Section 15.103(b) CFR 47 (Exempted devices) exempts "A digital device
used exclusively as an electronic control or power system" ... "in an
industrial plant" from complying with the technical requirements of
Subpart B. This means you don't have to do any testing and you do not
need to label your product. You are however
still subject to Part 15, specifically section 15.5 which requires you to
correct any interference to licensed radio transmissions that your
product causes in the field. Also, under section 15.29 you will need to
comply with any commission request to evaluate your product (extremely
unlikely, bordering on winning the lottery without betting).
The legal issues aside, you may still wish to test your products for
marketing reasons. You may find compliance with the FCC limits to be a
selling feature for your equipment. If you are meeting the European
requirements, compliance with the FCC limits should be almost automatic,
in fact the same test data can usually used to show compliance with both
the FCC and European specs. Finally, the FCC reevaluates the exemptions
on about a ten year cycle. Right now they "recommend" that your class of
products comply with the technical requirements. Someday the FCC might
extend coverage to your equipment.
Jon D. Curtis, P.E.
Director of Engineering email: j...@world.std.com
Curtis-Straus LLCphone: (508) 263-1897
409 Massachusetts Avenue fax:(508) 263-4164
Acton, MA 01720 http://world.std.com/~jdc/
USA
On Wed, 24 Apr 1996 m_sher...@delphi.com wrote:
> We're a manufacturer of industrial equipment. The equipment
> goes into what the European EMC directive would classify as a
> heavy industrial environment. We use a lot of electronics--PCs,
> PLCs, sensors, etc--in our controls that are built into this
> equipment.
>
> Question: do we have to comply with the FCC regs, Title 47 CFR
> 15, subpart A (b), as an unintentional radiator?
>
> thanks!
> Mike Sherman
> Product Safety Engineer
> FSI International
> (612) 361-8140
> m_sher...@delphi.com
>