OSHA Requirements for
Tower Construction
Related to RF Radiation
Bob Curtis
OSHA Directorate of
Technical Support
What Does OSHA Want?
Site-Specific S&H Program
• Should include an RF Safety Program if
potential exposures exceed limits
for Uncontrolled Environments
• Draft standard requiring S&H Programs
– OSHA’s highest priority, because they
work
• Using existing standards to encourage
employers to adopt an RF S&H program
Safety and Health Program
Core Elements
• Management leadership and
employee participation
• Hazard identification and
assessment
• Hazard prevention and control
• Information and training
• Evaluation of program effectiveness
Management Leadership and
Employee Participation
• Management commitment
• Assignment of duties
• Authority to enforce rules
Hazard Identification
and Assessment
• Inventory of Sources
• Assessment of exposures to
identify potential areas in
excess of exposure limits.
Use of ANSI vs. OSHA vs.
FCC Standards
• Newer, more restrictive standards, are
preferable
• Meeting SAR limits of new standards is often
easier than meeting field limits
• New standards allow for spatial averaging, but
include RF current limits
• Convenient to adopt FCC (with RF current
limits)
• OSHA state programs may dictate, but usually
defer to newer standards.
Hazard Assessment
Options
• Direct Measurement
• Indirect “Measurement” by
comparing to similar site
• Model calculations
Hazard Prevention
and Control
• Use good equipment
• Control hazard areas
• Limit exposures
• Medical surveillance and accident
response
Control Options
• Lockout/Tag out
• Personal alarm
• Prevent access to hazardous
locations
• Administrative control program
• Protective clothing
Information and Training
• Hazard Communication: A Primary
Control for Non-Ionizing Radiation
• RF Safety Signs
• Draft responsibilities for multi-
employer work sites
Hazcom Program should exist
for “Uncommonly High”
fields, such as:
>50 mG whole body ELF
>Uncontrolled limits of FCC
What to Teach
• Location of sources and potentially
hazardous areas
• Health effects and current and proposed
standards
• Extent of exposure compared to
standards, common sources and
background
• Required SOP’s and controls
• Optional controls employees may use
Suggested Placement of
RF Safety Signs
• “Notice” at Perimeter of Uncontrolled
Limits
• “Caution” at Perimeter of Controlled
Limits
• “Danger” at Location in Excess of Peak
Limits and to Identify Acute Burn
Hazards
Draft Host Employer’s
Responsibilities
• Provide information about hazards,
controls, safety and health rules,
and emergency procedures to all
employers at the workplace
• Ensure that safety and health
responsibilities are assigned as
appropriate to other employers at
the workplace.
Draft Contract Employer’s
Responsibilities
• Ensure that the host employer is aware
of the hazards associated with the
contract employer’s work and what the
contract employer is doing to address
them
• Advise the host employer of any
previously unidentified hazards that the
contact employer identifies at the
workplace.
Evaluation of Program
Effectiveness
• Audit schedule will depend on site.
• Interview employees
– What are the hazards and controls?
– What steps have been taken to
enforce the rules?
• Determine what to change, add,
and delete.
Applicable OSHA Standards
• 23 states have their own OSHA Standards
– Standards must be at least as strict as Federal
– Most copy Federal standards & interpretations
– Some require a Safety and Health Program
• 1910.97 - Non-Ionizing Radiation
– 10 mW/cm2, 6 min. average, 10M-100GHz
– No spatial averaging
– Uses voluntary language of 1966 ANSI
– Mandates look of RF Sign
Applicable OSHA Standards
(cont.)
• 1910.268 - Telecommunication Industry
– Primarily safety requirements, such as
electrical
– Mandates 1910.97 compliance for 1-300 GHz
– Describes “Tagout” of antenna 3-300 MHz
• 1926.54, 20 - Construction Industry
– Includes tower erection, repairs and painting
– Limits MW to 10 mW/cm2. (no averaging)
– Requires programs to provide safe work to
employees and contractors; includes
inspection
Applicable OSHA Standards
(cont.)
• 1910.147 - Lockout/Tagout of Power
– Requires lockout or tagout of power during
maintenance to prevent excessive exposures
• 1910.132 - Personal Protective Equipment
– Requires hazard assessment to select
appropriate PPE
– Interpretation letter addresses RF Clothing
• 1910.145, 1926.200 - Signs and Tags
– Use signs to warn of hazards
Applicable OSHA Standards
(cont.)
• 1904 - Record Keeping
– Log of injuries and illnesses, accidents
• 1910.1020 - Access to Employee Exposure
and Medical Records
• Section 5(a)(1) of OSH Act
– Requires a safe and healthful workplace free
of recognized serious hazards
Obviously Outdated
• Exposure Limit is from 1966 ANSI
– Not frequency dependent
– Does not address induced current
limits
• Incomplete on Hazard
Communication
– Describes RF Sign but not where to
use it
– Once Warning sign for all conditions
• Incomplete on RF Safety
Program Elements
OSHA Directive Covers Fall Protection and Safe Access to
Communications Towers Under Construction
The directive sets inspection policies to ensure uniform enforcement of
OSHA provisions
All employees climbing or otherwise accessing towers must be adequately
trained (1926.21 or 1926.1060)
Employees must be protected from falls with a fall arrest system
(1926.502) or a ladder assist safety device (1926.1053(a))
The directive covers worker access by hoists. Following the training of
hoist operators and workers and after meeting specific criteria,
employees may be lifted on hoist lines to reach work stations at
heights greater than 200 ft. (60.6 meters). The criteria are as
follows: (1) hoist lines must be equipped with a swivel to prevent the
rotation of workers being hoisted, (2) the use of spin-resistant wire
rope is prohibited, (3) workers must wear proper personal protective
equipment, (4) when hoisting personnel, the hoist capacity load rating
shall be reduced by half, and (5) riding the hoist line to work stations
at heights less than 200 ft. (60.6 meters) is prohibited.
Maintenance, retrofitting, and dismantling of existing towers are not
addressed in the directive, but will be covered in future directives.
Basis of RF Standards
• Behavioral disruption threshold
• Limit temperature increase to 1 degrees C
• 1-4 W/kg SAR
• 10-fold safety factor
