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ARLB011 Updated Radio Frequency Exposure Rules Become Effective on May 3

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QST de W1AW ARRL Bulletin 11 ARLB011

From ARRL Headquarters

Newington CT April 13, 2021
To all radio amateurs
SB QST ARL ARLB011

ARLB011 Updated Radio Frequency Exposure Rules Become Effective on
May 3

The FCC has announced that rule changes detailed in a lengthy 2019
Report and Order governing RF exposure standards go into effect on
May 3, 2021. The new rules do not change existing RF exposure (RFE)
limits but do require that stations in all services, including
amateur radio, be evaluated against existing limits, unless they are
exempted. For stations already in place, that evaluation must be
completed by May 3, 2023. After May 3 of this year, any new station,
or any existing station modified in a way that’s likely to change
its RFE profile – such as different antenna or placement or greater
power – will need to conduct an evaluation by the date of activation
or change.

The Report and Order can be found online in PDF format at,
https://docs.fcc.gov/public/attachments/FCC-19-126A1.pdf .

“In the RF Report and Order, the Commission anticipated that few
parties would have to conduct reevaluations under the new rules and
that such evaluations will be relatively straightforward,” the FCC
said in an April 2 Public Notice. “It nevertheless adopted a 2-year
period for parties to verify and ensure compliance under the new
rules.”

The Amateur Service is no longer categorically excluded from certain
aspects of the rules, as amended, and licensees can no longer avoid
performing an exposure assessment simply because they are
transmitting below a given power level.

“For most amateurs, the major difference is the removal of the
categorical exclusion for amateur radio, which means that ham
station owners must determine if they either qualify for an
exemption or must perform a routine environmental evaluation,” said
Greg Lapin, N9GL, chair of the ARRL RF Safety Committee and a member
of the FCC Technological Advisory Council (TAC).

“Ham stations previously excluded from performing environmental
evaluations will have until May 3, 2023, to perform these. After May
3, 2021, any new stations or those modified in a way that affects RF
exposure must comply before being put into service,” Lapin said.

The December 2019 RF Report and Order changes the methods that many
radio services use to determine and achieve compliance with FCC
limits on human exposure to RF electromagnetic fields. The FCC also
modified the process for determining whether a particular device or
deployment is exempt from a more thorough analysis by replacing a
service-specific list of transmitters, facilities, and operations
for which evaluation is required with new streamlined formula-based
criteria. The R&O also addressed how to perform evaluations where
the exemption does not apply, and how to mitigate exposure.

Amateur radio licensees will have to determine whether any existing
facilities previously excluded under the old rules now qualify for
an exemption under the new rules. Most will, but some may not.

“For amateurs, the major difference is the removal of the
categorical exclusion,” Lapin said, “which means that every ham will
be required to perform some sort of calculation, either to determine
if they qualify for an exemption or must perform a full-fledged
exposure assessment. For hams who previously performed exposure
assessments on their stations, there is nothing more to do.”

The ARRL Laboratory staff is available to help amateurs to make
these determinations and, if needed, perform the necessary
calculations to ensure their stations comply. ARRL Laboratory
Manager Ed Hare, W1RFI, who helped prepare ARRL’s RF Exposure and
You book, explained it this way. “The FCC did not change any of the
underlying rules applicable to amateur station evaluations,” he
said. “The sections of the book on how to perform routine station
evaluations are still valid and usable, especially the many charts
of common antennas at different heights.” Hare said ARRL Lab staff
also would be available to help amateurs understand the rules and
evaluate their stations.”

RF Exposure and You is available in PDF format for free download
from ARRL at,
http://www.arrl.org/files/file/Technology/RFsafetyCommittee/28RFSafety.pdf
.
ARRL also has an RF Safety page on its website at,
http://www.arrl.org/rf-exposure .

The ARRL RF Safety Committee is working with the FCC to update the
FCC’s aids for following human exposure rules – OET Bulletin 65 and
OET Bulletin 65 Supplement B for Radio Amateurs. In addition, ARRL
is developing tools that all hams can use to perform exposure
assessments.
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