• John Forrester commented on 2013-05-17 15:41:56.666:
  Section 3 3): The fundamental requirement for RF exposure evaluation is assessment to the basic restrictions. What is the basis for the 10cm separation distance used in a reference level evaluation instead of completing a basic restriction SAR evaluation? Why not 20cm or 1cm? For frequencies below 10MHz is the FCC considering updating CFR47 and necessary KDBs to also require assessment of induced current (J) and induced E in accordance with the basic restriction requirement defined in ICNIRP. Section 3 4): The FCC should consider defining or providing guideline measurement procedures for validating numerical analysis modeling at frequencies <100MHz. For example, the FCC may recommend E and/or H measurements in free space at different distances from 10cm to 300cm that could be used to validate a numerical model

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Note: It is important to understand that the staff guidance provided in the KDB is intended to assist the public in following Commission requirements and does not constitute rules. Accordingly, the guidance is not binding on the Commission and will not prevent the Commission from making a different decision in any matter that comes to its attention for resolution.