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28 April 2014

Manager

Technical Regulation Development Section

The Australian Communications and Media Authority

PO Box 13112

Law Courts

Melbourne VIC 8010

Dear Sir/Madam

The Australian Mobile Telecommunications Association (AMTA) is responding to the invitation of the Australian Communications and Media Authority (ACMA) to make a submission on the Remaking the Human Exposure Standard and Electromagnetic Radiation Labelling Notice, which was issued for public comment on 20 March 2014.

AMTA, on behalf of its members, supports the proposed changes to the legislative instruments.

We wrote to the ACMA on 17 October 2013 on the specific issue of the testing procedure for the Human Exposure Standard for devices capable of transmitting simultaneously on multiple frequency bands while being held to the head.

The effect of the proposed changes to the Radiocommunications (Electromagnetic Radiation – Human Exposure) Standard 2003 will, in our view, bring SAR testing procedures for devices that are used in close proximity to the ear and operating in multi-band transmission mode into alignment with testing procedures for simultaneous multi-band transmission devices that are held in the hand or body worn.

AMTA draws your attention to Clause 9 (2A) on page seven of the Draft Radiocommunications (Electromagnetic Radiation – Human Exposure) Standard 2014. This clause omits reference to EN 62209-2, which is identical to IEC 62209-2 and referenced in this clause. This contrasts with the two identical standards for head SAR – IEC 62209-1 and EN 62209-1, which are both referenced in the same clause.

AMTA believes that both IEC 62209-2 and EN 62209-2 should be referenced in this clause because overseas test houses may only have EN 62209-2 listed in their scope of accreditation and their test results would not be acceptable in Australia unless that standard was specifically listed, regardless of the identical nature of the two standards.

Similarly, clause 9 (3) should also contain reference to EN 62209-2 for the same reasons outlined in the previous paragraph of this submission.

We appreciate the ACMA’s consultation paper and process for allowing submissions from interested parties.

AMTA would be happy to discuss any issues with you on the remaking of the Standard.

Yours sincerely

Chris Althaus

Chief Executive Officer