Electromagnetic Safety - more rubbish.

A consultation has recently been launched by OFCOM, the UK telecoms regulator, on proposed changes to licences - including amateur licences - to ensure compliance with ICNIRP controls.

The new compliance controls will apply to everyone using over 10W EIRP.

It doesn't take a lot of reading to conclude that this whole exercise is very clearly motivated by potential concerns brought about by microwave mobile phone operations - with a catalyst being the new 5G system. 

In preparing my early formal response to the proposals, I came to ask the question: why are we being put together in the same room as commercial UHF operators, when most of us stop at 433MHz or so?

That brought me to the ICNIRP's website.  Here, it takes just a click to figure out what's going on.

For reasons that are extremely difficult to understand - but that I have asked the ICNIRP to explain - that organisation uses an extraordinarily unusual definition of HF.

The ITU defines HF in the same way that we all understand the range to be: 3 to 30MHz.

The ICNIRP has the view that the HF range is - wait for it - 100kHz to 300GHz!

Faced with that definition, which nobody yet seems to be challenging other than my response, OFCOM, I suppose, has to go along with it and throw us together with commercial mobile phone operators.


UPDATE 1:

Yesterday, I contacted the RSGB's EMC Chairman.  In a typically RSGB-esque response (dry, humourless, deferential to OFCOM), I was told that the ICNIRP uses 100kHz - 300GHz as the definition of HF because tissue heating is seen from 100kHz upwards.

I was also told that there is "peer-reviewed scientific evidence" to demonstrate this and, by inference, that OFCOM is justified in considering these controls.

I asked the Chairman whether the RSGB could provide me with citations for that evidence.  At the time of writing (05/03/2020), they have not provided any such citations [update, 18 months later: they never did].  I doubt it exists and, if it does, it will almost certainly not be applicable to amateur installations which, in the UK, are limited to quite low powers.  Once again, the RSGB seems to be deferential to OFCOM, going along with much of what idiotic ideas it comes up with next.

Indeed, a 2012 report into non-ionising radiation safety across the EM spectrum by the then Health Protection Agency in the UK, used not the NCIRP's ludicrous definition of 'HF', but the ITU - and our - definition.

Not only is that definition much more in keeping with common sense, it makes discussion, debate and challenge of the effects according to frequency much more possible and meaningful.  The present ICNIRP nonsense is something like saying X-rays at a certain power and duration have the same health effects as visible light under the same conditions.

Turning to ICNIRP, it has found itself in the remarkable position of having a peer-reviewed scientific paper written about its alleged conflicts of interest.  This seems to have been entrirely overlooked by OFCOM.

Another issue to contend with is that of enforcement.  Already, OFCOM is heavily criticsed amongst the amateur community for failing to enforce existing rules concerning EMC issues.  OFCOM is now reduced to not much more than an income-generating arm of government, mainly concerned with selling off microwave spectrum.  There will surely be nobody going around in vans to the furthest regions of the UK and wondering whether that 2m Yagi is just a bit too close to the street to be 'safe'.  There will be, in practice, zero chance of any such unlikely monitoring leading to a Court case.  So what is the point of all this?

In practice, it is to be hoped - as is already mentioned as a possibility - that amateurs will be able to simply submit a standard calculation based on broad antenna type, input power, feeder loss and distance to receiver.  Either that, or be exempted altogether.

Even then, there will be complex things like intervening material absorptions and duration of exposure to take into account in some circumstances.  Absolute measurements would seem to be ruled out, which would require reliably calibrated, likely extremely expensive field measuring equipment to demonstrate compliance to a legal standard.

All this, with an as-yet undemonstrated potential for harm!

UPDATE 2:

A few days after I wrote the above, OFCOM sent me what was in essence a Data Protection response form to complete.

The file name from OFCOM (I added my surname) says it all - all about 5G.  What have amateurs to do with any of this?

And guess what?  My contention that all this started with OFCOM trying to preemptively cover their backsides about potential 5G concerns is more than strongly supported when I looked at the file name of the document OFCOM sent me - 'response-form-5g-emf'  

I rest my case.  But the RSGB seems to think OFCOM is perfect to do all this.  Just as well I'm not a member, then!  [2021 update: the RSGB, presumably seeing a very considerable degree of dissent amongst the membership, came to submitting it "could not support" the proposal in the end].