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ARRL General Bulletin ARLB012 (2020)

ARLB012 ARRL Seeks Clarification of Amended Amateur Service RF 
Safety Rules

QST de W1AW  
ARRL Bulletin 12  ARLB012
From ARRL Headquarters  
Newington CT  May 15, 2020
To all radio amateurs 

ARLB012 ARRL Seeks Clarification of Amended Amateur Service RF 
Safety Rules

ARRL has filed a Petition for Clarification addressing two issues
arising from amended FCC RF safety rules that go into effect on June
1 for the Amateur Service and other FCC-regulated services.
Licensees will have 2 years to determine if an RF safety evaluation
is now required under the new rules and to perform an evaluation and
implement any needed mitigation measures. Current rules already
require amateur stations to meet RF exposure limits, but more radio
amateurs will have to evaluate their stations under the new rules.
The revised final rules, adopted last November, appeared in the
April 1 edition of The Federal Register.

"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 Part 97.13(c)(1) and
specify the use of occupational/controlled limits for amateurs where
appropriate," the FCC said. While radio amateurs have always had to
comply with RF exposure limits, certain stations have been exempted
from having to conduct evaluations based upon power and frequency.

On May 8, ARRL asked the FCC to clarify that using maximum
permissible exposure (MPE) limits be permitted in the Amateur
Service for required RF safety evaluations of 2200-meter operations,
just as they are elsewhere in the amateur spectrum. Removal of the
exemption for amateurs resulted in a requirement to use specific
absorption rate (SAR) limits for amateur frequencies between 100 and
300 kHz.

"SAR evaluations are very complex to directly measure and, we
believe, generally exceed the capability of most individual amateur
operators," ARRL argued in its petition, asserting that MPE limits
correspond to conservative estimates of SAR.

"Near-field calculation of a uniform field applied to a transmitter
and antenna operating at 1 W EIRP on 2200 meters would result in a
very conservative estimate of specific absorption rate (SAR) and is
a valid measurement for determining safety of operation," ARRL told
the FCC. "We request clarification that the rules do not intend to
preclude the use of MPE as a surrogate for SAR to evaluate amateur
operations in the 2200-meter band."

ARRL also wants the FCC to clarify that its amended rules permit the
use of near-field regression rates, using the MPE table to compare
against the maximum field strength that may occur from a handheld
portable device, instead of using the SAR. In its filing, ARRL
maintained that SAR data is not available for amateur equipment as
it is for equipment used in other services. Before the rules were
amended, mobile and portable transmitters generally were exempt from
the requirement to perform routine environmental evaluations.

Under Part 97.13(c)(1) as amended, effective on June 1, amateur
licensees must ensure compliance with FCC RF exposure requirements
spelled out in sections 1.1307(b), 2.1091, and 2.1093 of the FCC
rules, where applicable. "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 Part 1.1310, provided appropriate training and information
has been accessed by the amateur licensee and members of his/her

"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." The rule directs
radio amateurs to OET Bulletin 65, Supplement B for methodologies
and guidance to evaluate amateur radio operation.

OET Bulletin 65 can be found online in PDF format at,

The FCC has provided 2 years - until May 31, 2022 - for licensees to
determine if evaluations are now required, to perform such
evaluations where necessary, and to implement any needed mitigation

"The amended rules are intended to provide more efficient,
practical, and consistent RF exposure evaluation procedures and
mitigation measures to help ensure compliance with the existing RF
exposure limits," the FCC said. "The amended rules replace the
various inconsistent service-specific criteria for exempting parties
from performing an evaluation to demonstrate compliance with the RF
exposure limits with new, streamlined criteria." The amended rules
also allow the use of any valid computational method to determine
potential RF exposure levels. The FCC did not amend the actual RF
exposure limits that were adopted in 1996.