Primarily for general aviation discussion, but other aviation topics are also welcome.
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User avatar
By Dave W
FLYER Club Member  FLYER Club Member
#1833401
What is the actual hazard? Tootsies get a bit warm, or they rot, or you die 6 months earlier?

We know none of that and so we cannot knowledgeably accept a risk for which we don't know the consequences: just as our pax cannot.

Those same pax that are just about to defy gravity with us, trusting us the manage all those other associated risks for them.

Nope, makes no sense. It's not proportionate and there is a logic gap here.
Rob P, Supercat liked this
By Dominie
#1833408
xtophe wrote:
Dave W wrote:Chaps, my point was that if it is a hazard it logically is a hazard for every human regardless of whether they are owner, operator, maintainer or passenger.

It is illogical to exempt by role some humans and not others.


Yes but as the radio owner/operator you control the risk and you can choose to accept it for yourself.
But you cannot force that risk on third parties.

Third parties are not forced to fly with me!
By Stampe
FLYER Club Member  FLYER Club Member
#1833412
For those of us who operate on a CofA and have a radio annual certification this is surely a task to be delegated to certifying and qualified engineer to whom I pay a considerable sum.Job done!
Fly safe andRegards Stampe
By Hangar16
#1833413
The logic gap for me begins with the Ofcom document failing to describe or quantify the risks involved. The nearest it gets is “In normal conditions, most uses of radio spectrum for wireless communications present no health risk to humans - but exposure to very high levels of radiofrequency EMF can be harmful”
A link is offered which takes you to a PHE document relating to mobile phone base stations, which again fails to describe the risk. I guess if I had the time I could burrow deeper but suspect the answer becomes increasingly hypothetical.

Ultimately I guess the law will make me comply
Dan
User avatar
By kanga
#1833433
Spooky wrote:..

..Someone has seen the opportunity to justify their job :shock:


I'd expect, rather, that someone at OfCom has been told (possibly by someone senior at OfCom) to take steps to ensure that all their licensees are complying with a public health legal requirement; not new, but which OfCom had not noticed before. One thing which might have triggered this is FOIA or EIR request, or a panicky response by a Minister to a MP's or Lobbyist's query.

I very much doubt the hapless OfCom official either welcomed this or was idle beforehand :roll:
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By patowalker
FLYER Club Member  FLYER Club Member
#1833439
Dave W wrote:What is the actual hazard? Tootsies get a bit warm, or they rot, or you die 6 months earlier?

Tootsies do get a bit warm. There is a link in the OFCOM email to this ICNIRP page, which describes the hazard.
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User avatar
By Marvin
#1833447
I was at one time authorised to undertake ionising and non-ionising radiation surveys and I can assure you that there is a hazard with Non-ionising radiation or EMF as OfCOM are referring. There are many papers on scientific studies and during the course we were shown photographs of various injuries, not all visible on the skin surface. I tried to find images to post but decided against as some can be quite gruesome.

That said the main work I did was on high power Radar Systems, Multifrequency high power communications towers as well as ground navigation equipment such as DME, ILS, NDB etc. Needless to say to protect the public and people working on this type of kit, we had fenced off areas with Key Lock systems to prevent access while equipment was radiating and and work procedures to follow to minimise risk.

I am not going to provide any assurances about the average kit on a GA aircraft, or airfields for that matter, but it would appear that maybe the various manufacturing installation instructions may not have been clear on antenna siting in relation to the issue and certainly there are no clear guidelines that I can find on what the relevant duty cycles are for a DME, Transponder or even a VHF comm all of which are relevant to determining the risk and identifying an acceptable means of compliance on this matter which also takes into account the fact that we install kit which has to have CAA approvals and installation standards applied.

If I may, Trig Avionics have written a Frequently Asked Question on this matter for their transponders but I have not identified any other manufacturers.

The point is there is no clear direction on an Acceptable Means of compliance for our sector of aviation and I am aware that AOPA and LAA have made representations to the CAA to follow this up with OfCOM especially as the CAA may not have been aware that OfCOM were in the process of consulting on the subject. I myself have also written as licence holder objecting to the proposal, lack of transparent consultation with the GA industry and lack of information from equipment specifications and operations manuals as to what the duty cycles may be. The letter from OfCOM to licence holders does say that you may raise an issue with them up until 18th April 2021 and perhaps a suitable worded letter would be appropriate

The hazard has not appeared as if by magic, I was doing this work in the late 1980, I suspect that it is a consequence of OfCOM taking over all this frequency related from the CAA but cannot be sure of that.

Sorry for the lengthy post.
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User avatar
By Dave W
FLYER Club Member  FLYER Club Member
#1833469
Marvin wrote:I was at one time authorised to undertake ionising and non-ionising radiation surveys and I can assure you that there is a hazard with Non-ionising radiation or EMF as OfCOM are referring.

Oh, I'm not doubting that there is a hazard from some sources of radiation. In a previous life I was well aware of that.

What I am questioning is whether there is a hazard that only affects passengers - and not pilots, operators or maintainers despite their well-known super-human characteristics.
User avatar
By Marvin
#1833479
Dave W wrote:
Marvin wrote:I was at one time authorised to undertake ionising and non-ionising radiation surveys and I can assure you that there is a hazard with Non-ionising radiation or EMF as OfCOM are referring.

Oh, I'm not doubting that there is a hazard from some sources of radiation. In a previous life I was well aware of that.

What I am questioning is whether there is a hazard that only affects passengers - and not pilots, operators or maintainers despite their well-known super-human characteristics.

A fair question and so I suggest this document: Principles of non-ionising radiation protection from the ofcom website which outlines:

Categories of exposure
In non-ionizing radiation protection, a distinction is made between occupational exposure, exposure of the general pub- lic, and medical exposure of patients. One reason for the
5Effects can for instance be life-threatening, such as cancer and excessive heating, or debilitating, such as eye damage.
http://www.health-physics.com

distinction between restrictions for occupational and gen- eral public exposure is that occupationally-exposed individ- uals can be considered a more homogeneous group than the general population. Occupationally-exposed individuals are, in general, relatively healthy adults within a limited age range, while the general population contains diverse groups such as very young children and the elderly who might be more sensitive to adverse effects of non-ionizing radiation exposure, for instance because they have less efficient ther- moregulatory capacity. Thus, it is assumed that there is greater variability in sensitivity among the general population than among occupationally-exposed individuals. Another reason is that occupationally-exposed individuals should be operating under controlled conditions and be informed about the risks associated with non-ionizing radiation expo- sure for their specific situation and how to reduce these risks. Members of the general public are, in most cases, unaware of their exposure to non-ionizing radiation and, without educa- tion, cannot reasonably be expected to take precautions to minimize or avoid any adverse effects of exposure. For types


Basically the difference between this who are generally considered overalls healthy, informed and able to knowledgeable control their exposure and understand the risk as opposed to the general public who are considered innocents, less healthy, vulnerable, not informed and unable to control exposure to something they are not aware of.
User avatar
By Dave W
FLYER Club Member  FLYER Club Member
#1833492
How are pilots "informed"?

They are not - this is not part of the training syllabus (not even close), and for pilots that rent or who otherwise have no direct engagement with aircraft ownership they will have no prompt to a directed means of receiving such knowledge.

In that manner they are no more informed than their passengers, and are in practice "the general public".

No; U cannot see that there is any logic at all to this implicit assumption that pilots are automatically better able to assess any risk than their passengers - and for OFCOM to believe they are, and set policy based on that then that is blinkered bum-covering bureaucracy at its worst.

Note that I am not suggesting that there is in fact any practical risk! I am railing against OFCOM's lack of logic and blind adherence to their process.
User avatar
By Marvin
#1833497
Dave W wrote:How are pilots "informed"?

They are not - this is not part of the training syllabus (not even close), and for pilots that rent or who otherwise have no direct engagement with aircraft ownership they will have no prompt to a directed means of receiving such knowledge.

In that manner they are no more informed than their passengers, and are in practice "the general public".

No; U cannot see that there is any logic at all to this implicit assumption that pilots are automatically better able to assess any risk than their passengers - and for OFCOM to believe they are, and set policy based on that then that is blinkered bum-covering bureaucracy at its worst.

Note that I am not suggesting that there is in fact any practical risk! I am railing against OFCOM's lack of logic and blind adherence to their process.


The regulations and the documents I’ve quoted are not specifically written for pilots or in fact our corner of aviation. I would bet that OfCOM have little knowledge about aircraft, pilots etc and would normally get that from consultation with the aviation sector. That appears at first sight to have been lacking until this point of sending out letters of intent and asking for feedback.

If pilots/Operators have little training or knowledge then they are in fact “innocents” and it’s reasonable that they be subject to the same levels of exposure as the general public.

The issue I believe is that as a community we have insufficient information to make an informed declaration on the subject which is what is been asked. Hence its plausible to turn to the regulators of the equipment we have fitted and, for transponders, mandated to turn on if fitted and working, for guidance on how to comply.

I’m not sure that berating them for any lack of sympathy for our situation is going to help unless we are prepared to educate surely. That means feedback, directly and through the bodies who represent this sector of aviation.
By johnm
FLYER Club Member  FLYER Club Member
#1833526
Having done a bit more reading, as far as I can tell the only kit in a light aircraft that might have a power output and duty cycle that could be relevant is a Mode S ES transponder.
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