William H. Graff, American TCB

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William H. Graff, American TCB
Updates for Test Reporting
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GSM Duty Factor
Test Report and supporting documentation should
clearly support GPRS capabilities of the device.
Please include information regarding both the
GPRS classes (e.g. class 10 and class A). Test
with maximum power for both body-worn and head
positions as applicable. Currently the FCC has
been asking on most GSM applications to verify if
the GPRS capability will work while the device is
transmitting in voice mode.

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CDMA 2000 / W-CDMA

• The FCC has requested all TCBs to consult with
  them before any attempt to approve CDMA 2000 is
  attempted.
• FCC is considering whether or not to consider
  CDMA 2000 a new technology and therefore
  subject to approval exclusively by the Commission

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Layards
Devices with Neck worn lanyards or that are
intended to be next to the body should be tested
with 0 gap and body tissue liquid. Both Front
and Back should be tested. An eyelet on the
device does not necessitate use of neck lanyards.
Instructions to the user should clearly
support the correct uses.

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Layards
An eyelet on the device does not necessitate use
of neck lanyards. Instructions to the user should
clearly support the correct uses and accessories
provided. If the manufacturer provides a neck
lanyard with the device (in the box), or suggests
to the user that this device is intended for
lanyards, then it should be tested with 0cm gap.

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Tablet Devices

Tablet device screen sizes range 8-14 and
weights range 2-8 lbs.
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Tablet Type Devices

Smaller devices may qualify for handheld-only
operations, but filing must include strong
justification for such contact TCB or FCC for
guidance if needed. Generally unless a strong
justification can be made, portable may be
assumed.
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Tablet Type Devices
Consumer tablet PCs are expected to have
lap-held use positions per IDB RFx 7) d)
ii). - Excert from Mobile and Portable
Device RF Exposure Equipment Authorization
Procedures Released March 18, 2004 which
states For undefined or unclear device usage
positions, where existing or standardized test
procedures are not applicable, SAR should be
evaluated according to the normal operating
configurations which are intended for the device.

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SAR Test Documentation

• Important test setup details affecting SAR
  should be provided in SAR Test Documentation
• Belt clip and air gap thickness.

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SAR Test Documentation

• PCMCIA card distance to phantom for laptop and
  PDA testing.
• P1528 device reference lines
  
  
  for held to ear
  testing.

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USB Style Dongles

• Direct-connected USB (without integral cable)
  differs from most PCMCIA in that port alignment
  may be horizontal (H), vertical (V), and 180
  degrees H or V, with respect to a notebook
  computer host

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USB Style Dongles

• Grantee is responsible for SAR compliance in all
  such intended use positions.
• 1-host SAR testing is accepted for many Part 15
  and some licensed-service USB-dongle
  transmitters.
• 3-host SAR test results have been filed for some
  licensed-service devices
• IDB/KDB Mar04 webpost RFx Procedures 7)b), 7)c)
  are applicable

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802.11 WLAN Devices

The FCC has spent considerable amount of time
reviewing these devices and experimenting with
many aspects of the SAR testing. The FCC has
been seriously thinking about proposing many
changes to the SAR procedures used for testing
for these types of devices. Remember that
these are proposals, are subject to change, and
may or may not be implemented.
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802.11 WLAN Devices
Proposed Future Guidelines Only

• Proposed Changes Include the following. Note
  that these are proposed changes and should not be
  considered final until formally released by the
  FCC
• Default channels use for test may be different
  than simply Low, Mid and High and will depend on
  power measurements of channels near the Low and
  High channels. This is due to the variance of
  bandedge channels seed in some devices where the
  bandedge channels have reduced power.

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802.11 WLAN Devices
Proposed Future Guidelines Only

• 2.) Certain modulations may be considered
  required for default testing, but others may
  still need to be required depending on certain
  set power levels.
• For example, 802.11g is only required to be
  tested if the average power is 0.25 dB gt than the
  802.11b power for the same channel

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802.11 WLAN Devices
Proposed Future Guidelines Only
3.) Higher data rates usually have lower average
output. Higher data rates should be tested only
when the average output is 0.25 dB gt that at the
lowest data rate for the default a-b/g mode
test channels

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802.11 WLAN Devices
Proposed Future Guidelines Only
4.) Turbo modes (proprietary modes) typically
operate at higher data rates requiring higher
order modulations lower average power. Turbo,
half quarter rate channels should be tested at
the lowest data rate used in each proprietary
mode when the average output is greater than that
on the closest default a-b/g mode channels.

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802.11 WLAN Devices
Proposed Future Guidelines Only
5.) Switched Diversity Issue. The SAR of each
antenna should be measured independently on the
highest output channel in each a-b/g
mode. Other channels should be tested only
when the SAR vary by gt 25 for the two antennas
on highest output channel or gt 1.2 W/kg.

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802.11 WLAN Devices
Proposed Future Guidelines Only
6.) MIMO Type Devices. FCC is developing
Procedures. These are likely to involve
simultaneous TX conditions and

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5 GHz SAR

The FCC has expressed that review of SAR for
devices in the 3 6 GHz range will hopefully be
released to TCBs soon. However exact dates have
not been released.
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PCMCIA Cards
For PCMCIA Cards with antennas external to
the host device, the FCC is considering possible
changes to their current testing requirements.
1) The 3 host policy that is typically
required in certain situations may change for
depending on certain acceptable margins to
ensure compliance for variations among typical
laptops.
Proposed Future Guidelines Only

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PCMCIA Cards

• 2) The FCC is also considering test methods
  with use an extender card instead of a typical
  laptop computers and compare these measurements
  to those made in a typical host.

Proposed Future Guidelines Only

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Proposed Changes
The FCC also expects that any new procedures
required for SAR measurements will likely also
have a transition period associated with them.
This is subject to be determined depending on the
future release of information from the FCC.

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FCC/TCB Training Bulletins

• HAC for cellphones is mandatory on for 25 of a
  carriers product line
• HAC test procedure already exists.
• TCBs are able to review HAC soon.

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FCC/TCB Training Bulletins

• 5GHz SAR not yet released to TCBs.
• Notice will come in the form of a RO
• Training material is in preperation

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FCC/TCB Training bulletins

• SAR testing for WiFi products is being further
  refined.
• More emphasis on test software used inside WiFi
  transmitter and defining its characteristics.
• FCC will require more documentation of software,
  especially on/off transmitter timing
  characteristics.

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FCC/TCB Training Bulletins

• No agreement yet on DFS testing for 802.11a.
  Testing with NTIA / FCC on proposed new procedure
  has been scheduled for November.
• FCC hopes to get revised DFS Test Procedure to
  TCBs before end of year.

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FCC/TCB Training Bulletins

• Field Programmability to add DFS to existing
  802.11a radios prohibited unless radio is
  Certified as a SDR.
• Factory programmability allowed using the Class
  II change procedure.

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FCC/TCB Training Bulletins

• DFS products must go to FCC
• SDR products must go to FCC
• A DFS testing exclusion exists for client
  equipment which is under the control of a
  Certified access point.
• Ad-Hoc mode for clients prohibited

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FCC/TCB Training Bulletins

• FCC has provided further guidance on MIMO and
  steered array antennas.
• Specific guidance is offered from FCC on Pout
  measurements, RF Exposure calculations, radiated
  Restricted Band measurements.

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FCC/TCB Training Bulletins

• FCC will now allow Class II changes for RF
  category Portable to Mobile to be handled by
  TCBs.

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FCC/TCB Training Bulletins

• GPS repeaters are not permitted in USA. GPS
  spectrum is carefully protected. No Part 15
  Intentional Radiators are permitted.
• Reference See 15.205

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Questions?

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