Published: TV Technology

Issue: 23 February 98



FCC Proposes New Medical Sharing Plan



by Joe Fedele



WASHINGTON

  Imagine doing a news story at a hospital and then finding out your wireless microphone may have 

contributed to the death of a patient. This could conceivably happen now that an FCC Report and 

Order  97-379 (docket #95-177) has been put into effect.

  The FCC issued an order late last year that would allow biomedical telemetry devices to be oper-

ated on VHF and UHF television channels 7 to 46 within health care facilities. These telemetry de-

vices permit patients to move freely in hospitals while being continually monitored by health care 

providers. The devices include heart, blood pressure and respiration monitors that are used by pa-

tients in their recovery.

  Through the use of such unlicensed devices, one health care worker can monitor several patients at 

a time for adverse symptoms to medical treatments. This, the FCC said, would help speed patient 

recovery times, shorten lengths of stay and reduce health care costs.

  This order is actually a revision and expansion of a previous docket that allowed biomedical de-

vices to operate on TV channels 21 to 29 (Part 15.209(g)(2)), but at much higher power levels. In a 

strange twist, however, the commission said it is deleting the older rules because “it appears that no 

one has manufactured equipment for this application and that this rule is no longer necessary due to 

the expanded applications being adopted herein.”

  Yet, the order to allow unlicensed medical devises to operate on these frequencies — and at power 

levels of up to 59 dB higher than previously allowed — has broadcasters fearing the worst. In 

scathing comments filed in 1996, the Society of Broadcast Engineers (SBE) emphatically denounced 

the docket as “fundamentally flawed” and an “unrealistic use of unprotected Part 15 frequencies for 

medical telemetry [that] may even place patients at risk.”



A POOR DECISION?

  The Community Broadcasters Association (CBA) stated that the “TV spectrum is a poor environ-

ment to launch critical medical devices on which health and lives will depend.”

  But the commission appears adamant and has concluded that “the TV broadcast spectrum can sup-

port low-powered biomedical telemetry systems.” 

  In addressing the opposing comments submitted by the SBE, CBA and others, the order stated that 

“the patient benefits provided from providing additional frequencies for biomedical telemetry de-

vices are of sufficient importance to justify the operation of these products on vacant channels 

within the TV broadcast bands.”

  Oddly enough, the FCC has put the burden of preventing interference on hospitals but refuses to 

require that such equipment be installed by “trained field personnel.” The commission went on to 

say that due to the high cost of the equipment, engineering studies and “the potentially disastrous 

impact on patient health should the biomedical telemetry systems be installed without properly ad-

dressing all interference concerns ... [we] cannot conceive that any reputable health care facility 

would install this equipment without using highly skilled installation personnel.”

  Consequently “it is expected that health care facilities, in combination with the manufacturers and 

installers, would expend considerable effort to avoid operating on occupied broadcast channels.”

  The Critical Care Telemetry Group (CTTG), an organization that petitioned the FCC to implement 

these rule changes, stated that “the commission should consider dedicating spectrum to the exclusive 

use of medical telemetry after the DTV transition.”

  But the FCC nixed the CTTG’s suggestion and stated that “the record in this proceeding is not suf-

ficiently complete to determine which, if any, additional channels should be employed.”  But the 

commission left the door open for changes to its position in the future when “standard analog TV 

broadcasting is phased out.”



THE POSSIBLE DANGERS

  The Center for Devices and Radiological Health of the Food and Drug Administration expressed 

concern about the potential for injury to patients that might occur if there is interference between the 

medical device and broadcast licensees.  It recommended that the commission grant exclusive li-

censes to biomedical telemetry devices for the primary use of locally “unused TV channels.”

  In its Report & Order, the FCC does not address the fact that these “unused TV channels” are also 

used for wireless microphones and/or other communications services, such as land mobile, which 

constantly operate in the spectrum. This fact was pointed out in comments filed by the SBE, yet the 

order makes no mention of this and repeatedly refers to the spectrum as “unused TV channels.”

  Biomedical telemetry devices are currently authorized to operate in the 450-470 MHz band under 

Part 90. The new order would permit Part 15 licensees to operate biomedical telemetry devices in 

the 174-216 MHz band (VHF TV channels 7-13) with field strengths of 1,500 microvolts-per-meter 

(uV/m) and in the 512-566 MHz band (UHF TV channels 21-29) with field strengths of 200 uV/m. 

The field strengths specified are measured at three meters from the radiating source. This translates 

into about 5 milliwatts (mW) of output power.

  Battery-powered, biomedical belt packs typically operate at between 2 to 4 mW of power. When 

compared to the 20 to 100 mW output power of some wireless mics, one is able to see how broad-

cast equipment can cause severe interference to medical devices if used in proximity.

  Ironically, the FCC appears to also be interested in protecting radio astronomy equipment. The or-

der calls for a “coordination procedure to protect radio astronomy observatories from potential inter-

ference from biomedical telemetry devices operating at 608-614 MHz (TV channel 37).”

  The commission makes no mention of instituting similar coordination procedures to protect the 

biomedical devises from interference, however.  The order specifically states that biomedical de-

vices may only operate on a secondary biomedical telemetry device and that they must accept what-

ever level of interference is received from other radio operations. This “secondary status” is typical 

of unlicensed operations.

  Only Capital Cities/ABC indicated the need for “prior frequency coordination by medical telemetry 

user through the existing broadcast auxiliary frequency coordinator network.” But, the company 

goes on to note that “controls and accountability must be established for the resolution of interfer-

ence problems.”

  Comments filed by the CCTG suggest that broadcasters should have the burden of prior coordina-

tion of its licensed wireless microphones and other Broadcast Auxiliary services devices.

  This drew a venomous response from the SBE in reply comments, where it stated that “Broadcast 

Auxiliary licensees pay application fees when initially filing for their authorizations and then must 

pay annual user fees thereafter. Users of unlicensed, Part 15 devices pay no such fees and are not 

entitled to any protection whatsoever from licensed services.”

  Even the Leesburg Regional Medical Center  in ??? and Texas Children’s Hospital in ??? are con-

cerned that interference will be caused to biomedical devices from TV signals rather than interfer-

ence from biomedical devices to TV signals.  The commission agreed, stating that “biomedical 

telemetry systems are very sensitive to interference and are more likely to receive interference on 

any given channel before causing interference.”

  The commission’s concern for broadcasters was clearly spelled out as the order notes that “the 

standards being adopted for these devices should protect existing television and future advanced 

digital television (DTV) services and low-power television (LPTV) stations from potential interfer-

ence.”

  Such changes, the order states, would also “support spectrum efficiency by facilitating the sharing 

of scarce radio spectrum and facilitating use of radio spectrum to provide cost-efficient and needed 

medical technologies to health care communities.”

  But the Public Broadcasting Service (PBS) and the Association of America’s Public Television 

Stations commented that “it would be a mistake for the commission to establish a new system in the 

TV broadcasting spectrum where substantial changes are [already] planned.”

  The SBE was much more blunt about its opinions, stating that “potentially life-critical biomedical 

telemetry has no place as a ‘bottom-of-the-food-chain’ device.”