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Dear Bill Stumpf,
I thought as per "FCC Part 15 section 15.102 b", modular approvals
are applicable to ITE & unintentional radiators also. If not how computer
add on cards (PCI to SCSI add on card etc.) gets DoC.
Sincerely
K.Balasubramanian
Sr.Engineer, Hardware.
Bill Stumpf
<[email protected] To:
"'[email protected]'"
om>
<[email protected]>, Bill Stumpf
<[email protected]>
06/25/2004 11:09 cc:
[email protected], 'Jan Vercammen'
PM <[email protected]>,
[email protected]
Subject: RE: question
concerning FCC Subparts B/C
Dear K.Balasubramanian,
If a Modular Approval is done for the transmitter, no further testing is
required for the radio transmitter in the final product. The final product
would still need to be tested to FCC Part 15, and therefore a DOC. Modular
Approvals only apply to transmitters, not ITE or other unintentional
radiators. See FCC da001407 for rules regarding FCC Modular Approvals.
Bill Stumpf
DLS Electronics
166 South Carter St.
Genoa City WI 53128
ph: 262-279-0210
fx: 262-279-3630
email: [email protected]
From: [email protected]
[mailto:[email protected]]
Sent: Friday, June 25, 2004 9:19 AM
To: Bill Stumpf
Cc: [email protected]; 'Jan Vercammen';
[email protected]
Subject: RE: question concerning FCC Subparts B/C
For a message posted on 10th March I am coming up on 25th June, but it is
better late than never.
Dear William M Stumpf ,
The modular concept of approval that you proposed is not clear to me.
You mean a separate Class B approval for the transmitter by testing it in
stand alone mode and similarly for the printer without transmitter. In this
case is it necessary to obtain another approval for the total system
(printer fitted with the transmitter)? If so is it sufficient with a DoC by
combining the 2 reports without doing any additional testing. Section
15.102 b of FCC part 15 tells such a provision for assembled PCs. I have a
similar situation but for a different equipment.
Sincerely
K.Balasubramanian.
Bill Stumpf
<[email protected]> To: "'Jan
Vercammen'" <[email protected]>,
Sent by:
[email protected]
owner-emc-pstc@majordo cc:
mo.ieee.org Subject: RE: question
concerning FCC Subparts B/C
03/10/2004 10:12 PM
Please respond to Bill
Stumpf
Jan,
The digital device can be tested as a Class A device, but the transmitter
can not, as 15.225 requires testing to the limits of 15.209 for an
intentional radiator. One key element here is to recognize the the
frequency range for which the digital device must be tested is 150kHz to 30
MHz ac line conducted, and 30 MHz to 1000 MHz radiated (possibly higher
depending on the highest clock/timing signal in the device). The
transmitter has to be tested from the lowest radio frequency signal
generated in the device (no lower than 9kHz), up to at least the 10th
harmonic of the highest fundamental frequency of the transmitter. In your
case, approximately 136 MHz. See FCC Part 15.33 for further clarification.
The emissions from the digital device should be compared the the Class B
limits, and those emissions from the radio transmitter should be compared
tot he 15.209 limit. The devices both have to be tested as a system, unless
you chose to request a Modular Approval for the transmitter. I hope this
helps.
Regards,
William M Stumpf
DLS Electronics
166 South Carter St.
Genoa City WI 53128
ph: 262-279-0210
fx: 262-279-3630
email: [email protected]
-----Original Message-----
From: Jan Vercammen [mailto:[email protected]]
Sent: Wednesday, March 10, 2004 8:04 AM
To: [email protected]
Subject: question concerning FCC Subparts B/C
__________________
Hello emc-pstc list,
I have a question concerning the integration of an RF tag reader or
Short-Range-Device operating in the 13,56MHz band
in a medical printer.
In order to understand the full issue one needs complete product
information.
It concerns a medical printer, that is, a printer that is is used in
hospitals, healthcare centers and
possible at residential areas. For residential areas the printer
operation is by a healthcare specialist
(e.g. radiologist that operates his own radiology business, but these
cases are limited).
The printer is not portable (weight 75kg), but it is a model.
The printer is a complex machine that provides:
- a twisted-pair LAN (Ethernet) interface
- queueing and storage for images
- image processing
- manages many sensors, DC and stepper motors and electromagnetic
clutches for film transport
- and a wirelessshort range RF system for the identification of the
film type (batch nr, film type, film processing data, ...)
The RF device operates at 13.56MHz and is a small printed circuit
board (PCB) of 11cmx7cm. The antenna is
integrated on the PCB (and is not removable). The interface to the
printer is over a RS232 interface.
The RF tag reader is mounted in the film input cassette and is
positioned to align the tag in the film pack
with the antenna of the reader. The maxiumum power of the RF device
is 100mW( and, by means of a relay, 10mW for Japan).
The RF reader is part of the printer, it is just a module.
From a regulatory point of view we have Europ. The printer + RF
device is tested according to IEC60601-1-2:1993, class A
for emissions. The RF device is tested according to ETSI (EN)
standards.
Our main focus is now on the US and we need to apply FCC rules. The
code of federal regulations part 47 part 15
subpart A (=definitions), B (=unintentional radiators) and C
(=intentional radiators).
I reference the FCC standard clause 15.3 (K), which concerns the
definition of a digital device.
It states somewhere halfway:
A radio frequency device that is specifically subject to an emanation
requirement in any other FCC Rule part
or an intentional radiator subject to subpart C of this part that
contains a digital device is not subject to the standards for
digital devices, provided the digital device is used only to enable
operation of radio frequency devicea nd the
digital device does not control additional functions or capibilities.
In this case the digital device is the printer and the main
operation is that of a printing device. The RF device is a small
internal part. The digital device (= the printer electronics) has
many more functions and control functions
besides controlling the operation of the RF device and therefor it
seems to qualify (?) as a digital device.
The RF device should be tested according to clause 15.225 of part 47
part 15 subpart C, which has details about the testing of the
radio parameters of RF devices operating in the band
13.553-15.567MHz.
The printer with the RF device should comply with emission limits of
part 47 subpart B class A or B. If one follows the
classification then one can use class A.
The above, however, is my line of reasoning. It has a focus on the
fact that the printer is a commercial non-portable digital device,
which
happens to include a RF device of which the radio type parameters
have been tested.
However, there is an alternative line of reasoning: by including an
RF device, which requires class B emisison limits (see clauses
15.207 & 15.209), the whole printer becomes a class B device.
However, the class B limits are for intentional radiators and not for
digital devices!
The question is simple: can we use class A emission limits for the
printer + RF tag reader? If we can not, what are the
arguments why class A can not be used?
I hope that you can help me to figure this one out.
Kind regards,
Jan Vercammen
EMC engineer
I have asked the RF device maufacturer and the maintain that the
device should be tested as
Kind regards,
Jan Vercammen
Agfa-Gevaert NV, Belgium
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