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[802SEC] Responses to comments on 802.15.6 draft PAR and 5C

EC Colleagues:

Three people commented on the 803.15.6 PAR and one person commented on the 
5C. The revised documents are available at These changes were approved by the 
Working Group by a vote of 70/0/4

All comments received on the 802.15.6 PAR were editorial in nature.  They were:

From: "T W Olsen" <>
5.2 Explain "QoS" and "TX"
5.4 Explain "PANs"
5.6 Explain "EEG", "ECG", and "EMG".

From: "Ronald C Petersen" <>
5.2 Scope: The scope on the PAR should appear exactly as it will appear in 
the published standard. Consider revising the scope to describe what the 
standard covers rather than what it will cover or what will be considered.
5.4 Purpose: If the standard has a purpose clause, it should appear on the 
PAR exactly as it will appear in the published standard, i.e., the purpose 
of the standard rather than what the purpose of the proposed standard will be.

Response to the above two commenters was to spell out the acronyms on first 
use and to recast the tense of the scope and purpose.

5.2 Scope of Proposed Standard: This is a standard for short range, 
wireless communication in the vicinity of, or inside, a human body (but not 
limited to humans). It can use existing ISM bands as well as frequency 
bands approved by national medical and/or regulatory authorities. Support 
for Quality of Service (QoS), extremely low power, and data rates up to 10 
Mbps is required while simultaneously complying with strict 
non-interference guidelines where needed. This standard considers effects 
on portable antennas due to the presence of a person (varying with male, 
female, skinny, heavy, etc.), radiation pattern shaping to minimize SAR* 
into the body, and changes in characteristics as a result of the user 
motions. *SAR (Specific Absorption Rate) measured in (W/kg) = (J/kg/s). SAR 
is regulated, with limits for local exposure (Head) of: in US: 1.6 W/kg in 
1 gram and in EU: 2 W/kg in 10 gram. This limits the transmit (TX) power in 
US < 1.6 mW and in EU < 20 mW.

5.4 Purpose of Proposed Standard: The purpose is to provide an 
international standard for a short range (ie about human body range), low 
power and highly reliable wireless communication for use in close proximity 
to, or inside, a human body. Data rates, typically up to 10Mbps, can be 
offered to satisfy an evolutionary set of entertainment and healthcare 
services. Current Personal Area Networks (PAN)s do not meet the medical 
(proximity to human tissue) and relevant communication regulations for some 
application environments. They also do not support the combination of 
reliability (QoS), low power, data rate and noninterference required to 
broadly address the breadth of body area network applications.

5.5 Need for the Project: There is a need for a standard optimized for 
ultra low power devices and operation on, in or around the human body to 
serve a variety of applications including medical and personal 
entertainment. Examples of the applications served by the proposed standard 
are: Electroencephalogram (EEG), Electrocardiogram (ECG), Electromyography 
(EMG), vital signals monitoring (temperature (wearable thermometer), 
respiratory, wearable heart rate monitor, wearable pulse oximeter, wearable 
blood pressure monitor, oxygen, pH value , wearable glucose sensor, 
implanted glucose sensor, cardiac arrhythmia), wireless capsule endoscope 
(gastrointestinal), wireless capsule for drug delivery, deep brain 
stimulator, cortical stimulator (visual neuro-stimulator, audio neuro 
stimulator, Parkinsons disease, etc&), remote control of medical devices 
such as pacemaker, actuators, insulin pump, hearing aid (wearable and 
implanted), retina implants, disability assistance, such as muscle tension 
sensing and stimulation, wearable weighing scale, fall detection, aiding 
sport training. This will include body-centric solutions for future 
wearable computers. In a similar vein, the same technology can provide 
effective solutions for personal entertainment as well. The existence of a 
body area network standard will provide opportunities to expand these 
product features, better healthcare and well being for the users. It will 
therefore result in economic opportunity for technology component suppliers 
and equipment manufacturers.

From: <>Anne-Marie Sahazizian
Would like an explanation as to why the submitter considers the answer to 
7.3  -No

Response to Anne-Marie was-
We pondered this question and concluded it is ambiguous regarding the 
intent of what it is asking. Although the project relates in some aspects 
to health management and therefore affects human health management, we 
assumed the question relates to whether the proposed standard can cause 
health problems or potentially adversely affect human health. If the latter 
situation is the case then the answer is NO. The standard proposed in this 
project has substantially less health risk (because of considerable less 
use) than a cell phone which is also governed by Specific Absorbed 
Radiation limits. For all other wireless projects in 802 the answer has 
been NO even though technologies like 802.11 can be used as a network in 
health related applications.

Of course, if the question is intended to be more general than that, 
relating to health benefits as well as risks, then the answer would 
probably be YES. If NesCom can be specific on the intent of the question, 
we can fill in the appropriate answer. Any guidance on that?

The reply back from Anne-Marie was:  Question 7.3 was answered with NO and 
I simply wanted to have a better understanding of it. You kindly explain in 
your e-mail (intend was as per 1st para) This reply is sufficient --

We left the answer unchanged in the PAR.

Comments related to the 802.15.6 5C-

From: Steve Shellhammer
I looked over the BAN 5C and noticed that it did not address
the coexistence requirement from the P&P

Response:  In addition to the following reference which has always been in 
the PAR itself,

7.4 Additional Explanatory Notes: (Item Number and Explanation) It is in 
the best interest of users and the industry to strive for a level of 
coexistence with other wireless systems, especially those in similar market 
spaces. Coexistence requirements will be established by the Task Group in 
cooperation with the 802 TAG on coexistence (802.19) and included in the 
selection criteria against which the proposals will be evaluated.

we added the following statement to 4 c) in the 5C

A coexistence assurance document will be submitted to the 802.19 TAG.

Bob Heile, Ph.D
Chairman, ZigBee Alliance
Chair, IEEE 802.15 Working Group on Wireless Personal Area Networks
11 Louis Road
Attleboro, MA  02703   USA
Mobile: +1-781-929-4832

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