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Re: [RFI] ARRL to FCC...

To: "'Hare, Ed W1RFI'" <w1rfi@arrl.org>, "Dale J." <dj2001x@comcast.net>
Subject: Re: [RFI] ARRL to FCC...
From: "EDWARDS, EDDIE J" <eedwards@oppd.com>
Date: Tue, 1 Apr 2014 17:54:05 +0000
List-post: <rfi@contesting.com">mailto:rfi@contesting.com>
Ed, 

OK, so you say the FCC has the "right" to "ask for data" and/or to "test the 
unit" themselves, and the FCC "should" do those things; however, is there 
currently a regulation, rule or law that requires them to do any of this or 
anything at all?  

Of course, we currently see that even if there is an actual law on the books, 
the feds don't have to actually follow it or do anything about it, so I suppose 
that reality makes my question sort of pointless, but I am still curious.

73, de ed -K0iL

-----Original Message-----
From: RFI [mailto:rfi-bounces@contesting.com] On Behalf Of Hare, Ed W1RFI
Sent: Tuesday, April 01, 2014 12:38 PM
To: Dale J.
Cc: RFI@contesting.com
Subject: Re: [RFI] ARRL to FCC...

The FCC already has the right to ask for test data, to test the unit themselves 
and to determine that those tests  are accurate. I am not sure what else you 
are thinking they should have the right to do.

The FCC should actually do those things from time to time.

Ed


-----Original Message-----
From: Dale J. [mailto:dj2001x@comcast.net] 
Sent: Sunday, March 30, 2014 5:24 AM
To: Hare, Ed W1RFI
Cc: RFI@contesting.com
Subject: Re: [RFI] ARRL to FCC...

Ed,

If the manufacturer is required to test the device then the overseeing agency 
should have the right to visit the mfg lab where the testing is performed and 
do an audit of the procedures, watch tests being performed and if procedures 
are followed.  Unscheduled visits are also to be permitted and spot checks in 
the field may also be performed, not required, but the possibility would exist. 
 This would place a burden on the mfg to assure that testing is performed and 
in a prescribed way, sample sizes, methods, test equip. etc.  

I don't believe this would require an army of agency personnel to carry this 
out.  Just the fact that it's in place would send a message.  Of course the 
penalty for non-compliance would be enormous, both monitory and criminal 
negligence for those who knowingly broke the law with intent to deceive. This 
after all could constitute a safety issue.  

This business of allowing manufacturers to simply test something without any 
oversight and just because they say it's good is like allowing a fox to manage 
a chicken coop.  They probably don't do any testing at all, just take our word 
for it's good, ya right.  

As for product that's shipped from overseas, the receiving company would be 
responsible for the testing and would be under the same rules and penalty as on 
shore mfg.'s. 

This is not rocket science.  
 
73
Dale, k9vuj




On 29, Mar 2014, at 20:40, "Hare, Ed  W1RFI" <w1rfi@arrl.org> wrote:

> The unit we tested had the FCC logo on it, even though it was 58 dB over the 
> noise limits.
> 
> It also has a CE mark on it, and there are already complaints being brought 
> in Europe.  
> 
> Under the US rules, the FCC does not test any equipment to authorize it.  
> Even certification is based on manufacturer-supplied test data.  In the case 
> of lighting devices, the equipment is "verified," meaning that the 
> manufacturer is required to test the design before marketing it.
> 
> Ed Hare, W1RFI
> 
> 
> ________________________________________
> From: RFI [rfi-bounces@contesting.com] on behalf of Roger D Johnson 
> [n1rj@roadrunner.com]
> Sent: Saturday, March 29, 2014 8:50 PM
> To: RFI@contesting.com
> Subject: Re: [RFI] ARRL to FCC...
> 
> An occasional spot check wouldn't bring world commerce to a halt! If 
> an item fails and it's found that the mfr left out critical filtering 
> components, the whole load goes back to China.
> 
> On 3/29/2014 3:43 PM, Rik van Riel wrote:
>> On 03/21/2014 02:48 PM, W0MU Mike Fatchett wrote:
>>> Do you really think we need more gov't to be involved with 
>>> inspecting and testing EVERY item that is made so that it does not 
>>> hurt people, cause interference and on and on and on.  We would 
>>> never see another product brought to market.
>>> 
>>> We don't live in a perfect world and expecting something like this 
>>> with a gov't that is 17trillion in the hole is crazy.
>> Proactively having the government check everything does seem 
>> impractical, indeed.
>> 
>> However, putting rules in place that oblige manufacturers and/or 
>> importers to replace faulty equipment at their expense (instead of 
>> stiffing the consumers) might be a good deterrent to people sticking 
>> FCC stickers on untested equipment...
>> 
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