The Control of Electromagnetic Fields at Work Regulations 2016 require employers to assess the levels of EMFs their workers are exposed to against specific sets of exposure levels.

Helpfully, HSG281 'Electromagnetic fields at work - A guide to the Control of Electromagnetic Fields at Work Regulations 2016' has a table 2 that says that everything in my workplace will not exceed the indirect-effect ALs, and therefore the recording of my significant findings would just be that we don't have EMFs at the level to trigger requirements.

EXCEPT that table 2 when listing WiFi WAPs has a sneaky "Special consideration should be given to employees with active implants – see ‘Employees at particular risk’", and active implants include cochlea implants, and I have a member of staff with cochlea implants.  It also includes pacemakers, and various other stuff.

For all these, I'm apparently back to needing to do a full-blown measurement of EMF levels and detailed assessment.  I find it hard to believe that every site that has any WiFi in it and also has anyone with pacemaker, cochlear implants etc. is measuring EMFs. (But I've been known to be wrong once or twice before.)

There is possibly a get-out at para 59, which says "You should encourage workers to consider the information provided here and advise you if they may be affected. If they have implants or devices fitted, ask them to obtain information/instructions from the manufacturer of the medical device. If the device is implanted, they should also obtain advice from the medical professional who completed the implant procedure."

Is that saying we can put the onus on the person with the implants - tell them we have WiFi on site and ask them to tell us if that's a problem?

Alternatively, it also says "In the absence of any specific advice, you may wish to take a practical approach and limit the exposure of workers fitted with active implants to the public exposure limits – see Council Recommendation 1999/519/EC"

That would be fine, but how do I determine whether or not my office space is below the public exposure limits?  It probably is - we've got a few WAPs dotted around, but I can't find anything that relates ordinary WAPs to the public exposure limits - something that says 'if you stay at least 1.5m away you'll be below the public exposure limits' would be nice.

How is anyone else approaching this?  Do you monitor and map your EMF levels?  The HSE guide is full of repeated statements that most workplaces don't need any special measures, which would be fine except that it seems to be predicated on an assumption that 'most workplaces' don't have WiFi.