Consultation on Amending CPC-2-0-20 — Radio Frequency (RF) Fields—Signs and Access Control

1. Through the release of this document, Innovation, Science and Economic Development Canada (ISED), on behalf of the Minister of Innovation, Science and Industry (the Minister), is hereby initiating a consultation on proposed amendments to Client Procedures Circular CPC-2-0-20, issue 1, Radio Frequency (RF) Fields – Signs and Access Control.

2. The Minister, through the Department of Industry Act, the Radiocommunication Act, and the Radiocommunication Regulations, with due regard to the objectives of the Telecommunications Act, is responsible for spectrum management in Canada. As such, the Minister is responsible for developing national goals and policies for spectrum utilization, and for ensuring effective management of the radio frequency spectrum resource.

3. The Minister is provided the general powers for spectrum management in Canada, pursuant to section 5 of the Radiocommunication Act and sections 4 and 5 of the Department of Industry Act. Paragraph 5(1)(a) of the Radiocommunication Act provides the Minister with the authority to “issue radio licences in respect of radio apparatus” and “fix the terms and conditions of any such licence.”

4. The Minister, under the Radiocommunication Act, may take into account all matters that the Minister considers relevant for ensuring the orderly establishment or modification of radio stations and the orderly development and efficient operation of radiocommunication in Canada.

5. Pursuant to CPC-2-0-20, anyone operating an antenna installation within Canada (referred to herein as “the operator(s)”) is required to comply with the uncontrolled environment (UE) limits as specified in Health Canada’s Safety Code 6 (SC6) guidelines. While ISED utilizes the SC6 UE limits for the protection of the general public, the development as well as any revision to the guidelines is the sole responsibility of Health Canada.

6. The procedures for ensuring compliance with SC6, outlined in Client Procedures Circular CPC-2-0-20, issue 1, Radio Frequency (RF) Fields – Signs and Access Control, were last updated in 2013. The procedures apply to all operators of antenna installations.

7. There is a continuing increase in demand for wireless services and the RF spectrum that those services utilize. To fulfill the demand and provide the services Canadians desire and rely upon, an increase in infrastructure, including antenna installations, must occur. While meeting the demand, operators are still required to ensure the general public does not have access to any area where the UE limits are exceeded. This can typically be accomplished through site design and the installation of access control mechanisms.

8. In accordance with the terms of their relevant authorizations under the Radiocommunication Act, operators must follow the requirements in CPC-2-0-20 when assessing site compliance and implementing access control measures.

9. The proposed revisions to CPC-2-0-20 do not change the overall requirements as stated in issue 1. The proposed revised document (see annex A) is used to provide further guidance and clarity on those requirements. Antenna installations, whether on a tower or a non-tower structure, are still required to comply with the UE limits of SC6 at all times in areas accessible to the general public. The application of the UE limits have not changed from issue 1. The signage requirements as well as the requirement to implement corrective measures in the case of non-compliance remains unchanged from issue 1.

10. ISED is taking this opportunity to update the title of the document to better reflect its purpose. In addition, the name of the department will be updated throughout the document to “Innovation, Science and Economic Development Canada.” Existing references within the document will be revised as required to ensure they are up-to-date.

11. ISED is seeking comments on the following sections, which detail the proposed changes to CPC-2-0-20, issue 1. Proposed changes will also include a document name change to “CPC-2-0-20, issue 2, Radio Frequency Exposure – Site Compliance and Access Control” in order to better represent the content of the document. The proposed issue 2 is provided in annex A.

12. Section A3, Definitions

1. Definitions of terminology have been added to provide better understanding of the terms used throughout issue 2.

13. Section A4, Application

1. Two new terms have been added to help clarify where the UE limits apply. The terms are “restricted access area” and “publicly accessible area.”
2. Definitions of the terms “general public” and “work-related activities” have been defined in section A3 to provide clarity.

14. Section A6, Compliance and enforcement measures

1. Text has been added to help clarify factors that could impact a site’s compliance and possible results of non-compliance.

15. Section A7, Access control requirements

1. Text has been added to clearly state that ISED does not accept vegetation as a form of access control.
2. Text has been added to further detail fencing parameters as it is the most common form of access control.
3. A phased approach has been introduced to allow stakeholders time to ensure their existing access controls meet the more detailed requirements. The access controls are categorized into two types:
   • Existing access controls: Provided existing access controls meet the requirements outlined in section A7.2, Existing access controls, operators will be provided a seven-year timeframe to transition to the requirements outlined in section A7.3, Construction of new access controls
   • New access controls: Access controls installed after the publication of issue 2 must comply with the requirements outlined in section A7.3 from the date of installation onward

16. Section A7.2, Existing access controls

1. Text has been added to outline the basic requirements that existing access controls must meet to ensure compliance. The information applies to access controls that are in place at the time of the official publication of issue 2.
2. Text has been added to explain that if the existing access controls do not meet the requirements outlined in section A7.2, modification or replacement will be required as specified in issue 2.

17. Section A7.3, Construction of new access controls

1. Text has been added to outline the specific requirements for new access controls, which are being constructed after the official publication of issue 2. These requirements will also apply to all existing sites after the seven-year transition period.
2. Text has been added for specific reference to, and detailed requirements for, chain-link fencing and wooden fencing as they are the two most common types of fencing used at radiocommunication sites.
3. Text has been added to detail that if, at the end of the seven-year period referenced above, the access controls do not meet the requirements outlined in section A7.3, modification or replacement will be required as specified in issue 2.

18. Section A7.4, Non-tower structures

1. Text about antenna installations on non-tower structures has been addressed separately because of their difference in physical characteristics, which may require differing access controls. These installations are most often found on building rooftops and exist in great numbers.

19. Section A7.5, Alternate access controls

1. Text has been added to mention that, because of Canada’s vast geography and topography as well as large variations in antenna installation parameters, it is impossible to cover all possible access control scenarios within the document and that circumstances may exist where alternate access control methods may be acceptable.
2. Text has been added to explain that alternate access controls may be considered under extenuating circumstances; the goal still being to provide adequate protection to the general public from overexposure to RF energy. In these circumstances, compliance will be assessed based on the unique characteristics of the given site.

20. Section A8, Signage

1. Text has been added to the explain the prohibitive use of, or reference to, imagery associated with the Government of Canada federal identity.
2. Additional examples of acceptable signage have been added, for reference purposes.  

21. Section A9, Corrective measures

1. Text has been added to include examples of temporary measures that have been implemented and accepted.
2. Specific timeframes have been outlined to clarify ISED’s expectations regarding the implementation of corrective measures.

22. ISED will review the comments received and publish its decision as well as the official version of the document.

23. Respondents are requested to provide their comments in electronic format (Microsoft Word or Adobe PDF) by email to spectrumoperations-operationsduspectre@ised-isde.gc.ca and to specify the section and subsection for ease of reference.

24. Printed submissions should be mailed to the following address:

Innovation, Science and Economic Development Canada
Spectrum Management Operations Branch
Senior Director
6th Floor, East Tower
235 Queen Street
Ottawa ON  K1A 0H5

25. All submissions should cite the Canada Gazette, Part I, the publication date, the title and the notice reference number (DGSO-003-23). Respondents should submit their comments no later than January 4, 2024 to ensure consideration.

26. Soon after the close of the comment period, all comments received will be posted on ISED’s Spectrum Management and Telecommunications website.

27. As all comments and related information will be posted on ISED’s website, those making submissions are responsible for ensuring that they do not contain confidential or private information.

28. All ISED publications related to spectrum management and telecommunications are available on the Spectrum Management and Telecommunications website.

A1. Introduction

As a condition of authorization, under Innovation, Science and Economic Development Canada’s (ISED) tower siting policy, entitled CPC-2-0-03, Radiocommunication and Broadcasting Antenna Systems compliance with Health Canada’s Safety Code 6 (SC6) is an ongoing obligation. When assessing compliance, the combined effects of nearby antenna installations within the local radio environment must be considered.

The purpose of this Client Procedures Circular (CPC) is to outline various compliance measures that may be required to ensure a site is compliant with SC6.

Health Canada has established guidelines for exposure to radio frequency (RF) fields in its SC6 publication, entitled Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range from 3 kHz to 300 GHz. While the responsibility for developing SC6 rests with Health Canada, ISED has adopted these guidelines for the purpose of protecting the general public.

At any time, operators may be required, as directed by ISED, to demonstrate compliance with the uncontrolled environment limits (UE limits), which are specified in SC6 and, where necessary, implement corrective measures.

In order to demonstrate compliance, detailed calculations, computer simulations, and/or site surveys (measurements) may be required. In addition, all operators are required to facilitate ISED’s access to sites to conduct compliance audits. Compliance with SC6, including the implementation of access control measures and signage, must be undertaken with the highest regard for ensuring the safety of the general public.

A2. Mandate

The Minister of Innovation, Science and Industry (the Minister), through section 5 of the Radiocommunication Act, takes into account all relevant matters to ensure the orderly establishment or modification of radio stations and the orderly development and efficient operation of radiocommunication in Canada, issue radio authorizations and approve each site on which radio apparatus, including antenna systems, may be located. Furthermore, the Minister may approve the erection of all masts, towers and other antenna-supporting structures.

A3. Definitions

The following definitions are used throughout this document and shall take precedent over any competing definitions found outside this document.

Access controls: A method or combination of methods for preventing access by the general public to a given area.

At, or in proximity to, the site: Within the perimeter of a site (e.g. building or tower site property) or nearby the site, such as in adjacent buildings or public gathering areas close to the antenna installation. A set distance is not specified as it could vary on a case-by-case basis.

Controlled environment (CE) limits: The controlled environment limits as specified in Health Canada’s Safety Code 6 guidelines.

General public: Persons not having any work-related purpose for being within a given area. For the purpose of this document, "general public" does not include any individual who, as a result of work-related activities, is present within a restricted access area (RAA) at, or in proximity to, the site, nor does it include owners (including their representatives) of properties where the RAA is located.

Measurement equipment expanded uncertainty budget: The manufacturer’s published expanded uncertainty budget for the measurement equipment used to conduct Safety Code 6 (SC6) compliance assessment.

Non-compliant site: Any antenna installation where the radio frequency emissions at, or in proximity to, the site have been determined to exceed the uncontrolled environment limits of Safety Code 6 in any area accessible to the general public.

Permanent corrective measures: Access controls or technical parameter changes that have been implemented with the intent of being in place on a long-term basis to ensure ongoing site compliance.

Proponent and/or operator: Anyone planning to install or modify an antenna installation, or operating an existing antenna installation who holds or will hold a radio authorization issued by ISED, such as telecommunications carriers or broadcasting undertaking certificate holders. Note that proponents and operators must meet the requirements of CPC-2-0-03, Radiocommunication and Broadcasting Antenna Systems. For the purpose of this document a proponent or operator will be referred to as an “operator”.

Publicly accessible area (PAA): Any area that is accessible to the general public without defeating an access control mechanism(s). The uncontrolled environment limits of Health Canada’s Safety Code 6 must not be exceeded within this area.

Restricted access area (RAA): An area that has an acceptable form of access control in place in order to prevent access by the general public.

Site: A location where an antenna is installed for the purpose of radiating radio frequency energy.

Temporary corrective measures: Access controls or technical parameter changes that have been implemented on a short-term basis to ensure site compliance until such time as permanent measures can be implemented.

Uncontrolled environment (UE) limits: The uncontrolled environment limits as specified in Health Canada’s Safety Code 6 guidelines.

Work-related activities: All types of work, not just work that is specifically related to antenna installations and associated equipment. Examples of work activities not related to antenna installations include maintenance or repair of structures such buildings, lamp posts, utility poles, etc.

A4. Application

This document sets out requirements and corrective measures to help ensure compliance with the UE limits of SC6 for all types of antenna installations. It is very important to note that, while utilizing the UE limits contained within SC6, ISED does not utilize the definitions of controlled and uncontrolled environments as set out in SC6. For the purpose of this document, and in determining site compliance, ISED will utilize the terms restricted access area (RAA) and publicly accessible area (PAA). As this document deals with the protection of the general public, the exposure levels within a PAA must not exceed the UE limits of SC6.

The requirements stated in this document relate specifically to the protection of the general public, and therefore, do not apply to RF exposure related to areas designated as “occupancy only under controlled conditions” as set out in Health Canada’s Technical Guide for Safety Code 6: Health Canada’s Radiofrequency Exposure Guidelines.

A5. Responsibility

As a condition of authorization, it is the responsibility of all operators to ensure the sites on which their antenna installations reside comply with the UE limits at all times in areas accessible to the general public. Site compliance is based on the maximum possible RF energy levels for the entire site, including the combined effects of nearby installations within the local radio environment, not only the operator’s own installation. In addition to the RF energy levels, the site must also comply with the UE limits for contact currents and induced currents. As the limits are frequency dependent, operators must refer to SC6 to determine the appropriate limits when assessing compliance. When designing, constructing, and maintaining a site, operators should also consider any other hazards at a site, such as direct contact with a radiating element (e.g. AM antenna installations).

Each operator at a given site is jointly responsible for ensuring the site complies with SC6 requirements. As part of this shared responsibility, each operator is expected to openly share their system installation parameters and work cooperatively with other operators to ensure accurate and consistent analysis. The implementation of appropriate mitigation measures should be coordinated amongst the non-compliant site stakeholders as appropriate.

It is important that operators be diligent in monitoring their sites and antenna installations as the local physical or radio environment may change, necessitating the addition and/or modification of access control measures. Should changes to the access controls be necessary to ensure compliance, the operator must implement appropriate measures without delay.

ISED requires that, at each site, stakeholder contact information be available to personnel authorized to be within the RAA. Each operator at the site is responsible for ensuring the site owner/manager has their up-to-date contact information (see annex A.A) in order facilitate the timely resolution to any issues found. Where applicable, contact information for any landlord, property manager, and/or third-party tower owners should also be included with the information referenced above. For some types of antenna installations (e.g. those mounted on lamp posts, sign posts, or walls), a typical RAA area (e.g. a locked rooftop) may not exist, therefore the requirement to provide contact information in the same manner may not be practical. In such cases, operators are responsible for ensuring the owner/manager of the particular infrastructure has their up-to-date contact information.

Sharing of information between operators at a site will facilitate efficient and effective responses to issues that may arise relating to a site’s operation, including access control and compliance issues. Operators should make their best effort in providing an accurate and timely response to requests for information from other operators in order to help ensure compliance.

In some circumstances, property owners could be present inside an RAA at the site for prolonged periods and may not be aware of the potential for over-exposure to RF energy. Operators should take responsibility for making appropriate arrangements with the owner(s) of the property on which their antenna installation is located (e.g. farm field or building) so that the property owner(s) is made aware of the risks of over-exposure within an RAA and can effectively avoid such risks.

A6. Compliance and enforcement measures

ISED requires that, for all antenna installations, the general public must not have access to any area at or in proximity to the site where the UE limits are exceeded. The foregoing applies to RF energy levels as well as contact current and induced current levels. Access controls and corrective measures must meet the requirements set out in this document unless specific alternate measures are approved or required by ISED.

Operators must be diligent in ensuring their antenna installations remain compliant. It is strongly recommended that operators of antenna installations have a site inspection regime in place to ensure all of their antenna installations remain compliant.

Factors that could negatively impact site compliance include:

• a change of the local radio environment (e.g. additional emissions, increased output power)
• a change in the local physical environment (e.g. development of land near the antenna installation)
• access controls not being adequately maintained

Should RF energy levels exceed the UE limits in any area accessible to the general public at or in proximity to the site, it will be considered non-compliant. In such cases, the operators are required to implement corrective measures to bring the site into compliance without delay. In the event of non-compliance, operators are considered to be in breach of the conditions of their radio authorization and ISED may undertake enforcement actions under the Radiocommunication Act against those contributing to the non-compliance.

Repeated failure by an operator to maintain compliance of their antenna installations may lead to additional enforcement measures. Information about enforcement measures may be found on ISED’s Compliance and enforcement website.

A7. Access control requirements

The goal of any type of access control is to protect the general public by restricting access, at all times, to any area at, or in proximity to, the site where the UE limits are exceeded. This section sets out access control requirements for new and existing sites. Regardless of the type of site, it is likely some form of access control will be required. The nature of the site and the associated site compliance assessment will assist in determining the appropriate means of access control.

The location of access controls (e.g. fencing) may be determined based on detailed calculations, computer simulations, site surveys (measurements) or a combination thereof. However, regardless of the method used, ISED may require additional information, including additional measurements, to be provided in order to demonstrate compliance with the UE limits. ISED may also require specific mitigation measures not covered by this document to be implemented.

Antenna installations on guyed structures present additional factors that must be taken into consideration when assessing site compliance. Guy-wires and associated anchor points have the potential to re-radiate high levels of RF energy, which may exceed the UE limits. In addition, induced currents and contact currents may also be present at levels which exceed the UE limits. As neither numerical analysis methods, nor current computer simulations, are able to accurately assess the re-radiated RF energy, contact current, or induced current levels at these locations, it can necessitate the operator to conduct measurements in order to ensure compliance. Operators are responsible for ensuring the entire site, including all guy-wires and associated anchor points, complies with the UE limits at all times.

Should an operator be required to implement access controls at a site where none exist, those access controls must, at a minimum, meet the requirements outlined in section A7.3 below.

At any site where access controls already exist, those measures must meet, at a minimum, the requirements as outlined in section A7.2 below. Where those measures do not meet the minimum requirements as per section A7.2, they must be modified in order to meet those requirements. However, within seven years from the date of publication of this document, all access controls must meet, at a minimum, the requirements of section A7.3. Therefore, where significant modification to already installed access controls is undertaken, it is strongly recommended that all site access controls be designed and constructed to meet, or exceed, the requirements outlined in section A7.3. Where reconstruction of access controls occurs, the new controls must meet, or exceed, the requirements outlined in section A7.3.

Where a site has been assessed by ISED under CPC-2-0-20, issue 1 (March 2013) and, where no non-compliance issues were found, that site will continue to be considered compliant provided the access controls are appropriately maintained and meet, as a minimum, the Existing Access Controls requirements outlined in section A7.2. Should a case occur where a site’s existing access controls do not meet those set out in section A7.2, the operator must implement corrective measures without delay in order to bring the site into compliance. Refer to section A9 for additional information and requirements.

Operators must be diligent in monitoring the condition of the site and the surrounding environment to ensure the site remains compliant. In case of doubt as to whether any existing access controls, planned modification, or construction of new access controls meet the applicable requirements, it is recommended that the operator contact the local ISED office in order to obtain further site-specific guidance.

A7.1 Physical barriers

Typically, the most straightforward way to restrict general public access to areas where the UE limits could be exceeded is by using a physical barrier. Examples of this include, fencing with locked gates enclosing the site, locked doors on rooftops, or an anti-climbing device on a tower. Any location outside of an RAA will be considered accessible to the general public.

Access controls are not limited to fencing, other barriers and/or types of access controls may be utilized in place of, or in conjunction with, fencing. However, regardless of the type of barrier, it must restrict access by the general public to any area where the UE limits are exceeded. For example, walls constructed of solid material (e.g. concrete, metal or plywood) may be feasible or preferred in some scenarios. It is important to note that ISED does not accept vegetation (e.g. dense brush/forest) as a means of access control.

When designing, constructing and maintaining physical barriers as a means of access control, many factors must be taken into account to ensure effectiveness. Operators must recognize that sites, particularly towers, are enticing to investigate and climb, especially for children. Regardless of whether an antenna installation is located on private land, access controls must be designed and constructed to inhibit unauthorized access by the general public (including those who may be considered to be trespassing), at all times, to any area where the UE limits are exceeded.

Operators should carefully consider safety aspects relating to the use of barbed wire as part of access control measures, for example, it may not be suitable to install barbed wire lower than 1.8 m above ground level. It may be beneficial to refer to federal and provincial standards and codes for guidance on the installation of barbed wire in a given environment.

A7.2 Existing access controls

This section applies to all sites which have access controls in place as of the date of publication of this document. Those access controls must meet the following requirements:

• Access by the general public to areas where the UE limits are exceeded must be restricted at all times.
• All openings and clearances (e.g. separation between a fence and a gate, or the distance between a fence and the ground) in the access controls must be small enough to preclude access by the general public, including children, to any area where the UE limits are exceeded.
• The height of the fence/barrier must inhibit an individual from passing over it.
• Access controls must be structurally sound.
• Impede access by the general public regardless of season, surrounding vegetation, snow accumulation, or climbable objects in proximity (e.g. generator cabinets).
• Gates, moveable barriers, and other access points must, at a minimum, meet all of the same requirements as other parts of the access controls. For example, a gate must be of at least the same height as, and have a ground clearance no greater than, the surrounding fence/barrier.
• Access points (e.g. gates, doors, other moveable barriers) comprising part of the access control measures must be locked at all times unless operator personnel are present at the site and are able to prevent general public access to the RAA. Any other personnel accessing the RAA must, working in conjunction with operator personnel (who may or may not be present on site), ensure the access points are locked or that general public access is restricted in an alternate manner at all times.
• Where, due to the nature of the antenna installation (e.g. on a tower), the site is compliant with the UE limits in all areas typically accessible to the general public (e.g. the ground at, or in proximity to, the base of the tower), site fencing may not be required. However, in these scenarios, the antenna supporting structures must be equipped with anti-climbing devices to prevent access to parts of the structure where the UE limits are exceeded.

Recommendations and considerations:

• Conductivity of access controls must be given due consideration, most notably at AM broadcasting sites. Factors such as corrosion or the deterioration of grounding systems must be taken into account, especially as they relate to induced current and contact current.
• Site inspection and maintenance regimes should be conducted regularly in order to ensure access controls continue to remain effective.

A7.2.1 Modifications to existing access controls

In a case of non-compliance, operators are required to implement corrective measures without delay. The corrective measures can include temporary measures as referenced in section A9.1, modifying the current access controls in order to meet the existing access controls requirements outlined in section A7.2, or replacing the current access controls. When replacing access controls, they are required to meet the construction of new access controls requirements outlined in section A7.3.

The following is an example of where existing access control measures may not be sufficient to impede the general public from accessing areas where the UE limits are exceeded, but modifications may be possible to ensure compliance:

The decision as to the practicality of any modification compared to the replacement of access controls is left solely to the operator so long as it results in access controls which meet the existing access controls requirements or the construction of new access controls as applicable. When making the decision, it is important to note that within seven years from the date of publication of this document, all access controls must meet, at a minimum, the requirements of section A7.3. The purpose of altering the design and construction of existing access controls (e.g. fence or barrier) is to ensure it inhibits unauthorized access by the general public to any area where the UE limits are exceeded.

It must be noted that making alterations to the design and construction of an access control does not necessarily ensure compliance, therefore it is advisable to discuss the planned modifications with ISED officials prior to proceeding.

A7.3 Construction of new access controls

This section applies to all sites that do not have any existing access controls in place as of the date of publication of this document. All access controls installed at these sites must, in addition to meeting the existing access controls requirements outlined in section A7.2, meet the following requirements (refer to all Notes in section A7).

General requirements:

• If constructed of a conductive material the operator must ensure they are properly grounded and that contact currents and induced currents have been fully assessed to ensure compliance with the UE limits.
• Proper monitoring and maintenance of all conductive materials must occur to ensure corrosion does not result in a loss of grounding, which could result in a build-up of contact currents or induced currents.
• Access controls must be designed and constructed to inhibit any unauthorized entry over, under, or through it regardless of season, surrounding vegetation, snow accumulation, or climbable objects in proximity.
• Access controls must be at least 180 cm in height above grade as measured on the PAA side of the enclosed area.
• Any horizontal components, such as fence support rails, must be placed on the RAA side of the enclosed area and in such a way that they cannot easily be used to assist an individual in scaling the barrier.
• Objects in proximity to an access control, for example generator cabinets, fuel tanks, trees, snow accumulation, which may be used to assist in ascending the access controls more easily must be taken into account. Where such objects are present, the design and construction of the access controls must be altered to the degree necessary (e.g. increasing the height of the fence/barrier) to ensure it still inhibits unauthorized access to the RAA.
• Maximum separation between the ground and bottom of the access controls (in all locations) must not exceed 55 mm. The design and construction must be such that access, including by children, cannot be gained by going under the access controls without physically removing a significant amount of material from the ground.
  • Note: As this requirement applies specifically to the construction of new access controls it is expected to be achievable as part of the construction process. However, where an operator believes that extenuating circumstances apply to a particular site they should address the matter with ISED, including providing a detailed plan clearly demonstrating how compliance will be ensured. Refer to section A7.5 for related information and requirements.
• Access controls must be adequately sound such that an individual cannot push, pull or otherwise move the access controls in any direction to reduce its effectiveness in preventing access to the RAA.
• Gates, moveable barriers, and other access points must, at a minimum, meet all of the same requirements as other parts of the access controls. For example, a gate must be at least the same height as, and have a ground clearance no greater than, the surrounding fence/barrier.
• The maximum spacing between gates and supporting posts must not allow a spherical object of greater than 105 mm to pass through or between, and should be constructed in such a manner so as to impede climbing.
• Access points (e.g. gates, doors, other moveable barriers) comprising part of the access control measures must be locked at all times unless operator personnel are present at the site and are able to prevent general public access to the RAA. Any other personnel accessing the RAA must, working in conjunction with operator personnel (who may or may not be present on site), ensure the access points are locked or that general public access is restricted in an alternate manner at all times.
• Where, due to the nature of the antenna installation (e.g. on a tower), the site is compliant with the UE limits in all areas accessible to the general public (e.g. the ground at, or in proximity to, the base of the tower), site fencing may not be required. However, in these scenarios, the antenna supporting structures must be equipped with anti-climbing devices to prevent access to parts of the structure where the UE limits are exceeded.

General recommendations and considerations:

• Preferably, access controls should be constructed of non-conductive material; this is especially important at AM broadcasting sites.
• It is recommended that gates and doors be self-closing and self-latching, where possible.
• The structural integrity or effectiveness of a fence/barrier can be reduced due to the effects of frost/freezing and should be factored in to the design and construction. As a result of those effects, significant degradation in the effectiveness of the access control measures could result in a site becoming non-compliant over time.

The following information provides specific requirements for chain-link fencing and wooden fencing as they are the most common types of barriers that are typically installed for long-term use, however, it is important to note that these are not the only types of access controls that may be considered sufficient. Other types of barriers or access controls may be acceptable, provided they meet the general requirements listed above and accomplish the goal of inhibiting access by the general public to RAAs.

Chain-link fence requirements:

• Link openings must not allow a spherical object of greater than 55 mm to pass through.
• Structural portions of the fence, including posts, fence mesh, horizontal rails, tensioning wires and tie wires must be constructed of steel or material of equal or greater structural performance.
• Support posts must be spaced at intervals not exceeding 3 metres.
• Wire gauge of the mesh, tie wires and tensioning wires must be such that it maintains adequate structural integrity of the fence.

Chain-link fence recommendations and considerations:

• Corrosion can lead to loss of structural integrity as well as a decrease in grounding characteristics, which could result in the presence of induced current and/or contact current levels that exceed the UE limits. It is therefore recommended that corrosion resistant materials, such as galvanized or vinyl coated metals, be used for all structural portions of the fence, including posts, fence mesh, horizontal rails, tensioning wires and tie wires.
• Diamond mesh fencing material should be used.
• Fencing mesh should be located on the outside (PAA side) of the support posts.

Wood fence (vertical boards)/Wood barrier requirements:

• Maximum spacing between vertical materials, (e.g. fence boards) must not allow a spherical object of greater than 105 mm to pass through or between, and should be constructed in such a manner so as to impede climbing.
• Support posts must not be less than 88 mm by 88 mm (nominal 4”x4”) and must not be spaced at intervals of more than 2.4 metres.
• Horizontal rails must not be less than 38 mm by 88 mm (nominal 2”x4”) and must be spaced such that the top and bottom rails are at least 1.2 metres apart.
• Vertical boarding must not be less than 19 mm by 88 mm (nominal 1”x4”).

Wood fence (vertical boards)/Wood barrier recommendations and considerations:

• Choice of species and treatment of wood (both for posts and fencing/barrier material) should be such that it does well in wet environments;
• Rot can considerably weaken the structure and possibly lead to failure thereby resulting in the site becoming non-compliant.

A7.4 Non-tower structures

Antenna installations on non-tower structures (e.g. rooftops) may differ considerably from those on purpose built antenna supporting structures. Nevertheless, the requirement to restrict, at all times, unauthorized access by the general public to areas at, or in proximity to, the site where the UE limits are exceeded, also applies to these installations. In particular, the requirements listed in section A7.2 and A7.3 apply to non-tower structures as appropriate, however, the following requirements are more specific to rooftops.

Rooftop requirements:

• Access points (e.g. doors, hatches, ladder access barriers) comprising part of the access control measures must be locked at all times unless operator personnel are present at the site and are able to prevent general public access to the RAA. Any other personnel accessing the RAA must, working in conjunction with operator personnel (who may or may not be present on site), ensure the access points are locked or that general public access is restricted in an alternate manner at all times.
• For locations such as rooftop patios, where the general public is intended to have access, ensuring compliance with the UE limits may require more complex access controls or mitigation measures. Access controls such as fencing around the patio area may be a possible solution; refer to the applicable sections above for specific fencing requirements.
• When assessing a site’s compliance, operators must also consider areas accessible to the general public, which are not located on the site rooftop. This would include areas such as balconies of apartments, or gathering areas in proximity to the antenna installation. In such cases, specific mitigation measures (e.g. change in antenna installation technical parameters or placement) or access controls measures may be required to preclude access to areas where the UE limits are exceeded in order to ensure compliance.

A7.5 Alternate access controls

There may be specific site circumstances where access controls other than, or in addition to, fences/barriers may be necessary or more appropriate. ISED also recognizes there may be rare situations, due to extenuating circumstances (e.g. very large levels of snow accumulation or extreme topography such as sheer cliffs on mountaintop sites), where typical access controls may not be feasible or practical. In cases where an operator believes that such circumstances apply to their antenna installation, they must provide ISED with an explanation of their circumstances and justification for alternate access control measures to be considered.

The operator must submit a plan to ISED that clearly demonstrates how the proposed measures will provide appropriate protection to the general public. The plan must include a site layout drawing or map that details access control measures and their locations, area demarcation (signage), any proposed changes to station operating parameters, and any other relevant information.

As a part of their submission, the operator must include an attestation (see annex A.B) stating the site will continue to be compliant with the uncontrolled environment limits of Safety Code 6 in all areas accessible to the general public when the implementation of the access controls is complete.

Where temporary corrective measures have been implemented please refer to section A9 of this document for associated requirements and timeframes.

Once compliance has been demonstrated relative to an alternate access controls plan, the site’s compliance will be assessed against that plan going forward.

Failure to provide the appropriate plan and demonstrate compliance will be considered a breach of the operator’s condition of authorization. In the event of non-compliance, ISED may undertake enforcement actions under the Radiocommunication Act against those contributing to the non-compliance.

A8. Signage

It is important to note that signage alone does not constitute access control.

Demarcation signage (e.g. “caution” or “warning”) is required in conjunction with access controls in areas where the UE limits are exceeded. Operators should refer to Health Canada’s SC6 Technical Guide for information relating to the level of advisory relative to exposure levels. At AM broadcasting sites or other areas where serious injury or death may result, ISED strongly recommends that signage sufficiently reflects the dangers posed.

Sign imagery and design should follow accepted industry standards and common practices. Workplace laws, regulations and guidelines may also require additional signage to be displayed. Existing signage may remain in place provided it meets the minimum requirements for posting demarcation signs, which are as follows:

• signs must be at least 20 cm by 30 cm in size
• signs must be written in both official languages
• a sufficient number of signs must be installed around the affected areas
• the height, size and location of the signs must allow them to be visible and noticeable from any normal angle of approach to the affected areas, irrespective of seasonal snow cover or vegetation obstructions
• metallic signs and posts are not recommended near AM broadcasting sites

Figure A1 illustrates examples of acceptable signage that may be used for antenna installations. These images are only provided for reference; there may be other industry signage (colours, shapes and images) that may be acceptable as well.

Yellow backgrounds are often used to indicate an alert level of CAUTION and orange backgrounds are often used to indicate an alert level of WARNING but this can vary depending on the standard being referenced.

Figure A1: Signage examples

Signage must not make any form of representation as to being posted by, or approved by, the Government of Canada or any of its departments. It shall not display any images nor symbols related to the Government of Canada federal identity, including the Canada wordmark, the flag symbol, or arms of Canada, as shown in figure A2.

Figure A2: Government of Canada federal identity that may NOT appear on the signage

A9. Corrective measures

Where the RF energy levels at, or in proximity to, a site are found to exceed the UE limits in any area that is accessible to the general public, ISED requires that corrective measures be implemented without delay. Operators shall not leave a site unattended until the site is brought into compliance unless extenuating circumstances arise. These circumstances and the proposed corrective measures must be discussed with ISED where at all possible prior to the site being left unattended. Temporary corrective measures must remain in place until such time as permanent measures can be fully implemented.

A9.1 Temporary measures

Temporary measures can include:

• changing operating parameters
• implementing temporary access controls such as the installation of temporary fencing
• placement of security personnel to prevent unauthorized access to areas where the UE limits are exceeded
• any combination of the above
• switching transmissions to an authorized alternate site until the given site is brought into compliance, however, the alternate site must comply with SC6 at all times.

In situations where security personnel are posted at a site as a means of access control they must be made aware of the potential exposure to the RF energy present at the site. They must also be given specific instruction and guidance on areas where the general public must not enter (i.e. areas where the UE limits are exceeded).

Within one week of the implementation of the temporary measures, a description of what actions have been taken to bring the site into compliance, as well as an overview of permanent measures that will be implemented, must be provided by the operator to ISED in writing. Also within the same one week period, the operator will obtain consent from ISED as to the timeframe within which the operator will be providing ISED with a plan detailing the permanent compliance measures (access controls, technical parameter changes, etc.) to be taken.

The operator’s plan must clearly demonstrate the permanent measures that will be implemented in order to ensure compliance as well as committing to a timeframe by which the measures will be completed. The plan must include:

• a site layout drawing or map that details access control measures and their locations
• area demarcation (signage)
• any proposed changes to station operating parameters
• any other relevant information

A period of 90 days would typically be considered sufficient time to implement permanent corrective measures, however, ISED recognizes that there may be circumstances, such as seasonal conditions or remoteness of a site, which may justify longer implementation timeframes. Any delay longer than 90 days must be discussed with ISED and an agreed upon timeframe established.

A9.2 Notification of non-compliance

Should an operator determine one of their existing antenna installations is non-compliant, they must inform ISED without delay, including details of what mitigation measures have been implemented to bring the site into compliance. ISED may require that further corrective measures related to access control and/or operating parameters be taken. In addition, ISED may also require the operator to provide detailed calculations, computer simulations, and/or conduct site surveys (measurements) in order to demonstrate compliance.

A10. References

The latest versions of the following publications should be used in conjunction with this document.

BPR-1, General Rules

CPC-2-0-03, Radiocommunication and Broadcasting Antenna Systems

GL-01, Guidelines for the Measurement of Radio Frequency Fields at Frequencies from 3 kHz to 300 GHz

GL-08, Guidelines for the Preparation of Radio Frequency (RF) Exposure Compliance Reports for Radiocommunication and Broadcasting Antenna Systems

Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range from 3 kHz to 300 GHz

RIC-66, Addresses and Telephone Numbers of District Offices

Technical Guide for Safety Code 6: Health Canada’s Radiofrequency Exposure Guidelines

TN-261, Safety Code 6 (SC6) Radio Frequency Exposure Compliance Evaluation Template (Uncontrolled Environment Exposure Limits)

Annex A.A: Contact information template

The following information must be easily accessible on-site to authorized site personnel (i.e. not intended for public distribution). The information must be provided for the site owner and/or site manager. Each operator on the site is responsible for ensuring the site owner/manager has their up-to-date contact information in order facilitate the timely resolution to any issues found.

Annex A.B: Attestation to be submitted by operators with all compliance assessment reports