How To Review a TCB Application

1. How To Review a TCB Application Prepared by Chris Harvey EMC Consulting

2. Disclaimer!!! • This presentation provides one person’s opinion and point of view and is not intended to be interpreted as the only way to perform the duties of a TCB reviewer. • I have over 25 years of review experience with lots (did I say lots?) of trial-and-error

3. TCB Program Roles & Responsibilitiesper KDB 641163 D01 v02 • This 13 page document helps to explain the program set in motion by FCC Report & Order 98-68 and why training is needed to ensure quality • Explains how to become a TCB, TCB Scopes & Accreditation, impartiality, location, TCB Exclusion and Permit But Ask, Core Test Requirements (of a TCB), Key Personnel, Contract Employees, Information Maintenance, TCB Personnel Training, TCB Acceptance of Test Data, Test Procedures, Retention of records, Interpretation of the FCC Rules, Post-Market Surveillance requirements • Version 02 (v02) was released 2 days ago on 4/4/14

4. Roles of a TCB Reviewer – KDB 641163 D01 v02 (1) • 641163 D01 TCB Program Roles and Respv02 • When accepting test data in support of an application for certification, the TCB shall review the test report, and needs to be confident that the product meets the relevant requirements before it certifies the product. The process used by the TCB for the acceptance of test data will be reviewed during the ISO/IEC Guide 65 [becoming 17065] [TCB] assessment.

5. Roles of a TCB Reviewer – KDB 641163 D01 v02 (2) • When reviewing the application for certification, including the test report, the TCB should evaluate the following elements of the application for certification to determine the suitability the test data: • a) Clearly defined test procedures • b) Method of test validation • c) Clearly defined test configurations • d) A brief description of the test facilities – photo(s) and block diagram(s) of test setup • e) Calibration dates and traceability of all test equipment

6. The Goal of reviewing an application is: • Ensure it is Complete – all required documents are provided • Ensure it is Consistent – all exhibits paint the same picture • Ensure it is Correct – all compliance requirements have been met • Remember 3-C’s

7. Before an Application is submitted • The Application package is the final product submitted to the TCB to document the capabilities and compliance of a device being submitted for FCC Certification. • We’ll see examples shortly • Many times, the TCB Reviewer is the first person to see all documentation together that has been pieced together over time • By the time it gets to the TCB, all aspects of FCC requirements are supposed to have been addressed. • An application at submission to the TCB is rarely perfect • This is why a thorough review is necessary

8. What does an application look like? • A typical application package consists of 10-40 documents describing the device and the compliance requirements and compliance evidence

9. Example exhibits list (not including confidential)

10. FCC 2.1033 – What is required (minimum) to be in an application for Certification • FCC 2.1033 – Application for Certification • (b)- FCC Rule Parts 15 & 18 • Applications for equipment operating under Parts 11, 15 and 18 of the rules shall be accompanied by a technical report containing the following information: (next slide) • (c)- All other FCC Rule Parts • Applications for equipment other than that operating under parts 15 and 18 of the rules shall be accompanied by a technical report containing the following information:

11. FCC 2.1033(b) - Unlicensed • Name and address of manufacturer / applicant • FCC Identifier (FCC ID) • Copy of Installation and Operating Instructions (Manual) • Brief Description of Circuit Functions (Operational Description) • Block Diagram showing frequencies • Schematic Diagram (for Transmitters) • Test Report • Photographs (Label, Internal & External appearance) • Other incidentals….

12. FCC 2.1033 (c) - Licensed • Name and address of manufacturer / applicant • FCC Identifier (FCC ID) • Copy of Installation and Operating Instructions (Manual) • Types of Emissions • Frequency Range • Range of Operating Power • Maximum Power Rating • DC Voltages/currents at RF Components • Tune-Up Procedure • Schematic Diagram • Photographs (Label, Internal & External appearance) • Brief Description of Circuit Functions & Modulation (Operational Description) • Other incidentals….

13. Equipment Classes & TCB Scopes: • The FCC has divided approvals into Equipment Classes describing the type of device (i.e. DTS for Digital Transmission Systems of FCC 15.247) and into TCB Scopes, which are groupings of Approval Categories.

14. TCB Scope of Accreditation

15. Equipment Class • The category or class of equipment assigned to the device submitted for approval for marketing. • The FCC maintains an Equipment Class and Rule Part List at https://apps.fcc.gov/oetcf/eas/reports/EquipmentRulesList.cfm • And example: A single WLAN AP operating at 2.5 GHz and 5.2 GHz would all be approved in TCB Scope A4, but the 2.4GHz WLAN is DTS under FCC 15.247 and the 5.2GHz WLAN is NII under FCC 15.407. • Another example, a single 2.4GHz BT/ANT+ transmitter could be approved under 3 equipment classes: • DSS for FHSS Legacy BT modes • DTS for BT-LE • DXX for ANT+ operation • There are currently 74 different FCC Equipment Classes

16. Composite Device applications • FCC 2.1033(e) A single application may be filed for a composite system that incorporates devices subject to certification under multiple rule parts, • Each Equipment Class is a separate submission – each will get separate “Grant” • i.e. Cell Phone w/ Cell/PCS/LTE and WLAN & BT may have 3 (or more) applications • each application is individually uploaded to FCC • Separate ‘package’ of exhibits for each Equipment Class

17. Confidentiality – Long and ShortKDB 726920 D02 • FCC Confidentiality Policy in KDB 726920 D01 • Allowance list in KDB 726920 D01 • During review ensure: • Only allowed types are included in STC and LTC • Confidentiality Request follows FCC guidance/requirements (correct references) • Confidential items are not also located in non-confidential exhibits • i.e. Photos are all STC, but there is a photo of the EUT in a report exhibit • You don’t want to be responsible for releasing confidential information

18. Exhibit Confidentiality Table – KDB 726920 D01

19. How to first approach an application (1) • Know the Equipment Under Test (EUT) (even without a sample) • In order to review an application package you must first become very familiar with the device and its capabilities • I am a visual person, so I always start with the photos (Internal & External) • What does the device look like, how is it used, where is it used • Only once you can understand the device and how it is used can you tell if all requirements have been met….

20. Photo exhibits • Photos (Internal & External) should show: • Approximate size (larger than a bread-box?) • Visible features (buttons, displays, antennas…) • Battery or AC operated? • Hand-held (Portable or Mobile, per FCC definition) • Internal and external construction • There should be sufficient number and quality of photos to clearly show the external and internal appearance and construction

21. How to first approach an application (2) • Look at the Block Diagram, sometimes called a Functional Diagram, should show all functions and how they relate to each other • You now know what it looks like (photos) so the Block Diagram helps to paint a first and basic picture of what the device is and its functional

22. Example Block Diagram • What do you see? • Are there any Tx’s? • Does it raise questions? • Needs frequencies of operation • Do all features from photos show here? From Marvell http://www.marvell.com/communication-processors/pxa968/

23. How to first approach an application (3) • Look at the Operational Description – should completely document the capabilities of this device • Frequencies • Modulations • Channeling • Power • Should contain a fairly technical description

24. Test Reports and Compliance • Now that you have an understanding of the device, what it looks like, its capabilities and how it operates, now is time to ensure it meets the appropriate FCC requirements…. • What Rule Parts Apply • What Measurement Procedures apply • What additional Guidance applies (KDB’s) • Is further guidance needed (PBA)

25. No Interpretations needed (or allowed) • TCB’s are NOT allowed to interpret (TCB Roles & Responsibilities) • Only the FCC can interpret… TCB’s apply the FCC Guides and interpretations • We should also not assume anything about the device/report/compliance • All information should be stated clearly in the application exhibits • If information is vague or unclear, ask for clarifications in an RT, or Request for Technical (information)

26. Consistency throughout • This is tough, but should be evaluated throughout the review • Always look out for consistency of terms, capabilities, specifications, • Use Check Sheets to provide consistency between reviewers and between applications • I personally use review notes as I move from exhibit to exhibit • If MIMO in Operational Description, then look for testing of MIMO modes • If operation is for portable use and needs RF Exposure, make sure SAR is addressed • Data/parameters in one exhibit should match data/parameters in other exhibits

27. Taking notes and reviewing, my style(please refer back to my disclaimer) • I open all documents at the beginning and then start reviewing each one thoroughly (make sure your computer can handle the data) • I may close some, and leave others open longer. I may re-open some as I continue reviewing. • I may bounce back and forth between several exhibits as I try to determine requirements and consistency • I take notes throughout the review and refer back to them as I look at exhibits to ensure consistency

28. Know your resources, precedents • Recent precedents may be helpful in new review, but… • Avoid old examples as rules are constantly changing • What is old???? • Remember, 2 wrongs never make a right • A good and thorough example of similar approval from the FCC website may be a tool in assisting your review

29. Grant Comments • Many Grants will have ‘comments’ which assist in providing Grantee with restrictions or details about their approval. • Some simpler approvals don’t need Grant Comments • Used to address use restrictions, RF Exposure Compliance, clarifications on Grant RF Power, • The TCB’s are responsible for generating the Grant Comments from FCC guidelines and precedents.

30. Example Grant Comments:

31. Rules work together • The FCC Rules and regulations do not stand alone • Rule parts work together • Just because you cannot find specifics in the Rule Section…don’t stop • Keep looking in other rules that work with the one you are working with… • Example: • Approving device per DTS requirements of FCC 15.247 • Must also comply with technical requirements of 15.31, 15.35, 15.207/15.209, 15.215, RF Exposure, etc. • Understand how the rules work together to perform complete review

32. Permit But Ask (PBA) – KDB 388624 • How many know the game “Mother May I” • You are only allowed to move if mother says ‘yes’ • The Permit But Ask procedure is similar to that game • You are allowed to approve a device ONLY after the FCC says ‘Yes” • Details on the next slide • PBA Procedure is in KDB 388624 D01 • PBA List is in KDB 388624 D02

33. Permit But Ask (PBA) Procedure • KDB 388624 D01 v09r03 (lots of revisions) • 4 typed pages of guidance • Manufacturer/Laboratory responsibility • Follow existing guidance or submit inquiry for new guidance • Follow the guidance… and NOTIFY the TCB of all communication • TCB Responsibility • Review entire application first • Ensure guidance has been followed • Submit entire application without Granting, then submit PBA request • Respond to any FCC requests and issue Grant ONLY when FCC says ‘yes’

34. PBA filing • Even though a PBA process involves Manufacturer, Laboratory and TCB, the PBA filing is only a TCB process, and not filed by the manufacturer or the Laboratory • The PBA submission will have an associated KDB (PBA) number which is included in the TCB completed FCC Form 731 (that PBA number is not public)

35. PBA List – KDB 388624 D02 v14 • This list provides specifics about which devices fall into the PBA procedure Special Circumstances EMC for ‘Carrier Aggregation’, Confidentiality not in compliance with 726920, RF Exposure Evaluation 21 different RF Exposure situations (in current v14) that require PBA includes really new technology, really complex situations, coherent transmissions, simultaneous transmission measurements, non-standard procedures, where guidance is not available or applicable…

36. TCB Exclusion List • These are devices that may ONLY be approved by filing directly to the FCC • TCB Exclusion List is in KDB