The FCC also is taking the route mandated by their charter - protect the radio users from interference. Part 15 apparently does that adequately as interference complaints to the FCC have dropped to the noise level. Not so before Part 15, Subpart J was published in the late 1970s. Part 15 is doing its job. Immunity testing isn't a "protection of the spectrum" issue. Besides, with the legal climate in the US, if the FCC mandated a certain level of immunity and someone was injured because that level wasn't high enough (allegedly or in actuality) the FCC would be sued. Might not be successfully, but it is something to be avoided. Keep in mind that the commissioners are political appointees. Their job is to do their job while not making the President look bad. Getting hauled into court doesn't do that so well. Just another viewpoint...
Ghery S. Pettit -----Original Message----- From: John Allen [mailto:[email protected]] Sent: Friday, September 30, 2016 8:00 AM To: [email protected] Subject: Re: [PSES] [RFI] Part 15 isn't enough.. Cortland Sound like Congress being "ruled" by "big" and/or "small business" interests to make the FCC take the path of least resistance - I would have thought that their approach might have been deemed as being not in the general public interest, but I can now see where you are coming from on the warrantee front. OTOH, from what I think you wrote earlier, some States would not permit that warrantee approach - sounds like more "vested interests" coming into play there. Looks like rather a no-win situation on immunity improvements for products for the general public in the foreseeable future - unless, possibly, one or more important States were persuaded to pass appropriate legislation on the basis of the dangers from not doing so, as has been the cases related to environmental protection and energy conservation (and so on) that have affected the design and sale of electronic equipment Oh well, maybe someday EMC issues really will begin to "bite" a lot more people across the country and something will, most belatedly, be done at the Federal level. John E Allen W. London, UK -----Original Message----- From: Cortland Richmond [mailto:[email protected]] Sent: 30 September 2016 14:58 To: [email protected] Subject: Re: [PSES] [RFI] Part 15 isn't enough.. On 9/30/2016 8:59 AM, Dieter Paasche wrote: > The operator of a radio frequency device shall be required to cease > operating the device *upon notification by a Commission > representative* that the device is causing harmful interference. [emphasis added] The FCC has been reluctant to make that notification even after numerous complaints, as being too zealous in enforcing the Rules has historically resulted in Congress reducing the funds available to do so. You know the saying 'Was nicht ausdrücklich erlaubt ist, ist verboten'; we have gone quite the opposite way to "Alles was nicht erlaubt ist, ist pflichtig" – at least when there is profit to be had. This is why I advocate placing a requirement the vendor warrant noninterference and RF immunity in the purchase contract. What laws can't do, money can. Cortland Richmond KA5S - ---------------------------------------------------------------- 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]> - ---------------------------------------------------------------- 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]> - ---------------------------------------------------------------- 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]>
