Comments on a bunch of messages... Barry King wrote... "For Class A, or optionally for class B, you still file your test results with the FCC, pay the filing fee, and wait for a certification from them. Then you use the Certified form of the label, which includes a certificate number." This appears to conflict with 15.101 < http://www.hallikainen.com/cgi-bin/section.pl?section=15.101 >, which states that class A devices are subject to "verification". 2.902(a) < http://www.hallikainen.com/cgi-bin/section.pl?section=2.902 > states that no data is filed with the Commission... "Sec. 2.902 Verification. (a) Verification is a procedure where the manufacturer makes measurements or takes the necessary steps to insure that the equipment complies with the appropriate technical standards. Submittal of a sample unit or representative data to the Commission demonstrating compliance is not required unless specifically requested by the Commission pursuant to Sec. 2.957, of this part." Peter Van Hoof wrote... probably the easy way to avoid all this is make it a kit. Shouldn't cause problems because it would be the responsibility of the individual building the kit (a good disclaimer is needed) Peter pvh@vertonet.com -----Original Message----- From: pic microcontroller discussion list [mailto:PICLIST@MITVMA.MIT.EDU]On Behalf Of Adam Davis Sent: Monday, July 12, 1999 5:25 PM To: PICLIST@MITVMA.MIT.EDU Subject: Re: Correction: FCC Labeling? Ok, let's say that I'm a hobbyist who wants to make 20-30 devices to be sold to technicions who are not close friends. [deletia] Sec. 15.23 Home-built devices. < http://www.hallikainen.com/cgi-bin/section.pl?section=15.23 > (a) Equipment authorization is not required for devices that are not marketed, are not constructed from a kit, and are built in quantities of five or less for personal use. (b) It is recognized that the individual builder of home-built equipment may not possess the means to perform the measurements for determining compliance with the regulations. In this case, the builder is expected to employ good engineering practices to meet the specified technical standards to the greatest extent practicable. The provisions of Sec. 15.5 apply to this equipment. Section 15.25 < http://www.hallikainen.com/cgi-bin/section.pl?section=15.25 > is the only reference to "kits" I see in part 15, and it refers to "TV interface devices," which is not really applicable to what most of us are doing. It DOES appear the FCC has a bit hole in the rules where kits are concerned. Is the device without batteries a "kit"? The user is doing "final assembly." I know that various companies are selling broadcast transmitter kits that do not meet the requirements of part 73 or part 15. Since these are "kits", the company is apparently able to avoid liability, though the user is certainly liable. Should the Commission choose to regulate kits, how do you define a kit? Must a complete set of parts be supplied in the kit? If it's short one part (like batteries), is it a kit? If the "kit" contains no parts, but is merely plans for a device that would not be legal to operate, should the Commission have regulatory authority over the "plans?" Harold Harold Hallikainen harold@hallikainen.com Hallikainen & Friends, Inc. See the FCC Rules at http://hallikainen.com/FccRules and comments filed in LPFM proceeding at http://hallikainen.com/lpfm ___________________________________________________________________ Get the Internet just the way you want it. Free software, free e-mail, and free Internet access for a month! Try Juno Web: http://dl.www.juno.com/dynoget/tagj.