Gary
I think your answer is here: §2.953 Responsibility for compliance. ((d) Verified equipment shall be reverified if any modification or change adversely affects the emanation characteristics of the modified equipment. The party designated in §2.909 bears responsibility for continued compliance of subsequently produced equipment. Your pre-compliance chamber could be used to determine whether the modification "adversely affects the emanation characteristics of the modified equipment". If it does - go to the OATS and "reverify" If it doesn't, file the results and move on. This would cover you for EMC Directive as well. Regards Charlie -----Original Message----- From: Gary McInturff [mailto:[email protected]] Sent: 13 August 2014 22:25 To: [email protected] Subject: [PSES] Changes to verified equipment I have a project coming up that with replace a processor which is going end of life in an unintentional radiator - an IR camera. In the US it is subject to verification - primarily meaning that I don't have to submit the data to the FCC unless asked, but I still need to test according to the regulations. The new processor is form and fit identical, and is of the same technology family and the designers tell me it won't even need a board spin - just software updating. We are at odds over whether or not I need to actually perform OATS testing on the device. The budget for the tests has already been made available but I am second guessing my strict interpretation of the need for testing. I have been combing through CFR 47 for exact definition of what product changes mandate re-verification. I used to remember a section that discussed changes in technology - CMOS versus ECL etc. - along with a number of other factors, but I also remember that reasonable engineering judgment analysis was permissible, but I can't find any relevant paragraphs in section 2 or 15 that might clarify. I haven't look at the EMC directive for the EU yet but would appreciate input from my friends in the EU. I think the design guys ask a reasonable question in that if we are changing layout, EMC suppression devices, clock rates, logic families, etc. MUST we re-test? I do have a pretty good pre-compliance chamber that I can do A/B comparisons of the product which would allow me to make some reasonable engineering judgments about the emissions comparisons between the old and new processors.( I use the chamber on a regular basis before I do formal testing and the results from my chamber and the OATS is close enough I have only been surprised at the OATS site once, and that was when I grabbed a bad cable as I was heading out the door - my bad.) Here are the only references I could find in the US federal code - anybody else have more precise reference? §2.902 Verification. (a) Verification is a procedure where the manufacturer makes measurements or takes the necessary steps to insure that the equipment complies with the appropriate technical standards. Submittal . . . (b) Verification attaches to all items subsequently marketed by the manufacturer or importer which are IDENTICAL (emphasis is mine) as defined in 2.908 2.908 As used in this subpart, the term identical means identical within the variation that can be expected to arise as a result of quality production techniques. (So identical doesn't strictly mean the exact same processor) 2.953 Responsibility for compliance. (a) In verifying compliance, the responsible party, as defined in §2.909 warrants that each unit of equipment marketed under the verification procedure will be identical to the unit tested and found acceptable with the standards and that the records maintained by the responsible party continue to reflect the equipment being produced under such verification within the variation that can be expected due to quantity production and testing on a statistical basis. Am I being too strict in my interpretation? Can I do an A/B comparison in my lab, and presuming no signifint change in my lab measured emmission allow release to production without outside testing? For the EU I would put the results of the test and rational for not testing further in the compliance folder. I have the money but don't want to spend it needlessly. Thanks Gary McInturff Reliability/Compliance Engineer Esterline Interface Technologies Featuring ADVANCED INPUT, GAMESMAN, and LRE MEDICAL products 600 W. Wilbur Avenue Coeur d'Alene, ID 83815-9496 Toll Free: 800-444-5923 X1XXX Tel: (208) 635-8 Fax: (208) 635-8 www.esterline.com/interfacetechnologies<http://www.esterline.com/interfacetechnologies> Technology, Innovation, Performance. "Information in or attached to this e-mail message may be subject to export control restrictions of the International Traffic in Arms Regulations (ITAR) (22 CFR pts. 120-130) or the Export Administration Regulations (EAR) (15 CFR pts. 730-774). Before exporting this information outside the United States or releasing it to a foreign person in the United States, you need to determine whether a license under the EAR or the ITAR is required to do so. If you have any questions about this obligation, please contact me." - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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