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Next: Any insight for Automotive Sensor Inputs/ Front-End Protection.
From: Charlie E. on 26 Apr 2010 21:44
On Mon, 26 Apr 2010 18:31:50 -0700, Joerg <invalid(a)invalid.invalid>
wrote:

>Charlie E. wrote:
>> On Mon, 26 Apr 2010 17:33:32 -0700 (PDT), mpm <mpmillard(a)aol.com>
>> wrote:
>
>[FCC regs]
>
>
>>> Either way, a quick review of the Rule may put your mind at ease. The
>>> Rule is FCC 2.803
>>> For convenience, here's the link:
>>> http://www.gpo.gov/fdsys/pkg/CFR-2009-title47-vol1/pdf/CFR-2009-title47-vol1-part2.pdf
>>>
>>> Not knowing your situation, my recommendation is to be safe just add
>>> the following text to your web site (the page that has pricing info):
>>>
>>> This device has not been authorized as required
>>> by the rules of the Federal Communications
>>> Commission. This device is not,
>>> and may not be, offered for sale or lease, or
>>> sold or leased, until authorization is obtained.
>>>
>>> The above is the exact language specified by 47CFR2.803(c).
>>>
>>> Enjoy!! And best of luck with the project/product.
>>> -mpm
>>
>> Hmmmm...
>> It is definitely not an intentional radiator, and no clock outputs
>> leave the chip. The two switchers are only going to a cap less than
>> 10 mm from the chip. Would never have thought anything this simple
>> could need certification. Jeorge? Any thoughts?
>>
>
>Well, there are paths of self-certification:
>
>http://www.techintl.com/emcinusa.cfm
>
>I run into this a lot. Is a change serious enough to warrant re-cert?
>Most clients do it anyhow, send the stuff to an EMC lab. But it's
>expensive, basically we rarely get out of there under $5k. If this is
>more like a non-profit product and helps the visually-impaired you may
>be able to convince a lab to do a "charity run".
>
>But first I'd fix that "CLEAR" ambient subtraction routine that must
>have fallen through the cracks ... whoops ... got to have that :-)

Ok, so if we market this device in the US, since it has a MCU in it,
then we have to get certified by the FCC that we don't radiate?

We may just have gone out of business!!!!!!

Charlie
From: Joel Koltner on 26 Apr 2010 22:16
"Charlie E." <edmondson(a)ieee.org> wrote in message
news:59gct5du60i0scnfehuua3bbe3dvu7rlap(a)4ax.com...
> Ok, so if we market this device in the US, since it has a MCU in it,
> then we have to get certified by the FCC that we don't radiate?

Stricly speaking, I think that's the case, but it also seems that the FCC
doesn't really care that much when you're small: There are many companies
selling various ham radio-related accessories all over the Internet (and many
of them ARE intentional radiators), most of them are not certified (well,
maybe they're self-certified, but you can guess how many of those ever saw a
real test lab...), and they seem to stick around year after year.

Just a couple of examples:

http://www.aade.com/
http://www.ettus.com/
http://www.tigertronics.com/

Some of them seem to get away by calling their wares "kits" wherein, while you
get a fully-assembled PCB, you have to connect up a few cables and put the
screws in the case to finish things off...

Seems to me there's a rather large grey area here!

---Joel

From: mpm on 26 Apr 2010 22:16
On Apr 26, 8:11 pm, Charlie E. <edmond...(a)ieee.org> wrote:
> On Mon, 26 Apr 2010 17:33:32 -0700 (PDT), mpm <mpmill...(a)aol.com>
> wrote:
>
>
>
>
>
> >On Apr 26, 5:07 pm, Charlie E. <edmond...(a)ieee.org> wrote:
> >> Hi All,
> >> You have given me good advice in the past, and I am now really close
> >> to shipping this thing, but still running into some of the same old
> >> problems.
>
> >> Basically, when I program a unit, it works great here on the bench,
> >> and around the house, but when I go out into the real world, all heck
> >> breaks loose!
>
> >> My present problems seem to revolve around dark colors.  Browns shift
> >> to dark red, or green, blacks suddenly become dark greens, dark denims
> >> become black, dark green, or even dark blue-green.  
>
> >> Trying to determine the cause is difficult, because the problems never
> >> happen in the lab when I am in debug, and can get full data on what is
> >> going on internally.  My present guesses all point to shifts in the
> >> strengths of the LEDs and other electronics, perhaps with temperature,
> >> or maybe with differences in background lighting leaking into the
> >> unit.
>
> >> So, can anyone offer any suggestions?  You can find a schematic and a
> >> photo of the unit athttp://edmondsonengineering.com/RainbowColorReader..aspx
>
> >> Thanks in advance!
>
> >> Charlie
>
> >Hey Charlie,
> >Can't help with your circuit, but it looks like a pretty cool device.
> >It's the sort of thing that someone probably would never think of
> >unless they were familiar with blindness.?
> >I wonder if it could have application in teaching kids their colors,
> >or for use with colorblind individual.
> >Maybe an advanced unit to detect world currencies...??
>
> >My only thought is that maybe light is bouncing around in weird ways
> >on the input.
> >Try setting up some lights on your bench and see if you can emulate.
> >Use different types of lights (flourescent, tungsten, basically, every
> >wavelength you can think of).
> >I would also experiment with different daylight times (outdoors, of
> >course), as the Sunlight temperture varies considerably dusk to dawn.
> >(You probably already know all this, right??!)   Disclaimer: Amateur
> >photographer here.
>
> >I notice you're in the United States.
> >I thought I should point out a potential regulatory concern that
> >involves offering products for sale before they have either been FCC-
> >certified, or before the manufacturer (you!) has filed a Declaration
> >of Confirmity.
> >Honestly, I'm not sure which one your product would involve.  Probably
> >a DoC, but I don't know if they consider the LED emissions to require
> >certification...??  Maybe someone here will know.
> >Your PIC certainly operates fast enough to qualify for testing.  I
> >recall anything over 9kHz requires testing, though I could be wrong
> >about that lower bound.
> >8 to 32 MHz definitely qualifies, however.
>
> >I think the FCC might interpret your website as advertising of the
> >product, particularly in light of your web text suggesting wholesale
> >pricing.  (I realize the product is not ready for sale, but that's not
> >really the point.)
> >If the FCC were to draw that conclusion, it could subject you to an
> >Official Citation or Notice of Apparent Liability.  The former is a
> >slap on the wrist involving no out-of-poekct money.  The latter can
> >lead to possible fines and in-rem forfeiture - (though all of these
> >outcomes are highly unlikely).
>
> >Either way, a quick review of the Rule may put your mind at ease.  The
> >Rule is FCC 2.803
> >For convenience, here's the link:
> >http://www.gpo.gov/fdsys/pkg/CFR-2009-title47-vol1/pdf/CFR-2009-title...
>
> >Not knowing your situation, my recommendation is to be safe just add
> >the following text to your web site (the page that has pricing info):
>
> >This device has not been authorized as required
> >by the rules of the Federal Communications
> >Commission. This device is not,
> >and may not be, offered for sale or lease, or
> >sold or leased, until authorization is obtained.
>
> >The above is the exact language specified by 47CFR2.803(c).
>
> >Enjoy!!  And best of luck with the project/product.
> >-mpm
>
> Hmmmm...
> It is definitely not an intentional radiator, and no clock outputs
> leave the chip.  The two switchers are only going to a cap less than
> 10 mm from the chip.  Would never have thought anything this simple
> could need certification.  Jeorge?  Any thoughts?
>
> Thanks,
> Charlie- Hide quoted text -
>
> - Show quoted text -

I wasn't too sure about whether the LED's were modulated, and if so,
at what frequency, etc..,

Your device appears to be in the same family tree as small battery-
powered calculators and TV remotes.
In other words, a Class-B (household) digital device, configured as an
unintentional radiator
Note: A digital device is pretty much anything with a clock faster
than 9 kHz.

Typically, these types of devices will have DoC's, and I suspect yours
should as well.
That said, the rules appear vague and flexible enough to allow
Verification.

See FCC Rule 15.101. Link:
http://www.gpo.gov/fdsys/pkg/CFR-2009-title47-vol1/pdf/CFR-2009-title47-vol1-part15.pdf

Sorry to rain on your parade, (if I have?). Just thought you should
be aware, particularly given the advertising thing.
The good news is that Verification / DoC is a lot cheaper, easier and
faster to get than a full-blown TCB Equipment Certification.

Again, best of luck getting the bugs out!
-mpm




From: mpm on 26 Apr 2010 22:28
On Apr 26, 9:16 pm, "Joel Koltner" <zapwireDASHgro...(a)yahoo.com>
wrote:
> "Charlie E." <edmond...(a)ieee.org> wrote in message
>
> news:59gct5du60i0scnfehuua3bbe3dvu7rlap(a)4ax.com...
>
> > Ok, so if we market this device in the US, since it has a MCU in it,
> > then we have to get certified by the FCC that we don't radiate?
>
> Stricly speaking, I think that's the case, but it also seems that the FCC
> doesn't really care that much when you're small: There are many companies
> selling various ham radio-related accessories all over the Internet (and many
> of them ARE intentional radiators), most of them are not certified (well,
> maybe they're self-certified, but you can guess how many of those ever saw a
> real test lab...), and they seem to stick around year after year.
>
> Just a couple of examples:
>
> http://www.aade.com/http://www.ettus.com/http://www.tigertronics.com/
>
> Some of them seem to get away by calling their wares "kits" wherein, while you
> get a fully-assembled PCB, you have to connect up a few cables and put the
> screws in the case to finish things off...
>
> Seems to me there's a rather large grey area here!
>
> ---Joel

No. Kits are covered under the regs.

I agree that as a practical matter, nobody will complain unless /
until interference to some other licensed radio service occurs.
If / when that happens, the last thing you want is no DoC,
Verficiation or FCC ID on file for your gear. - particularly if
someone gets hurt.
That an invitation to get fined and sued into the poor house. (I'm
thinking about those motorized wheelchair controllers that went crazy
every time a taxicab radio keyed up in the vicinity!)

But before jumping ship, Charlie -- just call the folks at the FCC OET
in Washington, describe your product, and see if you can squeak by
with Verification.
If so, no money out of pocket -- assuming you know how to self-
certify, and have access to the right test equipment.

Even if they require a DoC, all is not lost. Shop around. It may be
cheaper than you think!
From: krw on 26 Apr 2010 22:30
On Mon, 26 Apr 2010 17:43:22 -0700, "Joel Koltner"
<zapwireDASHgroups(a)yahoo.com> wrote:

>Lots of places do rainbows... there are various samples here:
>http://en.wikipedia.org/wiki/Gayborhood
>
>That phallic-looking one in Boystown, Chicago seems quite fitting. :-)

Looks like something NASA would do.
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Prev: Financial Management Theory & Practice by Eugene F. Brigham, Michael C. Ehrhardt 13th Edition 2011 Solution manual is available for purchase at affordable prices. Contact me at alltestbanks11[at]gmail.com to buy it today. All emails will be answer
Next: Any insight for Automotive Sensor Inputs/ Front-End Protection.