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PICList Thread
'FCC Labeling?'
1999\07\12@141129 by Harold Hallikainen

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       I have several PIC-based products that I'm trying to figure out
FCC labeling for.  Perhaps someone on the list has figured this out.
       These are all "class A digital devices" as defined in 15.3(h) <
http://www.hallikainen.com/cgi-bin/section.pl?section=15.3 >.
       These devices are subject to "verification" as specified in
15.101(a) < www.hallikainen.com/cgi-bin/section.pl?section=15.101
>.
       15.19(a)(3) <
http://www.hallikainen.com/cgi-bin/section.pl?section=15.19 > requires
devices subject to verification that are not receivers or cable input
selectors to have the following label:

This device complies with part 15 of the FCC Rules. Operation is
subject to the following two conditions: (1) This device may not cause
harmful interference, and (2) this device must accept any interference
received, including interference that may cause undesired operation.

       This page of the rules (as shown in the PDF file) includes
graphics for labels that indicate the product is "for office or home
use."  It appears this artwork is only for products auhorized under a
"Declaration of Conformity."  Class A digital devices are not authorized
under a DOC (they are verified).

       So... it looks like the text shown above is what goes on the
product.  The second condition (this device must accept any interference
received, including interference that may cause undesired operation.)
seems inappropriate in that the device is not a receiver.  However, it
appears this must go on the device anyway.

       Comments?

Harold



Harold Hallikainen
spam_OUTharoldTakeThisOuTspamhallikainen.com
Hallikainen & Friends, Inc.
See the FCC Rules at http://hallikainen.com/FccRules and comments filed
in LPFM proceeding at http://hallikainen.com/lpfm

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1999\07\12@165522 by Barry King

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face
Harold,

Please check with your friendly local test lab, as I am going from
memory here, but I'm pretty sure that this is the way it works:

>         These are all "class A digital devices" as defined in 15.3(h)

That is, they meet the class A emissions standard.  OK.

>         These devices are subject to "verification" as specified in
> 15.101(a)
So you have to test them for emissions before they may be marketed,
like most consumer products with micros.

> requires
> devices subject to verification that are not receivers or cable input
> selectors to have the following label:

> This device complies with part 15 of the FCC Rules. Operation is
> subject to the following two conditions: (1) This device may not cause
> harmful interference, and (2) this device must accept any interference
> received, including interference that may cause undesired operation.

Yes, that's the standard (literally) wording.

> This page of the rules (as shown in the PDF file) includes
> graphics for labels that indicate the product is "for office or home
> use."
>  It appears this artwork is only for products auhorized under a
> "Declaration of Conformity."
> Class A digital devices are not authorized
> under a DOC (they are verified).
There are several sets of requirements for different types of
equipment.  There is Certification, Notification, and Verification.

"authorization" has no special meaning in this context as far as I
know.  The Declaration of Conformity is the document that declares
that the device has indeed been tested.  I think a DoC is required to
state that you met the Verification standard.

>         So... it looks like the text shown above is what goes on the
> product.  The second condition (this device must accept any interference
> received, including interference that may cause undesired operation.)
> seems inappropriate in that the device is not a receiver.
EVERY device is a receiver.  If you don't believe me, go see if you r
product works in the near field of your local broadcaster or (Even
worse) Pager transmittter.

> However, it
> appears this must go on the device anyway.

Yes.  You have to use that wording, even though it confuses even a
technical person such as yourself.  Desregarding the obvious risksof
attempting to interpret a government edict using (gasp) common sense,
here is my translation:

"This device's design was tested to make sure that the amount
radio frequency energy that it radiates is small enough that it
shouldn't cause any problem in typical residential service.

"However, if this device does turn out to interfere with an allocated
communication service, you may be required to stop using the device.
(47 CFR 15.16 10-1-1995)

"Also, this device might not work right under some circumstances
because of other allocated radio services.  If this occurs, it is NOT
the responsibility of the allocated transmitter to cease operations
to mitigate the problem."

>         Comments?
In other words, this device's operation is secondary to any allocated
communication service.

Example 1: If my computer mouse fails becuase I live next door to a
50 kW AM radio station, that's the mouse's problem and mine, not the
Chief Engineer's at the radio station.

The reality of this example is that most radio stations will try to
mitigate interference as a public service, because its good PR, and
because they are plagued with nuisance lawsuits about this kind of
problem, contrary to the intent of the regulations.  But if they
can't or won't, the Feds are NOT going to yank their license.

The more likely scenario is that my computer mouse freaks out when my
friendly licensed radio amateur next door fires up his transmitter.
The reality of this one is the same as the pros, only usually
friendlier.  But the Feds are NOT going to yank his license just
because your mouse won't work.

Example 2: If my tested and labelled PC or whatever  turns out to
screw up the Instrument Landing System at the local airport, I can be
required to stop using the PC.

The reality of this is that the Class A and Class B limits
were set to prevent this kind of nightmare.  BUT the in the final
analysis, if this occurred, you could be required to not use the PC
in that location.

Ain't this FUN!

-Barry.
------------
Barry King, KA1NLH

yup, that's MY transmitter  :)

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