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Filename : FCC

 
Output of file : FCC contained in archive : FCC.ZIP

Citation-> PC Magazine, Feb 26, 1991 v10 n4 p351(7)
COPYRIGHT Ziff-Davis Publishing Co. 1991

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Title-> What you should know about the FCC emission standards.
(Federal Communications Commission) (Lab Notes)
(technical)

Authors-> Rosch, Winn L.

Summary-> Many computer manufacturers fail to comply with the
Federal Communications Commission's demanding standard for
radio-frequency emissions, and ensuring that computers do
not interfere with electronic communications nearby is the
responsibility of the user. Any electronic device with
high internal operating frequencies can emit signals a
radio or television set can pick up, causing interference.
FCC certification shows that a particular product does not
exceed a given level of interference with broadcast
frequencies. The FCC Class B certification program began
in the late 1970s, when emissions from computers were
causing dangerous interference with police, aeronautical
and other communications vital to public safety. Computers
sold for use in the home must meet Class B standards;
Class A devices are those sold only in business and
industrial applications. All microcomputers are
categorized as Class B, but vendors can apply to have
specific machines treated as Class A if they can verify
that it is not suitable for home use and that it is not
sold for such use. Most 80386 and some 80486 machines fall
into this category.

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Even though your PC doesn't transmit 2 Live Crew or George Carlin
reciting the seven words you can't say on the radio, the Federal
Communications Commission is interested in what your personal computer
is broadcasting. FCC standards limiting the radio waves that your PC
is allowed to emit are sufficiently demanding that many computer
manufacturers fail to comply with them. The result is do thousands
of personal computers-possibly your next "bargain" PC purchase-are
sold illegally each year. And as you might have guessed, you are
responsible if your PC exceeds permissible radio frequency
interference standards.

You may not have thought of your PC as a radio transmitter, but it is.
A computer-indeed, any electronic device that uses high internal
operating frequencies-can flood the ether with emanations that almost
any radio or television set can pick up. These unwanted radio
emissions are an unintended by-product of a simple physical principle:
Any varying electrical current, including the minuscule logic signals
inside your PC, creates an electromagnetic field. Every time the
current flow starts, stops, or changes direction, an electromagnetic
field is radiated into space. At high frequencies these radiations
take the form of radio waves.

Almost anything that goes into the airwaves falls under FCC
jurisdiction. The Commission has Congressional authority to enforce
its rules over the signals emitted-however unintentionally-by your
computer. Every personal computer (and most computer peripherals)
legally offered for sale in the United States must comply with the
rules and regulations of the FCC. Specifically, that means that every
personal computer should wear an FCC Class B certification sticker
unless the computer maker has obtained an explicit waiver from the
FCC. REGULATION PROS AND CONS Few people know what the FCC rules
govern what they are meant to achieve, and why anyone should care. In
ignorance or in defiance of the FCC's authority, many computer
manufacturers illegally offer PCs for sale in the U.S. For the
conscientious computer designer, complying with the FCC certification
procedure is the last hoop to be leapt through before the product can
appear on your dealer's shelf. FCC certification can take six to eight
weeks. This slows your access to new technology and may give an
illegal seller a competitive head start.

To many users, the benefits of certification may seem slight. FCC
certification does not guarantee that a computer product is safe, for
example; health and safety are not the concern of the FCC. Nor does it
absolutely guarantee that a given computer product won't interfere
with your radio or television reception. (Tbat's why the FCC requires
that instructions for eliminating the interference caused by a
computer be included in the manual, even for equipment that is
properly certified.)

All that FCC certification shows is that a particular product won't
exceed a given level of interference with broadcast services such as
television and radio transmissions (including cellular phones,
emergency radio services, and the radio-navigation equipment used by
airplanes). Achieving that level of protection is something for which
you and your neighbors should be thankful, however, even if it often
creates a headache for computer manufacturers.

Preventing interference is one of the most important reasons for the
FCC's very existence. The Commission was created in 1934 primarily to
clean up the mess made by early broadcasters who, in the 1920s,
transmitted signals whenever, wherever, and however they wanted to.
The result was that in some places the airwaves became such a thick
electromagnetic goulash that no radio could successfully receive a
single program. The FCC was given the job of imposing order on all of
this chaos, and to do this, it created strict rules to prevent
interference between radio stations. As other services began to use
the airwaves, the FCC set rules for them, too, always with the same
purpose: to prevent signals from interfering with one another. The FCC
was not created to limit what you could hear. Rather, it was created
so that it would be possible to hear clearly the signals that were
there.

The Commission's authority over radiated electromagnetic waves extends
from frequencies so low-9,000 Hz-that you could hear them if they were
sound waves to frequencies you could almost see as light
waves-300,000,000,000 Hz. While at first the FCC was interested only
in signals do were meant to be broadcast, the advent of modem
computers created a new source of radio interference. As shown in
Figure 1, the clock frequencies of today's computers sit in the middle
of communications frequencies and are edging up toward the television
and FM broadcast bands. (A few older computers operate at frequencies
within the AM broadcast band, but IBM-standard PCs have never stooped
so low.)

Is the potential for radio and television interference really a cause
for concern? It's hard to summon up much sympathy for someone who
complains about a few undulations added to the televised image of
Roseanne Barr by a nearby computer. But when the FCC took control and
created the computer emission standards that resulted in the Class B
certification process, the situation really was more serious than
this. At the time-the late 1970s-emissions from computerlike equipment
were already proving a dangerous, possibly lifethreatening problem.
For example, according to the FCC, the police departments of several
Western states reported their radios were receiving interference from
coin-operated video games that were based on computer-style circuitry.
And in another case at an East Coast airport, interference in
aeronautical communications was traced to the computerlike electronic
cash register at a drug store a mile away.

Moreover, hobbyist-style computers and hand-held calculators were
already on the market, and these were known to generate spurious radio
signals. The Radio Shack TRS-80 was notorious for the television
interference it generated. And although the extent of the phenomenal
personal computer boom of the 1980s was hardly foreseen, the increased
use of high-frequency digital logic circuitry promised that the
situation could only become worse.

In a first attempt to regulate the emissions of personal computers,
the FCC developed a special set of rules for diem, enacted in October
1979 as Subpart J of Part 15. Compliance with these rules has been
blazoned forth on the certification stickers of millions of PCs.

In March of last year the niles were rewritten to bring together
computers and other equipment that generated similar interference,
under a new Subpart B, Part 15, of the FCC rules. The new rules apply
to all electronic equipment that inadvertently creates radio
signals-equipment the FCC calls unintentional radiators-as well, of
course, as devices that intentionally create radio signals for
communications or related purposes. WHAT IS COVERED The new FCC niles
cover computer systems, from mainframes to pocket calculators, with
personal computers in between. Moreover, many PC peripherals must
undergo the same certification process as do full computer systems.
The rules explicitly define which peripherals require certification
and which do not. Some examples of these are given below and are
illustrated diagrammatically in Figure 2.

Peripherals, according to the FCC, include both internal and external
devices used to enhance the operation of a personal computer. External
devices connected to a PC require their own certification unless they
are sold together with the computer, in which case the PC and
peripheral must be certified together. An example of the latter is the
PS/1, which is sold as a computer and monitor combination. Because the
two pieces must be connected together to operate, they must be FCC
certified when connected together and working.

Mice and joysticks are explicitly excluded from the need for
certification because they contain no high-frequency circuits and use
no high-frequency signals. However, a smart mouse with its own
internal microprocessor would require certification.

Internal peripherals need to be certified only if they affect the
speed or performance of the computer or if they can be connected to
external devices. A serial communications board or a graphics board
needs FCC certification because of its external connector. A turbo
board or microprocessor upgrade board like the IBM Model 70
PowerPlatform requires certification because it increases the speed
(and thus the radiation potential) of the computer. On the other hand,
a memory-only expansion board or a hard disk controller does not
require certification.

Computer components ordinarily used only in making a computer at the
factory are considered to be subassemblies, and as such do not require
item-by-item certification. When such subassemblies are united to make
a personal computer that will be sold to end users, it is the entire
computer that must be certified. Cases, motherboards, and power
supplies are specifically designated as subassemblies and need
not-indeed cannot-be FCC certified. Thus a computer motherboard does
not require separate certification, but once it is installed in a case
with a power supply to be sold as a personal computer, the entire
assembly must be certified.

The claim sometimes made by small computer makers that their product
is made only. from FCC-certified subassemblies and so does not require
FCC certification is simply false. A personal computer cannot be built
without a power supply, case, or motherboard, and these three
subassemblies cannot be FCC certified as individual units. Any
computer manufactured from subassemblies must be FCC certified as a
completed unit.

The rules recognize that the test equipment a hobbyist would need to
check the amount of interference generated by home-brew computers is
more expensive than most individuals can afford. Consequently, the FCC
niles allow a specific exemption from the certification requirement
for homemade personal computers. Implicit in this exemption is the
assumption that a single homemade computer won't generate enough
interference to worry about-at least on a widespread basis. For this
exception to apply, however, the home-built PC must meet all three of
the following criteria: (1) It must not be marketed or offered for
sale; (2) it must not be made from a kit; and (3) it must be made in
quantities of five or fewer, solely for personal use. Most commercial
computer kits, on the other hand, must be certified by the FCC.

Some other types of commercial personal computer equipment are
specifically excluded from the need for certification under FCC rules.
Very-low-power devices-anything that uses less than six nanowatts (six
billionths of a watt) in its high-frequency circuits-are unlikely to
radiate substantial interference, so such equipment is excluded from
certification requirements. All current microprocessors use far more
power than this. A fast 386 microprocessor, for example, may use five
watts-almost a billion times too much energy to qualify for the
exclusion.

Equipment that operates at very low frequencies, such as toasters
(which radiate enormous power at 60 Hz, but thus at a frequency too
low to be covered by the FCC rules), light bulbs, electric blankets,
and automobile alternators, do not have to comply with the FCC
certification rules. The rules are aimed at equipment that uses
digital logic signals (whose operating voltages are either on or off),
as opposed to analog devices, such as a public address amplifiers,
(whose signals vary continuously in amplitude). Nine kilohertz is the
minimum frequency for the FCC definition of digital device, so systems
that operate at such a glacial pace need not worry. Indeed, the
effective frequency limit can actually be much higher: devices
operating at speeds lower than 1.705 MHz that do not use AC power are
also excluded. THE CLASS STRUGGLE The FCC divides digital devices into
two classes, A and B, which have entirely different standards for
allowable emissions and testing. The division is made on the basis of
where the equipment is likely to be used. Class A digital devices are
those that are suited only to business, commercial, and industrial
applications. Class B applies to digital devices that are likely to be
used in the home. As we shall see, the emission standards for Class B
are much more difficult to meet.

Despite their presence in business, commercial, and industrial
settings, the FCC rules explicitly define personal computers-all
personal computers-as Class B equipment. The rules define the term
personal computer so that just about anything that you might think of
operating qualifies. What was classed as a "home" computer years
ago-for example, the Commodore 64-is covered because the FCC's Class B
definition includes any computer that uses a television set as its
display device. And a computer with a dedicated display system, such
as the PC that's probably sitting on your desk, also meets the FCC
definition of a personal computer if it has all three of the following
characteristics: (1) It is marketed through a retail dealer or
direct-mail outlet; (2) advertisements of the equipment are directed
toward the general public rather than restricted to commercial users;
and (3) the-computer operates on battery or 120-volt AC electrical
power.

Note that how a particular computer was actually sold does not matter.
As long as a particular model has been offered for sale through a
dealer or direct-mail outlet, it meets the first requirement.

All portable personal computers are considered Class B devices because
their very portability makes them likely to be used in a residential
setting. Although Class A portable computers are theoretically
conceivable-for example, a machine dedicated to taking seismological
measurements in oil prospecting-general-purpose portable PCs cannot
qualify as Class A devices. Thus, any portable computer offered to you
for sale as a Class A device violates the FCC rules. Legally, such a
computer cannot be sold.

The definition of Class A equipment implicitly covers mainframes and
minicomputers, most of which use industrial-standard 230-volt power.
According to the rules, however, the most important distinguishing
characteristic is that Class A devices are of such nature or cost that
they would or could not be used at home by individuals.

Here, the FCC gives PC manufacturers a potential out. Manufacturers or
importers can apply to the FCC to have specific personal computers
treated as Class A devices providing the computer is of such a
nature-priced too high or delivering perfomrance too high-that it is
not suitable for residential or hobbyist use.

No hard-and-fast nile defines what is too powerful or too expensive to
be a computer suitable for use in the home. One general but not
absolute) guideline used by the FCC, however, is that a base retail
price higher than $5,000 makes a computer more likely to be used in a
business-only setting. Further, computers based on 80486 (and some
80386) microprocessors are currently powerful enough to be likely to
earn the FCC approval for rating as Class A devices. As the power of
PCs increases and the expectations of home users rise, however, this
guideline will probably shift.

A manufacturer cannot simply declare that his computer is a Class A
device. He must ensure that it is not knowingly sold to someone
intending to use it in a residential area. if the manufacturer wants
to be absolutely sure that his device qualifies for Class A treatment,
he can write to the FCC for letter notification, which confirms that
his computer meets the requirements of Class A equipment.

There's quite a substantial incentive for a manufacturer to want his
products treated as Class A devices. Not only are the emission
requirements more lenient, but a PC rated as Class A does not require
undergoing the lengthy FCC testing and certification process. A Class
A device can be tested and verified by its maker as being in
compliance with FCC rules.

The latter process is admittedly quicker. It also offers the potential
for creative interpretation of the rules. For example, a manufacturer
might succumb to marketing pressure and say his equipment has been
verified for compliance before it actually is. However, the FCC can
double-check Class A verified equipment and prohibit its sale if it
doesn't in fact meet the standard and punish those who fraudulently
claim to have verified equipment. THE LIMITS The FCC rules set limits
on two kinds of emissions: conductive emissions, which travel through
the wires in the power cord; and radio frequency (r.f.) emissions,
which are radiated from the computer into space. The Commission is
concerned with conductive as well as with broadcast emissions, because
PC signals that escape through the power cord can be carried into
other equipment connected to the same electrical circuit. Figure 3
shows the limits for the two kinds of emissions both for Class A and
Class B equipment. As you will note, the maximum permissible levels
vary with frequency.

The justification for the distinction between Class A and B devices
may seem vague, and the different forms of verification procedure may
seem unjustifiable. In fact, however, there are good reasons for both.

The emission limits for a Class B device are not arbitrary or
capricious. They represent a level believed by the FCC to be low
enough to avoid interference to radio or television reception when
there is more than one wall and 30 feet separating the computer and
the receiver. That 30 feet and one wall is a reasonable description of
the separation between one household and another. The standard is thus
designed so that if Class B equipment causes interference at all, it
will bother only the home of the person owning the computer. The
neighbors shouldn't have anything to worry about.

Class A equipment, on the other hand, is allowed to produce
interference in equipment nearly ten times farther away than Class B
equipment. The higher allowable limit for possible interference is
based on the assumption that most residential areas are substantially
more than 30 feet from industrial or commercial buildings. The greater
separation means that even with greater radio-frequency emission
levels, Class A devices still should not bother the neighbors.

The different testing arrangements-verification versus
certification-for Class A and B equipment reflect hard realities as
well. Class B products are those mass produced in the thousands or
millions. Sending a sample Class B product to the FCC should cause no
real hardship except for the delay imposed by the certification
process.

Class A equipment, on the other hand, is likely to be unique-as, for
example, a custom-installed mainframe in an environmentally controlled
computer room. Sending a one-of-a-kind mainframe computer to the FCC
testing lab would be impractical at best. Moreover, because more Class
B than Class A devices are likely to be produced, a higher degree of
assurance against interference from the more popular equipment would
seem warranted.

Of course, most manufacturers won't make millions of something until
they are certain that the design will pass the certification tests. In
most cases, manufacturers check the emissions of the equipment
themselves (or have a private testing lab do it) before they submit it
for certification. The FCC's assumption is that the computer maker
will know what the requirements are and manufacture to meet them. If
he blows it, it's his own fault.

Under the FCC rules, commercial or industrial equipment can be sent to
the FCC to be certified as Class B equipment, and Class B equipment
can be used in business locations. The opposite of this, however, is
not true. Class A equipment should not be used in residential areas,
because its higher permissible radiations may cause interference to
neighbors' radio and television reception. THE RADIO POLICE The law
doesn't say you can't use a Class A device in your home, however, nor
will the Radio Police break down your door if you do. The FCC rules
implicitly allow you to use a Class A device in your home-as long as
no one is bothered. If your computer causes interference to someone's
radio or television reception, however-whether your PC is a Class A or
Class B device-you are responsible for eliminating the interference.
If you don't, the FCC can order you to stop using your computer until
you fix the interference problem. And if you don't obey the order, you
may be fined or imprisoned. That threat alone should be sufficient to
make you think twice about using a Class A device at home.

If the Commission's rules seem to incorporate more than a bit of Big
Brother, get ready for more. The FCC also has the authority to demand
to see your personal computer at almost any time it wants. The FCC
rules require that the owner of any Class A or B device (or any
equipment subject to the FCC rules) make the equipment and any
accompanying certification available for inspection upon request at
any reasonable time (generally, that means 9 A. M. to 5 P. M. on
workdays). You must also "promptly furnish" information about the
operation of your PC to any FCC representative who calls upon you.

Don't bother watching warily out your windows for big vans slowly
driving down your street with dish antennas pointed in your direction,
however. Those vans are things of cheap spy novels and even cheaper
movies. In reality, the FCC uses ordinary-looking cars that may not
even have visible antennas. Moreover, the FCC doesn't arbitrarily go
out looking for people using Class A computers in their homes. The
interference-locating equipment goes out in response to complaints, so
the odds are you'll hear from your neighbors before the FCC knocks. NO
SALE The FCC is more concerned about preventing the sale of
interference-causing equipment in the first place so that you don't
get a chance to put wavy lines through all your neighbor's favorite TV
shows. To that end, the FCC rules prohibit equipment that meets the
Class B definition from being sold or offered for sale without
certification. Class B personal computers that are not FCC certified
cannot legally be advertised for sale, although ads announcing
products with a disclaimer noting that the device is not yet certified
and thus, not available for sale) are permitted. If a company markets
a computer that has neither been approved by the FCC as a Class A
device nor certified as complying as a Class B device, that company
can be fined and ordered to stop selling the equipment. If the company
continues to flout the rules, company officials can be jailed.
According to the FCC, most companies get into compliance right away.

Before a Class B device is certified, it can be displayed at shows and
demonstrated with the appropriate disclaimer attached. The primary
prohibition is against sales of noncertified equipment. Thus, for
example, precertification demo units can be distributed but not sold
to computer dealers for display.

The certification process requires that a representative sample of the
personal computer or peripheral be sent to the FCC Laboratory in
Columbia, Maryland. The FCC will then test the device to determine
whether its emissions are within the limits specified for Class B
devices. If the unit qualifies, the FCC certifies the unit and issues
a certification number.

Every model of a personal computer that differs as to case, power
supply, or motherboard must be separately certified. Thus, if a
manufacturer offers two case styles-desktop and floor-standing-and
three system boards-286, 386SX, and 386DX-each of the six
configurations must be individually certified.

A personal computer need not be recertified if it differs from a
certified model only by the addition of a certified peripheral. For
example, a manufacturer could create a separate model by installing an
extra FCC-certified serial board. In this case the new" model would be
covered by the certification of the old one. As long as the model
changes do not affect the speed or radiation potential of the
equipment, recertification is not required.

IBM has proposed that the FCC begin certifying motherboards. This
would allow manufacturers greater freedom in building a variety of
computer models and would also let them install newer, more-powerful
certified motherboards in already-certified systems, without
recertification. Should the FCC accede to this proposal, new personal
computers could be introduced without the enforced hiatus of the
certification period.

Computers from different vendors can share the same FCC number,
providing they are identical units made by a single manufacturer and
differ only cosmetically-for example, in label or color. In the past,
the FCC required that it be notified about different trade names used
on certified products. This requirement has been relaxed under the new
(1989) rules. On the other hand, computers with different packaging,
processors, or power supplies cannot share an FCC certification number
even if they are made by the same manufacturer'

All of these niles may seem to make FCC certification important only
to computer manufacturers. And it remains true that in the end,
whatever its certification class, you are still liable for cleaning up
any interference problems your PC causes your neighbors. But FCC
certification should be important to you. The obvious reason is that a
Class B device is less likely to cause interference and thus makes it
less likely that you'll get involved in an imbroglio with your
neighbors about their television reception.

Moreover, lower emissions at radio frequencies generally go
hand-in-hand with lower emissions at lower frequencies, such as the
60-Hz fields that some scientists now believe may promote cancer and
have other biological ill-effects. (This issue was discussed in Lab
Notes in the December 12, 1989, issue of PC Magazine.) That can be
disturbing if you worry about the health effects of low-frequency
radiation.

Finally, all else being equal, achieving Class B certification takes a
better design and better workmanship. Although a certification sticker
is no guarantee that a particular product is well made, that sticker
does show that the PC or peripheral to which it is attached has met an
important technical standard that uncertified equipment has not.
Although you should not rely entirely on FCC certification when buying
a PC, it does give you one more piece of evidence about the quality of
your prospective purchase. Winn L. Rosch is a contributing editor of
PC Magazine.

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Citation-> Electronic News, Dec 24, 1990 v36 n1841 p1(2)
COPYRIGHT Fairchild Publications Inc. 1990

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Title-> U.S. makers cool to FCC CPU board certification plan.
(Federal Communications Commission proposed certification
of central processor units)

Authors-> Connelley, Joanne

Summary-> Several major US computer makers have filed petitions
against a Federal Communications Commission (FCC) proposal
to extend its Part 15 certification program to include
standalone microcomputer CPU boards. Zenith Data Systems,
Compaq, Tandy Corp and AT and T have filed against the
proposal, while IBM supports the proposal, with some
reservations. Foreign manufacturers generally support the
proposal, which would essentially reclassify CPU boards as
peripherals. At present, the FCC requires separate
certification of every microcomputer configured with a
different CPU board. The proposal would require separate
certification of the CPU board when it is sold alone. The
FCC seeks to reduce radio frequency interference from
digital devices that fall under the Part 15 guidelines.

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U.S. Makers Cool To FCC CPU Board Certification Plan

WASHINGTON -- Several U.S.-based computer manufacturers are giving a
cool reception to a recent FCC proposal to extend its certification
program to include stand-alone CPU boards, a move that would allow PC
makers and systems integrators to swap boards without requiring
approval for each system configuration.

In filings with the FCC, AT&T, Tandy Corp., Compaq Computer Corp. and
Zenith Data Systems argued that the proposed changes could result in
an increase in the number of computer systems which do notcomply with
the FCC's Part 15 radio frequency limitations. IBM Corp., while
supporting the FCC's proposal to permit authorization of modular CPU
boards, expressed reservations over the FCC's plan for implementing
the changes.

At the same time, the FCC heard from a number of foreign-based
manufacturers, largely of Japanese and Pacific Rim origin, expressing
general support for the reclassification of CPU boards as peripherals
with certain modifications.

The debate began in September with the release of a notice of proposed
rule making in which the FCC sought comment on changes to the
treatment and testing procedures of CPU boards (EN, Oct. 1). Citing
the increased popularity of modular PC systems that allow consumers to
put together their own combinations of base units and CPU boards, the
FCC recommended that CPU boards be treated as peripherals, making them
subject to the same testing and authorization regime as other Part 15
digital devices.

Current FCC rules require manufacturers to receive separate approval
for every PC reconfigured with a different CPU board that is sold to
the public. Under the new rules, separate authorization of the CPU
board would be necessary when it is marketed as a stand-alone product,
but when authorization would be required.

While most commenters wholeheartedly endorsed the commission's twin
goals of diminishing the interference potential of computer equipment
and reducing testing and compliance burdens on manufacturers,
manufacturers were split on how the commission should realize those
goals.

"Tandy is seriously concerned that the Commission's proposal, in its
current form, would lead to non-compliant computer systems, create
potential enforcement problems for the commission and competitively
disadvantage large computer manufacturers," according to a recent
Tandy Corp. filing with the FCC. Tandy contends that systems which
include necessary emissions-reducing features are more expensive to
manufacture than non-compliant systems which could be assembled by
integrators under the proposed rules.

Zenith Data Systems, while acknowledging that controls are needed on
stand-alone CPU boards, also warned the commission that "The changes
do open up an avenue that could lead to many computers being
manufactured and sold into the residential environment that do not
meet the specifications set forth" by the FCC.

In its filing with the FCC, AT&T said it opposed treating CPU boards
as peripheral devices, and urged the commission to craft separate
rules for those devices.

"Because of this difference between CPU boards and peripheral devices,
treating CPU boards as peripherals would permit combinations of CPU
boards and base units that might create harmful interference," AT&T
said. Because of the variation in emissions created by different
combinations of CPU boards, base units, and associated power supplies,
AT&T suggested that manufacturers should be required to test each
authorized CPU board in a representative configuration of every system
in which the manufacturer's marketing material states that the board
can work.

"AT&T sees no need to impose the extreme burden on manufacturers of
testing every possible combination," the company told the FCC. "In
order to reduce the possibility that customers will use CPU boards in
untested combinations, AT&T's Rule requires that the marketing
materials prominently state that the CPU board can only be used with
items listed in the marketing materials and that the Commission's
rules make the user responsible to prevent subsequent interference."

Similarly, Compaq took issue with the FCC's characterization of a CPU
board, calling it "the heart of the computer without which there are
no peripherals." Without testing, Compaq contends, there is no way to
know whether a combination of mother-board, enclosure, storage medium,
and power supply meet the FCC's emissions limits for Class B machines.
Like AT&T, Compaq urged the commission to require manufacturers to
demonstrate the compliance of CPU boards for those machines for which
the device is promoted.

Major Asian and Pacific Rim-controlled PC manufacturers responding to
the FCC proposal, including NEC Technologies, Daewoo Telecom and
Advanced Logic Research, expressed enthusiastic support for the
reclassification of CPU boards as peripherals.

----------------------------------------------------------------------

Citation-> PC Week, Aug 15, 1988 v5 n33 p1(2)
COPYRIGHT Ziff-Davis Publishing Co. 1988

----------------------------------------------------------------------

Title-> PC makers go under ground to circumvent FCC guidelines.
(includes related article on FCC-approved labs to help
manufacturers curb RF noise)

Authors-> Chandler, Doug

Summary-> Several microcomputer manufactures sell machines that do
not meet the FCC's shielding requirements. Some
manufacturers use counterfeit FCC-approval stickers, while
others send special machines to the FCC that do not
resemble final products. The FCC's ability to take action
is hindered by funding constraints, and poorly shielded
microcomputers are expected to continue to proliferate.

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PC Makers Go Underground To Circumvent FCC Guidelines

When a Washington-based systems integrator took its new line of add-in
boards to the Federal Communications Commission to be tested on a PC
for radio frequency interference (RFI) emissions, it entered into a
world of bribery, forgery and other illegal activities.

The boards themselves passed the FCC's tests without a problem,
said Merle Coe, president of HAAR Industries Inc. in Washington.
However,

Mr. Coe's company went through about 150 PCs--including models from
AST Research Inc., Hewlett-Packard Co., IBM, Mitsubishi Electronics
America Inc. and ITT Information Systems--before it found one that
would pass the FCC's Class B specification, he said.

Despite the FCC's enforcement efforts, many manufacturers sell
significant amounts of PCs, some with counterfeit FCC-approval
stickers, that would not pass the agency's stringent Class B emissions
standards for PCs that can be sold to the home market.

Every PC hardware manufacturer has to submit its hardware to the
government for FCC emissions approval. This often time-consuming
process forces many PC manufacturers to make a choice: They can spend
the extra R and D money and suffer through long lead times on new
products, or they can skirt the approval process to get their products
on the street.

'Lab Queens'

Some take the latter route, according to independent testing
laboratories and other industry sources, by sending the FCC
"laboratory queens," which are specially shielded systems that pass
emissions tests but don't resemble what finally ends up on store
shelves; by trying to bribe officials at independent emissions labs to
build "laboratory queens" for them; by putting FCC certification
stickers granted for one PC model on other models that haven't passed
inspection; and by printing counterfeit FCC stickers for their
hardware.

Approximately 75 percent of the off-the-shelf PCs that the FCC
recently tested failed the Class B certification test, according to J.
Jerry Freeman, the FCC's national coordinator for computer-marketing
enforcement. These machines, which the FCC had targeted as
potentially violating emissions standards, had originally been granted
Class B approval based on earlier tests of sample machines.

The FCC sets these guidelines to keep unauthorized emissions from
disrupting signals critical to police, fire and hospital
communications, and from interfering with television transmissions.

For smaller PC makers, especially overseas vendors, "there is extreme
market pressure to be on the street with the latest and the greatest,"
said Edward Black, president of Certitech Laboratories Inc., in
Running Springs, Calif. "The FCC emissions gauntlet is at least four
months, and then you could fail." Certitech refuses to prepare
special machines for companies to submit to the FCC, though "I've been
offered several bribes," Mr. Black said.

Rhein Tech Laboratories Inc. has also been approached to build
"laboratory queens," according to Richard Fortune, president of Rhein
Tech in Herndon, Va. "One lab did that for a monitor," he said.
"They put ferrite beads all over the circuitry [for emissions
shielding]."

When HAAR was trying to find an FCC-approved PC to test its add-in
boards, a second board maker offered the firm a "quiet" machine that
didn't give off illegal emissions--for $25,000, Mr. Coe said.

PC makers can also buck the FCC by putting invalid or counterfeit
certification stickers on their machines. The FCC does not supply
certification stickers; PC makers can legally print stickers for their
machines after the products receive certification, Mr. Freeman said.

The agency does not have the resources to print the stickers itself,
and Congress isn't likely to approve funds for the stickers, he said.
"If we did print the stickers we would [be forced] to have inspectors
make sure they went on the right machines," Mr. Freeman said. "It's a
Pandora's Box."

Some firms buy PCs off the shelf, remove the FCC sticker, and print up
thousands of duplicates, according to a salesman for a San Francisco
Bay area PC maker who asked not to be identified.

The salesman's firm was tipped off that its FCC sticker had turned up
on the back of some portable PCs, "and we don't make portables," he
said.

One Sunnyvale, Calif., distributor has been known to offer dealers a
motherboard, a PC case, a power supply and an FCC sticker in an
envelope. The sticker than then be attached to the system once it's
assembled, which is illegal, according to the salesman.

"We've had several leads on counterfeit stickers, but it's hard to
prove," Mr. Freeman said. "If we can get a good case, we will pursue
that as a felony."

Some users were surprised at the seemingly widespread nature of the
certification problem. "I normally do not look at the FCC sticker,"
said Steve Curcuru, information manager in charge of PCs at WNEV-TV in
Boston. "If the machine is from a major manufacturer I often assume
it has passed the test. That's probably not a good idea."

The funding constraints on the FCC have given some manufacturers the
confidence to do as they please regarding certification.

One source said a PC maker recently bought a computer from IBM,
replaced the IBM labels with its own and sent the machine to the FCC
for testing. "That's the most severe case of sticking it in the
commission's nose I've heard of," the source said.

FCC-Approved Labs

Have Hands Full in

Quieting RF Noise

The most potent source of PC radio frequency interference (RFI) is the
crystal that controls a microprocessor's clock speed, according to
Steven Dayhoff, director of laboratory operations at Rhein Tech
Laboratories Inc., in Herndon, Va.

Rhein Tech is one of 40 laboratories approved by the Federal
Communications Commission to help manufacturers modify the design of
their products to eliminate RFI emissions. Approximately 15 of these
labs specialize in the PC area, according to FCC officials.

RFI puring out of a poorly shielded PC can interfere with television
reception. More importantly, however, it can disrupt aircraft
control-tower transmissions and police, fire and emergency medical
communications, according to Richard Fortune, president at Rhein Tech.

The problem works in reverse as well. A poorly shielded computer can
allow radiation to seep in from other sources.

"When military ships in Norfolk, Va., test their high-powered radar,
it knocks out computer databanks in local financial institutions,"
said J. Jerry Freeman, national coordinator for computer-marketing
enforcement at the FCC offices in Norfolk. "I have to make
arrangements to have their computers turned off."

The FCC's Class B standard for PCs that will be marketed for the home
as well as the office is 10 times more stringent than the Class A
standard, which applies to machines that will be used only in business
environments, FCC officials said.

The agency fines PC makers $2,000 for selling uncertified PCs, Mr.
Freeman said.

A $250,000 fine and as many as five years in jail await those
convicted for printing counterfeit certification stickers, which is a
felony, he said.

"We are trying to regulate the industry and protect the
electromagnetic spectrum," Mr. Freeman said.

----------------------------------------------------------------------

Citation-> Government Computer News, Oct 23, 1987 v6 n21 p98(1)
COPYRIGHT Ziff-Davis Pub. Co. 1987

----------------------------------------------------------------------

Title-> CBEMA fights FCC emissions policy. (the Computer and
Business Equipment Manufacturers Association complains
about the FCC's attempts to reduce electromagnetic
interference)

Authors-> Munro, Neil

----------------------------------------------------------------------

CBEMA Fights FCC Emissions Policy

The Federal Communications Commission's attempt to reduce
electromagnetic interference (EMI) with radio, television and
telephone communications caused by growing numbers of powerful PCs has
prompted complaints from the Computer and Business Equipment
Manufacturers Association (CBEMA).

In a letter to the FCC, CBEMA protested the commission's recent
revision of MP-4, the set of regulations that govern the measurement
of electromagnetic emissions from computers.

The letter from acting CBEMA president Oliver Smoot said the
association fears that "devices previously tested and determined to be
compliant with the limits could now have to be redesigned." It said
the changes could have a "severe economic impact."

FCC official Art Wall said the revision of MP-4 merely clarified what
was current FCC practice. He said the FCC wished to measure the
highest level of emissions from any PC being tested and intended to do
this by testing the computers in a large number of configurations.

The EMI from computers can vary enormously, and simple movements of
cables can increase EMI by 10 times to 1000 times, Wall said. The FCC
found one computer that was interfering with communications at a
one-mile distance, he said.

Wall said CBEMA preferred only to test the computers from a few
aspects while they are on a test stand and objected to moving the
cables.

CBEMA argued that the FCC's description of the revisions as
"editorial" changes was incorrect. Because the changes were
substantive, they warranted a period of public comment before being
established as policy, a CBEMA statement said.

Wall said the FCC has allowed a public comment period on the current
set of MP-4 regulations and he is preparing a reply to the CBEMA
letter.

An electronics engineer at the FCC Laboratory, Richard F. Fabina, said
the EMI problems posed by modern PCs were not limited to TV reception
in the next room. He said the increased background level of EMI
threatened to interfere with radio, television and phone
communication.

Fabina said the increasing clock speeds of modern PCs is a major
problem, because the harmonics of the computer's 16 MHz to 32 MHz
emissions intrude into the VHF and UHF regions used by telephones and
radios.

Fabina said the second major source of EMI is poorly shielded
computers assembled from inexpensive components. These computers,
relatively easily assembled by individuals or small companies, produce
much EMI, he said.

More expensively engineered machines from well-known manufacturers
cause considerably fewer EMI problems, he said.

----------------------------------------------------------------------

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  3 Responses to “Category : Tutorials + Patches
Archive   : FCC.ZIP
Filename : FCC

  1. Very nice! Thank you for this wonderful archive. I wonder why I found it only now. Long live the BBS file archives!

  2. This is so awesome! 😀 I’d be cool if you could download an entire archive of this at once, though.

  3. But one thing that puzzles me is the “mtswslnkmcjklsdlsbdmMICROSOFT” string. There is an article about it here. It is definitely worth a read: http://www.os2museum.com/wp/mtswslnk/