The FCC defines test equipment as “equipment that is intended primarily for purposes of performing measurements or scientific investigations. Such equipment includes, but is not limited to, field strength meters, spectrum analyzers, and modulation monitors.”
The inquirer stated the device is an “industrial personal computer…” which is wrong. First off, there is no such thing as an ‘industrial personal computer’ as the FCC defines personal computer (industrial or otherwise) as “an electronic computer that is marketed for use in the home, notwithstanding business applications. Such computers are considered Class B digital devices.” So, even if used in a business or industrial environment, it is still a Personal Computer subject to Part 15 Class B. Perhaps it is meant that the device is a ‘business computer used in an industrial plant…” Then it would be class A, but it is still a computer (i.e. a Digital Device, previously called a ‘computing device’ by the FCC). NOTE: The term ‘Digital Device’ defined by the FCC is “An unintentional radiator (device or system) that generates and uses timing signals or pulses at a rate in excess of 9,000 pulses (cycles) per second and uses digital techniques; inclusive of telephone equipment that uses digital techniques or any device or system that generates and uses radio frequency energy for the purpose of performing data processing functions, such as electronic computations, operations, transformations, recording, filing, sorting, storage, retrieval, or transfer.” While the specific computer may be used in an industrial environment for measurement purposes, unless it is manufactured so that only measurement can be done and it makes those measurements without use of other ‘test equipment’, the primary purpose would fit a Class A Digital Device as defined and thus is still subject to Part 15 rules. So, while a piece of test equipment may contain a digital device and be exempt under 15.103c or d, the device in question would not seem to fit the definition of test equipment as its purpose is a computer used in the measurement process. Trying to make this a piece of test equipment would be the same as a test lab trying to say the computer connected to the analyzer which records and processes data from that analyzer is a piece of test equipment. The analyzer is the test equipment, and even if the device can be programmed to record measurement data from a piece of test equipment to which it is connected (i.e. the analyzer of power meter), its primary purpose still fits the definition of a Digital Device (Computing Device) as it performs data processing functions, electronic calculations etc, and not actual measurements. Consequently, subject to the rules under Part 15 for either Class A or B depending on other uses. Thanks Dennis Ward This communication and its attachements contain information from PCTEST Engineering Laboratory, Inc., and is intended for the exclusive use of the recipient(s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachments(s) are free from computer virus or other defect. Thank you. From: Crane, Lauren [mailto:[email protected]] Sent: Thursday, February 18, 2016 10:04 AM To: [email protected] Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? There is an intriguing aspect of Michaels original question. He states the object is an “industrial personal computer in an industrial plant for measurement purposes.” There seems to be significant ambiguity related to what “test” means in 15.103c… particularly, is it to mean A. test device for other equipment (such as an oscilloscope), or B. anything that tests another object (such as a camera attached to a computer that does dimensional analysis of work pieces as they pass by) or both? There may even be a third possibility, and that is C. test in the sense of prototype. I have seen A defended as the correct reading because it implies there is other equipment ‘in the equation’ that might be opened or in a state of failure when the test equipment is being used and so it make sense to carve out the exemption. I have seen B defended in some contexts by the FCC such as a test noise source in an anechoic chamber, and I have received FCC guidance by email also supporting this idea. However, I have not been able to find a definitive public guidance statement from the FCC The definition given for test equipment does not resolve the ambiguity – “Test equipment” is “equipment that is intended primarily for purposes of performing measurements or scientific investigations [and] includes, but is not limited to, field strength meters, spectrum analyzers, and modulation monitors.” It also seems important that the language of FCC is in terms of ‘devices’ more often than ‘products’ or ‘equipment’, thus a product or equipment might contain several devices each of which must have their particular FCC concerns addressed. Regards, Lauren Crane KLA-Tencor Public | Unrestricted From: Bill Stumpf [mailto:[email protected]] Sent: Thursday, February 18, 2016 11:13 AM To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? Dennis is 100% right. The exemption applies exclusively to products which are industrial, commercial, or medical test equipment. The "test equipment" classification applies to all of these categories, not only medical devices - at least this is my interpretation. So if the digital device is not test equipment, the exemption does not apply. If the exemption applies, it only pertains to the technical requirements of Part 15. The general operation requirements of 15.5 always apply. As to the Class A/B application, you have to look at how the device is marketed. If it is not marketed to the consumer and is not intended to be used in the home, then Class A applies. Bill Stumpf From: dward [mailto:[email protected]] Sent: Thursday, February 18, 2016 11:06 AM To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? In addition to the previous comment I made, it is noted that the FCC defines ISM equipment as “Equipment or appliances designed to generate and use locally RF energy for industrial, scientific, medical, domestic or similar purposes, excluding applications in the field of telecommunication.” So, unless a digital device meets the exemption requirements 15.103 and if it is not a piece of test equipment, it is subject to Part 15. Now then you must look to see if it is Class A or Class B. Dennis Ward This communication and its attachements contain information from PCTEST Engineering Laboratory, Inc., and is intended for the exclusive use of the recipient(s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachments(s) are free from computer virus or other defect. Thank you. From: dward [mailto:[email protected]] Sent: Thursday, February 18, 2016 8:46 AM To: 'Ted Eckert' <[email protected] <mailto:[email protected]> >; '[email protected]' <[email protected] <mailto:[email protected]> > Subject: RE: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? Several issues. First, 15.123 is not the clause exempting devices it is a clause referring to labeling of digital ready devices. Clause 15.103 is for exemption of devices. So, while it may say exempt, unintentional radiator devices are still subject to 15.5 and 15.29 with ‘strong’ recommendation to comply to part 15. (NOTE: 15.5b states “Operation of an intentional, unintentional, or incidental radiator is subject to the conditions that no harmful interference is caused and that interference must be accepted that may be caused by the operation of an authorized radio station, by another intentional or unintentional radiator, by industrial, scientific and medical (ISM) equipment, or by an incidental radiator.” 15.103 main paragraph states, “Although not mandatory, it is strongly recommended that the manufacturer of an exempted device endeavor to have the device meet the specific technical standards in this part.” So to say there are no mandatory EMC requirements is not accurate, as, while being exempt from any specific technical requirement, they are required NOT to interfere etc. It should also be noted that this exemption is ONLY for test equipment, not all digital equipment. NOTE: 15.103c says “A digital device used exclusively as industrial, commercial, or medical test equipment.” It is not saying a piece of medical test equipment and all other industrial or commercial equipment. It is saying industrial test equipment, commercial test equipment or medical test equipment. Also, be careful with the concept of fixed in regards exclusive use in these areas to exemption under 15.103. Exclusive does not mean fixed, it simply means that it is the ONLY area in which it is used, it means it cannot be taken out of the industrial, commercial or medical environment. I would think that test equipment would not be fixed and since the exemption for digital devices in these areas is for test equipment, I doubt if it means fixed. Thanks Dennis Ward This communication and its attachements contain information from PCTEST Engineering Laboratory, Inc., and is intended for the exclusive use of the recipient(s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachments(s) are free from computer virus or other defect. Thank you. From: Ted Eckert [mailto:[email protected]] Sent: Thursday, February 18, 2016 6:37 AM To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? Hello Michael, Whether or not EMC requirement apply in North America may depend on whether the industrial computer is in a fixed location. Digital devices that are part of industrial equipment are generally exempted. Incorporated devices are fixed in location and there is a general assumption that the environment is such that residential radio receivers, such as televisions, will not be within 3 meters of the equipment. A personal computer that has been ruggedized for use in industrial environments may still be subject to EMC requirements if it is movable. An industrial laptop, for example, may be used in a factory part of the time and in an office environment the rest of the time. I believe the key word is “exclusively” in the regulation you quoted. For a device to be exempted, it must be designed and marketed such that it is reasonably expected it will only be used in industrial environments. Best regards, Ted Eckert Microsoft Corporation The opinions expressed are my own and do not necessarily reflect those of my employer. From: [email protected] <mailto:[email protected]> [mailto:[email protected]] Sent: Thursday, February 18, 2016 2:09 AM To: [email protected] <mailto:[email protected]> Subject: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? Hi, I am sorry if my question was answered anytime before. Nevertheless here my question: An European manufacturer has applied EN 61326-1 and EN 61010-1 for an industrial personal computer in an industrial plant for measurement purposes. What are the mandatory requirements regarding EMC in US/Canada? Is ICES-003 mandatory for Canada? If not in my understanding ICES-001 is also not applicable. Is § 15.123 "exempted devices" (A digital device used exclusively as industrial, commercial, or medical test equipment.) for US applicable? If yes, 47 CFR Part 18 is in my opion also not applicable. Therefore NO mandatory EMC requirements for equipment which are in the scope of EN 61326-1 are existing in US/Canada? Thanks for comments in advance. Michael - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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