In the wirelessly connected world, radiofrequency (RF) signals are everywhere. They provide music to our radios, voice and data communications to our cell phones, internet connectivity to rural areas – the list of wireless services goes on and on.
Health Canada maintains a standard called Safety Code 6 which sets limits for human exposure to RF electromagnetic energy. Wireless spectrum users, be they broadcasters, cellular providers, or others are required to maintain compliance with Safety Code 6 at all times.
To an individual spectrum licence holder, the ability to demonstrate compliance on an ongoing basis in a multi-tenant (and sometimes multi-tower) communication site can be a challenge. There is no practical mechanism for a tenant on a communication tower to be notified of the addition of a new service or the modification of an existing one. Certainly there are publicly accessible databases which contain information on most licensed services. Due to security requirements, wireless systems used by law enforcement and military are not public for obvious reasons. Some services, such as certain spread-spectrum devices, do not require a licence.
The various licence databases maintained by Innovation, Science, and Economic Development Canada (or ISED), while a valuable resource to an engineer completing calculations of RF contributions from various sources to determine if a site conforms to Safety Code 6, need to be carefully looked at and compared with antenna inventories from structural reports to sort out any discrepancies.
ISED can request a report demonstrating Safety Code 6 compliance, which is due within 5 business days of the request. In order to be confident of compliance, each spectrum user, in theory, would have to have reliable up-to-date operating parameters for all other spectrum users on the same tower, and in some instances adjacent towers on the same property, hilltop, mountain, etc.
The communication tower owner, by virtue of the contractual relationship with the tenants, is in the best position to be completely up to speed with at least the antenna inventory on the tower, but hopefully the operating parameters as well. While the tower owner, assuming that it is not a spectrum licence holder itself, has no real obligation to comply with Safety Code 6 (since that is the responsibility of the license holder), it has a vested interest in having its tenants comply to the standard. The erection of any fencing or signage that may be required to bring a site into compliance will certainly be done under the control of the tower/site owner.
In the same way that the tower owner normally takes on the task of regular maintenance inspections and structural analysis, a regular Safety Code 6 compliance report could be generated, and shared amongst the tenants. In a multi-tower environment, this activity could be much more easily coordinated between a few tower owners, than dozens or perhaps a hundred or more spectrum licence holders depending on the location. The cost of the engineering services to produce the report would also be spread out among the tenants, and ideally included in the monthly lease payments. Rather than have dozens of tenants attempting their own Safety Code 6 compliance reports, a unified approach by the tower owner would be much more economical and beneficial to the tenants. This would be a great added value to potential new tenants.