Doesn’t part 68 have more to do with isolation and operation than emissions? Doesn’t one have to have both parts 15 and 68?
Gary _____ From: [email protected] [mailto:[email protected]] On Behalf Of Joe Randolph Sent: Thursday, August 17, 2006 10:51 AM To: Price, Ed; [email protected] Subject: Re: FCC Part 68 On 8/16/2006, Ed Price wrote: I was asked if Part 68 testing was required on a device which incorporates a vendor-supplied modem. The modem is already Part 68 compliant, and the customer intends to only extend the Telco lines from the internal modem to their own back panel. Does the final manufacturer need to repeat the Part 68 tests, or can they rely on their vendor's compliant part? Hi Ed: This is a gray area and you can approach it with an aggressive interpretation of the rules or a conservative interpretation. The aggressive interpretation is that the modem is already FCC registered and all you need to do is apply the vendor's FCC registration label to the product. Some modem vendors advocate this approach for their modems. On the conservative side, the thing that I have never liked about this approach is that there are things that the manufacturer of the product can do to compromise the FCC compliance of the modem. Simply by incorrectly routing the phone line connections from the modem to the back panel the manufacturer can compromise the required isolation and cause the end product to be non-compliant with FCC Part 68. Or, the modem can be mounted next to a noisy DC/DC converter and pick up enough noise to fail the out of band signal power limits in FCC Part 68. These types of situations can not possibly be anticipated during the initial FCC Part 68 testing of the modem itself. So, you need to look at your particular situation and weigh the risks. Enforcement of FCC Part 68 is sadly almost non existent, so you probably won't have the FCC knocking on your door even if the end product turns out to be non compliant. To my knowledge, the only way that the FCC gets involved is if they receive a specific complaint, and even so those situations are usually limited to cases where the product is not FCC registered at all. By the way, if you do decide to pursue formal testing of the end product, you should be able to negotiate a reduced scope and reduced fee due to the fact that the modem itself is already FCC compliant. The test suite can be limited to those parameters that could conceivably be influenced by the additional wiring that the end product manufacturer has added to the modem. Joe Randolph Telecom Design Consultant Randolph Telecom, Inc. 781-721-2848 (USA) http://www.randolph-telecom.com <http://www.randolph-telecom.com/> ______________________________________________________________________ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email ______________________________________________________________________ - ---------------------------------------------------------------- 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
