Basic Guide to FCC Compliance

by: Dennis P. Rollinger
    Chief Executive Officer of Radiometrics Midwest Corporation

The FCC Regulations:

Since 1934, the FCC has had the authority to regulate the electromagnetic
emissions from electronic devices. A Notice of Proposed Rule Making
(Docket 20780) was issued in 1976. This Docket introduced Part 15,
Sub-Part J for control of unintentional emissions. There was a period of
time for manufacturers of computer devices to sell existing systems and
design new compliant systems. Since October 1, 1983 all computer devices
are required to be compliant with the Rules and Regulations. These
Regulations can be found in the Code of Federal Regulations, Title 47
Parts 2 and 15. They are available through the Superintendent of
Documents, Government Printing Office, Washington, D.C. 20402 telephone
(202) 783-3238.

A "digital device" as defined by the FCC is any device that generates and
uses timing signals greater than 9 kHz using digital techniques. There are
some exemptions for equipment. Medical devices, Industrial Process
Controllers, and Scientific instruments are exempt. Subassemblies like
internal power supplies and Hard Drive Controllers that do not connect to
Drives outside the computer housing are exempt. Generally, all other
computers and peripherals are required to be compliant with the
regulations.

Computers and peripheral devices fall into two categories. They are either
a Class A or a Class B device. A Class A device is "a digital device that
is marketed for use in a commercial, industrial or business environment,
exclusive of a device that is marketed for use by the general public or
intended to be used in the home." A Class B device is "a digital device
that is marketed for use in a residential environment notwithstanding use
in commercial, business and industrial environments."

The FCC encourages responsible manufacturers of commercial, industrial or
business product to comply with the Class B requirements if possible. They
note that "In the event that a particular type of device has been found to
repeatedly cause harmful interference to radio communications, the
Commission may classify such a digital device as a Class B digital device,
regardless of its intended use."

A Class A device must be Verified to be compliant. A Class B device must be
Certified by the Commission. Initiation of marketing of any digital device
is prohibited before Verification or Certification. The advertisement or
display of a device will not be considered an offer for sale if the
advertisement contains and the display is accompanied by the following
conspicuous notice:

  This device has not been approved by the
  Commission.  This device is not, and may not be,
  offered for sale or lease, or sold or leased
  until the approval of the FCC has been obtained.

Penalties:

Compliance with the regulations is a Federal Law. The FCC has several
methods of "administrative remedies" available to them. A company that is
marketing a noncompliant piece of equipment will first be issued a
"Marketing Citation." This tells to the company that the FCC has found the
company violating the marketing regulations. It may be accompanied by a
"Notice of Forfeiture" that is a fine not to exceed $10,000.00 per day for
each violation.

A request for a sample of the product in question may be made by the
Commission. If the sample is violating the regulations a "Notice of
Apparent Liability" will be issued. It will be accompanied by a fine not
to exceed $75,000.00 per day per violation.

These sanctions may be imposed on "Any person who is determined by the
Commission to have willfully or repeatedly failed to comply with any rule,
regulation or order issued by the Commission." The regulation reads "any
person." Not only the manufacturers but their distributors, designers,
sales people or even the end user may be held liable.

In the extreme case the Justice Department may be brought in to levy
"Judicial Remedies". Any person found guilty of willful violation may be
facing imprisonment for a term not to exceed one year and a monetary fine
not to exceed $100,000.00 per violation. The FCC can and will seize all
equipment and facilities owned by the companies guilty of repeated
offenses.

Complying with the Regulations:

Compliance with the regulations can be simple. The cost of compliance can
be controlled by good engineering and early involvement of a competent EMI
laboratory. It always costs more to fix a problem after the development
cycle is complete. Start testing as soon as possible.

The tests required for verification and certification are rather straight
forward. A series of emissions measurements are made to determine the
level of Conducted Emissions and Radiated Emissions from the Equipment
Under Test (EUT). Conducted emissions are the emissions found on the power
cords attached to the EUT. They would be the source of interference that
would be found on the AC power lines attached to the same branch circuit
as the device. These emissions are determined by connecting a receiver or
spectrum analyzer to a Line Impedance Stabilization Network (LISN). The
LISN stabilizes the power to the EUT and provides a proper RF connection
for the analyzer.

The Radiated Emissions test is conducted by connecting a antenna to the
receiver or spectrum analyzer. The frequency spectrum is scanned on a Open
Area Test Site (OATS). This is done to provide reliable, traceable data
under controlled conditions. The emissions must be maximized by rotating
the EUT, raising and lowering the antenna, and by varying the position of
the EUT's cables. These tests typically help reduce interference to
licensed broadcast.

Class A Verification:

A Class A verification can be obtained by having the computer system tested
using FCC accepted techniques. The site used for the testing should meet
the requirement established by the FCC for Open Area Test Sites (OATS).
The data must be traceable to the National Institute of Standards and
Technology (NIST). A report of compliance should be written and kept
available for the FCC if requested. A formal submittal to the FCC is not
required for Class A devices. Systems compliant with the specifications
are required to have a label in a conspicuous location stating the
following:

  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 that may cause undesired
  operation.

In addition to the above label the following information must be placed in
a prominent location in the text of the manual.

  This equipment has been found to comply with the
  limits for a Class A digital device, pursuant to
  Part 15 of the FCC Rules. These limits are
  designed to provide reasonable protection
  against harmful interference when the equipment
  is operated in a commercial environment. This
  equipment generates, uses, and can radiate radio
  frequency energy and, if not installed and used
  in accordance with the instruction manual, may
  cause harmful interference to radio
  communications. Operation of this equipment in a
  residential area is likely to cause harmful
  interference in which case the user will be
  required to correct the interference at his own
  expense.

Class B Certification:

The Certification of a Class B device is somewhat more involved. The data
traceability requirements for Class B devices are the same as for Class A
devices. The test site used for Certifications is also similar to the site
used for verification with the exception that the site must have a ground
plane. The test procedures are the same as for Class A devices but the
limits are considerably tighter.

Grantee Code:

Before submitting a product for Certification the manufacturer must be
assigned a "Grantee Code." This code can be obtained by requesting it from
the FCC. A letter requesting the code should be attached to the "FCC
Remittance Advice" form number 159. Send it with $45.00 to:

  Federal Communications Commission
  Equipment Approval Services
  P.O. Box 358315
  Pittsburgh, PA 15251-3315

Remember to include the fee type code EAG in the 159 form. The three letter
code received from the FCC will become the first three letters in your FCC
ID number.

Submittal for Certification:

A FCC "Application for Equipment Authorization" form 731 is required with
the submission for Certification. It comes with a list of instructions for
completing the form. Send it, $845.00, and the following information to
the FCC Equipment Approval Service as above. This time use the Fee Code
"EGC" on the form to show that this submittal is for Certification.

1.  Detailed report of measurements. Data must be traceable to the
    NIST. A description of Open Area Test Site and a description of
    the test method used for testing is required.
2.  Block diagram or circuit diagrams of the system.
3.  A narrative describing how the device operates.
4.  The instruction manual furnished to the purchaser.
5.  Photographs showing the general appearance and component layout
    of the equipment. Photos are preferred to be 8x10.  Show both
    sides of all circuit boards.
6.  An engineering drawing or photograph of the proposed equipment
    identification nameplate.

The labeling must be according to section 2.1045 and 15.19 of the CFR. The
label must include the Grantee Code and a Equipment Product Code. The
Equipment Product Code is determined by the applicant and must not be
longer than 14 character. The label including a compliance statement
should look like the following:

      FCC ID: XXX12345

  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.

 Note: XXX=Grantee Code and 12345=Equipment Product Code

The user manual must include the information listed in CFR section 15.105.
It states that the user guide should include the following statement:

  Note: This equipment has been tested and found
  to comply with the limits for a Class B digital
  device, pursuant to Part 15 of the FCC Rules.
  These limits are designed to provide reasonable
  protection against harmful interference in a
  residential installation. This equipment
  generates, uses and can radiate radio frequency
  energy and, if not installed and used in
  accordance with the instructions, may cause
  harmful interference to radio communications.
  However, there is no guarantee that interference
  will not occur in a particular installation.  If
  this equipment does cause harmful interference
  to radio or television reception, which can be
  determined by turning the equipment off and on,
  the user is encouraged to try to correct the
  interference by one or more of the following
  measures:

  - Reorient or relocate the receiving antenna.

  - Increase the separation between the equipment
    and receiver.

  - Connect the equipment into an output on a
    circuit different from that to which the
    receiver is connected.

  - Consult the dealer or an experienced radio/TV
    technician for help.

When the submission package is complete remember to mail to entire package
with the above documents, the list of exhibits and the Fee Processing Form
to the following address.

  Federal Communications Commission
  Equipment Approval Service
  P.O. Box 358315
  Pittsburgh, PA 15251-5315

The FCC will answer any questions you may have about the submittal by
calling them at 301-725-1585.  This number is a direct phone number for
the FCC Sampling and Measurement Branch in Columbia Maryland. This is the
office that will certify the item or call in a sample to be tested before
certification.

The submittal package seems involved. Actually everything the FCC is asking
for should already be in place before selling your product.

Once the submittal is filed with the FCC, expect approximately a six to
eight week period to receive your Certification. Please consult the
current CFR Title 47 to make sure that there have not been any changes to
the submittal process since the publication of this guide.

Radiometrics Midwest Corporation has been performing FCC compliance testing
since 1983. Our business philosophy is simply to go beyond just testing.
If there is a problem Radiometrics is part of the solution. Our sole goal
is to have your product approved by the FCC. If there is anything that we
at Radiometrics can do to be of assistance, please contact us at
708-932-7262 or by fax 708-932-7271.

Send your product for testing to:

  Radiometrics Midwest Corporation
  55 West 22nd Street
  Lombard, IL 60148

Specialists in solving a wave of FCC compliance problems.

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