To ensure the protection of the public from exposure to EMR, the Australian government regulator, the Australian Communications Authority (ACA) has mandated regulations and standards to limit the maximum permissible levels of exposure to the public. For manufacturers, agents, and importers of MPTE, the regulatory arrangements include RF EMR human exposure limits, evaluation criteria, a mandatory test method, and labeling requirements. This article details the steps necessary for the approval of MPTE to the Australian specific absorption rate (SAR) requirements. The ACA EMR regulations and the ACA SAR measurement method are also discussed.

ACA Regulations

ACA's EMR regulation, "The Radiocommunications (Electromagnetic Radiation—Human Exposure) Standard 2001," sets the limits for human exposure to electromagnetic radiation from specified mobile and portable radiocommunications transmitters. The ACA EMR standard was made by ACA and took effect December 12, 2001. The companion document, "The Radiocommunications (Compliance Labeling—Electromagnetic Radiation) Notice 2001" prescribes requirements for manufacturers and importers of equipment covered by the ACA EMR standard for attaching labels to their products before placing them on the market. The ACA EMR standard mandates the basic restrictions for human exposure as prescribed by the reference standard AS/NZS 2772.1(int)1998. It also prescribes a standard test method for the measurement of SAR.

The regulations are given legislative effect under the Radiocommunications Act of 1992. This regulates the performance of radiocommunications transmitters to protect the health and safety of persons exposed to electromagnetic radiation from the transmitters. It mandates the SAR limits and evaluation criteria specified by the reference standard, AS/NZS 2772.1(int)1998. The reference standard specifies basic restrictions for human exposure to time-varying electromagnetic fields from MPTE.

The scope of the reference standard captures all RF transmitting devices operating in the range 3 kHz to 300 GHz including mobile and cordless phones and similar transmitting devices. It specifies SAR limits for MPTE and stipulates conditions for which testing must be conducted to verify compliance with the prescribed SAR limits.

AS/NZS 2772.1(int)1999 sets the basic restrictions for human exposure and references the measurement and calculation procedures of AS/NZS 2772.2. However, actual SAR measurement procedures are not specified.

When ACA introduced the EMR regulations in 1998, SAR measurement standards were not harmonized, so ACA prepared an interim SAR measurement standard. At that time, work on an international test method to measure SAR was under way in the IEC and IEEE standards bodies. The interim ACA SAR test method was based on that international work and represented current best practice for SAR measurement methodology.

The test method was updated in the last revision of the EMR regulation titled "Specific Absorption Rate Test Method Using Phantom Model Of Human Head(1):2001." This standard describes a test method to measure the SAR of RF energy within the human body for specified transmitters. The test method is part of the ACA EMR standard. It describes the measurement requirements for testing for compliance with basic SAR restrictions for MPTE that has an integral antenna where the normal position of use is close to the human body.

These restrictions apply to MPTE capable of operating in the frequency band of 800 to 2500 MHz. The method is also suitable for testing devices that, if used in conjunction with MPTE, modify the RF performance of the equipment. This includes so-called radiation reduction devices.

The New ARPANSA (ICNIRP) Standard

The International Committee for Non-Ionizing Radiation Protection (ICNIRP) sets guidelines for limiting exposure to EMR. These guidelines have been recently adopted by the Australian government health regulator, Australian Radiation Protection and Nuclear Safety Agency (ARPANSA), in the form of a standard for human exposure to EMR. The new ARPANSA standard, "Radiation Protection Standard for Maximum Exposure Levels to Radio Frequency Fields—3 kHz to 300 GHz," replaces the obsolete interim standard AS/NZS 2772.1(int)1998. Although the interim standard is literally obsolete, it still has legislative effect as the reference standard mandated by the ACA EMR regulations. ACA has signaled its intention to adopt the new ARPANSA standard; however, the details are yet to be determined.

MPTE that can be used very close to the human body must be assessed for SAR. If used further away from the body, the more-convenient power-flux density measurements can be used. For the general public, the basic restrictions set by the reference standard (AS/NZS 2772.1(int)1998) are:

Certain MPTE used under controlled circumstances by organizations such as the police, who have been trained to be aware of the exposure and to limit it, are assessed under the occupational limits and the aware-user provisions of the reference standard. Such MPTE are allowed exposure limits five times greater than the MPTE intended for use by the general public.

These basic restrictions described above are the same as those of the United States and Canada. The ICNIRP basic restrictions are the same as those of the current reference standard AS/NZS 2772.1(int)1998; it should be noted, however, that the derived limits (also known as reference levels) differ significantly. Both SAR and field-strength reference levels have been relaxed in the new ARPANSA standard.

As can be seen from the table of SAR limits, it is not yet possible to determine worldwide compliance by testing to one limit or one standard. Manufacturers and suppliers to the Australian market must ensure that MPTE meets the ACA SAR limits by testing to the ACA standards (see Tables I–III). See the sidebar "ACA SAR Measurement Method: System Specifications" below.

The ACA Labeling Notice

The "Radiocommunications (Compliance Labeling—Electromagnetic Radiation) Notice 2001" prescribes requirements for manufacturers and importers of equipment covered by the ACA EMR standard to attach labels to their products before placing them on the market. It requires that suppliers (manufacturers or importers) label devices to indicate that the device meets the requirements of the mandated standards. The labeling notice specifies two levels of compliance.

Compliance Level 1. Compliance level 1 applies to Category A devices:

Devices that fall under Category A include, but are not limited to, analog cordless phones, handheld CB radios used for recreational or domestic purposes, and electronic garage door openers.

No testing is required before labeling a Category A product. Compliance level 1 MPTE does not exceed 20 mW transmitted power; therefore, such equipment cannot exceed the limits of AS/NZS 2772.1(int)1998 and, hence, does not require testing. This equipment can be marketed after completing a Declaration of Conformity (DoC) and labeling the device with the C-Tick, A-Tick, or regulatory compliance mark (RCM) as appropriate. Before 2001, MPTE covered by the ACA class license requirements did not require C-Tick labeling. It is important to note that all devices now falling within the scope of the ACA EMR standard must now be labeled with a C-Tick, and a DoC must also be completed. No test report or compliance folder is necessary for Compliance level 1 devices; however, compliance is mandatory.

Compliance Level 2. Compliance level 2 devices are those that do not meet the criteria for compliance level 1. Compliance level 2 applies to Category B devices, and a Category B device is any device that is not a Category A device.

To comply with compliance level 2, a supplier must:

Devices that fall under Category B include, but are not limited to, mobile phones, digital cordless phones, wireless personal digital assistants, and wireless electronic-funds-transfer point-of-sale terminals.

Manufacturers and importers must sign a DoC and must also have their product evaluated against the ACA human exposure limits. Devices that have integral antennas and are designed to be used close to the human body are required to be evaluated against SAR limits. Other devices require evaluation against power-flux density or field-strength levels that have been derived from the SAR limits (see Figures 1 and 2). MPTE used within 2.5 cm of the body and having a transmit power of >20 mW must be evaluated against the SAR limits of the reference standard (see Figure 3).

Figure 1. Summary of compliance provisions for mobile and portable transmitting equipment—occupational exposure.

Figure 2. Summary of compliance provisions for mobile and portable transmitting equipment—nonoccupational exposure.

Figure 3. The maximum output power levels from Table 4 of AS/NZS 2772.1(int)1998.

A compliance folder must be established containing a DoC, a technical description that positively identifies the product, and a SAR measurement test report by an accredited test laboratory. The device must then be labeled with the appropriate C-Tick, A-Tick, or RCM.

Products requiring evaluation must be tested by a laboratory accredited to conduct the appropriate tests. This accreditation must have been conducted by Australia's National Association of Testing Authorities (NATA) or by an international body that has a mutual recognition agreement (MRA) with NATA. MRA partner accreditation bodies include the National Voluntary Laboratory Accreditation Program (NVLAP), the American Association for Laboratory Accreditation (A2LA), the United Kingdom Accreditation Service (UKAS), Germany's Deutscher Akkreditieurungsrat (DAR), and more than 30 other international bodies.

The physical labeling requirements for MPTE devices are the same as those for C-Tick labeling under the ACA EMC Framework. The manufacturer, importer, or the authorized representative may apply the C-Tick, A-Tick, or RCM label as appropriate, either in Australia or overseas. The label must be a minimum of 3 mm wide and digits and letters must be at least 1 mm in height. The label must be near the manufacturer's label and on an external surface, readily accessible to a user. Whenever it is not possible to apply the label to an external surface, it can be applied to the packaging and to the user manuals. The label must also contain at least one of the following items identifying the manufacturer:

The compliance folder must be maintained for five years after the date of last sale of the labeled device.

Variants can be included on the same DoC. The technical justification for compliance of the variant must be made in writing, must identify the variant, and must describe the difference in sufficient detail to show that it is a variant.

ACA may conduct a random audit or an audit as a result of a complaint. On written request from ACA, the compliance folder must be produced within 10 days. When the compliance of the product is called into question, ACA may request the registered supplier to provide three samples of the product within 10 days for testing by a NATA-accredited laboratory.

The compliance records, which may be kept electronically, must be kept for five years from the last date of sale of the product. Records must be in English. Records must include:

For Category B devices, compliance records must also include:

Radiocommunications devices may be labeled with either the C-Tick or RCM compliance marks. Telecommunications devices must be labeled with the A-Tick as prescribed by "Telecommunications Labeling (Customer Equipment and Customer Cabling) Notice 2001." If a device is covered by both the EMR labeling notice and the telecommunications labeling notice, it need only be labeled with an A-Tick.

The C-Tick, RCM, and A-Tick symbols are protected symbols and are only to be used in accordance with conditions specified by ACA. These marks may be used only after making a written application to ACA using the appropriate form set out in the notices. No fee is required to register with ACA for permission to use the marks. However, registration to use the marks is granted only to Australian-registered businesses or residents.

The latest changes to the ACA EMR regulations for human exposure to radio frequencies are intended to provide protection to the public and to workers from the effects of RF transmitted by mobile and portable transmitting equipment.

ACA has signaled its intention to adopt internationally harmonized SAR measurement standards as they become available. Until the legislative instruments are in place, MPTE that is intended to operate in close proximity to the human body must be evaluated against the exposure limits of AS/NZS 2772.1(int)1998 in accordance with the ACA SAR measurement method.