The fact remains that a new or existing company must design its products to meet Regulations. A newcomer has to figure out the cost of it products prior to embarking upon actually designing and making them, only the very poorest newcomer (poorest in the sense of piss poor planning) would embark upon the design of a product and then discover that it’s product failed to meet the regs during the testing phase.
As part of the generation of funding a startup would also account for the cost of achieving compliance, again if it failed to do this going back to the investor and highlighting the omission would be somewhat embarrassing. If there is any benefit to an existing company it might be that it had an already established regulatory department, but it still needs to budget for the cost of meeting compliance and fund the facilities and testing. A new startup would also benefit from achieving compliance since it would offset/reduce/omit any claim from a 3rd party (particular a competitor) alleging that its product did not meet a regulation, where the startup holds a formal indication it meets the required standards it is able to defend itself. If in the world of no regulation if Company A, an established competitor to Company B a new startup, alleged that company B’s newly released product interfered with its and everybody else’s electrical products there might well be a situation where Company B’s products failed to sell, a complete disaster for a startup. At least with independent evidence Company B can claim otherwise and quickly, in the world of no regulation Company B would have to seek legal re-dress through the courts which could realistically spell the end for company B given the time and resources needed to succeed in this route. Some current regulations are unnecessary, but regulation covering products interworking with other products or environments are IMO a good thing. Carl ________________________________ From: Ken Javor [mailto:ken.ja...@emccompliance.com] Sent: 02 May 2008 16:13 To: Richards, Carl; EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: FCC Immunity Requirements I don’t understand how the first statement applies to the idea that all these regulations are a barrier to entry, but just a cost of doing business to the established players. Ken Javor Phone: (256) 650-5261 ________________________________ From: "Richards, Carl" <carl.richa...@aspect.com> List-Post: emc-pstc@listserv.ieee.org List-Post: emc-pstc@listserv.ieee.org List-Post: emc-pstc@listserv.ieee.org Date: Fri, 2 May 2008 11:08:01 -0400 To: Ken Javor <ken.ja...@emccompliance.com>, <EMC-PSTC@LISTSERV.IEEE.ORG> Conversation: FCC Immunity Requirements Subject: RE: FCC Immunity Requirements Not at all, since the price of any product includes the cost of achieving compliance, amongst other things. If you said I object to paying so much for a product and compliance is a major contributor to the bottom line then I might agree with you. Carl ________________________________ From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] <mailto:emc-p...@ieee.org%5d> On Behalf Of Ken Javor Sent: 02 May 2008 16:03 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: FCC Immunity Requirements Apple is now and has been established since the introduction of the Mac (1984). The point is that the established companies profit from the raised level playing field, and newcomers are penalized. Ken Javor Phone: (256) 650-5261 ________________________________ From: "Richards, Carl" <carl.richa...@aspect.com> List-Post: emc-pstc@listserv.ieee.org List-Post: emc-pstc@listserv.ieee.org List-Post: emc-pstc@listserv.ieee.org Date: Fri, 2 May 2008 10:54:36 -0400 To: <EMC-PSTC@LISTSERV.IEEE.ORG> Conversation: FCC Immunity Requirements Subject: RE: FCC Immunity Requirements Apple still turn out cracking products even with today’s regulations, the customer pays for the regulation as part of the purchase price. Looking at my Iphone I can’t see any part of its functionality that is hindered by regulation, but plenty that is hindered by good old marketing and position protection. :-) Carl ________________________________ From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] <mailto:emc-p...@ieee.org%5d> <mailto:emc-p...@ieee.org%5d> <mailto:emc-p...@ieee.org%5d> On Behalf Of Ken Javor Sent: 02 May 2008 15:47 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: FCC Immunity Requirements A lack of perspective is on display here. First, has anyone anywhere bought ten of anything to find one that works – and in the total absence of immunity requirements? Of course not, that is an exaggeration to make the author’s point. But all this ignores a larger and much more important truth. It is indeed correct that industry comes up with these requirements, which are then imposed as Law. But it is perceived by existing industry that these requirements are useful to them. Because impartially imposed, they simply raise a level playing field, but in that raising they act as a barrier to entry of new competitors. Would the two Steves, Wozniak and Jobs, have been able to develop the Apple in their garage if they had to go through the wickets of all the requirements now on the books? A more basic question. Would Edison’ slight bulb have ever illuminated the night if an environmental impact statement had predicted the electrical power infrastructure necessary to support it, and the resultant “man-made global warming”? All regulations are in some manner a barrier to entry and a barrier to innovation. That cost is never seen nor measured, nor even, apparently, much considered. Ken Javor Phone: (256) 650-5261 ________________________________ From: Andrew McCallum <andrew.mccal...@deltarail.com> List-Post: emc-pstc@listserv.ieee.org List-Post: emc-pstc@listserv.ieee.org List-Post: emc-pstc@listserv.ieee.org Date: Fri, 02 May 2008 14:48:15 +0100 To: Ken Javor <ken.ja...@emccompliance.com>, <EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: FCC Immunity Requirements European standards are written up in consultation with industry to be realistic and workable (in theory). It may be the STATE that enforces it but industry has defined it. I would rather buy one laptop knowing it will work rather than have to go through 10 laptops till I find one that works. Thanks for your point of view though Ken >>> Ken Javor <ken.ja...@emccompliance.com> 02/05/2008 14:21 >>> Fascinating thought processes here. Who will protect the consumer? And from whom? It is one thing to impose EMI requirements on equipment to be installed in close proximity on platforms. There as pointed out the close proximity of susceptible equipment to high power sources, and not mentioned but also key, the juxtaposition of sensitive receivers to unintentional rf sources, makes the imposition of equipment-level requirements economical alternatives to checking compatibility solely at the point of integration. But this idea that the poor defenseless consumer must be protected against the uncaring free market by the beneficent state – where does that come from? It may well be as Mr. Woodgate states in Europe, that with high population densities and a dense electromagnetic environment that enough problems surfaced to make it again an economical solution to introduce an artificially leveled playing field via government mandate. But in the absence of that situation, which is clearly where we are at in the USA, it is either comical or tragical that someone feels that the government must step in to provide protection not afforded by the invisible hand of the free market. If I buy a laptop that freezes or loses its memory when I open it up at an airport, I make a mental note not to buy a product from that company again. Now in cases where the free market doesn’t work, you may need some extra help. If I don’t wake up from a medical operation because the equipment used during that operation malfunctioned, then there will be a free market correction, but it is too late to help me out. So there the FDA steps in. But the idea of government stepping in where it isn’t absolutely mandatory can’t help but dredge up memories of all the absolutely ridiculous pronouncements that continuously emanate from on high. For those of you who live in California, or who have ever traveled there, just how many health hazards are “known to the State of California” ? And what is the rate-of-increase of such postings? One would come to the conclusion that either the state of California is much smarter than the rest of the forty-nine states, or that CA is a very unhealthy place to live. Ken Javor Phone: (256) 650-5261 ________________________________ From: Andrew McCallum <andrew.mccal...@deltarail.com> List-Post: emc-pstc@listserv.ieee.org List-Post: emc-pstc@listserv.ieee.org List-Post: emc-pstc@listserv.ieee.org Date: Fri, 02 May 2008 13:43:56 +0100 To: <EMC-PSTC@LISTSERV.IEEE.ORG> Subject: FCC Immunity Requirements Grace I hope other countries do introduce immunity requirements to match the EU standards. In the railway industry at least it gives us some idea if a piece of equipment is going to last more than 5 minutes. Without the standards everything would have to be subject to extensive and expensive testing on the trains. I think the consumer would notice the removal of the standards with increased equipment failures and reliability issues with equipment in the home - who wants their washing machine skipping the spin cycle because someone stood too close with a mobile phone. In truth it may not be the FCC concern as such but if not them who will protect the consumer? Andy ________________________________ Confidentiality: This e-mail and its attachments are intended for the addressees only (or people authorised to receive them on their behalf) and may be confidential or privileged. If they have come to you in error you must take no action based on them, nor must you copy or show them to anyone; please delete them from your system and reply to this e mail highlighting the error. Security: Please note that this e-mail has been created in the knowledge that internet e-mail is not 100% secure. Anyone who communicates with us by e-mail is taken to accept this. 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