I would agree with Bill, that the FCC is certainly moving in the direction of a more “holistic approach toward the whole end product”, and less interested in the separation of the component parts (component parts, in the sense of assessing operations separately).
I would suspect that if Bill were to submit a KDB, my guess is that they will say “whole product”. We see it with things like the clarification on spurious emissions testing of the unintentional emissions, where the upper frequency range for Part 15B testing is based on the highest frequency in the installed module. They’re looking more at the full picture these days. Michael. From: Bill Stumpf [mailto:[email protected]] Sent: 15 February 2017 19:28 To: [email protected] Subject: Re: [PSES] Co-located modules I don't have any conclusively documented evidence from the FCC. This supposition is taken from recent FCC presentations, current KDB's and conversations with trusted "co-inhabitants" in this industry. An example of this indication is provided below. It is from an April 2015 FCC TCB Council presentation regarding KDB 551693 DR01. Real purpose of no-collocation condition – Not to restrict device usage options – Instead is to require compliance of multi-radio simultaneous transmission operations within a single end product • In cases where that is not already evaluated in the applications, or • For use outside parameters/scope for which the device was already evaluated I know in the past we've referenced 20cm as the minimum distance between antennas at which the FCC considered two simultaneously transmitting transmitters to be collocated. Even that was unwritten though. It would be nice to have a more clearly defined answer to what is considered collocation for requiring FCC multi-transmitter product procedures. Perhaps I will submit a KDB inquiry to the FCC... Bill From: [email protected] <mailto:[email protected]> [mailto:[email protected]] Sent: Wednesday, February 15, 2017 11:33 AM To: Bill Stumpf <[email protected] <mailto:[email protected]> > Cc: EMC-PSTC <[email protected] <mailto:[email protected]> > Subject: Re: [PSES] Co-located modules Bill -- This "in the same enclosure" interpretation sounds new and drastic to me. Do you have any official document/link on this interpretation? thanks Mike Sherman Graco Inc. _____ From: "Bill Stumpf" <[email protected] <mailto:[email protected]> > To: "EMC-PSTC" <[email protected] <mailto:[email protected]> > Sent: Wednesday, February 15, 2017 7:34:19 AM Subject: Re: [PSES] Co-located modules The latest chatter I gathered on this topic is that the FCC considers collocated as "in the same enclosure". Indications are that any reference to <20cm being considered collocated has been set aside. Bill From: Michael Derby [mailto:[email protected]] Sent: Wednesday, February 15, 2017 2:18 AM To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] Co-located modules Hi Stephen, One thing to remember is that “must not be co-located” really just means “must not be co-located without some additional effort” For example, co-locating two modules and then calculating the new combined RF Exposure MPE value to verify that the product still meets the requirements, would be acceptable. It does not necessarily mean a C2PC is needed, for example. I think you’re right that 20 cm is ‘good guidance’ with regard to RF Exposure. But if your modules are 20.5cm apart, you might still want to consider the overall compliance of that final product… and a co-located MPE calculation is not too hard. Thanks, Michael. From: Stephen Whalen [mailto:[email protected]] Sent: 14 February 2017 23:34 To: [email protected] <mailto:[email protected]> Subject: [PSES] Co-located modules All, For a module that has "must not be co-located" restriction on FCC grant. What is the minimum separation distance allowed for another transmitter? I recall 20cm but can't find where it is documented. Regards, Stephen - ---------------------------------------------------------------- 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] <mailto:[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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected] <mailto:[email protected]> > Mike Cantwell <[email protected] <mailto:[email protected]> > For policy questions, send mail to: Jim Bacher <[email protected] <mailto:[email protected]> > David Heald <[email protected] <mailto:[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] <mailto:[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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected] <mailto:[email protected]> > Mike Cantwell <[email protected] <mailto:[email protected]> > For policy questions, send mail to: Jim Bacher <[email protected] <mailto:[email protected]> > David Heald <[email protected] <mailto:[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] <mailto:[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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected] <mailto:[email protected]> > Mike Cantwell <[email protected] <mailto:[email protected]> > For policy questions, send mail to: Jim Bacher <[email protected] <mailto:[email protected]> > David Heald <[email protected] <mailto:[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] <mailto:[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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected] <mailto:[email protected]> > Mike Cantwell <[email protected] <mailto:[email protected]> > For policy questions, send mail to: Jim Bacher <[email protected] <mailto:[email protected]> > David Heald <[email protected] <mailto:[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]>
