John,
I have to agree with Gary on this one. While the scanner requires some sort
of host computer and connects via SCSI port, the host need not be a
Personal Computer of the sort destined for residential use. In a former
life, my employer made scanners and recorders for the graphics arts
industry. They could operate stand-alone or connected to a computer. The
products were marketed direct or through distributors and were not intended
for residential use, but rather for businesses. That is not to say that a
person with a home office could not buy our product. But the price point of
greater than $10,000 made residential use unlikely. And we did not intend
these things for home use, nor did we market them that way. All of them
were Class A.
So, while technically the scanner could be considered a peripheral of a PC,
that does not mean it needs be Class B. Since it can operate stand-alone
(as did our products), it technically is not a peripheral of a PC. And,
since there are plenty of PC's designed for industrial use, and they are
not Class B devices, there is no reason why the scanner cannot be Class A.
If the product is not intended for residential use, and is not marketed
that way, then it can be Class A regardless of what it is or is not
connected to. If the price point helps make it unlikely for residential
use, then so much the better. And if you are really worried about going
Class A, and assuming the above points are satisfied, then put a disclaimer
in the advertising and product manual stating not for residential use.
Can't get much more clear than that.
Just my opinion.
Scott Douglas
Senior Compliance Engineer
Narad Networks
515 Groton Road
Westford, MA 01886
office: 978 589-1869
cell: 978-239-0693
[email protected]
www.naradnetworks.com
At 05:02 PM 7/26/02 -0700, John Shinn wrote:
Lets get this straight. The unit connects to a PC with a SCSI port (Do I
read Apple?).
He is not questioning the the certification status of the PC. Apparently
the computer is not
of his design or manufacture. He simply connects to a PC. Unless he
specifies that
the unit is to be only connected to a host Personnal Computer that is for
industrial /
commercial use and has a SCSI port (is there such a thing?), the scanner
will take
on the characteristics of its host (a Personnal Computer - not just a
Computer). Again,
the normal run of the mill PCs are Class B. He needs to simply look at the
host PC
and determine the its class by looking at the label (that is assuming that
the required
label is there). If the label says Class B, the scanner and host must meet
Class B.
He then has to decide whether to go the certification route via a TCB (time
and money)
or DoC (no money, no time).
If he wants to OEM a main-frame, that is another story for another day.
'Nuff said, end of story.
John Shinn, P.E.
-----Original Message-----
From: [email protected]
[mailto:[email protected]]On Behalf Of Gary McInturff
Sent: Friday, July 26, 2002 1:51 PM
To: Pierre SELVA; Forum Safety-emc
Subject: RE: FCC and Professional Scanner : Verification or
certification
Pierre,
Another way to analyze the problem is the intended use, cost, and
how you advertise the product. Below is a small excerpt from the FCC part 15
rules defining a computer.
Such computers are considered Class B digital devices. Computers
which use a standard TV receiver as a display device or meet all of the
following conditions are
considered examples of personal computers:
(1) Marketed through a retail outlet or direct mail order catalog.
(2) Notices of sale or advertisements are distributed or directed to the
general public or
hobbyist users rather than restricted to commercial users.
(3) Operates on a battery or 120 volt electric al supply.
Basically the converse of the above takes you out of the computer
category.
(1) Not sold in retail outlets - The product is bought directly from
you or through business distributors that deal with business rather than
consumers. So a national distributor that a professional photographer would
use - sorry I can't think of a French distributor
(2) You advertise in Business magazines not consumer electronic
magazines etc.
(3) This one is no help because commercial equipment often runs on
120.
(4) Don't know exactly where its at, but there is also a clause that
mentions the price being such that it is unlikely that a consumer would
purchase the thing, even if they were aware.
If your equipment meets all of those categories then you can justify
Verification. The fact that an actual computer is attached to the device is
a bit of a red herring. It might be a DoC certified device and class B, and
even though it is necessary to have one to operate the scanner its emission
classification doesn't define your product. You can always use a class B
device on a Class A system, just not the other way around.
My opinion anyway.
Gary
-----Original Message-----
From: Pierre SELVA [mailto:[email protected]]
Sent: Friday, July 26, 2002 9:49 AM
To: Forum Safety-emc
Subject: FCC and Professional Scanner : Verification or certification
Hello all,
I have to clarify a point to classify a product regarding FCC part 15 rules.
The product is a scanner used in the photographic world. It scans negatives
films and converts it to digital files.
This scanner can be used as a stand alone one, or included in a bigger
machine which makes the complete process to develop photographies.
The scanner needs a personal computer to run thru a SCSI port.
In which category falls this product : Peripheral of a PC, or other digital
device ?
The choice is fundamental to determine the authorization process :
DofC/Certification or Verification.
Thanks for your help,
Best regards,
Pierre
========================================
eLABs (emc, safety, radio - product regulations)
Pierre SELVA
18 Rue Marceau Leyssieux
38400 SAINT MARTIN D'HERES - FRANCE
Phone : 33 (0)6 76 63 02 58
Fax : 33 (0)6 61 37 87 48
e-mail : [email protected]
======================================
