Good to know - FCC regulations

[armdnrdy]

I assume that one could self-certify assuming there was access to the test equipment and an anechoic chamber.  I am not sure about that. 

Highly unlikely.

What would stop you from "doctoring" the results?

About as likely as the police letting you take your own breathalyzer test without witnessing the results. 

There is no certification that I know of that isn't performed in a lab or in the field by an authorized third party company.

[pickdropper]

Strictly speaking, that's not true.

I've been involved with the development of products that allow self-certification.  It looks better if done by a third party lab, but if you have the proper equipment, you are sometimes allowed to self-certify.

This is even true with some of the ANSI standards.  But you better have all of your ducks in a row if the auditors come and you better be able to prove your verification and validation is legit.

But sure, other stuff needs to be verified by a certified lab.

[armdnrdy]

There is a big difference between standards and laws that are on the books.

I am an industrial electrical contractor and everything that I've come across in local, State, and Federal jurisdictions need a third party certification.

There is no budget for "auditors" or equipment to test various items that need certification.
If that were the case....the FCC could certify the circuits in question, sign them off, and be done with it.

[armdnrdy]

I stand corrected.

According to what I just breezed through:

http://www.arrl.org/part-15-radio-frequency-devices#Authorization

the "honor" system and self testing may actually be in play here.

I'll have to read through this more thoroughly to be sure.

[Jdansti]

Industrial electrical requires third party inspectors, but in the environmental business where you have to do chemic analyses, mist states and the EPA don't require third party testing. However, if you do your own testing, you better make sure you follow the testing methods exactly, keep good records, and make sure your instrument calibrations are traceable to NIST standards. I imagine that the FCC testing is very similar. If you get inspected/audited you better have your ducks in a row because there are hefty fines and possible imprisonment for defrauding the federal government.

[armdnrdy]

Industrial electrical requires third party inspectors

I also deal with manufacturing equipment certifications which do not allow self testing.

What I've gathered so far from the link that I posted is there are different levels of requirements, some requiring the testing being performed at a certified lab.

The problem is....I can't really tell by the examples where stompboxes fit under which requirements.

[pickdropper]

Industrial electrical requires third party inspectors, but in the environmental business where you have to do chemic analyses, mist states and the EPA don't require third party testing. However, if you do your own testing, you better make sure you follow the testing methods exactly, keep good records, and make sure your instrument calibrations are traceable to NIST standards. I imagine that the FCC testing is very similar. If you get inspected/audited you better have your ducks in a row because there are hefty fines and possible imprisonment for defrauding the federal government.

This is the crux of the issue, I think.  While you CAN self-certify some of this stuff, you need access to the proper equipment and test environment.  I'd need to comb through the standard more carefully, but it seems you'd need some expensive equipment and an anechoic chamber at the very least.

I'll read through the standard more when I have a chance, but it's been an ANSI-heavy week for me; I'll deal with this next week.

[Jdansti]

Right. It might not make sense to self certify due to the expense of the equipment and the conflict of interest issue.

[Tony Forestiere]

Just don't do this: https://www.youtube.com/watch?v=WWlpJ3k_Ik0

[PRR]

> I don't think this stuff is new, I've got Boss pedals that are probably 15 years old that have statements on them saying they're compliant with part 15 of the FCC rules.

Back in the 1960s, Pop Electronics would publish projects and include a printed statement about Part 15 which you could attach to your build.

No, not new. And certainly known by Mike. He "forgot" for some decades, while selling many million un-tested gizmos. Indeed the FCC's attentions are selective-- they can only go after the more obvious targets.

I suspect the fact that some Japanese companies are very-very careful about Compliance may have made Mike's un-tested pedals stand-out on the market.

[amz-fx]

Also, if you import an FCC regulated device, even if it has been tested and complies, you have to file a Form 740.

http://transition.fcc.gov/Forms/Form740/740.pdf

How many of the US Ebay sellers of cheap Chinese guitar pedals have filed the Form? Assuming of course that the pedals have been tested, and the Mooer and Daphon pedals that I have were not. Not sure about Joyo or any of the others.

regards, Jack

[SeanCostello]

A hypothetical question: If something like a Belton brick was tested and approved with regards to FCC standards, would devices that use the submodule also meet FCC standards?

In other words, let's say that you have a submodule which has analog audio inputs and outputs, power, ground, inputs for relevant pots, etc. This submodule is packaged in such a way that it won't exceed FCC standards. In the case of something like the Belton brick, let's say that the encapsulation also shielded the module. No clock signal is passed into the submodule. For all intents and purposes, it acts like an analog module. If pedals are designed around this brick, do they need to be FCC tested as well?

Sean Costello

[armdnrdy]

From what I've read so far...I think that modules and actual components (charge pumps, BBDs, etc.) are exempt from testing.

It's when you actually use it in a device that counts.

This makes sense because depending on the design, routing, and use, (frequency) a component or module may pass under certain test environments but fail in a different design.

Think about a clock incorporated in a design....some designs may have ticking introduced into the audio path which is inherent to the design. Other designs that utilize the same clock components may be free from ticking.

[R.G.]

If we were to go with the good-governance theory of regulation, requiring that devices not interfere with each other would be a Good Thing.

That being the case, certifying components is useless, as complying components can be combined in non-complying ways. For instance, an IC  that makes harmonics out in the 100s of MHZ may not radiate that power effectively - until you connect it to wires and/or PCB traces that happen to be tuned high-gain radiators for one of the harmonics by accident. So I don't think there is an exemption for modules and components, just a realization that certifying these is pointless.

Checking the final product for small enough emitted interference is the only thing that makes sense. Pre-certifying components doesn't necessarily help, from the technical standpoint.

[seedlings]

Does this court case address sales on the used market of untested EH gear?

CHAD

[PRR]

> sales on the used market of untested EH gear?

Nobody has said the existing E-H gear is bad.

The consent decree (not court case) says that E-H didn't test or certify, E-H agrees they probably should have, and will try to do better in the future (and pay a $450K "donation"/bribe).

[amptramp]

Industrial electrical requires third party inspectors

I also deal with manufacturing equipment certifications which do not allow self testing.

What I've gathered so far from the link that I posted is there are different levels of requirements, some requiring the testing being performed at a certified lab.

The problem is....I can't really tell by the examples where stompboxes fit under which requirements.

When I worked in avionics, the larger companies had their own test facilities for MIL-STD-461 and MIL-STD-462 testing but might still have outside labs and contractors to do specialized testing.  One contract called for testing to 40 GHz, which we were not prepared to do, so I accompanied the unit to a test facility in Los Angeles.  Smaller companies might do the testing entirely at outside labs.  One company we bought power supplies from had an interesting take on the test chamber - they rented a U-Haul cube van for $23 per day and added some bonding straps to the inside.  This lasted them a couple of years until they moved into a larger facility.  The $16790 they paid for two years was a small part of the cost of a real chamber and the shielding was good except for the local channel 6 TV station that could go through any shielding.

It is still necessary to select operating modes for some computerized equipment that will give the worst case emissions, so an operator should accompany the item under test.

[wavley]

Industrial electrical requires third party inspectors

I also deal with manufacturing equipment certifications which do not allow self testing.

What I've gathered so far from the link that I posted is there are different levels of requirements, some requiring the testing being performed at a certified lab.

The problem is....I can't really tell by the examples where stompboxes fit under which requirements.

When I worked in avionics, the larger companies had their own test facilities for MIL-STD-461 and MIL-STD-462 testing but might still have outside labs and contractors to do specialized testing.  One contract called for testing to 40 GHz, which we were not prepared to do, so I accompanied the unit to a test facility in Los Angeles.  Smaller companies might do the testing entirely at outside labs.  One company we bought power supplies from had an interesting take on the test chamber - they rented a U-Haul cube van for $23 per day and added some bonding straps to the inside.  This lasted them a couple of years until they moved into a larger facility.  The $16790 they paid for two years was a small part of the cost of a real chamber and the shielding was good except for the local channel 6 TV station that could go through any shielding.

It is still necessary to select operating modes for some computerized equipment that will give the worst case emissions, so an operator should accompany the item under test.

I worked for a very short time in a sweat shop that made small aircraft avionics (just analog traditional gauges and stuff) and they let folks self inspect their work and were strongly discouraged from rejecting anything.  I had to sit in a room with two people, both not very bright, with the opinions that if they built it then it worked and then they would stamp it.  The day I quit was the day after I called in to go to a job interview, I got  a message on the way to work with a job offer, I was going to play nice and put in my notice, but then I got there and clocked in.  As soon as I clocked in the boss started screaming at me wanting to know why the hell I called in and that Grayson had spend the entire day putting caps in backwards and then blowing them up and he needed me to clean up the mess.  I said "Kiss my a$$" and clocked out, it was very satisfying.  That place was a hellhole and I hope they go out of business, plus I have a lot of suspicions about where they got all the Russian women soldering with no ventilation in the other room.

[italianguy63]

Speaking of soldering with no ventilation.  Has anybody seen Jimi lately?  He has been quiet.  MC

[Seljer]

Industrial electrical requires third party inspectors

I also deal with manufacturing equipment certifications which do not allow self testing.

What I've gathered so far from the link that I posted is there are different levels of requirements, some requiring the testing being performed at a certified lab.

The problem is....I can't really tell by the examples where stompboxes fit under which requirements.

When I worked in avionics, the larger companies had their own test facilities for MIL-STD-461 and MIL-STD-462 testing but might still have outside labs and contractors to do specialized testing.  One contract called for testing to 40 GHz, which we were not prepared to do, so I accompanied the unit to a test facility in Los Angeles.  Smaller companies might do the testing entirely at outside labs.  One company we bought power supplies from had an interesting take on the test chamber - they rented a U-Haul cube van for $23 per day and added some bonding straps to the inside.  This lasted them a couple of years until they moved into a larger facility.  The $16790 they paid for two years was a small part of the cost of a real chamber and the shielding was good except for the local channel 6 TV station that could go through any shielding.

It is still necessary to select operating modes for some computerized equipment that will give the worst case emissions, so an operator should accompany the item under test.

The added benefit of the U-Haul is you could always drive it to somewhere quieter if you're still having external interference (deep into a tunnel perhaps)