• Mike Ramnath commented on 2010-11-10 12:22:12.17:
  Motorola (EMS) generally agrees with the rationale underlying the SAR-driven approach used to develop the protocol illustrated in the draft KDB 643646 in order to allow test reductions according to a conservative compliance framework. As outlined in the following, several amendments are requested in order to enhance the operational efficiency gains offered by the KDB and to conform to well-established practices regarding the radio/accessory configurations requiring testing. Clarification is also sought to facilitate the unambiguous implementation of the test reduction protocol. 1. The current draft (in "Body SAR Test Considerations for Body-worn Accessories") requires that all body-worn accessories be tested with all antennas and all batteries (unless any body-worn accessory, antenna, or battery can be excluded due to similarity). It is requested that the protocol be amended in order to increase operational efficiencies without compromising its conservativeness, by allowing the test of the thinnest battery only with all antennas and body-worn accessories. This corresponds to performing the antenna search for each individual body-worn accessory while using the thinnest battery. In this way, the two prominent ”parameters” influencing SAR (i.e., antennas and body-worn accessories) are evaluated in a conservatively-biased condition (i.e., thinnest battery) before moving to the subsequent battery and the audio accessories searches. As already specified in the draft KDB, the thinnest standard battery with the highest capacity should be employed. 2. The current draft (in "Body SAR Test Considerations for Body-worn Accessories") requires testing the radio with a body-worn accessory and no audio accessory (unless the radio features a single audio accessory, which is extremely rare for Motorola professional two-way PTT radios). Such a configuration is not among the intended-use configurations; therefore such a requirement represents a drastic departure from the well-established practice of requiring the SAR testing of intended-use configurations (those that replicate the actual user's exposure) only. As a matter of fact, with the sole exception when the radio features a wireless PTT-enabled audio accessory, e.g., via Bluetooth, the user cannot clearly and readily communicate while the radio is worn at the belt unless a PTT-enabled audio accessory is physically attached to the radio. As a consequence, the SAR values measured in such unintended-use configurations would not be representative of actual user's exposure. Even so, according to the current draft KDB, those SAR values will be used to make decisions that may significantly impact (and potentially increase unnecessarily) the number of subsequently required tests. This is possible because the test reduction protocol in the current draft KDB is based on phased decision criteria to determine the next set of required tests from the measured SAR values up to each decision point. It is requested that the aforementioned provision be amended so as to require that one audio accessory be employed in every body-worn SAR tests, and more broadly to explicitly reaffirm that only intended-use accessory configurations be tested throughout the execution of the test protocol. Motorola two-way PTT radios typically comprise at least one audio accessory that is compatible with all batteries, body-worn accessories, and antennas. It is also requested that the KDB clearly state that the SAR values that are considered relevant to the product compliance are only those associated with the intended-use accessory configurations. 3. The current draft (in "Head SAR Test Considerations" 2) A)) requires that "Justifications for antenna similarities must be clearly explained in the SAR report." It would be useful if the KDB provided examples of acceptable justifications, such as same antenna length, SAR values within one system uncertainty, and similar SAR distributions.

---

Note: It is important to understand that the staff guidance provided in the KDB is intended to assist the public in following Commission requirements and does not constitute rules. Accordingly, the guidance is not binding on the Commission and will not prevent the Commission from making a different decision in any matter that comes to its attention for resolution.