HR2.0 - New FCC RF Safety Rules | Ham Radio Livestream with Ria Jiaram

I have cancer concerns.

Why should I, or anyone, "shut down"??

Part 97 is a technically based enterprise, with many,many technically oriented participants. Why should we accept opinion in place of fact?

 

Time while not transmitting i.e., listening, is definitely allowable in the duty cycle calculation per FCC OET Bulletin 65, Supplement B, page 13.

In examples of SSB phone communications they used a 67% duty cycle, 2 minutes on, 2 minutes off, over 6 minutes, since the averaging period is 6 minutes for controlled exposure and 30 minutes for uncontrolled exposure.

If the ham is long winded and typically talks for 7 minutes then listens for 7, the duty cycle example for the controlled case would rise to 100%.

Obviously with the longer averaging period of 30 minutes for the uncontrolled case, both of these would have a duty cycle much closer to 50%.

 

So, according to this logic, the Part 97 licensee must document--to "ensure compliance"-- receive mode in communications. But Part 97 applies to transmissions, not receiving. The station license is a license to transmit.

What the FCC is suggesting is that you must be able to document--read 'record' --the communications between the first station identification and the last, in order to calculate and demonstrate compliance. Good luck on that! The duty cycle will vary dramatically. With operator. With context. So what do you suggest-- a histogram for each station/operator on duty cycle??

If you don't want to get hung up on demonstrating that (silly) interpretation on 'duty cycle', then just do the calculations with the transmit signal only, which by definition for sideband and CW, will never by 100% duty cycle anyway.

The intent of that FCC example is to show that the duty cycle of simplex communications is not approaching the high percentage ascribed, for example, to broadcast stations, which are continuous and usually on all the time. We transmit. We do not broadcast.

Be careful here-- some people will misinterpret that as meaning :' oh, I wasn't transmitting, but I was RX monitoring, for a contiguous 4 hours today, and I then transmitted for 5 minutes total, so my duty cycle is less than, say, 2 %'.

 

Informative video. Thank you for posting it.

I do have a comment regarding the FCC "Enforcement" comment at 34:35 in the video:

While it is VERY unlikely that the FCC will (or would) ever do any "random" inspections of any amateur station (they simply do not have the resources to ever do so), it IS possible that some nosy, ham radio antenna-hating neighbor might [or could] file a complaint with the FCC, saying that your operations are allegedly making them "sick", and they want to shut you down. In such a case, the FCC *could* request information about your station, and/or *could* perform a physical inspection of your equipment and installation. If you've run the numbers beforehand, you'd likely be covered 100%.

Just because of that possibility, it would be wise for all amateur operators to run the simple calculations and verify that the exposure limits are within the guidelines. This may be particularly true of those operators who live in more densely-built residential areas, who don't have large lots on which to erect antennas. However, if you're out in the country, or have a large lot, with many, many feet of distance from your antennas to your nearest neighbor (and yourself!), this probably wouldn't be a concern (although, nosy, whack-jobs also live out in the country too! LOL).

Nonetheless, the calculators are VERY easy to run, so why not? Run [calculate] with the power output levels at both minimum and maximums, just to be sure... 73, ~Alan

 

Yes Alan, you are correct. Not only is it the PRUDENT thing to do, it is the REQUIREMENT to 'ensure compliance'. 'Ensure' is a code word for 'document'.

Best to write up your station and antenna description , and copy the output of the calculator, all dated, and put into a folder--put it on the cloud if you want.

We have 3 years to do this for extant station and antenna setups. Each time we change or start anew with same, we have to do an immediate and documented analysis.

73
Chip W1YW

 

So I guess I am just to stupid to understand! But Chip has ALL the answers. And loves to argue!
So Chip have you ever had to document MPE compliance ? I have! You know I had a "manager" just like you. A Yankee who always was right!
So step up. You know it all. Prepare us the ultimate document we all need!
You seem to want to be the QRZ expert!
I retired ti get away from MICRO MANAGEMENT!

 

Nope. never said that.

BTW I was a resident of the South for decades. Y'all pay attention now.

I am not responsible for your pent up anger. I am not a proxy for those in your past.

What I have presented are prudent approaches to 'ensure compliance'.

No more. No less.

Certain statements you have made are just not correct , such as your statement suggesting ignoring passengers. It seems, to me, a shirking of responsibility. If they are, say, two feet from an HF whip and there is a 100 watt transmission, prudence would dictate making the passenger(s) aware, or better yet, cutting down the power. Ensure compliance.

Having done a fair amount of desert travel, there is clearly benefit to HF mobile in that and other circumstances.

It is within your determination to ignore my statements. Instead you want to provoke a personal conflict. Sorry, not in for that.

Have a pleasant day.

73
Chip W1YW

 

Well the way it works from the FCC includes both.

“Duty factor” takes care of the characteristics of SSB or CW etc. on transmission not being 100% key down power continuously, and these are set out in table 2 in supplement B.

“Duty cycle” accounts for the time transmitting vs time listening.

Both are used in the calculation.

If you want to use 100% duty cycle in your calculations in order to arrive at some wacky worst case, go right ahead. I’ll use what the FCC allows me to do.

 

And analysis can go from practical to ridiculous in short order. As an example of the latter, factor in the difference between two CW operators - one accomplished QRQ type and the other a raw QRS guy just learning the code. Their "duty factors" will be drastically different.

Insignificant difference? Perhaps. But consider the fact that there's nothing stopping that QRS operator from running full legal output at barely 5 WPM. Suddenly that "insignificant difference" isn't so insignificant.

My HW-8 is staring at me as I type this with the CTL-B and Vibrolux sitting just right of the mouse...

...I think I'm exempt.

 

.........................

Ok CHIP... Let see......what you got.

Using the various on line calculators and running the numbers... YES I am in compliance. Gets a little iffy above VHF and up, but that's another story.

If not... show me where I am wrong. Willing to learn from an expert and crow is not that bad if done right.

Here's the set up. 1.8 to 30 MHz, 100 Watts, lossy mobile HF antenna, but for giggles 2 dB gain, radiating element 9 feet above the ground, distance to first passenger 7 feet, feed line 10 feet loss .2 dB, SSB no compression. 1 minute QSO exchanges back and forth, speed 52 MPH.

Sit down, seat belt on, Shut up, and enjoy the ride, it 's a hobby... OH and life s not without some risk.

Where's the radio police when you need them?

CAM WA6VVC / WA6CAM

 

LOL! great stuff Cam! A perfect response...


Hey "Chip",

OET Bulletin 65, Sup.B [Introduction] specifically states:

All mobile amateur stations are categorically excluded from this requirement. Such mobile stations are presumed to be used only for very infrequent intermittent two-way operation. They are, however, required to comply with the exposure guidelines. Otherwise the operation is categorically excluded from routine RF radiation evaluation except as specified in Sections 1.1307(c) and (d) of the FCC’s Rules.

So much for that argument.

 

I still have my hairline despite so much RF in my shack.

 

Hi,
I have a custom modified Hf amp that puts out 8,000 watts, into a K40 3’ antenna which is mounted on the side of my bath tub. My transmitter and amp is mounted above the water line of course, to ensure it doesn’t get wet and short something out! Anyway, I found if I TX while sitting in the warm water, I get better signal reports I think because of the strong grounding the water in the tub creates since my K40 isn’t grounded at all (plastic mount). Anyway, I’m a bit long winded and usually transmit at 90% power for about 15 minute intervals before taking a 30 second break.

I think I am all good/exempt, yes? Thanks, and 10-4, or is it 73? Over!

 

I hear there is an "IGNORE" function so as not to read post from certain folks.

There is nothing wrong with input from another person. Especially if it is with the topic at hand. If you don't like their comments just ignore them.

ok....now back to my popcorn.

 

We finally got to the point with streaming video where we were not being blamed for "messing up the TV" and now we will be accused of "Microwaving" the neighborhood.