Hi Charles,
Sorry for the late reply. I'm just back from vacation and it's possible you may already have your answer. I think there's the engineering aspect and also the legislative aspect. Firstly, if the WiFi part is a "fully certified module", then you should not need to repeat all those WiFi tests. The module should have been certified for any host and should therefore not require re-testing for a change in host. (Accepting that the host must be re-tested for its own emissions). If the WiFi part is a "Limited Modular Approval", then it may need to be partially re-tested, to allow use in this "newly designed host", if the changes are significant. (For example, you might need to consider if the module has a voltage regulator and if the voltage to the module has changed. Now, based on your question, I am going to guess that the WiFi part does not actually have a certification or an FCC ID of its own. So, you would be taking test results from one unit and applying them to another unit. As an engineer, I can see that it would most likely not be a problem. Most likely, the majority of test results may remain unchanged. Of course, I have no idea about the voltage supply to your WiFi transmitter section, or the temperature change around the WiFi part, etc., etc., all of which can affect transmitter performance. (Notice the excessive use of "most likely" and "may" in there). >From an admin point of view though, you need to be careful that you're not calling the WiFi a "reference design", whereby you have certified a device once and then assume the same design will always comply in other hosts, environments and circumstances. There is not (yet?) a place for this in the FCC rules. Also, your old device and your new device would have different FCC IDs but they would have identical test report values for the WiFi sections. When the FCC are searching for faked test reports, this is one of their search criteria (two separate certified devices with identical output powers, for example). In their search, your two devices would show up as having identical output powers. Further investigations would show that all the test results are identical in the reports for two separate products. This could be flagged as a faked test report! At the very, very least, I suspect it would be called in for audit testing. So, I would say that if you do want to use your old WiFi test results for your new product, then you should not just "include the results and forget about it". Instead, you will need to provide very clear and thorough explanations/justifications to your TCB, for upload to the FCC website. You may need to do some partial testing to justify it. The FCC's modular approvals (and limited modular approvals) process exists to allow this sort of "data re-use". Certification of a design within a device, to be copied by other devices, is not a permitted route. If in doubt, I would recommend a re-test. Michael. Michael Derby Regulatory Engineer ACB Europe From: Grasso, Charles [mailto:charles.gra...@echostar.com] Sent: 30 August 2013 17:20 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Using existing WiFi FCC data for new FCCID - Yes or No? Hello, Given: A product that has a front panel and a main board. The front panel (along with USB and other electronics) also includes the WiFI circuitry and antenna connectors. The main board also integrates (on board) a RF4CE radio for remote functionality. Scenario: As the result of a cost reduction effort, the main board has been redesigned and a new cheaper RF4CE radio circuit included - however there are *NO* changes to the front panel. Of course the RF4CE radio will be tested to ensure compliance to FCC regulations, however as the WiFi radio has not changed - there is a desire NOT to repeat the extensive WiFi testing that has already been previously done. A query was made to a TCB as to whether the previous WiFi data could be used in addition with the new RF4CE data to apply for a new FCCID. Question: Does anyone know why this approach would not be acceptable?? Best Regards Charles Grasso Compliance Engineer Echostar Communications (w) 303-706-5467 (c) 303-204-2974 (t) 3032042...@vtext.com (e) charles.gra...@echostar.com (e2) chasgra...@gmail.com - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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://www.ieee-pses.org/list.html (including how to unsubscribe) 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>
