Posted 01/17/2023: UPDATES TO THE TRANSITION PERIOD UNTIL FURTHER NOTICE
Attachment "447498 D04 Interim General RF Exposure Guidance v01" can be used for equipment authorization and must be used in its entirety along with any other associated revised KDB RF exposure procedures and policies (including FCC-TCB conference presentations) during a transition period in effect from August 13, 2022 until further notice.
Notification of the end of this transition period will be provided well in advance before use of any new published guidance is required.
The previous version, "447498 D01 General RF Exposure Guidance v06," may also be used during this transition period as long as the 731 Form and the related granted application are submitted to the FCC on or before the end of transition period. "447498 D01 General RF Exposure Guidance v06" must be used entirely (i.e., no mixing of old and new procedures for certification application filing(s)).
To clarify our guidelines and in response to questions from interested parties regarding required documentation, we provide the following information: during this transition period, all applications for equipment certification of RF devices shall include at least one exhibit that addresses compliance with the RF exposure KDB guidance. This exhibit must also be included for equipment where the applicant is claiming exemption from RF exposure testing. Contributions from unintentional or incidental radiators are not required to be included in this assessment at this time. This exhibit shall illustrate how the guidance in the applicable KDB 447498 has been followed: as explained in the previous paragraph, by adhering to the guidance in either KDB 447498-v06, or KDB 447498-D04; applicants must follow a single KDB guidance and may not mix and match portions of each for showing compliance.
After the end of the transition period, all applications must only use new procedures which will be published as "447498 D01 General RF Exposure Guidance v07", replacing "447498 D01 General RF Exposure Guidance v06." When the new 447498 D01 General RF Exposure Guidance v07 becomes available, we will provide notice regarding the transition period for compliance with the updated guidance.
The only exception is for cases where certification application(s) include items subject to Pre-Approval Guidance (PAG, KDB Publication 388624) submitted prior to the end of the transition period. In this case, the TCB can grant the device after the end of transition period, using either "447498 D04 Interim General RF Exposure Guidance v01" or "447498 D01 General RF Exposure Guidance v06," after the PAG is approved.
Posted 08/24/2023. Interim Guidance for RF Exposure Compliance of Devices Equipped with Motion Sensor for Conducted Power Control
Guidance is here provided in regard to RF devices that use motion sensors to detect a "on-body" use conditions, in order to control the RF conducted power to maintain RF exposure compliance. For these cases, it is also necessary to address "off-body, but close" use condition, such as the device on a stationary surface (e.g., a table), thus with the motion sensors not triggered and therefore operating at maximum power, but close enough to a person's body to pose RF exposure compliance concerns.
Accordingly, it is possible to consider that, if the particular device under test (DUT) is shown to be RF-exposure-compliant at 25 mm without any power reduction, then any off-body use will also lead to an exposure that, on average, is within the compliance threshold. This argument is based on the fact that, for this particular DUT under consideration, operations at distances closer than 25 mm will likely lead to contact with the DUT, even temporary or accidental, thus triggering the motion-sensor-based power reduction feature.
This consideration is applicable only on a case-by-case basis, and cannot be generalized, nor provides a precedent to support similar applications/devices, therefore, it can be leveraged only after the related application for certification has been approved for the PAG item"PWRDYN".