You're right Ken - the module we're using is far below the radiated power limit and with the right antenna we've been told it will pass the SAR testing. But that doesn't change the fact that the FCC 20cm limitation is a requirement of using the module unless we do the SAR testing. Or at least that's what my understanding is, and what my e-mail was probing to understand better.
Jim Eichner, P.Eng. Compliance Engineering Manager Xantrex Technology Inc. phone: (604) 422-2546 fax: (604) 420-1591 e-mail: [email protected] web: www.xantrex.com Confidentiality Notice: This email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. From: [email protected] [mailto:[email protected]] On Behalf Of Ken Javor Sent: Friday, April 28, 2006 1:45 PM To: [email protected] Subject: Re: Embedding WiFi into a non-radio product - FCC 20cm rule A quick back-of-the-envelope calculation assuming dipole radiation pattern shows you need 3 W XMIT power to get 1 mW/cm^2 at 20 cm. Surely this thing radiates nowhere near that much power? > From: "Jim Eichner" <[email protected]> > Date: Fri, 28 Apr 2006 13:24:32 -0700 > To: <[email protected]> > Subject: Embedding WiFi into a non-radio product - FCC 20cm rule > > We are looking at embedding an 802.11 transmitter into a product. The > transmitter has an FCC limited modular approval and one stipulation of > that approval is that steps must be taken to ensure the user cannot > come within 20cm of the antenna. I am being told that the 20cm is > measured from any part of the user's body and that this is a firm requirement. >> From what I can tell, most (all?) modular approvals have this > limitation. > > For an end-product that will find use in homes, business, and > industrial locations, ensuring this separation seems difficult if not impossible. > The product is intended for wall mounting, and even at the very top of > a wall or on the ceiling in a house tall people will be able to reach > to within 20cm of the product. Are we really expected to restrict the > installation such that it is not physically possible for someone to > come within 20cm of the antenna?!? > > This isn't a laptop computer or a cell phone - nobody has any reason > to be holding onto it, holding it against their head, or even be > looking at its LED's for more than a few seconds. It seems to me to > be overkill that it can't just sit on the wall like a thermostat for > your furnace or the control panel for your home alarm. Maybe I > wouldn't want it mounted on the wall right above the head of my > daughter's crib, but surely there's a common sense compromise that is compliant? > > If not, is our only way out of this to do expensive SAR testing and > prove that the 1mW/cm2 limit is met? > > Does anyone know if Zigbee also has this 20cm limitation? > > Thanks in advance, > Jim Eichner, P.Eng. > Compliance Engineering Manager > Xantrex Technology Inc. > e-mail: [email protected] > web: www.xantrex.com > Any opinions expressed are those of my invisible friend. > Confidentiality Notice: This email message, including any attachments, > is for the sole use of the intended recipient(s) and may contain > confidential and privileged information. Any unauthorized review, use, > disclosure or distribution is prohibited. If you are not the intended > recipient, please contact the sender by reply e-mail and destroy all > copies of the original message. > > - > ---------------------------------------------------------------- > This message is from the IEEE Product Safety Engineering Society > emc-pstc discussion list. Website: http://www.ieee-pses.org/ > > To post a message to the list, send your e-mail to [email protected] > > Instructions: http://listserv.ieee.org/request/user-guide.html > > List rules: http://www.ieee-pses.org/listrules.html > > For help, send mail to the list administrators: > > Scott Douglas [email protected] > Mike Cantwell [email protected] > > For policy questions, send mail to: > > Jim Bacher: [email protected] > David Heald: [email protected] > > All emc-pstc postings are archived and searchable on the web at: > > http://www.ieeecommunities.org/emc-pstc > - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
