FCC Certification: FCC Proposes Major Changes to Certification Rules
On February 15, 2013, the FCC released a Notice of Proposed Rulemaking to amend FCC Parts 0, 1, 2, 15, and 68. The PDF document can be found here (ET Docket No. 13-44 RM-11652).
The changes proposed by the FCC will affect the TCB Program, Test Laboratory Accreditation and Validation, and recognized Measurement Procedures; and have an implementation transition period of one year after publication of the rules in the Federal Register.
The TCB Program:
The telecommunications certification body (TCB) program, which has been implemented since June of 2000, is well established; and the FCC is proposing to no longer directly issue any grants of equipment authorization for wireless products or modules, but instead allow TCBs to authorize all wireless products subject to certification. This would include eliminating the current KDB TCB Exclusion List of device types which still require the Commission for certification, but also implementing a "pre-approval" process for specific product types which would require TCB to receive the Commissions concurrence prior to granting an equipment authorization. This transfers the authority for granting certification to the TCB, while still allowing the Commission oversight and control of these special product types; at least until such time that the Commission determines oversight is no longer requisite.
In addition, the FCC is proposing changes to the post-market surveillance rules to clarify the authority of TCBs when requesting samples from grantees, and procedures for when the Commission requests a TCB perform surveillance on a specific device, as well as procedures in the event a non-compliance is discovered.
The Commission is also seeking input regarding logistics, counterbalancing influences, and minimizing the expense of these post market surveillance efforts. Suggestions such as sample request methods that limit solicitation duplication, cross-checking efforts amongst TCBs, and how the burden of expense for these efforts are distributed are currently under proposal.
A clarification of the role NIST will have in the designation of domestic TCBs, along with clarification of the process with which a laboratory must follow to demonstrate competence as a TCB. With the proposal of added authority for all equipment authorization for TCBs, the Commission is also proposing new corrective programs when deficiencies are discovered with a TCB, and under current rules there is no recourse other than withdrawal of the TCBs designation or recognition. These efforts would be designed specifically for performance issues that the Commissions recognizes can be resolved with simple corrective actions by the TCB.
Test Laboratory Accreditation and Verification:
One of the most significant changes being proposed has to do with a change to the Commission's requirements for Test Laboratories, the acceptance of data based upon accreditation, and the requirements for measurement sites.
Currently there are three authorization procedures: Certification, Declaration of Conformity (DoC), and Verification. Certification is a grant of equipment authorization issued by the Commission or TCB based on the submittal of an application and test data; a Declaration of Conformity is a statement of conformance to the requirements with the appropriate technical standards but isn't requisite for a grant of equipment authorization from the Commission or TCBs, just a statement supplied with the product; and a verification requires no application for a grant of equipment authorization, nor a statement of compliance, just performance of measurements which ensure the equipment complies with appropriate technical standards.
Under current Commission rules, only DoC procedures requires laboratory accreditation to the requirements of ISO/IEC 17025; however, under this proposal, accreditation will be required for laboratories performing certification as well, with the most significant effect being that any testing performed in countries without a US MRA may not be accepted for Part 15 or Part 18 certification.
Additionally, the proposal will update the test site validation requirements to those specified in ANSI C63.4-2009 for emissions below 1GHz, and the Site VSWR requirements specified in CISPR 16-1-4 for emissions in the range of 1GHz to 40GHz.
The Commission is also proposing To incorporate ANSI C63.4-2009 and ANSI C63.10-2009 for determining the compliance of unintentional and intentional radiators respectively. However, the Commission will not acknowledge the use of rod antennas below 30MHz, artificial hand for handhold devices, or absorber clamps for radio noise power measurements due to insufficient evidence that they produce accurate, repeatable measurements. Additionally, it will not observe relaxation of limits for emissions of a transient nature resulting from findings which demonstrate that brief durations in emissions still produce nuisance interference.
As of the publishing of this blog, the FCC will continue to review comments regarding the proposed rulemaking for another 4-5 weeks, with responses to comments following 30 days later.