The 20cm "rule" in OET65 Supp C applies to operating distance from the body,
not between the transmitters.  If the 20cm rule applies, then the FCC
requires SAR whether it is a fix, mobile or portable device.

David Seabury

From: "Rachid Sehb" <[email protected]>
To: <[email protected]>; <[email protected]>
Sent: Thursday, August 14, 2003 10:32 AM
Subject: RE: FCC Human Exposure Limits


>
> Hello Richard,
>
> If the device fall into the criteria of " mobile", an RF exposure
evaluation
> would be required. Since you would have two radio collocated, by less than
> 20cm from each other in the same unit, an MPE evaluation would be
required.
> You would need to show compliance to the whole body exposure, with 2.4Ghz
on
> and 915Mhz off, and vice versa, and finally with the two units ON.
>
> Sincerely,
>
>
>
>
>
>
> -----Original Message-----
> From: [email protected] [mailto:[email protected]]
> Sent: Thursday, August 14, 2003 9:42 AM
> To: [email protected]
> Subject: FCC Human Exposure Limits
>
>
>
> Consider a handheld wireless device operating in the 915 MHz band or 2.45
> GHz band. Do I understand correctly that such a  handheld device where the
> radiating elements are expected to be at least 20 cm from the head and
torso
> of the body is considered to be a "mobile device" by the FCC, and thus it
is
> sufficient to demonstrate compliance by whole body exposure using the
> spatially averaged field?
>
> Richard Woods
> Sensormatic Electronics
> Tyco International
>
>
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