How To Review a TCB Application

Prepared by

Chris Harvey EMC Consulting

Disclaimer!!!

This presentation provides one person’s opinion and point of view and is not intended to be interpreted as the only way to perform the duties of a TCB reviewer.

I have over 25 years of review experience with lots (did I say lots?) of trial-and-error

TCB Program Roles & Responsibilities

per KDB 641163 D01 v02 This 13 page document helps to explain the

program set in motion by FCC Report & Order 98-68 and why training is needed to ensure quality

Explains how to become a TCB, TCB Scopes & Accreditation, impartiality, location, TCB Exclusion and Permit But Ask, Core Test Requirements (of a TCB), Key Personnel, Contract Employees, Information Maintenance, TCB Personnel Training, TCB Acceptance of Test Data, Test Procedures, Retention of records, Interpretation of the FCC Rules, Post-Market Surveillance requirements

Version 02 (v02) was released 2 days ago on 4/4/14

Roles of a TCB Reviewer – KDB 641163 D01 v02 (1)

641163 D01 TCB Program Roles and Resp v02  When accepting test data in support of an

application for certification, the TCB shall review the test report, and needs to be confident that the product meets the relevant requirements before it certifies the product. The process used by the TCB for the acceptance of test data will be reviewed during the ISO/IEC Guide 65 [becoming 17065] [TCB] assessment.

Roles of a TCB Reviewer – KDB 641163 D01 v02 (2)

When reviewing the application for certification, including the test report, the TCB should evaluate the following elements of the application for certification to determine the suitability the test data:

a) Clearly defined test procedures b) Method of test validation c) Clearly defined test configurations d) A brief description of the test facilities – photo(s)

and block diagram(s) of test setup e) Calibration dates and traceability of all test

equipment

The Goal of reviewing an application is: Ensure it is Complete – all

required documents are provided Ensure it is Consistent – all

exhibits paint the same picture Ensure it is Correct – all

compliance requirements have been metRemember 3-C’s

Before an Application is submitted The Application package is the final product submitted to

the TCB to document the capabilities and compliance of a device being submitted for FCC Certification.

We’ll see examples shortly

Many times, the TCB Reviewer is the first person to see all documentation together that has been pieced together over time

By the time it gets to the TCB, all aspects of FCC requirements are supposed to have been addressed. An application at submission to the TCB is rarely perfect

This is why a thorough review is necessary

What does an application look like?

A typical application package consists of 10-40 documents describing the device and the compliance requirements and compliance evidence

Example exhibits list (not including confidential)

FCC 2.1033 – What is required (minimum) to be in an application for Certification

FCC 2.1033 – Application for Certification (b)- FCC Rule Parts 15 & 18

Applications for equipment operating under Parts 11, 15 and 18 of the rules shall be accompanied by a technical report containing the following information: (next slide)

(c)- All other FCC Rule Parts Applications for equipment other than that operating under

parts 15 and 18 of the rules shall be accompanied by a technical report containing the following information:

FCC 2.1033(b) - Unlicensed Name and address of manufacturer / applicant FCC Identifier (FCC ID) Copy of Installation and Operating Instructions (Manual) Brief Description of Circuit Functions (Operational

Description) Block Diagram showing frequencies Schematic Diagram (for Transmitters) Test Report Photographs (Label, Internal & External appearance) Other incidentals….

FCC 2.1033 (c) - Licensed Name and address of manufacturer / applicant

FCC Identifier (FCC ID)

Copy of Installation and Operating Instructions (Manual)

Types of Emissions

Frequency Range

Range of Operating Power

Maximum Power Rating

DC Voltages/currents at RF Components

Tune-Up Procedure

Schematic Diagram

Photographs (Label, Internal & External appearance)

Brief Description of Circuit Functions & Modulation (Operational Description)

Other incidentals….

Equipment Classes & TCB Scopes:

The FCC has divided approvals into Equipment Classes describing the type of device (i.e. DTS for Digital Transmission Systems of FCC 15.247) and into TCB Scopes, which are groupings of Approval Categories.

TCB Scope of Accreditation

Equipment Class

The category or class of equipment assigned to the device submitted for approval for marketing.

The FCC maintains an Equipment Class and Rule Part List at https://apps.fcc.gov/oetcf/eas/reports/EquipmentRulesList.cfm

And example: A single WLAN AP operating at 2.5 GHz and 5.2 GHz would all be approved in TCB Scope A4, but the 2.4GHz WLAN is DTS under FCC 15.247 and the 5.2GHz WLAN is NII under FCC 15.407.

Another example, a single 2.4GHz BT/ANT+ transmitter could be approved under 3 equipment classes:

DSS for FHSS Legacy BT modes

DTS for BT-LE

DXX for ANT+ operation

There are currently 74 different FCC Equipment Classes

Composite Device applications

FCC 2.1033(e) A single application may be filed for a composite system that incorporates devices subject to certification under multiple rule parts,

Each Equipment Class is a separate submission – each will get separate “Grant”

i.e. Cell Phone w/ Cell/PCS/LTE and WLAN & BT may have 3 (or more) applications

each application is individually uploaded to FCC Separate ‘package’ of exhibits for each Equipment

Class

Confidentiality – Long and ShortKDB 726920 D02

FCC Confidentiality Policy in KDB 726920 D01 Allowance list in KDB 726920 D01 During review ensure:

Only allowed types are included in STC and LTC

Confidentiality Request follows FCC guidance/requirements (correct references)

Confidential items are not also located in non-confidential exhibits

i.e. Photos are all STC, but there is a photo of the EUT in a report exhibit

You don’t want to be responsible for releasing confidential information

Exhibit Confidentiality Table – KDB 726920 D01

How to first approach an application (1) Know the Equipment Under Test (EUT) (even without

a sample) In order to review an application package you must

first become very familiar with the device and its capabilities I am a visual person, so I always start with the photos

(Internal & External) What does the device look like, how is it used,

where is it used

Only once you can understand the device and how it is used can you tell if all requirements have been met….

Photo exhibits

Photos (Internal & External) should show: Approximate size (larger than a bread-box?)

Visible features (buttons, displays, antennas…)

Battery or AC operated?

Hand-held (Portable or Mobile, per FCC definition)

Internal and external construction

There should be sufficient number and quality of photos to clearly show the external and internal appearance and construction

How to first approach an application (2) Look at the Block Diagram, sometimes called a

Functional Diagram, should show all functions and how they relate to each other

You now know what it looks like (photos) so the Block Diagram helps to paint a first and basic picture of what the device is and its functional

Example Block Diagram

What do you see? Are there any Tx’s? Does it raise

questions? Needs frequencies

of operation Do all features from

photos show here?

From Marvell http

://www.marvell.com/communication-processors/pxa968/

How to first approach an application (3)

Look at the Operational Description – should completely document the capabilities of this device Frequencies

Modulations

Channeling

Power

Should contain a fairly technical description

Test Reports and Compliance

Now that you have an understanding of the device, what it looks like, its capabilities and how it operates, now is time to ensure it meets the appropriate FCC requirements….

What Rule Parts Apply What Measurement Procedures apply What additional Guidance applies (KDB’s) Is further guidance needed (PBA)

No Interpretations needed (or allowed)

TCB’s are NOT allowed to interpret (TCB Roles & Responsibilities) Only the FCC can interpret… TCB’s apply the FCC Guides

and interpretations

We should also not assume anything about the device/report/compliance All information should be stated clearly in the application

exhibits

If information is vague or unclear, ask for clarifications in an RT, or Request for Technical (information)

Consistency throughout This is tough, but should be evaluated throughout the review Always look out for consistency of terms, capabilities,

specifications, Use Check Sheets to provide consistency between reviewers

and between applications I personally use review notes as I move from exhibit to exhibit If MIMO in Operational Description, then look for testing of

MIMO modes If operation is for portable use and needs RF Exposure, make

sure SAR is addressed Data/parameters in one exhibit should match data/parameters

in other exhibits

Taking notes and reviewing, my style (please refer back to my disclaimer)

I open all documents at the beginning and then start reviewing each one thoroughly (make sure your computer can handle the data)

I may close some, and leave others open longer. I may re-open some as I continue reviewing.

I may bounce back and forth between several exhibits as I try to determine requirements and consistency

I take notes throughout the review and refer back to them as I look at exhibits to ensure consistency

Know your resources, precedents

Recent precedents may be helpful in new review, but… Avoid old examples as rules are constantly changing

What is old????

Remember, 2 wrongs never make a right

A good and thorough example of similar approval from the FCC website may be a tool in assisting your review

Grant Comments

Many Grants will have ‘comments’ which assist in providing Grantee with restrictions or details about their approval.

Some simpler approvals don’t need Grant Comments

Used to address use restrictions, RF Exposure Compliance, clarifications on Grant RF Power,

The TCB’s are responsible for generating the Grant Comments from FCC guidelines and precedents.

Example Grant Comments:

Rules work together

The FCC Rules and regulations do not stand alone Rule parts work together

Just because you cannot find specifics in the Rule Section…don’t stop

Keep looking in other rules that work with the one you are working with…

Example: Approving device per DTS requirements of FCC 15.247

Must also comply with technical requirements of 15.31, 15.35, 15.207/15.209, 15.215, RF Exposure, etc.

Understand how the rules work together to perform complete review

Permit But Ask (PBA) – KDB 388624

How many know the game “Mother May I” You are only allowed to move if mother says ‘yes’

The Permit But Ask procedure is similar to that game You are allowed to approve a device ONLY after the FCC

says ‘Yes”

Details on the next slide

PBA Procedure is in KDB 388624 D01 PBA List is in KDB 388624 D02

Permit But Ask (PBA) Procedure

KDB 388624 D01 v09r03 (lots of revisions) 4 typed pages of guidance Manufacturer/Laboratory responsibility

Follow existing guidance or submit inquiry for new guidance

Follow the guidance… and NOTIFY the TCB of all communication

TCB Responsibility Review entire application first

Ensure guidance has been followed

Submit entire application without Granting, then submit PBA request

Respond to any FCC requests and issue Grant ONLY when FCC says ‘yes’

PBA filing

Even though a PBA process involves Manufacturer, Laboratory and TCB, the PBA filing is only a TCB process, and not filed by the manufacturer or the Laboratory

The PBA submission will have an associated KDB (PBA) number which is included in the TCB completed FCC Form 731 (that PBA number is not public)

PBA List – KDB 388624 D02 v14

This list provides specifics about which devices fall into the PBA procedureSpecial Circumstances

EMC for ‘Carrier Aggregation’, Confidentiality not in compliance with 726920,

RF Exposure Evaluation

21 different RF Exposure situations (in current v14) that require PBA

includes really new technology, really complex situations, coherent transmissions, simultaneous transmission measurements, non-standard procedures, where guidance is not available or applicable…

TCB Exclusion List

These are devices that may ONLY be approved by filing directly to the FCC

TCB Exclusion List is in KDB