atcb.com fcc rules seminar taipei, taiwan april 2004

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FCC Rules SeminarTaipei, Taiwan April 2004

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AmericanTCB Taiwan

• AmericanTCB, Inc.3F, 201, Ti Ding Avenue, Sec.2,

• Neihu 114 Taipei, Taiwan • Major Chen

Sales Manager• Phone: 886-2-2658-5152 ext 311• Tim Johnson: +886 092039926

www.atcb.com

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WELCOMEand Thank You to our Sponsors

• Trivet Industrial Corporation

• Richtec Instruments Co., Ltd

• Training Research Corporation (TRC)

• EMI&EMC (Item Publications)

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Seminar Schedule and Overview

• Introduction & Overview of FCC Rules– Bill Graff: 1: 00-1:45

• Latest NPRMs and Rules Changes– Tim Johnson: 1:45-2:30

• New requirements for Specific Absorption Rate (SAR) Testing– Bill Graff, ATCB: 2:30-3:15

• Break: 3:15-3:30• Feature Presentation by Sponsors

– Jones Yen, Trivet Industrial Corporation– Frank Tsai, TRC: 3:30-4:00– P.H. Yuan, Richtech: 3:30-4:30

• European Update– Mike Violette, ATCB: 4:30-5:00

• Q&A– 5:00-5:30

• Reception– 5:30-7:30

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Fundamental Rules SeminarWilliam H. Graff, AmericanTCB

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USA Compliance

• US: Federal Communications Commission– Title 47 Code of Federal Regulations– Product approvals can be performed by FCC or

Telecommunications Certification Bodies– TCBs are able to perform “routine” evaluations only

using FCC recognized industry standard methods– New technologies or technologies where there is no

industry consensus are excluded.

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FCC 47 CFR Regulations

• Part 2 General Requirements• Part 5 Experimental Radio Service• Part 15 Subpart C, D, and E Unlicensed

Low Power Transmitters (802.11a/b/g, Bluetooth, etc.)

• Part 20 Common Carrier• Part 21 Domestic Public Service• Part 22 Public Mobile Service• Part 24 Licensed PCS

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• Part 25 Satellite Communication Services• Part 26 General Wireless Services• Part 27 Miscellaneous Wireless Services• Part 68 Telecom Services• Part 73 Education Services• Part 74 Television Broadcast• Part 80 Maritime Service

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• Part 87 Aviation• Part 90 Private Land Mobile• Part 95 Personal Radio Service• Part 97 Amateur Radio• Part 101 Fixed Microwave

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• FCC does not regulate

• safety (except RF Exposure)• susceptibility• product performance

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Certification

– Used for most “Equipment Authorizations” Formerly called “Type Acceptance”.

– Is more than just a “test report” – actually a legal document

– Requires a detailed list of “Exhibits” • See 2.1033 for complete detail

– Test Report should be designed to show transmitter is “well-behaved”

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Licensed Radio Services Test Parameters

• 2.1046 - Power Output• 2.1047 - Modulation

Characteristics• 2.1049 - Occupied Bandwidth• 2.1051 - Antenna Terminal

Spurious Emissions• 2.1053 - Radiated Spurious

Emissions • 2.1055 - Frequency Stability for

Temperature and Voltage Variations

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•In most cases - the actual Radio Service rules have special or unique requirements and additional testing parameters.

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•In addition to the Part 2 rules addressing test parameters the FCC also recognizes the test methods contained in ANSI/TIA/EIA-603-1992 document

•***Reference test procedures in report

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•Remember that the purpose of performing the measurements required and submitting interpretations is to establish compliance with the technical requirement contained in the Radio Service Rules.

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•Power Output: 2.1046

•For any special case as sighted in the specific rules compliance to 2.1046 test method is accepted provided the specific Rule is addressed as part of the information.

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•Where sections of the recommended standard EIA-603 differ from Part 2 requirements - the Part 2 test method must be used for testing purposes.

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•Modulation Characteristics 2.1047

•Test requirements of this section differ from EIA-603 requirements.

•Compliance to Part 2 requirements is mandatory.

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•Example: EIA 603 differs from Part 2.1047 regarding the range which the audio frequency

response is to be measured.– Part 2.1047 requirement of 100 - 5000 Hz should

be used for this test.

•General Test SetupTransmitter

UnderTest

Power Attenuator

Power Measuring Receiver/Spectrum

Analyzer

Modulating Signal

Generator

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•Occupied Bandwidth 2.1049

•While this test is identified as “Occupied Bandwidth” which is defined as that portion where 99% of the emitted energy (with the remaining 0.5% above & 0.5% below the occupied band), the results are mainly used to compare modulated spectrum with emissions masks

•OBW @ 10 Log (0.01) = -20 dBc

•Other rule sections may call out -23 or -26 dBc

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•In addition to meeting the emission mask, the occupied bandwidth may not exceed the authorized bandwidth as listed in the Radio Service Rules.

•This test should be performed for each kind of emission to be listed on the FCC Grant.

•Note: the emission mask is normally applied with 0 dB equal to the level of the unmodulated carrier.

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Emissions Mask ExampleAnalog Modulation

Mask

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Emissions Mask ExampleDigital Modulation

Mask

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Licensed Radio Services Test Parameters•2.1049 does not cover Occupied Bandwidth tests for amplifiers or similar units since these devices are intended to reproduce the modulated signal.

•Amplifiers designed to handle multiple channels should be tested with multiple channels for each emission to show intermodulation products.

•Tests for power amplifiers still should include “gozinto” and “gozouta” plots for each modulation desired.

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•Intermodulation is considered a spurious emission by the FCC and are covered by the general emission limitations (masks) in each radio service.

•This specifically refers to the IM products produced by transmitters / amplifiers carrying two or more signals.

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•Antenna Terminal Spurious Emissions 2.1051•(Otherwise know as Conducted Emissions)

•View levels of harmonic emissions.

•An extension of the occupied bandwidth test showing the emission up to the highest frequency as specified in Section 2.1057 [usually 10th harmonic].

0

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•If the unit does not have a detachable antenna or an antenna output terminal then the test data is collected at the base of the antenna.

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Licensed Radio Services Test Parameters•Field Strength of Spurious Emissions 2.1053

– ERP/EIRP Spurious Measurement

•This test includes those emissions radiated from the cabinet, chassis, and associated wiring. The specification is the same emission mask under the Radio Service rules extended to the highest frequency specified in 2.1057.

•Substitution method described in TIA/EIA 603 required test procedure. Be sure to account for SWR when using broadband antennas !

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•Frequency Stability 2.1055

•Done over temperature [-30 C to +50 C] and operating voltage [+/- 15%] specifications.

•Battery operated devices should also include B.E.P [Battery End Point]

•Usually defined in ppm but other units such as Hz, % are accepted as defined in specific rule section.

•Differs some from methodology described in •TIA/EIA 603

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•Reference Standards:

•TIA/EIA 603 Land Mobile FM or PM Communications Equipment Measurement and Performance Standards

•TIA/EIA Telecommunications System Bulletin TSB102 (Digital C4FM/CQPSK Transceivers Measurement Method

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•Emission Designator: Determined from the Occupied bandwidth and the modulation scheme used

•Classic equations described in Part 2

•Required as part of submittal

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Common Part 22 H Cellular Emission Designators

• 40K0F8W – AMPS Cellular voice & signaling tone

• 40K0F1D – AMPS Cellular wideband data• 1M25F9W – CDMA (IS 95/98)• 30K0DXW - North American digital cellular

- TDMA• 300KGXW – GSM• 300KG7W - EDGE

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Emission Designator Calculation

• Emission Designator– 40K0F8W - Voice & SAT signal

• Voice (M=2.5k, D=12k), SAT (M=6k, D=2k)• Pick highest frequency and add deviations and

apply Carson’s Rule 2M+2D• 2(6k) + 2(12k+2k) = 12+28 = 40 kHz

– 40K0F8W - Signaling Tone (ST) & SAT• ST (M=10k, D=8k), SAT (M=6k, D=2k)• 2(10k) + 2(8k+2k) = 20+20 = 40 kHz

– 40K0F1D - Wideband Data• Data (M=10k, D=8k), SAT (M=6k, D=2k)• 2(10k) + 2(8+2) = 20+20 = 40 kHz

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Example Part 22 H Grant

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Certification Checklist for Licensed Services

• Applicant Name Correct• Test Firm• FCC ID: number• Equipment Functional Description• Equipment Class

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•Confidentiality Request Letter– Letter with details to be included with

confidentiality.– Commonly only Block Diagram, Schematics,

Parts List and Tune-up are eligible for confidential treatment

– Manuals, photos, test reports, SAR reports never allowed confidentiality

– Date of letter

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• Technical Information• Rule Part(s)• Frequency Range• Power Output

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• Antenna Port– (Real Connection or Integral antenna?)

• Frequency Tolerance

• Emissions

• Necessary Bandwidth Values Justified

• Emission Type Justified

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• RF Exposure Information

• Description: Purpose, Use and Users

• Instruction Manual

• DC Voltages and Currents Listed

• Tune Up Procedure

• Circuit Diagram \ Block Diagrams

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• Photos (Internal & External) Technical Report

• Power Output – (ERP/EIRP or Conducted? Peak or Average?)

• Audio Frequency Response

• Modulation Limiting

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• Frequency Stability vs Voltage

+ 15% and Battery end point• Frequency Stability vs Temperature

-30C to +50C

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Required Exhibits for Licensed Services

• Agent Authorization Letter• Confidentiality Request• Schematics• Block Diagram• RF Exposure Evaluation• Operational Description• Tune Up Procedure

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Required Exhibits for Licensed Services

• External Photographs• Internal Photographs• Sample Label with FCC ID:• Label Location• Test Setup Photographs• Users Manual• Test Report

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Timothy R. Johnson, American TCB

Recent FCC Clarifications, Latest NPRM’s and Rules Changes

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Presentation Overview

•Part 15 Recent Interpretation Issues, Reminders, and Application Concerns

•Part 15 Rulemaking updates– NPRM’s, Report and Orders, etc.

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Multiple Modulation Capabilities in One Device

•One familiar example, 802.11(g) incorporates the following modulation capabilities.

• BPSK modulation at 1 and 2 Mb/s• CCK modulation at 5.5 and 11 Mb/s• OFDM modulation at 54 Mb/s

•The FCC expects each of these modes and •modulations to be evaluated (i.e. pretest, etc.)

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•Justification for worse case results reported or modes reported should be included in the test report

•As a minimum, it is suggested that an 802.11g test report should include:

– Data for BPSK/CCK. Due to similar

waveforms, only worse case data needs

to be shown for these 2 modulations– Data for OFDM

Multiple Modulation Capabilities in One Device – Cont.

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AC Line Conducted Emissions for Part 15 Modules

•Section 15.207(a) requires test data unless the device is battery powered with no provision for receiving power directly or indirectly from an AC source.

•Any application granted for battery power only will be listed as a condition on the grant of authorization.

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AC Line Conducted Emissions for Part 15 Modules – Cont.

• Battery powered examples:– The transmitter is powered by an on-board battery.

Transmitter has a battery connector/compartment

– The transmitter is only intended for battery powered applications and installed by OEM. Device is conditioned only for battery powered applications and a

limited module approval is issued Any new non-battery application requires a new authorization (new

FCC ID)

– The transmitter is installed only in the manufacturers equipment that will be battery powered Grant is conditioned accordingly and a LMA is issued

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CISPR AC Line Conducted Limits for All Transmitters

•Since December 3, 2002, all Part 15 and 18 devices required to be tested for AC Line conducted emmissions must have either Note Code ’05’ or ‘CE’ listed on the grant of equipment authorization.

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CISPR AC Line Conducted Limits for All Transmitters – Cont.

•"05" NOTE- The manufacture and importation of this device must cease on July 10, 2005 pursuant to 15.37(j) or 18.123 transition provisions adopted under FCC 02-157 (ET Docket 98-80).

•"CE" NOTE - This device has shown compliance with the conducted emissions limits in 15.107, 15.207, or 18.307 adopted under FCC 02-157 (ET Docket 98-80) and may be marketed after July 11, 2005 and is not affected by the 15.37(j) or 18.123 transition provisions.

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•Currently the ’05’ note has been used on all devices that meet the older FCC line conducted regulations and not the new CISPR limits. This will only be allowed up until July 11, 2004. After this time TCBs and the Commission will no longer use the ’05’ note code.

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•The ‘CE’ note is used on all devices that are tested and comply with the new CISPR requirements and are granted before July 12, 2004. On July 12, 2004, all new approvals must meet the new CISPR limits. TCBs and the Commission will not use the “CE” note after July 11, 2004.

•All devices (both new and previously approved) marketed after July 11, 2005 must meet the new CISPR AC Line Conducted Limits.

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•To update a Part 15 grant that was approved using the previous Part 15 limits, a Class II permissive change filing should be submitted showing compliance with the CISPR AC line conducted limits.

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•Special Note: •The policies for filing Class II permissive changes are different for some Part 18 devices because certain types of Part 18 devices had no AC line conducted emissions limits before the FCC adopted the CISPR limits.

– Example Microwave ovens - for a detailed description see link: http://hraunfoss.fcc.gov/eas_public/SilverStream/Pages/pg_html_fts_res.html?letter=1344

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•Special Note 2: •Part 18 RF lighting devices were excluded from the new CISPR AC line conducted limits by the last sentence in Paragraph 22 of the Report and Order (ET Docket No. 98-80; FCC 02-157). Therefore, RF lighting devices will not have a Note Code 05 or CE on a grant of Certification.

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Vehicular Battery Chargers (VBC) for Cellular Phones

•There have been recent questions regarding whether a battery charger intended for use only in a vehicle requires FCC Certification.

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Vehicular Battery Chargers (VBC) for Cellular Phones – Cont.

•Exempted per Section 15.103(a) – The VBC is not promoted for applications

other than use within a vehicle, Section 15.103(a) exempts digital devices used exclusively in transportation vehicles

– Classified as a digital device under Part 15 of the FCC rules

– Subject only to non-interference provisions (Sections 15.5 and 15.29)

– Certification not required

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Part 15 Water Meter Transceivers In Ground Testing Guidance

•FCC has recently issued a special guidance regarding this issue. See link:•http://hraunfoss.fcc.gov/eas_public/SilverStream/Pages/Fpg_html_fts_res.html?letter=1366

– This guidance allows testing in ground as opposed to an open area test site (OATS)

– This gives the manufacturer more flexability to measure “system” vs. stand-alone configurations. Allows manufacture to tune power to meet their installation requirements

– Professional installation is required

– Instructions must provide appropriate details for the installation of the transmitter in the pits and must specify the types of pits

– Grant will contain conditions accordingly Professional installation and specific types of pits

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Part 15 Water Meter Transceivers In Ground Testing Guidance – Cont.

•Special Guidance:– Use mast. Do not use a tripod with fixed height– Section 8.1 in ANSI C63.4 should be

consulted. Frequency scans of the EUT field strength with both polarities of the measuring

– antenna shall be made at a minimum of 16 azimuth angles (nominally 22.5 degrees) around the EUT

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15.407(d) Integral Antenna Requirement for 5.2 GHz UNII Devices

•The integral antenna rule requires that the antenna is permanent or not removable.

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15.407(d) Integral Antenna Requirement for 5.2 GHz UNII Devices – Cont.

•Acceptable methods:– Antenna and/or antenna connectors are

soldered together– Permanent Loctite or industrial strength epoxy

can be used– A locking connector that cannot be removed,

even with a special toolMust be locked prior to shipment

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– An antenna and/or connectors inside of a non-accessible (there is no need for the user to ever open the case) Note that it is assumed that users will open desktop computers.

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•Exceptions:

•For a 5.15-5.25 GHz UNII mini-PCI card installed in a notebook computer with built-in antennas

– Bios locking feature satisfies the rule

•Antenna with embedded code.– Code ensures that the proper antenna is used

•Reminder: 5.15 – 5.25 GHz is for indoor use only. No outdoor antennas.

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•Unacceptable Methods:– A unique connector is not sufficient– Bios lock with external antenna– A locking connector that can be removed

with a special tool does not satisfy the requirement

– Heatshrink– User Warnings

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User Selectable Frequencies

•End user selectable frequencies for non USA frequencies are not allowed.

– User selectable options must be disabled– This must be clear in all exhibits within the filing. For

example user manual or descriptions for these options

•Section 15.15(b) prohibits adjustments of any control by the user that will cause operation of a device in violation of the regulations.

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Configuration of Antennas for Testing

•The FCC has recently developed 2 concerns regarding test configurations for the antennas of a modular approval.

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Configuration of Antennas for Testing – Cont.

•1) Antenna positioning in test setup should represent typical final product configuration

•2) DO NOT LAY ANTENNAS ON WOOD TABLETOP

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•In this example the monopole antennas should be supported in vertical position, e.g., using foamed-polystyrene blocks

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•Note that this also applies to antennas such as PIFA. The antennas shown on the following page should not be placed in contact with the table top during test. Additionally, the positioning should be justified in the report.

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•The FCC has seen that the matching of the antenna changes when placed too closely to the table top, which affects the radiation pattern.

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Co-located Transmitters, i.e. Laptop w/ LAN & Bluetooth – Cont.

•Co-Location is typically defined as when 2 transmitter antennas are located < 20 cm apart from each other, and both transmitters may be active at the same time.

•Each radio must be tested individually and appropriate test data submitted with the application

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•The application must also include tests for simultaneous transmission when the end use device may function with both transmitters active at the same time

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•Special care should be taken to investigate bandedge and intermodulation products

•Submit antenna conducted measurements with both transmitters on, if transmitters share an antenna

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– If radiated data for simultaneous transmission is no worse (no new intermod, spurs or increased levels) than individual tests, then also submit statement that simultaneous transmission was investigated and no new emissions were found

– If new emissions were found during simultaneous tests, provide data and indicate the worst case condition

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Cordless Phones

•Cordless phones under Part 15 have typically been approved under several sections of the FCC rules such as 15.233, 15.247, and 15.249.

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Cordless Phones – Cont.

•The FCC has just released an interpretation that requires a cordless telephone that operates on two different frequency bands to be approved under two separate FCC ID numbers, one for the base and one for the handset.

•For detailed information, refer to FCC Interpretation Data Base Posting 200009-13-004

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NPRM’s

•NPRM – Notice of Proposed Rule Making•This is a term used to denote a document that is published for public comment. The changes shown in the document are proposals only which may or may not actually become new rules and/or regulations.

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NPRM Modification of Parts 2 and 15

•Proposal to make changes to Parts 2 and 15 may be found in ET Docket No. 03-201, FCC 03-223

– http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-223A1.doc

•Published December 10, 2003– Public comments were due February 7, 2004

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NPRM Modification of Parts 2 and 15 – Cont.

• 1) Work to clarify the rules for advanced antenna technologies– (i.e. phased array/steerable beam systems) in 2.4 GHz band

• 2) Modify the rules on replacement of Part 15 antennas• 3) Modify the rules on configuring transmission

systems– No need to obtain separate authorization for every combination of

system components. i.e. adding amplifiers

• 4) Harmonize the measurement procedures for digital modulation systems under the Spread Spectrum and UNII rules

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NPRM Modification of Parts 2 and 15 – Cont.

• 5) Modify the channel spacing requirements for hoppers in the 2.4 GHz band to allow wider bandwidth hoppers

• 6) Clarify and change modular approval requirements• 7) Make other changes to update or correct Parts 2

and 15 of the rules

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NPRM on Interference Temperature

•Proposal in ET Docket No. 03-237, FCC 03-289– Adopted: November 13, 2003– Released: November 28, 2003– Published January 21, 2004– Comments due April 5, 2004– Reply Comments due May 5, 2004– http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-289A1.doc

•News Release– http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-241226A1.doc

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NPRM on Interference Temperature-Cont.

•RM seeks comments on “Interference Temperature”

approach to quantify and manage interference between

different services.

•Interference temperature model takes into account the

cumulative radiofrequency (RF) energy from

transmissions of spectrum-based devices and would set

a maximum cap on the aggregate of the transmissions.– Current interference management approach is based on specifying and

limiting transmit powers of individual spectrum based devices

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NPRM for Access Broadband Over Power Line Systems

• Proposal to make changes to Part 15 may be found in ET Docket No. 03-104 & 04-37, FCC 04-29

– http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-29A1.pdf

• 1) Access broadband operational requirements• 2) Equipment authorization and measurement

guidelines

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Report and Order

•Report and Order (R&O)

•This is a term used to denote a document that includes adopted rules, provides background on reason for adoption and Effective Date. Requires publication in Federal Register

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2nd R&O and MO&O Part 15Deregulation

•New Rules in ET Docket No. 01-278, FCC 03-149– Effective date: January 8, 2004– http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-149A1.doc

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2nd R&O and MO&O Part 15Deregulation – Cont.

• 1) Change emission levels in the restricted bands above 38.6 GHz

• 2) Allow data transmission in 15.231• 3) Modify the FS limits for 13 MHz RF ID systems• 4) Simplify the labeling requirement for self

authorized equipment (DOC)– Removed “For Home or Office Use” and statement that a

complete device was tested for compliance

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2nd R&O and MO&O Part 15Deregulation – Cont.

• 5) Other changes to update and correct FCC rules.– Incorporate the ANSI C63.17 test procedure for UPCS devices into the

rules

– Provide exemption for certain low power devices <490 kHz and FS is less than 40 dB below Part 15 limits

– Allow user manual information on CD-ROM or on internet if manual is provided likewise

– FRS transmitters tested -20 to+50 degrees C for frequency stability tests

– Accredited labs do not have to file description of measurement facilities with the Commission. However, Certain information is still required. Name, address, contact info, accrediting body’s name, designation number and date of renewal

– Miscellaneous rule corrections and deletions

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R&O UNII Devices

•New Rules in ET Docket No. 03-122– Effective date, February 19, 2004

– http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-287A1.doc

– Adds 255 MHz of spectrum 5.47-5.725 GHz to current UNII bands

– Dynamic Frequency Selection (DFS) for devices in the 5.25-5.35 GHz band and 5.47-5.725 GHz band

– Interim DFS Test procedure is in the Appendix of the Rules.

– Transmit power control (TPC) 5.47-5.725 GHz band

– According to the FCC only a statement that the device has TPC is required to be submitted in the filing. No test required

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R&O UNII Devices – Cont.

•DFS and TPC are considered new technology– TCB cannot approve any device operating under the

new rules

•Test procedure will be updated in the near future

– Currently this is considered a complex test which requires specialized equipment and software

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R&O UNII Devices – Cont.

•Class II permissive change for existing equipment to add DFS & TPC

– Allowed only for software change– Any hardware change requires NEW AUTHORIZATION

•Transition dates; equipment operating in 5.25-5.35 GHz

– 1 year, Certification filings must comply w/ new rules by February 19, 2005

– 2 years, All devices imported and marketed must comply by February 19, 2006

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Additional References

•FCC Interpretation Database:•https://svartifoss2.fcc.gov/prod/oet/cf/ri/FccEasRi.cfm

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RF Exposure TutorialWilliam H. Graff, AmericanTCB

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Portable vs. Mobile

• Specific definitions for RF exposure– Mobile – Greater than 20 cm– Portable – Less than 20 cm

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What is SAR?

• Close field phenomenon which occurs when an electromagnetic wave interacts with a biological medium

• Occurs at less than ¼ wavelength

• E and H fields are at relative maximums

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MPE calculation

• MPE calculations assume a linear plane-wave field.

• Considered an overestimate of maximum field density

• Not applicable to distances under 20cm

• Cannot predict interaction with nearby structures

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SAR measurement

• Requires isotropic power measurement systems

• Typically use 3 axis probes in a biological “soup”

• Soup has electrical characteristics nearly identical to tissue at specified frequency

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Example Systems

SPEAG IndexSAR Aprel/IDX

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P1528 §1.4.2 Positioning Rationale

Touch/cheek Tilt

M

RE LE

M

LE

RE

LE15o

M

RE LE

M

LE

RE

LE

(Source: based on IEEE SCC-34/SC-2, P1528 Draft)

M

RE LE

M

LE

RE

LE15oM

RE LE

M

LE

RE

LE15o

M

RE LE

M

LE

RE

LE


M

RE LE

M

LE

RE

LEM

RE LE

M

LE

RE

LEM

RE LE

M

LE

RE

LE


M

RE LE

M

LE

RE

LE15o

M

RE LE

M

LE

RE

LE


M

RE LE

M

LE

RE

LE15oM

RE LE

M

LE

RE

LE15o

M

RE LE

M

LE

RE

LE


M

RE LE

M

LE

RE

LEM

RE LE

M

LE

RE

LEM

RE LE

M

LE

RE

LE


• 2 pos. intended to encompass normal use, may not be worst-case

• 2 pos. are subset of 4 from ES 59005:1998 (CENELEC), where experiences showed that 2 pos. are enough for conservative

• Touch position is most repeatable since it relies on two- or more point contact with phantom; accounts for RF current densities in device case regions

• Tilt position accounts for RF current densities in external antennas and antenna feed-regions at top of handset

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SAR Mapping Systems

1) control and data capture unit

2) field-probe readout electronics

3) dosimetric E-field probe

4) probe positioner

5) unwanted ambient fields

6) phantom shell with tissue-equivalent liquid,

7) device-under-test

8) device holder/positioner.

coarse scan over device outline to locate hot-spots

- beam 3-axis E-field probe

54.7 0

DETECTOR

DIODE

HIGH-RESISTANCE LINES

RESISTIVE DIPOLE

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Head Phantom • SCC-34/SC-2 head model - SAM

(Source: IEEE SCC-34/SC-2, P1528 Draft)

ERP

EEP - entrance to ear canal

15 mm

M

BLE

F

ERP - ear reference point

EEP

M

B

-30

N

F+30

0

+20 0

-60

RE (ERP)

10 mm squareN

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SAR Test Positions

M

B

-30

N

F+30

0

+20 0

-60

RE (ERP)

10 mm square

.

wb/2wb/2

vertical center line

horizontal line

bottom of handset

acoustic output

wt/2wt/2

A

B

.wt/2 wt/2

wb/2 wb/2

acoustic output

horizontal line

vertical center line

bottom of handset

A

B

•point A is “test device reference point”•align point A to ERP on head model•align vertical center line to M-B•align horizontal line to N-F

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Limitations of P1528

• Does not address all body worn configurations

• Does not address methodologies above 3GHz

• Does not address non-standard ear-held devices which do not conform to M to LE or RE line

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SAR Limits

• Experiments with laboratory rats

• Scaled up to humans using known models borrowed from pharmaceutical industry

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Supplement C: Exposure LimitsSupplement C: Exposure Limits(A) Limits for Occupational/Controlled Exposure

Frequency Electric Field Magnetic Field Power Density Averaging TimeRange Strength (E) Strength (H) (S) |E|2, |H|2 or S(MHz) (V/m) (A/m) (mW/cm2) (minutes)

0.3-3.0 614 1.63 (100)* 63.0-30 1842/f 4.89/f (900/f2)* 630-300 61.4 0.163 1.0 6

300-1500 -- -- f/300 61500-100,000 -- -- 5 6

(B) Limits for General Population/Uncontrolled Exposure

Frequency Electric Field Magnetic Field Power Density Averaging TimeRange Strength (E) Strength (H) (S) |E|2, |H|2 or S(MHz) (V/m) (A/m) (mW/cm2) (minutes)

0.3-1.34 614 1.63 (100)* 301.34-30 824/f 2.19/f (180/f2)* 3030-300 27.5 0.073 0.2 30

300-1500 -- -- f/1500 301500-100,000 -- -- 1.0 30

f = frequency in MHz *Plane-wave equivalent power densityNOTE 1: See Section 1 for discussion of exposure categories.NOTE 2: The averaging time for General Population/Uncontrolled exposure to fixed transmitters is not applicable for mobile and

portable transmitters. See 47 CFR §§2.1091 and 2.1093 on source-based time-averaging requirements for mobile andportable transmitters.

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Supplement C: SAR LimitsSupplement C: SAR Limits (A) Limits for Occupational/Controlled Exposure (W/kg)

Whole-Body Partial-Body Hands, Wrists, Feet and Ankles

0.4 8.0 20.0

(B) Limits for General Population/Uncontrolled Exposure (W/kg)

Whole-Body Partial-Body Hands, Wrists, Feet and Ankles

0.08 1.6 4.0

NOTE 1: See Section 1 for discussion of exposure categories.

NOTE 2: Whole-Body SAR is averaged over the entire body, partial-body SAR is averaged over any 1 gram oftissue defined as a tissue volume in the shape of a cube. SAR for hands, wrists, feet and ankles isaveraged over any 10 grams of tissue defined as a tissue volume in the shape of a cube.

NOTE 3: At frequencies above 6.0 GHz, SAR limits are not applicable and MPE limits for power density shouldbe applied at 5 cm or more from the transmitting device.

NOTE 4: The time averaging criteria for field strength and power density do not apply to general populationSAR limit of 47 CFR §2.1093.

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Controlled vs. Uncontrolled

• End users which have a knowledge of radio waves and can limit their exposure can use Controlled limits

• End users which may have no knowledge of the limits must use Uncontrolled limits

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Differences in Limits

• Limit for Controlled exposure in the head = 4W/kg (4mW/g)

• Limit for Uncontrolled exposure in the head = 1.6W/kg (1.6mW/g)

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When is SAR testing required?

• FCC maintains two threshold limits – one for itself and another for TCBs.

• TCBs must always follow TCB Exclusion List of July 17, 2002

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Portable PTT

• Part 80, 90, 95

• FCC – SAR data required for PTT above 1W radiated or conducted

• TCB – 60mW/f(GHz)

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Portable 15.247 and 15.407

• Below 3GHz– FCC – SAR data if above 50-100mW– TCB – 60mW/f(GHz)

• Above 3GHz– FCC – SAR data if above 50mW– TCB – cannot do– ***By law, SAR data required for all portable

UNII devices regardless of Pout

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Modules

• No such thing as RF category “Portable” modular approval. (Same FCC or TCB)

• Full modular approvals are only permitted for RF category “Mobile” modules

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LMA and SAR

• Limited Modular Approvals are permitted but only for carefully defined host platforms.

• Hosts must have similar mechanical constructions.

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Three Host Method

• RF category “Portable” modules are permitted under specific circumstances and specific hosts.

• Testing to be performed in three each portable devices (i.e. notebook PC, PDA, etc.)

• Unlimited “Portable” modular approvals never permitted

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Simultaneous Transmission

• If radiating structures <20cm then simultaneous transmission may be of concern.

• FCC evaluates co-located devices with simultaneous transmission

• TCB cannot per TCB Exclusion List if second non-dominate transmitter above 5mw

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Above 3GHz

• IEEE P1528 does not yet define a methodology for SAR testing above 3GHz, therefore all SAR evaluation above 3GHz must go to FCC

• Expect approvals from FCC to take 90 days

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RF Safety Documents for Issues with Human Exposure

• ANSI C95.1

• OET 65

• OET 65-C

• FCC Part 1.1037

• FCC Part 2.1091 Mobile Devices

• FCC Part 2.1093 Portable Devices

• TCB Exclusion List

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Future Provisions

• Additional guidance on body-worn configurations

• Release of procedure for TCBs to evaluate SAR above 3GHz– Likely to be timed with release of DFS

procedure to TCBs

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Questions?

atcb.comwww.atcb.com

R&TTE DirectiveMichael Violette, P.E.

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European R&TTE Directive

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European R&TTE Market

• R&TTE equipment: 58 b € /year in the EU – Machinery market: >250 b € /year– Telecommunication Services: 200 b € /year

• Diverse industry– Big Companies (Nokia, Ericsson, Motorola, Siemens, Philips,

Alcatel, Nortel)– Many SMEs in e.g. Short Range Radio markets

• Before R&TTE Directive: Many different requirements– > 1000 national regulations, around 30 harmonised EU regulations– fragmentation of spectrum

• After R&TTE Directive: less fragmented• Total sectors covered by EMC Directive: 250 b€

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EU Market

• May 1st 2004 Members of EU:• Austria, Belgium, Denmark, Finland, France,

Germany, Greece, Ireland, Italy, Luxembourg, The Netherlands, Portugal, Spain, Sweden, United Kingdom, Cyprus, Czech Republic, Estonia, Hungary, Latvia, Lithuania, Malta, Poland, Slovakia, Slovenia

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R&TTE• For wired and wireless

telecommunications equipment

• Covers the following aspects:– Efficient use of spectrum– EMC– Safety

• Includes EMC and Low Voltage Requirements

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R&TTE Approval Process

• CE Marking by manufacturer is allowed

• Self-Declaration for many products

• Reduced approval procedures and processes

• Harmonized standards developed

• Faster, cheaper, more market coverage for SME

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Annexes• Annex I: Things NOT covered

– Cables, Receive-only broadcast, Kits, Aviation and Air Traffic, marine

• Annex II: Internal Production Control– Basis for all Annexes (good documentation!)

• Annex III: Annex II + Testing– Type testing

• Annex IV: TCF– Notified Body (for new technologies)

• Annex V: Full QA– Accredited Quality Assurance System

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R&TTE Testing• No longer requires involvement of

accredited test house• Test to harmonized standards

– DoC– CE Marking– Ship

• Non-harmonized frequencies:– Notification to Governments– Alert Signal (Equipment Class Identifier)– Restricted Geographical Area

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TCF & NB Opinion

•For new technologies WITHOUT harmonized standards

•Notified Body or Conformity Assessment Body opinion

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TCF Documentation

• Product description• Conceptual design and manufacturing drawings such as

schematics and subassembly drawings • A description and explanation of the drawings,

schematics, and operation of the product • A list of all standards that were applied, in full or in part,

to show compliance.– If standards were not used or do not exist, then a description

and explanation of the solutions used to meet the essential requirements of the directive must be included

• Results of design calculations and examinations• Test reports• A copy of the DoC

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Self Certification (ALL Harmonized)

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Self Certification (Standard Harmonized,

Frequency NOT harmonizedNotification required)

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Standard NOT Harmonized, Notified Body

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Which way to go?

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Harmonized Frequencies(Short Range Devices)

• Document CEPT 70-03– Lists frequencies and usage in different European

countries

• Published by: European Conference of Postal and Telecommunications Administrators

• Available at: http://www.atcb.com/techlib/index.asp

• European Radiocommunications Office link to National Frequency Plans:– http://www.ero.dk/EEE33BA9-9EE9-4252-AD6C-BE7EFB81898.W5Doc

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Examples from CEPT 70-03

http://www.atcb.com/techlib/index.asp

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Notification

• Applies to radio equipment using a non-harmonized frequency

• If non-harmonized frequency band, the manufacturer must determine if the frequency is available for use in a particular member state

• Notify each member state where the equipment is to be sold

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Notification

• Notify the Spectrum Authorities in each member state

• Must be made 4 weeks prior to the equipment being offered for sale.

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Identify Requirements

• Market (Countries)

• Restrictions (CEPT 70-03)

• Harmonized Standards? (Official Journal)

• TCF/Notified Body

• Test Suite

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Example ETSI/EN Standards• Available from www.etsi.org (free!)• Telecom, EMC & Radio Matters• EN 300 386:

– Electromagnetic compatibility and Radio spectrum Matters (ERM); Telecommunication network equipment; ElectroMagnetic Compatibility (EMC) requirements

• ETS 300 328: – Radio Equipment and Systems (RES); Wideband transmission systems;

Technical characteristics and test conditions for data transmission equipment operating in the 2,4 GHz ISM band and using spread spectrum modulation techniques

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Getting the CE MarkingProcedure for Harmonized Standard

• Look in ERC Report 70-03 for Country Restrictions and Harmonized Standard

• Test product to standard

• Notify Spectrum Authorities

• Prepare final documentation

• Label device

• Ship

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Classification• Class 1: equipment, which can freely move and

be switched on in the Community (wired equipment, GSM, Receive-only equipment, etc.)

• Class 2: equipment, for which this is not the case (transmitters, which are to be licensed)

– Marking: simple marking scheme agreed between Member States:

• CE mark only for class 1 equipment (+ NB Numbers)

• CE mark + for class 2 equipment (+ NB Numbers)

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Examples

• Short Range Device (SRD) Operating at 433 MHz

• Spread Spectrum WLAN/RLAN operating at 2.4 GHz

• GSM phone operating at 900 MHz band

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Example 1: Short Range Device (SRD)

• Equipment Parameters:– 433.92MHz– Low power <2.5mW– Modulation: FSK– Duty Cycle: <1%– Integral Antenna– Battery Powered– “Non-Specific Short Range Device”

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Example 1 SRD:ERC 70-03 Restrictions

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Example 1 SRD:ERC 70-03 Technical Restrictions

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Example 1 SRD: ERC 70-03 Standards to Apply

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Example 1 SRD: Full R&TTE Requirements

• Compliance test requirements– Radio: EN 300 220-3

• Radio and Spectral Matters

– LVD: EN 60065– EMC EN 301 489-3 (SRD)

• Emissions• Immunity

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Example 1 SRD: Documentation

• Requirements1. Equipment complies: Test report/TCF

2. Generates and signs DOC

3. Labels equipment

4. Notifies countries before marketing (Only if frequencies are not harmonized)

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Example 2:Spread Spectrum WLAN/RLAN

• Equipment Parameters:– 2400-2483.5 MHz– Power <100mW EIRP– Duty Cycle: No Restriction

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Example 2 RLAN: ERC 70-03 Restrictions

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Example 2 RLAN:ERC 70-03 Technical Restrictions

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Example 2: ERC 70-03Standard to Apply

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Example 2: Standard to Apply

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Example 2 RLAN: Full R&TTE Requirements

• Compliance test requirements– Radio: EN 300 328

• Radio and Spectral Matters

– LVD: EN 60950– EMC EN 301 489-17 (RLAN)

• Emissions• Immunity

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Example 3: GSM Phone

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Example 3 GSM Phone: Harmonized Standard for BS

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Example 3 GSM Phone: Harmonized Standards for Handsets

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RF Exposure

• Harmonised Standards for Electromagnetic Fields

• EN50360 & EN50361 for handsets

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Labeling SummaryRoute to

Compliance Frequency Allocation

Notified Body Used Marking

No CE mark

Harmonized Yes

CE mark

NB number

No CE mark ECI

Standards route

Nonharmonized

Yes CE mark NB number ECI

Harmonized Yes CE mark NB number

Technical construction

file route Nonharmonized Yes

CE mark NB number ECI

Harmonized Yes CE mark NB number

Full quality assurance route

Nonharmonized Yes CE mark NB number ECI

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R&TTE Labeling Example

NAME OF A COMPANY

MODEL NUMBER

SERIAL NUMBER

FREQUENCY BAND

nnnn

The Notified Body Number: used when either annex III, IV or V have been used

Alert symbol used when frequency is not harmonized

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Conclusions

• Much simpler than in years past

• CE Marking allows access to multiple markets

• Frequencies increasingly harmonized

• Good access to ETSI/EN standards

• Worldwide product designs possible for many types of products.

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Thank You!