On 12 Dec 96, Brian Weppler wrote:
We manufacture a simple single line analog telephone product. It has FCC
part 68 and part 15 approvals. We have made a few minor changes to it and
would like to know if we need to get the entire product reapproved, or if we
can simply file some paper work with FCC attesting that we have tested the
product and it still meets specs.
Any help on what is the "right" thing to do here would be appreciated.
In reply,
The FCC Part 68 allows you to file a "modification" application
for situations such as yours. The modification application consist
mostly of a letter explaining the changes, data of the relative Part
68 tests that your changes may have affected, updated schematics,
and a completed 730 application form. Your FCC Part 68 number
does not change when a modification application is submitted. If
your changes are indeed minor in connection with Part 68 (in other
words you have not changed the hardware in the Tip and Ring interface
circuit or made changes affecting any signalling going out to the network)
then your Part 68 continuing compliance testing should cover you.
Speak with your lab that did the testing, they should be able to help you.
As for Part 15, what you consider minor changes may in fact be
large changes when it comes to affecting EMI. Generally, retesting is
necessary when any hardware has been changed. I suggest you speak to
the lab that did your testing. If your product was originally
certified as opposed to verified, and depending on what changes you
made, you may need to submit a Class II Permissive Change report or
even a new certification for Part 15. A class II report submission
does not change your ID number but a new certification will. If your
product was originally certified and the changes you made were indeed
minor and your retesting shows the results as better than when originally
tested, then you prepare a Class I permissive report which you must
keep on file but do not need to submit to the FCC unless they
specifically request it from you for auditing reason. If you just
have a verification device, just do the retesting and prepare another
verification report and keep it on file. Again, I suggest you speak
with the lab that originally did your testing. If they no longer
exists, give me a call.
.....John Chase 801/972-6146 ext 1218
