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PICList Thread
'[OT] FCC approval'
1999\04\20@094703 by Octavio Nogueira

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Let's suppose I want to assemble and sell the ProPic 2
in USA. Do I need FCC approval?

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1999\04\20@113050 by Bob Blick

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On Tue, 20 Apr 1999, Octavio Nogueira wrote:

> Let's suppose I want to assemble and sell the ProPic 2
> in USA. Do I need FCC approval?

I don't see a sticker on the PicStart Plus. I see a lot of stuff without
FCC approval. If it's not a product targeted at consumers, it appears that
very few products get FCC approval, unless it has to cross borders to get
here.

-Bob

1999\04\20@125613 by David Reinagel

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>
> Let's suppose I want to assemble and sell the ProPic 2
> in USA. Do I need FCC approval?
>
FCC "approval" is a funny business.  From my understanding of it,
everything made, sold or used in the US must meet FCC regulations.
Now suppose you sell a widget, and at some point an FCC inspector
by chance checks your widget and discovers that its emmisions
exceed the regulation -- then you are in trouble and susceptable
to fines, the equipment can't be used until it is brought into
compliance, and other nasty things.  Now if you are sure that you
equipment is in compliance (which requires a million dollars of
equipment to really be sure) then your are OK (again this is my
understanding).  Now very few companies have all the needed
equipment for this testing, so they hire an independent lab to
test the equipment.  And in my experience they ALWAYS find something
wrong with whatever it is.  I had one 16C54 driven by a 1MHz
crystal oscillator with by-pass caps on each, measuring the tach
pulses of a fan and lighting a bi-color LED Green if the fan was
above a certain speed, and "amber" if it was below that level
(can't use Red in Europe unless it means shut down building power
and start spraying the equipment with a fire extinguisher -- but
that's another story).  Well, it would not pass FCC tests without
a lot of filtering on the 5V line and removing the socket on the
PIC part (excuse me? -- how can a socket make such a big difference
on the emissions, but believe it or not, that made a big difference).
Now if you can get your sample product to pass FCC as measured by
the independent lab, you can now put on a sticker saying so, and
if one of the widgets don't pass, you point them to the report
(which in this case cost about $10,000 US) and they make the lab
recalibrate its equipment, but you are not in trouble.

The amazing thing is that we have found almost every off-brand PC
misses FCC regulations by a long mile -- I mean not even close; but
they got their sample to pass, and this gives them the right to
sell that eguipment here (I guess they 'paid' their dues to the
independent lab and are now in).  Of the PCs we tried to use for
a system component, only IBM, HP and Dell computers would on their
own pass FCC requlations before we added our board into it.

So what's the moral: read some books or attend a seminar on how to
minimize emissions in whatever you design; try to test the equipment
the best you can with sniffers and whatever else you can borrow or
use; take you chances or hire a lab to help you.  I found a lab in
the California San Francisco Bay area that was really good, helpful
and honest.  For a few hundred dollars, they would do a preliminary
'quick' scan to help you see if you had problems, at what frequency
they were at, and how far were you from meeting FCC regulations.  The
final testing with reports if everyting went swimmingly in the quick
scan was only about $2500.  E-mail me privately if you want more info
on them.

Dave Reinagel
.....daverKILLspamspam@spam@cisco.com

1999\04\20@132357 by Dave VanHorn

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> FCC "approval" is a funny business.  From my understanding of it,
> everything made, sold or used in the US must meet FCC regulations.

If it's got a clock rate (or other on-board signal) at 9kHz or greater, with
an exception for digital watches.

> Now if you are sure that you
> equipment is in compliance (which requires a million dollars of
> equipment to really be sure) then your are OK (again this is my
> understanding).

As the manufacturer, you are responsible. You can just put a sticker on it
that says it complies. If the FCC tests it, and it fails, you better look
out.  The usual path is to test a prototype that is identical to a
production unit, and then to re-test samples every time you make a
"substantive" change (your judgement as to what substantive means)

If you've tested with a lab, and haven't made any changes, then the worst
you can expect on a violation is that the FCC will demand a re-test, and
make you fix whatever shows up, and handle any units in the field. (possibly
a shield kit or cable ferrites)

If you wing it, you're on your own, and the FCC can get pretty nasty,
especially if you are intentionally violating the spec.

You can get a pretty good sense of it for about $2k, invested in a GOOD
wideband receiver.  We tried the approach with the HP spectrum analyzer, but
it turns out that although this instrument is supposedly designed for EMI
testing, it "dosen't pick up pulsed noise very well"... !($$#%!(#%&#

I use an Icom R-8500 and scan 30 MHz to 1GHz with a discone antenna at 10'
See my web page at www.cedar.net/users/dvanhorn/hamrad/index.html
"EMI a practical guide for practical people". It's a bit tongue in cheek,
but it describes a way to do your own pre-scans and save plenty money.  This
is NOT a substitute for independent testing, but it makes it a better bet
that you pass on the first try.

> Now very few companies have all the needed
> equipment for this testing, so they hire an independent lab to
> test the equipment.  And in my experience they ALWAYS find something
> wrong with whatever it is.

The only way to be sure, is to have a real lab test it. I usually get the
"Is that thing on?"
level, passing part B by about 20dB or better, with a 14 MHz micro, and
switching power supply, but I have once hit the point where I was off-scale
at 162 MHz. The Icom found that immediately. (This is how the Icom was
bought!)

They will also test for conducted noise below 30 MHz on the cables, but I've
never had anything show up there, so I have no experience to relate on that.
I always pass.

> Now if you can get your sample product to pass FCC as measured by
> the independent lab, you can now put on a sticker saying so, and
> if one of the widgets don't pass, you point them to the report
> (which in this case cost about $10,000 US) and they make the lab
> recalibrate its equipment, but you are not in trouble.

I usually pay $1k for a half-day in the chamber, or $2k for a half-day at
the open-field site.  If you're quiet in the chamber, then you pass and
that's it. If you're marginal, then you go to open-field and test again. If
you're under by at least 3dB, you pass.

> The amazing thing is that we have found almost every off-brand PC
> misses FCC regulations by a long mile -- I mean not even close; but
> they got their sample to pass, and this gives them the right to
> sell that eguipment here (I guess they 'paid' their dues to the
> independent lab and are now in).  Of the PCs we tried to use for
> a system component, only IBM, HP and Dell computers would on their
> own pass FCC requlations before we added our board into it.

The FCC is back with teeth this time. Recently Commissioner Hollingsworth
has been heard PERSONALLY tagging violators on the ham HF bands, which is
unheard of in the history of ham radio, and in the last several months,
they've been handing out big fines as well.   Non-compliant equipment can be
$10k per unit per day!

I would get it tested if I were you.

1999\04\20@132735 by Michael Shiloh

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The wise Dave Reinagel writes, in response to this question:

>>
>> Let's suppose I want to assemble and sell the ProPic 2
>> in USA. Do I need FCC approval?
>>
> <stuff cut out>
>
>So what's the moral: read some books or attend a seminar on how to
>minimize emissions in whatever you design; try to test the equipment
>the best you can with sniffers and whatever else you can borrow or
>use; take you chances or hire a lab to help you.  I found a lab in
>the California San Francisco Bay area that was really good, helpful
>and honest.  For a few hundred dollars, they would do a preliminary
>'quick' scan to help you see if you had problems, at what frequency
>they were at, and how far were you from meeting FCC regulations.  The
>final testing with reports if everyting went swimmingly in the quick
>scan was only about $2500.


One thing I would add is that a good lab will also have LOTS of experience
(much more than you or I ever will) and can be very helpful in pointing
out where the problem areas are and even suggesting solutions; they
will have a long list of materials and suppliers to help. In the long
run, they can actually save a lot more than they cost.

For real problems, they probably will have a list of consultants.

Back when I did this, we probably would not have gotten FCC certification
without the help of the lab.

How to find a good lab? Ask for recommendations in your area....

1999\04\20@204000 by Brian Gracia

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At 09:00 AM 4/20/99 , you wrote:
>Let's suppose I want to assemble and sell the ProPic 2
>in USA. Do I need FCC approval?
>

Yes.  Any electronic device sold in the US must meet FCC Rules!

Brian

1999\04\20@211332 by Bob Drzyzgula

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On Tue, Apr 20, 1999 at 07:32:47PM -0500, Brian Gracia wrote:
> At 09:00 AM 4/20/99 , you wrote:
> >Let's suppose I want to assemble and sell the ProPic 2
> >in USA. Do I need FCC approval?
> >
>
> Yes.  Any electronic device sold in the US must meet FCC Rules!
>
> Brian

This begs the question... what about products not sold?
Dave Reinagel's message from earlier suggested that
anything made, used or sold in the US needed FCC
approval. However, I was under the impression that
non-commercial products were in some manner exempt; that if
you hack a PIC project together in your basement and only
ever use it yourself that it was legal as long as it didn't
cause *actual* disruption of communications traffic. Thus,
if your PIC project is used to drive a 50,000 Watt antenna
blasting crap out from 90 to 110 MHz, you'd probably get
into a bit of trouble. But if it just screws up your own
personal TV reception, you've got yourself to blame. Now,
if your contraption was built into your home as part of
an automation or security system, and then you tried to
sell the house with that system intact, then you might be
in a bit of a fix. Similarly, I had imagined that there
was a line drawn between assembling a computer system
for your own use and doing so with the intent to sell
or otherwise transfer the system to others.

Now perhaps this is just a matter of practicality, sort of
like municipal permits. Most municipalities will require a
homeowner to get a permit before making modifications to
the electrical system in his or her home. But I'm pretty
sure that they don't try to correlate these permits to
sales of circuit breakers and romex at local home centers;
surely sales would be out of all proportion to permits. The
boom would come down, however, if you had an electrical
fire that was clearly your fault, or if you sold the house
and the inspector found wiring not meeting code.

But I wonder: Is there a line drawn in the FCC regs between
devices that are manufactured for trade (I can imagine
that as long as there was an exchange, even if it was for
free, that the rules would kick in) and devices that are
constructed for personal use? Or are tens or hundreds of
thousands of computer, radio and electronics hobbyists
simply skirting the law with impunity because anything
else simply wouldn't be practial?

Just wondering...

--Bob

--
============================================================
Bob Drzyzgula                             It's not a problem
bobspamKILLspamdrzyzgula.org                until something bad happens
============================================================

1999\04\20@220251 by kirmse

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>From FCC Part 15

¤ 15.23 Home-built devices.
(a) Equipment authorization is not required for devices that are not marketed,
are not constructed from a kit, and are built in quantities of five or
less for personal use.
(b) It is recognized that the individual builder of home-built equipment
may not possess the means to perform the measurements for determining
compliance with the regulations. In this case, the builder is expected to employ
good engineering practices to meet the specified technical standards
to the greatest extent practicable. The provisions of ¤ 15.5 apply to this equip-ment.

Bob Drzyzgula wrote:

{Quote hidden}

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| Portable System Design, High Speed Serial Links
| FPGA Design, Video Hardware, Graphics Hardware
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1999\04\20@224949 by Richard Martin

picon face
A good place to see what the .gov has to say about all this
is at:

http://www.fcc.gov/oet/info/documents/bulletins/

oet61.pdf    <~500kb> is the relevant document.
oet63.pdf    is a more abbreviated commentary incl. 'private' use

N.B. that (as best I recall) a "transmitter" is anything that can
transmit rf, intentional or not. The short answer is you can't
sell or transfer anything, but it seems VERY unclear about
e.g. a 'hobby' data link with published design but (many) 'free'
individual builders. I'd like to here anything on that (privately).

R.Martin

R.Martin

1999\04\21@013319 by Dave VanHorn

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> This begs the question... what about products not sold?

You're liable for interference, but you don't have to get part 15.
As a company, prototypes can be distributed, but they must be marked:
"PROTOTYPE NOT FOR SALE", I think you have to add some text about not being
in compliance (or at least untested) with part 15

Those prototypes have to be rounded up in the end and either certified, or
retired, or you're responsible for them.

1999\04\21@013524 by Dave VanHorn

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> N.B. that (as best I recall) a "transmitter" is anything that can
> transmit rf, intentional or not. The short answer is you can't
> sell or transfer anything, but it seems VERY unclear about
> e.g. a 'hobby' data link with published design but (many) 'free'
> individual builders. I'd like to here anything on that (privately).


Each builder would be responsible for any interference created, and for
compliance with part 15.

1999\04\21@085312 by Harrison Cooper

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I'm not sure if I would agree on this.  Any CONSUMER device running above 1
MHz (this I am not sure about), should have approval.  All the approval
means is that the device is not suppose to be radiating emissions that could
interfere with other devices...like medical devices, etc.  But, as I drive
around, my various radio gear (2M, public service, 10M, etc) that I have in
my truck, can hear leaky stuff.  Outside one office...it nails one of the
county emergency channels.

And...there are allot of commercial devices that are not approved...take my
word for it...I've seen em all the time.

*flame suit on*

-----Original Message-----
From: Brian Gracia [EraseMEbgraciaspam_OUTspamTakeThisOuTRTRIPP.COM]
Sent: Tuesday, April 20, 1999 6:33 PM
To: PICLISTspamspam_OUTMITVMA.MIT.EDU
Subject: Re: [OT] FCC approval


At 09:00 AM 4/20/99 , you wrote:
>Let's suppose I want to assemble and sell the ProPic 2
>in USA. Do I need FCC approval?
>

Yes.  Any electronic device sold in the US must meet FCC Rules!

Brian

1999\04\21@123954 by DREITEK

picon face
In a message dated 4/20/99 7:50:21 PM Pacific Daylight Time,
@spam@rmmartinKILLspamspamSERV.NET writes:

<< A good place to see what the .gov has to say about all this
is at:

http://www.fcc.gov/oet/info/documents/bulletins/

oet61.pdf    <~500kb> is the relevant document.
oet63.pdf    is a more abbreviated commentary incl. 'private' use

N.B. that (as best I recall) a "transmitter" is anything that can
transmit rf, intentional or not. The short answer is you can't
sell or transfer anything, but it seems VERY unclear about
e.g. a 'hobby' data link with published design but (many) 'free'
individual builders. I'd like to here anything on that (privately).

R.Martin

R.Martin >>


Hi All

I have a question along this topic.
Did Parralax get FCC approval for their programmer????


Dave Duley

1999\04\22@024142 by Harold Hallikainen

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       You can read the rules for yourself at http://hallikainen.com/FccRules .
Look at part 15.

Harold

On Tue, 20 Apr 1999 08:29:19 -0700 Bob Blick <KILLspambobKILLspamspamTED.NET> writes:
{Quote hidden}

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1999\04\22@104332 by mathias

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>FCC "approval" is a funny business.  From my understanding of it,
>everything made, sold or used in the US must meet FCC regulations.

.... EXCEPT for the devices that are EXEMPT.

This includes laboratory & test equipment. Look at your O-scopes, logic
analyzers, ICEs....  Most are not FCC certified.

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