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Next: Any insight for Automotive Sensor Inputs/ Front-End Protection.
From: krw on 26 Apr 2010 22:40
On Mon, 26 Apr 2010 19:28:07 -0700 (PDT), mpm <mpmillard(a)aol.com> wrote:

>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.

Or a competitor gets a burr under their saddle.

>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!

IME, EMI compliance is pretty cheap (though test labs vary quite a bit). It's
all the rest of the stuff that takes time and $$. If there is no AC power
(even a charger) most of that goes away.
From: mpm on 26 Apr 2010 22:47
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

Hey Joel,

Tigertronics is FCC registered.
Link: https://fjallfoss.fcc.gov/oetcf/eas/reports/GenericSearch.cfm

I didn't check them all, or course; nor every product Tiger has.
I did pull up one of their manuals (online PDF) and if that's what
comes in the box, I think you're right - they are violating some
specific FCC rules.
I would also question whether the device itself is marked with the FCC
ID#, as required by law. ???

-mpm
From: Charlie E. on 26 Apr 2010 23:04
On Mon, 26 Apr 2010 19:16:48 -0700 (PDT), mpm <mpmillard(a)aol.com>
wrote:

>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
>
>
>

Ok, heart attack over. From the FCC at
http://www.fcc.gov/oet/ea/ea_app_info.html

looks like we don't even have to file anything, just put a note in our
instructions that we meet (verification) the specs. Whewwww... you
had me worried there!

Charlie
From: Robert Baer on 27 Apr 2010 04:59
Charlie E. 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 at
> http://edmondsonengineering.com/RainbowColorReader.aspx
>
> Thanks in advance!
>
> Charlie
Add software to sample levels and other parameters that you measure
in the lab; samples to be stored where you can get at them later at
worst or add display for them.
From: Royston Vasey on 27 Apr 2010 06:36

"Charlie E." <edmondson(a)ieee.org> wrote in message
news:kvkct5ttueknpcqgohje2n3d8pe4j7b7p9(a)4ax.com...
> On Mon, 26 Apr 2010 19:16:48 -0700 (PDT), mpm <mpmillard(a)aol.com>
> wrote:
>
>>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
>>
>>
>>
>
> Ok, heart attack over. From the FCC at
> http://www.fcc.gov/oet/ea/ea_app_info.html
>
> looks like we don't even have to file anything, just put a note in our
> instructions that we meet (verification) the specs. Whewwww... you
> had me worried there!
>
> Charlie


I'm in another country Charlie, but have had similar compliance issues with
low volume items. If you feel the need, find a friendly EMC test lab and see
if he will rent himself to you for a couple of hours & provide you with a
couple of spectrograms to show that emissions are acceptable. The cost goes
up up up if the lab writes up any report for you.


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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.