FCC Certification ...

I note that Farnell UK declares very strong policy statements, which include:

Statement of Quality Policy (part) [my highlighting]

 

All employees will be appropriately trained so they understand fully the importance of meeting customer as well as statutory and regulatory requirements. All training will be recorded.

Top management support will be given at all levels of the business to ensure that sufficient resource is available to realise customer expectations, to ensure legal compliance and to see that the requirements of any relevant national or international standards are satisfied.

That sounds very professional, and it doesn't leave much room for misinterpretation.

So why is there so much difficulty in locating and supplying the relevant certifications that were obtained by Raspberry Pi?  Or does the above Statement of Quality Policy apply only to Farnell UK?

I note that Farnell UK declares very strong policy statements, which include:

 

Statement of Quality Policy (part) [my highlighting]

 

All employees will be appropriately trained so they understand fully the importance of meeting customer as well as statutory and regulatory requirements. All training will be recorded.

 

Top management support will be given at all levels of the business to ensure that sufficient resource is available to realise customer expectations, to ensure legal compliance and to see that the requirements of any relevant national or international standards are satisfied.

I decided to see if any of the Newark support folks on live chat have any such training

on FCC regulatory requirements.  Here's the relevant excerpt:

me:  What are you basing your opinion on? Have you been trained at all on FCC rules?

agent:  No I have not you may contact the FCC directly or you may contact the Raspberry PI foundation.

agent:  I have sent you a link for that before.

me:  Is there someone else I can chat with that has some training on FCC rules?

agent:  We are not trained on FCC rules I apologize.

me:  Is there someone else I can chat with that has some training on FCC rules?

agent:  No I am sorry we do not have anyone that is trained on that in our department.

If that requires Pi board redesign, so be it, the result will be a better board.

Back in May 2012, Eben said there was already PCB-level work going on to meet Class B standards.

Starting at 17:35

http://www.youtube.com/watch?v=WIf4Fk2252A

So the question was when are the boxed ones for kids going to be available?

Most of our distribution partners have boxing plans afoot.

I've seen some CAM models they look pretty cute.

I guess the kid's thing's got two things associated with it.

One of them is a Class B FCC pass, so a consumer FCC pass.

It's really pretty important I think not to start to ship millions of these

into schools before we have the FCC pass,

so we'll be doing that.

There's PCB level work going on at the moment to accomplish that

and, yeah, lets say summertime.

It doesn't take 14 months to redesign a small board and a box, so a reasonable conclusion is that the PCB work Eben described as ongoing in May 2012 was put on hold.

Pi board redesign is Pete Lomas' bailiwick, I think.  I wonder if there are any clues as to why the work was stopped in the articles he's written.

It doesn't take 14 months to redesign a small board and a box, so a reasonable conclusion is that the PCB work Eben described as ongoing in May 2012 was put on hold.

So maybe it's all Jamodio's fault for finding the LAN chip power bug, which may have accelerated plans for rev 2.0, pushing Class B compliance back to rev 3.0.  Then maybe 3.0 was delayed by the camera module.  Who knows?  The emphasis these days seems to be on industrial applications, so that may have shifted the focus away from homes and schools.  A recent Eben intervew says:

Gareth Jones tells me that the Raspberry Pi is being considered as a processor for controlling industrial processes, with a division of Sony in San Jose interested in using the computer for a project they’re developing.

http://www.makeuseof.com/tag/raspberry-pi-featureinterview/

The interview says they will soon be producing up to 12,000 boards per day, and I doubt they are expecting schools to be a large fraction of that demand anytime soon.

I've added FCC reference links confirming currency of the Class A and B definitions to my long post #16 above.

During the whole conversation, I did not see any mention of the new rev of the boards.

The conversation seemed to cover the original design, and ignore the changes made in the latest release.

Maybe this one passed all the test, but we do not have documentation.

Just my two cents.

AC9GH

Yes, that's clearly a very relevent issue, since certification of one revision of a board may not carry over to another revision.  What's more, Pi Models A and B are very different electronically despite using the same PCB.

So, quite separate from the issue of Class B certification for what is clearly a device in residential use, there is also the matter of whether the revisions of both models sold today are actually covered by a current FCC certification even for Class A.  Newer revisions can usually be expected to behave better than old ones (as I think you were hinting), but this of course needs to be verified.  I assume that a test certificate details the exact board revision being tested, so Element14 can (presumably) verify the validity of existing certifications immediately without room for doubt just by checking revision numbers.

I suspect that there are clear rules for when a certification can be carried over to a new revision and when not.  Has anyone found the relevant FCC guidelines?

I suspect that there are clear rules for when a certification can be carried over to a new revision and when not.  Has anyone found the relevant FCC guidelines?

See p. 10 of the previously cited OET Bulletin 62 under the heading

What changes can be made to an FCC-authorized device without requiring a new FCC

authorization?

http://transition.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet62/oet62rev.pdf

If my reading of p.13 is correct, then "For certified equipment (personal computers and their peripherals)", with the proviso that clock circuitry is unchanged (because that could entirely change RF characteristics), if there is no increase in RF emissions, then no new certification is required.  Again stressing that this is only if my reading is correct. then because this equipment is only certified rather than verified, it is up to the certifier to declare that there has been no increase in RF emissions, rather than it needing to be verified.  It seems to work on trust.

It wouldn't surprise me if my reading of this is incorrect, since such an approach seems open to abuse --- comments welcome.  That said, I would not expect any  engineering professional in the Pi ecosystem to abuse such regulations, so it doesn't seem to be relevant here.

In other words, it seems to me that if Pi development engineers find that "a change does not affect, or reduces the radio frequency emissions from the device" (the FCC's words) then it's entirely proper to consider the previous certification to continue to apply.  Needless to say, this "Class I permissive change" would have to appear on the certification, or an ammendment to it.  Just saying nothing is asking for trouble.

Morgaine

Without diving in FCC, if you certify something, you have tested that it meets the necessary requirement/laws and that testing will record the conditions under which it met those requirement/laws.

If the manufacturer continues with the method, then any subsequent items will still meet that certification.

Verify is to check it still meets the requirement/law and could be random sampling (espcially if its close) or when something has been changed.

I believe there were issues with the HDMI during inital testing, hence it was reduced slightly to meet the necessary emissions, and tested under those settings.

I do note that once again NZ and Australia have been singled out.

AUSTRALIA AND NEW ZEALAND CLASS A EMISSIONS COMPLIANCE STATEMENT

Warning: This is a Class A product. In a domestic environment this product may cause radio interference in which case the user may be required to take adequate measures.

Mark

Yes Model A and B require different emissions tests given that Model A does not include the 25MHz crystal and ethernet PHY, a very well known source of common mode noise and EMI.

-J

Yes Model A and B require different emissions tests given that Model A does not include the 25MHz crystal and ethernet PHY, a very well known source of common mode noise and EMI.

-J