>-----Original Message-----
>From: Tom Cokenias [mailto:[email protected]]
>Sent: Friday, March 12, 2004 9:19 PM
>To: [email protected]; [email protected]
>Cc: T.Sato; [email protected]; [email protected];
>[email protected]
>Subject: Re: Who is responsible for the conducted noise injected into
>A.C mains
>
>
>
>It would depend a lot on how the product marketed.  Are the two 
>devices sold separately or together?  Are they integrated into a 
>single system? If so who is the integrator?
>
>It appears that both products would fall under FCC Part 15 in the US. 
>If the two are sold separately in the US, there is no legal 
>requirement for one party to effect a fix as both devices operate on 
>a sufferance basis, any interference problems would need to be worked 
>out amongst the players.
>
>If integrated into a system, the integrator is responsible for the 
>system's overall compliance.
>
>If they are in proximity by reason other than integrator's action, it 
>seems to me neither party would have liability from an equipment 
>authorization point of view as long as each device displayed 
>compliance with its respective requirements.  The scenario you 
>describe is similar to having a 27 MHz CB portable radio operating 
>near a computer - the 27 MHz will couple into the power lines and 
>perhaps will result in line conducted emissions that exceed the 
>limits, but it's not an equipment authorization issue.
>
>- or so it seems to me.
>
>
>best regards
>
>Tom Cokenias


Maybe I'm missing something obvious, but it seems to me that the real
question is one of exempted conducted emissions for the ISM category.
Section 18.307 places limits on the CE voltage, over the frequency range of
9 kHz through 30 MHz, but exempts the limitation for those ISM bands defined
by Section 18.301 (6.78 MHz, 13.56 MHz & 27.12 MHz).

So, an ISM device is exempt from the CE requirement at the ISM frequencies.
But, does integrating an ISM device into a larger system make the whole
system an ISM device? If the larger system was originally a Part 15 device,
does the addition of an ISM device now grant the system an exemption from
the CE limit at ISM frequencies?

Ed

Ed Price
[email protected]         WB6WSN
NARTE Certified EMC Engineer & Technician
Electromagnetic Compatibility Lab
Cubic Defense Applications
San Diego, CA  USA
858-505-2780  (Voice)
858-505-1583  (Fax)
Military & Avionics EMC Is Our Specialty


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