Mark, all,

I stand corrected:

        > FCC part 15.31(i) requires that the peripherals be unmodified,
                   ^^^^^ 
        > commercially available devices.

This section applies regardless of whether the product is
FCC-certified, verified, or whether a DofC is issued.

I had only remembered the section in 47CFR2.1033, which
only applies to certification.

Next time I'll defer to the lawyers...

Regards,
Dan


> From owner-emc-p...@majordomo.ieee.org Wed Sep  2 15:31:20 1998
> Subject: Re:  peripherals
> Date: Wed, 2 Sep 98 10:11:05 -0800
> x-sender: mbri...@pop.elliottlabs.com
> From: Mark Briggs <mbri...@elliottlabs.com>
> To: "Gary McInturff" <gmcintu...@packetengines.com>, <emc-p...@ieee.org>
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> 
> Gary, in answer to your comments:
> 
> >I would appreciate some skull scratching here, but preferably can
> >someone provide the FCC/CISPR citation on this point.
> >I have spent an interesting amount of money testing big name devices
> >looking for very quite support equipment.
> 
> FCC part 15.31(i) requires that the peripherals be unmodified, 
> commercially available devices.
> 
> ANSI C63.4 section 11 defines the minimum system configuration for 
> computer peripherals and clearly shows, in section 6, the host PC and 
> accompanying peripherals located on the test table.  The last amendment 
> to CISPR 22 (A2) began to align CISPR 22 with ANSI C63.4 such that it 
> defines minimum system configurations for PC-type products.
> 
> >Equally important in this argument is that you cannot identify through
> >test identify a non-complying signal as belonging to the support
> >equipment rather than the EUT and then claim compliance. 
> >This concept has been stuck in my head for many years, probably dating
> >back to the earliest MP-4 documents and part 15 regulations. I vaguely
> >associate it with the sections that described peripherals to exercise
> >equipment and what was or was not acceptable.
> 
> ANSI C63.4 (1992) section 6.1.2.1 (which discusses the use of remote 
> support equipment under certain circumstances) clearly indicates that the 
> purpose of the test is to evaluate  "...the interference potential of the 
> EUT, its accessories, and interconnecting cables or wires apart form the 
> remotely located device...".  This would suggest that the combination of  
> EUT and local support equipment must meet the limits, i.e. you cannot 
> switch off the support equipment.  
> 
> >Obviously, I would prefer to win this argument but on the other hand it
> >sure makes the search for peripherals that meet my needs a lot easier.
> 
> 
> Hope this doesn't add more fuel to the fire !
> 
> Mark
> 
> 
> 
> Mark Briggs
> mbri...@elliottlabs.com
> 
> 
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