Good afternoon,
I'll repeat my earlier story and give the group an update.
We have made some small changes to our product (prominently to Y-caps, and
some beads) which unfortunately did not increase our margin vs EMC limits,
but the product still passes FCC and ISED. Engineering wanted to use the
self-declaration process to document these changes, including passing test
results w/o going through the TCB and re-file process. The changes do
appear to classify for what CFR 47, Part 15 § 2.1043 call a class II
permissive change, but it's just as certain that the original FCC and ISED
ID's are still valid as the product is roughly the same, still passes
emission limits and made no changes to the WiFi system (same chip,
location, antenna, and firmware).
I've been told - by (a) an engineer from a well-known EMC/TCB, and (b) an
engineer at a local EMC test lab - that Class II permissive change only
applies to intentional radiators. I can't find the legal language in Part
15 that spells this out; does anyone know?
Does anyone want to confirm Engineering's assertion that SDoC will suffice?
Thanks,
Colorado Brian
Please note: forwarded message attached
From: David Schaefer <david.schae...@element.com>
To: Brian Gregory <brian_greg...@netzero.net>, "EMC-PSTC@LISTSERV.IEEE.ORG"
<EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] Necessary Lab accreditations, class 2 permissible change
Date: Thu, 10 Aug 2023 15:42:24 +0000
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 All
emc-pstc postings are archived and searchable on the web at:
https://www.mail-archive.com/emc-pstc@listserv.ieee.org/
Website: https://ewh.ieee.org/soc/pses/
Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to
unsubscribe)
List rules: https://ewh.ieee.org/soc/pses/listrules.html
For help, send mail to the list administrators:
Mike Sherman at: msherma...@comcast.net
Rick Linford at: linf...@ieee.org
For policy questions, send mail to:
Jim Bacher at: j.bac...@ieee.org
To unsubscribe from the EMC-PSTC list, click the following link:
https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1
RE: [PSES] Necessary Lab accreditations, class 2 permissible change
From David Schaefer david.schae...@element.com
Date Aug 10, 11:42 AM
To Brian Gregory brian_greg...@netzero.net, EMC-PSTC@LISTSERV.IEEE.ORG
Certification activities in the USA are handled by TCBs. Most test labs
either have a separate TCB group, or work with a specific TCB for
approvals. You should work with a lab to determine what tests need to be
repeated, and take the data. Based on the new data the lab can determine if
it is a Class 1 or Class 2. For a Class 2 the TCB will do a filing with the
FCC. For a Class 1 you just need to keep the data on hand internally to
prove the change was investigated.
David Schaefer​
Technical Manager
Element Materials Technology
9349 W Broadway Ave
Brooklyn Park
,
MN
55445
,
United States
O +1 612 638 5136
ext. 10461
david.schae...@element.com
www.element.com
From: Brian Gregory [mailto:brian_greg...@netzero.net]
Sent: Thursday, August 10, 2023 10:01 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Necessary Lab accreditations, class 2 permissible change
CAUTION:This email originated from outside of Element Materials Technology.
DO NOT click links or open attachments unless you recognize the sender and
know the content is safe. Please contact IT Service Desk if you are in any
doubt about this email.
Yes, we increased the Y-Caps to get more margin. And we did!
So, to qualify for a Class 1 permissive change, we'd need to show before &
after data ?
Applying for a Class 2 permissive change, means FCC will look only at the
latest data to be sure it passes?
Colorado Brian
---------- Original Message ----------
From: John Woodgate <j...@woodjohn.uk>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Necessary Lab accreditations, class 2 permissible change
Date: Thu, 10 Aug 2023 00:02:42 +0100
What are you changing about the Y-caps? If it's just a new supplier and the
caps conform to the required component standard, there is no degradation.
Reducing he capacitance would be a degradation for EMC but not for safety.
Who determines the class is the person who has all the necessary data. The
test house of surveillance authority check the decision.
On 2023-08-09 23:20, Brian Gregory wrote:
Hello EMC experts,
A question came up today about filing new results to FCC for our legacy
product.
1. If the filing is only for FCC, then the lab providing the report does
not need A2LA accreditation,
2. If the filing is for a safety report, then the lab does need A2LA
accreditation.
Have I got that right?
We're filing some small board changes, including Y-caps and can't figure
out if this is a Class 2 permissible change, defined as: " includes those
modifications which degrade the performance characteristics as reported to
the Commission"
3. How or who determines if our change is Class 2 (degraded performance)
or Class 1?
We think the results are better, but it's not like we got uniformly more
margin across the board.
Thanks!
Colorado Brian
720-450-4933
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
<emc-p...@ieee.org> All emc-pstc postings are archived and searchable on
the web at:
https://www.mail-archive.com/emc-pstc@listserv.ieee.org/
Website: https://ewh.ieee.org/soc/pses/
Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to
unsubscribe)
List rules: https://ewh.ieee.org/soc/pses/listrules.html
For help, send mail to the list administrators:
Mike Sherman at: msherma...@comcast.net
Rick Linford at: linf...@ieee.org
For policy questions, send mail to:
Jim Bacher at: j.bac...@ieee.org
To unsubscribe from the EMC-PSTC list, click the following link:
https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1
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
<emc-p...@ieee.org> All emc-pstc postings are archived and searchable on
the web at:
https://www.mail-archive.com/emc-pstc@listserv.ieee.org/
Website: https://ewh.ieee.org/soc/pses/
Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to
unsubscribe)
List rules: https://ewh.ieee.org/soc/pses/listrules.html
For help, send mail to the list administrators:
Mike Sherman at: msherma...@comcast.net
Rick Linford at: linf...@ieee.org
For policy questions, send mail to:
Jim Bacher at: j.bac...@ieee.org
To unsubscribe from the EMC-PSTC list, click the following link:
https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1
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 All
emc-pstc postings are archived and searchable on the web at:
https://www.mail-archive.com/emc-pstc@listserv.ieee.org/
Website: https://ewh.ieee.org/soc/pses/
Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to
unsubscribe)
List rules: https://ewh.ieee.org/soc/pses/listrules.html
For help, send mail to the list administrators:
Mike Sherman at: msherma...@comcast.net
Rick Linford at: linf...@ieee.org
For policy questions, send mail to:
Jim Bacher at: j.bac...@ieee.org
To unsubscribe from the EMC-PSTC list, click the following link:
https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1
Disclaimer
This email is sent on behalf of Element Materials Technology Group Limited
or the relevant group company with which you are dealing (together,
Element). Element Materials Technology Group Limited is a limited company
registered in England and Wales with registered number 09915743. Its
registered office and its principal place of business is at 3rd Floor,
Davidson Building, 5 Southampton Street, London, United Kingdom, WC2E 7HA.
Element cannot accept responsibility for any loss or damage sustained as a
result of viruses or malware and the recipient must ensure that the email
and attachments are virus and malware free. Emails and attachments are
opened at your own risk.
The information transferred is intended only for the person or entity to
which it is addressed and may contain confidential and/or privileged
material. Transmission of this email is not intended to waive
confidentiality and/or privilege.
The contents of this email are subject to contract and do not contain an
offer that is capable of acceptance. Unless otherwise agreed in writing
with you, the Element Standard Terms of Business for the relevant group
company apply in respect of any services provided to you, including advice
given to you by email. The Standard Terms of Business are available on
request and can be found at https://www.element.com/terms/terms-and-conditions
For information about how we process data and monitor communications please
see our Privacy statement at https://www.element.com/terms/privacy-statement
