Georgia Tech Justification for Experimental License Request

0090-EX-PL-2007 Text Documents

Georgia Institute of Technology

2007-02-26ELS_79846

Atlanta, February 26, 2007 Jochen Teizer, Ph.D. Assistant Professor School of Civil and Environmental Engineering Georgia Institute of Technology 790 Atlantic Dr. N.W. Atlanta, Georgia, 30332-0355 Sustainable Education Building (SEB), Room 327 Phone: 404-894-8269 Fax: 404-894-2278 E-Mail: teizer@gatech.edu http://www.rapids.gatech.edu Mr. James R. Burtle Experimental Licensing Branch Chief Federal Communication Commission 445 12th Street SW Washington, DC 20554 Copy to: Douglas Young, Phone 202-418-2440, douglas.young@fcc.gov RE: Application 0090-EX-PL-2007 Dear Mr. Burtle, I need your assistance in making a major advance in construction safety. Please expedite approval for indoor and outdoor use of Multispectral Solutions’ (MSSI) one-watt Ultra- wideband tags. The School of Civil and Environmental Engineering at the Georgia Institute of Technology is striving to improve safety in construction operations to enhance compliance with federal safety regulations (Occupational Safety and Health Administration, e.g. OSHA rule 1926.550(a)). One key issue is how to locate people during construction operations and in particular locating people surrounding the travel path or swing radius of heavy equipment. Currently, most construction sites manually install various improvised safety tools (see example in Figure 1 below), however, if installed at all, they do not guarantee any safety. Construction companies and equipment vendors have long been asked by regulators to use innovative technologies or best practices to find a better solution. Using Ultra-wideband tags allows the accurate tacking of the location of heavy equipment and the relative position of workers surrounding it. This might help reduce the many accidents and fatalities in construction. 1

Manually installed passive safety tapes do not work. Figure 1. Currently installed best practices in safety using passive tape devices Safety Statistics Operation of heavy equipment in hazardous work environments like on onstruction or at night times is one of the primary issues of construction related to the transportation industry. According to OSHA (Occupational Safety and Health Administration), the construction industry continues to report the largest number of fatal work injuries of any industry. A significant number of equipment-human or equipment-objects accidents resulted from missing safety features installed on currently operated heavy equipment. In 2002, the Bureau of Labor Statistics publicized a statistic that the category “contact with objects or equipment” accounts for 18% of 1,125 fatal injuries in U.S. construction. But the portion of injuries actually involving construction vehicles and equipment is probably greater. Falls were responsible for 33% of fatalities in the construction industry, 24% in transportation incidents, exposure to harmful substances or environments killed 18% workers (of which 74% were related to contact to electrical current and overhead power lines), 18% had contact with objects and equipment (about half each were “struck by” or “caught in”), fires accidents and assaults each were attributable to about 3%. Three categories combined (“struck-by”, “caught-in”, electronic shock incidents) accounted for over 58% of total fatalities and were largely due to accidents stemming from false operations of heavy equipment (Statistics from Bureau of Labor Statistics and OSHA, 2006). Our past research efforts in safety indicate that actively sensing the environment (e.g. use of Ultra-wideband) can prevent or reduce accidents and fatalities by a significant number. 2

Research Plan We have found that ultra-wideband RFID holds the answer. Combined with other technologies it will drastically reduce the chance of human error and provide real-time locations of all personnel including machinery. The only procedure required of the staff will be “wear your badges at all times” (see Figure 2). Safety inspectors will have full accounting of the workers who are within the safety perimeter of heavy equipment, and of those who are, an automated signal, visually through a blinking light, or an acoustic alarm can go off. Figure 2. Tracking the location of workers on a construction Site to prevent accidents Our research staff in the Real-time Acquisition and Processing for Information Decision Systems (RAPIDS) has evaluated different RFID tags and also different Ultra-wideband systems. None of the investigated products was achieving nearly the performance (accurate location in densely cluttered environments consisting of reinforced concrete wall environments) that the one-watt ultra-wideband tags, provided by Multisprectral Solutions Inc. (MSSI) can provide. Furthermore we have based our selection of ultra-wideband tags on the fact that the Federal Communications Commission (FCC) has awarded Multispectral Soultions Inc. (MSSI) / British Petrol (BP) / IBM an experimental license at a much larger scale of 5,000 tags. Application File Number: 0038-EX-ML-2006 Callsign: WD2XSW Our research intends to be at a much smaller scale of maximum 100 tags. We will try to locate the proximity of workers to heavy equipment machinery such as cranes, derricks, excavators, etc on a nearby construction site. In addition, we are cooperation with the National Institute of Standards and Technology (NIST) in this research domain. Two research groups at NIST are using the same equipment from MSSI and the same 1W tags. 3

Experimental license We are awaiting FCC approval to implement the system inside our research laboratories, and on a construction site that is on the Georgia Institute of Technology campus. We have leaned from the experimental results of above described research project at a BP refinery and would like to implement, experiment, and test these tags on a medium sized construction project with adequate number of tags that can cover the personnel involved in the daily construction operation. We believe that once these tests are performed successfully, manufactures of safety equipment related to the construction industry will follow suite to comply with federal and state regulations, and improve safety actively using these tags. Please enable the major improvement in construction safety as quickly as possible by approaching our petition to allow indoor and outdoor use of 1W ultra- wideband tags. SEB Site currently under construction Figure 3: Location on Georgia Tech’s campus (RAPIDS laboratory in the Sustainable Education Building (SEB), Structural Laboratory, and nearby construction site for Nanotechnology building), reinforced structures require 1W tags We ask you to issue an experimental license to us to use - Multispectral Solutions Ultra-wideband equipment - Maximum one hundred 1W tags - License duration of 48 months (needed to validate safety approach in a long term study to prove that accidents/fatalities are prevented using UWB-tags) - Location: Indoor and outdoor use on the campus of the Georgia Institute of Technology, Radius 0.6km According to a note from Multispectral (MSSI) to the FCC on September 19, 2006 “the higher power tags (1W) are designed to be hermetically sealed. Furthermore, the electronic design and enclosures were required to pass stringent UL certifications for use 4

in hazardous environments (UL 1604). As such, these tags were not designed with a mechanism for deactivation. […] MSSI has also applied for a waiver relating to the use of higher power tags for safety applications. It is our understanding that deactivation will be required for tags designed to operate under this waiver. It is our intent to redesign the tags used in the experimental license (1. above) to incorporate a deactivation switch for use under the broader waiver.” Educational Merit Secondly, our mission and vision at Georgia Tech is to teach our students on emerging technologies to strive for better education and innovation through research that hopefully will benefit the entire society. Granting an experimental license will educate students involved in the research project to strive for new goals in their careers. Request for experimental license I do ask you to give Georgia Tech an experimental license that allows us proceeding in our research efforts to prevent accidents and save lives in the construction industry. We believe our experimental research efforts will have significant impact in other industries. Thank you very much for your assistance in this urgent matter. Sincerely, Jochen Teizer Director of the Real-time Acquisition and Processing for Information Decision Systems (RAPIDS), Research for the Future Construction and Transportation Industry Attachments that were previously submitted to FCC that may clarify some of the technical components and intentions in safety: - Details on the FCC experimental license issued to BP - Support Letter from IBM for BP’s experimental license - Needs Letter from BP’s refinery to issue experimental license Please be aware that our experiments will be on a much smaller scale. 5

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Document Created: 2007-02-26 15:48:57
Document Modified: 2007-02-26 15:48:57
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