from having to conduct RF radiation studies. Households
where amateur stations operate should be considered under
“occupational exposure” standards, which may require signage and
education for household members, according to the agency.
proposed rules have the potential to become expensive for a handful
of radio owners whose transmitter sites are in remote areas. The
commission notes that in the past, the agency has allowed warning
signs to be used without physical barriers in areas that the agency
considers “remote.” But the commission seeks comment from
stations about whether it should continue to try to determine the
“remote” nature of a site as it now does, by considering
“evidence of public access, such as litter and trails,” or
whether the commission should automatically require “positive
access control,” as in fences and gates.
setting out its new rules, the FCC also is formalizing its
expectations for station owners to educate employees and contractors
who may be working in areas that exceed general exposure limits.
the mass of minor technical changes that take effect on Aug. 5,
mainly relating to specific methods of determining RF exposure, the
commission is also revising section 1.1310 of its rules for broadcast
stations. The new version of those rules now allows for “transient”
workers whose jobs may involve occasional entry into high-RF zones to
receive warning information verbally, instead of or in addition to
the written warnings now mandated.
said his company’s LBA University has been busy helping RF
operators understand what they’re now required to do by both OSHA
and the FCC.
is a huge amount of interest in training,” Behr said, not only from
broadcasters but also from wireless operators.
those wireless operators who may feel more of the sting from the
FCC’s proposed new rules, as the wireless world has exploded since
the original 2003 docket opened. The bulk of the FCC’s work here
concerns exposure levels, not only from fixed transmitters but from
for the new docket being opened by the FCC, it’s mostly a specific
inquiry that even the experts on broadcast RF exposure are unlikely
to join, according to some observers.
purpose in opening this proceeding is to provide a forum for full and
transparent discussion to determine whether any action may be
appropriate,” the commission states, but the agency notes that its
especially interested in hearing from experts at other federal
agencies — and that the information being sought is specialized,
having to do with different standards for measuring RF exposure
across the human body.
issue in the new inquiry that may be of the most interest to
broadcasters has to do with “contact currents,” the shocks and
burns that can zap construction workers who are near large metal
objects like cranes and metal roofs in close proximity to AM
transmitters. The FCC asks for comment on whether the agency should
provide maps showing where those intense fields (10 volts/meter or
higher) are present, and whether broadcasters already have access to
complicating the matter, the FCC notes, “the AM station may be a
long-standing facility, while recent development has generated the
construction nearby.” The commission is asking broadcasters to
weigh in on whether the station or the developer should bear the cost
of mitigating this issue, and whether the FCC is even the appropriate
agency to ask the question.
been contemplating whether we want to put any comments in and haven’t
made a decision whether we want to or not,” said LBA’s Behr.
“Some broadcasters may look at this and their attorneys may want to
put some stakes in the ground, but I don’t see anything I would
those who do want to file a comment to ET Docket 13-84, the comment
period closes Sept. 3, with reply comments due Nov. 1.