My employer manufactures industrial computers, so I have considerable experience
with this issue. Our products are all Class A.
The FCC is very rigid in their interpretation of this exemption. When they
state "used exclusively", they mean it. I've had much dialog with personnel at
the agency and they have confirmed that if a device such as a computer does
absolutely nothing but control, then the exemption applies. If it performs
control AND another application such as accumulation and distribution of data
(which they referred to as "Administrative Functions") then the exemption does
not apply. This is why "industrial computers" must typically comply - because
they are used in such a wide variety of applications.
Two years ago I appealed to the FCC for a written confirmation that a specific
industrial computer configuration was exempt. They asked that I put together my
argument and submit it to them for review. I did so - and got it. Go the
www.fcc.gov and look for OET BULLETIN NO. 62, "UNDERSTANDING THE FCC REGULATIONS
FOR COMPUTERS AND OTHER DIGITAL DEVICES". It should be somewhere under the
auspices of the Office of Engineering Technology.
Carl Newton
Xycom Automation, Inc.
From: "Dan Kinney (A)" <[email protected]> on 11/01/2000 03:41 PM
Please respond to "Dan Kinney (A)" <[email protected]>
To: [email protected]
cc: (bcc: Carl Newton/XYCOM)
Subject: FCC Part 15 exempted devices
I need help with interpretation of one paragraph in FCC Part 15. I have the
1 Oct 97 version. Paragraph 15.103 (b) says a digital device is exempted
from Part 15 if it is "used exclusively as an electronic control or power
system utilized by a public utility or in an industrial plant." One could
interpret this several ways to include:
A digital device is exempted if it is used exclusively as:
1) an electronic control
2) an electronic control utilized by a public utility only
3) an electronic control utilized in an industrial plant
The first interpretation is pretty broad and would exclude a lot of
equipment. The third interpretation is broad but causes the manufacturer of
control equipment to somehow make certain his products do not end up in use
anywhere except in an industrial plant. The second interpretation is narrow
and might be the real intent of this exemption.
I would appreciate any advice on how any of you would interpret this.
Thanks in advance.
Dan Kinney
Horner APG
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