[arrl-odv:29062] FCC Adopts RF Safety Rules Changes
ODV Earlier this evening the FCC released its decisions on RF Safety issues. I have not fully digested all 159 pages. The title alone may set some kind of record for an FCC decision of this nature: RESOLUTION OF NOTICE OF INQUIRY, SECOND REPORT AND ORDER, NOTICE OF PROPOSED RULEMAKING, AND MEMORANDUM OPINION AND ORDER 1. If you are interested in the subject, the full document is here: https://tinyurl.com/qluvcff. 2. The decision writ large is that the current RF exposure safety limits will remain the same. 3. For amateur radio, it is as I reported earlier to the EC and reflected in the Oct. EC meeting minutes. The routine evaluation exemption at 97.13(c)(1) will be deleted when the Order takes effect – probably a couple of months from now, it depends upon the date of publication in the Federal Register. (Exemptions for many other services similarly were deleted –this was not aimed at amateur radio in any way. It is a broad-based policy decision driven by all sorts of new RF radiating situations popping up, some of which result in gain antennas being much closer to people than expected in 1996 when the rules were last revised.) In the future, amateurs will be subject to the general RF Safety rules based upon the (more generous) occupational/controlled limits. Addressing all the services losing their special exemptions, the Commission states that generally if an RF source was “categorically excluded” from routine evaluation under the old rules, it will most likely still be exempt from routine evaluation under the general rules. With regard to amateur radio in particular, the FCC noted the continued availability and applicability of its 1997 publication OET Bulletin 65 Supplement B (available here: https://tinyurl.com/yarokme2) and Ed Hare’s ARRL book RF Exposure and You. This would be an opportune time for the ARRL staff to quickly come up with a concise explanation of the rules and simple ways to comply to allay concerns that members may have when they hear about this. Maybe Ed’s book already has that and can be leveraged? 73, Dave K3ZJ David R. Siddall Managing Partner DS Law, PLLC 1629 K St. NW, Ste 300 Washington, DC 20006 direct: +1 202 559 4690 Unauthorized Disclosure Prohibited. This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you.
Dave, Ed’s book RF Exposure and You is an excellent resource. For some years now, it has been out of print. For some teaching purposes at our club, I got Ed to send me the text and a statement that I could have copies made, but this approach is clearly out of the question for wider distribution. Staff will need to decide how to respond to the surely increasing demand for this information, along with whatever updates are needed since the last time the book was revised. In the near term, short articles on the web and QST will undoubtedly be the best way to respond to the inevitable flood of questions from the field. 73, Greg, K0GW On Wednesday, December 4, 2019, david davidsiddall-law.com < david@davidsiddall-law.com> wrote:
ODV
Earlier this evening the FCC released its decisions on RF Safety issues.
I have not fully digested all 159 pages. The title alone may set some kind of record for an FCC decision of this nature: *RESOLUTION OF NOTICE OF INQUIRY, SECOND REPORT AND ORDER, NOTICE OF PROPOSED RULEMAKING, AND MEMORANDUM OPINION AND ORDER *
1. If you are interested in the subject, the full document is here: https://tinyurl.com/qluvcff. 2. The decision writ large is that the current RF exposure safety limits will remain the same. 3. For amateur radio, it is as I reported earlier to the EC and reflected in the Oct. EC meeting minutes. The routine evaluation exemption at 97.13(c)(1) will be deleted when the Order takes effect – probably a couple of months from now, it depends upon the date of publication in the Federal Register. (Exemptions for many other services similarly were deleted –this was not aimed at amateur radio in any way. It is a broad-based policy decision driven by all sorts of new RF radiating situations popping up, some of which result in gain antennas being much closer to people than expected in 1996 when the rules were last revised.)
In the future, amateurs will be subject to the general RF Safety rules based upon the (more generous) occupational/controlled limits. Addressing all the services losing their special exemptions, the Commission states that generally if an RF source was “categorically excluded” from routine evaluation under the old rules, it will most likely still be exempt from routine evaluation under the general rules.
With regard to amateur radio in particular, the FCC noted the continued availability and applicability of its 1997 publication OET Bulletin 65 Supplement B (available here: https://tinyurl.com/yarokme2) and Ed Hare’s ARRL book *RF Exposure and You. *
This would be an opportune time for the ARRL staff to quickly come up with a concise explanation of the rules and simple ways to comply to allay concerns that members may have when they hear about this. Maybe Ed’s book already has that and can be leveraged?
73, Dave K3ZJ
*David R. Siddall*
*Managing Partner*
*DS Law, PLLC*
*1629 K St. NW, Ste 300 <https://www.google.com/maps/search/1629+K+St.+NW,+Ste+300+%0D%0A+Washington,+DC+20006?entry=gmail&source=g>*
*Washington, DC 20006 <https://www.google.com/maps/search/1629+K+St.+NW,+Ste+300+%0D%0A+Washington,+DC+20006?entry=gmail&source=g>*
*direct: +1 202 559 4690*
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*Unauthorized Disclosure Prohibited.* This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you.
I did a little more searching around, and found that since I obtained a copy directly from Ed Hare in 2018, the full PDF of all 316 pages of the book is now available on ARRL.org-- http://www.arrl.org/rf-exposure You have to look carefully to find it--it is the second line of the second bullet point under Articles.
From what Dave said in his e-mail to us, it appears that many of the details of the new procedures will be different from those described in Ed's book, and from the worksheets found on the RF Exposure page. All of which means that updating will certainly be necessary. 73, Greg, K0GW
On Thu, Dec 5, 2019 at 7:42 AM G Widin <gpwidin@comcast.net> wrote:
Dave, Ed’s book RF Exposure and You is an excellent resource. For some years now, it has been out of print. For some teaching purposes at our club, I got Ed to send me the text and a statement that I could have copies made, but this approach is clearly out of the question for wider distribution. Staff will need to decide how to respond to the surely increasing demand for this information, along with whatever updates are needed since the last time the book was revised. In the near term, short articles on the web and QST will undoubtedly be the best way to respond to the inevitable flood of questions from the field. 73, Greg, K0GW
On Wednesday, December 4, 2019, david davidsiddall-law.com < david@davidsiddall-law.com> wrote:
ODV
Earlier this evening the FCC released its decisions on RF Safety issues.
I have not fully digested all 159 pages. The title alone may set some kind of record for an FCC decision of this nature: *RESOLUTION OF NOTICE OF INQUIRY, SECOND REPORT AND ORDER, NOTICE OF PROPOSED RULEMAKING, AND MEMORANDUM OPINION AND ORDER *
1. If you are interested in the subject, the full document is here: https://tinyurl.com/qluvcff. 2. The decision writ large is that the current RF exposure safety limits will remain the same. 3. For amateur radio, it is as I reported earlier to the EC and reflected in the Oct. EC meeting minutes. The routine evaluation exemption at 97.13(c)(1) will be deleted when the Order takes effect – probably a couple of months from now, it depends upon the date of publication in the Federal Register. (Exemptions for many other services similarly were deleted –this was not aimed at amateur radio in any way. It is a broad-based policy decision driven by all sorts of new RF radiating situations popping up, some of which result in gain antennas being much closer to people than expected in 1996 when the rules were last revised.)
In the future, amateurs will be subject to the general RF Safety rules based upon the (more generous) occupational/controlled limits. Addressing all the services losing their special exemptions, the Commission states that generally if an RF source was “categorically excluded” from routine evaluation under the old rules, it will most likely still be exempt from routine evaluation under the general rules.
With regard to amateur radio in particular, the FCC noted the continued availability and applicability of its 1997 publication OET Bulletin 65 Supplement B (available here: https://tinyurl.com/yarokme2) and Ed Hare’s ARRL book *RF Exposure and You. *
This would be an opportune time for the ARRL staff to quickly come up with a concise explanation of the rules and simple ways to comply to allay concerns that members may have when they hear about this. Maybe Ed’s book already has that and can be leveraged?
73, Dave K3ZJ
*David R. Siddall*
*Managing Partner*
*DS Law, PLLC*
*1629 K St. NW, Ste 300 <https://www.google.com/maps/search/1629+K+St.+NW,+Ste+300+%0D%0A+Washington,+DC+20006?entry=gmail&source=g>*
*Washington, DC 20006 <https://www.google.com/maps/search/1629+K+St.+NW,+Ste+300+%0D%0A+Washington,+DC+20006?entry=gmail&source=g>*
*direct: +1 202 559 4690*
[image: Default Line]
*Unauthorized Disclosure Prohibited.* This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you.
Ed Hare and Rick Lindquist are coordinating with Atty Siddall to get something out quickly to quell any fears, something more substantial for next week's Letter, and then possibly something more complete for long term use. Plans may change as we are tying to digest the report and order. 73, Howard, WB2ITZ On 12/05/2019 2:46 PM, G Widin wrote: I did a little more searching around, and found that since I obtained a copy directly from Ed Hare in 2018, the full PDF of all 316 pages of the book is now available on ARRL.org-- http://www.arrl.org/rf-exposure You have to look carefully to find it--it is the second line of the second bullet point under Articles.
From what Dave said in his e-mail to us, it appears that many of the details of the new procedures will be different from those described in Ed's book, and from the worksheets found on the RF Exposure page. All of which means that updating will certainly be necessary. 73, Greg, K0GW
On Thu, Dec 5, 2019 at 7:42 AM G Widin <gpwidin@comcast.net<mailto:gpwidin@comcast.net>> wrote: Dave, Ed’s book RF Exposure and You is an excellent resource. For some years now, it has been out of print. For some teaching purposes at our club, I got Ed to send me the text and a statement that I could have copies made, but this approach is clearly out of the question for wider distribution. Staff will need to decide how to respond to the surely increasing demand for this information, along with whatever updates are needed since the last time the book was revised. In the near term, short articles on the web and QST will undoubtedly be the best way to respond to the inevitable flood of questions from the field. 73, Greg, K0GW On Wednesday, December 4, 2019, david davidsiddall-law.com<http://davidsiddall-law.com> <david@davidsiddall-law.com<mailto:david@davidsiddall-law.com>> wrote: ODV Earlier this evening the FCC released its decisions on RF Safety issues. I have not fully digested all 159 pages. The title alone may set some kind of record for an FCC decision of this nature: RESOLUTION OF NOTICE OF INQUIRY, SECOND REPORT AND ORDER, NOTICE OF PROPOSED RULEMAKING, AND MEMORANDUM OPINION AND ORDER 1. If you are interested in the subject, the full document is here: https://tinyurl.com/qluvcff. 2. The decision writ large is that the current RF exposure safety limits will remain the same. 3. For amateur radio, it is as I reported earlier to the EC and reflected in the Oct. EC meeting minutes. The routine evaluation exemption at 97.13(c)(1) will be deleted when the Order takes effect – probably a couple of months from now, it depends upon the date of publication in the Federal Register. (Exemptions for many other services similarly were deleted –this was not aimed at amateur radio in any way. It is a broad-based policy decision driven by all sorts of new RF radiating situations popping up, some of which result in gain antennas being much closer to people than expected in 1996 when the rules were last revised.) In the future, amateurs will be subject to the general RF Safety rules based upon the (more generous) occupational/controlled limits. Addressing all the services losing their special exemptions, the Commission states that generally if an RF source was “categorically excluded” from routine evaluation under the old rules, it will most likely still be exempt from routine evaluation under the general rules. With regard to amateur radio in particular, the FCC noted the continued availability and applicability of its 1997 publication OET Bulletin 65 Supplement B (available here: https://tinyurl.com/yarokme2) and Ed Hare’s ARRL book RF Exposure and You. This would be an opportune time for the ARRL staff to quickly come up with a concise explanation of the rules and simple ways to comply to allay concerns that members may have when they hear about this. Maybe Ed’s book already has that and can be leveraged? 73, Dave K3ZJ David R. Siddall Managing Partner DS Law, PLLC 1629 K St. NW, Ste 300<https://www.google.com/maps/search/1629+K+St.+NW,+Ste+300+%0D%0A+Washington,+DC+20006?entry=gmail&source=g> Washington, DC 20006<https://www.google.com/maps/search/1629+K+St.+NW,+Ste+300+%0D%0A+Washington,+DC+20006?entry=gmail&source=g> direct: +1 202 559 4690 Unauthorized Disclosure Prohibited. This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you. -- Howard E. Michel, WB2ITX Chief Executive Officer ARRL, The National Association for Amateur Radio® 225 Main Street, Newington, CT 06111-1494 USA Telephone: +1 860-594-0404 email: hmichel@arrl.org<mailto:hmichel@arrl.org>
participants (3)
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david davidsiddall-law.com -
G Widin -
Michel, Howard, WB2ITX (CEO)