[PSES] Question on FCC Part 15C Transmitter Approvals

[Scott Douglas]

We make a product that has a wireless receiver in it, 2.4 GHz band. I 
know we'll need to test  for and get FCC Part 15C Certification on this 
product (and apply FCC ID, etc.).


The supplier of our wireless receiver component also sells a "matching" 
transmitter. This transmitter is complete and self-contained and can be 
plugged into a USB port on a laptop for example. Data from the laptop is 
sent to our product via the wireless link.


This transmitter has its own FCC ID obtained by the manufacturer. 
Remember it plugs into some other product (like the laptop) and is not 
hidden. This is much like the transmitter for a wireless mouse.


Question is, do we need to get another FCC ID for this transmitter if:
1. We sell it with our product but do not alter the transmitter 
labeling in any way?
2. We sell it with our product and have the manufacturer print our 
brand name on the transmitter (but leave their FCC ID showing)?
3. We sell the transmitter separately from our product in generic 
packaging not altering the labeling on the transmitter?
4. We sell the transmitter separately but have the manufacturer 
print our brand name on the transmitter (but leave their FCC ID showing)?


This apparently does not meet the criteria for a modular approval and 
the transmitter FCC ID Grant does not have modular in it anywhere.


Can anyone make sense of this and explain please?

Your wisdom is much appreciated.

Scott Douglas

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Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

[John Woodgate]

In message 
<3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net>, 
dated Thu, 21 Mar 2013, Charlie Blackham  
writes:




My point is that you were, perhaps inadvertently, citing a section 
talking about antennas as guidance for how to deal with Product A and 
Product B scenario.


OK, now I understand. In my opinion, the *general* statement:

Where a radio system is integrated on site - as in the case of microwave 
point-to-point and point-to-multipoint systems - the system integrators 
responsible for ensuring compliance of the system with the Directive 
when the system is brought into service.


applies precisely to the A + B1, B2, B3... case, irrespective of 
appearing in a section on antennas. Since the A and the alternative B's 
are from different manufacturers, it's most likely that they would be 
brought together and connected on site, but the same applies if they are 
brought together elsewhere by the system integrator.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

[Charlie Blackham]

John



You previously wrote:

{begin quote}



You have quoted several old messages unnecessarily, but you seem to have missed 
the most important one. Anthony Thomson wrote:



QUOTE

However... I guess it's entirely possible that any meaningful assessment 
against the R&TTED may not be possible on the separate components assuming both 
are required to implement the 'radio'. In this case, the Commission's 2009 
guide offers some very helpful advice: "Where a radio system is integrated on 
site - as in the case of microwave point-to-point and point-to-multipoint 
systems - the system integrators responsible for ensuring compliance of the 
system with the Directive when the system is brought into service."



So my opinion would be that each component of the system falls under the R&TTED 
and it is the system integrator's responsibility for compliance.

ENDQUOTE



This means that manufacturer A need only ensure that product A meets the 
relevant requirements. Responsibility for making sure that combinations of A 
with B1, B2, B3... rests with the 'system integrators' who put the products to 
work together.



{end quote]



My point is that you were, perhaps inadvertently, citing a section talking 
about antennas as guidance for how to deal with Product A and Product B 
scenario.



Regards

Charlie





-Original Message-,
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 21 March 2013 18:42
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not



In message

<3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net>,

dated Thu, 21 Mar 2013, Charlie Blackham 
mailto:char...@sulisconsultants.com>>

writes:



>

>Section 1.3.1 of the guidance document, that contains this phrase,

>discusses whether or not antennas are covered by the R&TTE Directive.



I haven't any idea of what useful point you are making, if any. I think you are 
indulging in pointless debate. If I'm wrong, please explain why you think that 
whoever puts product A together with Product B (or B1, B2, B3 etc.) to make a 
working system is not responsible for the system's conformity with the RTTED.

--

OOO - Own Opinions Only. See www.jmwa.demon.co.uk 
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John 
Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK



-



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Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

[John Woodgate]

In message 
<3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net>, 
dated Thu, 21 Mar 2013, Charlie Blackham  
writes:




Section 1.3.1 of the guidance document, that contains this phrase, 
discusses whether or not antennas are covered by the R&TTE Directive.


I haven't any idea of what useful point you are making, if any. I think 
you are indulging in pointless debate. If I'm wrong, please explain why 
you think that whoever puts product A together with Product B (or B1, 
B2, B3 etc.) to make a working system is not responsible for the 
system's conformity with the RTTED.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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 

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Re: [PSES] Summary of compliance with National Differences

Depending on the standard you are working with, you can see the list of 
National Differences, Group differences,  etc. on the IECEE.org website as 
well.  .

Go to   www.iecee.org -

Pull down on the heading "IECEE CB Scheme" and release on "CB Bulletin"

-  Select the product category and then click on the applicable 
standardscroll down to view the window that opens up...there should tabs 
for National Differences, Group Differences, and so on..each with a 
corresponding list of countries displayed below the tab.

-  To get the details however, it appears a purchase has to be made


Kaz Gawrzyjal
Dell Inc.



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Knudsen, 
Patricia
Sent: Thursday, March 21, 2013 12:34 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Summary of compliance with National Differences

Here is the list of CB Scheme members.

http://members.iecee.org/


Patty Knudsen
Product Safety Engineering
17095 Via del Campo
San Diego, CA  92127
858-485-3748

Teradata Labs
patricia.knud...@teradata.com
teradata.com
Facebook

The information contained in this message is private and confidential, is the 
property of Teradata Corporation, and is solely for the use of its intended 
recipient.  If you are not the person to whom this e-mail is addressed, or if 
it has been sent to you in error, please notify the sender immediately.  If you 
are not the intended recipient, please note that permission to use, copy, 
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Please consider the environment before printing.

From: Grace Lin [mailto:graceli...@gmail.com]
Sent: Thursday, March 21, 2013 10:16 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Summary of compliance with National Differences

Thank you very much, Joe.

I found a CB report online that included the following statement:
"Compliance with the National requirements of "(countries)" as given in CB 
Bulletin "(112A)" dated December 2006 and IECEE website dated July 2009 were 
also confirmed."

A quick visit to cbscheme.org found that CB Bulletin was 
not free to the general public.  Is there anyway that a CB report reader can 
find out a list of CB Scheme members?
On Thu, Mar 21, 2013 at 9:47 AM, Joe Randolph 
mailto:j...@randolph-telecom.com>> wrote:
Hi Grace:

I'm pretty sure that by default, a (passing) CD report on the standard report 
is interpreted as showing compliance with the requirements of all CB member 
countries that do not have additional national deviations.  The section on 
national deviations shows the list of *additional* countries that have national 
deviations that were tested in addition to the requirements that are common to 
all countries.

I can see how this could be confusing, though, since a non-safety person would 
simply like to see a list of all the countries that are covered by the report.  
The only way I can think to accomplish that is to provide the non-safety person 
with a list of all the countries that are members of the CB scheme, showing 
which ones have national deviations and which ones do not.  It may also be 
necessary to provide some explanation of what the CB scheme is and how it works.


Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848 (USA)
http://www.randolph-telecom.com






Dear Members,

Please help me understand the language under "Summary of compliance with 
National Differences" of a CB report.

Does "List of countries addressed:" refer to the country deviations evaluated?

Or, does it refer to the report covering/applying (only) to the countries 
listed?

For a non Safety expert, how to tell if a country is covered in a CB report?

Thank you very much and look forward to hearing from you.

Best regards,
Grace Lin
-


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discussion list. To post a message to the list, send your e-mail to 
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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:
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Mike Cantwell mcantw...@ieee.org

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David Heald

Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

[Charlie Blackham]

Section 1.3.1 of the guidance document, that contains this phrase, discusses 
whether or not antennas are covered by the R&TTE Directive.



Point to point systems are integrated on site with an antenna, but that antenna 
must (typically) comply with certain requirements that may include gain and 
aspects of antenna pattern. For some equipment they must use antennas that are 
covered by other Harmonised Standards. The antenna gain will also affect other 
aspects such as article 3.1a EMF compliance which is another aspect that the 
final system integrator must consider.



This particular product in question contains two separate and active parts with 
part B containing a frequency conversion and amplification stage. Correct 
consideration of the application of the R&TTE Directive to this device cannot 
be taken from a section discussing correct choice of antenna.



Regards

Charlie



-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 21 March 2013 17:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not



In message

<3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net>,

dated Thu, 21 Mar 2013, Charlie Blackham 
mailto:char...@sulisconsultants.com>>

writes:



>The sentence "Where a radio system is integrated on site — as in the

>case of microwave point-to-point and point-to-multipoint systems — the

>system integrator is responsible for ensuring compliance of the system

>with the Directive when the system is brought into service." Is in a

>section dealing with the integration of a unit with an antenna, it is

>not in the context of combining two or more boxes to form a radio

>transmitter or transceiver.



But that's exactly what it is. How A and B are connected together is surely 
site-dependent, because there is not just one possible B. And the length and 
quality of the interconnecting cables are influential.

--

OOO - Own Opinions Only. See www.jmwa.demon.co.uk 
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John 
Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK



-



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 
mailto:emc-p...@ieee.org>>



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Attachments are not permitted but the IEEE PSES Online Communities site at 
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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 mailto:emcp...@radiusnorth.net>>

Mike Cantwell mailto:mcantw...@ieee.org>>



For policy questions, send mail to:

Jim Bacher:  mailto:j.bac...@ieee.org>>

David Heald: mailto: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 


All emc-pstc postings are archived and searchable on the web at:
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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 
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Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] Summary of compliance with National Differences

[Knudsen, Patricia]

Here is the list of CB Scheme members.

http://members.iecee.org/


Patty Knudsen
Product Safety Engineering
17095 Via del Campo
San Diego, CA  92127
858-485-3748

Teradata Labs
patricia.knud...@teradata.com
teradata.com
Facebook

The information contained in this message is private and confidential, is the 
property of Teradata Corporation, and is solely for the use of its intended 
recipient.  If you are not the person to whom this e-mail is addressed, or if 
it has been sent to you in error, please notify the sender immediately.  If you 
are not the intended recipient, please note that permission to use, copy, 
disclose, alter or distribute this message, and any attachments, is expressly 
denied.
Please consider the environment before printing.

From: Grace Lin [mailto:graceli...@gmail.com]
Sent: Thursday, March 21, 2013 10:16 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Summary of compliance with National Differences

Thank you very much, Joe.

I found a CB report online that included the following statement:
"Compliance with the National requirements of "(countries)" as given in CB 
Bulletin "(112A)" dated December 2006 and IECEE website dated July 2009 were 
also confirmed."

A quick visit to cbscheme.org found that CB Bulletin was 
not free to the general public.  Is there anyway that a CB report reader can 
find out a list of CB Scheme members?
On Thu, Mar 21, 2013 at 9:47 AM, Joe Randolph 
mailto:j...@randolph-telecom.com>> wrote:
Hi Grace:

I'm pretty sure that by default, a (passing) CD report on the standard report 
is interpreted as showing compliance with the requirements of all CB member 
countries that do not have additional national deviations.  The section on 
national deviations shows the list of *additional* countries that have national 
deviations that were tested in addition to the requirements that are common to 
all countries.

I can see how this could be confusing, though, since a non-safety person would 
simply like to see a list of all the countries that are covered by the report.  
The only way I can think to accomplish that is to provide the non-safety person 
with a list of all the countries that are members of the CB scheme, showing 
which ones have national deviations and which ones do not.  It may also be 
necessary to provide some explanation of what the CB scheme is and how it works.


Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848 (USA)
http://www.randolph-telecom.com






Dear Members,

Please help me understand the language under "Summary of compliance with 
National Differences" of a CB report.

Does "List of countries addressed:" refer to the country deviations evaluated?

Or, does it refer to the report covering/applying (only) to the countries 
listed?

For a non Safety expert, how to tell if a country is covered in a CB report?

Thank you very much and look forward to hearing from you.

Best regards,
Grace Lin
-


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

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Attachments are not permitted but the IEEE PSES Online Communities site at 
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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 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
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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:
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For policy questions, send mail to:
Jim Bacher mailto:j.b

Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

[John Woodgate]

In message 
<3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net>, 
dated Thu, 21 Mar 2013, Charlie Blackham  
writes:


The sentence "Where a radio system is integrated on site — as in the 
case of microwave point-to-point and point-to-multipoint systems — 
the system integrator is responsible for ensuring compliance of the 
system with the Directive when the system is brought into service." Is 
in a section dealing with the integration of a unit with an antenna, it 
is not in the context of combining two or more boxes to form a radio 
transmitter or transceiver.


But that's exactly what it is. How A and B are connected together is 
surely site-dependent, because there is not just one possible B. And the 
length and quality of the interconnecting cables are influential.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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 

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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] Summary of compliance with National Differences

[Grace Lin]

Thank you very much, Joe.

I found a CB report online that included the following statement:
"Compliance with the National requirements of "(countries)" as given in CB
Bulletin "(112A)" dated December 2006 and IECEE website dated July 2009
were also confirmed."

A quick visit to cbscheme.org found that CB Bulletin was not free to the
general public.  Is there anyway that a CB report reader can find out a
list of CB Scheme members?

On Thu, Mar 21, 2013 at 9:47 AM, Joe Randolph wrote:

>  Hi Grace:
>
> I'm pretty sure that by default, a (passing) CD report on the standard
> report is interpreted as showing compliance with the requirements of all CB
> member countries that do not have additional national deviations.  The
> section on national deviations shows the list of *additional* countries
> that have national deviations that were tested in addition to the
> requirements that are common to all countries.
>
> I can see how this could be confusing, though, since a non-safety person
> would simply like to see a list of all the countries that are covered by
> the report.  The only way I can think to accomplish that is to provide the
> non-safety person with a list of all the countries that are members of the
> CB scheme, showing which ones have national deviations and which ones do
> not.  It may also be necessary to provide some explanation of what the CB
> scheme is and how it works.
>
>
> Joe Randolph
> Telecom Design Consultant
> Randolph Telecom, Inc.
> 781-721-2848 (USA)
> http://www.randolph-telecom.com
>
>
>
>
>
> Dear Members,
>
> Please help me understand the language under "Summary of compliance with
> National Differences" of a CB report.
>
> Does "List of countries addressed:" refer to the country deviations
> evaluated?
>
> Or, does it refer to the report covering/applying (only) to the countries
> listed?
>
> For a non Safety expert, how to tell if a country is covered in a CB
> report?
>
> Thank you very much and look forward to hearing from you.
>
> Best regards,
> Grace Lin
> -
> 
>
> 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
>
>

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Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

[Charlie Blackham]

Care must be taken when quoting from guidance documents.

The sentence "Where a radio system is integrated on site — as in the case of 
microwave point-to-point and point-to-multipoint systems — the system 
integrator is responsible for ensuring compliance of the system with the 
Directive when the system is brought into service." Is in a section dealing 
with the integration of a unit with an antenna, it is not in the context of 
combining two or more boxes to form a radio transmitter or transceiver.

I suspect that a complete answer to this issue could only be given when knowing 
more detail as to the exact application of this device

Regards
Charlie



-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 21 March 2013 08:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

In message <000b01ce2609$28d0d960$7a728c20$@no>, dated Thu, 21 Mar 2013, Amund 
Westin  writes:

>Radio tests on one combination of A+B is approximate $10.000. So doing 
>a reasonable number of combinations will be very costly. And we can run 
>into problems that is caused by Item B's, which are made from other 
>manufacturers ...

You have quoted several old messages unnecessarily, but you seem to have missed 
the most important one. Anthony Thomson wrote:

QUOTE
However… I guess it's entirely possible that any meaningful assessment against 
the R&TTED may not be possible on the separate components assuming both are 
required to implement the ‘radio’. In this case, the Commission's 2009 guide 
offers some very helpful advice: “Where a radio system is integrated on site — 
as in the case of microwave point-to-point and point-to-multipoint systems — 
the system integrators responsible for ensuring compliance of the system with 
the Directive when the system is brought into service.”

So my opinion would be that each component of the system falls under the R&TTED 
and it is the system integrator's responsibility for compliance.
ENDQUOTE

This means that manufacturer A need only ensure that product A meets the 
relevant requirements. Responsibility for making sure that combinations of A 
with B1, B2, B3... rests with the 'system integrators' who put the products to 
work together.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like 
DNA found in chicken and turkey meals John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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Re: [PSES] FCC Part 5 Experimental Services

[Bill Owsley]

A couple of references...  I get "news" from all over the place and may have 
mixed a couple of items.


http://www.incompliancemag.com/index.php?option=com_content&view=article&id=1490:fcc-proposes-changes-to-equipment-approval-process-&catid=1:latest-news&Itemid=19


http://transition.fcc.gov/Daily_Releases/Daily_Business/2013/db0215/FCC-13-19A1.pdf





>
> From: Ed Price 
>To: EMC-PSTC@LISTSERV.IEEE.ORG 
>Sent: Thursday, March 21, 2013 4:55 AM
>Subject: RE: [PSES] FCC Part 5 Experimental Services
> 
>
>Bill:
> 
>Am I reading this wrong? It looks to me like the thing was released on 31 
>January 2013, and they call it a “Report & Order”, which I thought meant they 
>were no longer “thinking” about it.
> 
>Federal Communications Commission FCC 13-15
>Before the
>Federal Communications Commission
>Washington, D.C. 20554
>In the Matter of
>Promoting Expanded Opportunities for Radio 
>Experimentation and Market Trials under Part 5 of 
>the Commission’s Rules and Streamlining Other 
>Related Rules
>2006 Biennial Review of Telecommunications 
>Regulations – Part 2 Administered by the  
>Office of Engineering and Technology (OET)
>)
>ET Docket No. 10-236
>ET Docket No. 06-155
>REPORT AND ORDER
>Adopted:  January 31, 2013 Released:  January 31, 2013
>By the Commission:  Chairman Genachowski and Commissioners McDowell, Clyburn, 
>Rosenworcel,
>    and Pai issuing separate statements.
> 
>Ed Price
>WB6WSN
>Chula Vista, CA  USA
> 
>From:Bill Owsley [mailto:wdows...@yahoo.com] 
>Sent: Tuesday, March 19, 2013 7:54 PM
>To: EMC-PSTC@LISTSERV.IEEE.ORG
>Subject: Re: [PSES] FCC Part 5 Experimental Services
> 
>and at the moment the proposal is open for comment.
>I find the requirement for accreditation to 17025 and similar for any lab, 
>such as the manufacturers lab, a bit onerous.
>And in effect, it appears  we have to get a experimental license to develop 
>our product, and then have to submit it to a 17025 qualified or accredited lab 
>for formal data and test report.  
>I suspect that there are a number independent labs and consultants represented 
>on the committee.
>(my spell check has turned off???)
> 
> 
>>
>>
>>
>>From:Ed Price 
>>To: EMC-PSTC@LISTSERV.IEEE.ORG 
>>Sent: Tuesday, March 19, 2013 7:12 PM
>>Subject: FCC Part 5 Experimental Services
>>
>>
>>
>>The USA FCC has been doing some sweeping changes in the Part 5 Experimental 
>>Radio Services. They issued Report & Order FCC-13-15 on 31 January 2013. This 
>>has ramifications for broadcasters, product developers and even compliance 
>>test labs! Among the interesting changes are:
>> 
-
>
>
>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 
>
>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 
>Mike Cantwell  
>For policy questions, send mail to:
>Jim Bacher  
>David Heald  
>
>

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Re: [PSES] Summary of compliance with National Differences

[Joe Randolph]

Hi Grace:
I'm pretty sure that by default, a (passing) CD report on the standard
report is interpreted as showing compliance with the requirements of all
CB member countries that do not have additional national
deviations.  The section on national deviations shows the list of
*additional* countries that have national deviations that were tested in
addition to the requirements that are common to all countries.
I can see how this could be confusing, though, since a non-safety person
would simply like to see a list of all the countries that are covered by
the report.  The only way I can think to accomplish that is to
provide the non-safety person with a list of all the countries that are
members of the CB scheme, showing which ones have national deviations and
which ones do not.  It may also be necessary to provide some
explanation of what the CB scheme is and how it works.  

Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848 (USA)
http://www.randolph-telecom.com


Dear Members,
 
Please help me understand the language under "Summary of compliance
with National Differences" of a CB report.
 
Does "List of countries addressed:" refer to the country
deviations evaluated?  
 
Or, does it refer to the report covering/applying (only) to the countries
listed?  
 
For a non Safety expert, how to tell if a country is covered in a CB
report?
 
Thank you very much and look forward to hearing from you.
 
Best regards,
Grace Lin
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[PSES] Summary of compliance with National Differences

[Grace Lin]

Dear Members,

Please help me understand the language under "Summary of compliance with
National Differences" of a CB report.

Does "List of countries addressed:" refer to the country deviations
evaluated?

Or, does it refer to the report covering/applying (only) to the countries
listed?

For a non Safety expert, how to tell if a country is covered in a CB report?

Thank you very much and look forward to hearing from you.

Best regards,
Grace Lin

-

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Re: [PSES] SV: [PSES] RTTE - Radio product or not

[Heckrotte, Michael]

Amund,

This approach typically includes a set of design and/or installation guidelines 
and engineering justification as needed to establish a presumption of 
conformity with the Directive for the untested combinations. The "reasonable 
number" of tests, the number of full tests, the number of partial tests, and 
the particular guidelines are case-by-case and subject to discussion with and 
approval by the NB.

Best Regards,
Mike

-Original Message-
From: Amund Westin [mailto:am...@westin-emission.no]
Sent: Thursday, March 21, 2013 12:53 AM
To: Heckrotte, Michael; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: SV: [PSES] SV: [PSES] RTTE - Radio product or not

Mike

I see that approach.
Radio tests on one combination of A+B is approximate $10.000. So doing a 
reasonable number of combinations will be very costly. And we can run into 
problems that is caused by Item B's, which are made from other manufacturers ...

But we have done a successful test on Item A + B previously. We could measured 
the IF spectra on output port (coax cable) of old Item A model, and compared it 
with similar measurements (harmonics, spurious, freq. drift, etc) on the new 
Item A model. Then should at least the input signals to Item B be in the same 
range.

#Amund






-Opprinnelig melding-
Fra: Heckrotte, Michael [mailto:michael.heckro...@ul.com]
Sendt: 20. mars 2013 17:07
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] SV: [PSES] RTTE - Radio product or not

Amund,

Regarding your second paragraph, a cost-effective approach is to develop a Test 
Plan that specifies tests on a reasonable number of combinations, submit it to 
a Notified Body for review, then get the Notified Body Expert Opinion based on 
that plan and the test results.

Best Regards,
Mike

-Original Message-
From: Amund Westin [mailto:am...@westin-emission.no]
Sent: Wednesday, March 20, 2013 1:44 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] SV: [PSES] RTTE - Radio product or not

Thanks!
I see the 'intended function'  ... Agree that Item A should be handled as a 
radio product.
But it will be hard to make compliance to radio standards since the product 
Item, A is only a part of a total radio systems. Radio parameters according to 
ETSI / EN standards will not be able to check before a complete systems (Item A 
+ B) is running. These parameters will not be able to check before the complete 
system is running.

Let me just comment that Item A is made by a single manufacturer and Item B is 
made by manufacturer B and there are many possible Item B's on the market. 
Testing out all possible configurations of Itema A + Item B is considered 
unacceptable, since it will cover 95% of configurations which never will be 
used and it would also cost a huge amount of $$.

Thanks.

#Amund




-Opprinnelig melding-
Fra: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sendt: 19. mars 2013 20:42
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] RTTE - Radio product or not

In message
<3f0347ac6ed9504191f91f07629fbb0c01540...@thhsle14mbx2.hslive.net>,
dated Tue, 19 Mar 2013, Charlie Blackham 
writes:
>
>Product B isn’t a radio without product A attached, therefore product A
>is part of a radio system and the R&TTE Directive applies.

I would tentatively agree: in CENELEC long ago, the question was (half
seriously) raised as to whether a washing machine with a  microprocessor was a 
household appliance or ITE. The answer was  that the 'intended function' is 
definitive.

I think this can be extended to products like A and B, which are not intended 
to work alone but are components of a system. The 'intended function' of the 
system is a radio, so the component parts are 'radio'.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like 
DNA found in chicken and turkey meals John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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discussion list. To post a message to the list, send your e-mail to 


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Re: [PSES] FCC Part 5 Experimental Services

[Ed Price]

Bill:

 

Am I reading this wrong? It looks to me like the thing was released on 31 
January 2013, and they call it a “Report & Order”, which I thought meant they 
were no longer “thinking” about it.

 

Federal Communications Commission FCC 13-15

Before the

Federal Communications Commission

Washington, D.C. 20554

In the Matter of

Promoting Expanded Opportunities for Radio 

Experimentation and Market Trials under Part 5 of 

the Commission’s Rules and Streamlining Other 

Related Rules

2006 Biennial Review of Telecommunications 

Regulations – Part 2 Administered by the  

Office of Engineering and Technology (OET)

)

ET Docket No. 10-236

ET Docket No. 06-155

REPORT AND ORDER

Adopted:  January 31, 2013 Released:  January 31, 2013

By the Commission:  Chairman Genachowski and Commissioners McDowell, Clyburn, 
Rosenworcel,

and Pai issuing separate statements.

 

Ed Price

WB6WSN

Chula Vista, CA  USA

 

From: Bill Owsley [mailto:wdows...@yahoo.com] 
Sent: Tuesday, March 19, 2013 7:54 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC Part 5 Experimental Services

 

and at the moment the proposal is open for comment.
I find the requirement for accreditation to 17025 and similar for any lab, such 
as the manufacturers lab, a bit onerous.
And in effect, it appears  we have to get a experimental license to develop our 
product, and then have to submit it to a 17025 qualified or accredited lab for 
formal data and test report.  
I suspect that there are a number independent labs and consultants represented 
on the committee.
(my spell check has turned off???)

 

 


  _  


From: Ed Price 
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Sent: Tuesday, March 19, 2013 7:12 PM
Subject: FCC Part 5 Experimental Services





The USA FCC has been doing some sweeping changes in the Part 5 Experimental 
Radio Services. They issued Report & Order FCC-13-15 on 31 January 2013. This 
has ramifications for broadcasters, product developers and even compliance test 
labs! Among the interesting changes are:

 


-

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discussion list. To post a message to the list, send your e-mail to 


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

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Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

[John Woodgate]

In message <000b01ce2609$28d0d960$7a728c20$@no>, dated Thu, 21 Mar 2013, 
Amund Westin  writes:


Radio tests on one combination of A+B is approximate $10.000. So doing 
a reasonable number of combinations will be very costly. And we can run 
into problems that is caused by Item B's, which are made from other 
manufacturers ...


You have quoted several old messages unnecessarily, but you seem to have 
missed the most important one. Anthony Thomson wrote:


QUOTE
However… I guess it's entirely possible that any meaningful assessment 
against the R&TTED may not be possible on the separate components 
assuming both are required to implement the ‘radio’. In this case, 
the Commission's 2009 guide offers some very helpful advice: “Where a 
radio system is integrated on site — as in the case of microwave 
point-to-point and point-to-multipoint systems — the system 
integrators responsible for ensuring compliance of the system with the 
Directive when the system is brought into service.”


So my opinion would be that each component of the system falls under the 
R&TTED and it is the system integrator's responsibility for compliance.

ENDQUOTE

This means that manufacturer A need only ensure that product A meets the 
relevant requirements. Responsibility for making sure that combinations 
of A with B1, B2, B3... rests with the 'system integrators' who put the 
products to work together.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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 

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.

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Instructions:  http://listserv.ieee.org/request/user-guide.html
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For policy questions, send mail to:
Jim Bacher:  
David Heald: 

[PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

[Amund Westin]

Mike

I see that approach. 
Radio tests on one combination of A+B is approximate $10.000. So doing a 
reasonable number of combinations will be very costly. And we can run into 
problems that is caused by Item B's, which are made from other manufacturers ...

But we have done a successful test on Item A + B previously. We could measured 
the IF spectra on output port (coax cable) of old Item A model, and compared it 
with similar measurements (harmonics, spurious, freq. drift, etc) on the new 
Item A model. Then should at least the input signals to Item B be in the same 
range.

#Amund


 



-Opprinnelig melding-
Fra: Heckrotte, Michael [mailto:michael.heckro...@ul.com] 
Sendt: 20. mars 2013 17:07
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] SV: [PSES] RTTE - Radio product or not

Amund,

Regarding your second paragraph, a cost-effective approach is to develop a Test 
Plan that specifies tests on a reasonable number of combinations, submit it to 
a Notified Body for review, then get the Notified Body Expert Opinion based on 
that plan and the test results.

Best Regards,
Mike

-Original Message-
From: Amund Westin [mailto:am...@westin-emission.no]
Sent: Wednesday, March 20, 2013 1:44 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] SV: [PSES] RTTE - Radio product or not

Thanks!
I see the 'intended function'  ... Agree that Item A should be handled as a 
radio product.
But it will be hard to make compliance to radio standards since the product 
Item, A is only a part of a total radio systems. Radio parameters according to 
ETSI / EN standards will not be able to check before a complete systems (Item A 
+ B) is running. These parameters will not be able to check before the complete 
system is running.

Let me just comment that Item A is made by a single manufacturer and Item B is 
made by manufacturer B and there are many possible Item B's on the market. 
Testing out all possible configurations of Itema A + Item B is considered 
unacceptable, since it will cover 95% of configurations which never will be 
used and it would also cost a huge amount of $$.

Thanks.

#Amund




-Opprinnelig melding-
Fra: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sendt: 19. mars 2013 20:42
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] RTTE - Radio product or not

In message
<3f0347ac6ed9504191f91f07629fbb0c01540...@thhsle14mbx2.hslive.net>,
dated Tue, 19 Mar 2013, Charlie Blackham 
writes:
>
>Product B isn’t a radio without product A attached, therefore product A 
>is part of a radio system and the R&TTE Directive applies.

I would tentatively agree: in CENELEC long ago, the question was (half
seriously) raised as to whether a washing machine with a  microprocessor was a 
household appliance or ITE. The answer was  that the 'intended function' is 
definitive.

I think this can be extended to products like A and B, which are not intended 
to work alone but are components of a system. The 'intended function' of the 
system is a radio, so the component parts are 'radio'.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like 
DNA found in chicken and turkey meals John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

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