Generally agree, but government people can be capricious. For several years, have loaned a 'measurement device' to customers having issues with interfacing our stuff to their stuff. The device is marked "Property of the Empire. For Test and Evaluation Only". The device is a small plastic box with an USB port and a terminal block for analog and digital inputs that is embedded inside the customer's equipment; and the box has no display/keyboard/etc. Inside this little box is an ARM 4 processor and other stuff to measure and record.
There was one site where the box was supposedly interfering with a zigbee mesh, which resulted in another supplier making complaint. The brilliant and charming government people said that my little box was essentially a computer so should be Class B. The customer's laptop computer, while connected to the 'device' USB port, caused the interference. The customer had defeated electromechanical interlocks to run his equipment with their computer connected to my USB port. There are several mundane morals to this silly story, but will not restate the obvious. Brian From: Gary McInturff [mailto:[email protected]] Sent: Thursday, February 18, 2016 11:49 AM To: [email protected] Subject: Re: [PSES] [EXTERNAL] Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? I interpreted the original post correctly this was a system that was developed by the original posters company expressly to be used in the industrial market. It might look like a personal computer but there is another factor to be considered. The OEC document provides an escape clause, if you will, in a couple of places if you read it carefully enough. The term “marketed” is important in this context. Since I don’t know who can see snippets of a PDF file and I don’t want type out the paragraphs I’m going to just refer you to section 15.3 (h), 15.3 (i) and 15.3(s) Section (s) defines a personal computer stating “computers that are “marketed” through retail outlets, mail order, and advertised to the general public. If the original poster is building a computer that isn’t marketed to the average consumer, advertises in trade magazines rather that Best Buy type circulars, and/or is too big or bulky or even lacking consumer esthetics then it’s not a personal computer is industrial equipment. The marketing can also include price and supported software functions. 3X the price of an average computer, optimized to support only a CNC machine etc. takes it out of the personnel computer definition. Section h and I essentially do the same thing: Class A digital devices are ones that are are “marketed Exclusively” for use in Business, industrial and commercial environments. I had this discussion many years ago with the FCC. We were building banking automation systems, and we developed our own workstations hardware (IBM compatible) and banking specific software. I believe it was running MS O/S, and one could play with Excel or Lotus if you bought those applications and loaded it onto the computer but the marketing was as I described above, advertised in trade journals, was pricey, and was supplied only with our custom designed banking automation software. The agreed FCC agree it was not a personal computer and was in fact an industrial machine. For what it’s worth Gary - ---------------------------------------------------------------- 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://www.ieee-pses.org/list.html (including how to unsubscribe) 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]>
