On December 30, 2014, the U.S. Federal Communication Commission (FCC) issued a Report and Order in ET Docket No. 13-44, updating the Commission’s radiofrequency (RF) equipment authorization program to expand the use of FCC-recognized Telecommunications Certification Bodies (TCBs) like MET Labs as a faster and less expensive way to certify equipment. The new rules outsource the entire certification process to TCBs, in order to speed the introduction of new and innovative products to the market while ensuring that they do not cause harmful interference.
Updating Measurement Procedures
The FCC is updating equipment measurement requirements by incorporating references to ANSI C63.4-2014 and ANSI C63.10-2013 into the rules, for determining the compliance of unintentional and intentional radiators, respectively.
The new rules go into effect 30 days after publication in the Federal Register, but the FCC is providing a one year transition period for ANSI C63.4. During this transition, parties may continue to comply with either ANSI C63.4-2003, ANSI C63.4-2009 or with the new ANSI C63.4-2014. After the transition period, only compliance with ANSI C63.4-2014 will be accepted. The FCC will apply the same one-year transition period for use of the new edition of ANSI C63.10-2013.
The FCC continues to believe that there is insufficient evidence that rod antennas, artificial hands or absorber clamps produce accurate, repeatable measurements, and that short-duration emissions can produce as much nuisance to radio communications as continuous emissions. Therefore, the FCC will continue to exclude ANSI C63.4-2014 sections that allow for these methods.
The FCC also addressed the so-called “2 dB rule,” which is a method used to limit the amount of testing needed by determining the worst-case equipment configuration. ANSI C63.4-2009 included a change from ANSI C63.4-2003 that revised this procedure, but some industry stakeholders were concerned that this change would lead to substantial increases in costs. To reduce potential burdens on equipment manufacturers, the FCC will continue to accept the use of the 2 dB method in ANSI C63.4-2003 for demonstrating compliance with the requirement in Section 15.31(i), at least until the FCC adopts further revisions to the standard.
On a related matter, the FCC remains unconvinced that it should allow the use of the measurement procedures in CISPR 22 for unintentional radiators, as an alternative to the ANSI-ASC standards being incorporated into the rules at this time. The FCC also noted that the use of the ANSI C63.4-2014 standard is an improvement over the 2009 standard, in that it provides a means for the use of hybrid antennas that is appropriate and reliable for providing accurate radiated emissions measurements.
Post-Market Surveillance
The new FCC equipment authorization program also includes a new surveillance element for already-certified equipment. This is something that has been integral in other product compliance programs, like the U.S. NRTL product safety program.
Manufacturers need to maintain methods for ensuring that their equipment continues to meet the specifications certified under the new procedures. The FCC codified the guidelines currently appearing in its Knowledge Data Base (KDB) for conducting post-market surveillance, placing them into Section 2.962 of the Commission’s rules as mandatory requirements. In addition to performing post-market surveillance on devices selected by the TCB, the FCC’s Office of Engineering and Technology (OET) may select samples for the TCB to test. This is designed to prevent a manufacturer or TCB from selecting “golden samples” that may misrepresent the actual behavior of the equipment.
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