• Daniel Hoolihan commented on 2010-05-17 21:28:09.62:
  
  Comments on Test Site Validation
   
  Under Paragraph 6, Scope of Accreditation, it is stated in the paragraph "Intentional Radiator Testing" that "However, in all cases, test site validation shall occur on an interval  not to exceed two  years."
   
  Under Paragraph 8, Radiated Emissions Test Facility, it is stated in the paragraph "Site Validation Requirements" that "Validation of the acceptability criterion shall be confirmed no less than once every three years."
   
  It is recommended that a fixed interval of two years be required for the site validation. It is further recommended that site validation for less than 1 GHz be done one year, and, then in alternate years, site validation for greater than 1 GHz be performed.
   
  The two-year interval would be consistent with Lab Accreditation policies of an on-site assessment every two years.

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• Adam Gouker commented on 2010-05-17 16:07:37.043:
  Section 4, part h: if the FCC Staff would like evidence of each of these sub-parts uploaded to the OET website by the DA, perhaps it should be clearly explained as such. Section 4, part h, sub-part i. : there are several procedures to be followed during the accreditation process of a CAB. Clarification is requested as to which procedure the FCC staff will look to review regarding this sub-part. Section 5, A2LA contact info : please update telephone number to: 301-644 3217, fax number to: 301 662-2974, contact to: Adam Gouker, and email address to: agouker@A2LA.org Section 8, Antenna Calibration para.1 : clarification should be added to this paragraph indicating that C63.5-2006 is not 'mandatory', since the FCC still allows for testing in accordance with C63.4-2003. Section 8, Site Validation Requirements para.1 : The statement is made that "Validation of the acceptability criterion shall be confirmed no less than once every three years."... If it is expected that the Accreditation Bodies perform a spot check of site validation data, perhaps a statement should be added to indicate something to the effect that "The Accreditation Body assessor will review validation data during initial and renewal CAB assessments" to ensure this requirement is being met.

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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.