Roger That is true, but if your company sells other components that could be used in the 'good system' then you must use your own products.
The assumption is that your sales personnel will not sell a competitors printer (etc) in place of your own, therefore for the system test to be valid any of the required peripherals (or PC components) that your company makes must be used in the 'good system to support your EUT. John Mowbray > -----Original Message----- > From: [email protected] [SMTP:[email protected]] > Sent: Thursday, September 03, 1998 5:49 PM > To: [email protected]; [email protected]; > [email protected]; Gary McInturff > Cc: [email protected] > Subject: Re[2]: Peripherals > > > I heard from the test lab that you can use a "good system" as your > peripherals to test your EUT rather than test it with a "worst > system" > to obtain worst case for CE and FCC compliance, is that right? As I > know for CE and FCC, they only require a "typical system", so you can > > choose your "favorite system". Any comments? > > Regards, > Roger Hsu > > > ______________________________ Reply Separator > _________________________________ > Subject: RE: Peripherals > Author: Gary McInturff <[email protected]> at Internet > Date: 9/2/98 10:09 AM > > > Dan, > Thank you very much for providing the paragraphs. I happen to be > away from my office and can't get to these documents handily. I follow > your logic on the DoC equipment modifications thread but (theirs always > a but(t)). We are now discussing interpretation and intent. I think that > the FEDS are allowing for a change in the field during test time. The > assumption is that you make a change that will be manufacturable. In > fact I always re-test to insure this is true, particularly if it is a > mechanical rather than component value change. As a manufacturing of the > actual EUT I have control over the production of the test item. I don't > have that luxury with other vendors equipment. They could change it, but > let's face it they are more likely to tell you that the only people they > have a problem with is when your equipment, and do nothing. So in this > case documenting the change doesn't really solve the problem unless you > were to modify each peripheral as well. > I guess I should point out that I don't have a huge problem. On > occasion I have some troubles with somebody else's stuff and I have no > reason to believe it to be anything other than the single sample I > happen to be looking at. Its more that I don't have the time in the > schedule, or the nature to mess around during tests. I look for rock > solid peripherals and won't use one unless I first check it out and am > satisfied that it not only meets the limits but provides some margin to > those limits. > Thanks again Dan. > Gary > > > -----Original Message----- > From: [email protected] > [SMTP:[email protected]] > Sent: Tuesday, September 01, 1998 12:52 PM > To: [email protected]; [email protected] > Cc: [email protected] > Subject: Re: Peripherals > > 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) > > MIME-Version: 1.0 > > Content-Transfer-Encoding: 8bit > > X-Resent-To: Multiple Recipients <[email protected]> > > X-Listname: emc-pstc > > X-Info: Help requests to [email protected] > > X-Info: [Un]Subscribe requests to > [email protected] > > X-Moderator-Address: [email protected] > > > > 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] > > > > > > --------- > > 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). > > > > --------- > 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). 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