NAB to FCC: No Reason to Alter RF Exposure Rules

Trade group says current transient exposure rules are clear
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NAB opposes one of the proposed changes to the FCC’s RF exposure rules.

Overall, the trade association has told the agency that very little has changed with regard to RF emissions in the broadcast services since the commission’s last major examination of RF exposure issues in the 1990s. “We are not aware, for example, of any increased RF exposure issues due to the transition to digital television,” writes NAB. “Absent new evidence of a rise in RF exposure issues related to broadcast facilities, there is no basis to make radical changes to RF exposure rules for a broadcast industry with a strong safety record.”

The trade association is focusing specifically on a proposal to reduce the allowable amount of RF emissions for so-called “transient persons” near an antenna. Currently, the FCC allows broadcasters to treat transient persons, which include untrained employees or members of the public, the same as RF-trained employees, provided the “transients” are made aware of their possible exposure and such exposure is only brief and nonrepetitive. The transient exception only applies to “controlled” environments, like “fenced areas near tower sites or antennas on rooftops with locked access.”

The current rules governing transient exposure are clear but what is proposed is not, and will confuse the public and cause implementation problems for broadcasters, says NAB, which adds that the proposed change could severely limit public access near RF sources “for no apparent reason.” The current balance makes sense, continues NAB, which asserts that brief, nonrepetitive exposure to RF emissions at occupational limits does not raise public health concerns. “There is no reason this type of exposure should inhibit activities ranging from air conditioning repair near an antenna to tourists standing on an observation deck of a tall building, particularly assuming those transient persons are made aware of possible exposure.”

Existing RF guidelines incorporate two levels of exposure limits — one for general population/uncontrolled exposure and one for occupational/controlled exposure. The less restrictive occupational/controlled exposure limit applies generally where employees are aware of their potential exposure and can control that.

Under changes to the RF exposure rules the FCC recently adopted, workers in controlled environments must be made aware of their possible exposure by verbal or written communication and must receive training on how they can control their exposure. The stricter general population/uncontrolled exposure limits typically apply to situations where members of the public or employees have no or little knowledge of potential exposure and little means to mitigate their exposure.

Instead of applying the occupational/controlled limits to transient persons, the proposal would instead apply a newly created, and effectively undefined, “general population/controlled” limit, according to NAB. That would “sharply reduce” the allowable RF exposure limits for transient persons — likely requiring significant and costly changes to the way licensees comply with RF exposure rules.

Further, the FCC proposed that transient people should be supervised “by trained occupational personnel within the controlled area where the general population limit is exceeded.” NAB opposes this as well, saying it’s impractical and that the definition of “supervision” isn’t clear.

We’ve reported the commission has been revising its RF exposure limits and policies. Comments on further changes were due to ET Dockets 13-84 and 03-137 by Sept. 3, with replies by Nov. 1.