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.



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                                                   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.



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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.



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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


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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.




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

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