FCC and Exposure Limits

[Steve - K4HX]

Anyone seen this or know if/how it will impact amateur radio?

http://transition.fcc.gov/Daily_Releases/Daily_Business/2013/db0422/FCC-13-39A1.pdf

One of the pertinent sections.


138. As stated previously, one goal of the general exemptions from routine RF exposure evaluation proposed here is to avoid specific exemptions for particular services and ensure a consistent set of rules without exceptions. Thus, we propose to delete the special exemptions from evaluation in the Amateur Radio Service in section 97.13(c) of our rules. We appreciate that amateur radio operators are knowledgeable about the appropriate use of their equipment such that separation distances are likely to be maintained to ensure compliance with our exposure limits. However, since the existing amateur exemptions are based only on transmitter power and do not consider separation distance or antenna gain, exempt transmitting antennas that are unusually close to people could potentially lead to non-compliant exposure levels. For example, a separation distance of at least 24 feet would meet our proposed exemption criteria, considering a currently-exempt 50-watt transmitter at VHF in accord with section 97.13(c) and assuming an antenna gain of 6 dBd. Existing classification of amateur exposure as occupational249 is consistent with use of our proposed general exemption criteria based on general population exposure limits because awareness of exposure greater than the general population limits is required in all occupational settings, including amateur households.250 Application of the general exemptions proposed here to amateur radio installations would preclude the possibility of overexposure and require further evaluation only when necessary, giving guidance for both fixed and mobile transmitting antennas. We invite comment as to the impact of this proposal on the amateur community. Parties that support maintaining the current exemption based on power alone are requested to explain how it provides adequate assurance that the public is protected against exposure to RF energy in excess of our limits and the extent of the burden imposed by this proposal. We encourage interested parties to comment on the relative costs and benefits of the proposed changes in this section, as well as those of alternative approaches.

[W7TFO]

Really stupid, unenforceable within any logical regs.

The camel's nose is under the side of the tent....

73DG

[KM1H]

Lie and tell them you use aluminum siding and leaded glass.

Might also be a good reason to lobby the FCC to finally prempt any local tower height restrictions.  I suspect my 2M 1500W and 20dB + of antenna gain could do some damage if it wasnt at about 110'.

[k7yoo]

This is a whole herd of camels. The bottom line is that this is just another tool in the hands of attorneys to add to the homogenizing of living spaces aka CC&R, deed restrictions, etc. it also opens the door (literally) for "inspectors" to come into your abode if they detect radiation levels that tweak their meters, etc.
I don't believe in conspiracy theories, only realities.
We have a whole new generation that could care less about all of the oddball obsolete technology that we enjoy. They are too smart to hit us head on with regulation or outright banning of whatever it is that makes us tick, so they employ attorneys (sorry for the foul language) to incrementally grind us down. Death by a thousand regulations. Not theory, just reality.

[WA3VJB]

What gets me is how regulations will get on the books and rarely go away when they become obsolete, are disproven, or otherwise discredited as to their practical value or intended purpose.

Example: The ban on receivers that can hear signals on a discontinued portion of the spectrum where analog cellular used to live.  It's only been about five years since that type of service was retired.

[DMOD]

This is a whole herd of camels. The bottom line is that this is just another tool in the hands of attorneys to add to the homogenizing of living spaces aka CC&R, deed restrictions, etc. it also opens the door (literally) for "inspectors" to come into your abode if they detect radiation levels that tweak their meters, etc.
I don't believe in conspiracy theories, only realities.
We have a whole new generation that could care less about all of the oddball obsolete technology that we enjoy. They are too smart to hit us head on with regulation or outright banning of whatever it is that makes us tick, so they employ attorneys (sorry for the foul language) to incrementally grind us down. Death by a thousand regulations. Not theory, just reality.

Very true Richard, chip away at rights and privaleges until the populace is so regulated only the regulators and the wealthy can enjoy a hobby.

Please educate yourself on this BS proposed non-exemption and write a response as this is a potentially dangerous proposal.

This c**p is based on the dangerous "Precautionary Principle."

No harm has ever been shown to hams, their households, or neighbors in the 93 years or so of operation in the ARS.

 
Phil - AC0OB

[K1JJ]

Back in the mid-90's, according to the AWA journal,  there was a large number of early pioneering radio men who passed away.  Many were in their mid to late 90's.  These guys were truly the OB's of radio.

Considering the unshielded RF exposure many of these guys had in the early days, this cornvinced me that HF RF has no negative effect on humans. It might even prolong life...

But it's all about perception. If our neighbors think our zero dB gain sky wire on 75M can harm their kids, we have a big problem.

T

[W2VW]

I thought this thread had something to do with Janet Jackson.

[Jim, W5JO]

Recently my optometrist diagnosed my eye problem  as Macular Pucker.  He said that a film forms over some of the fluid in the eye near the center of vision which distorts the vision in parts of the eyeball, leaving clear vision in the center as what appears to be a keyhole.  The optometrist said he had seen this in people who are exposed to high levels or RF. 

That caught my attention so I asked him who those people were?  Seems they were people who worked in the X-ray department at hospitals and doctor's clinics.  I asked if any studies had been completed on the subject and he said the information was anecdotal, limited to his practice and a few others as reported in a business journal.  I haven't had that kind of exposure but have worked around MF and HF frequencies since age 13 with very limited exposure to SHF frequencies .  I am considerably older than that now.

This makes one wonder how many of these reports have made their way to the FCC and could it be why they are looking at this and, being typical governmental agencies making rules to cover their derrièr.

[flintstone mop]

Recently my optometrist diagnosed my eye problem  as Macular Pucker.  He said that a film forms over some of the fluid in the eye near the center of vision which distorts the vision in parts of the eyeball, leaving clear vision in the center as what appears to be a keyhole.  The optometrist said he had seen this in people who are exposed to high levels or RF. 

That caught my attention so I asked him who those people were?  Seems they were people who worked in the X-ray department at hospitals and doctor's clinics.  I asked if any studies had been completed on the subject and he said the information was anecdotal, limited to his practice and a few others as reported in a business journal.  I haven't had that kind of exposure but have worked around MF and HF frequencies since age 13 with very limited exposure to SHF frequencies .  I am considerably older than that now.

This makes one wonder how many of these reports have made their way to the FCC and could it be why they are looking at this and, being typical governmental agencies making rules to cover their derrièr.

Maybe it is not good to press your face against the glass window of a microwave oven.

[K5UJ]

That caught my attention so I asked him who those people were?  Seems they were people who worked in the X-ray department at hospitals and doctor's clinics.  I asked if any studies had been completed on the subject and he said the information was anecdotal, limited to his practice and a few others as reported in a business journal.  I haven't had that kind of exposure but have worked around MF and HF frequencies since age 13 with very limited exposure to SHF frequencies .  I am considerably older than that now.

A business journal isn't exactly a science journal reporting the result of an experiment done in a way to control all variables except the one under study and with a statistically significant population.  BUT, for us, it doesn't matter because X-rays are an entirely different kind of "radiation"--they are at the upper limit of the spectrum where the energy level is so high (above visible light even) that they can ionize, i.e. modify DNA.  That's why you wear lead bibs at the dentists office.  Ultra-violet can do this also.  RF for us is vastly lower in energy level, and is non-ionizing and is harmless (except for when you touch a hot tower   ).

The irony here is that the radio services have been and are now being further burdened with this pending rule, but anyone can walk out into the sunshine with no sunscreen or lay down in a tanning bed and be in much greater danger.  It's really ridiculous when think about it--RF is harmless with a few exceptions* especially at ham power, but beaches and tanning salons are all over the place offering people exposure to ionizing radiation that can in fact lead to skin cancer.  No one is shutting them down (but you wonder what the FCC would do if tanning beds were under their purview) but hams and other communications services are being treated as if they're processing uranium, perhaps because someone thinks something might happen some day.
This is a great example of why the FCC should be primarily a science and engineering agency.


*A few limited situations do call for safety procedures, most all, having to do with protection of workers near or on broadcast towers where RF burns are a risk.

[WD8KDG]

..............and the FCC is toothless to enforce Part 15, where are they gonna get money to enforce RF exposure? More law/regulation for zip return.

Craig,

[K4RT]

I don't understand the basis for including ham stations under the occupational exposure scheme. Paragraph #77 references training.  Could ARRL have put a bug in FCC's ear so it can sell an online training/certification course to generate revenue?

[Steve - K4HX]

Occupational exposure limits are higher than the limits for the general population. So relative to meeting the exposure limit, it is better than amateur stations are including in the occupational category. The idea is that in a business the workers are informed of the exposure and of ways to limit/prevent it, whereas the general public doesn't know and can't do anything to limit their exposure. Hams should have a clue about how RF works and the amount of exposure since they control the entire system and the amount of time the system is transmitting.

[DMOD]

I don't understand the basis for including ham stations under the occupational exposure scheme. Paragraph #77 references training.  Could ARRL have put a bug in FCC's ear so it can sell an online training/certification course to generate revenue?

See paragraph 12:

"In its 2003 Notice in this proceeding,17 the Commission noted that some transmitters and
devices categorically excluded from routine environmental evaluation for RF compliance may be inappropriately excluded and that certain exclusion criteria can be harmonized to govern similar facilities
in different services."

I have not seen any filings from the ARRL as yet.

But the Enviro-wacko's and special interest groups who do radiation measurements have started filing.

http://apps.fcc.gov/ecfs/upload/display?z=x96d0

[DMOD]

..............and the FCC is toothless to enforce Part 15, where are they gonna get money to enforce RF exposure? More law/regulation for zip return.

Craig,

How about the EPA?

[Steve - K4HX]

Technically, since 1996 some amateur radio stations were required to perform an evaluation. You are exempt, if peak-envelope-power (PEP) input to the antenna was less than listed below.


Band         Power
meters       (W)
160           500
80             500
40             500
30             425
20             225
17             125
15             100
12              75
10              50
6                50
2                50
1.25           50
0.7             70
0.33          150
0.23          200
0.13          250

All higher frequency allocations: 250w


Repeaters:

  Non-building-mounted antennas: If the distance between ground level and the lowest point of the antenna is greater than 10 meters and the power is less than 500 W ERP.
 
  Building-mounted antennas: 500 W ERP.


There is a pretty good explanation and evaluation procedure detailed at the link.

http://www.arrl.org/fcc-rf-exposure-regulations-the-station-evaluation

[WD8KDG]

..............and the FCC is toothless to enforce Part 15, where are they gonna get money to enforce RF exposure? More law/regulation for zip return.

Craig,

How about the EPA?

have to LOL about this exposure farce............the hippies on the other side of I-5, "The People's Republic of Eugene", have been having a fit over new electric power meters which transmit data back to the power company. guess the senate & congress don't have anything better to do...............................the US is broke!!!! wonder why?

[W3RSW]

I think I'll move to Greenbank where all the other anti-RF wackos are moving to escape cell tower and TV  rays.

Of course astronomical / direct sky radiation radio waves along with zillions of ionospherically propagated waves from all over the world don't count in their dazzled brains.

And yeah, the daytime sun will bake them all the more at altitude, some thousand feet above sea level.

Innumeracy reigns supreme in "the demon haunted world."

..now ask me as a registered petroleum engineer (R) about fracking ; big bucks and leadership power in starting enviro opposition to that one too.

[DMOD]

Occupational exposure limits are higher than the limits for the general population. So relative to meeting the exposure limit, it is better than amateur stations are including in the occupational category. The idea is that in a business the workers are informed of the exposure and of ways to limit/prevent it, whereas the general public doesn't know and can't do anything to limit their exposure. Hams should have a clue about how RF works and the amount of exposure since they control the entire system and the amount of time the system is transmitting.

Ok, I can see limiting exposure to high power FM where the whole body is close to a resonant wavelength (tissue heating), and not standing in front of a high powered microwave dish (cataracts due to heating), but so do UV radiation from the sun.

From my research, the only real RF issue is tissue heating of the body due to electrical currents in body dielectric materials from 75 MHZ to 6 GHZ.

The problem with this proposal is that all of this so-called exposure mania is based on precautionary concepts of "caution now," science be-d**d.

[Pete, WA2CWA]

Testing 1 2 3 ................................

[Steve - K4HX]

"We will restore science to its rightful place, ......"

"The truth is that, promoting science isn't just about providing resources, it's about protecting free and open inquiry. It's about ensuring that facts and evidence are never twisted or obscured by politics or ideology. It's about listening to what our scientists have to say, even when it's inconvenient, especially when it's inconvenient. Because the highest purpose of science is the search for knowledge, truth and a greater understanding of the world around us. That will be my goal as President of the United States, and I could not have a better team to guide me in this work."


Uh, yea, blah, blah, blah ... not!

[W3RSW]

"Where are the white jackets,  you know, ..the lab jackets?
Gotta have 'he white jackets for my docs."

Statsis scientists.  The new "SS."

[K6JEK]

What do you guys enter for average power in the online calculator for AM with our non-sine wave voices? The ARRL has duty cycle approximations for SSB, CW, and FM but not for AM, at least I didn't see them. The ARRL link (from Steve):

http://www.arrl.org/fcc-rf-exposure-regulations-the-station-evaluation

The link to this online calculator is at the bottom of that page

http://hintlink.com/power_density.htm

It had been awhile since I ran the calculations. I'd forgotten just how easy it is to get over the line on 10M, over that is if there were sunspots and I actually found a reason to operate 10M and when I did if I ran high power, neither of which is true.

[KB2WIG]

I'd just use 100% and work backwards.
klc