While I am waiting for my test sample to (finally) die... OSHA does NOT mandate any EMC requirements through the NRTL program. OSHA has adopted the FDA guidelines for RF-emitting devices used in the work place. OSHA bases these limits on FDA guidelines, which also establishes the limits used by other federal agencies. Some limits are codified in various CFR sections. I am not aware of any SAR-related material in the NEC.
The American governmental bureaucracy is confusing, but here is my synopsis of the part of this mess that could be considered related to SAR-based stuff: OSHA = Dept of Labor -> concerned with work-place safety, implements the NRTL program FCC = independent federal agency -> concerned with preserving the spectrum CDRH = FDA = Dept of Health and Human Services -> the FDA in particular is focused on 'technical' safety, while the HHS is concerned with direct services and public welfare CPSC - independent federal agency -> legally authorized to regulate the marketing of all consumer-related materials except guns, drugs, food, and vehicles. The people that your lawyers will talk to if your device bakes a human organ. Department of Defense (DOD) - RF energy + biology research (Brooks AFB) -> data has been used by FDA EPA - 'wannabe' in the RF safety field - not a 'full' cabinet-level agency; ignore them. incomplete chronology: 1968- Radiation Control for Health and Safety Act -> mostly to limit ionizing radiation 1969 - National Environmental Policy Act -> an ambiguos and open-ended text that allows the EPA to get involved in anything for any reason. 1971- OSHA issued 29 CFR 1910.97 1985 - FCC adopts 1982 ANSI standard -> must now consider effects of RF on enviroment 1992 - new standard for RF exposure ANSI/IEEE C95.1-1992 1995 - FCC updates CFR to include ANSI/IEEE C95.1-1992 exposure limits 1999 - formal filing for FCC to adopt CISPR 22 emissions limits 2001 - updated CFR formally released w/CISPR 22 harmonization Other than the SAR-based stuff, it should be noted that, outside of vehicle, medical, aviation, and military, there is no generic requirements for EMC-related functional safety of consumer goods in American code. luck, Brian > -----Original Message----- > > > Also, was there a date that a U.S. safety law WAS enacted and by who > (OSHA)? > > Thanks,, > Dave Lohbeck - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc ______________________________________________________________________ This e-mail has been scanned by MCI Managed Email Content Service, using Skeptic(tm) technology powered by MessageLabs. For more information on MCI's Managed Email Content Service, visit http://www.mci.com. ______________________________________________________________________
