John, obviously I disagree. The definitions I provided from part 15
describe a PC. Outside of that definition it might not be a PC. While a scanner
doesn't really look or act like a PC, one can apply those same definitions to
analyze whether or not any digital device, in this case a scanner, is likely to
be class A or Class B. But I don't believe that to really be the point anyway.
His question is a little more subtle and one has to find out first, where the
scanner can be used. If his is a class A system used in a class A environment,
his equipment is the controlling device - not the PC. He is not obligated to
become class B because he uses a device that is class B in a commercial
environment. The fact that outside of his application the PC might be used in a
residential area is of little concern to him. He isn't using or supporting the
PC in all of its possible uses. He is supporting the use of the PC only as it
applies to the use of his equipment when developing and dig!
itizing photographs. The determination lies in his scanner. Again a Class A
device in a Class A environment can be interconnected with either a Class A
device or A class B device. The class B device by definition meets the Class A
requirements.
Look at Ethernet routers and switches. They sit only in commercial
locations, can cost many thousands to hundreds of thousands of dollars, aren't
advertised in consumer magazines, nor are they sold in consumer outlets. They
do have ports that could be connected to a PC but they are clearly class A
devices. The fact that a class B computing device might be hooked up to it in
its industrial location doesn't require the router to all of a sudden become a
class B device - nor is it re-labeled a PC peripheral.
Contrast that with a small Ethernet hub. They share a great deal with
routers and switches. But because they sit in homes and/or industrial
locations, they only cost some tens of dollars, are sold in consumer magazines
and stores, basically all the definitions of a PC as described earlier, and as
such are likely to be found in both commercial and residential areas. So they
are required to be class B. They also have a port for one or more PC's. But
its not the fact that a PC can be hooked up that makes the determination its
the usage of the device that is being tested - in this case the hub.
So we go back to, I believe, even if it were to look like a PC its
either a PC or not a PC depending on how it meets the definitions I provided
earlier.
A very similar argument can be made for Pierre's scanner. Is it cheap,
is it sold to consumers through magazines, and is it sold in consumer outlets.
If not it simply is a digital device used in a commercial environment.
Gary
-----Original Message-----
From: John Shinn [mailto:[email protected]]
Sent: Friday, July 26, 2002 5:02 PM
To: Gary McInturff; 'Pierre SELVA'; 'Forum Safety-emc'
Subject: RE: FCC and Professional Scanner : Verification or
certification
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]
======================================
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