Page 451 - Complete Wireless Design

Wireless Issues

450 Chapter Ten

radiators in RF communications would comprise receivers that create high levels
of RF radiation internally for frequency conversions, but do not purposely propa-
gate this energy beyond their own cabinet. Both intentional and unintentional
radiators must obtain FCC authorization to be marketed within the United
States. (There are some exceptions to this rule; see “Keeping the FCC Happy—A
Reference Article,” Mitchell Lazarus, Wireless Design and Development Magazine,
November 1999.) The third category, incidental radiators, is not of interest to the
average wireless designer. This category comprises devices that are not intended
to generate RF internally or externally, but do anyway, such as light dimmers,
neon signs, and electric motors. No FCC authorizations are needed for any of
these devices under the incidental radiator category, but they must not produce
RF radiation above similar devices on the market.
Both intentional and unintentional radiators must have one of three new
FCC authorizations, depending on the product and its use (or possible misuse).
The old Type Approval, Notification, and Type Acceptance authorizations have
been replaced with the Verification (similar to the old Notification), Declaration
of Conformity (DoC), (similar to the new Verification), and Certification, (simi-
lar to the old Type Acceptance). There is no old Type Approval replacement.
Because of the legal complexity, a lawyer that specializes in FCC technical
issues should be consulted before marketing any wireless device, but the fol-
lowing is a general guide to the type of equipment and the type of authoriza-
tion that typically must be obtained. A major communications law firm such
as Fletcher, Heald & Hildreth of Washington, D.C., is a full-service telecom-
munications firm founded in 1936, and is quite capable of handling most FCC
related technical issues. Other practices, such as Latham & Watkins and
Miller & Van Eaton, are also very competent in this area.
Fixed microwave point-to-point and licensed broadcast transmitters (inten-
tional radiators), as well as television and FM stereo and mono receivers
(unintentional radiators), will usually obtain a Verification Authorization.
This type of authorization simply requires the manufacturer of the device to
test for FCC technical compliance. A Verification Authorization is by far the
least complicated to acquire, as your company need not even file FCC compli-
ance documents and, as soon as the device successfully passes, sales can
actively begin. All test and design paperwork should be preserved over the
manufacturing life of the product, plus 2 years. All that is demanded is that
certain devices must be labeled as directed by the FCC rules.
Virtually all other consumer unintentional radiators are commonly autho-
rized under the Declaration of Conformity. The DoC also allows your company
to obtain its own equipment authorization and, as with the Verification
Authorizations, the FCC is not even notified of the product’s existence.
However, the DoC is far more expensive and complex to obtain than the simple
verification, since all RF equipment tests must be performed by an accredited
test facility. If passed, the equipment must be sold with the FCC logo attached,
as well as with copies of paperwork called the Compliance Information
Statement (which contains information on the product and its manufacturer).
If the manufacturer so desires, it may also opt to obtain a Certification.

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