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Pieter Robben
ACB
FCC/TCB Market Surveillance
FCC/TCB market surveillance
• Market surveillance on products which have been
certified for use in the USA is carried out by several
entities:
- Federal Communications Commission (FCC)
- Telecommunications Certification Bodies (TCBs)
FCC market surveillance
• Carried out or initiated by the FCC OET Laboratory
• Carried out or initiated by the FCC Enforcement
Bureau
• Carried out based on received complaints
• Targeted projects
• New technologies
• Oversight of TCBs
• Random sampling
TCB market surveillance
• TCB’s must carry out market surveillance activities as
described in, and based on, KDB 610077
• January 11, 2011 revision of KDB 610077 clarified
the required non-compliance reporting by TCBs
• June 8, 2011 revision of KDB 610077 clarified the
audit counting method which is to be used by TCBs
• October 25, 2011 clarification of follow up and
reporting requirements
FCC surveillance policy summary
• The TCB must audit 5% of the number of issued
scope A and B certifications per year
• The TCB must audit 2% of the number of issued
scope C approvals per year
• The TCB must audit 1% of the issued certifications
with SAR testing per year
• The TCB must actually test products
FCC surveillance policy summary
• Audits should be performed by TCBs throughout the
surveillance year and not all audits should be
performed at the end of the surveillance year or in the
year following the surveillance year
• The number of audits by TCBs must be based on the
number of issued Grants and not on the number of
unique FCC ID’s
• The sampling percentage required must be based on
the number of Grants issued by the TCB in the
surveillance year
FCC surveillance policy summary
• When an audit sample has not been tested it does not
count as an audit
• In case of found non-compliance the TCB must
inform the FCC and Grantee code holder immediately
and a resolution/follow-up should be submitted to the
FCC within 30 days
• The TCB must notify the FCC of non-responsive
applicants or applicants unwilling to send audit
samples (not marketed in USA is not a valid reason
for not providing an audit sample)
FCC surveillance policy summary
• The TCB must work with the applicant until the issue
is resolved
• If an issue cannot be resolved, the TCB must send a
summary to FCC which identifies all attempts to
resolve the issue
TCB selection criteria for audit sampling
• When selecting the samples to be audited
consideration may be given to the following factors:
- New technologies
- New applicant
- New test laboratory
- Products likely to exhibit non-compliances
TCB selection criteria for audit sampling
- Request from the FCC or IC for an audit to be
performed on specific product types
- Potential impact on licensed radio services, the
public switched telephone network (PSTN) or
user from a non-compliant device.
Typical items to be checked/audited
• Labeling of product
• User manual
• Comparison of sample product with certified product
• Antenna power (conducted)
• Radiated field strength
Typical items to be checked/audited
• Transmitter radiated/conducted spurious emissions
• Frequency band edge compliance
• Occupied bandwidth
• RF power spectral density
• SAR (specific absorption ratio)
Common items which fail checks/audits
• Labeling of product
- Label missing
- FCC ID missing on label
- Modular approval (host) label information
incorrect or missing
- Required warnings and information missing
Common items which fail checks/audits
• User manual
- User manual not made available for audit
- User manual not made available in English
- Required information to the user missing or
incorrect
Common items which fail checks/audits
• Comparison of sample product with certified product
- Sample product does not match the product
which was certified
- Modifications to ensure compliance are not
present in the final product
- Product was or has been revised
Common items which fail checks/audits
• Antenna power is higher than for the product which
has been certified
• Other items such as occupied bandwidth, frequency
band edge compliance
• Most items which fail checks/audits are
administrative items such as labeling and user manual
• Problem issues are detected in approximately 30% of
the total number of audits per year
Common problems concerning audit activities
• Requests for audits remain unanswered
• Materials are missing when audit samples are
received for testing
• Instructions for placing test samples in “test modes”
where required for audit testing are missing or
incomplete
• Test samples are not submitted for audit testing for
several other reasons (e.g. the product is no longer
manufactured or the product never has been
marketed)
Implications of audits for a certification body
• Many issued certificates implies many audits per year
• Many audits impose a relatively high cost on a
certification body
• Cost and time for audits will even increase due to
simple and sometimes unnecessary non-compliances
which are found
• Audits take up a lot of time in the testing laboratory
due to complications during testing (e.g. “test modes”
are not implemented or accessible)
Questions ?
Thank you for your attention
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