Station Compliance›Field Notes

Most compliance gaps described on this site are recent, driven by a rule adopted this year. This one is the opposite: the rules changed years ago, the transition period ran out in May 2023, and a large number of stations never did anything because nothing arrived in the mail to tell them to.

If you have not looked at your RF exposure compliance since before 2020, you are working from a framework that no longer exists.

The two limits

The foundation has not changed. § 1.1310 sets maximum permissible exposure in two categories:

• Occupational / controlled exposure — people who are aware of the exposure and can exercise control over it. Your engineer on the roof.
• General population / uncontrolled exposure — everyone else. A limit several times stricter, applying to anyone who has not been trained and cannot be expected to know.

The distinction matters more than the numbers for most small stations, because compliance usually turns not on reducing power but on controlling who can get where.

What actually changed

The Commission's 2019 order — FCC 19-126 — rewrote the framework around exposure rather than around service type.

Categorical exclusions were replaced by exemption criteria. The old model excluded whole categories of facility from evaluation. The new model in § 1.1307(b) sets out exemption criteria based on power, separation distance and frequency. The question is no longer "am I the kind of station that is excluded?" but "does this specific source, at this specific distance, meet the exemption test?"

Mitigation became a defined, tiered obligation. Where limits are exceeded, the rules now specify what you have to do about it, with signage and access control spelled out rather than left to judgement.

The deadlines. Rule changes took effect June 1, 2020 for § 1.1310 and May 3, 2021 for the § 1.1307(b) changes. Existing facilities were given a transition: they could rely on compliance with the prior rules, but had to comply with the new ones no later than May 3, 2023.

The four tiers

Where evaluation shows limits are exceeded, mitigation is tiered by severity. In practical terms:

Signs must carry the signal word and its colour, the RF energy symbol, an explanation of the source, what behaviour is required to comply, and current contact information — and they must be visible from the boundary of the area where the limits are exceeded.

That last requirement is the one to check first. A correct sign bolted to the transmitter building does nothing if the area where the limit is exceeded starts at the fence line.

What a small station usually needs

For most small-market AM and FM facilities, the honest picture is:

• The tower site needs a real boundary. A fence that is intact, a gate that latches, and signage at the point where someone would encounter the exposure — not only at the building.
• Contact information on the signs has to be current. A sign naming an engineer who retired in 2014 fails the "current contact information" requirement and tells an inspector how long since anyone looked.
• AM stations have particular exposure at the base. Energised towers and ground systems put the exceedance right where people walk.
• Rooftop sites need coordination. Where you share a roof, the exposure environment includes everyone else's transmitters, and access by building maintenance staff — who are general population, not occupational — is the risk.
• Somebody needs to have done an evaluation, or to have documented that the facility meets the exemption criteria in § 1.1307(b). "We assumed we were excluded" is not a record.

Enforcement

The Commission does issue forfeitures here. A-O Broadcasting was assessed a $25,000 forfeiture for violations of RF radiation limits alongside other rule violations.

The pattern in RF cases is that they tend to surface during an inspection prompted by something else. An engineer arrives for a different reason and the fence is open, the signs are missing, or the signage is the pre-2021 style. It is rarely the thing that triggers the visit; it is frequently the thing found during it.

What to do, in order

1. Find out whether an evaluation exists. If your facility has never been evaluated under the current rules, that is the gap.
2. Determine whether you meet the § 1.1307(b) exemption criteria for each source. This is genuinely technical and it is the right place to bring in a consulting engineer — the arithmetic depends on power, frequency and distances specific to your site.
3. Walk the site and look at your signage. Right tier, right placement, right symbol, current contact.
4. Check the physical boundary. A fence with a gap is the whole control failing.
5. Write down what you found and what you did. As with § 11.35(d), nothing gets filed — the record exists for the next person.

Where this differs from the rest of the site

Most of what is published here can be worked through by a competent station person with a weekend and a checklist. RF exposure is the exception. The exposure calculations are real engineering, the consequences of getting them wrong are health consequences rather than paperwork ones, and the right move for most small stations is to pay a consulting engineer for an evaluation rather than to estimate.

What you can do yourself is find out whether an evaluation exists, and look at your fence and your signs. That alone will tell you whether you have a problem.

Tower lighting covers the other obligation that lives at the tower site, and the compliance calendar covers what runs on a schedule.