Comments on OET Lab Policy Document

There have been 12 comment(s) made on this document:

Steve Liu commented on 2011-09-14 12:41:02.156:
Also a grammatical note, the SAR should be "is" and not "are": The highest reported SAR for head, body-worn accessory, product specific (wireless router), and simultaneous transmission use conditions IS #.## W/kg, #.## W/kg, #.## W/kg, and #.## W/kg, respectively

Steve Petruska commented on 2011-09-12 15:27:42.396:

Regarding item 4, as others have commented, clarification is needed to understand how the SAR value will be indicated on the grant when the sum of the 1g SAR for each stand-alone SAR value is >1.6W and the SAR to Peak Location Separation Ratio is <0.3. In this case it seems a SAR value could be stated on the grant that exceeds the limit, although no simultanous transmission SAR measurement was required.

Our concern is how to present this information in the user manual for the device. We understand that the FCC rules do not require the SAR value(s) to be stated in the manual, but if it is provided it should not differ from, or contradict, the SAR values indicated on the FCC grant(s).

Kai Niskala commented on 2011-09-12 09:11:31.146:
Regarding Clause 4): We understand the texts SAR exclusion and SAR test exclusion to mean either: 1: {Max SAR + Max SAR} < 1.6W/kg or 2: {Max SAR + Max SAR} > 1.6W/kg AND {Max SAR + Max SAR}/Separation between SAR peaks < 0.3. With regard to Clause 4a): in the case of {Max SAR + Max SAR} > 1.6W/kg, but the ratio of {Max SAR + Max SAR}/Separation distance < 0.3, this clause as currently drafted requests that either the {Max SAR + Max SAR} value or the Max Cellular/AWS/PCS SAR value appears on the Grant. Here the former value > 1.6W/kg so some clarification of this clause is requested. With regard to Clause 4b): we understand both of the SAR exclusion conditions to mean both of the exclusions 1: and 2: above but these cannot both apply as they are mutually exclusive. The intention of this clause should be clarified. Regarding Clause 5): As drafted, the text appears to require only a single SAR value for simultaneous transmission. As many devices nowadays are routinely capable of simultaneous transmission against both the Head and the Body, it is suggested that the example format be extended to cover both Head and Body-worn use conditions. Regarding Clause 8): For the 1st bullet point: as drafted, the text appears to require only a single SAR value for simultaneous transmission. As many devices nowadays are routinely capable of simultaneous transmission against both the Head and the Body, it is suggested that the example format be extended to cover both Head and Body-worn use conditions. General comment regarding listing simultaneous transmission SAR values on the Grant: Nokia - like many mobile manufacturers - is a global mobile manufacturing company that tries to use global SAR testing rules whenever possible. Various methods for evaluating simultaneous SAR - including FCCs adopted approach of extended zoom scans - are available in IEC62209-2 (Body-SAR measurement Standard) and are currently being drafted into IEEE1528 and IEC62209-1. Nokia has adopted one of these methods (calculating the 3D zoom scans from 2D measured data -> adding the zoom scans together -> calculating simultaneous SAR values from the composite scan) as the company standard method. Even when simultaneous transmission SAR evaluation is not required according to FCC rules, Nokia always presents simultaneous SAR values (calculated according to this adopted method) in FCC SAR reports. Nokia requests that when FCCs simultaneous transmission rules do not apply, it is permitted to report simultaneous SAR values on the Grant calculated according to an alternative method of assessment.

Bill Graff commented on 2011-09-09 19:16:59.483:
I believe the FCC should try and provide more guidance to manufacturers/applicants on how to list the SAR values in their manuals. Either that or simply allow manufacturers/applicants to direct consumers directly to the FCC website. This added complexity will be tough for them to swallow.

Steve Liu commented on 2011-09-08 17:04:52.36:
For a single product with let's say PCB, NII and DTS equipment classes, do we use the highest simultaneous SAR for all three, or do we need to go through the data to figure out the highest simultaneous SAR that involves the particular equipment class transmissions? We ask this because when the end-user looks up the grant, they are looking up a single product, so we wanted clarification from FCC whether FCC prefers the same simultaneous Tx SAR. Much like the body-worn distance harmonization across equipment classes because of the fact that the subject device is one product. Thank you.

Chris Harvey commented on 2011-08-31 11:40:26.85:
This is my favorite Draft KDB: We are requested to list the highest SAR of each Equipment Class on the Grant for that Equipment Class. For devices with multiple Equipment Classes each Grant will indicate "The highest reported SAR for the device is #.## W/kg" BUT the SAR values will be different on each of the Grants which is likely to cause confusion when different Grants state that the highest SAR for the Device are different. Also, please clarify the guidance in item #4 regarding simultaneous transmission SAR as it is not clear how this should be stated on the Grants (how to list on Grant for sum >1.6W/kg but SPLSR <0.3 and no measurement needed).

Chris Harvey commented on 2011-08-30 06:25:07.183:
Shall Users Manuals that list the SAR values also change the wording format to match the format being proposed in this Draft KDB? historically, the manuals that listed the SAR values followed the old listing format that was found on the grants.

Randy Clark commented on 2011-08-29 20:13:03.666:
In the case where equipment satisfies RF Exposure compliance requirements by exemption (for example 15.247 device with power output of 0.01mW), should a grant note be universally applied such as, "This equipment satisifies RF Exposure requirements by exempltion." For modules falling into the same category, should an additionl comment be applied such as, "This equipment has not been evaluated for RF Expousue under simultaneous transmission conditions."

Chris Harvey commented on 2011-08-23 11:44:29.0:
One clarification is requested regarding Hot-Spot or Personal Wireless Router listing for a handset. Hot-Spot mode is a Simultaneous Transmission Use Condition, so it is assumed that this SAR value listed on the Grant would be a sum or simultaneous SAR value. If this is the only Simultaneous Transmission Use Condition for the device, shall the same value be listed for both Product Specific (Wireless Router) and Simultaneous Transmission Use Condition listings on a Grant? or would listing this value once as Simultaneous Transmission Use Condition (Wireless Router) be acceptable?

Chris Harvey commented on 2011-08-23 11:42:50.126:
One clarification is requested regarding Hot-Spot or Personal Wireless Router listing for a handset. Hot-Spot mode is a Simultaneous Transmission Use Condition, so it is assumed that this SAR value listed on the Grant would be a sum or simultaneous SAR value. If this is the only Simultaneous Transmission Use Condition for the device, shall the same value be listed for both Product Specific (Wireless Router) and Simultaneous Transmission Use Condition listings on a Grant? or would listing this value once as Simultaneous Transmission Use Condition (Wireless Router) be acceptable?

Chris Harvey commented on 2011-08-23 11:42:36.463:
One clarification is requested regarding Hot-Spot or Personal Wireless Router listing for a handset. Hot-Spot mode is a Simultaneous Transmission Use Condition, so it is assumed that this SAR value listed on the Grant would be a sum or simultaneous SAR value. If this is the only Simultaneous Transmission Use Condition for the device, shall the same value be listed for both Product Specific (Wireless Router) and Simultaneous Transmission Use Condition listings on a Grant? or would listing this value once as Simultaneous Transmission Use Condition (Wireless Router) be acceptable?

Chris Harvey commented on 2011-08-19 09:25:13.72:
item 2 which indicates: "Grant listings should use the less-than symbol for all values less than 0.10; i.e., SAR < 0.10 W/kg." seems to contradict the first statement for rounding to 2 decimal places. Rounding to 2 decimal places the statement should read: "Grant listings should use the less-than symbol for all values less than 0.01 W/kg; i.e., SAR < 0.01 W/kg." [note i changed the value to 0.01 and added the units of measurement.]

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.

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