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.

Given what we now know about the group-wide Code of Ethics, I suspect that they are currently wondering (and in great dismay about) how they ever managed to get themselves into this situation.  They have a well-manned team providing professional advice on certification to industry, yet somehow nobody noticed the need for residential certification when bringing their own digital device to market for residential use.

It's certainly a worrying problem, but delay just makes it worse, which is why I recommended on Monday that the Class B certification work be (re)commenced with maximum urgency to reduce the risks for all stakeholders in the chain.  Everything else can be done in parallel while the certification work runs its course.

Mark Beckett wrote:

 

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.

The FCC provides some guidelines that explain what constitute a change that may require a new test. Also is not "you" who can perform the test, it has to be an approved third independent party who performs the test.

Here is some information about the enforcement arm of the FCC

http://transition.fcc.gov/eb/

-J

jamodio

Also is not "you" who can perform the test, it has to be an approved third independent party who performs the test.

Yes. We also have to use recognised testing authorities for certification.

Very interesting link.

It shouldn't be hard to follow whats needed to rectify.

Thanks

Mark

Mark Beckett wrote:

 

Yes. We also have to use recognised testing authorities for certification.

To add a ray of sunshine to a rather depressing week on the certification front, your system of democracy is working well too --- "New Zealand Bans Software Patents".  Awesome!  (And congratulations.)

Any room for immigrants?

Good spotting

That slipped quietly under cover as they are busy arguing about spying, opposition leader changing and selling off our assets.

There is room for more. (if we run out the neighbours have empty space)

I suspect the software companies will be registering overseas, and effectively bypass it, but the patent system as it currently is, limits innovation imo.

Mark

Mark Beckett wrote:

 

There is room for more. (if we run out the neighbours have empty space)

Haha.

but the patent system as it currently is, limits innovation imo.

It only ever promoted innovation back in the early days of the industrial revolution, when industry was thin on the ground and required help to germinate.  Today patents are at best a mechanism for profit extension and slowdown of innovation, because without them a company would have to innovate faster to survive among the huge swarm of other companies in the sector.

Innovation is universal, not rare.  Only those without the mental apparatus to innovate think it's rare.  It's second-nature to engineers and scientists and legions of craftsmen and artists, not to mention everyone with commonsense, enthusiasm and time to think.

The excuse that "without patents we couldn't afford to invest" is mind-bogglingly ridiculous, because if one company chooses not to invest then another will, and will grab a large slice of the market simply through being first.  It's not like there's a shortage of competitors eager for a chance.  Patents stifle the whole process of innovation by entrenching the incumbents.

Morgaine Dinova wrote:

 

Only those without the mental apparatus to innovate think it's rare. 

Unfortunately you're describing an approaching 100% of the MBA, 'business leaders' type people there.

Apologies for the continuing thread drift, only just catching up after building a rather large wall over the last week or so..

selsinork wrote:

 

Unfortunately you're describing an approaching 100% of the MBA, 'business leaders' type people there.

Innovation in business is a double-edged sword.  Look at the example closest to us:  Raspberry Pi.

Technical innovation in Pi was nil, since an existing SoC was just slapped onto a board along with very rudimentary power circuitry (I'm being generous) and some ad hoc socketry (again, being generous).

In contrast, business innovation in Pi was extremely high.  The business plan amounted to:  "Design a low-tech board to the lowest standards that will pass industrial certification, advertise it as a $25 computer but don't bring the $25 model to market for almost a year, claim the 'educational' high ground but focus primarily on the low ground of media centre functionality for mass appeal, hype it across the entire known universe and beyond, sell it into the residential market despite lacking residential certification, and (as the meme goes), profit."

This was quite awesome business innovation because nobody else ever had the temerity to do such a thing, and the business plan worked.  It was undoubtedly innovation in business  The question is, was it a good thing?  This is a very hard question to answer because both good and bad things were done.  The only possible complete answer has to be "Yes and  No".

On the "Yes" side, as I have said many times before, RPF did enthusiasts a huge favour and gave the ARM ecosystem an incredible push by creating and popularizing a price niche that just didn't exist previously, and the unprecedented price has opened up a veritable mountain of new applications and competing products.  This was quite an awesome achievement, and the many demerits that both Pi and RPF rightfully earned cannot take that good thing away.  In my view, we're in a better world post-Pi than we were pre-Pi,  and that's not causal coincidence --- it was achieved quite deliberately by RPF.

Unfortunately, and very much on the "No"  side, it was achieved as a consequence of RPF doing some pretty bad things.  The worst is probably marketing and selling Pi into the residential market despite lack of residential certification.  The legal ramifications aside, in my opinion it is very unethical engineering to knowingly place a million+ boards into an environment in which their emissions do not meet the regulatory requirements for residential use, and hence knowingly to expose the public to potential EMC mishaps.  In my opinion, this is professionally inexcusable.

We've been examining other "No" side issues for a year and a half on this forum, so I won't repeat them here.  (This thread is preferably focused on FCC certification anyway.)  Suffice to say, there hasn't been a shortage of aspects to the Pi project that have received strong criticism, and merited it.

There is no well-founded way of comparing dissimilar things nor of calculating an average of good outcomes and bad practices.  The Pi business innovation brought very good and very bad things, and both are important.

Perhaps the moral of the story regarding innovation from BMAs is:  Be careful what you ask for.

Morgaine Dinova wrote:

 

... claim the 'educational' high ground but focus primarily on the low ground of media centre functionality for mass appeal ...

I still like to think that RasPi Foundation really did want to push RasPi as a tool for education, but that once the technology was for sale the applications went every other way: media center as you state, but also as a cheap GNU/Linux board for hardware applications where there's a significant risk of destroying your computer.

I agree with others here who have said the problem with RasPi regarding education is that they're throwing cheap hardware at what is almost exclusively a software problem.  Most RasPi users do have access to a PC of some sort, and it's probably a whole lot more effective for them to learn about programming on that PC.  Maybe at some point RasPi will have an SD card that boots directly into a friendly programming environment without myriad lines of debugging data scrolling past first.  But for now, you're booting into a mainframe computing environment that "chooses its friends carefully".

JMO/YMMV

John Beetem wrote:

 

I agree with others here who have said the problem with RasPi regarding education is that they're throwing cheap hardware at what is almost exclusively a software problem.

Phrased that way, it almost sounded like the Foundation is using its profits to equip school classrooms.

I know you weren't saying that, but it gave rise to the idea.  If contributing directly to the software problem and to IT education is too hard or not cost effective given their limited manpower, RPF could instead pour the profits from Pi and camera sales into hardware donations.  That could be a worthwhile thing for a non-profit charity to do with profits, as some schools are desperately short of cash for equipment.

John Beetem wrote:

 

I agree with others here who have said the problem with RasPi regarding education is that they're throwing cheap hardware at what is almost exclusively a software problem.

Phrased that way, it almost sounded like the Foundation is using its profits to equip school classrooms.

I know you weren't saying that, but it gave rise to the idea.  If contributing directly to the software problem and to IT education is too hard or not cost effective given their limited manpower, RPF could instead pour the profits from Pi and camera sales into hardware donations.  That could be a worthwhile thing for a non-profit charity to do with profits, as some schools are desperately short of cash for equipment.

Morgaine Dinova wrote:

 

John Beetem wrote:

 

I agree with others here who have said the problem with RasPi regarding education is that they're throwing cheap hardware at what is almost exclusively a software problem.

Phrased that way, it almost sounded like the Foundation is using its profits to equip school classrooms.

 

I know you weren't saying that, but it gave rise to the idea.  If contributing directly to the software problem and to IT education is too hard or not cost effective given their limited manpower, RPF could instead pour the profits from Pi and camera sales into hardware donations.  That could be a worthwhile thing for a non-profit charity to do with profits, as some schools are desperately short of cash for equipment.

Charity does not exist to ensure that education is fit for purpose. Neither does it exist to prop up industry (who are the ultimate beneficiaries of education).

If the Foundation do actually intend spending some of that money I'd be happier if it was directed towards a public campaign to convince the UK taxpayer that computer science education is important and pressuring government, educational institutions and industry into providing solutions.

that's the oldest argument with computer problems :  "It's a hardware problem... No Damn it,, it is obviously a software problem "   lol 

I do appreciate you guys debating about the educational side ,,, but let's please find a compromise and keep it cheap !!   I just read an article online that a lot of schools are using an iPad base of teaching kids.. but I think that is just the educational materials of learning through the grades,,, not learning the basics of how a computer works and hooking it up and designing software to run devices.  and an iPad is not cheap.

Morgaine Dinova wrote:

 

That could be a worthwhile thing for a non-profit charity to do with profits, as some schools are desperately short of cash for equipment.

In the USA, a not-for-profit organization refers to money left over as a "surplus", not a "profit".  After all, how could a "not-for-profit" have a profit without running into trouble with the tax authorities?

A quick-witted friend of mine once said out loud at a NFP business meeting:

So, I guess "surplus" is the politically-correct term for "profit"

Well here's a radical  idea:  How about spending any "surplus" first  on residential FCC certification in order to comply with EMC regulations and federal law?

(Laughter track for the humour impaired:  It's an idea for those who live in a world in which compliance with FCC regulations and federal law is optional.)

I  am just a rasp-pi user but i am intelligent in other fields of endeavor,, and what I want to know is why are you guys so hell bent on this FCC debate instead of concentrating on us r-pi users ??  I have asked a couple questions with no response but I am getting a full law degree on FCC regulations !!    lol,,,    Is there a way that u can take your debate off-line,, and keep us paying users satisfied with what we have at the moment ?   Don't get me wrong,, I am enjoying your FCC debate and educational concerns and all that,, but I thought this forum was for R-pi questions and problems,,, and also enticing us with cool projects  ??      Sincerely, Chuck Smith

This is an engineering forum, and compliance with EMC regulations is part and parcel of professional electronics engineering.  There is no escaping it.

Engineering aside, seeking residential EMC compliance is also the socially  responsible thing to do, because it affects everyone.  If an unintentional radiator causes a pacemaker to fail or a traffic fatality to happen, no amount of smilies will make up for it.  It is very serious.

The regulatory certifications are not frivolous, but mandatory for a reason.  Raspberry Pi has no free pass.

To those who don't care about the EMC impact of their devices, I recommend simply to not read the threads about Class B certification.  But everyone should care.

PS. There is plenty of discussion here about  Pi technology and applications, but it's in other threads.

Chuck

I agree 100% with what Morgaine stated.

I have asked a couple questions with no response

Looking at your postings every question you raised has been answered, so are we missing something (other than you not marking them as answered despite multiple answers).?

and keep us paying users satisfied with what we have at the moment ?

I wasn't aware anyone paid for access to element14's forums, and there is no joining fee, so maybe you refer to your internet time.?

Perhaps you mean the item you have paid for, but doesn't meet the necessary laws?.

There are many threads on multiple different groups, and you don't require to have every one of them email you, or indeed read them.

Unlike some forums where it shows your unread content, e14 isn't the same.

IMO this is the correct place to have the debate about FCC requirements regarding RaspberryPi.

Yes it shouldn't be required, however we the users don't dictate that, the FCC does, and the manufacturers and suppliers are required to meet that, however in this case its not been done, hence the conversation.

If you want a similar comparison, it's like buying a car, where the manufacturer has tested this model for compliance in their country, and for some others.

The dealership that sells that model has issued a warning that it doesn't comply, so the users drive it when it doesn't comply, or they pay mega$ to test it for compliance.

The problem with the first option, is it may result in major costs if something goes wrong and causes damage to others.

Mark

Is there a way that u can take your debate off-line,, and keep us paying users satisfied with what we have at the moment ?  

Chuck,

   In a university class, it is annoying when the professor allows a student to enroll without the required prerequisite courses,

who then unfortunately monopolizes the class time with remedial questions.  Everyone else wishes the professor would have

enforced the prerequisites.

You seem to have the same discomfort here where "remedial" issues are being discussed rather than how to get along with

using our RPi's. We share that discomfort and are wishing that E14 would have enforced the FCC prerequisites for residential

sales, prior to importing and selling the device in large numbers.

But in this case, it doesn't make sense to try to discuss the issue "offline" using PMs, because it affects a wide class of users.

There has been an attempt to discuss it more privately in the "top member" forum, but that discussion ended with

"that's a good question, we'll ask our legal experts and get back to you", with nothing further after considerable time.

Fortunately, it's not exactly like a classroom where discussion can be monopolized, as plenty of other threads here

are able to proceed in parallel.

Take your intelligence and post the questions in the proper thread, if you have some left read the title of this thread.

It is not a LOL thing, and if the use of acronyms make you "throw up" you need to see a doctor. If you do take the opportunity to ask him/her to figure in which "endeavours" your intelligence is located because if you are a "paying" user of the forum your intelligence is being abused by someone.

If you are not interested in this subject or have nothing to contribute you are more than welcome to ignore it.

Sincerely

John Doe