Hi, Alex - "Normally" actually means "intended use". That is a relatively complex combination of what is definitional for the device (eg. something with a keypad really will be touched by the user...) and what the user will do with it (eg. if the POS is the size of a deck of cards, it may well go into someone's pocket; it certainly won't if it is 30 cm by 25 cm!). You will soon find a definition for this term in the upcoming IEC 62209 Part 2 standard (Part 1 is in CDV, or voting, stage - these are products of IEC TC106 WG4).
In general, SAR is applicable for distances less than 20 cm from the body or body parts; MPE evaluations (measurements and/or calculations) are applicable for distances exceeding this. It gets tricky for some devices, as you indicate. For example, a laptop device with its antenna in the screen would usually be considered to fall under the 20 cm rule - but not normally if the radiating elements come closer than that, and not if the thing can radiate with the cover closed (ie be carried while transmitting). Having said all of that, there have, in the past, been inconsistencies in the treatment of devices which are in contact with the hand/wrist. From a limits perspective, both the ICNRP and IEEE limits do include the hand/feet/extremities (although the limits are less stringent than for the torso, limbs, or head). Exposure in the hand is not the same exclusion of the hand from head measurements (they have exactly opposite purposes). Note that in our experience, SAR in the hand can certainly approach the limits, and even exceed them. The "record" is still held by a device which gave a whopping 6 watts/kg in 10 g! Ultimately, you must comply with RSS 102 in Canada, FCC OET Bulletin 65, Supplement C (which is the implementation of the Part 1 and Part 2 requirements - note that an NPRM is out for comment now) in the US, the R&TTE Directive (via EN 50371 or similar - "soon" it will be 62209 Part 2), and various others for Japan, Korea, Singapore, etc. Many of these standards are in some way derived from or based on the IEEE, IEC and CENELEC work in this area. Note that all of these I will be happy to answer any direct questions with more detail offline, whether about the standards currently in play or in development, and of course about your product. Regards, Kate Kathy M. MacLean President, APREL Laboratories Chair, IEC TC106 WG4 Vice-Chair, IEEE SCC 34 -EMC-RF Safety-Antenna Design/Test-SAR/MPE-SAR/Near-Field Tools-Acoustics-HAC-Wireless- 51 Spectrum Way, Nepean, Ontario K2R 1E6 (613) 820-2730 fax (613) 820-4161 cell (613) 791-3777 Web site: http://www.aprel.com - watch for our new web site coming soon! From: Alex McNeil [mailto:[email protected]] Sent: August 12, 2003 3:39 AM To: [email protected] Subject: SAR test applicability, standards? Hi Forum, I would very much appreciate help and advice from this forum with regards to the applicability of SAR, or RF evaluation, certification requirements for products that can either be handheld or placed on a sales counter e.g. Point of Sale terminals that are used for financial transactions via credit and smart cards. These products may contain Bluetooth (2.45GHz ISM band) or GSM (900/1800MHz)technology. Advice for worldwide usage would be ideal but Europe and N. America would suffice for now. Information I have so far is that it depends on how far away from the body the product is "normally" and the power level of the RF signal? I do not know at this time what standards would apply? I look forward to your kind replies. Kind Regards Alex McNeil Principal Engineer This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: [email protected] Dave Heald: [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: [email protected] Dave Heald: [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc

