and at the moment the proposal is open for comment. I find the requirement for accreditation to 17025 and similar for any lab, such as the manufacturers lab, a bit onerous. And in effect, it appears we have to get a experimental license to develop our product, and then have to submit it to a 17025 qualified or accredited lab for formal data and test report. I suspect that there are a number independent labs and consultants represented on the committee. (my spell check has turned off???)
>________________________________ > From: Ed Price <[email protected]> >To: [email protected] >Sent: Tuesday, March 19, 2013 7:12 PM >Subject: FCC Part 5 Experimental Services > > >The USA FCC has been doing some sweeping changes in the Part 5 Experimental >Radio Services. They issued Report & Order FCC-13-15 on 31 January 2013. This >has ramifications for broadcasters, product developers and even compliance >test labs! Among the interesting changes are: > >· Some sections of Parts 73 & 74, covering broadcast experiments, have >been moved to a new Subpart of Part 5. All experimental rules are now solely >inside Part 5. >· They now have something called Program Experimental Licenses for >colleges, research labs, development engineers, medical researchers and >manufacturers to experiment with radio devices. >· They have set up a website where licensees must register their >planned experiments prior to their “experiments.” >· A Licensee will also have to post “reports” about their experiments. >· Another new Subpart in Part 5 deals with provisions for market trials >and modifies when RRF devices may be “marketed” and/or “operated” prior to >equipment certification. This also applies to importing devices into the USA. >· They have established a “medical testing license,” to permit “health >care facilities” to conduct RF-related, uhh, something, maybe treatments or >maybe medical data transmission. >· They have defined something called an “Innovation Zone,” where a >Licensee can operate in addition to the Licensee’s licensed region. And what >that means could start several careers. >· They have created a “Compliance Testing License.” I think that means >the FCC will give broad latitude to “FCC recognized” testing labs to operate >(and maybe develop) experimental RF devices, with the ultimate goal of >demonstrating their compliance with FCC R&R. >· They mention an overall caveat about these experimental operations; >“…harmful interference caused by an experimental licensee to any licensed >service is unacceptable..." >· And if one of these licensed services experiences interference, the >licensee must have set up a “contact point” which will have the ability to act >as a “Stop Buzzer” to immediately cease operation in the event of a complaint. > >You will have to take a look for yourself as to how this affects your existing >operations, and whether it opens possibilities of new engineering services for >you and your company. You also might want to put in a job requisition for >another lawyer or two. Here’s the FCC source (I didn’t look through every file >in this area, so who knows what else might be deep in the texts): > >http://transition.fcc.gov/Document_Indexes/Engineering_Technology/2013_index_OET_RO.html > >http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-13-15A1_Rcd.pdf > >Of course, this isn’t official until it has been published in the Federal >Register and incorporated into the eCFR, but it looks like the Part 5 at: > >http://www.ecfr.gov/cgi-bin/text-idx?sid=64f63e21c14d853c79afa96fd333ff3e&c=ecfr&tpl=/ecfrbrowse/Title47/47cfrv1_02.tpl > >was last modified on 15 March 2013, so it should be all in there. Well, as I >said, this has a lot of implications. > >Ed Price >WB6WSN >Chula Vista, CA USA > - >---------------------------------------------------------------- > >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.ieee-pses.org/emc-pstc.html >Attachments are not permitted but the IEEE PSES Online Communities site at >http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used >formats), large files, etc. >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.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. 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]>
