first mention of twins

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.

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.