Evaluating Compliance With FCC Guidelines For Human .
Federal Communications CommissionOffice of Engineering & TechnologyEvaluating Compliance with FCCGuidelines for Human Exposure toRadiofrequency Electromagnetic FieldsAdditional Information for Amateur Radio StationsSupplement BOET(Edition 97-01)toBulletin 65 (Edition 97-01)
Evaluating Compliance with FCCGuidelines for Human Exposureto Radiofrequency Electromagnetic FieldsAdditional Informationfor Amateur Radio StationsSUPPLEMENT BEdition 97-01toOET BULLETIN 65Edition 97-01November 1997AUTHORSJerry L. UlcekRobert F. Cleveland, Jr.Standards Development BranchAllocations and Standards DivisionOffice of Engineering and TechnologyFederal Communications CommissionWashington, D.C. 20554
IMPORTANT NOTEThis supplement is designed to be used in connection with the FCC’s OETBulletin 65, Version 97-01. The information in this supplement providesadditional detailed information that can be used for evaluating complianceof amateur radio stations with FCC guidelines for exposure toradiofrequency electromagnetic fields.However, users of this supplementshould also consult Bulletin 65 for complete information on FCC policies,guidelines and compliance-related issues. Definitions of terms used in thissupplement are given in Bulletin 65. Bulletin 65 can be viewed anddownloaded from the FCC’s Office of Engineering and Technology’s WorldWide Web Internet Site: http://www.fcc.gov/oet/rfsafety.
ACKNOWLEDGMENTSThe following individuals and organizations reviewed an early draft of thissupplement. Their valuable comments and suggestions greatly enhanced the accuracy andusefulness of this document, and their assistance is gratefully acknowledged.American Radio Relay League (ARRL) HQ staff and outside advisors:Paul Danzer, N1II, ARRL Assistant Technical EditorWalter L Furr III, K4UNCRobert E. Gold, M.D., WB0KIZ, ARRL RF Safety CommitteeGerald Griffin, M.D., K6NN, ARRL RF Safety CommitteeArthur W. Guy, Ph.D., W7PO, ARRL RF Safety CommitteeEd Hare, W1RFI, ARRL Laboratory SupervisorJohn Hennessee, N1KB, ARRL Regulatory Information SpecialistTom Hogerty, KC1J, ARRL Regulatory Information Branch SupervisorHoward Huntington, K9KM, ARRL Central Division Vice DirectorWayne Irwin, W1KI, ARRL VEC Assistant to the ManagerBart Jahnke, W9JJ, ARRL VEC ManagerZack Lau, W1VT, ARRL Senior Laboratory EngineerRoy Lewellan, P.E., W7EL, ARRL Technical AdvisorJim Maxwell, Ph.D., W6CF, ARRL Pacific Division Vice DirectorGary E. Myers, K9CZB, ARRL RF Safety CommitteeWilliam J. Raskoff, M.D., K6SQL, Chairman, ARRL RF Safety CommitteePeter Richeson, KA5COI,Kazimierz Siwiak, P.E, KE4PT, ARRL RF Safety CommitteeR. Dean Straw, N6BV, ARRL Senior Assistant Technical EditorLarry Wolfgang, WR1B, ARRL Senior Assistant Technical EditorJay Jackson, Wireless Telecommunications Bureau, FCCJohn B. Johnston, Wireless Telecommunications Bureau, FCCFred O. Maia, W5YI Group, Inc., and W5YI-VEC, Inc.Professor Wayne Overbeck, California State University, FullertonEdwin Mantiply, U.S. Environmental Protection Agencyi
TABLE OF CONTENTSPageIntroduction.1-8Section 1: What it Radiofrequency Radiation?. 8-10Section 2: FCC Exposure Guidelines and Their Application.10-14Exposure Environments.11Time and Spatial Averaging.11-14Section 3: Methods of Predicting Human Exposure. 15-21Tables Using Far-Field Formulas.15Tables Derived from NEC Modeling. 16Antenna Modeling.16Prediction Methods and Derivation of Tables.17-20Measurements.21Section 4: Estimating Compliance Distances from TypicalTransmitting Antennas.Tables Based on Far-field Equations.21-4221-30Tables Based on Computer Modeling. 31-39Examples Using Models.40-42Section 5: Controlling Exposure to RF Fields.42-44Conclusion.45Appendix A: Exposure Criteria Adopted by the FCC. 46-47Appendix B: Optional Worksheet and Record of Compliance. 48ii
IntroductionIn 1996, the FCC adopted new guidelines and procedures for evaluating humanexposure to environmental radiofrequency (RF) electromagnetic fields from FCC-regulatedtransmitters. The new guidelines replaced those adopted by the FCC in 1985 (the 1982 RFprotection guides of the American National Standards Institute, ANSI).1 The FCC’sguidelines are used for evaluating exposure from fixed station transmitters and from mobileand portable transmitting devices, such as cellular telephones and personal communicationsdevices, in accordance with FCC responsibilities under the National Environmental Policy Actof 1969 (NEPA).2 These rule changes set new limits on maximum permissible exposure(MPE) levels that apply to all transmitters and licensees regulated by the FCC.The FCC also revised its policy regarding transmitters, facilities and operations forwhich routine evaluation for compliance is required before granting an application. A routineevaluation is a determination as to whether the station conforms to the RF exposurerequirements. For amateur stations, the new policy requires that the station be subject toroutine evaluation when it will be operated above certain power levels. In the past, althoughamateur stations were expected to comply with the FCC’s guidelines, routine stationevaluation was not required.In August, 1997, the FCC issued a revised technical bulletin, OET Bulletin 653, thatprovides assistance and guidance to applicants and licensees in determining whether proposedor existing transmitting facilities, operations or devices comply with FCC-adopted limits forhuman exposure to RF fields. Although Bulletin 65 provides basic information concerningevaluation for compliance, it is recognized that additional specific guidance and informationmay be helpful for certain specialized categories of stations and transmitters such as radio andtelevision stations and amateur stations. Therefore, supplements to Bulletin 65 have beenprepared to provide this additional information. Supplement A was developed for radio andtelevision broadcasting stations and this supplement (Supplement B) has been prepared foramateur stations. Users of this supplement are also strongly advised to consult Bulletin 65itself for complete information and guidance related to RF guideline compliance. It shouldalso be noted that, although Bulletin 65 and this supplement offer guidelines and suggestionsfor evaluating compliance, they are not intended to establish mandatory procedures, and othermethods and procedures may be acceptable if based on sound engineering practice.1See Report and Order, ET Docket 93-62, FCC 96-326, adopted August 1, 1996, 61 FederalRegister 41006, 11 FCC Rcd 15123 (1997). The FCC initiated this rule-making proceeding in 1993 in responseto the 1992 revision by ANSI of its earlier guidelines for human exposure.2See 47 CFR § 1.1301, et seq.3To view and download OET 65, the website address is: http://www.fcc.gov/oet/1
In general, the information contained in Bulletin 65 and in this supplement is intendedto enable the applicant or amateur to make a reasonably quick determination as to whether aproposed or existing amateur station is in compliance with the exposure guidelines and if not,the steps that can be taken to bring it into compliance.4 Bulletin 65 and this supplementinclude information on calculational methods, tables and figures that can be used indetermining compliance. In addition, amateurs are encouraged to consult Section 4 ofBulletin 65 that deals with controlling exposure. In some cases, e.g., some multiple-emitterlocations such as amateur repeater sites and multi-transmitter contest-style stations,measurements or a more detailed analysis may be required. In that regard, the part of Section2 of Bulletin 65 dealing with multiple transmitter sites and, also, Section 3 of Bulletin 65dealing with measurements and instrumentation provide basic information and references.The new FCC limits for exposure incorporate two tiers of exposure limits based onwhether exposure occurs in an occupational or "controlled" situation or whether the generalpopulation is exposed or exposure is in an "uncontrolled" situation. A detailed discussion ofthe guidelines and adopted limits are included in Bulletin 65.As mentioned, in the FCC’s recent Report and Order, certain amateur radioinstallations were made subject to routine evaluation for compliance with the FCC’s RFexposure guidelines, effective January 1, 1997 (this date was later extended).5 Section 97.13of the Commission’s Rules, 47 C.F.R. § 97.13, requires the licensee to take certain actionsbefore causing or allowing an amateur station to transmit from any place where the operationof the station would cause human exposure to levels of RF fields that are in excess of theFCC guidelines. The licensee must perform the routine evaluation if the transmitter power ofthe station exceeds the levels specified in 47 CFR § 97.13(c)(1) and repeated in Table 1.6Amateurs may use the optional worksheet shown in Appendix B of this supplement to help indetermining whether a routine evaluation is required.All mobile amateur stations are categorically excluded from this requirement. Suchmobile stations are presumed to be used only for very infrequent intermittent two-wayoperation. They are, however, required to comply with the exposure guidelines. Otherwisethe operation is categorically excluded from routine RF radiation evaluation except asspecified in Sections 1.1307(c) and (d) of the FCC’s Rules.4As is the case with all other FCC rules, an amateur station licensee or grantee is responsible forcompliance with the FCC’s rules for RF exposure.5See para. 152 of Report and Order, ET Docket 93-62, (footnote 4). See also, 47 CFR 97.13, as amended.In the FCC’s First Memorandum Opinion and Order in this docket, FCC 96-487, released December 24, 1996,the Commission extended the implementation date of the new guidelines for the amateur radio service to January1, 1998. See 62 Federal Register 3232 (January 22, 1997).6These levels were chosen to roughly parallel the frequency of the MPE limits of Table 1 in Appendix Aof this supplement. These levels were modified from the Commission’s original decision establishing a flat 50W power threshold for routine evaluation of amateur stations (see Second Memorandum Opinion and Order, ETDocket 93-62, FCC 97-303, adopted August 25, 1997).2
Table 1. Power Thresholds for Routine Evaluation of Amateur Radio StationsEvaluation Required ifPower* (watts) Exceeds:Wavelength BandMF160 m500HF80 m50075 m50040 m50030 m42520 m22517 m12515 m10012 m7510 m50VHF (all bands)50UHF70 cm7033 cm15023 cm20013 cm250SHF (all bands)250EHF (all bands)250non-building-mounted antennas: heightabove ground level to lowest point ofantenna 10 m and power 500 W ERPbuilding-mounted antennas:power 500 W ERPRepeater stations (all bands)* Transmitter power PEP input to antenna. For repeater stations only, powerexclusion based on ERP (effective radiated power).3
No station is exempt from compliance with the FCC’s rules and with the MPE limits.However, many amateur stations are categorically exempt from the requirement to perform aroutine station evaluation for compliance. Stations operating at or below the power levelsgiven in Table 1, are not required by the FCC to perform a routine evaluation for compliance.Also, stations using mobile and portable (hand-held) transmitters (as defined by the FCC’srules) are not required to be routinely evaluated.7 Amateur repeater stations transmitting with500 W ERP or less whose antennas are not mounted on buildings, but rather on stand alonetowers, and which are located at least 10 meters above ground are also categorically exemptfrom performing an evaluation. In the case of building-mounted repeater station antennas, theexemption applies regardless of height if the ERP is 500 W or less.Many classes of amateur stations are categorically exempt from the need to do astation evaluation. This is because the circumstances under which exempt stations are usuallyoperated are such that the station is presumed to be in compliance with the MPEs. Undersome circumstances, such as an antenna that is located unusually near people such as anindoor antenna in a living space or a balcony mounted antenna a foot or so away from aneighbor’s balcony, the FCC could require a station evaluation or take other action. FCC ruleparts 1.1307 (c) and 1.1307 (d) could require that in cases where a station is categoricallyexempt, the FCC can require additional action, including a station evaluation, be taken by thestation licensee if the FCC believes there is reason to believe that the exposure levels arebeing exceeded.Although not required by the FCC’s rules, it is advisable that mobile stations also beconsidered for potential exposure before an amateur automatically applies the categoricalexemption. As an example, a 500-watt, 10-meter mobile installation with a vehicle mountedantenna would certainly merit a closer look. On VHF, the use of a high-power amplifiercould also present problems in some cases. In general, it is recommended that in these higherpowered installations, the antenna be located such that the vehicle occupants will be shieldedfrom the antenna during normal use. One good location is in the center of an all-metal roof.Locations to be avoided for high-power operation would be a trunk-mounted antenna, orinstallation on a vehicle with a fiberglass roof. In general, mobile installations, evenhigher-powered ones, should not exceed the MPEs if sound installation guidelines arefollowed. The ARRL Handbook and ARRL antenna books, available from the ARRL, haveadditional material on mobile installations and antennas (see footnote 9).7The FCC has defined "mobile" devices as those designed to be used in other than fixed locations and to beused in such a way that a separation distance of at least 20 cm is normally maintained between the transmitter’sradiating structure(s) and the body of the user or nearby persons. The FCC defines "portable" devices as thosedesigned to be used so that the radiating structure(s) of the device is/are within 20 cm of the body of the user.For example, this definition would apply to handheld cellular phones. Although amateur mobile and portable(handheld) PTT devices are categorically exempt from routine evaluation, users are cautioned to be aware thatrelatively high-powered mobile or portable devices can expose persons in their immediate vicinity to significantRF fields under conditions of relatively continuous transmission. An example might be a 100-110 W vehiclemounted mobile antenna that is mounted in such a way (e.g., on a rear window) so that RF fields are createdinside the vehicle. An example of this was noted in the FCC’s measurement survey of typical amateur radiostations that is cited in Footnote 10.4
Even if the regulations do not require an evaluation, there could be a number ofreasons to conduct one anyway. At a minimum, such an evaluation would be good practicefor the time when a station change is made that would require an evaluation. In addition, theresults of an evaluation will certainly demonstrate to the amateur and his or her neighbors thatthe station’s operation is well within the guidelines and is not a cause for concern. In thecase of some of the unusual circumstances described earlier, the FCC’s rules could require anevaluation of a station otherwise categorically exempt. In all cases, regardless of categoricalexemption, the FCC’s rules require compliance with the MPE limits. In most cases, the FCCwill rely on amateurs to determine for themselves how the evaluation requirements apply totheir stations, but under the rules, the FCC does have the flexibility to ask that an evaluationbe performed on any transmitter regulated by the FCC.The Commission’s Report and Order instituted a requirement that amateur licenseexamination question pools will include questions concerning RF environmental safety atamateur stations. Five questions on RF safety are required within each of the first threelevels of written examination elements. Applicants for new amateur licenses mustdemonstrate their knowledge of the FCC Guidelines through the examinations prepared andadministered by the volunteer examiners. The Commission also adopted the proposal of theAmerican Radio Relay League (ARRL) that amateurs should be required to certify, as part oftheir license application process, that they have read and understand our bulletins and therelevant FCC rules. In addition, applicants for new, renewed and modified primary, club,military recreation and radio amateur civil emergency service (RACES) station licenses andapplicants for a reciprocal permit for alien amateur licenses are also required to certify thatthey have read and understood the applicable rules regarding RF exposure.When routine evaluation of an amateur station indicates that exposure to RF fieldscould be in excess of the limits specified by the FCC, the licensee must take action to correctthe problem and ensure compliance (see Section 4 of OET Bulletin 65 on controllingexposure). Such actions could be in the form of modifying patterns of operation, relocatingantennas, revising a station’s technical parameters such as frequency, power or emission typeor combinations of these and other remedies. For example, assume an amateur applicant orlicensee determined that his or her station was in compliance at full power with all relevantFCC limits in all surrounding areas except for one corner of a neighboring property when acertain antenna was aimed in that direction. In such a case, one way of complying would beto simply avoid pointing the antenna in that direction when people are present at that location.Amateur station licensees are also expected to follow a policy of systematic avoidanceof excessive RF exposure. In its Report and Order the Commission said that it will continueto rely upon amateurs, in constructing and operating their stations, to take steps to ensure thattheir stations comply with the MPE limits for both occupational/controlled and generalpublic/uncontrolled situations, as appropriate. In that regard, for a typical amateur stationlocated at a residence, the amateur station licensee and members of his or her immediatehousehold are considered to be in a "controlled environment" and as such are subject to theoccupational/controlled MPE limits. All persons, with particular emphasis on neighbors, whoare not members of an amateur station licensee’s household are considered to be members ofthe general public, because they cannot reasonably be expected to exercise control over their5
exposure. In those cases, general population/uncontrolled exposure MPE limits apply.Similar considerations apply to amateur stations located at places other than a residence.8To qualify for use of the occupational/controlled exposure criteria, appropriaterestrictions on access to high RF field areas must be maintained and educational instruction inRF safety must
HF 80 m 500 75 m 500 40 m 500 30 m 425 20 m 225 17 m 125 15 m 100 12 m 75 10 m 50 VHF (all bands) 50 UHF 70 cm 70 33 cm 150 23 cm 200 13 cm 250 SHF (all bands) 250 EHF (all bands) 250 Repeater stations (all bands) non-building-mounted antennas: height above ground level to lowest point of antenna 10 m and power 500 W ERP building-mounted .
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