Re: [PSES] Fw: FCC/ISED file change update

[Jim Bacher, WB8VSU]

Brian, I agree that Class II permissive changes only applies to intentional 
radiators. The catch is if your device contains a Wi-Fi device, then your 
device is also a Wireless device / intentional radiator.



However as you are not modifying the Wi-Fi module there is no reason to do 
a formal filing and the SDoC is enough.



Permissive changes really just apply to the parts that affect frequency, RF 
Amplitude or modulation. Changes to Digital support parts are usually not 
considered a reason to do a formal filing.


Jim

On August 29, 2023 6:15:46 PM Brian Gregory  wrote:


Good afternoon,

I'll repeat my earlier story and give the group an update.

We have made some small changes to our product (prominently to Y-caps, and 
some beads) which unfortunately did not increase our margin vs EMC limits, 
but the product still passes FCC and ISED.  Engineering wanted to use the 
self-declaration process to document these changes, including passing test 
results w/o going through the TCB and re-file process.  The changes do 
appear to classify for what CFR 47, Part 15 § 2.1043  call a class II 
permissive change, but it's just as certain that the original FCC and ISED 
ID's are still valid as the product is roughly the same, still passes 
emission limits and made no changes to the WiFi system (same chip, 
location, antenna, and firmware).


I've been told - by (a) an engineer from a well-known EMC/TCB, and (b) an 
engineer at a local EMC test lab -  that Class II permissive change only 
applies to intentional radiators.   I can't find the legal language in Part 
15 that spells this out;  does anyone know?


Does anyone want to confirm Engineering's assertion that SDoC will suffice?

Thanks,

Colorado Brian




Please note: forwarded message attached

From: David Schaefer 
To: Brian Gregory , "EMC-PSTC@LISTSERV.IEEE.ORG" 


Subject: RE: [PSES] Necessary Lab accreditations, class 2 permissible change
Date: Thu, 10 Aug 2023 15:42:24 +



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RE: [PSES] Necessary Lab accreditations, class 2 permissible change
FromDavid Schaefer david.schae...@element.com
DateAug 10, 11:42 AM
To  Brian Gregory brian_greg...@netzero.net, EMC-PSTC@LISTSERV.IEEE.ORG



Certification activities in the USA are handled by TCBs. Most test labs 
either have a separate TCB group, or work with a specific TCB for 
approvals. You should work with a lab to determine what tests need to be 
repeated, and take the data. Based on the new data the lab can determine if 
it is a Class 1 or Class 2. For a Class 2 the TCB will do a filing with the 
FCC. For a Class 1 you just need to keep the data on hand internally to 
prove the change was investigated.










David Schaefer​


Technical Manager


Element Materials Technology


9349 W Broadway Ave


Brooklyn Park

,

MN

55445

,

United States


O +1 612 638 5136

ext. 10461


david.schae...@element.com


www.element.com







From: Brian Gregory [mailto:brian_greg...@netzero.net]
Sent: Thursday, August 10, 2023 10:01 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Necessary Lab accreditations, class 2 permissible change



CAUTION:This email originated from outside of Element Materials Technology. 
DO NOT click links or open attachments unless you recognize the sender and 
know the content is safe. Please contact IT Service Desk if you are in any 
doubt about this email.




Yes, we increased the Y-Caps to get more margin.  And we did!

So, to qualify for a Class 1 permissive change, we'd need to show before & 
after data ?




Applying for a Class 2 permissive change, means FCC will look only at the 
latest data to be sure it passes?




Colorado Brian

-- Original Message --
From: John Woodgate 
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Necessary Lab accreditations, class 2 permissible change
Date: Thu, 10 Aug 2023 00:02:42 +0100

What are you changing about the Y-caps? If it's just a new supplier and the 
caps conform to the required component standard, there is no degradation. 
Reducing he capacitance would be a degradation for EMC but not for safety.


Who determines the class is the person who has all the 

[PSES] Fw: FCC/ISED file change update

[Brian Gregory]

 Good afternoon, I'll repeat my earlier story and give the group an update. We 
have made some small changes to our product (prominently to Y-caps, and some 
beads) which unfortunately did not increase our margin vs EMC limits, but the 
product still passes FCC and ISED.  Engineering wanted to use the 
self-declaration process to document these changes, including passing test 
results w/o going through the TCB and re-file process.  The changes do appear 
to classify for what CFR 47, Part 15 § 2.1043  call a class II permissive 
change, but it's just as certain that the original FCC and ISED ID's are still 
valid as the product is roughly the same, still passes emission limits and made 
no changes to the WiFi system (same chip, location, antenna, and firmware). 
I've been told - by (a) an engineer from a well-known EMC/TCB, and (b) an 
engineer at a local EMC test lab -  that Class II permissive change only 
applies to intentional radiators.   I can't find the legal language in Part 15 
that spells this out;  does anyone know? Does anyone want to confirm 
Engineering's assertion that SDoC will suffice? Thanks,  Colorado Brian 



Please note: forwarded message attached

From: David Schaefer 
To: Brian Gregory , "EMC-PSTC@LISTSERV.IEEE.ORG" 

Subject: RE: [PSES] Necessary Lab accreditations, class 2 permissible change
Date: Thu, 10 Aug 2023 15:42:24 +


-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
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--- Begin Message ---
Certification activities in the USA are handled by TCBs. Most test labs either 
have a separate TCB group, or work with a specific TCB for approvals. You 
should work with a lab to determine what tests need to be repeated, and take 
the data. Based on the new data the lab can determine if it is a Class 1 or 
Class 2. For a Class 2 the TCB will do a filing with the FCC. For a Class 1 you 
just need to keep the data on hand internally to prove the change was 
investigated.



[cid:image439490.jpg@6431776C.1BB6A68A]
David Schaefer​
Technical Manager
Element Materials Technology
9349 W Broadway Ave
Brooklyn Park
,
MN
55445
,
United States
O +1 612 638 5136
ext. 10461
david.schae...@element.com
www.element.com
[cid:image333160.png@4AF050CB.ADA894E2]
[cid:image439401.png@6BA00905.6FD1FCB6]
[cid:image942733.png@1540D0F8.60649E36]
[cid:image077280.png@866A6847.6767A7AC]
[cid:image873315.jpg@A94560F1.CC1DFEA7]
From: Brian Gregory [mailto:brian_greg...@netzero.net]
Sent: Thursday, August 10, 2023 10:01 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Necessary Lab accreditations, class 2 permissible change


CAUTION:This email originated from outside of Element Materials Technology. DO 
NOT click links or open attachments unless you recognize the sender and know 
the content is safe. Please contact IT Service Desk if you are in any doubt 
about this email.

Yes, we increased the Y-Caps to get more margin.  And we did!
So, to qualify for a Class 1 permissive change, we'd need to show before & 
after data ?

Applying for a Class 2 permissive change, means FCC will look only at the 
latest data to be sure it passes?

Colorado Brian

-- Original Message --
From: John Woodgate mailto:j...@woodjohn.uk>>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Necessary Lab accreditations, class 2 permissible change
Date: Thu, 10 Aug 2023 00:02:42 +0100

What are you changing about the Y-caps? If it's just a new supplier and the 
caps conform to the required component standard, there is no degradation. 
Reducing he capacitance would be a degradation for EMC but not for safety.

Who determines the class is the person who has all the necessary data. The test 
house of 

[PSES] Proceedings and Papers from EMC Symposium 2023

[Chas Grasso]

Hello,

I could not attend the EMC Sy,p[osium this year and now I am on the
hunt for the papers and presentations and proceedings. Does anyone
know where I can obtain these items from?


-- 

Charles Grasso

Dish Technologies

 (c) 303-204-2974

(w) 303-706-5467

(h) 303-317-5530

(e ) charles.gra...@dish.com

(e2) chasgra...@gmail.com

-

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[PSES] DFMEA Component Selection

[Ronan Shanley]

Hi All,

We are going through a DFMEA process for an enclosure we have designed but are 
having trouble determining which components to analyze. We know we want all the 
safety rated components and likely the upstream components of those as well. 
We're unsure if we should include components related only to functionality or 
how granular we should get with the components upstream of the safety 
components. For example do we include the wire feeding the safety controller or 
what about the terminal blocks? Is anyone familiar with where the limit for 
component criticality usual falls for DFMEAs?

Best,

RONAN SHANLEY
EE

[cid:image001.png@01D9DA8C.B7D88FC0]

ALERT INNOVATION
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