William H. Graff, American TCB

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William H. Graff, American TCB
Overview of Hearing Aid Compatibility (HAC)
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Presentation Overview

• This presentation is an introductory overview of
  the FCC Perspective to Cellphone HAC requirements
  and recent information released by the FCC
  regarding this new requirement.
• Detailed test methods or setups are not covered
  in this presentation.

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What does HAC compatibility mean?
That a device does not cause interference to
hearing aid. That a Hearing Aid is immune to
external interference which may be caused by a
wireless device. That a device provides output
for T-Coil so that the hearing aid can be
used. Note that even with best intentions,
compatibility between 2 particular random
devices can not be fully guaranteed due
to variances of design of all devices.

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Historical Perspective Wireline Phones

• During the 1970s changes in audio transducers
  caused some hearing aids to no longer work with
  some telephones.
• In the 1980s, FCC and IC implemented HAC
  standards for telephone connecting to the public
  network as part of Part 68 and CS-03 standards
  (wireline devices).
• These standards addressed only H-field
  performance of the telephone handsets
  (H-field magnitude, spatial
  distribution, and frequency response).

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Historical Perspective -
Move Toward Wireless Phones

• In the 1990s, new digital technologies were
  found to cause audible interference in certain
  hearing aids
• Mobile phones were exempt from HAC in earlier
  years due to lack of applicable ratings and
  measurements standards.
• The Telecom Act of 1996 mandated compatibility,
  but not enough action was taken by manufacturers.

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Historical Perspective Wireless Devices

• ANSI C63.19 was approved in 2001 as a relevant
  rating and measurement standard
• New FCC regulation as of July 10th 2003 mandated
  a certain level of availability of HAC handsets
  both manufacturers and the carriers must make HAC
  wireless phone available to individuals using
  hearing aids.

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Historical Perspective Wireless Devices

• Since 2003, the use of wireless phones has
  increased dramatically. Wireless phones are used
  everyday for safety, business and personal use.
  The FCC has noted that it is more vital than ever
  for individuals with hearing impairment to have
  access to digital wireless phones.

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FCC Implementation

• Report and Order (RO) FCC 03-168 removed
  exemption of certain digital wireless devices
  therefore making HAC required by certain mobile
  phones falling under Part 22, 24, and 90. ANSI
  C63.19-2001 was originally referenced in the
  associated rules given in 47 CFR section 20.19.
• Public Notice DA-05-1134A1 accepts an updated
  standard draft version 2005 of
  C63.19.

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FCC Implementation

• Additionally in June 2005, the FCC reaffirmed the
  timetable for development and sale of digital
  wireless phones that are HAC compliant and later
  on July 11 published a consumer advisory about
  this.

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FCC Implementation - Carriers

• September 16, 2005
• The 5 largest U.S. wireless carriers (Sprint,
  Nextel, Verizon Wireless, Cingular, and T-Mobile)
  must
• Either make 4 HAC handsets available for each air
  interface or
• Ensure that 25 of their handset models are
  HAC compatible.
• HAC compliance is for RF Emissions Rating
  M3 to 20.19(b)(1)

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FCC Implementation Manuf.

• September 16, 2005
• Each manufacturer of handsets used with public
  mobile services for use in the United States or
  imported for use in the United States must
• Make 2 HAC handsets per air interface that meet
  with RF Emissions Rating of M3 to 20.19(b)(1)

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FCC Implementation - Carriers

• During 2006 the 5 largest U.S. wireless carriers
  must
• By September 16, 2006 make 5 HAC handsets
  available for each air interface must be
  compliant with with RF Emissions Rating of M3
• By September 18, 2006 2 Models of each
  interface must comply with inductive
  coupling Rating of T3 to 20.19(b)(2)

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FCC Implementation Manuf.

• September 18, 2006
• Each manufacturer of handsets used with public
  mobile services for use in the United States or
  imported for use in the United States must
• 2 Models of each interface must comply with
  inductive coupling Rating of T3

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FCC Implementation - Carriers

• By February 18, 2008, manufactures and
  carriers alike
• Ensure that 50 of their handset models are HAC
  compliant with RF Emissions Rating of M3
• The results based upon our experience with
  business competition is that individual
  manufacturers must agree to HAC compatibility now
  or be shut out of the USA market in the future

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FCC Implementation

• There is a legal term described as the De
  minimis exception for certain manufacturers or
  service provides that offer 2 or fewer handset
  models in the U.S. These providers are exempt
  from HAC requirements. But manufacturers that
  offer 3 or more handset models at any given time
  must make at least one complaint phone every 2
  years.

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FCC Implementation

• Much of this information has been published in a
  consumer advisory for public awareness of the
  FCCs position and some implementation dates
• http//ftp.fcc.gov/cgb/consumerfacts/accessiblewir
  eless.html
• However, please note that this mainly addresses
  the carriers and does not adequately address the
  manufactures.

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FCC Implementation

• Manufacturer information can be found in sections
  20.19(c)
• An amendment to 20.19 was published July 27,
  2005, in the Federal Register under 70 FR 43325.
  The effective date is August 28, 2005.

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FCC Implementation

So it appears that while the FCC has tried to
make phase in periods as straight forward as
possible, suffice it to say we all feel
Everything Is Now Clear as Mud!!
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FCC Implementation
Specific questions regarding how your offerings
are affected by HAC requirements, or how many
units are required to be HAC compliant should be
addressed to the FCCs Wireless
Telecommunications Bureau (WTB) directly. Note
this is NOT the same branch of the FCC from which
you obtain Equipment Authorizations

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FCC Implementation
WTB Contact Information There are specific
contacts at WTB that you should reach if you have
questions regarding the phase in requirements and
how they apply to your company. However I do not
have the specific contact information today, but
expect to have it shortly. If you require this
information, please contact us and we will be
glad to forward to you!

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Additional Carrier Expectations
All carriers owned and operated retail outlets
must make live, in-store testing available to
consumers. Carriers are encouraged to include
HAC information on call-out cards as part of
handset displays. Wireless service providers are
encouraged to provide a 30-day trial period or
adopt a flexible return policy. This allows
individuals with hearing aids sufficient time to
choose suitable phones.

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FCC Rules 47 CFR 20.19

• All digital transmission modes in all frequency
  bands contained in a HAC phone must meet Level M3
  or M4 levels.
• Assumes held to ear usage.

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FCC Rules

• Note
• 20.19 (b)(1)-- The original U rating previously
  given in C63.19 2001 is now equal to an M
  rating in C63.19-2005.
• 20.19 (b)(2)-- The original UT rating previously
  given in C63.19-2001 is equal to a T rating in
  C63.19-2005.

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FCC Rules

• 20.19 f) Labeling Requirements
• Handsets used with public mobile services that
  are hearing aid compatible, as defined in
  20.19(b) shall clearly display the rating, as
  defined in 20.19(b)(1)/(2) on the packaging
  material of the handset. An explanation of the
  ANSI C63.192003 M-rating system shall also be
  included in the owner's manual or as an insert in
  the packaging material for the handset.
• Although the manufacturer is required to
  place this information on the package, it
  is not necessary to provide this during
  your equipment Certification
  Process.

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FCC Rules

• Relevant user information (i.e. users manual)
  should be provided that
• Is complete, clear and easily understood by the
  average consumer.
• Explains the HAC rating system for both the
  wireless device and hearing aids and their
  use as a pair.

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FCC Rules

• Explains how to use the device (i.e. including
  specific instructions about antenna positioning
  if applicable i.e. the antenna should be
  extended for best compatibility).
• Provides details of any special user selectable
  HAC modes (i.e. acceptable modes might be back
  light off, BT off, Tcoil on, and similar. Note
  that RF power cannot be reduced and basic phone
  functionality must be preserved.)

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Manufacturer Expectations

Manufactures need to start phasing in HAC
compliant phones as soon as possible to meet FCC
deadlines. HAC handset packaging must have
prominent exterior labeling indicating the
handsets technical rating and have more detailed
information included inside the package. This
information will allow end users to quickly and
easily determine which handsets are compatible
with their hearing aids.
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HAC Test Standards/Regulations

ANSI C63.19 2001 and 2005 editions Title
American National Standard for Methods of
Measurement of Compatibility between Wireless
Devices and Hearing Aids Note Europe and other
regions are expected to follow with
HAC requirements in the future.
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HAC Test Standards/Regulations

The 2005 editions was recently accepted by C63
but is currently a draft. The FCC has commented
that they expect few changes, and any changes are
likely not expected to impact the technical
nature of the document.
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HAC Test Standards/Regulations

While approvals can be done to the 2001 or 2005
editions, the FCC does not expect many
applications to follow the 2001 edition.
Additionally, please note that approval to the
2001 edition will likely slow down and complicate
the review process. Where possible, ensure
compliance to the 2005 edition.
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The M Ratings

• M1 M4 Phones
• A phone which has low interference-causing
  emission (H- and E-field) is given a higher M
  rating. The rating is based upon a peak field
  strength as measured over a 5 x 5 cm grid in the
  region of the ear piece.

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The T Ratings

• T1 T4 Phones
• A phone is rated for quality of desired signal in
  T-coil mode. The rating is based on measurement
  of audio band magnetic signal strength, signal to
  noise and frequency response.

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Test Evaluation M Rating Considerations

All normal ear configurations should be described
and tested. One exception is that if the device
has an extendable antenna, then only the extended
position needs to be tested. User instructions
are not considered sufficient to test a subset of
operational conditions.
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Test Evaluation M Rating Considerations

Options that can affect HAC must be tested (i.e.
form factors, batteries, metallic face plates,
etc.) If a Tcoil exists in the device, the
measurement grid for M ratings shoiuld be
centered and performed on both the acoustic and
Tcoil locations.
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HAC Test Equipment

We expect that several manufacturers will be
coming out with appropriate test equipment for
wireless device HAC tests. However currently
this equipment is already offered by both Aprel
and ETS/Lindgren.
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HAC Test Equipment

Aprel
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HAC Test Equipment

ETS/Lindgren
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Certification Applications

Applications for M ratings can currently be
submitted to TCBs that have been to FCC training
on HAC. Applications including T coil data or
that require special accessories to be HAC
compliant can currently only be submitted to the
FCC directly.
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Certification Applications

Additionally please note that an HAC approval
can be added to an existing model via a Class II
Permissive Change. This assumes that there is
not any hardware changes necessary to make the
phone HAC compliant.
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Certification Applications

The FCC expects a very complete and
comprehensive test report for HAC to be provided.
The level of detail and data is similar in many
ways to the current SAR reports you may be
familiar with.
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Certification Applications

For example, the report should include All
contour plot with device and grid overlays,
measurement uncertainity, summary of all values,
measurement system description and factors,
detailed EUT information (such as modulations,
modes, etc), calibration information, validation
information, etc.
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Related HAC Articles/Sites

http//www.fcc.gov/cgb/consumerfacts/accessiblewi
reless.html http//www.asha.org/about/publication
s/leader-online/archives/2003/q4/031104a.htm http
//www.audiologyonline.com/articles/arc_disp.asp?i
d1263
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Questions?

• whgraff_at_atcb.com
• major_at_atcb.com
• jerry_at_atcb.com