2014-04-07-07 How To Review and Application

Report
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 met

Remember
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 Short
KDB 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
From Marvell http://www.marvell.com/communication-processors/pxa968/

What do you see?

Are there any Tx’s?

Does it raise
questions?

Needs frequencies
of operation

Do all features from
photos show here?
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 reopen 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 procedure
Special 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

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