Since May 3, 2023, updated Radio Frequency Exposure Rules have been active. These rule changes are detailed in a lengthy 2029 Report and Order governing RF exposure (RFE)limits but require that stations in all services, including amateur radio, be evaluated against existing limits unless they are exempted. Any existing station must complete this evaluation by May 3, 2023. Any new or existing station that has been modified in a way that’s likely to change its RFE profile—such as a different antenna or placement or greater power—must be evaluated by the activation date or change.
“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 FCC’s restrictions on human exposure to RF electromagnetic fields are changed by the December 2019 RF Report and Order. This affects how various radio services determine and achieve compliance with those limits. The FCC replaced a service-specific list of transmitters, facilities, and activities for which study is necessary with new simplified formula-based criteria to speed the process of evaluating whether a particular device or deployment is exempt from a more extensive analysis. The R&O also discussed exposure mitigation and how to conduct evaluations in cases when the exemption does not apply.
The holders of amateur radio licenses must decide if any facilities previously excluded under the prior regulations can now be exempted under the new rules. While most will, some might not.
Amateurs can get assistance from the ARRL Laboratory staff in making these decisions and, if necessary, in performing the calculations required to guarantee their stations comply. This is how ARRL Laboratory Manager Ed Hare, W1RFI, who assisted in creating ARRL’s RF Exposure and You book, put it. “The FCC did not change any of the underlying rules applicable to amateur station evaluations,” he said. “The book’s sections 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 for free download from ARRL. ARRL also has an RF Safety page on its website.
The ARRL RF Safety Committee is collaborating with the FCC to improve the FCC’s tools for adhering to human exposure limits, OET Bulletin 65 and OET Bulletin 65 Supplement B for Radio Amateurs. Furthermore, the ARRL is developing tools for all hams to conduct exposure assessments.