confidential r.s.i. corporation rf controlled exposure hazards only competent people can work in rf...

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RF Controlled Exposure RF Controlled Exposure Hazards Hazards Only Competent Only Competent People can work People can work in RF C in RF C ontrolled ontrolled Areas Areas

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Page 1: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

CONFIDENTIAL R.S.I. CORPORATIONCONFIDENTIAL R.S.I. CORPORATION

RF Controlled Exposure HazardsRF Controlled Exposure Hazards

Only Competent People Only Competent People can work in RF Ccan work in RF Controlledontrolled

AreasAreas

Page 2: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

0.3 1 3 10 30 100 300 1 3 10 30 1000.3 1 3 10 30 100 300 1 3 10 30 100 0.3 1 3 10 30 100 300 1 3 10 30 1000.3 1 3 10 30 100 300 1 3 10 30 100

MHzMHzMHzMHz GHzGHzGHzGHz

100100100100

10101010

1111

5555

30303030

.2.2.2.2

mW/cmmW/cm22

mW/cmmW/cm22

AM FM

MPE LAW

ControlledControlled

Uncontrolled

1996 Rulemaking1996 Rulemaking 1996 Rulemaking1996 Rulemaking

Both E&HBelow 300MHz

6 Min TWA

30Min TWACellphones

Page 3: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

CONFIDENTIAL R.S.I. CORPORATIONCONFIDENTIAL R.S.I. CORPORATION

General Population/Uncontrolled General Population/Uncontrolled ExposureExposure

Applies to situations in which the public may be exposed or in which persons who are exposed as a part of their employment who may have not been made fully aware of the potential for exposure or cannot exercise control over their exposure.

Page 4: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

CONFIDENTIAL R.S.I. CORPORATIONCONFIDENTIAL R.S.I. CORPORATION

Controlled Exposure HazardsControlled Exposure Hazards

Controlled/Occupational Environment Controlled/Occupational Environment (Trained Workers Only)(Trained Workers Only)

• Controlled environments are locations where there is exposure that may be incurred by persons who are made “fully aware” of the potential for exposure and can exercise control over their exposure.

• Workers and the public have the Right to Know about RF hazards. Compliance is now Mandated by the MPE Law Requirements.

Page 5: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

CONFIDENTIAL R.S.I. CORPORATIONCONFIDENTIAL R.S.I. CORPORATION

• We …explain in a note to Section 1.1310 of our rules that “fully aware” means that an exposed individual

has received written and verbal information concerning the potential for RF exposure and has received training regarding appropriate work

practices relating to controlling or mitigating his or her exposure …for instance, appropriate signage. We

…. specify that “exercise control” means that an exposed individual is able to reduce or avoid exposure by administrative or engineering work practices, such as

use of PPE or time-averaging of exposure.

•] See OSHA CFR 1910.1020)

FCCFCC Statement 6/ 30/03 Statement 6/ 30/03

Page 6: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

CONFIDENTIAL R.S.I. CORPORATIONCONFIDENTIAL R.S.I. CORPORATION

“Controlled” the Safety Definition is NOT JUST A LOCKED GATE OR DOOR “Workers Must be Trained before passing through”.

Page 7: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

CONFIDENTIAL R.S.I. CORPORATIONCONFIDENTIAL R.S.I. CORPORATION

““Controlled”Controlled” HAS FOUR THINGS

• Security • Exercise control with training “SAFETY”• The Site Must have MPE Data this is the

Exposure in % of MPE. “Controlled as a Standard” INDUSTRIAL HYGIENEINDUSTRIAL HYGIENE

• RF Site SignageRF Site Signage

Page 8: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

CONFIDENTIAL R.S.I. CORPORATIONCONFIDENTIAL R.S.I. CORPORATION

1. “Exercise control” means that an exposed individual is able to reduce or avoid exposure (How to do this, must be covered in the training)

2.2. ““Must have RF Safety training Must have RF Safety training before passing through”before passing through”

Page 9: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

CONFIDENTIAL R.S.I. CORPORATIONCONFIDENTIAL R.S.I. CORPORATION

If working in a Controlled/Occupational Area: Everyone must be “Fully Aware” of their

exposure potential and can exercise control of their exposure.

The Site Must have MPE Data

Page 10: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

CONFIDENTIAL R.S.I. CORPORATIONCONFIDENTIAL R.S.I. CORPORATION

1910.1020 Access to employee 1910.1020 Access to employee exposure and medical recordsexposure and medical records

• The purpose is to prove employees a right of access to relevant exposure

• 1910.1020 c (5) (I) Requires: Workplace monitoring or measuring of harmful physical agent relevant to interpretation of the results obtained

• 1910.1020 c 8 Exposure or exposed means that an employee is subjected to harmful physical agent in the course of employment through any route of entry (contact or absorption), and includes past exposure and potential exposure

• Whenever an employee requests access, the employer shall provide data

Page 11: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

““Controlled” ExposureControlled” Exposure• ““Controlled” Exposure is when someone is Controlled” Exposure is when someone is

in an area with 100% MPE for 6 minutes.in an area with 100% MPE for 6 minutes.• Or 200% for 3 minutesOr 200% for 3 minutes• Higher level of security (Site Control)Higher level of security (Site Control)• Note: If employees are in areas above Note: If employees are in areas above

100% 100% “Your Safety Plan”“Your Safety Plan” must outline must outline how the employee is to avoid MPE how the employee is to avoid MPE exposure exposure

Page 12: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

CONFIDENTIAL R.S.I. CORPORATIONCONFIDENTIAL R.S.I. CORPORATION

0.3 1 3 10 30 100 300 1 3 10 30 1000.3 1 3 10 30 100 300 1 3 10 30 100 0.3 1 3 10 30 100 300 1 3 10 30 1000.3 1 3 10 30 100 300 1 3 10 30 100

MHzMHzMHzMHz GHzGHzGHzGHz

100100100100

10101010

1111

5555

30303030

.2.2.2.2

mW/cmmW/cm22

mW/cmmW/cm22

AM FM

MPE LAW

ControlledControlled

Uncontrolled

1996 Rulemaking1996 Rulemaking 1996 Rulemaking1996 Rulemaking

Both E&HBelow 300MHz

6 Min TWA

30Min TWACellphones

Page 13: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

CONFIDENTIAL R.S.I. CORPORATIONCONFIDENTIAL R.S.I. CORPORATION

Page 14: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

CONFIDENTIAL R.S.I. CORPORATIONCONFIDENTIAL R.S.I. CORPORATION

What OSHA says about safety training when

employees have exposure• 1910.1020 (c)(13) “Toxic substance or harmful physical

agent” means any chemical substance, biological agent, or physical stress ( noise, heat, cold, vibration, repetitive motion, ionizing and non-ionizing radiation). “The uncontrolled criteria is OSHA’s action limit”

• 1910,1020 (g)(1)Upon an employee’s first entering into employment, and at least annually thereafter, each employer shall inform current employees ….(g)(1)(i) The existence, location, and availability of any records….

Page 15: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

CONFIDENTIAL R.S.I. CORPORATIONCONFIDENTIAL R.S.I. CORPORATION

Only Competent people can Only Competent people can work in RF Cwork in RF Controlledontrolled areas areas Only Competent people can Only Competent people can work in RF Cwork in RF Controlledontrolled areas areas

CFR 1926.21CFR 1926.21

““Competent person”Competent person” means one who is capable of means one who is capable of identifying existing and predictable hazards and identifying existing and predictable hazards and who who has authorizationhas authorization to take prompt to take prompt corrective corrective measures to eliminate themmeasures to eliminate them..

Page 16: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

CONFIDENTIAL R.S.I. CORPORATIONCONFIDENTIAL R.S.I. CORPORATION

Safety OSHA StandardsSafety OSHA Standards

• It’s Your Job Per OSHA: After you have determine the hazard, it is up to a competent person to do the work and Qualified person to determine how to mitigate that hazard.

Page 17: CONFIDENTIAL R.S.I. CORPORATION RF Controlled Exposure Hazards Only Competent People can work in RF C ontrolled Areas

Questions?Questions?