All,
I believe you guys are referring to 47CFR2.1033,
Application for certification:
(8) If the equipment for which certification is being sought
must be tested with peripheral or accessory devices connected
or installed, a brief description of those peripherals or
accessories. The peripheral or accessory devices shall be
unmodified, commercially-available equipment.
See also the previous section, 47CFR2.1031:
The general provisions of this subpart [section] 2.901 et seq.
shall apply to applications for and grants of certification.
As for products only subject to a Declaration of Conformity,
there is this requirement in 47CFR2.1075a (Retention of records):
(1) A record of the original design drawings and specifications
and all changes that have been made that may affect
compliance with the requirements of [section] 2.1073.
My interpretation is that unmodified, commercially-available
support equipment are only required for FCC Certification.
For Declarations of Conformity, I would take the retention-of-records
requirements one step further. I would not modify support equipment
unless it does not disguise emissions from the EUT, and I would
justify it in the test report per 47CFR2.1075a3 (Retention of records):
(iv) A description of the equipment under test (EUT) and
support equipment connected to, or installed within, the EUT;
To be fair, one argument against my intepretation is the following
section, which explicitly requires that modifications
to the EUT (but not support equipment,) be documented:
(viii) A description of any modifications made to the EUT
by the testing company or individual to achieve compliance
with the regulations;
Please also note that the requirements of 47CFR2.1075a
(Retention of records) may not apply to equipment assembled
using modular components. See 47CFR2.1075b.
My 2 cents,
Dan
> From [email protected] Tue Sep 1 11:28:03 1998
> Date: Tue, 01 Sep 1998 08:36:09 -0400
> Subject: Re: Peripherals
> To: [email protected]
> Cc: [email protected]
> From: [email protected] (Scott Douglas)
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> Gary,
>
> I have had my problems with support equipment and peripherals also. And,
> having used a lot of big name products, mostly computers, etc., I was
> surprised at how many of them failed when my product was turned off and
> theirs was left running. It is quite common for test house guys to say "
> Oh, that's the host, we'll ignore that one". I finally got to the point
> where I put them outside the test environment, i.e. below the floor or
> outside the shield room. I do this because I don't sell them and figure
> that if I run self test mode and don't see the problem, then it is either
> the other guy's stuff or my I/O. If it is my I/O, I will fix it. If it is
> the other guy's stuff, I leave it alone. I can't / won't fix their
> non-compliant equipment, don't have either the time or money to do so. I
> did eventually find a quiet PC and monitor which I guard with my life. I
> have even coerced the software guys into making their latest stuff play
> with my older PC so I can keep using it.
>
> I can't point to the reference you are asking for. It seems to me that if
> the support / host equipment is required to be on the table during test,
> then the entire thing must comply. It can be difficult to point the finger
> at one piece and say that it is the source of the problem, especially on
> the immunity side. If you try several different pieces of support
> equipment and the "system" continues to fail, it probably is within the
> common unit, i.e. your product. If you find that changing the support
> equipment can make the "system" pass, then either you have a marginal
> product or a too-sensitive support equipment. In this case, you have a
> decision to make, and a tough one at that. Sorry I am not more help on
> this one.
>
> Regards,
> Scott
> [email protected]
>
>
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