Trends & Insights from an Industry Pioneer
About Subsurface Reflections:
The goal of this blog is to share interesting and inspiring articles related to subsurface imaging and geophysics. Written by experts in the field of geophysics, ground penetrating radar, software development and data analysis, this is a source for insights about the practical application of technology in the field of subsurface imaging and a place to shed light on common misconceptions in the industry.
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Ground Penetrating Radar (GPR)
Dr. Peter Annan
Founder & CEO
Peter is the CEO of Sensors & Software. His scientific research has been recognized worldwide with numerous awards for his pioneering work in ground penetrating radar (GPR) instruments and data analysis methods. He has authored multiple scientific publications, patents, and technical reports and served on various government and professional committees.
GPR use is regulated! What does this mean? There are two parts to regulation which are summarized as follows.
- Manufacturers must have devices which are government-approved. In order to be government approved, GPR devices must be tested at a certified test facility and records kept on their performance. In the United States results must be reviewed by the Federal Communications Commission (FCC) and a unique device identifier assigned. Details of the device and test results are posted on the FCC website. Canada imposes the same requirements through Industry Canada. In Europe the devices must meet the ETSI standard and a declaration of conformity must be available from the manufacturer.
- Second, regulation most often requires users to be licensed to use a GPR device. Most users may be shocked to hear that they could be in violation of this requirement. Different jurisdictions approach this licensing requirement differently which makes things complicated.
Most GPR users know that the manufacturers requirement is to only sell certified equipment; few know about the user licensing requirement. Licensing is a fuzzy issue; it varies from jurisdiction to jurisdiction, creating further confusion.
In the USA, the FCC avoids individual user licensing by designating users as a class of professionals by making reference to part 90 of the FCC regulations. Users must be of a class of professionals as designated on the labelling on the GPR instrument. Further, users are required to register the geographic area of use of their GPR with the FCC. If users refer to their instrument manuals there should be a form accompanied with instructions on how to register. Lack of this information in the manual means that the manufacturer is not conforming with FCC regulations. Failure to submit the information means the user is in violation. From my experience, few, if any, users do this.
In the EU, all users are required to maintain a usage log for each GPR with details as to GPR type, time of operation and location. In addition, users must obtain a license to use GPR in the country where they were making measurements. While this requirement was mandated in 2008, only the UK, to my knowledge, has actually created a mechanism to license GPR users. After a decade, other countries in the EU have yet to create a licensing regime. Some may have moved lately, but after waiting years, following progress has become a waste of time.
In Canada, individual user licenses are not needed although it is normally a requirement. Industry Canada learned from the EU licensing challenges and decided that the bureaucracy to create a licensing structure could not be justified from a cost perspective. As a result, they decided to allow unlicensed usage but this could change if the number of GPR uses balloons and interference becomes a problem. Wording on manuals required the use to be limited to that same type of processionals as defined by the FCC
What are some of the fictions that seem to have appeared around regulation and licensing? The sources of these fictions are obscure but, from what I have seen, some vendors create misinformation in an attempt to gain a sales advantage. These pieces of misinformation pop up from time to time and they need to be countered regularly.
A few misconceptions are as follows.
There are many more, but we will identify those in future commentaries.
GPR cannot be used below 100 MHz.
This is a totally false statement. Only in the EU is there currently a lower limit on GPR devices and this is 30 MHz. This frequency limit has a historical basis but no technical foundation and at some point, will probably be removed. Given the slowness of bureaucratic processes,this could take another 10 or 20 years.
GPR must use shielded antennas.
This again is another fallacious statement. There are no criteria in any of the regulations about how a device is constructed. The only regulatory limitation is that the device must meet the limit on emissions into the air when tested.
GPR must be on the ground to be operated.
The statement is again incorrect. GPR can be above the ground surface for some types of measurements. There is a strict limit on height which is one meter in all jurisdictions currently. (Beware all drone and UAV users who are flying GPR at greater heights.)
All GPR devices that claim to satisfy regulations are legal.
Again, this is a false statement in all jurisdictions with published regulations, GPR instrumentation must carry some form of labeling dictated by the country of use/sale. For example, the FCC requires a unique device identifier to be on the product along with some statement about the professional users who can use the device. In some cases, specific GPR usage labels are not required but there is always some form of labeling requirement. Failure to comply with labeling makes the device unfit for commercial sale and therefore not usable by a buyer. The FCC is a strong proponent of proper labeling and cases of large fines being leveled for improper labeling are reported regularly.
In summary, it is important to understand the regulations surrounding the use of GPR in your region, and ensure that you are in compliance.