Hi, everyone. Here's a problem: To get "modular approval" for an unlicensed low-power (Part 15) transmitter, so that the device can be used pre-approved in other products, the applicant must attest to compliance to eight points contained in the FCC's Public Notice DA 00-1407.
The first of those says that "the modular transmitter must have its own RF shielding." They give two reasons: "to ensure that the module does not have to rely upon the shielding provided by the device into which it is installed in order for all modular transmitter emissions to comply with Part 15 limits;" and second "to prevent coupling between the RF circuitry of the module and any wires or circuits in the device into which the module is installed. Such coupling may result in non-compliant operation." Note that the first reason references Part 15 limits, but the second one requires you to prevent coupling that "may result in non-compliant operation." There is no measurement parameter for this second rationale for shielding. We have a module that complies with the Part 15 limits, without the need for a shield. In our request to apply for modular approval, our test lab insists that the FCC will only grant it to us if we use a shield. I have argued that we don't need a shield to comply with the Part 15 limits, and to require one just to say we have one is pointless. I posited the examples of a device measuring 20 dB below Part 15 limits, without a shield, being non-compliant; while a device that barely meets the requirements with heavy shielding in place being compliant. All to no avail. Have any of you run into this situation? Will the FCC insist on a shield, regardless of measured emissions, before they grant a modular approval? Regards, Chuck Burns Manager of Compliance Cubic Transportation Systems, Inc. 5650 Kearny Mesa Road San Diego, CA 92111 Tel.: (858) 627-4562 Fax: (858) 292-9987 [email protected] 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
