Yes, FCC requirements for this type of equipment are not very practical. As a side note, such large equipment is industrial in nature, which may lead one to believe they would fall under FCC Part 18 for ISM instead of Part 15. However, Part 18 only covers industrial equipment that generates and locally uses RF energy for the production of physical, biological, or chemical effects. An industrial machine that does not utilize RF energy for these purposes is not within scope of Part 18, and so Part 15 applies.
I don't think there is any hope of FCC revisiting these rules any time soon, however. Jim Hulbert From: John Woodgate [mailto:[email protected]] Sent: Friday, February 22, 2019 3:05 AM To: Jim Hulbert <[email protected]>; [email protected] Subject: **External**Re: [PSES] FCC Part 15 Testing in Situ Such very large equipment tends to be custom-designed, so three identical installations never exist. Even if there are three identical installations, they are unlikely to be completed simultaneously, so how can the first two be legally operated before the third is installed and tested? I wonder if FCC needs to look again at this requirement. Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk> Rayleigh, Essex UK On 2019-02-21 20:48, Jim Hulbert wrote: Equipment that is covered under FCC Rules Part 15, but which is too large to test on an open area test site, can alternatively been tested in situ. However, the rules state that the test should be performed at 3 different representative installations of the equipment. Does anyone on this forum have experience doing this? I would expect conducted emissions to be reasonably similar, but I can see how environmental influences could result in 3 different sets of radiated emissions data. How do you make sense of the data? Jim Hulbert This email message may contain confidential, proprietary and/or privileged information. It is intended only for the use of the intended recipient(s). If you have received it in error, please immediately advise the sender by reply email and then delete this message. No one other than the intended recipient may disclose, copy, distribute or use the information contained in this message. - ---------------------------------------------------------------- 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]>
