I didn't receive any response to my puzzler last week. Perhaps: a) I didn't put it in question form. b) There was insufficient interest in the topic. c) The mention of the word "auditor" was a mistake.
Assuming all (or some) of the above; Here's one more attempt. Is anyone using the 2009 version of C63.4 for FCC Part 15 compliance testing? If so what is your basis for its validity? FCC Public Notice DA 09-2478? Or something else? This appears not to be of general interest for group discussion, so if I receive enough private replies, I will post a summary of them. Thanks, Bob Sykes From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Sykes, Bob Sent: Monday, January 30, 2012 1:32 PM To: 'emc-p...@ieee.org' Subject: FCC Part 15 and ANSI C63.4 Worldly Experts, In preparing for an upcoming ISO audit and making sure my standards are in order, I have uncovered some potential problems. I am currently using ANSI C63.4 2009. My basis for doing so is the November 2009 FCC Public Notice (DA 09-2478) clarifying use of C63 Measurement Standards which effectively updated the (then) Rules by permitting either the 2003 or 2009 version of C63.4 for part 15 compliance testing. The Public Notice further stated: "The Commission will consider modifying its rules to reference the new measurement standards in a future rulemaking proceeding." Well here we are in 2012 and the latest version of Part 15 (Oct 2011 edition) still (only) references ANSI 63.4-2003. § 15.31(a)(3) states: "Other intentional and unintentional radiators are to be measured for compliance using the following procedure excluding sections 4.1.5.2, 5.7, 9 and 14: ANSI C63.4-2003:" With the re-numbering of the 2009 version, the indicated exclusions no longer align with the relevant topics (artificial hand, noise power measurements etc.). Adding further confusion is the note: "NOTE TO PARAGRAPH (a)(3): Digital devices tested to show compliance with the provisions of §§ 15.107(e) and 15.109(g) must be tested following the ANSI C63.4 procedure described in paragraph (a)(3) of this section." § 15.107(e) doesn't seem to exist? I can fill in the blanks and make sense of all of the above, but my concern is that this will not appease the auditor(s). If they take the position that the 2011 version of Part 15 supersedes the 2009 Public Notice I don't have anything to counter with. I feel like I must be missing something somewhere, but I am unable to find any further guidance on this. Any ideas most appreciated. adTHANKSvance, Bob Sykes Please be advised that this email may contain confidential information. If you are not the intended recipient, please notify us by email by replying to the sender and delete this message. 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To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
