Preventing interference is first a duty of the user, then of the seller who "knew or should have known etc" then of the manufacturer, who must not only meet Part 15's requirements -- but KEEP meeting them. A Part 15 product I helped get approved some 20 years ago at a former employer was fairly recently the subject of a Commission action, and if my guess is correct, someone probably removed a piece of copper tape we'd added to reduce its field strength. Another example might be consent agreements these past five or ten years WRT widely retailed SMPS-based car and gel-cell battery chargers.
Part 15 strongly implies a manufacturer's duty to follow up: Section 15.15 General technical requirements. (c) Parties responsible for equipment compliance should note that the limits specified in this Part will not prevent harmful interference under all circumstances. Since the operators of Part 15 devices are required to cease operation should harmful interference occur to authorized users of the radio frequency spectrum, the parties responsible for equipment compliance are encouraged to employ the minimum field strength necessary for communications, to provide greater attenuation of unwanted emissions than required by these regulations, and to advise the user as to how to resolve harmful interference problems (for example, see Section 15.105(b)). Proving harmful interference isn't hard, really, just some credible recordings and witnesses. The hard part is getting the FCC to accept a complaint and act on it. Ask ARRL's Ed Hare. Cortland KA5S > [Original Message] > From: Dennis Ward <[email protected]> > To: Cortland Richmond <[email protected]>; John Woodgate <[email protected]>; <[email protected]> > Date: 1/27/2011 12:34:09 AM > Subject: RE: dow for new standards > > Yes - but when question of interference comes about it is the FCC or the 'complaining' entity that has the burden of proof. The grantee simply says, this is what is certified, the reports are all on the FCC site, prove my product causes a problem. Only when the certified product has been proven not to meet the limits it is certified to does the FCC take action. > > Dennis Ward > > Director of Engineering > American Certification Body > Certification Resource for the Wireless Industry http://www.acbcert.com > 703-847-4700 fax 703-847-6888 > direct - 703-880-4841 > > -----Original Message----- > From: Cortland Richmond [mailto:[email protected]] > Sent: Wednesday, January 26, 2011 5:49 PM > To: Dennis Ward; 'John Woodgate'; [email protected] > Subject: RE: dow for new standards > > Let's nor forget that Part 15 (or 55024 etc for that matter) do NOT prevent interference -- just (slightly) reduce the probability. > > Cortland > KA5S > > -----Original Message----- > >From: Dennis Ward <[email protected]> > >Sent: Jan 26, 2011 1:29 PM > >To: 'John Woodgate' <[email protected]>, [email protected] > >Subject: RE: dow for new standards > > > >Ahh but isn't that the problem when an entire system makes one entity 100% > >responsible for everything and negates any legal acceptance or > >responsibility of others to alleviate that burden??? It basically says, > >'since you are 100% responsible, it is you that has to prove it, not I who > >brings your assumptions into question." The very fact that it is an > >'assumption' of conformity shows the burden of proof is on the one > >'assuming', if and when that assumption is called into question. > > - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ 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]>
