Comments on OET Lab Policy Document

There have been 11 comment(s) made on this document:

Brian Scarpelli commented on 2012-06-29 16:43:06.686:
The Telecommunications Industry Association (TIA) hereby submits input to the Federal Communications Commissions (FCC) Office of Engineering and Technology (OET) on draft Laboratory Division Knowledge Database (KDB) publication 447498 (KDB 447498). Specifically, TIA submits the following input for OETs consideration: TIA hereby expresses concerns about the provisions of KDB 447498 that require phone manufacturers to accept responsibility for products marketed by third party accessory providers. The language regarding third party accessories on page 7, paragraph (2)(i)(b), is overbroad by sweeping in types of body-worn accessories users may acquire that are sold outside the control of the phone manufacturer. TRPC believes that the intent of the provision is to assure that phone manufactures provide guidance to consumers sufficient to enable them to know how use the handset with accessories and maintain compliance with FCCs exposure guidelines. That requirement is already part of paragraph 2(d). Accordingly, paragraph 2(i)(b) is unnecessary and the language appears overbroad. We strongly recommend that it be taken out of the KDB. In Section (IV)(B)(2)(i)(d)(i) it is stated that specific information must be provided in the User Manual, including "All unsupported body-worn accessories and operating configurations (emphasis added) must be clearly disclosed to users through conspicuous instructions in the user guide or manual to ensure such operations are avoided." No manufacturer could anticipate all possible unintended modes of operation. Any attempt to do so would, by its very nature, not be comprehensive, and would potentially mislead the user by omission. It seems more reasonable to define the intended modes (e.g. minimum spacings for use at the body). The test reduction in Section IV(C) should be updated to include the specific absorption rate (SAR) exclusion for modes where higher power bands have been tested. We urge OET to aim to reduce test cases where lower SAR levels have been demonstrated. OET had indicated that additional review was being proposed for module integrations including RF exposure. We encourage additional discussion before implementing these into official test procedures. A review of the 1.2 level for Permit But Ask (PBA) approval should be addressed and modified based on unique design characteristics and low SAR value. Given the potential impact of the proposed KDBs on test time, lab capacity, and even product design, we request that OET determine and announce a reasonable transition period for implementation of the KDBs once finalized. TIA members recommend that a transition period of at least ninety days in order to mitigate the impact that such extensive changes to testing protocols will have. TIA has previously requested an extension of the due date for comments on draft KDBs as critical to industrys ability to provide thoughtful comments. In order to facilitate review of industrys concerns, TIA may submit comments to selected KDBs, subject to supplementation, after June 30, 2012. We therefore respectfully submit this comment to draft KDB 447498, and urge the Commission to adopt policies consistent with the above. View attachment associated with this comment

Chuck Powers commented on 2012-06-29 16:41:31.483:
1. KDB 447498 [Page 6, section iv (A) 4]: The FCC should not impose on two-way radio manufacturers an impossible obligation to foretell all possible use configurations and produce compliance evidence based on every conceivable off the shelf accessory, some of which may still be in development or only sold overseas by aftermarket accessory suppliers during product compliance testing. The best solution, indeed the only one that is workable and reliable, is to require the radio manufacturers to continue to clearly instruct users on how to use their radios in a compliant manner and to provide them with a readily accessible list of approved accessories that have been verified to be compliant with a particular radio. 2. KDB 447498 [Page 24, section VII (A) item 6 (i,ii)]: Item 6 (i) requires manufacturers to assess MPE compliance in all directions surrounding the antenna and radiating structure of the device if the antenna does not meet the condition (a) and/or (b) of this item, and item 6 (ii) indicated the evaluation points in the horizontal planes should be at 30 degrees or 45 degrees apart depending on the test distance from the antenna. This seems to be inconsistent with a similar requirement in the proposed KDB 643646 revision, where only angles greater than or equal to 45 degrees are required. More importantly, this requirement will increase the MPE test cycle time for a bystander by 4x for the 45 degree (-90, -45, 45, 90) and 6x for the 30 degree (-90, -60,-30, 30, 60, 90) assessments. We propose that the angular scans be required only for the highest MPE condition found for a certain product, not for all the tests as proposed. The additional cost of applying the proposed test protocol is not justifiable given that MPE tests are more conservative than the SAR, as shown by the fact that SAR simulations have so far shown compliant results even when MPE was above the limit. 3. KDB 447498 [Page 24, section VII (A) item 6 (iii)]: Item 6 (iii) requires the evaluation points in the vertical direction to be at least 10cm beyond the exposed portion of a persons body or until the evaluated results are <10% of the MPE limit. We propose that the measurements be performed over a 2 m vertical line as currently accepted by the FCC, and to remove the consideration about the 10% of the MPE limit. MPE measurements have consistently been shown to be more conservative than SAR ones, but they are frequently employed to demonstrate compliance since they require less time and simpler equipment. Making this method more complex negates the aforementioned efficiency gains. 4. KDB 447498 [Page 24, section VII (A) item 6 (iii, a)]: Item 6 (iii, a) indicates that the spatial resolution of the evaluation points (in vertical direction) should be 10cm. This new requirement will increase the MPE test cycle for bystanders by 2x because currently FCC accepts MPE tests with 20 cm distance between measurement points. We propose that the distance between measurement points be kept at 20 cm, also in view of the fact that MPE measurements have consistently been shown to be more conservative than SAR ones.

Chuck Powers commented on 2012-06-29 16:33:06.89:
1. KDB 447498 [Page 24, section VII (A) item 6 (i,ii)]: Item 6 (i) requires manufacturers to assess MPE compliance in all directions surrounding the antenna and radiating structure of the device if the antenna does not meet the condition (a) and/or (b) of this item, and item 6 (ii) indicated the evaluation points in the horizontal planes should be at 30 degrees or 45 degrees apart depending on the test distance from the antenna. This seems to be inconsistent with a similar requirement in the proposed KDB 643646 revision, where only angles greater than or equal to 45 degrees are required. More importantly, this requirement will increase the MPE test cycle time for a bystander by 4x for the 45 degree (-90, -45, 45, 90) and 6x for the 30 degree (-90, -60,-30, 30, 60, 90) assessments. We propose that the angular scans be required only for the highest MPE condition found for a certain product, not for all the tests as proposed. The additional cost of applying the proposed test protocol is not justifiable given that MPE tests are more conservative than the SAR, as shown by the fact that SAR simulations have so far shown compliant results even when MPE was above the limit. 2. KDB 447498 [Page 24, section VII (A) item 6 (iii)]: Item 6 (iii) requires the evaluation points in the vertical direction to be at least 10cm beyond the exposed portion of a persons body or until the evaluated results are <10% of the MPE limit. We propose that the measurements be performed over a 2 m vertical line as currently accepted by the FCC, and to remove the consideration about the 10% of the MPE limit. MPE measurements have consistently been shown to be more conservative than SAR ones, but they are frequently employed to demonstrate compliance since they require less time and simpler equipment. Making this method more complex negates the aforementioned efficiency gains. 3. KDB 447498 [Page 24, section VII (A) item 6 (iii, a)]: Item 6 (iii, a) indicates that the spatial resolution of the evaluation points (in vertical direction) should be 10cm. This new requirement will increase the MPE test cycle for bystanders by 2x because currently FCC accepts MPE tests with 20 cm distance between measurement points. We propose that the distance between measurement points be kept at 20 cm, also in view of the fact that MPE measurements have consistently been shown to be more conservative than SAR ones.

Ying Wang commented on 2012-06-29 14:54:03.9:
Suggest removing V.A.1 (b) (iii) and (iv), because these two provisions would cause confusion among different transmitter grantees with regards to each partys responsibility, especially when subsequent permissive changes are performed to one or more transmitters. VII.A.6 seems to suggest that simple MPE calculation is not permitted to use when routine evaluation is required. This is inconsistent with many of the existing FCC filings for mobile devices and also contradictory to OET Bulletin 65, which permits the use of simple equations for MPE calculation. The Class I permissive changes referred in VII.B.1 should not apply if all those conditions have been addressed in the initial filing and included in the FCC grant note, in which case there isnt a change to the condition permitted by the grant.

Mats Hansson commented on 2012-06-29 08:47:12.026:
IV General RF Exposure Test Guidance A 4: During discussions with our different test facilities and TCB we have seen different interpretations on this topic. Our understanding is that we can use a device with normal production tuning (maximum 2dB tuning tolerance) for SAR compliance testing. The measured value is included in the report and scaling is applied of the measured SAR value up to the maximum allowed production level. The scaled value is included in the test report, grant and end user SAR information in order to be consistent in all reporting. The highest reported SAR value would be the highest SAR value from the scaling of the measured values Please clarify if this is the intentional use of the scaling. Please clarify if the maximum 2 dB tuning tolerance is +/- 2 dB or +/-1dB B 3 Extremity exposure conditions (iv) Please clarify irregular shapes and form factors Our understanding is that most mobile phone devices today has a normal form factor that can easily be applied to the phantom for SAR testing. Such devices would then not be subject for a FCC inquires. Products shaped as boll or banana or other extreme shapes would be subject for a FCC inquire. Its understandable that its not possible to be fully clear in referring to irregular shapes and forms. But in order to give some guidance for manufacturers and certification bodies it would be good with some clarifications.

John Forrester (Qualcomm) commented on 2012-06-27 02:11:09.29:
Please see the attached document. View attachment associated with this comment

Steve Liu commented on 2012-06-26 10:43:49.203:
Thank you for your work in updating these KDBs. PCTEST submits comments regarding this draft publication in the attached file. Thank you. View attachment associated with this comment

John Lewczak commented on 2012-06-25 10:07:53.043:

[KDB 447498, General RF Exposure Guidance; Section (IV)(B)(2)(i)(d)(i)] - Unsupported Configurations Subject KDB states that specific information must be provided in the User Manual, including "All unsupported body-worn accessories and operating configurations must be clearly disclosed to users through conspicuous instructions in the user guide or manual to ensure such operations are avoided."

Taken literally, this suggests that the user guide must anticipate any possible unintended mode of operation. This puts an onerous burden on manufacturers, and would result in the portion of the manual dedicated to regulatory considerations growing larger and more unreadable, thus undermining its intended purpose.

John Lewczak commented on 2012-06-25 10:03:07.723:

[KDB 447498, General RF Exposure Guidance; Section (IV)(B)(2)(i)(b)] - Third Party Accessory Subject KDB appears to contain provisions that hold phone manufacturers accountable for products marketed by third party accessory providers. On Page 7, the KDB states:

A conservative minimum separation distance for supporting off-the-shelf body-worn accessories that may be acquired by users should be used to test for body-worn accessory SAR compliance for consumer handsets. The distance should be determined according to the device form-factor and types of body-worn accessories users may acquire and fully justified in the SAR report.

This language is overbroad and imposes impossible conditions on phone manufacturers. Not only does it appear to require manufacturers to be aware of all third party accessories on the market at the time a product is introduced (accessories that may be acquired by users) but it would hold manufacturers accountable for products subsequently introduced into the marketplace i.e., types of body-worn accessories users may acquire.

No doubt, such a broad reach is not be intended by the FCC Lab in drafting the KDB. However, the language contains no limitations on the extent of knowledge of third party products that a phone manufacturer will be held to. As a realistic matter, manufacturers can do more with regard to off-the-shelf accessories than define the compliance distance. Given that paragraph 2(d) imposes just such a requirement, there is no separate purpose served by paragraph 2(i)(b) and, therefore, it should be removed.

Kai Niskala commented on 2012-06-25 06:18:12.64:
447498 D01 General RF Exposure Guidance v05. I: In the Introduction it is stated: (Test) Guidance in the most recent revision of the published KDB procedures, TCB workshop updates and Supplement C, whichever is the latest at the time when device testing begins, must be applied. .. does this mean that we should regard these Draft documents are applicable now? IV: In the General RF Exposure test Guidance section it is stated: A.4.: All devices must be evaluated .... at the maximum rated output power, within the tune-up tolerance range specified for the product .. A.4.(i): When tune-up tolerances are not required to be reported for equipment approval, RF exposure compliance must be determined with equivalent criteria and with respect to the highest maximum output power allowed for production units. All tested devices will have been set during assembly to full production power levels. Is this sufficient to satisfy the above requirements or is FCC asking for additional consideration of the spread of powers on top of that? B.3.(ii).(a): This section states that Extremity SAR is not required if Power <= 7.5 d / √fGHz This formula gives Powers 2.5 x the Head & Body-worn exclusion powers given later in C.1.(ii).(a), yet the SAR limit for Extremities is defined in terms of the 10g averaged value. In other words, this formula makes no allowance for the 10g averaging for extremities. For the cellular band of 850MHz, SAR values using 10g averaging are typically 70% of their equivalent 1g values, whilst in the higher AWS and PCS bands they can be approaching 50% of their 1g equivalents. We would ask FCC to consider modifying this formula to allow for 10g averaging. C.1.(ii).(a): This section states that Standalone SAR is not required if Power <= 3.0 d / √fGHz - and that this applies for separation distances >=5mm and <=50mm. It would help if the separation distance to use for Head SAR consideration was clearly stated here.

Mark Briggs commented on 2012-06-14 14:02:51.113:
PLease refer to our comments in the attached document. View attachment associated with this comment

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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