March 2006 Slide 1 doc.: IEEE 802.15-06/138r0 Submission DRAFT - I Project: IEEE P802.15 Working...

March 2006March 2006

Slide 1

doc.: doc.: IEEE 802.15-06/138r0IEEE 802.15-06/138r0

Submission

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Project: IEEE P802.15 Working Group for Wireless Personal Area NetworksProject: IEEE P802.15 Working Group for Wireless Personal Area Networks

Submission Title:Submission Title: [RF Exposure Rule Under Part 15.255] [RF Exposure Rule Under Part 15.255]Date Submitted: Date Submitted: [March 2006][March 2006]Source:Source: [Gary Baldwin, SiBEAM, Freemont, CA] [ [Gary Baldwin, SiBEAM, Freemont, CA] [[email protected]][email protected]] [Abbie Mathew, NewLANS, Westford, MA] [[email protected]][Abbie Mathew, NewLANS, Westford, MA] [[email protected]] [Kamran Sayrafian, NIST, Gaithersburg, MD] [[email protected]][Kamran Sayrafian, NIST, Gaithersburg, MD] [[email protected]]Re:Re: [] []Abstract: Abstract: [][]

Purpose:Purpose: [[Contribution to 802.15 TG3c at March 2006 plenary in DenverContribution to 802.15 TG3c at March 2006 plenary in Denver]]

Notice:Notice: This document has been prepared to assist the IEEE P802.15. It is offered This document has been prepared to assist the IEEE P802.15. It is offered as a basis for discussion and is not binding on the contributing individual(s) or as a basis for discussion and is not binding on the contributing individual(s) or organization(s). The material in this document is subject to change in form and organization(s). The material in this document is subject to change in form and content after further study. The contributor(s) reserve(s) the right to add, amend or content after further study. The contributor(s) reserve(s) the right to add, amend or withdraw material contained herein.withdraw material contained herein.Release:Release: The contributor acknowledges and accepts that this contribution becomes The contributor acknowledges and accepts that this contribution becomes the property of IEEE and may be made publicly available by P802.15.the property of IEEE and may be made publicly available by P802.15.


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Top Level Document Flow ChartTop Level Document Flow Chart

§1.1307(b)§1.1307(b)Compliance ActionsCompliance Actions

§1.1310§1.1310Radiation ExposureRadiation Exposure

§15.255(g)§15.255(g)RF Radiation ExposureRF Radiation Exposure

§2.1091§2.1091Mobile DeviceMobile Device

§2.1093§2.1093Portable DevicePortable Device

ANSI/IEEE C95.1-ANSI/IEEE C95.1-19921992

§15.255§15.255

Abbie Mathew, NewLANSAbbie Mathew, NewLANS


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Top Level Document Flow ChartTop Level Document Flow Chart

§1.1307(b)§1.1307(b)Compliance ActionsCompliance Actions

§1.1310§1.1310Radiation ExposureRadiation Exposure

§15.255(g)§15.255(g)RF Radiation ExposureRF Radiation Exposure

§2.1091§2.1091Mobile DeviceMobile Device

§2.1093§2.1093Portable DevicePortable Device

ANSI/IEEE C95.1-ANSI/IEEE C95.1-19921992

§15.255§15.255


1.1307(b)(1)1.1307(b)(2)1.1307(b)(3) 1.1307(b)(3)(i) 1.1307(b)(3)(ii)1.1307(b)(4)

2.1091(a)2.1091(b)2.1091(c)2.1091(d) 2.1091(d)(1) 2.1091(d)(2) 2.1092(d)(3) 2.1092(d)(4)

2.1093(a)2.1093(b)2.1093(c)2.1093(d) 2.1093(d)(1) 2.1093(d)(2) 2.1093(d)(3) 2.1093(d)(4)


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Review of Part 15.255 RulesReview of Part 15.255 Rules

2. Limits on Human Exposure to RF Emissions2. Limits on Human Exposure to RF Emissions

1. Limits on Emission1. Limits on Emission

Average power density ≤ 9 W/cm2 at 3 m• Translates to EIRP of 40 dBm in the far field

Peak power density ≤ 18 W/cm2 at 3 m• Translates to an EIRP of 43 dBm in the far field

Total peak transmitter power ≤ 500 mW

3 m is in the far field for small apertures

Information contained in OET Bulletin 65

Enables an applicant to make a reasonably quick determination as to

whether a proposed or existing facility is in compliance with the limits

3. Transmitter Identification3. Transmitter Identification Within any 1 second interval of signal transmission, each transmitter must

transmit a transmitter identification at least



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Mobile & Portable DevicesMobile & Portable Devices§2.1091 & §2.1093§2.1091 & §2.1093

MobileMobile PortablePortable

DefinitionDefinition

§2.1091(b)§2.1091(b)

Transmitting devices where Transmitting devices where the antenna is at least 20 the antenna is at least 20 cm from the usercm from the user

§2.1093(b)§2.1093(b)

Transmitting devices where Transmitting devices where the antenna is within 20 cm the antenna is within 20 cm from the body of the userfrom the body of the user

CertificationCertification

§2.1091(c), §1.1307(b)(2)§2.1091(c), §1.1307(b)(2) §2.1093(c), §1.1307(b)(2)§2.1093(c), §1.1307(b)(2)

Require RF exposure evaluation prior to equipment Require RF exposure evaluation prior to equipment certificationcertification



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MobileMobile PortablePortable

Warning LabelWarning Label(Controlled Exposure)(Controlled Exposure)

§2.1091(d)§2.1091(d)

Compliance with exposure Compliance with exposure guidelines can be guidelines can be accomplished by the use of accomplished by the use of warning labels and by warning labels and by providing users with providing users with information on minimum information on minimum separation distanceseparation distance

§2.1093(d)(1)§2.1093(d)(1)

Awareness of exposure can Awareness of exposure can be accomplished by use of be accomplished by use of warning labels or by specific warning labels or by specific training or education through training or education through appropriate means, such as an appropriate means, such as an RF safety program in a work RF safety program in a work environment.environment.

Warning LabelWarning Label(Uncontrolled Exposure)(Uncontrolled Exposure)

Same as aboveSame as above §2.1093(d)(2)§2.1093(d)(2)

Not PermittedNot Permitted


NoteFor mobile devices, warning labels can be used for controlled and uncontrolled exposures


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Unclear Distinction

If the device usage does not allow easy classification as either mobile or portable then applicants are responsible for determining minimum distances for compliance for the intended use and installation of the device based on power density



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Actions For Non-ComplianceActions For Non-Compliance

§1.1307(b)§1.1307(b)

If the radiator as specified in §1.1310 and §2.1093 is exceeded, If the radiator as specified in §1.1310 and §2.1093 is exceeded, then Environment Assessment (EA) has to be preparedthen Environment Assessment (EA) has to be prepared

Applications or renewals for equipment authorization or modification Applications or renewals for equipment authorization or modification must contain a statement confirming compliance with the limits in must contain a statement confirming compliance with the limits in §1.1310 and §2.1093§1.1310 and §2.1093

§1.1307(b)(2)§1.1307(b)(2) Require evaluation for RF exposure prior to equipment authorization Require evaluation for RF exposure prior to equipment authorization or use as specified in §15.255(g)or use as specified in §15.255(g)

§1.1307(b)(3)(i)§1.1307(b)(3)(i)

Applicant of previously compliant transmitters that are now non-Applicant of previously compliant transmitters that are now non-compliant with limits in §1.1310 must submit an Environment compliant with limits in §1.1310 must submit an Environment Assessment (EA) if power density emissions exceeds 5% of the Assessment (EA) if power density emissions exceeds 5% of the exposure limitexposure limit

§1.1307(b)(3)(ii)§1.1307(b)(3)(ii)

Renewal applicant of previously compliant transmitter that are now Renewal applicant of previously compliant transmitter that are now non-compliant with limits in §1.1310 must submit an Environment non-compliant with limits in §1.1310 must submit an Environment Assessment (EA) if power density emissions exceeds 5% of the Assessment (EA) if power density emissions exceeds 5% of the exposure limitexposure limit



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DefinitionsDefinitions

Occupational/Controlled ExposureOccupational/Controlled Exposure• Work related or transient in natureWork related or transient in nature• Person must be fully aware of exposurePerson must be fully aware of exposure• Person must have knowledge to control and limit Person must have knowledge to control and limit

exposureexposure• Require RF exposure trainingRequire RF exposure training• High exposure limits applyHigh exposure limits apply


General Population/Uncontrolled ExposureGeneral Population/Uncontrolled Exposure• Apply to all consumer devicesApply to all consumer devices• No knowledge of exposure is requiredNo knowledge of exposure is required• More restrictive exposure limits applyMore restrictive exposure limits apply


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DefinitionsDefinitions


Maximum Permissible Exposure (MPE):Maximum Permissible Exposure (MPE): The plane- The plane-wave equivalent power density to which a person may be wave equivalent power density to which a person may be exposed without harmful effect and with an acceptable exposed without harmful effect and with an acceptable safety factorsafety factor

Power density: Power density: Power per unit area normal to the Power per unit area normal to the direction of propagation, expressed in mW/cmdirection of propagation, expressed in mW/cm22 or or μW/cmμW/cm22


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Absolute MPE Limits for DifferentAbsolute MPE Limits for Different FrequenciesFrequencies


20

1

5

100

1

0.2

0 1 10 100 1,000 10,000 100,000

Frequency, MHz

Controlled, mW/cm2

Uncontrolled, mW/cm2


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Spatial AveragingSpatial Averaging

These exposure guidelines apply to power densities that These exposure guidelines apply to power densities that are spatially averaged over the body dimensions* are spatially averaged over the body dimensions*

Local values of exposures that exceed the stated MPEs Local values of exposures that exceed the stated MPEs may not be related to non-compliance if the spatial may not be related to non-compliance if the spatial average of RF fields over the body does not exceed the average of RF fields over the body does not exceed the MPEs MPEs

Further discussion of spatial averaging as it relates to Further discussion of spatial averaging as it relates to field measurements can be found in OET-65 and in the field measurements can be found in OET-65 and in the ANSI/IEEE and NCRP reference documentsANSI/IEEE and NCRP reference documents

Kamran Sayrafian, NISTKamran Sayrafian, NIST

* This information is as of March 2006. Spatial averaging window size is under active rulemaking

process. Please direct further inquiries to FCC


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Partial Body ExposurePartial Body Exposure

Partial-body exposure results when RF fields are Partial-body exposure results when RF fields are substantially non-uniform over the bodysubstantially non-uniform over the body

Fields that are non-uniform over volumes comparable to Fields that are non-uniform over volumes comparable to the human body may occur due to highly directional the human body may occur due to highly directional sources, standing-waves, re-radiating sources or in the sources, standing-waves, re-radiating sources or in the near fieldnear field

Limits for localized absorption are based on Limits for localized absorption are based on recommendations of both ANSI/IEEE and NCRPrecommendations of both ANSI/IEEE and NCRP



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Temporal AveragingTemporal Averaging

Exposures, in terms of power density, may be averaged Exposures, in terms of power density, may be averaged over certain periods of time with the average not to over certain periods of time with the average not to exceed the limit for continuous exposureexceed the limit for continuous exposure

FCC has not explicitly adopted limits forFCC has not explicitly adopted limits for peak peak power power density (guidance on these types of exposures can be density (guidance on these types of exposures can be found in Section 4.4 of the ANSI/IEEE C95.1-1992 found in Section 4.4 of the ANSI/IEEE C95.1-1992 standard)standard)


Average (Temporal) PowerAverage (Temporal) PowerThe time-averaged rate of energy transferThe time-averaged rate of energy transferAveraging TimeAveraging TimeThe appropriate time period over which exposure is averaged for purposes of The appropriate time period over which exposure is averaged for purposes of determining compliance with RF exposure limits.determining compliance with RF exposure limits.Continuous ExposureContinuous ExposureExposure for durations exceeding the corresponding averaging time Exposure for durations exceeding the corresponding averaging time


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Time-Averaged MPE Limits Time-Averaged MPE Limits §1.1310§1.1310

FrequencyFrequency

(GHz)(GHz)

Power DensityPower Density

(mW/cm(mW/cm22))

Averaging TimeAveraging Time

(minutes)(minutes)

Controlled ExposuresControlled Exposures

1.5 to 100.01.5 to 100.0

55 66

Uncontrolled ExposuresUncontrolled Exposures 11 3030

• Controlled exposure applies in situation where a person is exposed as a consequence of his employment, provided he is fully aware of and can exercise control over his exposure.

• Uncontrolled exposure applies in situation where the general public may be exposed, or when a person is exposed as a consequence of employment may not be fully aware of the potential for exposure or cannot exercise control over his exposure.



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Time-Averaged MPE LimitsTime-Averaged MPE Limits

In general, the sum of the products of the exposure levels and the In general, the sum of the products of the exposure levels and the allowed times for exposure must equal the product of the appropriate allowed times for exposure must equal the product of the appropriate MPE limit and the appropriate time-averaging intervalMPE limit and the appropriate time-averaging interval


2expexp /30 cmmWtStS minlimitlimit

SSexpexp = power density level of exposure (mW/cm = power density level of exposure (mW/cm22))

SSlimitlimit = appropriate power density MPE limit (mW/cm = appropriate power density MPE limit (mW/cm22))

TTexpexp = allowable time of exposure (minutes) = allowable time of exposure (minutes)

TTavgavg = appropriate MPE averaging time (minutes) = appropriate MPE averaging time (minutes)

wherewhere


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Time AveragingTime Averaging

• MPE limits adopted by the FCC areMPE limits adopted by the FCC are time-averaged exposure limits time-averaged exposure limits • This means that the exposure duration should be taken into account This means that the exposure duration should be taken into account • Especially relevant for cases of occupational/controlled exposureEspecially relevant for cases of occupational/controlled exposure

ExampleExample

The relevant interval for time-averaging for occupational/controlled The relevant interval for time-averaging for occupational/controlled exposures is six minutes as shown belowexposures is six minutes as shown below


30 mW-min/cm30 mW-min/cm22

time6 min (Sliding Window)

5 m

W/c

m2


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Time AveragingTime AveragingExample for Controlled EnvironmentsExample for Controlled Environments

• During any given six-minute period a worker could be exposed to two times During any given six-minute period a worker could be exposed to two times the applicable power density limit for three minutes as long as he or she were the applicable power density limit for three minutes as long as he or she were not exposed at all for the preceding or following three minutes or not exposed at all for the preceding or following three minutes or

• He/She could be exposed at three times the limit for two minutes as long as He/She could be exposed at three times the limit for two minutes as long as no exposure occurs during the preceding or subsequent four minutes, and so no exposure occurs during the preceding or subsequent four minutes, and so forth.forth.

time

6 min

10 m

W/c

m2

15 m

W/c

m2

3 min 3 min

6 min

30 mW-30 mW-min/cmmin/cm2230 mW-30 mW-

min/cmmin/cm22



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Time Averaging Provision For General Time Averaging Provision For General Population/Uncontrolled EnvironmentsPopulation/Uncontrolled Environments

• For devices intended for use by consumers in general For devices intended for use by consumers in general population/uncontrolled environments time-averaging provisions may population/uncontrolled environments time-averaging provisions may not be used in determining typical exposure levels (§2.1091(d)(2)). not be used in determining typical exposure levels (§2.1091(d)(2)). However, However, source-based’ time-averagingsource-based’ time-averaging based on an inherent based on an inherent property or duty cycle of a device is allowed.property or duty cycle of a device is allowed.


In contrast to "user-based" or “activity-based”, source-based time-In contrast to "user-based" or “activity-based”, source-based time-averaging does not consider user behavior when calculating the time-averaging does not consider user behavior when calculating the time-average. For example, it cannot be assumed that users will step average. For example, it cannot be assumed that users will step in/out of exposure for certain periods of time.in/out of exposure for certain periods of time.


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Source-Based Time AveragingSource-Based Time Averaging

Example for source-based time-averaging is the Example for source-based time-averaging is the determination of exposure from device that uses digital determination of exposure from device that uses digital technology such as a time-division multiple access technology such as a time-division multiple access (TDMA) scheme for transmission of a signal. In (TDMA) scheme for transmission of a signal. In general, maximum average power levels must be used general, maximum average power levels must be used to determine compliance.to determine compliance.

e.g. A GSM handset can transmit in one out of eight e.g. A GSM handset can transmit in one out of eight possible time slots. This is an inherent property of the possible time slots. This is an inherent property of the source and it does not depend on the user behavior.source and it does not depend on the user behavior.



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IEEE PerspectiveIEEE Perspective

• Recommendation to prevent harmful effects in Recommendation to prevent harmful effects in human beings exposed to electromagnetic fields human beings exposed to electromagnetic fields in the frequency range from 3 KHz to 300 GHzin the frequency range from 3 KHz to 300 GHz

• Apply to exposures in controlled as well as Apply to exposures in controlled as well as uncontrolled environmentsuncontrolled environments


IEEE Standard C95.1, IEEE Standard C95.1, 1999 Edition1999 Edition


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MPE Limits (Controlled & Uncontrolled MPE Limits (Controlled & Uncontrolled Environments)Environments)

Frequency Range Frequency Range (MHz)(MHz)

Power Density (S) Power Density (S) E-field, H-field E-field, H-field

(mW/cm(mW/cm22))

Averaging Time |E|Averaging Time |E|22 , |H|, |H|22 or S (min) or S (min)

15000 - 30000015000 - 300000 1010 616000 / 616000 / f f 1.2 *1.2 *

•Note: f is the frequency in MHz. Also, the averaging time window size is subject to change in the upcoming IEEE draft

For the frequency of 60GHz, the averaging time is approximately 1.137 minutes


* This information is as of March 2006


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Partial Body ExposuresPartial Body Exposures


• Compliance for the MPE is determined from spatial averages of power density over an area equivalent to the vertical cross-section of the human body (projected area) at a distance no closer than 20 cm from any object *.

• For partial body exposure (i.e. all parts except the eyes and the testes), limits on the peak value of the power density exist.

* This information is as of March 2006. Spatial averaging window size is subject to change in the upcoming IEEE draft


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Maximum Peak Value of the Mean Maximum Peak Value of the Mean Squared Field StrengthSquared Field Strength


Maximum Peak value Maximum Peak value of the mean squared of the mean squared

field strengthfield strengthFor For ff = 60 GHz = 60 GHz

Controlled Controlled EnvironmentsEnvironments

20(20(ff/6)/6)1/41/4 mW/cm mW/cm2 2

for frequencies for frequencies between 6 and 96 between 6 and 96 GHzGHz

35.57 mW/cm35.57 mW/cm2 2

Uncontrolled Uncontrolled EnvironmentsEnvironments

20 mW/cm20 mW/cm2 2 for for frequencies above frequencies above 30 GHz30 GHz

20 mW/cm20 mW/cm22


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Summary (as of March 2006!)Summary (as of March 2006!)


FCC Guidelines IEEE Guidelines

Controlled Uncontrolled Controlled Uncontrolled

Absolute MPE Absolute MPE ((mW/cmmW/cm22))

5 1 10 10

Averaging Time Averaging Time (min)(min)

6 30 1.1371 1.1371

Limit on the Limit on the Temporal Peak Temporal Peak ((mW/cmmW/cm22))

None NoneSee Section 4.1.2 Parts

f & g

See Section 4.1.1 parts

f & g

Limit on the Limit on the Spatial Peak Spatial Peak ((mW/cmmW/cm22))

None2 None235.571

(Only for partial body exposure)

201

(Only for partial body exposure)

1 These numbers are as of March 2006. Please watch for possible changes in the upcoming IEEE draft2 This information is as of March 2006. Spatial averaging window size is under active rulemaking process. Please direct further inquiries to FCC


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AcknowledgementAcknowledgement

We would like to express our gratitude to Mr. Ed Mantiply We would like to express our gratitude to Mr. Ed Mantiply

(from the Federal Communications Commission) for his (from the Federal Communications Commission) for his

time in answering our questions and his review of the time in answering our questions and his review of the

materials in this presentation.materials in this presentation.


March 2006 Slide 1 doc.: IEEE 802.15-06/138r0 Submission DRAFT - I Project: IEEE P802.15 Working...

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