Something supporting FCC requirement regarding the testing of peripherals can be found in ANSI C63.2-1992, 7.2.1 and 8.2.2. I have had discussions on this issue with the FCC in the past and they have referred me to these sections. Resulting test data must reflect devices that meet FCC limits.
Sections 7.2.1 covers line conducted tests. A part of section 7.2.1 reads: " When test configuration comprises multiple units that have their own individual power cords, ac powerline conducted emissions measurements shall be performed with the power cord of the particular unit under test connected to one LISN that is connected to the measuring instrument." The FCC stresses that this supports the requirement to test for line conducted all devices on the test table, including peripherals. Section 8.2.2 covers radiated emissions. A part of section 8.2.2 reads: "This method is applicable for radiated radio noise from all units, cables, powerlines and interconnecting wiring." Again, I was informed that this supports the requirement to test for radiated emissions all devices on the test table, including peripherals. You are correct in your recollection that according to FCC policy, one may not make modifications to support devices (peripherals) to bring an EUT to meet FCC limits. I have FCC certification application dismissal letters (from 1980s) to prove it. The issue of "Modifications to support equipment" was addressed in a "FCC Public Notice" some years back. I remember that I have a copy of the notice, but cannot find it at the moment to refer to the date or number. I am quite sure it is somewhere in this pile of boxes that I have in storage. I will look for it and forward it at a later date. You may also contact the FCC lab in Columbia and I am sure that they could send you a copy of the notice or write up another one. If you want something in writing from the FCC, it is better to send them a written inquiry. They will reply in written form. Bandele Rockford Engineering Services, Inc. ---------- From: Gary McInturff [SMTP:[email protected]] Sent: Monday, August 31, 1998 8:48 PM To: [email protected] Its put up or shut up time for me. I claim that CFR 47, ANSI c63.4 and/or CISPR 22 all require compliant peripherals or host systems when they are required as part of the EUT test setup but I can't find the actual paragraphs to demonstrate my point. As I understand the regulations you can make no modifications to support devices, except that which restores them to their original manufactured condition. In other words I have been known to clean mating services, retighten enclosures and shields, but no other modifications. The justification seems fairly simple to me. If you have to modify someone else's equipment there isn't a chance in hell that the manufacturer will implement it just because you say so. Equally important in this argument is that you cannot identify through test identify a non-complying signal as belonging to the support equipment rather than the EUT and then claim compliance. This concept has been stuck in my head for many years, probably dating back to t! he earliest MP-4 documents and part 15 regulations. I vaguely associate it with the sections that described peripherals to exercise equipment and what was or was not acceptable. I would appreciate some skull scratching here, but preferably can someone provide the FCC/CISPR citation on this point. I have spent an interesting amount of money testing big name devices looking for very quite support equipment. Obviously, I would prefer to win this argument but on the other hand it sure makes the search for peripherals that meet my needs a lot easier. Thanks Gary McInturff --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to [email protected] with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to [email protected], [email protected], or [email protected] (the list administrators). --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to [email protected] with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to [email protected], [email protected], or [email protected] (the list administrators).
