Michael, is your equipment test equipment? I have asked the FCC this
question before and the answer I received is that test equipment is exempt
not all industrial and commercial equipment. If the equipment is test
equipment for the commercial, industrial, and medical environments then it
is exempt. If it is not then it falls under Part 15 unless it intentionally
uses RF for a purpose (RF heater, RF welder, etc.) then it falls under Part
18.
Bob Heller
3M EMC Laboratory, 76-1-01
St. Paul, MN 55107-1208
Tel: 651- 778-6336
Fax: 651-778-6252
=============================================================================
"Ilarina, Alvin"
<alvin.ilarina@pl
antronics.com> To
Sent by: "Ron Pickard" <ronpick...@cox.net>
emc-p...@ieee.org "Bill Stumpf" <bstu...@dlsemc.com>
cc
"M. Loerzer-Mobile (GLOBALNORM)"
09/19/2007 07:32 <loerzer_mob...@globalnorm.de>
PM <emc-p...@ieee.org>
Subject
RE: FCC Part 15 and electrical
equipment of machinery
Hello,
> therefore subject to FCC Part 15?
Yes, but more than likely eligible for an FCC Part 15.103 exemption.
> believe that FCC Part 18 would need to be applied, not FCC Part 15.
No, unless the equipment meets the following definition:
§ 18.107 Definitions.
(c) Industrial, scientific, and medical (ISM) equipment. Equipment or
appliances designed to generate and use locally RF energy for industrial,
scientific, medical, domestic or similar purposes, excluding applications
in the field of telecommunication. Typical ISM applications are the
production of physical, biological, or chemical effects such as heating,
ionization of gases, mechanical vibrations, hair removal and acceleration
of charged particles.
However, without a more specific definition of the equipment and intended
use it is difficult to answer correctly and probably foolish to try.
Regards,
Alvin
Disclaimer: The contents reflect the opinion of the author and are meant
for entertainment purposes only.
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ron Pickard
Sent: Wednesday, September 19, 2007 4:32 PM
To: 'Bill Stumpf'
Cc: 'M. Loerzer-Mobile (GLOBALNORM)'; emc-p...@ieee.org
Subject: RE: FCC Part 15 and electrical equipment of machinery
Hi Bill et al,
I do not know anything about Michael’s machinery products, their specific
applications or their intended environment of operation other than what
Michael has stated. However, Michael did state that these machines are only
offered for sale as complete machines that include microprocessor
controlled units, programmable electronic systems, drives, touch screens,
etc. It has not been stated that these electronic components are generally
sold separately for other applications.
If these electronic components are solely integral of these machinery
systems, then would these electronic components still be considered truly
“digital devices”, therefore subject to FCC Part 15? But, if those
machinery products are intended for the industrial environment (from
Michael’s description, they likely are), then I believe that FCC Part 18
would need to be applied, not FCC Part 15.
Comments anyone? I look forward to your replies.
Best regards,
Ron Pickard
ronpick...@cox.net
623-512-3451
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Bill Stumpf
Sent: Wednesday, September 19, 2007 1:47 PM
To: M. Loerzer-Mobile (GLOBALNORM); emc-p...@ieee.org
Subject: RE: FCC Part 15 and electrical equipment of machinery
Dear Mr. Loerzer,
Digital devices used exclusively as industrial, commercial, or medical test
equipment are subject only to the general conditions of operation in
Sections 15.5 and 15.29 and are exempt from the specific technical
standards and other requirements of Part 15. That said, exempted device
are required not to cause harmful interference. If the device is found to
cause interference, it is required that the operator stop operating the
device, and operation shall not resume until the condition causing the
harmful interference has been corrected. Although not mandatory, the FCC
recommends that the manufacturer of an exempted device endeavor to have the
device meet the specific technical standards in Part 15 Subpart B for Class
A unintentional radiators.
Regards,
Bill Stumpf
D.L.S. Electronic Systems, Inc.
EMC Testing & Consulting
166 South Carter Street
Genoa City WI, 53128
262-279-0210
This e-mail and any attachments may contain confidential material for the
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please be aware that any disclosure, copying, distribution or use of this
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in error, please contact the sender and delete all copies.
Thank you for your cooperation
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of M.
Loerzer-Mobile (GLOBALNORM)
Sent: Wednesday, September 19, 2007 8:53 AM
To: emc-p...@ieee.org
Subject: AW: FCC Part 15 and electrical equipment of machinery
Hi FCC Part 15 Experts,
if a EU machinery tool supplier bring a machinery into the US market and
this machinery includes "microprocessor controlled units" like programmable
electonic systems, drives, touc screens, ect. does the "overall machinery
system" need a FCC Part 15 approval? The equipments are not available
single units in the US market and haven´t therefore a single FFC approval.
But in my understanding the "machinery system" is a "unintential radiator"
with clock frequencies > 9 kHz (PES, drives) and must comply with FCC Part
15.
Is that correct?
Mit freundlichen Grüßen
Yours sincerely
Dipl.-Ing. Michael Loerzer
Managing Director
Regulatory Affairs Specialist
Fon: +49 30 3229027-50, Direct Call: -51
Mobile: +49 177 3229027 (new)
Fax: +49 30 3229027-59
www.Globalnorm.de
Globalnorm GmbH, Sitz der Gesellschaft: Alt-Moabit 94, 10559 Berlin
Geschaeftsfuehrer: Dipl.-Ing. Michael Loerzer
Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448
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