Some weeks ago, I involved myself with the OFCOM consultation on proposals to force all UK amateur radio operators to demonstrate that their emissions did not pose a health risk to the public.
Unfortunately, very few people seem to take an interest in these bureaucratic changes. As a result, they often occur with little or no scrutiny.
Key to the proposals, should they become rules, is the technical ability of amateur hobbyists to accurately measure and carry out computations on RF fields.
Remember, in the ultimate case, where someone next door wanted (as they inevitably will) to claim your 12-element Yagi was a risk to their health, you would have to show very accurately the actual fields in operation are safe to a legal standard, in defence of your rights to operate.
OK, so doing all this as standard, regardless of whether someone is complaining, could be said to be a wise step that will head them off at the pass if they do complain. But we can only relax if the method we used is highly standardised, can be relied upon to be accurate and beyond reasonable legal challenge, or is based on a standard mathematical assessment that everyone accepts, rather than physical measurement.
The introduction of the words and concept of EMF radiation safety will add to the scientifically-illiterate panic amongst councillors and town planning staff, which will again erode our ability to get the installations we are licensed to use.
What was very unusual throughout the consultation text was the clear evidence that the whole EMF safety case was based on the roll-out of 5G mobile data; even OFCOM's consultation response form was entitled '5G-something'! 5G, of course, has very little relevance to amateur radio operations, and the public don't generally take to social media to claim their emissions are spreading virus pandemics!
I put it to OFCOM that this exercise was (a) overwhelmingly motivated by perceived developing concern amongst the public about 5G masts and (b) that including amateur radio in this exercise was irrational, irrelevant and unnecessary.
OFCOM accepted that the motivation was indeed 5G. They changed the name of the consultation form so that it was no longer just '5G-something', although that was a bit too much like retrospectively covering their true intentions.
When I asked about the evidence that there were reasonable circumstances (i.e. not standing in front of a beam antenna at full legal power for 3 hours, which isn't reasonable) in which amateurs had, or reasonably could cause public harm, OFCOM said they did not have such evidence. They said that they were simply following Public Health England, who follow ICNIRP - a non-democratically accountable body that has been criticised in the academic press for conflicts of interest (the first example I've personally ever seen of such a thing).
ICNIRP, incidentally, have a highly unusual definition of 'HF', being 100kHz to...300GHz!
The inference, then, was that PHE would have the evidence.
A FoIA request to PHE for peer-reviewed evidence of likely harm from HF frequencies (as normally understood to be ~3-30MHz) at UK amateur power levels revealed that they, too, had no such evidence (or any other kind of evidence).
So, OFCOM has no evidence that HF radiation from amateur installations is likely to be harmful to the public, nor has Public Health England. It seems ICNIRP say 'jump', and the regulators say 'how high?'
ICNIRP has not seen fit to respond to any of my enquiries, which hardly instils confidence in their perception and practice of accountability.
So why is there an exercise to propose all amateurs must comply with some EMF safety limits that have never been shown to be relevant to them? How did we come to be included with an exercise about 5G? OFCOM refuses to say on some nebulous grounds that, if I had the time to challenge it, probably wouldn't stand up.
OFCOM also wanted to play a long game on the content of exchanges between themselves and the RSGB on this issue, but I did not pursue that further for lack of time. Personal correspondence with the RSGB showed they were rather miffed at being asked, and couldn't see the problem, in keeping with their usual support of the regulator. As a private company, the RSGB doesn't have to (and won't) release any information under FoIA, despite the fact it is paid for by member subscription.
All in all, a complete irrational mess, with no evidence to support the idea of EMF compliance for amateurs ever having been suggested, let alone put into a consultation and then, in all likelihood, practice.
