first mention of twins

ill try keep this nice.

i think the whole hype about Rpi being the big bad educational tool was nothing more than a pr stunt to get it selling quick, and that is just what happened. i also remember hearing somthing about this being developed by employees of broadcom, when it was first released the soc data sheet required a nondisclosure agreement, so right out of the gate there were problems calling it open source.

i'm sorry if i dont get the idea about teaching computer science with an embeded linux board. don't comp sci cources use full-blown computers already? and if you really want to learn about how computers work, it is much better to start with an 8051 or 8088 and assembly.

but now it seems the more i read, the more i can't suggest the pi for any use other than a media center.

anyways thats my two bits on the the pi.

sheldon bailey wrote:

 

but now it seems the more i read, the more i can't suggest the pi for any use other than a media center.

Professionals who are aware of the relevant  FCC regulations shouldn't be suggesting the Pi for use in any residential application in FCC jurisdiction anyway, since the device does not have FCC certification for residential use.  That would be a Class B certification, and it doesn't have one at the present date.

I doubt that anyone would deny that media centres constitute an overwhelmingly residential or domestic use of a digital device.  It's probably as close to being a poster child for residential use as one could find anywhere.

Indeed - the road to a lucrative career in Law is paved with semantics.

So how many semantic issues do you detect in the opening line of

Eben's March 2013 pycon keynote speach:

[Eben]: Thankyou guys. So, my name is Eben Upton, I run a thing based in the UK called the Raspberry Pi Foundation. Ah, we make little computers for kids.

https://github.com/robotclass/pycon-us-2013-keynote-eben-upton/blob/master/keynote-eben-upton.textile

coder27 wrote:

 

Indeed - the road to a lucrative career in Law is paved with semantics.

 

So how many semantic issues do you detect in the opening line of

Eben's March 2013 pycon keynote speach:

[Eben]: Thankyou guys. So, my name is Eben Upton, I run a thing based in the UK called the Raspberry Pi Foundation. Ah, we make little computers for kids.

https://github.com/robotclass/pycon-us-2013-keynote-eben-upton/blob/master/keynote-eben-upton.textile

I'd say that in my opinion that opening sentence was explicit and not open to misinterpretation by any reasonable person.

#1) He's still leaning on the Foundation for promotional purposes, rather than on Raspberry Pi (Trading) Ltd - of which he is listed as a director.

#2) He's promoting his organisation's consumer product. Computers, if I'm not mistaken.

Have I missed anything?

Being a portable computer by the FCC definition  would automatically define Pi as a Class B device.

Note however that it's captured as a Class B device anyway, even without the above, because if falls foul of the FCC's three key questions that distinguish between devices of the two classes:

1. Is the marketing of the device restricted in such a manner that it is not sold to residential users?
2. Does the application for which the device is designed generally preclude operation in residential areas?
3. Is the price of the device high enough that there is little likelihood that it would be used in a residential environment, including a home business?

Since it fails to be excluded from the residential environment through restricted marketing and sales (point 1), and it cannot avail itself of the exemptions in points 2 and 3, by FCC rules it is a Class B device anyway, even if someone could retrospectively wish away the fact that it is clearly a portable computer.

A Class B device without Class B certification is uncertified for its expected use, and cannot be marketed or offered for sale to residential users.  If it has Class A certification then it can be marketed or offered for sale as a restricted commercial or industrial device, but that is not  how Pi has been marketed and offered for sale, as anyone can plainly see.

Have I missed anything?

So you would say "I run a thing based in the UK called the RPF, but not officially; we make little computers, but officially just motherboards; it's for kids, but not officially for kids in residential areas."

The 2013 Premier Farnell annual report shows the target audience as "engineers and hobbyists".

Raspberry Pi

The element14 Community played a key role in another very successful

product launch this year. The Raspberry Pi, the credit card sized computer

developed to put computer programming back at the heart of engineers,

launched to phenomenal interest from engineers and hobbyists alike. In the

first 15 minutes after launch our websites received over ½ million hits as

customers flocked to order from us and by January 2013, Premier Farnell

had sold 600,000 Raspberry Pi units.

http://www.premierfarnell.com/sites/default/files/reports/Premier-Farnell-Annual-Report-2012-13(2).pdf

The "educational focus" appears to have come at least in part, from David Braben.  Liz wrote:

David was one of the people Eben brought the original idea to, along with the other trustees and a few others who aren't trustees. He's helped us develop the educational focus behind it, ...

http://www.raspberrypi.org/phpBB3/viewtopic.php?f=63&t=319&start=20

coder27 quoted:

 

"not officially; we make little computers, but officially just motherboards; it's for kids, but not officially for kids in residential areas."

I'd rather not speculate what that meant, but it sounds like something that should have raised a big red flag to Element14 regulatory certification experts.

I'd rather not speculate what that meant, but it sounds like  something that should have raised a big red flag to Element14 regulatory certification experts.

That was my parsing of Eben's quote, not his original quote, just to be clear.

However, there is no doubt that E14's regulatory certification experts had plenty of

red flags.  They didn't need any more of mine.  They certainly knew it was intended

for residential use, and they certainlly acknowledged that it did not pass Class B.

They also acknowledged that BIS had determined that it was classed as a finished product.

How many more red flags does one need?

But it is also clear that there was lots of incentive not to incur any further delays

in a project that had the attention of E14's CEO.  They probably assumed, as Liz

claimed, that achieving Class B certification would be easily obtained. 

Happily, we’ve found it doesn’t need a shielded enclosure to reach Class B, although it will require a (very minimal) redesign.

http://www.raspberrypi.org/archives/978#comment-19273

@coder27: It would then seem that David Braben might be an important factor - if education was indeed the motivation for his involvement. I note that he is part of the Cambridge set though.

PC mag reported in 2011 that Braben was actually the creator of the Raspberry Pi and ran a feature:

http://www.pcmag.com/article2/0,2817,2385055,00.asp

It's this kind of shoddy tech "journalism" that is responsible for the current situation imo. As now, "education" is hinted at, but it's explicitly a hardware sales pitch.

Good work btw.

It would then seem that David Braben might be an important factor

Yes, I think so.  My impression is that Eben's goal is to shift lots of units,

regardless of where they are shifted to, and that fits with his position with the

RP Trading subsidiary.  I don't detect much enthusiasm from him with regard to

developing educational materials.

btw, Abishur credits Liz's legal work for the original determination that compliance

testing wasn't needed until later.

The issue was that originally the boards were going to be released as development boards and therefore didn’t need the CE stamp (Liz is a lawyer, she did her homework ), but due to how many boards there are being ordered and the fact that the first 10K will be released with the main bulk release the distribs decided they wanted them all CE marked.

http://www.raspberrypi.org/archives/852#comment-17096

It's this kind of shoddy tech "journalism" that is responsible for the current situation imo.

I think the "journalists" are only half responsible.  Eben likes to talk about how he was

the Director of Studies at St. John's College at Cambridge University prior to founding

the RPF in 2008, and how he and his Cambridge colleages were motivated by noticing

a decline from the mid 1990's to the mid 2000's in the number and quality of applicants.

So you might assume that Eben was Director of Studies from the mid 1990's to the mid

2000's.   But I believe he graduated from Cambridge with his CS PhD in 2005, and started

work at Broadcom in July 2006.

coder27 wrote:

 

 

But it is also clear that there was lots of incentive not to incur any further delays in a project that had the attention of E14's CEO.

I suppose it's possible that there is a long reporting chain from the regulatory certification people to the E14 CEO, and the red alert got lost somewhere on its trip to the top.  However, it seems unlikely that a CEO would ever countermand regulatory advice --- that would be career-limiting.  What's more, CEOs almost certainly have input to global policy statements  such as those we examined, since they have funding implications.  This makes it even less likely that the regulatory hiccup was at top level, it seems to me.

Unfortunately, arguing from the bottom up doesn't work either, because if you're the local FCC certification expert then you would keep poking at the problem until it gets resolved to your satisfaction (it's your job after all), and you'd be highly unlikely to allow yourself to be ignored.  What's more, you have the law on your side, as well as the company Code of Ethics.  Seriously, there is no way your advice could be sidelined in a serious company like this.

Of course, it could be human error, misreading of the FCC regulations.  The trouble with that is, Title 47 Part 15 is written pretty clearly for engineers and technical management to understand, containing very little convoluted legalese.  And the FCC even went to the trouble to publish the even more simplified OET Bulletin 62, expressly to achieve what it states in its title:  "UNDERSTANDING THE FCC REGULATIONS FOR COMPUTERS AND OTHER DIGITAL DEVICES".  It's not really conceivable that the language there can be misunderstood by someone charged with FCC certification duties.

So, I'm at a loss to understand how this could possibly have happened.

coder27 wrote:

 

 

But it is also clear that there was lots of incentive not to incur any further delays in a project that had the attention of E14's CEO.

I suppose it's possible that there is a long reporting chain from the regulatory certification people to the E14 CEO, and the red alert got lost somewhere on its trip to the top.  However, it seems unlikely that a CEO would ever countermand regulatory advice --- that would be career-limiting.  What's more, CEOs almost certainly have input to global policy statements  such as those we examined, since they have funding implications.  This makes it even less likely that the regulatory hiccup was at top level, it seems to me.

Unfortunately, arguing from the bottom up doesn't work either, because if you're the local FCC certification expert then you would keep poking at the problem until it gets resolved to your satisfaction (it's your job after all), and you'd be highly unlikely to allow yourself to be ignored.  What's more, you have the law on your side, as well as the company Code of Ethics.  Seriously, there is no way your advice could be sidelined in a serious company like this.

Of course, it could be human error, misreading of the FCC regulations.  The trouble with that is, Title 47 Part 15 is written pretty clearly for engineers and technical management to understand, containing very little convoluted legalese.  And the FCC even went to the trouble to publish the even more simplified OET Bulletin 62, expressly to achieve what it states in its title:  "UNDERSTANDING THE FCC REGULATIONS FOR COMPUTERS AND OTHER DIGITAL DEVICES".  It's not really conceivable that the language there can be misunderstood by someone charged with FCC certification duties.

So, I'm at a loss to understand how this could possibly have happened.

However, it seems unlikely that a CEO would ever countermand regulatory advice

We can only speculate as to what advise was given, but apparently at the time the

contract was signed between E14 and RPF, the operating assumption was that

limited quantities would be initially produced, and that initial interest in an uncased

version would be mostly from developers.  

Then the first day of sales demonstrated that the initial operating assumptions were wrong,

but by then the contract was in place and E14 perhaps didn't feel like they had a whole lot of

leverage to change the certification plans beyond what could be achieved with the existing board.

Of course that doesn't explain why 1+ years and 1M+ boards later, and with a re-negotiated

distribution contract, they still don't have a published Class B certificate.

coder27 wrote:

 

but by then the contract was in place and E14 perhaps didn't feel like they had a whole lot of

leverage to change the certification plans beyond what could be achieved with the existing board.

How about the law of the land.  That tends to give one pretty good leverage.

And those massive FCC penalties  would probably provide pretty good incentive as well.

Of course that doesn't explain why 1+ years and 1M+ boards later, and with a re-negotiated

distribution contract, they still don't have a published Class B certificate.

Indeed.  It does not seem likely that the certification department simply fell asleep for 14 months.

I'm at such a loss for a viable explanation that perhaps it's time to examine alternative possiblities.

What if Element14's regulatory certification team was not involved at all, because all responsibility for Raspberry Pi affairs was factored out to another autonomous department?  And they, lacking the deep knowledge of the regulatory certification team, simply didn't understand the regulatory requirements for devices in residential use?

What if Element14's regulatory certification team was not involved at all, because all responsibility for Raspberry Pi affairs was factored out to another autonomous department?  And they, lacking the deep knowledge of the regulatory certification team, simply didn't understand the regulatory requirements for devices in residential use?

Feel free to ask the experts what happened.  They welcome questions.

Do you have any queries about electronics legislation? Send your questions to Gary at glegislation@premierfarnell.com

http://www.element14.com/community/docs/DOC-38293/l/gary-nevison--legislation-compliance-expert

or

http://www.element14.com/community/community/legislation?ICID=expertgroup#askexpert

It appears from their recent document updates that the compliance experts are not on holiday.

It'll be important to ask questions which they can  answer.  Questions about internal business issues, however interesting they might be, would probably not be in that category.

However, we do have a genuine and very specific role as stakeholders, defined by Premier Farnell as:

• The employees of the Premier Farnell Group
• Potential future employees
• Customers and suppliers of all Premier Farnell Group companies
• Members of the local communities in which we operate
• Premier Farnell plc shareholders, and the investment community at large

As PF stakeholders in at least two of the above categories, we have a very strong stake in the legal and safe operation of the products we buy from the Group, which are being marketed and sold to us as residential users but without carrying residential certification.  This has a strong possibility of being unlawful in some key jurisdictions.  If the group's Code of Ethics is at all meaningful, this should provide a good platform from which to ask a direct question and have it addressed in an effective way, and not with a brush off.  EMC is an important issue, and can even be fatal.

Perhaps we can come up with a well-formed question or two reflecting our genuine stake in this.

Perhaps we can come up with a well-formed question or two reflecting our genuine stake in this.

I don't think there's anything difficult about what the question is, it's simply

how is it legally possible to market the RPi to residential customers without

a Class B certificate.

The difficulty is getting someone to answer it.  The closest we've come to an

answer is that Gary Nevison said

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.

and that he

will also post a blog around this subject containing further statements of authority.

http://www.element14.com/community/community/legislation/europe/other/blog/2012/04/17/the-pi-is-now-ready#comment-13501

If the Pi certification mishap can be remedied quickly before it brings forth unfortunate ramifications, it might even be worthwhile becoming a PF stakeholder of the 5th type.  But then I'd be very keen about details of which part of the business was responsible for this mess, and assurance that it could not happen again.

coder27 wrote:

       Gary Nevison said (my highlighting in bold):

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.

Citation needed.

I've seen no such exemption in Title 47 Part 15 anywhere (there are instructions about warning labels, but for different purposes).  It wouldn't even make any sense, since if it were true the unscrupulous wouldn't ever bother to obtain Class B certifications for residential equipment at all, they'd just use Class A and a warning label, and EMC chaos would ensue.

The warning label is almost certainly for Class A equipment marketed and sold exclusively to commercial, industrial or business users, with a label warning that should such equipment be used in a residential setting, it could cause interference.  That's totally different.  FCC regulations distinguish Class A from Class B digital devices based on to whom they are marketed and sold.  A Class A device by definition cannot be marketed and sold to residential users.

Title 47 Part 15.3 Section (h) states it clearly (my highlighting in bold):

FCC writes:

 

(h) Class A digital device. A digital device that is marketed for use in a commercial, industrial or business environment, exclusive of a device which is marketed for use by the general public or is intended to be used in the home.

 

(i) Class B digital device. A digital device that is marketed for use in a residential environment notwithstanding use in commercial, business and industrial environments. Examples of such devices include, but are not limited to, personal computers, calculators, and similar electronic devices that are marketed for use by the general public.

It's stated in black and white.  A Class A device cannot be marketed for use by the general public or intended to be used in the home.  If it's marketed for use by the general public or intended to be used in the home then it's no longer a Class A device, it becomes a Class B device.  That's the whole point of the word "exclusive" in Section (h).  The corresponding definition of a Class B device is given in Section (i).

====

I think it may be appropriate to link to Premier Farnell's Code of Ethics  here (again).  It's not that I expect any finessing of FCC regulations, but I'd much rather forestall them rather than have to point them out later.  I like Farnell, and I would be disappointed for the esteem earned over many decades to drop.  By the book, please.

I've seen no such exemption in Title 47 Part 15 anywhere (there are instructions about warning labels, but for different purposes). 

Exactly.

I'm not expecting E14 to stick with that answer, for exactly the reasons you give,

and I think that's the reason why the promised authorities for it never appeared.

Their previous answer, that "the board is in a much better place than it potentially was",

isn't an answer I expect them to go back to either, since it directly implies that

the place it's in isn't where it needs to be.

So I'm looking forward to what the next answer will be.

It's unfortunate that discussions about FCC certification continued here where they're likely to get lost, instead of in the "FCC Certification ..." sister thread.  I suggest moving back to the latter unless the topic is RP twins.

I have at least added the FCC 15.3 (h) citation given in post #45 to the related thread in Feedback & Support.