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August 15, 2017 
The Honorable Ajit Pai 
Chairman 
Federal Communications Commission 
445 12th Street, SW 
Washington, DC 20554 
Dear Chairman Pai: 
We write regarding a matter of critical importance to the health and safety of the estimated 
250,000 workers a year that work in close proximity to cellular antennas: exposure to 
radiofrequency (RF) radiation in excess of the Federal Communications Commission' s (FCC) 
human exposure limits. 
On September 17, 2015, we wrote to the FCC urging it to work with the Occupational Safety and 
Health Administration (OSHA) to ensure wireless carriers are employing the necessary measures 
to comply with the FCC's RF human exposure regulations and protect the hundreds of thousands 
of individuals working in close proximity to cellular antennas. The letter further urged the FCC 
to move quickly to finalize the Further Notice of Proposed Rulemaking (Further NPRM) adopted 
on March 27, 2013, proposing new requirements for licensees to demonstrate compliance with 
the FCC's exposure limits. To date, the FCC has failed to make progress on either request. 
As you know, FCC regulations explicitly require licensees to protectall individuals from the 
hazards associated with excessive exposure to RF radiation, yet we remain concerned that 
licensees are not adhering to these requirements, particularly with respect to third party workers 
who perform their jobs near cellular broadcast antennas. In fact, in their communications with 
the FCC, the carriers have said they cannot "control" access to rooftop sites and have asked the 
Commission for a safe harbor from their responsibility to protect third-party workers. Even more 
concerning, recent moves by major insurers, including Lloyds of London, to exempt RF radiation 
from coverage in their policies demonstrate they believe overexposure is a significant threat. 
As consumer demand for wireless services increases, wireless carriers are increasingly relying on 
leasing rooftop space and building access from property managers to house cellular antennas, 
including apartment buildings, schools, hospitals, places of worship, fire stations, and other 
public and private buildings. Unlike cellular towers, which are generally free-standing structures 
with restricted external access, rooftop-mounted antennas pose a unique occupational hazard to 
the numerous kinds of personnel whose job requirements compel them to work on rooftops. 
At risk from rooftop and building mounted antennas are not only the wireless industry's trained 
RF technicians but also roofers, water proofers, electricians, carpenters, building maintenance 
personnel, HV AC technicians, painters, firefighters, and more. While wireless carriers take 
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important precautions to outfit their own employees with protective equipment and RF exposure 
monitoring units, and may even power down an antenna to eliminate the RF radiation hazard, 
their subcontractors and unaffiliated third party workers are not regularly afforded these same 
protections. 
We call on you to finalize the NPRM and update us on the actions the FCC is taking to ensure 
individuals and workers in close proximity to cellular towers and antennas are protected from 
excessive RF radiation. We strongly urge you to work with your colleagues at OSHA to bring 
together the carriers and compel them to adopt a solution to address this serious issue that is in 
the interest of building owners, employers and unions, workers and others who are at risk of RF 
exposure from transmitting antennas. 
We look forward to hearing what steps the Commission plans to take to ensure the safety of all 
workers from the danger ofRF radiation exposure. We respectfully request a response no later 
than August 29, 2017. 
Sincerely, 
~;~ ~~~ 
United States Senate 
cc: The Honorable Mignon Clyburn, Commissioner, Federal Communications Commission 
The Honorable Michael O'Rielly, Commissioner, Federal Communications Commission 
The Honorable Thomas Galassi, Acting Deputy Assistant Secretary of Labor for 
Occupational Safety and Health