On 7/15/2008, Darrell Locke wrote:
We are beginning contract manufacturing a telephone dictation device
used in
medical office environment. We do not place the product on the market as our
customer does. The existing product we are replacing is quite old and the
label indicates Compliant to FCC Part 68 and our customer is requesting we
comply. I am unfamiliar with this standard and cannot find much information
on Part 68. The protocol in the telephone system is the same we are really
just producing a new unit for cost, part obsolescence, etc. Can any provide
any information such as what steps to take or if we need to do anything since
we are not selling it on the market.
Hi Darrell:
FCC Part 68 is a regulatory requirement that applies to equipment that
connects to the public telephone network. For example, if your product
connects to a regular phone line, it will be subject to FCC part 68.
Fortunately, the requirements in FCC Part 68 are generally not difficult to
pass, since they are almost exclusively focused on preventing harm to the
phone network. In general, the product does not actually have to perform any
particular functions, as long as it does not "harm" the network. There are
only a few exceptions to this "network harm" philosophy, such as hearing aid
compatibility for handsets and user volume controls.
The procedure for getting the product tested and registered is fairly simple.
Any commercial test lab that offers FCC Part 68 testing can perform the tests
and register the product for $2500 or so.
One thing that may be confusing is that several years ago, the FCC decided to
turn over the day-to-day management of the requirements and the registration
process to an industry group. This group is known as ACTA
(http://www.part68.org <http://www.part68.org/> ), and most of the Part 68
requirements are now contained in the industry specification TIA-968. Due to
legal considerations, a few requirements remain within FCC Part 68. This
transition has had very little impact on the actual technical requirements.
Rather, it has altered (and streamlined) the administrative process for
getting a product registered.
If I recall correctly, the FCC Part 68 registration has to identify the
manufacturer of the product, although I have not looked at this aspect lately
to see if it changed under the ACTA procedures. The application also has to
disclose certain aspects of the phone line interface that affect compliance.
Chances are that your company, as the designer and manufacturer, will need to
be involved in the registration process. This should not be a problem as long
as the product is, in fact, compliant with the requirements of FCC Part 68.
Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848 (USA)
[email protected]
http://www.randolph-telecom.com <http://www.randolph-telecom.com/>
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