regulatory guidance and safety standards

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Regulatory Guidance and Safety Standards Andrew H. Thatcher, MSHP, CHP [email protected] March 19, 2018 University of Washington

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Page 1: Regulatory Guidance and Safety Standards

Regulatory Guidance and Safety Standards

Andrew H. Thatcher, MSHP, CHP

[email protected]

March 19, 2018

University of Washington

Page 2: Regulatory Guidance and Safety Standards

Overview

• 60 Hz power frequency exposure standards

• Static Fields

• RF (current fields to 3 GHz)

• Upcoming applications for mm Wave and exposure limits

Page 3: Regulatory Guidance and Safety Standards

Frequencies below ~100 kHz

• The limiting hazard is electrostimulation of tissue, either from electric fields induced within the body or by exposure to external fields, or from contact currents that occur when a person touches a charged conductive object.

Page 4: Regulatory Guidance and Safety Standards

60 Hz Power Frequency Field Exposure Limits

• No state or federal standards exist with regards to power frequency fields.

• Three relevant guidelines are used for exposure limits: • International Commission on Non-Ionizing

Radiation Protection (ICNIRP), 2010 • IEEE C95.6-2002 Standards for Safety Levels with

Respect to Human Exposure to Electromagnetic Fields, 0-3 kHz

• American Conference of Governmental Industrial Hygienists (ACGIH), 2009

Page 5: Regulatory Guidance and Safety Standards
Page 6: Regulatory Guidance and Safety Standards

Power Frequency Fields Continued

• From ACGIH: • Arms and legs – 50,000 mG

• Hands and feet - 100,000 mG

• Electric field limit of 25 kV/m

Page 7: Regulatory Guidance and Safety Standards

ACGIH Induced and Contact Current Limits (mA)

From IEEE C95.1-2005

Frequency

Through

Both Feet

Through

Either Foot

Grasping

Averaging

Time

30 kHz – 100 kHz

2000 f

1000 f

1000 f

0.2 s

100 kHz – 100 MHz

200

100

100

6 min

Note that the current limits above may not adequately protect against startle reactions and burns caused by transient discharges when contacting an energized object. Maximum touch current is limited to 50% of the maximum grasping current. The ceiling value for induced and contact current is 500 mA.

Page 8: Regulatory Guidance and Safety Standards

Static Magnetic Fields: MRI

• FDA: Criteria for Significant Risk Investigations of Magnetic Resonance Diagnostic Devices (2014), which identifies the operating conditions for MRI systems that FDA considers significant risk. An MRI system that exceeds any of these operating conditions would be considered significant risk and require FDA oversight via an IDE:

• Main static magnetic field over 8 tesla (80,000 Gauss) for adults, children, and infants >1 month of age; main static magnetic field over 4T for infants less than 1 month of age, or

• Specific absorption rate (SAR) greater than 4 W/kg whole body for 15 minutes, >3.2 W/kg averaged over the head for 10 minutes, or

• dB/dt sufficient to produce severe discomfort or painful stimulation, or

Page 9: Regulatory Guidance and Safety Standards

RF Safety Standards: Philosophy

Contemporary exposure limits are biologically based and reflect a consensus interpretation of relevant studies from the bioelectromagnetics literature by qualified scientists, physicians and engineers

Classifications of findings are made without pre-judgment of mechanisms of effects

The intent is to protect exposed human beings from harm by any mechanism, including those arising from excessive elevations of body temperature

The bases (basic restrictions) of contemporary RF safety standards are essentially the same; differences in exposure limits are engineering related - not philosophical – and are being resolved through standards harmonization programs

Page 10: Regulatory Guidance and Safety Standards

Adverse Health Effects

An adverse health effect is a biological effect characterized by a harmful change in health that is supported by consistent findings of that effect in studies published in the peer-reviewed scientific literature, with evidence of the effect being demonstrated by independent laboratories, and where there is consensus in the scientific community that the effect occurs for the specified exposure conditions. [IEEE Standard C95.1™-2005]

Page 11: Regulatory Guidance and Safety Standards

Standards and Guidelines

ICNIRP (1998): “…this publication is to establish

guidelines for limiting EMF exposure that will

provide protection against known adverse health

effects”.

*ICNIRP reconfirmed its guidelines in 2009.

IEEE ICES C95.1-2005: “The purpose of this

standard is to provide exposure limits to protect

against established adverse effects to human health

induced by exposure to RF electric, magnetic and

electromagnetic fields over the frequency range of 3

kHz to 300 GHz.”

Page 12: Regulatory Guidance and Safety Standards

Established Adverse Health Effects

Expert panels that review the literature agree that the only adverse effects that have been established are the following:

Aversive or painful electrostimulation due to excessive RF internal electric fields (< 5 MHz)

RF shocks or burns due to contact with excessively high RF voltages (< 110 MHz)

Heating pain or tissue burns due to excessive localized RF exposure (> 100 kHz)

Behavioral disruption, heat exhaustion or heat stroke due to excessive whole body RF exposures (> 100 kHz)

Page 13: Regulatory Guidance and Safety Standards

Literature Evaluation

Recommendations in contemporary RF safety standards and guidelines (Basic Restrictions and Exposure Limits) are based on the following:

the results of comprehensive reviews and evaluations of the scientific literature (more than 1300 relevant citations in C95.1-2005) –

More than 6200 articles currently found on

www.emf-portal.org

findings of studies published mainly after 1950

studies that involve low level exposures (especially important)

conclusions supported by a lack of credible scientific and medical reports showing adverse health effects for RF exposures at or below similar exposure limits in past standards

Page 14: Regulatory Guidance and Safety Standards

Results of Literature Evaluations

The most sensitive measure of potentially harmful biological effects is disruption of food-motivated behavior in laboratory animals

The threshold was found to reliably occur over a narrow SAR range between ~ 3 and 9 W/kg in several animal species under widely varying exposure parameters and was accompanied by an elevation in core temperature

The C95.1 standard, and all modern RF safety standards and guidelines, are based on a threshold SAR of 4 W/kg

Page 15: Regulatory Guidance and Safety Standards

Basic Restrictions

basic restrictions (BR):

Exposure restrictions that are based on established adverse health effects that incorporate appropriate safety factors. BRs are expressed in terms of the in situ electric field (< 100 kHz), specific absorption rate (100 kHz to 3 GHz), or incident power density (3 GHz to 300 GHz).

Because of the difficulty in determining the BRs under typical exposure conditions, exposure limits (ELs) derived from the BRs are used for assessing compliance.

Page 16: Regulatory Guidance and Safety Standards

Basic Restrictions (SAR)

Specific absorption rate (SAR) is the basic dosimetric quantity for comparing and extrapolating laboratory results (bioeffects studies) for frequencies above ~ 100 kHz

All modern RF safety standards are based the threshold SAR for the most sensitive, reproducible biological effects that can be related to human health

Despite slight differences in field limits, all modern RF safety standards (less than 6 GHz) are based on limiting the whole-body-averaged SAR to 0.4 and 0.08 W/kg, for exposures in controlled and uncontrolled environments, respectively

Greater than 6 GHz the safety standards are based on limiting the power density as the absorption is limited to the skin layer

Page 17: Regulatory Guidance and Safety Standards

Comparison of Power Density and SAR Thresholds for Behavioral Disruption

Species and

Conditions

CW

225 MHz

Pulsed

1.3 GHz

CW

2.45 GHz

Pulsed

5.8 GHz

Norwegian Rat

Power Density:

SAR:

-----

-----

10 mW/cm2

2.5 W/kg

28 mW/cm2

5.0 W/kg

20 mW/cm2

4.9 W/kg

Squirrel Monkey

Power Density:

SAR:

-----

-----

-----

-----

45 mW/cm2

4.5 W/kg

40 mW/cm2

7.2 W/kg

Rhesus Monkey

Power Density:

SAR:

8 mW/cm2

3.2 W/kg

57 mW/cm2

4.5 W/kg

67 mW/cm2

4.7 W/kg

140 mW/cm2

8.4 W/kg

Page 18: Regulatory Guidance and Safety Standards

Safety Factors

Whole body exposure:

Behavioral effects in several animal species over many frequencies; threshold between ~ 3 and 9 W/kg

10X - 0.4 W/kg for upper tier

50X - 0.08 W/kg for lower tier

Localized exposure (averaged over any 10 g)

Lens opacities (cataract) observed in rabbits, threshold 100 W/kg

10X – 10 W/kg for upper tier

50X – 2 W/kg for lower tier

Page 19: Regulatory Guidance and Safety Standards

Basic restrictions for frequency range 100 kHz to 6 GHZ

47 CFR 1.1310 Radiofrequency Radiation Exposure Limits

General Public /

Uncontrolled

Exposure (W/kg)

Occupational/

Controlled Exposure

(W/kg)

Whole Body

exposure Whole Body Average 0.08 0.4

Localized exposure Localized (peak

spatial average) 1.6a 8a

Localized exposure Extremities and

pinnae 4b 20b

aAveraged over any 1 gram of tissue

bAveraged of any 10 grams of tissue

Page 20: Regulatory Guidance and Safety Standards
Page 21: Regulatory Guidance and Safety Standards

Relevant Scientific Literature

Several thousand relevant RF bioeffect studies in the extant

literature cover a wide range of frequencies and modulations

The literature database in of uneven quality

Absence of support for the “non-thermal hypothesis”

— Biophysical analyses and reviews do not provide

convincing evidence that non-thermal interactions are

plausible at RF frequencies

— Examination of biological effects literature does not

provide a consistent body of data supporting theoretical

postulates on “non-thermal” mechanisms

Page 22: Regulatory Guidance and Safety Standards

Source: FCC OET Bulletin 65. 1997

Page 23: Regulatory Guidance and Safety Standards

30 30

20.1 0.8 0.2 1.6 0.2 0.04

0

10

20

30

40

50

60

70

80

90

100E

xp

osu

re (

µW

/cm

²)

Cordless

phone

Bluetooth Baby

Monitor @

7 feet

FM & TV Wireless

Laptop

WiFi maximum

outdoor

exposure

Typical

outdoor

exposure

Max

indoor

exposure

nearby

home

Typical Radiofrequency Exposures in our Lives

The Public exposure limit is:

200 µW/cm² for FM

425 µW/cm² for TV (UHF)

570 µW/cm² for cellular

1,000 µW/cm² for PCS

Copyright ©2011

Andrew H. Thatcher,

Page 24: Regulatory Guidance and Safety Standards

FCC OET 65

Page 25: Regulatory Guidance and Safety Standards

What About Exposures to Multiple RF Frequencies?

1)(1

n

i iTLVMPE

densitypower

Page 26: Regulatory Guidance and Safety Standards

Exclusions

The electric field, magnetic field and power density MPEs can be exceeded if it can be shown by appropriate techniques that:

the whole-body-averaged (WBA) SAR does not exceed the

appropriate WBA SAR limits, and

the spatial peak SARs do not exceed the corresponding spatial

peak SAR limits (except in the hands, wrists, feet and ankles),

and

the spatial peak SAR in the hands, wrists, feet and ankles do

not exceed 20 W/kg and 4 W/kg in any 10 g of tissue in the

shape of a cube for the controlled and uncontrolled

environments, respectively, and

the induced currents in the body do not exceed the appropriate

induced current MPEs

Page 27: Regulatory Guidance and Safety Standards
Page 28: Regulatory Guidance and Safety Standards

What is 5G? What Frequencies are Involved?

• FCC makes changes to allow for millimeter wave (mmW) technology

• Changes in rules to promote 3.5 GHz as a core frequency for 5G

• Expand use in Mid-Band spectrum between 3.7 GHz and 24 GHz (3.7 – 4.2 GHz, 5.925-6.425 GHz, 6.425-7.125 GHz)

• Additional 1700 MHz in 24 GHz and 47 GHz bands

• Allocations in 28 GHz, 37 GHz, and 39 GHz bands

Page 29: Regulatory Guidance and Safety Standards
Page 30: Regulatory Guidance and Safety Standards

What about 5G frequencies?

• Exposures > 6 GHz have very shallow penetration limited to the skin. Limits are related to incident power density as opposed to a SAR due to the limited penetration distance.

• A number of articles are reviewing the models and results of mmW absorption:

• Foster, KR. Ziskin, MC. and Balzano, Q. Thermal Response of Human Skin to Microwave Energy: A Critical Review, Health Physics, 111(6): 528-541. 2016

• Foster, KR. Ziskin MC. and Balzano, Q. Thermal Modeling for the Next Generation of Radiofrequency Exposure Limits: Commentary. Health Physics, 113(1); 41-53, 2017.

• Ziskin, MC, Alekseev, SI, Foster KR, and Balzano, Q. Tissue Models for RF Exposure Evaluation at Frequecies above 6 GHz. Bioelectromagnetics, In Review.

• And others in review

• Aside: Expectations is that the current 8.4 Billion connected devices will grow by 10X in the next few years

Page 31: Regulatory Guidance and Safety Standards

What About Low-level RF Biological Effects?

Despite more than 60 years of RF research, there is no convincing evidence that supports low-level biological effects, i.e., effects that occur at exposure levels below the limits found in contemporary standards and guidelines

No theoretical mechanism has been established that supports the existence of any effect characterized by trivial heating other than microwave hearing

The relevance of reported low-level biological effects remains speculative and such effects are not useful for developing exposure limits

Page 32: Regulatory Guidance and Safety Standards

The study of the biological effects of RF energy is a mature scientific discipline with more than a 60 year history

The RF bioeffect literature database is extensive but of uneven quality

Scientists have been developing RF safety criteria based on critical evaluations and interpretations of the scientific literature for almost 60 years

Despite many thousands of studies that have been reported on all aspects of the subject since the first safety criteria were proposed, the exposure limits have not changed significantly

Changes in the exposure limits over the years have mainly resulted from a better understanding of the dosimetry

Both IEEE C95.1-2005 and ICNIRP guidelines are undergoing major revisions – estimated completion ~late 2018.

Final Thoughts