12/05/2019

The FCC is amending its Part 97 Amateur Service rules relating to RF exposure safety. In a lengthy document[1] in ET Docket 19-226 released on December 4 that addresses a broad range of RF safety issues, the FCC said current amateur radio RF exposure safety limits will remain unchanged, but that the amateur-specific exemption from having to conduct an RF exposure evaluation will be replaced by the FCC's general exemption criteria. Radio amateurs have always had to comply with RF exposure limits, but certain stations have been exempt from having to conduct evaluations based only upon power and frequency. The Commission indicated that by and large, if an RF source was "categorically excluded" from routine evaluation under the old rules, it will most likely still be exempt under the new rules, which are expected to take effect in the next couple of months.

"For applicants and licensees in the Amateur Radio Service, we substitute our general exemption criteria for the specific exemption from routine evaluation based on power alone in Section 97.13(c)(1) and specify the use of occupational/controlled limits for amateurs where appropriate," the FCC said.

"The sky is not falling here," ARRL Lab Manager Ed Hare, W1RFI, commented. "The major aspects of the rules will not impose major new burdens on the Amateur Radio Service. As in all regulatory matters, though, the devil may be in the details, so the ARRL technical staff, legal staff, and the experts on the ARRL RF Safety Committee are carefully evaluating this FCC document."

Under the revised Section 97.13(c)(1), "In lieu of evaluation with the general population/uncontrolled exposure limits, amateur licensees may evaluate their operation with respect to members of his or her immediate household using the occupational/controlled exposure limits in Section 1.1310, provided appropriate training and information has been accessed by the amateur licensee and members of his/her household," the amended rule says.

"RF exposure of other nearby persons who are not members of the amateur licensee's household must be evaluated with respect to the general population/uncontrolled exposure limits. Appropriate methodologies and guidance for evaluating Amateur Radio Service operation is described in the Office of Engineering and Technology (OET) Bulletin 65, Supplement B[2]," the revised rule concludes.

The FCC said it was not persuaded by ARRL's argument in its comments that the routine evaluation exemption for amateur radio stations operating below a certain power threshold should be maintained. "Amateur radio licensees operate a variety of installations of different size, power, and frequency, which can be located in close proximity to people, giving rise to various RF exposure concerns," the FCC noted.

In a meeting with FCC OET Chief Julius Knapp and senior staff in early November, ARRL asked the FCC to make available on the internet a calculator to facilitate making the correct calculations the rules require. ARRL said that would be preferable to unofficial third-party calculators, the results from which might not be accorded the same degree of deference in local disputes. Several software programs were suggested as models.

The FCC did not single out amateur radio in drafting its latest RF exposure rules. The rules affect multiple services, and exemptions for many other services were also deleted as part of a broader policy driven by a proliferation of RF devices, some resulting in situations where gain antennas are sited much closer to people than was expected in 1996 when the rules were last revised.


[1] https://docs.fcc.gov/public/attachments/FCC-19-126A1.pdf
[2] https://transition.fcc.gov/bureaus/oet/info/documents/bulletins/oet65/oet65b.pdf

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