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OSHA 1910.97

Nonionizing radiation definitions

Subpart G

19 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.97(a)(1)(i) (Electromagnetic radiation), what part of the electromagnetic spectrum does OSHA mean by "electromagnetic radiation" for this standard?

The term refers specifically to the radio-frequency portion of the spectrum, and for this rule it also includes the microwave region. See 1910.97(a)(1)(i).

Under 1910.97(a)(2)(i) (Radiation protection guide), what numerical exposure limit does OSHA give for frequencies from 10 MHz to 100 GHz?

The radiation protection guide is 10 mW/cm² averaged over any 0.1-hour period (6 minutes), which corresponds to a power density of 10 mW/cm² and an equivalent energy density of 1 mW‑hr/cm² during that 0.1‑hour period. See 1910.97(a)(2)(i).

Under 1910.97(a)(2)(i), does the 10 mW/cm² guide apply to both continuous and intermittent radio‑frequency radiation?

Yes — the 10 mW/cm² radiation protection guide applies whether the radiation is continuous or intermittent. See 1910.97(a)(2)(i).

Under 1910.97(a)(2)(ii), does the radiation protection guide cover both whole‑body and partial‑body irradiation, and why is partial exposure important?

Yes — the guide covers both whole‑body and partial‑body irradiation because some body parts (for example, the eyes and testicles) may be harmed by exposures well above the general guide. See 1910.97(a)(2)(ii).

Under 1910.97(a)(3)(i), what does the required radio‑frequency radiation warning symbol look like and what text must appear on it?

The symbol must consist of a red isosceles triangle above an inverted black isosceles triangle with an aluminum‑color border, and the words “Warning—Radio‑Frequency Radiation Hazard” must appear in the upper (red) triangle. See 1910.97(a)(3)(i).

Under 1910.97(a)(3)(ii), what color and lettering specifications apply to the RF warning symbol?

All lettering and the border of the RF warning symbol must be aluminum color, and the colors called for (red upper triangle and black lower triangle) should follow the ANSI color specifications incorporated by reference in 1910.6. See 1910.97(a)(3)(ii) and 1910.6 for the ANSI incorporation.

Under 1910.97(a)(3)(iii), can employers add extra precautionary instructions to the RF warning symbol, and where should they appear?

Yes — employers may include additional warning information or precautionary instructions at their discretion, and if included those instructions must appear in the lower triangle of the warning symbol. See 1910.97(a)(3)(iii).

Under 1910.97(a)(1)(iv), what does the standard mean by the word “symbol” in relation to the RF radiation sign?

The word “symbol” refers to the overall design, shape, and coloring of the RF radiation sign shown in Figure G‑11 (the red/black triangles and aluminum border and lettering). See 1910.97(a)(1)(iv).

Under 1910.97(a)(4) (Scope), which sources of radiation does this section cover and what common exemption does it include?

This section applies to radiation originating from radio stations, radar equipment, and other EM sources used for communication, radio navigation, and industrial and scientific purposes, but it does not apply to the deliberate exposure of patients by or under the direction of practitioners of the healing arts. See 1910.97(a)(4).

Under 1910.97(a)(2), what frequency range does the 10 mW/cm² radiation protection guide cover?

The guide covers incident electromagnetic energy with frequencies from 10 MHz to 100 GHz. See 1910.97(a)(2)(i).

Under 1910.97(a)(1)(iii), how does OSHA define a “radiation protection guide” in plain terms?

A radiation protection guide is the radiation level that should not be exceeded without careful consideration of the reasons for doing so — in other words, it is a recommended upper level that calls for review before exposures go higher. See 1910.97(a)(1)(iii).

Under 1910.97(a)(2)(i), how should an employer evaluate intermittent RF exposures shorter than the 0.1‑hour averaging period?

Employers should average exposures over any 0.1‑hour (6‑minute) period; when exposures are intermittent, calculate the energy received during that 0.1‑hour window (the standard gives the energy density as 1 mW‑hr/cm² for the 0.1‑hour period) and ensure the averaged power density does not exceed 10 mW/cm². See 1910.97(a)(2)(i).

Under 1910.97, if I choose to post an RF radiation warning sign, am I required to use the exact design in Figure G‑11?

If you use the radio‑frequency radiation hazard warning symbol, it must consist of the design described (red isosceles triangle above an inverted black isosceles triangle with an aluminum border) as shown in Figure G‑11; the standard mandates that the RF warning symbol shall consist of that design. See 1910.97(a)(3)(i).

Under 1910.97(a)(3)(ii) and 1910.6, where do I find the color specifications referenced for the RF warning symbol?

The color specifications are taken from ANSI standards incorporated by reference in 1910.6 — specifically, ANSI Z53.1‑1967 or ANSI Z535.1‑2006(R2011) as referenced in 1910.97(a)(3)(ii) and 1910.6.

Under 1910.97(a)(2)(ii), why does OSHA say partial body irradiation must be included in recommendations?

Because research has shown certain localized body parts (for example, eyes and testicles) can be harmed by incident radiation levels significantly above the general guide, so the recommendations explicitly include partial‑body irradiation to protect sensitive organs. See 1910.97(a)(2)(ii).

Under 1910.97(a)(2)(i), how does OSHA express the radiation limit as energy density as well as power density?

OSHA gives the limit as a power density of 10 mW/cm² averaged over any 0.1‑hour period and equivalently as an energy density of 1 mW‑hr/cm² during any 0.1‑hour period. See 1910.97(a)(2)(i).

Under 1910.97(a)(4), do the standard's protections apply to diagnostic or therapeutic medical procedures that deliberately expose patients?

No — the section expressly excludes deliberate exposure of patients by, or under the direction of, practitioners of the healing arts from its application. See 1910.97(a)(4).

Under 1910.97, is the radiation protection guide presented as an OSHA permissible exposure limit (PEL) or as a guidance level?

The standard frames it as a "radiation protection guide" — a level that should not be exceeded without careful consideration — rather than labeling it a PEL; employers should treat it as the recommended limit in 1910.97(a)(2)(i) and consider additional controls or evaluations if exposures approach or exceed it. See 1910.97(a)(1)(iii).

Under 1910.97(a)(1)(ii) and 1910.97(a)(2)(ii), how should an employer evaluate potential harm to sensitive organs when employees may receive focused RF energy?

Employers should include partial‑body exposure assessments because the standard explicitly requires considering partial‑body irradiation — certain organs (for example, eyes and testicles) can be more vulnerable and must be evaluated separately from whole‑body averages. See 1910.97(a)(1)(ii) and 1910.97(a)(2)(ii).