Re: [PSES] Control over handheld radio and similar low-power transmitter harmonic and spurious power output, USA

2013-04-02 Thread Charlie Blackham
Ken



Don't look at 15.109 at all for intentional transmitters



UHF/VHF radios are typically part 90, so nothing to do with any section of part 
15, unless you are mains powered, when you need to do 15.207.



15.209 limits for devices covered by other parts of 15, such as 902-928 MHz 
devices covered under 15.245, 15.247 or 15.249, are only applied as specified 
in that part. And the requirement will vary depending on type of device and tx 
power and bandwidth.

· 15.245 and 15.249 require ...Emissions radiated outside of the 
specified frequency bands, except for harmonics, shall be attenuated by at 
least 50 dB below the level of the fundamental or to the general radiated 
emission limits in § 15.209, whichever is the lesser attenuation.

· 15.247 is for higher power, wideband devices, and only required 
15.209 in restricted bands as defined in 15.205, not across the band:

o   Attenuation below the general limits specified in § 15.209(a) is not 
required. In addition, radiated emissions which fall in the restricted bands, 
as defined in § 15.205(a), must also comply with the radiated emission limits 
specified in § 15.209(a) (see § 15.205(c)).



Regards

Charlie





-Original Message-
From: Ken Javor [mailto:ken.ja...@emccompliance.com]
Sent: 02 April 2013 03:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Control over handheld radio and similar low-power transmitter 
harmonic and spurious power output, USA



All,



Several people provided helpful pointers to various sections of the CFR with 
regards to the subject, but I am confused reading sections 47 CFR Parts

15.109 and 15.209. What I am looking for is a control on harmonics and spurious 
emissions from handheld transmitting devices, which can include RFID, and 
transmitters in the unlicensed 900 MHz range, and Wi-Fi, but also handheld 
radios operating at vhf and uhf, such as around 150 MHz and 400 MHz.  What I am 
seeing in the above named sections are what appear to be limits on field 
intensity in the uV/m to mV/m range with no differentiation between fundamental 
and harmonics and spurs, and while these might make sense for unlicensed bands, 
it doesn't make sense (to me at least) for a handheld radio that can transmit 
up to 5 Watts.



Can someone please clue me in?



Thank you,



Ken Javor

Phone: (256) 650-5261



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Re: [PSES] Control over handheld radio and similar low-power transmitter harmonic and spurious power output, USA

2013-04-02 Thread Ken Javor
Thanks to all who replied ­ you have been a great help!
  
Ken Javor
Phone: (256) 650-5261



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Re: [PSES] CONTAMINATION CLASS

2013-04-02 Thread John Woodgate
In message 
3d061464a0c0bb438a8712afce9013831da7f...@tor1exc01.americas.tsp.ad, 
dated Tue, 2 Apr 2013, Bolintineanu, Constantin 
cbolintine...@tycoint.com writes:


Could you please be so kind and let me know which document  provides 
the DEFINITION of  the term:  CONTAMINATION CLASS.


It is not in either Electropedia or the IEC Glossary, both of which are 
in the public area of the (new) IEC web site.




--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
Swine wave - a waveform whose spectrum is exceptionally difficult to calculate.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] India BIS/DEITY mandatory registration scheme for ITE/AV products

2013-04-02 Thread sudhakar wasnik
Hi Guys, 

By this time you may be well aware of DEITY/BIS mandatory registration scheme 
has been extended till July 3, 2013 and till Oct 3, with certain conditions.

This extended period should help manufacturer to better organize and plan for 
certification /registration.

During this time BIS is planning to discuss the report variations issues with 
the approved labs and try to close the all variability.

This is also good time to revisit the fundamental definitions like series 
classification which has a direct bearing on the # of samples to be tested and 
certfied.

There are also some critical aspects in registration application like factory 
layout , applicant , contact info etc. which will require due attention, So 
that BIS does not reject it and cause delay in accepting the application

As I mentioned previously in this e-mail , I am expert in all aspects of the 
scheme and have first hand knowledge and contact with DEITY/BIS

Please feel free to contact me offline.

 Thank you , 

Sudhakar Wasnik, MS EE, IES

Tel. 925-734-6708.




 From: sudhakar wasnik saloni95...@yahoo.com
To: EMC-PSTC Listserver emc-pstc@LISTSERV.IEEE.ORG 
Sent: Friday, March 15, 2013 4:54 AM
Subject: India BIS/DEITY mandatory  registration scheme for ITE/AV products
 

Hello Members, 

Indian has launched mandatory in country testing @ BIS approved laboratories 
and registration scheme for ITE and AV products ( Scope is limited to certain 
products) w.e.f April 3, 2013.

I am expert in this scheme  and if any body needs any kind of assistance in 
this scheme, Please contact me offline.


Regards, 

Sudhakar Wasnik MS EE, IES

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[PSES] so what does a DoC look like for a subassembly that isn't usable on its own?

2013-04-02 Thread McInturff, Gary
Does one just state there are no requirements at this level on the DoC, do they 
reference the appropriate directives for safety and EMC for the final product.
We custom design bits and pieces for end customers in EU, and we keep dancing 
around this issue both for ITE and medical devices. It might have a digital 
clock but no way to measure emissions until it's in the final enclosure. The 
end user would then do some final declarations and issue DoC's.

We make RoHS and WEEE statements but those are not currently part of our DoC 
for EU
 Just what does a DoC for a rock look like if I wanted to ship it?

Gary McInturff
Reliability/Compliance Engineer











Esterline Interface Technologies

Featuring
ADVANCED INPUT, GAMESMAN, LRE MEDICAL, and MEMTRON  products

600 W. Wilbur Avenue
Coeur d'Alene, ID  83815-9496
Toll Free: 800-444-5923 X1XXX
Tel:  (208) 635-8
Fax: (208) 635-8

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Re: [PSES] so what does a DoC look like for a subassembly that isn't usable on its own?

2013-04-02 Thread Brian Oconnell
Not much different than for end-use equipment. For my component power
supplies - simple tabulation of directives and respective standards that
were used as basis for presumption of conformity to whatever directives.
Then add paragraph for Conditions of Acceptability and intended end-use.

For last several units (more important for my stuff that is intended for PV
market), added second page for stuff that would be in addition to what is
being required by EU; for example, electric building code applicability and
environmental definitions.

Does the document perfectly reflect only the scope per ISO17050 or any
particular directive? Probably not, as the importance is to use the DoC as
another opportunity for another vehicle to reinforce certain expectations
(that would typically only be found in install instructions or spec) for a
component.

Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of McInturff,
Gary
Sent: Tuesday, April 02, 2013 1:18 PM
To: 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: so what does a DoC look like for a subassembly that isn't usable on
its own?

Does one just state there are no requirements at this level on the DoC, do
they reference the appropriate directives for safety and EMC for the final
product.
We custom design bits and pieces for end customers in EU, and we keep
dancing around this issue both for ITE and medical devices. It might have a
digital clock but no way to measure emissions until it's in the final
enclosure. The end user would then do some final declarations and issue
DoC's.
 
We make RoHS and WEEE statements but those are not currently part of our DoC
for EU
 Just what does a DoC for a rock look like if I wanted to ship it?
 
Gary McInturff
Reliability/Compliance Engineer  
 
Esterline Interface TechnologiesFeaturing 
ADVANCED INPUT, GAMESMAN, LRE MEDICAL, and MEMTRON  products
600 W. Wilbur Avenue
Coeur d'Alene, ID  83815-9496
Toll Free: 800-444-5923 X1XXX
Tel:  (208) 635-8
Fax: (208) 635-8

-

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Re: [PSES] so what does a DoC look like for a subassembly that isn't usable on its own?

2013-04-02 Thread John Woodgate
In message 
d250d01e39356a4e9cc3b4b459d6655094dc1...@ms-cda-01.advanced-input.com, 
dated Tue, 2 Apr 2013, McInturff, Gary gary.mcintu...@esterline.com 
writes:


Does one just state there are no requirements at this level on the DoC, 
do they reference the appropriate directives for safety and EMC for the 
final product.


If it's not usable on its own, it may well be something that should not 
have a CE mark and a DoC. From 1.2 of the 'EMC Guide' 2010:


1.2 Defining the scope of apparatus
The EMC Directive defines apparatus as any finished appliance, or
combination thereof made commercially available (i.e. placed on the
market) as a single functional unit, intended for the end-user, and 
liable to generate electromagnetic disturbance, or the performance of 
which is liable to be affected by such a disturbance.


1.2.1 Finished appliances
A finished appliance is any device or unit that delivers a function and
has its own enclosure.
A finished appliance is considered as apparatus in the sense of the EMC
Directive, if it is intended for the end-user and thus has to fulfil all 
the applicable provisions of the Directive.

When the finished appliance is intended exclusively for an industrial
assembly operation for incorporation into other apparatus, it is not
apparatus in the sense of the EMC Directive and consequently the EMC
Directive does not apply.

We custom design bits and pieces for end customers in EU, and we keep 
dancing around this issue both for ITE and medical devices.


End customers are presumably manufacturers, not 'end-users' as defined 
in the Directive? If not, 1.2.3 of the Guide is applicable:


1.2.3 Components/Sub-assemblies
In contrast to finished appliances, components /sub-assemblies do not, 
in general, have a proper enclosure intended for their final use.
Components/sub-assemblies are often intended to be fitted into or added 
to an apparatus in order to add an additional function.


1.2.3.1 Components/sub-assemblies within scope
Components or sub-assemblies on the market which are:
- for incorporation into an apparatus by the end-user;
- available to end-users;
are to be considered as apparatus with regard to the application of the
EMC Directive.
The instructions for use accompanying the component or sub-assembly
should include all relevant information, and should assume that
adjustments or connections can be performed by an end-user not aware of
the EMC implications.
Illustrative examples:
Plug-in cards for computers;
Programmable logic controllers;
Electric motors (except for induction motors, see section 1.1.4);
Computer disk drives;

It might have a digital clock but no way to measure emissions until 
it's in the final enclosure. The end user would then do some final 
declarations and issue DoC's.


So the 'end-user' in your terminology IS a manufacturer and NOT an 
end-user in the meaning given in the Directive.


We make RoHS and WEEE statements but those are not currently part of 
our DoC for EU

Just what does a DoC for a rock look like if I wanted to ship it?


If it's not suitable for throwing, it is benign and thus exempt.
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
They took me to a specialist burns unit - and made me learn 'To a haggis'.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] so what does a DoC look like for a subassembly that isn't usable on its own?

2013-04-02 Thread McInturff, Gary
Yes end user was a very poor choice of words, but manufacturer gets muddy as 
well. The manufacture according to the guide for Guide to the implementation of 
directives based on the New Approach and the Global Approach (The blue book) 
but having said that I should have used that term rather than end user. 
But I still don't see how the exempt status is indicated - by no accompanying 
DoC or by a note in the DoC that covers the applicable directives for the final 
product but with a note that says the subassembly is exempt from those 
standards.

It's a bit like proving - or stating at least - a negative.


3.1.1. New Approach directives
 A manufacturer, in the meaning of New Approach, is the person
who is responsible for designing and manufacturing a
product with a view to placing it on the Community market on
his own behalf.
 The manufacturer has an obligation to ensure that a product
intended to be placed on the Community market is designed
and manufactured, and its conformity assessed, to the essential
requirements in accordance with the provisions of the
applicable New Approach directives.
 The manufacturer may use finished products, ready-made
parts or components, or may subcontract these tasks. However,
he must always retain the overall control and have the
necessary competence to take the responsibility for the
product (47).

Gary


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Tuesday, April 02, 2013 2:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] so what does a DoC look like for a subassembly that isn't 
usable on its own?

In message 
d250d01e39356a4e9cc3b4b459d6655094dc1...@ms-cda-01.advanced-input.com, 
dated Tue, 2 Apr 2013, McInturff, Gary gary.mcintu...@esterline.com 
writes:

Does one just state there are no requirements at this level on the DoC, 
do they reference the appropriate directives for safety and EMC for the 
final product.

If it's not usable on its own, it may well be something that should not 
have a CE mark and a DoC. From 1.2 of the 'EMC Guide' 2010:

1.2 Defining the scope of apparatus
The EMC Directive defines apparatus as any finished appliance, or
combination thereof made commercially available (i.e. placed on the
market) as a single functional unit, intended for the end-user, and 
liable to generate electromagnetic disturbance, or the performance of 
which is liable to be affected by such a disturbance.

1.2.1 Finished appliances
A finished appliance is any device or unit that delivers a function and
has its own enclosure.
A finished appliance is considered as apparatus in the sense of the EMC
Directive, if it is intended for the end-user and thus has to fulfil all 
the applicable provisions of the Directive.
When the finished appliance is intended exclusively for an industrial
assembly operation for incorporation into other apparatus, it is not
apparatus in the sense of the EMC Directive and consequently the EMC
Directive does not apply.

We custom design bits and pieces for end customers in EU, and we keep 
dancing around this issue both for ITE and medical devices.

End customers are presumably manufacturers, not 'end-users' as defined 
in the Directive? If not, 1.2.3 of the Guide is applicable:

1.2.3 Components/Sub-assemblies
In contrast to finished appliances, components /sub-assemblies do not, 
in general, have a proper enclosure intended for their final use.
Components/sub-assemblies are often intended to be fitted into or added 
to an apparatus in order to add an additional function.

1.2.3.1 Components/sub-assemblies within scope
Components or sub-assemblies on the market which are:
- for incorporation into an apparatus by the end-user;
- available to end-users;
are to be considered as apparatus with regard to the application of the
EMC Directive.
The instructions for use accompanying the component or sub-assembly
should include all relevant information, and should assume that
adjustments or connections can be performed by an end-user not aware of
the EMC implications.
Illustrative examples:
Plug-in cards for computers;
Programmable logic controllers;
Electric motors (except for induction motors, see section 1.1.4);
Computer disk drives;

It might have a digital clock but no way to measure emissions until 
it's in the final enclosure. The end user would then do some final 
declarations and issue DoC's.

So the 'end-user' in your terminology IS a manufacturer and NOT an 
end-user in the meaning given in the Directive.

We make RoHS and WEEE statements but those are not currently part of 
our DoC for EU
 Just what does a DoC for a rock look like if I wanted to ship it?

If it's not suitable for throwing, it is benign and thus exempt.
-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
They took me to a specialist burns unit - and made me learn 'To a haggis'.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

Re: [PSES] so what does a DoC look like for a subassembly that isn't usable on its own?

2013-04-02 Thread Brian Oconnell
For EMC, Mr. Woodgate's reply is relevant, but us component mfrs will find
this guidance difficult to use. But back to the original question of a
'generic' requirement for D of C. Since RoHS is now a marking directive,
your widget no longer has a basis for bearing the CE mark. Also note that
RoHS now has a harmonized standard for all to adore, whereas REACH is not
yet a marking directive and has no harmonized standard to use as basis for
presumption of conformity.

So my answer is a non-answer. An importer of components for professional
installation cannot know what type of import enforcement would be applied by
any particular EFT state, or how any particular official would interpret the
scope of any directive.

From this side of the pond and from my experience, components for use by
other mfrs in med and ITE have two principle requirements that would be
looked at by the governmental people - the CE mark on the component and the
declaration. If the governmental person goes further, the next document
requirement would the Technical File. In fact, just recently shipped a TF on
a DVD to a wonderful governmental organization in the EFT. So you really
need to be ready with all of the new and wonderful document requirements in
accordance with the NLF stuff.

Brian

-Original Message-
From: Brian Oconnell [mailto:oconne...@tamuracorp.com]
Sent: Tuesday, April 02, 2013 2:05 PM
To: 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: RE: so what does a DoC look like for a subassembly that isn't
usable on its own?

Not much different than for end-use equipment. For my component power
supplies - simple tabulation of directives and respective standards that
were used as basis for presumption of conformity to whatever directives.
Then add paragraph for Conditions of Acceptability and intended end-use.

For last several units (more important for my stuff that is intended for PV
market), added second page for stuff that would be in addition to what is
being required by EU; for example, electric building code applicability and
environmental definitions.

Does the document perfectly reflect only the scope per ISO17050 or any
particular directive? Probably not, as the importance is to use the DoC as
another opportunity for another vehicle to reinforce certain expectations
(that would typically only be found in install instructions or spec) for a
component.

Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of McInturff,
Gary
Sent: Tuesday, April 02, 2013 1:18 PM
To: 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: so what does a DoC look like for a subassembly that isn't usable on
its own?

Does one just state there are no requirements at this level on the DoC, do
they reference the appropriate directives for safety and EMC for the final
product.
We custom design bits and pieces for end customers in EU, and we keep
dancing around this issue both for ITE and medical devices. It might have a
digital clock but no way to measure emissions until it's in the final
enclosure. The end user would then do some final declarations and issue
DoC's.
 
We make RoHS and WEEE statements but those are not currently part of our DoC
for EU
 Just what does a DoC for a rock look like if I wanted to ship it?
 
Gary McInturff
Reliability/Compliance Engineer  
 
Esterline Interface TechnologiesFeaturing 
ADVANCED INPUT, GAMESMAN, LRE MEDICAL, and MEMTRON  products
600 W. Wilbur Avenue
Coeur d'Alene, ID  83815-9496
Toll Free: 800-444-5923 X1XXX
Tel:  (208) 635-8
Fax: (208) 635-8

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
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Re: [PSES] Control over handheld radio and similar low-power transmitter harmonic and spurious power output, USA

2013-04-02 Thread Bill Owsley
5 watts is licensed.  1 watt and less is unlicensed - maybe.
handheld voice communication is limited, a lot,
In general, spurious cannot be any higher than intentional.
As long as both are below 15.209.
Note peak limits too!
and the restrictied bands of 15.205?
which incudes harmonics - in my view!
For example, if my harmonics look like my fundamental but they are in the 
restricted bands then they have to get fixed!

Dang... forgot to hit send last night!







 From: Ken Javor ken.ja...@emccompliance.com
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Sent: Monday, April 1, 2013 10:43 PM
Subject: Control over handheld radio and similar low-power transmitter 
harmonic and spurious power output, USA
 
All,

Several people provided helpful pointers to various sections of the CFR with
regards to the subject, but I am confused reading sections 47 CFR Parts
15.109 and 15.209. What I am looking for is a control on harmonics and
spurious emissions from handheld transmitting devices, which can include
RFID, and transmitters in the unlicensed 900 MHz range, and Wi-Fi, but also
handheld radios operating at vhf and uhf, such as around 150 MHz and 400
MHz.  What I am seeing in the above named sections are what appear to be
limits on field intensity in the uV/m to mV/m range with no differentiation
between fundamental and harmonics and spurs, and while these might make
sense for unlicensed bands, it doesn't make sense (to me at least) for a
handheld radio that can transmit up to 5 Watts.

Can someone please clue me in?

Thank you,
  
Ken Javor
Phone: (256) 650-5261

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Re: [PSES] so what does a DoC look like for a subassembly that isn't usable on its own?

2013-04-02 Thread ce-test, qualified testing bv - Gert Gremmen
For low voltage many components also need ce marking
to the LVD. Regardless their applicaton or target buyers.

Regards,

Ing.  Gert Gremmen, BSc



g.grem...@cetest.nl
www.cetest.nl

Kiotoweg 363
3047 BG Rotterdam
T 31(0)104152426
F 31(0)104154953

 Before printing, think about the environment. 


-Oorspronkelijk bericht-
Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens Brian Oconnell
Verzonden: Wednesday, April 03, 2013 12:49 AM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: RE: so what does a DoC look like for a subassembly that isn't usable 
on its own?

For EMC, Mr. Woodgate's reply is relevant, but us component mfrs will find this 
guidance difficult to use. But back to the original question of a 'generic' 
requirement for D of C. Since RoHS is now a marking directive, your widget no 
longer has a basis for bearing the CE mark. Also note that RoHS now has a 
harmonized standard for all to adore, whereas REACH is not yet a marking 
directive and has no harmonized standard to use as basis for presumption of 
conformity.

So my answer is a non-answer. An importer of components for professional 
installation cannot know what type of import enforcement would be applied by 
any particular EFT state, or how any particular official would interpret the 
scope of any directive.

From this side of the pond and from my experience, components for use by other 
mfrs in med and ITE have two principle requirements that would be looked at by 
the governmental people - the CE mark on the component and the declaration. If 
the governmental person goes further, the next document requirement would the 
Technical File. In fact, just recently shipped a TF on a DVD to a wonderful 
governmental organization in the EFT. So you really need to be ready with all 
of the new and wonderful document requirements in accordance with the NLF 
stuff.

Brian

-Original Message-
From: Brian Oconnell [mailto:oconne...@tamuracorp.com]
Sent: Tuesday, April 02, 2013 2:05 PM
To: 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: RE: so what does a DoC look like for a subassembly that isn't usable 
on its own?

Not much different than for end-use equipment. For my component power supplies 
- simple tabulation of directives and respective standards that were used as 
basis for presumption of conformity to whatever directives.
Then add paragraph for Conditions of Acceptability and intended end-use.

For last several units (more important for my stuff that is intended for PV 
market), added second page for stuff that would be in addition to what is being 
required by EU; for example, electric building code applicability and 
environmental definitions.

Does the document perfectly reflect only the scope per ISO17050 or any 
particular directive? Probably not, as the importance is to use the DoC as 
another opportunity for another vehicle to reinforce certain expectations (that 
would typically only be found in install instructions or spec) for a component.

Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of McInturff, Gary
Sent: Tuesday, April 02, 2013 1:18 PM
To: 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: so what does a DoC look like for a subassembly that isn't usable on 
its own?

Does one just state there are no requirements at this level on the DoC, do they 
reference the appropriate directives for safety and EMC for the final product.
We custom design bits and pieces for end customers in EU, and we keep dancing 
around this issue both for ITE and medical devices. It might have a digital 
clock but no way to measure emissions until it's in the final enclosure. The 
end user would then do some final declarations and issue DoC's.
 
We make RoHS and WEEE statements but those are not currently part of our DoC 
for EU  Just what does a DoC for a rock look like if I wanted to ship it?
 
Gary McInturff
Reliability/Compliance Engineer  
 
Esterline Interface TechnologiesFeaturing ADVANCED INPUT, GAMESMAN, LRE 
MEDICAL, and MEMTRON  products 600 W. Wilbur Avenue Coeur d'Alene, ID  
83815-9496 Toll Free: 800-444-5923 X1XXX
Tel:  (208) 635-8
Fax: (208) 635-8

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