Inconsistency of a recently proposed method for assessing magnetic field exposure for protection against peripheral nerve stimulation in occupational situations

A non-binding guide to practical implementation of European Directive 2013/35/EU concerning the limitation of occupational exposure against electromagnetic fields has been published recently. With regard to exposure assessment this guide proposes practically applicable assessment methods for non-uniform and non-sinusoidal environmental electric and magnetic fields, respectively. For non-sinusoidal magnetic fields in the low frequency range this guide proposes a time domain assessment (TDA) method, claimed to reduce the overestimation of exposure inherent to other assessment methods while being based on fundamental physiological principles regarding nerve stimulation. In the present paper we demonstrate that the proposed TDA method is not consistent with the obvious underlying principles of directive 2013/35/EU. Based on practically relevant waveforms and general considerations it can be shown that external magnetic fields may be deemed compliant by the TDA method although the underlying exposure limit values defined in 2013/35/EU may be exceeded. We therefore strongly recommend that the TDA method is removed from the guide for implementing 2013/35/EU as soon as possible.