Hoi Jan, Dear Jan,
- Printer has to be tested against FCC class A;
- RF unit has to be tested (standalone) against part 15.225 en 15.209.
Telefication is one of the leading suppliers of worldwide radio and telecom
approvals.
Designated as European Notified Body for the EMC Directive, R&TTE Directive
and the Marine Equipment Directive.
Designated as American FCC Telecommunication Certification Body with full
scope.
Designated as CAB Canada (FCB) for certification of Radio Equipment to the
requirements of Industry Canada.
Designated as CAB Japan for the certification of Radio Equipment and
Telecommunication Terminal Equipment to the Japanese requirements.
Designated as CAB Switzerland for the certification of Radio Equipment and TTE.
Designated as CAB New Zealand and CAB Australia for the certification of TTE.
For other approvals we are your intermediary to the local authorities (our
Liaison services).
Test facilities and experienced engineers are in house available (our
Laboratory services).
Certification and audits of ISO 9000-series based quality systems (our System
Certification services).
Met vriendelijke groet,
With Kind Regards
Henry Rutjes
Manager Sales & Liaison
* Telefication bv
Edisonweg 12 A
6902 PK Zevenaar
The Netherlands
* + 31 316 583 180
* + 31 316 583 189
* + 31 651 182 400
* [email protected]
* http://www.telefication.com/
From: Jan Vercammen [mailto:[email protected]]
Sent: woensdag 10 maart 2004 15:04
To: [email protected]
Subject: question concerning FCC Subparts B/C
__________________
Hello emc-pstc list,
I have a question concerning the integration of an RF tag reader or
Short-Range-Device operating in the 13,56MHz band
in a medical printer.
In order to understand the full issue one needs complete product information.
It concerns a medical printer, that is, a printer that is is used in
hospitals, healthcare centers and
possible at residential areas. For residential areas the printer operation is
by a healthcare specialist
(e.g. radiologist that operates his own radiology business, but these cases
are limited).
The printer is not portable (weight 75kg), but it is a model.
The printer is a complex machine that provides:
- a twisted-pair LAN (Ethernet) interface
- queueing and storage for images
- image processing
- manages many sensors, DC and stepper motors and electromagnetic clutches for
film transport
- and a wirelessshort range RF system for the identification of the film type
(batch nr, film type, film processing data, ...)
The RF device operates at 13.56MHz and is a small printed circuit board (PCB)
of 11cmx7cm. The antenna is
integrated on the PCB (and is not removable). The interface to the printer is
over a RS232 interface.
The RF tag reader is mounted in the film input cassette and is positioned to
align the tag in the film pack
with the antenna of the reader. The maxiumum power of the RF device is 100mW(
and, by means of a relay, 10mW for Japan).
The RF reader is part of the printer, it is just a module.
>From a regulatory point of view we have Europ. The printer + RF device is
tested according to IEC60601-1-2:1993, class A
for emissions. The RF device is tested according to ETSI (EN) standards.
Our main focus is now on the US and we need to apply FCC rules. The code of
federal regulations part 47 part 15
subpart A (=definitions), B (=unintentional radiators) and C (=intentional
radiators).
I reference the FCC standard clause 15.3 (K), which concerns the definition of
a digital device.
It states somewhere halfway:
A radio frequency device that is specifically subject to an emanation
requirement in any other FCC Rule part
or an intentional radiator subject to subpart C of this part that contains a
digital device is not subject to the standards for
digital devices, provided the digital device is used only to enable operation
of radio frequency devicea nd the
digital device does not control additional functions or capibilities.
In this case the digital device is the printer and the main operation is that
of a printing device. The RF device is a small
internal part. The digital device (= the printer electronics) has many more
functions and control functions
besides controlling the operation of the RF device and therefor it seems to
qualify (?) as a digital device.
The RF device should be tested according to clause 15.225 of part 47 part 15
subpart C, which has details about the testing of the
radio parameters of RF devices operating in the band 13.553-15.567MHz.
The printer with the RF device should comply with emission limits of part 47
subpart B class A or B. If one follows the
classification then one can use class A.
The above, however, is my line of reasoning. It has a focus on the fact that
the printer is a commercial non-portable digital device, which
happens to include a RF device of which the radio type parameters have been
tested.
However, there is an alternative line of reasoning: by including an RF device,
which requires class B emisison limits (see clauses
15.207 & 15.209), the whole printer becomes a class B device. However, the
class B limits are for intentional radiators and not for
digital devices!
The question is simple: can we use class A emission limits for the printer +
RF tag reader? If we can not, what are the
arguments why class A can not be used?
I hope that you can help me to figure this one out.
Kind regards,
Jan Vercammen
EMC engineer
I have asked the RF device maufacturer and the maintain that the device should
be tested as
Kind regards,
Jan Vercammen
Agfa-Gevaert NV, Belgium
