Under the latest Part 68 Rules, I believe you no longer submit an application to the FCC for Part 68 registration. This initial registration process is now handled in the private sector by Technical Conformance Bodies, or TCB's, that have been approved for that purpose. The manufacturer can do his own six month continuing compliance testing.
The next revision of the Part 68 Rules further de-regulates the approval process and allows for a manufacturer's self-certification, provided the manufacturer tests his product to the appropriate technical standards -- similar to the present verification process for Part 15. The details and logistics of this next step in the de-regulation process are not yet worked out. Jim Hulbert [email protected] on 01/18/2001 03:56:52 PM Please respond to [email protected] To: [email protected], [email protected] cc: (bcc: Jim Hulbert/MSD/US/PBI) Subject: Re: FCC Part 68 Continuing Compliance In a message dated 1/17/01, Courtland Thomas write: > I have a question concerning coninuing compliance for Part 68. I believe > that we are required to submit units for testing every six months. If the > FCC audits and finds that the test reports aren't up to date, then there can > be problems. This testing costs around $1500.00 for our ITE products. This > becomes a very expensive process. Is there anything that can be done to > eliminate this cost. I would like to test the units in house and log the > results and use that info as my continuing compliance data. Any thoughts on > this? > Hi Courtland: To the best of my knowledge, there is no reason why you can't do the continuing compliance testing yourself. In fact, you can even do the initial testing yourself if you are equipped to do so. For the initial testing you would have to submit a written report to the FCC, but there is no filing requirement for continuing compliance. You simply have to keep the test data on file. If you have a lot of different products in production, the economics favor in-house testing. A few years ago one of my clients who had about 30 different products decided to do their continuing compliance testing in-house. They figured the savings of at least $60,000 per year would easily justify the cost of the test equipment and a part time technician. They purchased the FCC Part 68 test equipment from Compliance Design, but never actually used it. I guess they just got too busy with other priorities to set up the in-house capability. Recently they told me they would like to unload the equipment, so if you are interested I will put you in touch with them. I wouldn't necessarily recommend the Compliance Design equipment for a new purchase, but if the price is right on the used equipment, it might be an attractive option. Joe Randolph Telecom Design Consultant Randolph Telecom, Inc. 781-721-2848 http://www.randolph-telecom.comIn a message dated 1/17/01, Courtland Thomas write:
I have a question concerning coninuing compliance for Part 68. I believe
that we are required to submit units for testing every six months. If the
FCC audits and finds that the test reports aren't up to date, then there can
be problems. This testing costs around $1500.00 for our ITE products. This
becomes a very expensive process. Is there anything that can be done to
eliminate this cost. I would like to test the units in house and log the
results and use that info as my continuing compliance data. Any thoughts on
this?
Hi Courtland:
To the best of my knowledge, there is no reason why you can't do the
continuing compliance testing yourself. In fact, you can even do the initial
testing yourself if you are equipped to do so. For the initial testing you
would have to submit a written report to the FCC, but there is no filing
requirement for continuing compliance. You simply have to keep the test data
on file. If you have a lot of different products in production, the
economics favor in-house testing.
A few years ago one of my clients who had about 30 different products decided
to do their continuing compliance testing in-house. They figured the savings
of at least $60,000 per year would easily justify the cost of the test
equipment and a part time technician. They purchased the FCC Part 68 test
equipment from Compliance Design, but never actually used it. I guess they
just got too busy with other priorities to set up the in-house capability.
Recently they told me they would like to unload the equipment, so if you are
interested I will put you in touch with them. I wouldn't necessarily
recommend the Compliance Design equipment for a new purchase, but if the
price is right on the used equipment, it might be an attractive option.
Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848
http://www.randolph-telecom.com
