Hi Charles I would agree with your reasoning, but experience indicates that your leading statement below is the correct one. We know of a laboratory in Malaysia that is 17025 accredited for Part 15 tests by A2LA. We were surprised to find out that since Malaysia has no MRA with the US, that results / test reports from the A2LA EMC lab located in Malaysia are not acceptable for DoC. Below is the response to my question for clarification on the matter. Response: When a testing laboratory is accredited it must then be designated to the FCC for the FCC to recognize. The FCC only recognizes A2LA (and NVLAP) to designate domestic testing laboratories to the FCC. Testing laboratories in foreign economies must be designated to the FCC by the government of the foreign economy. Note - emphasis not mine..... Thus, since Malaysia doesn't have an MRA with US - the test lab is not recognized. This does not really match my reading of the rules in Part 2. Several people I considered subject matter experts were a bit confused by it as well. I am not really even sure as to what mechanism exists as to how the foreign economy would designate labs to the FCC - I thought the accreditation bodies reported this to them. Nevertheless, I was able to confirm that this is the FCC position by another independent source familiar with this issue afterwards. If you find out otherwise let me know. Best regards, Mac Elliott
[ ] General Public ________________________________ From: [email protected] [mailto:[email protected]] On Behalf Of Grasso, Charles Sent: Thursday, October 29, 2009 2:14 PM To: peter merguerian; [email protected] Subject: RE: India_US MRA for EMC? - Expanded. Thank you to all of you who replied. I am in a position of reviewing test reports for a DoC product designed and tested in India. So with no MRA I suppose the DoC could be invalid. I have asked the lab for their accreditations and I am told that they are NABL accredited. It turns out that NABL is a signatory to both the ILAC (International Laboratory Accreditation Cooperation) and the APLAC (Asia Pacific Laboratory Accreditation Cooperation) agreements. These agreements are suppose to make all accredited labs equal. NVLAP and A2LA are also signatories to the same agreements. While I could not find an MRA (Mutual Recognition Agreement) between NVLAP/A2LA and NABL, the fact they are a signatory to these two international agreements would make me think that an NABL accredited lab’s results would be accepted by the FCC. Does anyone else agree?? Best Regards Charles Grasso Compliance Engineer Echostar Communications (w) 303-706-5467 (c) 303-204-2974 (t) [email protected] <mailto:[email protected]> (e) [email protected] <mailto:[email protected]> (e2) [email protected] <mailto:[email protected]> ________________________________ From: peter merguerian [mailto:[email protected]] Sent: Thursday, October 29, 2009 7:44 AM To: [email protected]; Grasso, Charles Subject: Re: India_US MRA for EMC? They have no MRA but if this is telecom related, TEC should accept your US accredited laboratory emc test reports. Telecom tests are done in-country Peter --- On Wed, 10/28/09, Grasso, Charles <[email protected]> wrote: From: Grasso, Charles <[email protected]> Subject: India_US MRA for EMC? To: [email protected] Date: Wednesday, October 28, 2009, 12:12 PM Hello all! Does anyone know if a MRA exists between the US and India for accepting EMC test reports? Best Regards Charles Grasso Compliance Engineer Echostar Communications (w) 303-706-5467 (c) 303-204-2974 (t) [email protected] <http://us.mc1 20.mail.yahoo.com/mc/[email protected]> (e) [email protected] <http:/ us.mc1120.mail.yahoo.com/mc/[email protected]> (e2) [email protected] <http://us.mc 120.mail.yahoo.com/mc/[email protected]> - 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] <mailto:[email protected]> > All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc <http://www.ieeecommunities.org/emc-pstc> Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ <http://www.ieee-pses.org/> Instructions: http://listserv.ieee.org/request/user-guide.html <http://listserv.ieee.org/request/user-guide.html> List rules: http://www.ieee-pses.org/listrules.html <http://www.ieee-pses.org/listrules.html> For help, send mail to the list administrators: Scott Douglas <[email protected] <mailto:[email protected]> > Mike Cantwell <[email protected] <mailto:[email protected]> > For policy questions, send mail to: Jim Bacher <[email protected] <mailto:[email protected]> > David Heald <[email protected] <mailto:[email protected]> > - 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://www.ieeecommunities.org/emc-pstc 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]> - 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://www.ieeecommunities.org/emc-pstc 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]>
