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.

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?

BTW, you can also add to the list that the hazardous materials tests report is not available either and the individual ROHS certificate automatically generated by e14 won't do.

There are a few tidbits here:

... the product was tested for RoHS which showed bromine in several plastics and a trace of cadmium in one component but was declared compliant, and the REACH analysis of Substances of Very High Concern concluded that the Pi was low risk.

http://www.element14.com/community/community/legislation/europe/other/blog/2012/05/02/raspberry-pi--the-road-to-compliance

btw, there was an interesting case a few years ago of Hobby Lobby importing

RF devices without proper FCC certification, as discussed in this thread:

http://www.rcgroups.com/forums/showthread.php?t=1057497

post #2 says:

Jeti is working on the FCC paperwork. It is my understanding that the system meets all the requirements.

 

 

Thanks,

Jason Cole

Hobby Lobby

post #6 says:

Hey guys,

I'm not exactly sure about the process. It's my understanding that the modules and rx's meet all of the FCC requirements, but Jeti never went the certification process. We have suspended all sales until this is worked out. We will inform customers who purchased thus far if they need to do anything. Hopefully Jeti will resolve this soon, I really want to try out the variometer!

 

 

Thanks,

Jason Cole

Hobby Lobby

 

In the recommendation I'm working on, said reports (not just a self made certification of complaince) have to be public records, where is shown who, where, how and when the tests were done and the detailed results of each sections of the test and detailed analysis.

The underlying issue is a question and game of liabilites.

-J

The recent $30M Apple contract for the Los Angeles Unified School District shows (p. 11)

  http://www.scribd.com/doc/156571124/Apple-LAUSD-iPad-Contract-Signed-FINAL-7-16

25. FCC AND UL APPROVAL

Motherboards used to manufacture the desktop, mobile computers, and server computer systems

provided under this Contract must be Federal Communications Commission (FCC) approved,

and the power supplies must be Underwriters Laboratories (UL) approved.

Complete systems must be submitted to the FCC for evaluation and certification, or self certified

(declaration of compliance) in accordance with guidelines established by the FCC for self

certification. Each such system must have FCC and UL or self-certification/labeling affixed to

the back of each system.

Systems without FCC and UL approval or declaration of compliance statements and labels will

be considered non-compliant and will be rejected. Desktop and laptop systems must be FCC

Class B certified, or self certified, and server systems must be FCC Class A certified, or self

certified.

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.

The policy statements I quoted are from Farnell UK, and unfortunately I have no information whatsoever about their relevance or otherwise to Premier Farnell as a whole.  I would certainly hope that the entire group holds to these policies (or similar ones) because that would underline their committment to professional engineering and social responsibility.  That's just my personal hope though.

I'm not aware of who runs Newark's "live chat", but judging by your excerpt, it seems that they have not been trained to the policy standards of Farnell UK.  It may not be strategic to pursue that though --- beware of detours that just make the desired destination even more distant..

The interest here should be purely in obtaining factual information about Pi certification, promptly, in order to meet "customer as well as statutory and regulatory requirements".  (Quoting Farnell UK again.)  I welcome anything that brings that closer.

It's a bit concerning that anyone has to beg for this.  Certifications aren't supposed to be secret.

I'm not aware of who runs Newark's "live chat",

Her name is Rachelle Sheffer, technical support manager.

http://www.element14.com/community/thread/17930

Certifications aren't supposed to be secret.

Of course not.  And they aren't. 

http://www.element14.com/community/docs/DOC-44828/l/raspberry-pi-safety-data-sheet

What is secret is the legal justification for selling a Class B device,

and portable computers are considered Class B devices,

to residential customers with only a Class A certificate. 

Is that the issue here, that there is no evidence of Class B certification?  (I haven't been following the story, sorry.)

If so, can't we just ask, point blank?

Element14, do the existing revisions of Raspberry Pi currently being sold by the group have FCC Class B (Residential) Certification?  If they do, please link to the certificate, and if not, please confirm that it's lacking. (Don't pass the buck!)

These are just matters of fact.  How hard can it be?

If so, can't we just ask, point blank?

Yes, I have asked.  The answer was:

So, Class A is all that RPi were aiming for.

It passed quite comfortably and, add to that, FCC, C-tick, REACH SVHC and RoHS compliance testing

the board is in a much better place than it potentially was.

Best wishes

Gary

http://www.element14.com/community/community/legislation/europe/other/blog/2012/04/17/the-pi-is-now-ready#comment-13475

Nobody seems to be able or willing to confirm if the Raspberry Pi has passed a Class B certification with the FCC and provide access to the appropriate test reports and certification documents.

It is not a matter if it may interfere with your TV or radio but as I said before an issue of liabilities.

A school district will have a hard time to approve a non-certified device that may interfere with among others devices, for example a medical device like a pacemaker, even if there is no chance for anything wrong to happen.

Premier Farnell's answer to code27 appears to describe the situation very authoritatively:

Gary Nevison wrote:

 

The board underwent EMC testing which enables one to discern if it should be classed as A or B.  From the RPi pre-compliance work it was evident that it would not meet Class B.  It did not meet the Class B limit but did meet, and comply with Class A.  It is legal to place Class A equipment on the market for use in a domestic environment in both the EU and U.S. and to affix the CE and FCC mark provided that there is a warning on the product that it may cause interference. In the case of RPi the warning is on the Safety Data Sheet (a copy of this can be found on the Raspberry Pi area of element14.

That seems totally clear.  The Pi board in question (which revision?) was Class A certified only.  That was in April 2012 and things may have changed since then, but at least there can be no doubt about that specific Model B.

This Raspberry Pi Safety Data Sheet is probably the one mentioned by Gary.  Note that it's dated 19th April 2012.