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 
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