Senior Technical Leader Regulatory
Cisco Systems Inc
Abstract: The FCC Authorization and Evaluation Branch has been the forefront in regards to reviewing and issuing of FCC certification. With the adoption of the Telecommunications Certified Body (TCB) program, a number of these approvals were done via TCB reviewers with FCC oversight, though the FCC did reserve some specific applications for their review only. In April of 2014, the FCC Authorization Branch issued updated KDB (Knowledge Data Base) moving all current products on the exclusion list to TCB review. In December of 2014, the FCC adopted Report and Order 13-44, which moved the overall certification process over to the TCB’s. Further a number of changes were adopted as well in regards to TCB audits, test site validations and technical standards.
One key issue manufacturers face is time to market. The FCC review process could take from 65 to over 100 days at times. As every device had to go through FCC, the number of device reviews increased and so did the review time at the FCC, which as a result impacted time to market for manufacturers. To accommodate industry the FCC acted.
In 1999, the FCC developed the Telecommunication Certified Body (TCB) certification program which offloaded some of the simpler review to Accredited 3rd party bodies.
Over the years the TCB reviewers went from approving 10% to over 90% of the products. As TCB’s gained in expertise of reviewing, the use of TCB’s reduced time to market for a number of products needing certification.
The FCC authorized them to perform reviews on more types of products including some new technologies that were restricted to the FCC, only, at one time. Some more difficult products were approved via the TCB Permit but Ask (PBA) process, which the TCB did the overall review but the FCC would review and in some case perform pre-grant audits on products before a TCB could issue a grant.
In response to petitions from the industry to further streamline the approval process and adopt the updated versions of the test standards, the Commission issued a Notice of Proposed Rulemaking (NPRM) in 2013.
In parallel to this April of 2014, the FCC removed authorized the TCB’s to be allowed to review all items on the exclusion list under PBA process.
In December of 2014, the Commission adopted new streamlined rules for the Authorization and Evaluation Branch in regards to updating the overall approval process.
Updated Certification Process
With the adoption of this order the Commission has designated that all products subject to certification are to be reviewed by the TCB’s only. The FCC lab has been tasked with developing additional guidelines and procedures in regards to facilitating this change.
With this decision, the FCC is technically out of the certification business as far as product review other than to provide guidance and consultation to the TCB’s. Obviously there will be pros and cons to tis and time will point them out but overall, the concept is good.
The role of the FCC lab will then be focused on enforcement issues, interpretations, developing guidelines and test procedures. The FCC also would develop a list of products that the TCB’s must consult with them on in regards to issuing certifications.
The FCC will also develop pre-grant audit program for the TCB’s to address new technologies being approved such as for DFS (Dynamic Frequency Selection) testing.
The TCB training seminars will still be the focus for the FCC to bring TCB’s up to speed on new requirements.
The order addresses additional requirements for TCB’s including post-grant audit process changes. With these changes the program addresses some needed changes to better help facilitate the overall process.
The changes allow the FCC to dismiss an application or set aside a grant within 30 days via the E (equipment Authorization System. Until this change only the FCC could dismiss an application or remove a grant.
In regards to being accredited as a TCB, NIST has been appointed as the Designating Authority for US TCB’s and outside the US Designated Authorities who have been recognized by the FCC in countries where MRA’s exist.
The FCC will increase overall oversight of the TCB’s themselves and TCB’s that perform poorly may be suspended or removed from the overall program until deficiencies are addressed.
The Order also addresses the requirement for the need to perform the 5% audits and stipulates some requirements to insure the manufacturers provide actual production product verse the golden sample for audit. Further the FCC lab has the retained the right to pick which samples or devices could be audited by a TCB. The FCC also limit the product audits a TCB can do to only products the TCB itself certified.
Test Site and Standard Issues
One major change is that the FCC will now require all test labs submitting test data for certification under any FCC rule part to be accredited and as such will be phasing out the listed lab list. This requirement not only applies to labs doing Part 15 and Part 18 testing but testing various licensed radio service devices.
After a specified date as set forth upon adoption of the rule change, test labs that are not accredited will no longer be able to submit test data unless accredited in accordance with ISO 17025.
In addition, any lab being subcontracted for testing by an accredited lab will also need to be accredited per the FCC regulations, even if only doing bench testing of the device.
Further in regards to recognition of accredited labs, the current proposal will be limited to countries where current Mutual Recognition Agreements exist. The FCC rules do include a mechanism for additional accreditation bodies to be recognizing as to allow non US labs in countries where there is on existing MRA to be recognized by OET.
For devices that require testing on an ANSI site, the test site must be compliant with the requirements of C 63.4 (2014) in regards to the site validation requirements. As such, the FCC R&O specifies the time period in which labs must be accredited to C63.4 (14).
Labs, which are listed on the FCC lab list, but not accredited, will also have a transition period in which to get accredited to allow acceptance of test data after the cutoff date.
The FCC adopted the latest versions of C63.4 (2014), which includes test site requirements for testing above 1GHz, This is a major change as until now, the site validation had to only be done to 1GHz.
In regards to radio testing, C63.10 (2013) has been adopted and replaces C63.10 (2009) that the FCC had authorized to be used via a Public Notice. One major change in regards to the test set up requires that the EUT antenna be mounted 1.5 meters above the ground plane for measurements above 1GHz. Further, the standard reflects most of the latest FCC changes in the various KDB’s with a few exceptions. Note that one will still need to consult the KDB’s in regard sto some differences before performing some of the tests.
As such with the mandate for these standards, test labs will need to make changes in regards to their test sites and set ups.
It should be noted that Industry Canada RSS-Gen rev 4, which was adopted in November of 2014 also references these specific standards for use in testing similar devices, thus aligning the testing requirements for US and Canada.
The FCC also addressed a couple of obsolete requirements by removing them from the rules. The FCC also addressed the question on the measurement uncertainty in regards to RF Exposure testing with the withdrawal of OET65C.
Also OET can now has the allowance through updated Designated Authority to adopt later versions of Industry Standards without a formal rulemaking, thus allowing later versions that meet FCC review criteria to be authorized for use by FCC.
In regards to the various implementation times for the various parts, the clock will start running once the order is published in the Federal Register. For additional details see the Report and Order 13-44.
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