FCC Seeks Comments for Blanket Waiver to Allow Amateur Radio in Hospital Emergency Dr

From the AHA website. Sounds like they expect a change in the rules to be forthcoming.

"FCC seeks comments on blanket amateur radio waiver for disaster drills

March 03, 2010
The Federal Communications Commission is accepting comments through April 2 on an AHA request for a blanket waiver to permit hospitals seeking accreditation from The Joint Commission to use amateur radio operators who are hospital employees to transmit communications on behalf of the hospital as part of emergency preparedness drills. Hospitals accredited by The Joint Commission must prepare an emergency operations plan setting forth how the hospital will communicate during emergencies, establish back-up communications links to communicate essential information if primary communication systems fail, and test their emergency operations plans twice annually. The AHA requested the blanket waiver last month as an interim solution to prevent the FCC and hospitals from having to prepare, file and process a raft of waiver requests while the FCC prepares a proposed rule that would allow amateur radio operators who are hospital employees to participate in drills."

 

There are several alert readers of this thread who are helping the participants find documentation of some of the points discussed.

I was directed to take a look deeper into the Joint Committee's standards, and indeed, Amateur Radio is among the suggested assets that could be shared as part of an Emergency Communications Plan. It looks like the hobby has been in there a few years, always as a suggested resource.

In conjunction with a reader's help, I then pursued whether I could find other references beyond the one the AHA's attorney had mentioned in her letter requesting a waiver to the FCC.

On April 7, 2010, the Joint Commission is planning an event entitled Annual Ambulatory Care Conference.

Communication During Emergencies is one of the seminars, and the standard known as EM 02.02.01 is a topic of discussion.

It will be interesting to learn whether they talk about "HAM" radio and the controversy underway about using paid hospital staff to conduct drills on hobbyist frequencies.

Someone should probably call around, to see whether participants and invited spectators include any ARRL people, or other business leaders from the "HAM" industry with a stake in the outcome of this waiver request.

http://www.jcrinc.com/common/PDFs/education/2010%20Agendas/EDU1019.pdf/.

Page 1
2010 Emergency Management Update:
The Challenging Standards
Agenda (Subject to Change)
Wednesday, April 7
Start
End
Session
7:00 - 8:00
Registration
8:00 - 10:00
Emergency Management Standards Update
10:00 - 10:15
Break
10:15 - 12:00
EM.01.01.01 & EM.02.02.03 Advanced Planning
• EP 8 – Documented inventory of the assets & resources
• EP 6 - Monitoring consumption of assets
EM.02.01.01 Emergency Operation Plan (EOP)
• Six Critical Functions
• Incident Command Structure
• Staffing Patterns
EP 3- 96 Hour rule
12:00 - 1:00
Lunch
1:00 - 2:15 2
EM.02.02.01 Communication During Emergencies
• EP 13- Alternate Sights of Care
EM.02.02.03 Managing Resources
• EP 5- Sharing resources with other organizations
• EP 9- Transporting patients, meds, staff, etc.
2:15 - 2:30
Break
2:30 - 3:00
EM.02.02.05 Managing Security
• EP 2- Roles of community security agencies
• EP 4- Hazardous waste and materials
3:00 - 3:30
EM.02.02.07 Managing Staff
• EP 7- Staff trained
• EP 8- LIP roles
EM.02.02.09 Managing Utilities
• EP 5- Fuel requirements
EM.02.02.11 Managing Patients
• EP 6- Mental health
• EP 7- Mortuary services
• EP 8- Documenting and tracking clinical information
3:30 - 4:00
Open Forum- Q & A

 

Access to documents

It could be useful to have access to the Joint Commission's standards documents that describe the requirements for backup communications systems. I took a quick look at their web site and it looked like it would take a nearly $500 subscription to get access. And that would be even more stuff to read.

 

A copy of EM02-02-01 is available in an attachment to comments filed in the proceeding. Here is the link: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020395627

There is a rather expensive standards handbook and is heavily augmented with notes and such. It can be previewed at amazon.com . The actual cited standard, EM02-02-01, does not require use of amateur radio to obtain accreditation. Ms. Welsh's correspondence confuses the reader by implying incorporation of amateur radio is a necessity in order to obtain accreditation.

Amateur radio is not mentined in the document in the link to the Joint Commission HAP cited in this posting. The standard includes just what is required to achieve accreditation.

 

One comment on the FCC site spoke of an Amateur Station installed in a hospital, paid for by a grant, at a cost of over one hundred thousand dollars. This seems a strange cost level for a ham station and is cause for one to wonder just what has transpired with this installation.

The hospitals have other means of communication, so many I wonder just why the AHA is so interested in having commercial use of the Amateur Service.

My suspicions are some individuals {hams} are interested in employment in a ‘communication’ job of some kind paid for by grant monies.

 

I can imagine the "image problem" a high-cost, seldom used station could create for "HAM" radio if one of the talk show hosts wanted a topic of the day to chew on.

But there's a lot of money coming through the health care industry, and accreditation is one of the ways a hospital corporation can provide the appearance of meeting certain standards.

This request for a waiver is part of that effort.

It would be at the expense of radio hobbyists. The cost? We won't know unless it happens.

 

I only wished the FCC required those hospitals submitting comments included whether they had either a radio system installed or planned and/or hams on the payroll.

Those would be interesting figures. Imagine, a hospital supporting the waiver but has neither.

 

WP Docket No. 10-72
NOTICE OF PROPOSED RULEMAKING

http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-10-45A1.doc

 

Planning ahead.

Supporting the waiver request for possible future use would be a reasonable thing to do.

You may have noticed a couple more of those standard form letters from hospitals. They all (since they are copies) contain the same errors. I wonder if any of those people signing the letters have any idea what amateur radio is. Or if they even read the letter.

 

Interesting development.

Note however that this specifically applies only to government sponsored drills - i.e. the types of drills that they had previously issued a memorandum about saying that such drills would need waivers on a case by case basis.

Note also that this would not give the AHA what they are asking for: a blanket waiver for drills even without government sponsorship.

 

For convenience in the discussion, here is the FCC's proposed rule:

The documents says that "government" includes federal, state and local government.

I also see in the document that in addition to soliciting comments about this specific rule language quote above,, they also are solicting comment about extending it to non-government sponsored drills

No mention of the CQ or Gordon West petitions, or any mention of that screwy ARRL language the the board approved.

 

Correct on both points.

Do you think it renders moot the invitation to comment on the request from the AHA?
And yes, does it also eclipse potential FCC action on the petitions from CQ magazine and Gordon West, and the threatened petition from the ARRL ?

I had trouble bringing up the document from the FCC site.

Here's a link to a backup copy for those needing:

http://www.qsl.net/wa3vjb/FCC-10-45A1.doc

 

Personally, my initial reaction (although I reserve the right to change my mind after I've mulled it over some more) is that I don't have a problem with this proposed language - since it is limited to government sponsored drills. It makes sense, too, because any disaster major and widespread enough to warrant falling back on amateur radio is probably going to be serious enough to involve at least the local government agencies. I also think government sponsored drills are not likely to be too frequent, they'd involve multiple organizations and agencies, as well as volunteers. I don't see much potential for abuse in this proposal.

On the other hand, I would have a serious problem with it if they were to broaden it to include non-government sponsored drills because that would just open things up to the whole range of abuses and exploitation that we've been talking about that would come with the AHA blanket waiver.

 

When they put out that request for waiver they probably already were getting this NPRM ready. My take on it is that the NPRM change would NOT satisfy what the AHA is asking for, so I think AHA waiver request is still in play as a separate issue.

Maybe. But I think those petitions and threatened petition will reincarnate as as comments to this, anyway. I can't imagine any reasons why the FCC would release this NPRM and then another separate one covering the same issue.

Or maybe they read those CQ and West petitions and the ARRL "communication" and didn't take them seriously? ?

 

First, apologies to both you and Paul, as I should have checked here before my email in basket.

The old song by the group "The Circle" comes to mind: "It's a Turn Down Day.....and I Dig It."

Yes. They speak of limiting the activity, so that's one means.

It is important that we comment on the NPRM, as I believe I read in the text that they are soliciting commentary to do just that: Broaden the language to include not just government sponsored drills.

It will be fun to read what AHA's comments to the NPRM will consist of, since they won't have the administrative burden of filling out waivers to participate in government-sponsored drills.

Overall, it's your worry, Ron, that was soundly based. We all pontificated as to why the League "slipped-in" their suggested overly-loose language somewhat informally. Apparently, they knew what was going on behind the scenes. Probably the "communication" was a phone call back to "Deep Throat" at the Commission.