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DIY Stompboxes => Building your own stompbox => Topic started by: Mark Hammer on May 06, 2014, 02:36:00 PM

Title: Good to know - FCC regulations
Post by: Mark Hammer on May 06, 2014, 02:36:00 PM
I was unaware that EHX had been fined $450k and settled with the FCC last year:  http://www.fcc.gov/document/new-sensor-pays-450k-settle-equipment-marketing-investigation

Here is a nice coherent writeup of the regs: http://www.effectsbay.com/2014/05/fcc-regulations-for-pedals/

Many thanks to Canadian Guitar Forum member bzrkrage for drawing this to my attention.
Title: Re: Good to know - FCC regulations
Post by: italianguy63 on May 06, 2014, 02:49:47 PM
This is very bad to the small hobbyist.
Title: Re: Good to know - FCC regulations
Post by: armdnrdy on May 06, 2014, 02:54:15 PM
I breezed through the complaint...and about all I see is that EHX didn't have their compliance paperwork in order.

I would imagine that they didn't even realize that they even fell into that category!

I would like to know when the FCC laws changed to include delay units and amplifiers!!!

I have never heard of such a thing!

Anything for the Government to make take more money
Title: Re: Good to know - FCC regulations
Post by: midwayfair on May 06, 2014, 02:54:52 PM
WTF.

Technically a guitar pickup does this.
Title: Re: Good to know - FCC regulations
Post by: Mark Hammer on May 06, 2014, 03:00:44 PM
One wonders if any commercial product with a PT2399 in it, or any of the Molten Voltage Tap-tempo chips, falls under the same guidelines.  If so, that's an awful lot of unwitting offenders out there.  I take it that anything using an FV-1 is an obvious digital device.
Title: Re: Good to know - FCC regulations
Post by: davent on May 06, 2014, 03:12:21 PM
The Effects Bay link talks about > 9kHz signals or clocks, internally generated, being the threshold between digital/analogue, eg. given is the clock output in a Small Clone, 20-80kHz.
Title: Re: Good to know - FCC regulations
Post by: Mark Hammer on May 06, 2014, 03:18:18 PM
I have no idea what differentiates things like BBDs and their HF clocks, from "digital" devices.
Title: Re: Good to know - FCC regulations
Post by: karbomusic on May 06, 2014, 03:25:48 PM
Quote from: midwayfair on May 06, 2014, 02:54:52 PM
WTF.

Technically a guitar pickup does this.

I didn't see where a pickup fits the following but could be missing something...

Quote
A digital device is defined as "an unintentional radiator (device or system) that generates and uses timing signals or pulses at a rate in excess of 9,000 pulses (cycles) per second and uses digital techniques." A Class B digital device is defined "as a digital device that is marketed for use in a residential environment notwithstanding use in commercial, business and industrial environments."

IOW the second definition is as subset of the first.
Title: Re: Good to know - FCC regulations
Post by: Govmnt_Lacky on May 06, 2014, 03:25:52 PM
Hahahahahahahahaha  ;D  :icon_mrgreen:  :icon_lol:  :icon_lol:   :icon_lol:

So, what are all of the booteek builders gonna do when you call out their BBD-based devices as "Digital?"

I suppose you can retort with a link to the FCC regulation  ;)

Bye Bye BBD mojo!! I think I just heard multiple For Sale listings drop!!  :icon_twisted:
Title: Re: Good to know - FCC regulations
Post by: GibsonGM on May 06, 2014, 03:27:33 PM
The *best* thing about regulations is that it makes offenders out of uncountable numbers of people who have no idea they ARE *offenders*  :o/  

It's that thing about unelected bureaucrats again....they can be used to protect huge corporations, if someone wanted to....and to squash little guys...

*cough* CF Martin *cough*
Title: Re: Good to know - FCC regulations
Post by: mth5044 on May 06, 2014, 03:37:34 PM
Quote from: Govmnt_Lacky on May 06, 2014, 03:25:52 PM
Hahahahahahahahaha  ;D  :icon_mrgreen:  :icon_lol:  :icon_lol:   :icon_lol:

So, what are all of the booteek builders gonna do when you call out their BBD-based devices as "Digital?"

I suppose you can retort with a link to the FCC regulation  ;)

Bye Bye BBD mojo!! I think I just heard multiple For Sale listings drop!!  :icon_twisted:

People were buying boutique 'analog' delays that were made of PT2399's without hesitation, so I can't imagine this is going to change anything.
Title: Re: Good to know - FCC regulations
Post by: slacker on May 06, 2014, 04:01:46 PM
Quote from: Mark Hammer on May 06, 2014, 03:00:44 PM
One wonders if any commercial product with a PT2399 in it, or any of the Molten Voltage Tap-tempo chips, falls under the same guidelines.  If so, that's an awful lot of unwitting offenders out there.  I take it that anything using an FV-1 is an obvious digital device.

Yep, they'd all fall under the same rules. All your Klon klones as well  ;D
Title: Re: Good to know - FCC regulations
Post by: Mark Hammer on May 06, 2014, 04:02:56 PM
So anything with a charge pump would need to get FCC clearance to be a commercial product?
Title: Re:
Post by: slacker on May 06, 2014, 04:10:42 PM
That's what the link says, and my Soul Food has an FCC sticker on it.
Might be interesting for us to learn some techniques for making compliant pedals, might help understand and stop hetrodyning problems.
Title: Re: Good to know - FCC regulations
Post by: R.G. on May 06, 2014, 04:20:56 PM
Quote from: Mark Hammer on May 06, 2014, 03:00:44 PM
One wonders if any commercial product with a PT2399 in it, or any of the Molten Voltage Tap-tempo chips, falls under the same guidelines.  If so, that's an awful lot of unwitting offenders out there.  I take it that anything using an FV-1 is an obvious digital device.
Under the letter of the law as I read these revisions, anything with a PT2399 or any uC with an internal or external clock set to more than 9kHz, or *anything* is under the guidelines. In fact, any simple setup with a CMOS oscillator over 9kHz is over the limit. Or a discrete flipflop oscillator. Every BBD clock ever made is over the edge, so under the strict definition, importing a chorus made in the early 70s into the USA without testing for emissions is a violation, unless there was a grandfather clause I missed.

The limit for digital devices used to be 100kHz, below which  no special testing was needed.

I was surprised when the FCC retreated from actual enforcement some years ago. They used to be all over single over-transmitting ham radio operators, but that mostly all quit. They seem to have woken up again.  It will be interesting to see if the FCC gets all militarized and starts running armed surprise raids like the EPA and Forest Service have started doing.    :icon_eek:

Quote from: slacker on May 06, 2014, 04:10:42 PM
That's what the link says, and my Soul Food has an FCC sticker on it.
Might be interesting for us to learn some techniques for making compliant pedals, might help understand and stop hetrodyning problems.
Note that the requirement is not that you have used compliant techniques, it is that your pedal has been certified to pass the radiated emissions limits by someone. There is a self certification rule, apparently, but I suspect there are penalties for certifying without really verifying. The average DIYer simply can't make compliant pedals because the instrumentation to verify is so expensive. And a pass through a certification lab is several thousand bucks a pass, whether you pass or not.
Title: Re: Good to know - FCC regulations
Post by: wavley on May 06, 2014, 04:32:15 PM
And yet Fujitsu is allowed to make an air conditioner that radiates RFI so bad that anything in my house with a speaker goes "zing zing zing zing" and I had to go fix it myself.  But hey, we should worry about the charge pump in a die cast box polluting the spectrum.  Good job FCC.

I'm a believer in FCC regulations when they aren't arbitrary and stupidly enforced. 
Title: Re:
Post by: slacker on May 06, 2014, 04:38:48 PM
I didn't actually mean make compliant pedals,  bad choice of words. I just meant that presumably there's techniques and good practices used in commercial products that we can learn from. As hobbyists the actual rules don't apply to us, as I understand it you're allowed to make things for personal use without worrying about the FCC coming after you.
I suspect most small boutiquers flout a whole heap of different legislation so one more ain't worth worrying about.
Title: Re: Good to know - FCC regulations
Post by: wavley on May 06, 2014, 04:51:35 PM
A sibilant s can be 8 to 12 kHz and is internally generated, am I now considered digital when I say words like "stupid"?
Title: Re: Good to know - FCC regulations
Post by: armdnrdy on May 06, 2014, 04:53:35 PM
Quote from: slacker on May 06, 2014, 04:38:48 PM
As hobbyists the actual rules don't apply to us, as I understand it you're allowed to make things for personal use without worrying about the FCC coming after you.

I doubt that the rules don't actually apply to hobbyists. The FCC is obviously concerned with interference of some kind.

This would be like a car manufacturer having to put seatbelts in a car. If you were to build a car in your garage do you think that you would be exempt from installing seatbelts?

As far as the FCC coming after the hobbyist for non compliance: They won't if they don't know....unless they start doing house to house searches for non compliant electronic devices!
Then we have to hide them in our basements and attics!  :icon_wink:

Just like anything...there is no money in going after the little guys. So I think we're safe!
Title: Re:
Post by: slacker on May 06, 2014, 05:02:24 PM
Ha ha I should just shut up or learn to write what I actually mean. As hobbyists you don't have to get stuff you make for personal use tested and certified. If the FCC come and tell you to stop polluting the airwaves you have to stop. That seems to be the size of it.
Title: Re: Good to know - FCC regulations
Post by: armdnrdy on May 06, 2014, 05:07:18 PM
Ian...

You don't have to worry about it anyway.

The last that I heard....the FCC is a U.S. entity and only governs in the U.S. of A.

But....you never know...coming soon to a town near you....The WCC (World Communications Commission)  ;D
Title: Re: Good to know - FCC regulations
Post by: R.G. on May 06, 2014, 05:09:29 PM
Quote from: wavley on May 06, 2014, 04:32:15 PM
I'm a believer in FCC regulations when they aren't arbitrary and stupidly enforced. 
I'm a believer in regulations per se that are not arbitrary and stupidly enforced. Sadly, the actions of many governments is to make almost everything illegal, then enforce the rules selectively when they like.

Here's an interesting read:
http://www.huffingtonpost.com/john-w-whitehead/the-overcriminalization-of-america_b_1747000.html (http://www.huffingtonpost.com/john-w-whitehead/the-overcriminalization-of-america_b_1747000.html)
Title: Re:
Post by: slacker on May 06, 2014, 05:12:11 PM
I'm sure the EU has similar things for us to worry about.

This is quite a good read on the subject https://www.sparkfun.com/tutorials/398 (https://www.sparkfun.com/tutorials/398)
Title: Re: Good to know - FCC regulations
Post by: GibsonGM on May 06, 2014, 05:28:43 PM
Quote from: R.G. on May 06, 2014, 05:09:29 PM
Quote from: wavley on May 06, 2014, 04:32:15 PM
I'm a believer in FCC regulations when they aren't arbitrary and stupidly enforced. 
I'm a believer in regulations per se that are not arbitrary and stupidly enforced. Sadly, the actions of many governments is to make almost everything illegal, then enforce the rules selectively when they like.

Here's an interesting read:
http://www.huffingtonpost.com/john-w-whitehead/the-overcriminalization-of-america_b_1747000.html (http://www.huffingtonpost.com/john-w-whitehead/the-overcriminalization-of-america_b_1747000.html)

Good read, R.G. - thanks.   Wish it was a happier story, though!! 
Title: Re: Good to know - FCC regulations
Post by: midwayfair on May 06, 2014, 05:43:29 PM
I'm going to talk with my boss (I work at a law office) tomorrow to see if he has anything to say about it.

The only way out of this I see is that the FCC will have to approve specific devices, and not individual products, because if they don't they're harming an exceptionally wide range of audio equipment, not just guitar pedals. Hopefully one of the big players will push for that. OR maybe we can start a petition. Just reading the regulations, this makes a very, very wide swath of pedals illegal:

Title: Re: Good to know - FCC regulations
Post by: R.G. on May 06, 2014, 06:23:31 PM
Quote from: midwayfair on May 06, 2014, 05:43:29 PM
... because if they don't they're harming an exceptionally wide range of audio equipment, not just guitar pedals.
Sadly, the recent direction of the US government is to simply tell you what you have to do because they think it's good for you. "Harms a lot of people" doesn't seem to get into the considerations much.
Title: Re:
Post by: Mark Hammer on May 06, 2014, 06:42:48 PM
Quote from: slacker on May 06, 2014, 05:02:24 PM
Ha ha I should just shut up or learn to write what I actually mean. As hobbyists you don't have to get stuff you make for personal use tested and certified. If the FCC come and tell you to stop polluting the airwaves you have to stop. That seems to be the size of it.
Pretty much.  Such agencies can get stoopid, but are generally limited by the budget they have to work with.  No inspectors, no enforcement.

I'm just curious about why 9khz.  Why there and not, say, 8khz, or 20khz?  Anyone have any technical insight as to the origins of that boundary/threshold?  Is there any sort of more recent technology operatng in that zone whose functioning might possibly be interfered with?  For example, any health devices, pumps, electrical stimulators, etc. whose functioning can be interfered with?
Title: Re: Good to know - FCC regulations
Post by: amz-fx on May 06, 2014, 06:45:58 PM
Apparently the New-Sensor-EHX people do not read DIYstompboxes since I posted a notice about a similar incident over eight years ago.

Check it out: http://www.diystompboxes.com/smfforum/index.php?topic=42399.0

I just picked up a couple of digital pedals off my pedalboard and they had FCC compliance stickers on the back (Digitech and Boss pedals).

regards, Jack

Title: Re: Good to know - FCC regulations
Post by: R.G. on May 06, 2014, 06:50:51 PM
Mike is not big on reading, maybe.  :icon_biggrin:

If you want to see a frenzy, wait for when - not if - someone gets electrocuted by a custom/boutique amplifier that wasn't built to safety standards.
Title: Re: Good to know - FCC regulations
Post by: amz-fx on May 06, 2014, 07:00:20 PM
Quote from: R.G. on May 06, 2014, 06:50:51 PM
If you want to see a frenzy, wait for when - not if - someone gets electrocuted by a custom/boutique amplifier that wasn't built to safety standards.

No doubt.

I just looked at my Arduino Uno and it has an FCC compliance statement in the manual but not attached to the device. I'm not sure that is completely legal.  The Chinese Arudino clone that I have has nothing related to FCC compliance.

regards, Jack

Title: Re: Good to know - FCC regulations
Post by: italianguy63 on May 06, 2014, 07:02:26 PM
The Chinese will just keep selling with no regard-- (what are we going to do about it)?  And, we will all be felons.

MC
Title: Re: Good to know - FCC regulations
Post by: R.G. on May 06, 2014, 07:06:12 PM
It's a common problem with really low-end electronics that the buyer can have whatever they like printed on the device, the packaging, whatever.

I do however, envision a New! Improved!! FCC arming its agents and swarming over incoming containers at ports in a highly news-friendly mode (i.e., we tipped off the networks that there would be a raid) so they can get in on the SWAT team, ATF, EPA and Forest Service, and BLM's recent promotion of their enforcement arms to military police status.
Title: Re: Good to know - FCC regulations
Post by: italianguy63 on May 06, 2014, 07:10:54 PM
Why can't they focus on stuff that really hurts people?  Like counterfeit designer purses, Tiffany jewelry, and sneakers?
Title: Re: Good to know - FCC regulations
Post by: karbomusic on May 06, 2014, 07:14:39 PM
Quote from: armdnrdy on May 06, 2014, 04:53:35 PM
I doubt that the rules don't actually apply to hobbyists. The FCC is obviously concerned with interference of some kind.

They shouldn't apply if one is truly a hobbyist; that doesn't mean someone can't mangle enforcement but they are marketing rules and appear on the surface as fairly specific:

QuoteTitle 47, Volume I, Chapter I, §2.803, includes the sale or lease, or offer to sell or lease your musical instrument product, including advertising in any form. Marketing also includes importing, shipping or distributing a product for the purpose of selling or leasing.

So for accuracy's sake, selling one's pedal wares isn't necessarily a hobbyist but yes interference at least was the initial concern IIRC.

I do agree outside of this issue that some FCC interference rules are good, I don't really want some guy next door rendering every digital device in my home essentially unusable when he fires up his widget or grandpa going "face in the plate" because someone fried his pacemaker from three houses away.

With the widespread use and sheer dependence on technology these days, I think this window is going to get smaller and more restricted/complex. Will someone try to exploit the rules to their gain? Exploitation comes with the territory even if there aren't' rules.
Title: Re: Good to know - FCC regulations
Post by: davent on May 06, 2014, 07:21:26 PM
Quote from: amz-fx on May 06, 2014, 07:00:20 PM
Quote from: R.G. on May 06, 2014, 06:50:51 PM
If you want to see a frenzy, wait for when - not if - someone gets electrocuted by a custom/boutique amplifier that wasn't built to safety standards.

No doubt.

I just looked at my Arduino Uno and it has an FCC compliance statement in the manual but not attached to the device. I'm not sure that is completely legal.  The Chinese Arudino clone that I have has nothing related to FCC compliance.

regards, Jack



Somewhere in my perusing today there was mention that if the device was too small to carry a legible attached notice it then had to be printed in the owners manual or something to that effect.
dave
Title: Re: Good to know - FCC regulations
Post by: Dave W on May 06, 2014, 07:37:20 PM
look at the manual from BOSS digital f/x. they have a statement of compliance written in them. i remember seeing that in the 1990's in a dd-3 i purchased.
so.... EH had to know about this. mr. matthews is savvy businessman. i find it hard to believe he had no knowledge of these regs. why didn't he/they address this?
i have some thoughts about this but will refrain from posting them. don't want to start a firestorm here....
Title: Re: Good to know - FCC regulations
Post by: GibsonGM on May 06, 2014, 08:50:24 PM
Quote from: italianguy63 on May 06, 2014, 07:10:54 PM
Why can't they focus on stuff that really hurts people?  Like counterfeit designer purses, Tiffany jewelry, and sneakers?

Because the name of the game is, and always has been, to protect your "friends" and take down your "enemies".  Gibson gets raided, but Martin doesn't - but they use the SAME "illegal" wood???  Raw milk raids?  The list is long.    Follow the money: who donates where?  Who doesn't?    Who stands to gain from this action?  << this one is a biggie...someone out there is going to gain from EH's problem...

They don't USUALLY make these laws/regulations because they protect or help folks;  they are playing favorites. 
Don't want to start a firestorm, either, ha ha, but sometimes it happens! 
Title: Re: Good to know - FCC regulations
Post by: JohnForeman on May 06, 2014, 09:17:35 PM
EHX should have taken that money, bought lots of guns and ammo and told the FCC to stick in their ass.  It worked for a Nevada rancher!
Title: Re: Good to know - FCC regulations
Post by: seedlings on May 06, 2014, 09:18:57 PM
On the flip side, it appears the diy pedal community has the capability to take down governments. Maybe on that missing maylasian flight there was a suitcase with a battery powered chorus engaged.

CHAD
Title: Re: Good to know - FCC regulations
Post by: attyguitarplayer on May 06, 2014, 10:26:44 PM
Quote from: midwayfair on May 06, 2014, 05:43:29 PM
I'm going to talk with my boss (I work at a law office) tomorrow to see if he has anything to say about it.

The only way out of this I see is that the FCC will have to approve specific devices, and not individual products, because if they don't they're harming an exceptionally wide range of audio equipment, not just guitar pedals. Hopefully one of the big players will push for that. OR maybe we can start a petition. Just reading the regulations, this makes a very, very wide swath of pedals illegal:


  • Anything with a charge pump

  • Anything that requires a clock chip to produce the effect -- analog octave down, bucket brigade delay/chorus/vibrato, etc.

  • PT2399 delays and other digital delays -- so far as I can tell, everything involved in making analog delay pedals, with one notable exception, is now in violation. That exception is tape delays. I'm sure we'll all be thrilled to go back to THAT technology.

  • Anything with tap tempo.

  • Every pedal you can think of based on the FV-1 -- this covers a LOT of reverb pedals.

  • All those reverbs based on the Belton brick -- this covers most of your other reverbs.

I am an attorney. I can post the FCC regs the violated on here. I like how they are citing them with violation of law passed in 1932. Next time the FCC proposes rule changes, the public has the right to comment and I would suggest that we all submit our comments to something that effects musicians.

Here is a PDF from the FCC. If is easier to read. http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-13-706A1.pdf (http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-13-706A1.pdf)
THIS IS NOT LEGAL ADVICE. NOR DOES IT FORM AN ATTORNEY/CLIENT RELATIONSHIP. IF YOU NEED AN ATTORNEY OR LEGAL ADVICE CONTACT AN ATTORNEY IN YOUR JURISDICTION
Title: Re: Good to know - FCC regulations
Post by: armdnrdy on May 06, 2014, 10:42:26 PM
Mark brought up a good point.

If this is all about interference of some sort, then shouldn't there be a FCC zone ordinance/warning label regarding the distance that a particular device can be operated around ???? whatever it might interfere with?

Instead of something that would make sense like a label....manufacturers have to dish out part of their profit to show that a device complies with the FCCs guidelines.

If a charge pump laden stompbox can interfere with the workings of sensitive medical devices...I think we're safe.
I am 51 years old and I can honestly say that I have never witnessed anyone playing an electric guitar through a pedal board in the emergency room of a hospital!

Title: Re: Good to know - FCC regulations
Post by: armdnrdy on May 06, 2014, 10:45:49 PM
Quote from: attyguitarplayer on May 06, 2014, 10:26:44 PM
I am an attorney. I can post the FCC regs the violated on here. I like how they are citing them with violation of law passed in 1932.

They are actually citing them with the amendments that have been passed in more recent times.

Section 302(b) of the Communications Act
of 1934, as amended (Act),1 and Sections 2.803, 2.1203, 2.1204, 2.1205, 15.19, and 15.105 of the
Commission's rules (Rules)2 pertaining to the marketing of digital radio frequency devices, such as bass
amplifiers, pre-amplifiers, bass pedals, digital delay and loop carriers, and vocal processors.


I don't believe that 1932 was a very "digital" year.  :icon_wink:
Title: Re: Good to know - FCC regulations
Post by: attyguitarplayer on May 06, 2014, 10:55:01 PM
(a) Regulations The Commission may, consistent with the public interest, convenience, and necessity, make reasonable regulations.

(1) governing the interference potential of devices which in their operation are capable of emitting radio frequency energy by radiation, conduction, or other means in sufficient degree to cause harmful interference to radio communications; and

(2) establishing minimum performance standards for home electronic equipment and systems to reduce their susceptibility to interference from radio frequency energy. Such regulations shall be applicable to the manufacture, import, sale, offer for sale, or shipment of such devices and home electronic equipment and systems, and to the use of such devices.

(b) Restrictions No person shall manufacture, import, sell, offer for sale, or ship devices or home electronic equipment and systems, or use devices, which fail to comply with regulations promulgated pursuant to this section.

(c) Exceptions The provisions of this section shall not be applicable to carriers transporting such devices or home electronic equipment and systems without trading in them, to devices or home electronic equipment and systems manufactured solely for export, to the manufacture, assembly, or installation of devices or home electronic equipment and systems for its own use by a public utility engaged in providing electric service, or to devices or home electronic equipment and systems for use by the Government of the United States or any agency thereof. Devices and home electronic equipment and systems for use by the Government of the United States or any agency thereof shall be developed, procured, or otherwise acquired, including offshore procurement, under United States Government criteria, standards, or specifications designed to achieve the objectives of reducing interference to radio reception and to home electronic equipment and systems, taking into account the unique needs of national defense and security.

(d) Cellular telecommunication receivers

(1) Within 180 days after October 28, 1992, the Commission shall prescribe and make effective regulations denying equipment authorization (under part 15 of title 47, Code of Federal Regulations, or any other part of that title) for any scanning receiver that is capable of--(A) receiving transmissions in the frequencies allocated to the domestic cellular radio telecommunications service,(B) readily being altered by the user to receive transmissions in such frequencies, or(C) being equipped with decoders that convert digital cellular transmissions to analog voice audio.

(2) Beginning 1 year after the effective date of the regulations adopted pursuant to paragraph (1), no receiver having the capabilities described in subparagraph (A), (B), or (C) of paragraph

(1), as such capabilities are defined in such regulations, shall be manufactured in the United States or imported for use in the United States.(e) Delegation of equipment testing and certification to private laboratoriesThe Commission may--(1) authorize the use of private organizations for testing and certifying the compliance of devices or home electronic equipment and systems with regulations promulgated under this section;(2) accept as prima facie evidence of such compliance the certification by any such organization; and(3) establish such qualifications and standards as it deems appropriate for such private organizations, testing, and certification.

(f) State and local enforcement of FCC regulations on use of citizens band radio equipment

(1) Except as provided in paragraph

(2), a State or local government may enact a statute or ordinance that prohibits a violation of the following regulations of the Commission under this section:

(A) A regulation that prohibits a use of citizens band radio equipment not authorized by the Commission.(B) A regulation that prohibits the unauthorized operation of citizens band radio equipment on a frequency between 24 MHz and 35 MHz.(2) A station that is licensed by the Commission pursuant to section 301 of this title in any radio service for the operation at issue shall not be subject to action by a State or local government under this subsection. A State or local government statute or ordinance enacted for purposes of this subsection shall identify the exemption available under this paragraph.(3) The Commission shall, to the extent practicable, provide technical guidance to State and local governments regarding the detection and determination of violations of the regulations specified in paragraph (1).(4)(A) In addition to any other remedy authorized by law, a person affected by the decision of a State or local government agency enforcing a statute or ordinance under paragraph (1) may submit to the Commission an appeal of the decision on the grounds that the State or local government, as the case may be, enacted a statute or ordinance outside the authority provided in this subsection.
(B) A person shall submit an appeal on a decision of a State or local government agency to the Commission under this paragraph, if at all, not later than 30 days after the date on which the decision by the State or local government agency becomes final, but prior to seeking judicial review of such decision.
(C) The Commission shall make a determination on an appeal submitted under subparagraph (B) not later than 180 days after its submittal.(D) If the Commission determines under subparagraph (C) that a State or local government agency has acted outside its authority in enforcing a statute or ordinance, the Commission shall preempt the decision enforcing the statute or ordinance.
(5) The enforcement of statute or ordinance that prohibits a violation of a regulation by a State or local government under paragraph (1) in a particular case shall not preclude the Commission from enforcing the regulation in that case concurrently.(6) Nothing in this subsection shall be construed to diminish or otherwise affect the jurisdiction of the Commission under this section over devices capable of interfering with radio communications.(7) The enforcement of a statute or ordinance by a State or local government under paragraph (1) with regard to citizens band radio equipment on board a "commercial motor vehicle", as defined in section 31101 of Title 49, shall require probable cause to find that the commercial motor vehicle or the individual operating the vehicle is in violation of the regulations described in paragraph (1).

47 U.S.C.A. § 302a (West)
Title: Re: Good to know - FCC regulations
Post by: attyguitarplayer on May 06, 2014, 11:01:06 PM
Quote from: armdnrdy on May 06, 2014, 10:45:49 PM
Quote from: attyguitarplayer on May 06, 2014, 10:26:44 PM
I am an attorney. I can post the FCC regs the violated on here. I like how they are citing them with violation of law passed in 1932.

They are actually citing them with the amendments that have been passed in more recent times.

Section 302(b) of the Communications Act
of 1934, as amended (Act),1 and Sections 2.803, 2.1203, 2.1204, 2.1205, 15.19, and 15.105 of the
Commission's rules (Rules)2 pertaining to the marketing of digital radio frequency devices, such as bass
amplifiers, pre-amplifiers, bass pedals, digital delay and loop carriers, and vocal processors.


I don't believe that 1932 was a very "digital" year.  :icon_wink:

Of course it not a very digital year. Here are the laws passed to amend that law.

(June 19, 1934, c. 652, Title III, § 302, as added Pub.L. 90-379, July 5, 1968, 82 Stat. 290; amended Pub. L. 97-259, Title I, § 108(a), Sept. 13, 1982, 96 Stat. 1091; Pub.L. 102-556, Title IV, § 403(a), Oct. 28, 1992, 106 Stat. 4195; Pub.L. 104-104, Title IV, § 403(f), Feb. 8, 1996, 110 Stat. 131; Pub.L. 106-521, § 1, Nov. 22, 2000, 114 Stat. 2438.)

47 U.S.C.A. § 302a (West).
Title: Re: Good to know - FCC regulations
Post by: Lurco on May 07, 2014, 04:05:23 AM
History repeating? http://www.mi-pro.co.uk/news/read/behringer-s-music-group-files-us-suit-against-peavey-2 Beh-revenge?
Title: Re:
Post by: Blitz Krieg on May 07, 2014, 04:08:40 AM
Quote from: Mark Hammer on May 06, 2014, 06:42:48 PM
I'm just curious about why 9khz.  Why there and not, say, 8khz, or 20khz?  Anyone have any technical insight as to the origins of that boundary/threshold?  Is there any sort of more recent technology operatng in that zone whose functioning might possibly be interfered with?  For example, any health devices, pumps, electrical stimulators, etc. whose functioning can be interfered with?

What device did they decide they don't care about?
Title: Re: Good to know - FCC regulations
Post by: Lurco on May 07, 2014, 04:57:45 AM
AM-radio channel bandwidth spacing: 9kHz http://en.wikipedia.org/wiki/AM_broadcasting
Title: Re: Good to know - FCC regulations
Post by: craigmillard on May 07, 2014, 06:05:58 AM
Is there anything like this for the UK or EU market?
Id imagine there is but whenever i try and find any regs on manufacturing pedals nothing comes up as its all low voltage..

There must be somehting for smps's as well!
Title: Re: Good to know - FCC regulations
Post by: Ice-9 on May 07, 2014, 06:23:09 AM
In the Uk we have quite a high unemployment issue which I'm sure the rest of the world does as well, the UK government encourages people to go self employed (mostly just to fiddle there figures). So you decide to do something like build pedals for a living and we all know that's not going to pay your bills properly, you maybe sell 4-5 pedals a week if your lucky.

So

First of all in Europe we have RoHs to comply with if you want to sell anything. which IS rules gone mad.
Then the FCC thing, if you try and sell in the USA,  I imagine to have a pedal tested for FCC certification would cost more than a 'One man pedal building small business' would turn over a year.

What annoys me is that people try to better themselves by trying to work a small business in something they enjoy doing, but too many stupid hurdles are thrown up in front of you. The normal man/woman just gets kicked down all the time.

I am all for rules on quality and safety but the trouble is that someone comes up with a good idea like RoHs and then some other do-gooder arrives and totally bastardizes the idea behind it and makes the whole thing unworkable for the little business man.
Title: Re: Good to know - FCC regulations
Post by: GibsonGM on May 07, 2014, 07:18:18 AM
The rules for actual safety were established long ago. This has nothing to do with anything more than slamming the door on others who may be on their way up, and/or getting control of a pie that is worth BIG money.   You are a power player, or you are not.  If not, you are going to be stepped on.   You don't always know WHY something happens, but there IS a money trail, if one could find it.

Wondering about 'oh, why are they doing this?' won't get you anywhere.  Nor will appeals, etc.  Nobody is 'misguided', they know exactly what is going on.  This is how the world always was...we DID have a limited gov. in the US, but in the last decades have been convinced we need more "oversight" of our lives and hence, voted our personal power over to the 'greater good'. This is the DIRECT result of the massive empowerment of bureaucracies that we asked for - no, that we demanded.   
So, I hope we all enjoy it!

Net Neutrality is SURE to even the playing field and give us ALL equal access to the internet, remember!     Maybe one day we'll think before we blindly accept the pretty words of a paid professional liar politician.    The same thing is happening in literally dozens of areas of our lives, but not too many are actively aware of it.

Sorry, rant mode off now!  These things are close to me given that where I live, they're blowing the tops off of mountains and destroying watersheds and endangered birds in order to be green (and make bazillions of dollars)   >:(
Title: Re: Good to know - FCC regulations
Post by: R.G. on May 07, 2014, 08:51:55 AM
The initial reasoning behind the safety standards and FCC electromagnetic compatibility standards is solid - don't make and sell stuff that either harms people directly (safety) or messes with stuff they have (radios, etc.). The RFI standards are quoted with distance measurements in the case of radiated noise, in that there are graphs of maximum permitted radio emission intensity specified for the all frequencies from low RF up to high GHz, with antennae at specified distances.

The intent is GOOD - don't have somebody's (for instance) chorus pedal making your (for instance) cell phone go insane is a reasonable scenario. Or don't let someone's digital delay in the apartment above you keep every TV in the building from receiving.

Consistent, equal treatment of everyone under the law is good. If the laws are bad, the idea is that people will vote for representatives that will repeal them. Well, in theory anyway. If people voted.

Selective enforcement is the work of the devil; well, OK, the work of an incipient police state. What scares me is a situation where you get news reports like this:
QuoteEPA under fire for allegedly obstructing investigations
QuoteInternal memos reveal EPA secretly worked to kill Alaska mine project
QuoteThe Environmental Protection Agency may have intentionally delayed issuing a regulation limiting carbon dioxide emissions from new power plants so the rule would not be finalized until after the midterm elections
QuoteThe "John Doe" investigation into conservatives [in Wisconsin] is dead. At least for now... Judge Rudolph Randa on Tuesday granted a preliminary injunction to stop the politically charged probe
Those are from *today*. They don't even touch the IRS targeting program and the ongoing train wreck on Benghazi.
We have a situation where the USA government can decide how to selectively apply laws and regulations for whatever personal or political agenda they like and mostly get away with it. This is just the stuff that has become public. We don't know what else is hiding under there, but it's very unlikely that this is all the ugly things hiding under the rock.

Although any specific incident of selective or politically motivated enforcement is bad, the worse thing is that people are not stupid; they see that laws are not being applied fairly and the general respect for law is eroded. That is a disaster for a society. Laws and regulations ought to be universally and uniformly applied. Anything else just reduces the society to seeing how much they can get away with. And reduces bureaucrats to tinhorn dictators carving out their fiefdom.
Title: Re: Good to know - FCC regulations
Post by: Mark Hammer on May 07, 2014, 09:07:21 AM
Quote from: armdnrdy on May 06, 2014, 10:42:26 PM
Mark brought up a good point.

If this is all about interference of some sort, then shouldn't there be a FCC zone ordinance/warning label regarding the distance that a particular device can be operated around ???? whatever it might interfere with?

Instead of something that would make sense like a label....manufacturers have to dish out part of their profit to show that a device complies with the FCCs guidelines.

If a charge pump laden stompbox can interfere with the workings of sensitive medical devices...I think we're safe.
I am 51 years old and I can honestly say that I have never witnessed anyone playing an electric guitar through a pedal board in the emergency room of a hospital!
You reminded me of the scene in This Is Spinal Tap, where they're playing a gig on an air force base, and the control-tower communications starts coming through Nigel Tufnel's wireless receiver and out of his Marshall stack.
Title: Re: Good to know - FCC regulations
Post by: italianguy63 on May 07, 2014, 09:09:36 AM
R.G.  

Our government although well intentioned (I do believe that), has just gotten too big, and over-regulated to the point of trying to save us from ourselves.  Yeah, there are bad people doing bad things-- but that is true EVERYWHERE, it is not limited to the goverment of the USA.  I don't think it is an intentional sinister agency.

We have to go back towards smaller government, and UN-regulation.  But, in a world of entitlements, and government to be everything-for-everybody... we have created a society of sue-happy victims and a regulating body trying to manage it.

Our individual freedoms are daily being eroded, and I don't believe that what our Founding Fathers envisioned.  No longer are we "the home of the free."

I hope we can pull it back from going over the edge... I feel bad for my kids.  I think it may be too late.

MC
Title: Re: Good to know - FCC regulations
Post by: modsquad on May 07, 2014, 05:16:08 PM
Mark, I hope you meant unregulation and not UN regulation.  That sure wouldn't fix things... :icon_mrgreen:
Title: Re: Good to know - FCC regulations
Post by: italianguy63 on May 07, 2014, 05:19:26 PM
LOL - The "UN" 

I like money!

MC
Title: Re: Good to know - FCC regulations
Post by: GibsonGM on May 07, 2014, 05:39:04 PM
+1,000   

Guess we got a little bit "OT", huh?  Ha ha!
Title: Re: Good to know - FCC regulations
Post by: Mark Hammer on May 07, 2014, 07:15:54 PM
Listen, folks, Joe Gagan justifiably took me to task some time back for being inappropriately political.  So, I will suggest here that we all heed Joe's advice, and ixnay on the omment-cay.

My original point in raising the topic was not to instigate folks into railing about "big government" or whatever, but to broach the topic of how FCC regulations regarding digital technology had kinda sorta snuck up on us while we were thinking of ourselves as separate from all of that.  I imagine a lot of folks don't even bother with UL certification.  FCC clearance is yet one more wrinkle that people making the transition from dorm room hobby to business tend not to think about.  And if MIke Matthews neglected it, it can happen to any of us.

So, keep abreast of what your legal responsibilities are, and know your regulations.  End of story.
Title: Re: Good to know - FCC regulations
Post by: italianguy63 on May 07, 2014, 07:50:39 PM
Sorry,  I'm old and crotchity.  I get biatchy sometimes.  I apologize.

MC
Title: Re: Good to know - FCC regulations
Post by: Mark Hammer on May 07, 2014, 08:32:26 PM
Hey, I invented crotchety, buddy.   :icon_lol:  No apologies required.  We just need to stick to the topic.
Title: Re: Good to know - FCC regulations
Post by: PRR on May 07, 2014, 09:12:23 PM
It is implausible that Mike Matthews never heard of the FCC. He read Carl & Jerry (http://www.copperwood.com/carlandjerry.htm) along with the rest of us. Every boy with a CK722 lived in fear the FCC would knock at his door.

In fact you had to do something extraordinary to raise the FCC's attention.

Like make millions of little buzz-boxes.

The FCC has done valuable service in keeping the airwaves free of interference so they may be used for the good of society. In early years they shut-down spark-gap rigs and coordinated diathermy machines, two prolifically polluting technologies. In the 1930s when US broadcasters wanted to flood the world, the FCC sat with other nations and worked out a wiser plan.

Mike may have been in denial of his FCC responsibilities. And of course he does not personally manage every product, and his underlings may truly have been ignorant (the training plan suggests this was an issue). However some other pedal makers, especially the large Japanese companies, can be quite obsessive about regulatory compliance. As you can tell by the stickers. He (and his company) coulda, shoulda, got a clue a lot sooner.

Oh... 9KHz is the lower end of a radionavigation band. 3KHz is on the chart, but presently "unallocated". Chart (http://upload.wikimedia.org/wikipedia/commons/d/df/United_States_Frequency_Allocations_Chart_2011_-_The_Radio_Spectrum.pdf) Obviously you do not want an oil or ore freighter homing-in on your stompbox; the captain would be annoyed.

Yes, audio sibilants go well past 9KHz, and we put them on wires. I think the distinction is that we don't sibilate steady all the time. Also most audio has to be protected (shielded) against external interference, so is less likely to cause interference.
Title: Re: Good to know - FCC regulations
Post by: R.G. on May 07, 2014, 09:14:21 PM
Quote from: Mark Hammer on May 07, 2014, 07:15:54 PM
So, keep abreast of what your legal responsibilities are, and know your regulations.  End of story.
That's the problem Mark. You *can't* know your regulations.

Here's an excerpt from the Wall Street Journal's article "The Many Failed Efforts to Count Nation's Federal Criminal Laws"
QuoteIn 1998, the American Bar Association performed a computer search of the federal codes looking for the words "fine" and "imprison," as well as variations. The ABA study concluded the number of crimes was by then likely much higher than 3,000, but didn't give a specific estimate.

"We concluded that the hunt to say, 'Here is an exact number of federal crimes,' is likely to prove futile and inaccurate," says James Strazzella, who drafted the ABA report. The ABA felt "it was enough to picture the vast increase in federal crimes and identify certain important areas of overlap with state crimes," he said.

None of these studies broached the separate—and equally complex—question of crimes that stem from federal regulations, such as, for example, the rules written by a federal agency to enforce a given act of Congress. These rules can carry the force of federal criminal law. Estimates of the number of regulations range from 10,000 to 300,000. None of the legal groups who have studied the code have a firm number.

"There is no one in the United States over the age of 18 who cannot be indicted for some federal crime," said John Baker, a retired Louisiana State University law professor who has also tried counting the number of new federal crimes created in recent years. "That is not an exaggeration."
Note that (1) the attempt to count was by the American Bar Association, not some undergrad at a local junior college, (2) that's only US Federal law, and only the actual statutes, not the regulations that are enacted by the bureaus that have the force of criminal law and change without legislative action, and (3) that does not include state, county, and local laws and regulations that can put you in jail as well as taking your property.

In the limited area of safety standards and EMI regulations, no testing lab will issue a certificate saying "you pass all the regulations and legal requirements". I know, I've worked with them. The best you'll get is a statement saying "we tested this and we did not find any way it fails the requirements on this set of testing". Those are very different statements.
Title: Re: Good to know - FCC regulations
Post by: Mark Hammer on May 07, 2014, 09:44:53 PM
Quote from: PRR on May 07, 2014, 09:12:23 PM
Yes, audio sibilants go well past 9KHz, and we put them on wires. I think the distinction is that we don't sibilate steady all the time. Also most audio has to be protected (shielded) against external interference, so is less likely to cause interference.
Excellent points.  Shielding what's inside against what's outside also means that what's outside is shielded against what's inside.

But that's a matter of increased likelihood that the product will pass inspection with ease.  RG's point is that it is often hard to know in advance exactly what those requirements may be.
Title: Re: Good to know - FCC regulations
Post by: Ice-9 on May 08, 2014, 04:17:07 AM
So are mobile phone manufacturers exempt from these laws in some way, as I can't get through a day without phones interfering with my computer speakers, TV, guitar amps etc. If I want to record some tunes in my home studio I have to remember to leave the phone at some other location of my house or turn it off altogether. Is this phone polling sound a different issue than what the FCC rulings are addressing?
Title: Re: Good to know - FCC regulations
Post by: Gus on May 08, 2014, 06:57:42 AM
Quote from: R.G. on May 06, 2014, 06:50:51 PM


If you want to see a frenzy, wait for when - not if - someone gets electrocuted by a custom/boutique amplifier that wasn't built to safety standards.

Good post
Title: Re: Good to know - FCC regulations
Post by: CodeMonk on May 08, 2014, 06:58:27 AM
Quote from: Ice-9 on May 08, 2014, 04:17:07 AM
So are mobile phone manufacturers exempt from these laws in some way, as I can't get through a day without phones interfering with my computer speakers, TV, guitar amps etc. If I want to record some tunes in my home studio I have to remember to leave the phone at some other location of my house or turn it off altogether. Is this phone polling sound a different issue than what the FCC rulings are addressing?

Things like cell phones and, more in "our" realm, wireless mic and instrument systems have other hoops and regulations they have to jump through (I'm assuming).
Those items are designed to emit a signal through the air.
What I think the FCC is "concerned" with, are electronic devices that are not, by design, meant to emit a signal (RF or whatever), but may still do so, even if its unintentional.

From : http://www.effectsbay.com/2014/05/fcc-regulations-for-pedals/
QuoteWithin the scope of radio frequency devices is a sub-class known as Class B digital devices. The majority of digital musical instrument products fall into this category. A digital device is defined as "an unintentional radiator (device or system) that generates and uses timing signals or pulses at a rate in excess of 9,000 pulses (cycles) per second and uses digital techniques.
QuoteThere are two basic classifications of digital devices or RF radiators: products that are not meant to communicate wirelessly with other devices are known as Unintentional Radiators (for example most guitar pedals, synthesizers, amplifiers); products that do feature wireless communication are called Intentional Radiators (for example wireless mics, wireless guitar systems). Class B digital devices are considered Unintentional Radiators.
I found that page to be a very interesting read.

My main concern with this, is I have a project (commercial, but on indefinite hold due to finances) that makes use of a charge pump.
I've spent a sh*tload of time on this project and while I could make it work without a charge pump, It works better with one (and gives me more options) than without one.
I haz a BIG sad over this.
Title: Re: Good to know - FCC regulations
Post by: amz-fx on May 08, 2014, 07:37:40 AM
Here is a link to the New Sensor compliance document for those interested:

http://www.namm.org/sites/www.namm.org/files_public/New%20Sensor%20FCC%20Compliance%20Guide_v8_0.pdf

regards, Jack
Title: Re: Good to know - FCC regulations
Post by: quad on May 08, 2014, 08:09:36 AM
What about shielding? Doesn't that prevent a device from leaking out electromagnetic radiation?
Title: Re: Good to know - FCC regulations
Post by: R.G. on May 08, 2014, 08:19:29 AM
Quote from: quad on May 08, 2014, 08:09:36 AM
What about shielding? Doesn't that prevent a device from leaking out electromagnetic radiation?
Maybe. I have been directly responsible for working with a testing lab to certify EMI compatibility of a number of things. Shielding is designed into all commercial products ... check - most commercial products, as EH can testify - and it does odd things. Mostly shielding is fine for low frequencies and low powers. But it has to be continuous, no gaps or joints, which is impossible. It also sometimes happens that simply putting more RF power into a box with shielding forces the RF to flow out the wires coming into it.

It's worth noting before this gets to being a hysteria that low RF power being radiated is one of the certification criteria. If your box only creates minimal power, it may pass the criteria without any shielding at all. Or if the circuit board is laid out well for RF compatibility, it may not radiate effectively, so little RF power is emitted.

The big issue is testing and certification. You should not certify your stuff passes without testing, of course. And testing is expensive. As a practical matter, the home handicraft boutique pedal maker cannot afford testing, period. So the home builder is always going to have to rely on being under the radar - which is a ping of RF emission itself.  :icon_eek:
Title: Re: Good to know - FCC regulations
Post by: italianguy63 on May 08, 2014, 08:25:11 AM
Anybody have experience of what having a "widget" tested would cost?
Title: Re:
Post by: slacker on May 08, 2014, 08:28:48 AM
I think the link about EHX mentions about $1500 for a test a the certification,  that's assuming it passes first time of course.
Title: Re: Good to know - FCC regulations
Post by: wavley on May 08, 2014, 09:58:36 AM
Quote from: Mark Hammer on May 07, 2014, 09:44:53 PM
Quote from: PRR on May 07, 2014, 09:12:23 PM
Yes, audio sibilants go well past 9KHz, and we put them on wires. I think the distinction is that we don't sibilate steady all the time. Also most audio has to be protected (shielded) against external interference, so is less likely to cause interference.
Excellent points.  Shielding what's inside against what's outside also means that what's outside is shielded against what's inside.

But that's a matter of increased likelihood that the product will pass inspection with ease.  RG's point is that it is often hard to know in advance exactly what those requirements may be.

I was just being facetious when I mentioned sibilance, but also somewhat pointing out the absurdity of how things are potentially selectively regulated.  It used to be that the FCC would put the smack down on things (like my air conditioner) that are actually polluting the spectrum, but I'm hearing from HAMs more and more (I work with a lot of them) that the FCC is unresponsive to these things, they used to be able to report a source when they found it and you would get a visit from the FCC.  I actually live in the outskirts of the National Radio Quiet Zone because of the observatory and Sugar Grove, you would think that things like my air conditioner would not be tolerated, but no, we have our own RFI mitigation team that tracks down polluters and repairs them, I imagine Sugar Grove does too but I really have no interest in meeting anybody from there.

For me the silliness lies in the wording of these regulations and the sleeping giant waking up and regulating dirt boxes when there are thousands of ductless HVAC systems crapping up the airwaves all over the place.  I'll have to go check the audio files I recorded of my amps going "zing zing zing" but I'm pretty sure a good chunk of that noise was right around 9k. 
Title: Re: Good to know - FCC regulations
Post by: italianguy63 on May 08, 2014, 10:07:42 AM
I'm still a card carrying HAM (WD4CSA).

It was a good thing when FCC would check on spurious transmissions when un-tuned equipment and antennas would blow out TV reception for blocks around (before cable).  Or, hunting people with illegal 1KW transmitters, etc..

But a 9V buzz box.  Really?  Silly.  I think this will work itself out.  I don't think it has been really thought through yet.  Which is typical of the lumbering giant called government.

MC
Title: Re: Good to know - FCC regulations
Post by: karbomusic on May 08, 2014, 12:41:18 PM
QuoteBut a 9V buzz box.  Really?  Silly.  I think this will work itself out.

I think it will as well and I highly doubt most tiny/little guys need to freak out (odds wise) that the FCC is going to knock on your door if you occasionally build and possibly sell a pedal here and there. That isn't advice, it's just my opinion of those odds and the sensibility of it. However, here is where it always goes south..

You do just that, build pedals on request for a person here and there, no big deal and you are never even noticed.  However, you do it really, really well and 5 years later you have built some larger business (almost without realizing it) that distributes lots of pedals and now you are part of the industry and on the radar.

You got in the habit of not chasing down regulations as a small time hobbyist and before you know it you are in big trouble; by the time you showed up on the radar you had forgotten all about that regulation that was previously (odds wise) insignificant. Now it is significant and you are in trouble.

This happens everywhere, not just pedals and FCC. People start small and feel they don't really need to act like it is a business, they then become successful and miss stuff until it is too late. Business is the real deal, IOW you can really shoot yourself in the face if you take the route of "I'm creative and don't need to know business ". If one is going to do business, get some schooling on the business aspect or there is a risk of complete failure or worse. Owning a business is the one thing where something you didn't even realize can get you in large amounts of trouble.

Mark is right, study it and be aware now and in the future. I think there is no need to think the sky is falling, just be smart and aware about what you do.
Title: Re: Good to know - FCC regulations
Post by: armdnrdy on May 08, 2014, 01:00:53 PM
Quote from: karbomusic on May 08, 2014, 12:41:18 PM
I think there is no need to think the sky is falling,

I don't think you quite understand......
The sky IS falling!

(https://dl.dropboxusercontent.com/u/53299166/DIYstompboxes/Chicken%20Little.jpg)
Title: Re: Good to know - FCC regulations
Post by: karbomusic on May 08, 2014, 01:13:10 PM
Quote from: armdnrdy on May 08, 2014, 01:00:53 PM


I don't think you quite understand......
The sky IS falling!



That does it, I am now going to design and build a pedal called "Chicken Little".  :icon_mrgreen:
Title: Re: Good to know - FCC regulations
Post by: italianguy63 on May 08, 2014, 01:13:40 PM
I personally think you will see (crystal ball here), for example, TI will test their own product (i.e. charge pump IC) for a particular purpose (i.e. 12V voltage inversion), and show it is not a threat to pace-makers around the world.  They will make the testing papers available to end-users and the FCC since they are the ones that manufacture the component they want to sell, and have the pockets to have the testing done.  

I know.  It makes too much sense.

MC
Title: Re: Good to know - FCC regulations
Post by: armdnrdy on May 08, 2014, 01:24:57 PM
Quote from: karbomusic on May 08, 2014, 01:13:10 PM

That does it, I am now going to design and build a pedal called "Chicken Little".  :icon_mrgreen:

And stuff in all of the RF radiating components that the enclosure will handle whether they do something in the circuit or not.

Then...put a label on it DARING the FCC to come after you!  :icon_wink:
Title: Re: Good to know - FCC regulations
Post by: Jdansti on May 08, 2014, 04:48:26 PM
Does anyone know if the Burst Box is FCC compliant???   ;D

Seriously, any company planning to sell pedals needs to include in their business plan to consult an attorney who can explain all of the regulations, have their products tested, file the proper forms, and if necessary, provide the proper labeling.  Ca-Ching $$$

I agree that the gov't bureaucrats over reach and selectively enforce the laws (regardless of which party is in office), but any business person would be negligent by not playing by the rules, whether he agrees with them or not.
Title: Re: Good to know - FCC regulations
Post by: R.G. on May 08, 2014, 05:10:42 PM
The penalty for violating Class B limits was at one time up to $10,000.
Per day.
Per unit.
I don't know what it is now. Or how it's enforced. Or upon whom.

"Flying below the radar" is another version of "I know it's illegal, but I hope they do selective enforcement".

What was the line? Step out of line and the man come and take you away.
Title: Re: Good to know - FCC regulations
Post by: karbomusic on May 08, 2014, 05:35:10 PM
Quote from: Jdansti on May 08, 2014, 04:48:26 PM

Seriously, any company planning to sell pedals needs to include in their business plan to consult an attorney who can explain all of the regulations, have their products tested, file the proper forms, and if necessary, provide the proper labeling.  Ca-Ching $$$

Right, part of a business plan is to help you determine if the business can be profitable before diving in including the expense for regulations, statutes etc.. As long the regulations are applicable they need to be top of mind, properly evaluated and considered up front. If one is successful and purposely tries to fly under the radar, they eventually end up in the news.  :icon_wink:
Title: Re: Good to know - FCC regulations
Post by: GibsonGM on May 08, 2014, 06:05:06 PM
Quote from: karbomusic on May 08, 2014, 05:35:10 PM
Quote from: Jdansti on May 08, 2014, 04:48:26 PM

Seriously, any company planning to sell pedals needs to include in their business plan to consult an attorney who can explain all of the regulations, have their products tested, file the proper forms, and if necessary, provide the proper labeling.  Ca-Ching $$$

Right, part of a business plan is to help you determine if the business can be profitable before diving in including the expense for regulations, statutes etc.. As long the regulations are applicable they need to be top of mind, properly evaluated and considered up front. If one is successful and purposely tries to fly under the radar, they eventually end up in the news.  :icon_wink:

Yes, and now think of all the ones who COULD have been successful, but can't afford to 'play by the rules' (whose rules??  The big dogs with the power).   That's what over-regulation does - it ruins markets, stunts creativity, and puts a ball and chain on the market(s).  Eventually, nobody wants to play anymore.  OR - it's worth more to you to take the risk under the radar, creating MORE problems for people rather than less.

The cost of "compliance" is actually simply money that is taken out of the economy, since it does NOTHING, serves no useful purpose.  Just like the money paid to attorneys and accountants when you have an overly-complex and very punitive tax code.   It's simply waste.  Damn shame; I personally could have hired a couple of guys this year, but "the cost of compliance" just cost those two mystery workers decent jobs.  I had to pay to remain 'legal', and taking 2 workers on would have put my biz in jeopardy.      *shrug* 

Get used to it, you'll see much more of that going forward.   This is apolitical, BTW; it's about public policy, not "politics".

Title: Re: Good to know - FCC regulations
Post by: CodeMonk on May 08, 2014, 11:23:16 PM
I dunno if this has been posted (I'm sure a few here have found their way to this link already)...
http://www.ecfr.gov/cgi-bin/text-idx?SID=e496c9bf69a719781578cfa0373e06fd&tpl=/ecfrbrowse/Title47/47cfr15_main_02.tpl
More specifically for us:
http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=e496c9bf69a719781578cfa0373e06fd&n=47y1.0.1.1.16.2&r=SUBPART&ty=HTML
Title: Re: Good to know - FCC regulations
Post by: PRR on May 08, 2014, 11:32:40 PM
> things (like my air conditioner) that are actually polluting the spectrum

Quote§15.103   Exempted devices.

The following devices are subject only to the general conditions of operation in §§15.5 and 15.29 and are exempt from the specific technical standards and other requirements contained in this part. The operator of the exempted device shall be required to stop operating the device upon a finding by the Commission or its representative that the device is causing harmful interference.

(d) A digital device utilized exclusively in an appliance, e.g., microwave oven, dishwasher, clothes dryer, air conditioner (central or window), etc.

Build your digi-pedal into a clothes dryer.
Title: Re: Good to know - FCC regulations
Post by: Jdansti on May 09, 2014, 01:05:04 AM
^ Looks like the appliance manufacturers spent a little money up front on lobbyists to save a bunch later. ;)
Title: Re: Good to know - FCC regulations
Post by: TOPLEL on May 09, 2014, 01:41:04 AM
Could something like an ADA Flanger pass this test built into a shielded alu enclosure?

What about the modular synth guys? Their stuff is not shielded, will all of their modules fail these tests?
Title: Re: Good to know - FCC regulations
Post by: amz-fx on May 09, 2014, 07:39:50 AM
Quote from: TOPLEL on May 09, 2014, 01:41:04 AM
Could something like an ADA Flanger pass this test built into a shielded alu enclosure?

What about the modular synth guys? Their stuff is not shielded, will all of their modules fail these tests?

If the power is low and the pcb is properly designed, an enclosure may not even be needed to pass the emissions tests. For example, the Arduino Uno has been certified and it is an exposed pc board.

Most pedals are low power and you would expect the radiated emissions to be low, but this does not alleviate the need to test the product.

Also, for DIY guys: Part 15.23   Home-built devices. (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.

regards, Jack
Title: Re: Good to know - FCC regulations
Post by: R.G. on May 09, 2014, 07:46:55 AM
Sure puts a crimp in the guys who come here not knowing how to solder and then having a web site up to sell boutique pedals two weeks later, though.    :icon_eek:
Title: Re: Good to know - FCC regulations
Post by: Jdansti on May 09, 2014, 08:53:50 AM
It would be interesting to know if any of the dozen boutiquers on the forum are testing and using labeling. Those who aren't would probably be better off not saying anything.
Title: Re: Good to know - FCC regulations
Post by: Govmnt_Lacky on May 09, 2014, 09:01:00 AM
Quote from: R.G. on May 09, 2014, 07:46:55 AM
Sure puts a crimp in the guys who come here not knowing how to solder and then having a web site up to sell boutique pedals two weeks later, though.    :icon_eek:

You mean these guys:

(http://i.huffpost.com/gadgets/slideshows/283349/slide_283349_2159015_free.gif?1361935931794)

::)  :icon_lol:
Title: Re: Good to know - FCC regulations
Post by: midwayfair on May 09, 2014, 10:19:05 AM
Quote from: Jdansti on May 09, 2014, 01:05:04 AM
^ Looks like the appliance manufacturers spent a little money up front on lobbyists to save a bunch later. ;)

It's because you can't hook up those devices just anywhere. Most driers need a gas line, and washers need a water line. Houses are already set up to have them in a specific place.

>Part 15.23   Home-built devices. (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.

Does this mean that KITS (like from BYOC) are potentially a problem -- i.e., you sell a kit, someone builds the kit, do the people selling the kit need to get certification? I sure hope not. :( It's not an emitter when it's sold.

Oh, quoting TH Custom here (from the Madbean thread) for the EU guys. Not legal advice, etc., but I wonder whether there's a similar workaround under the U.S. guidelines:
Quote
I only know the european rules with RF testing. You need to do this to get the CE-sign. No sign, not able to sell a single device.

The procedures to test things are very complex but the is a lot of writing about 'similar devices' that dont need testing.

Where they get you is if you dont write about possible interferences in your manual.
If you state that your device should not come near audio amplification because it might impact it and if you say that cell phones should be kept away from your device you are fine.

I know this is crazy to tell people that they should not put their new effect pedal near an amplifier, but the point is that if you tell the buyer you have met the guidelines!
Title: Re: Good to know - FCC regulations
Post by: TOPLEL on May 09, 2014, 12:34:10 PM
Quote from: amz-fx on May 09, 2014, 07:39:50 AM
Quote from: TOPLEL on May 09, 2014, 01:41:04 AM
Could something like an ADA Flanger pass this test built into a shielded alu enclosure?

What about the modular synth guys? Their stuff is not shielded, will all of their modules fail these tests?

If the power is low and the pcb is properly designed, an enclosure may not even be needed to pass the emissions tests. For example, the Arduino Uno has been certified and it is an exposed pc board.

Most pedals are low power and you would expect the radiated emissions to be low, but this does not alleviate the need to test the product.

Also, for DIY guys: Part 15.23   Home-built devices. (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.

regards, Jack


And what will happen with something like a one man modular synth business? For example where the guy sells 10-15 different modules where most of them have some digital clocking here and there. Is he forced to spend 10-15x1000 dollars to get them measured and stuff? I hope my favourite guys won't vanish from the net because of this. Or this won't be enforced that seriously?
Title: Re: Good to know - FCC regulations
Post by: slacker on May 09, 2014, 12:39:21 PM
This mentions kits https://www.sparkfun.com/tutorials/398 (https://www.sparkfun.com/tutorials/398) seems clear as mud.
Title: Re: Good to know - FCC regulations
Post by: Mark Hammer on May 09, 2014, 12:43:53 PM
Well, it's not like these regs came into effect this week.  The articles I linked to concerned a fine that EHX paid much earlier last year, and related to infractions from previous years.  EHX is a big company with lots of products and customers, and extensive worldwide distribution: i.e., a big target, low-hanging fruit, or whatever metaphor you want to use.  I think the little guys are pretty safe for now.  Even if they aren't, one little guy in a herd of 1,000,000 stampeding wildebeest has a pretty good chance of not being the one the cheetah takes down.

BTW, that Sparkfun writeup is pretty decent.  Thanks.
Title: Re: Good to know - FCC regulations
Post by: slacker on May 09, 2014, 12:53:50 PM
I was going to say the same Mark, 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.
Title: Re: Good to know - FCC regulations
Post by: davent on May 09, 2014, 01:02:01 PM
Quote from: slacker on May 09, 2014, 12:53:50 PM
I was going to say the same Mark, 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.

My Yamaha REX 50, bought in 1987-88 has the FCC compliance sticker on the back as well as more info in the manual.
Title: Re: Good to know - FCC regulations
Post by: Mark Hammer on May 09, 2014, 03:12:16 PM
I don't know that the discussion is entirely over, but I did want to say that it has been most instructive.  I didn't dream when I started the thread that it would generate such interest and "digging down" by members who were variously familiar with the technology, and with the law and/or regs.

It's been fascinating.  And with any luck and foresight, none of us here will be paying a $450,000 fine!  :icon_lol:

Thanks, one and all. You've done a service to your colleagues.
Title: Re: Good to know - FCC regulations
Post by: Digital Larry on May 09, 2014, 03:22:27 PM
Quote from: midwayfair on May 09, 2014, 10:19:05 AM
Quote from: Jdansti on May 09, 2014, 01:05:04 AM
^ Looks like the appliance manufacturers spent a little money up front on lobbyists to save a bunch later. ;)

It's because you can't hook up those devices just anywhere. Most driers need a gas line, and washers need a water line. Houses are already set up to have them in a specific place.


I wouldn't be so sure about that...  washers on stage (http://3.bp.blogspot.com/_NuMV_kr05_8/RnGJMQt2LoI/AAAAAAAAABU/eMvza1b3I8o/s320/GeddyLeeWasherDryerHighlight.bmp)
Title: Re: Good to know - FCC regulations
Post by: wavley on May 09, 2014, 03:31:30 PM
Quote from: Digital Larry on May 09, 2014, 03:22:27 PM
Quote from: midwayfair on May 09, 2014, 10:19:05 AM
Quote from: Jdansti on May 09, 2014, 01:05:04 AM
^ Looks like the appliance manufacturers spent a little money up front on lobbyists to save a bunch later. ;)

It's because you can't hook up those devices just anywhere. Most driers need a gas line, and washers need a water line. Houses are already set up to have them in a specific place.


I wouldn't be so sure about that...  washers on stage (http://3.bp.blogspot.com/_NuMV_kr05_8/RnGJMQt2LoI/AAAAAAAAABU/eMvza1b3I8o/s320/GeddyLeeWasherDryerHighlight.bmp)

I forgot about the Geddy Lee thing!!

I don't see what not being hooked up just anywhere, while I see your reasoning and it's probably what they used, has anything to do with being exempt.  Last time I checked a Faraday cage isn't usually a feature built into a laundry room, so it's selective enforcement of the rules by excluding some of the biggest radiators.  When I was having my problem a HAM I worked with said "It's probably your air conditioner, I pick them up all the time" and let me borrow some equipment to track it down.
Title: Re: Good to know - FCC regulations
Post by: Unlikekurt on May 09, 2014, 03:45:19 PM
Is anyone aware of how this impacts the sale of a dc switching wallwart with a pedal?
At that point you are a reseller.  Is this covered in some manner such as how MSDS or IMDS is handled?  By having the certification of your vendor you are then good to go.  Or would that not be sufficient, in which case you'd be better suited to not include the powering device with your units?

Title: Re: Good to know - FCC regulations
Post by: pickdropper on May 09, 2014, 04:01:43 PM
This is the third thread  on three forums that I read dealing with this.  Hopefully, I can keep it all straight.

For anybody that enjoys a good read, here is a link to the previous ANSI standard that covers this.  The current version is the 2009 standard, but I couldn't find a link to it and I didn't feel like paying nearly $150 for it.

http://ecee.colorado.edu/~ecen4517/materials/refs/standards/ANSI_C63.4-2003.pdf

This is a copy of the post I put on TGP:

--------------------------------------------------------------------

Anything can generate noise, the FCC only appears to care if it is above 9kHz. The rules aren't new; they've been around for decades. According to a friend of mine, they really began leaning on this in the the 80's when a lot of complaints rolled into the FCC about interference with television reception (apparently from personal computers and video game systems). There's a WIKI article that doesn't dig too deep, but it's a starting point:

http://en.wikipedia.org/wiki/Home_co...y_interference

The rules have been there for a long time, it just hasn't trickled down to most of the small fish yet. Will it cause any issues if they don't comply? That's hard to say. Could it cause them to get fined? Certainly.

As far as the FCC knocking down your door and asking you to surrender your pedal/mixing board/etc, that is HIGHLY unlikely. If you had an unlicensed radio station and a cluster of klystron tubes, they'd be more interested. But for a 9kHz offender? Not likely unless your device is causing serious problems to somebody else and they complain to the FCC.

------------------------------------------------

And this is what I posted on Madbeans:

-------------------------------------------------

Here's a bit more info that I've found:

http://www.bureauveritas.com/wps/wcm/connect/31b53f004edb713e8d5fcd600bbc220b/FCC_Frequently_Asked_Questions_Aug10.pdf?MOD=AJPERES

For those who CBA to read the link, here are a couple of salient points:

"Battery power is not an exemption. Even a cell ph
one can broadcast for miles. Toys are not exempt
either. Toys can make more radio noise than other equipment because plastic or plush enclosures
do not shield the electronics like a metal box may.
Manufacturing run is not exempt either. Even if
you make and sell only a handful of devices,
it needs FCC equipment authorization. "

It also breaks down what types of testing are needed.  For a 9kHz device like a pedal, it is an unintentional radiator and only needs verification testing (basically, it needs to be checked to ensure that it passes emissions standards).  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.  Unintentional radiator does seem to have the least stringent requirements.  Compare that to something like a Bluetooth device, where you have to do all of the testing, get certified and register with the FCC.

"The FCC has four main categories of equipment authorization:

Verification (unintentional radiators)

Declaration of Conformity (unintentional radiators that connect with PC's or television systems)

Certification (intentional radiators, radar detectors)

Registration (telephones & telecommunication devices)
Different authorization is needed for different types of equipment. Technical expertise is needed to
evaluate the design to ensure correct authorization. "

I'm still trying to figure out what the overall bottom line is to this.  I'm hoping I can find something that is reasonable as far as cost but qualifies from a regulatory perspective.

----------------------------------------

Basically, pedals would fall into the category of "unintentional radiator" unless they have bluetooth or some other wireless design built into them.  FCC testing for anything that radiates emissions at frequencies 9kHz or above has been in place for a long time, it's just bubbling to the surface now.  Everybody is bound by its rules, but not everybody who ignores the rules will run into issues, much like it is now.  The cost of being wrong is potentially high, however.


__________________
Title: Re: Good to know - FCC regulations
Post by: armdnrdy on May 09, 2014, 04:19:36 PM
Quote from: pickdropper on May 09, 2014, 04:01:43 PM
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.  :icon_wink:

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.
Title: Re: Good to know - FCC regulations
Post by: pickdropper on May 09, 2014, 04:27:06 PM
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.
Title: Re: Good to know - FCC regulations
Post by: armdnrdy on May 09, 2014, 05:04:02 PM
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.
Title: Re: Good to know - FCC regulations
Post by: armdnrdy on May 09, 2014, 05:57:51 PM
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.
Title: Re: Good to know - FCC regulations
Post by: Jdansti on May 09, 2014, 06:14:52 PM
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.
Title: Re: Good to know - FCC regulations
Post by: armdnrdy on May 09, 2014, 06:26:57 PM
Quote from: Jdansti on May 09, 2014, 06:14:52 PM
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.
Title: Re: Good to know - FCC regulations
Post by: pickdropper on May 09, 2014, 07:01:50 PM
Quote from: Jdansti on May 09, 2014, 06:14:52 PM
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.
Title: Re: Good to know - FCC regulations
Post by: Jdansti on May 09, 2014, 07:06:45 PM
Right. It might not make sense to self certify due to the expense of the equipment and the conflict of interest issue.
Title: Re: Good to know - FCC regulations
Post by: Tony Forestiere on May 09, 2014, 09:29:55 PM
Just don't do this: https://www.youtube.com/watch?v=WWlpJ3k_Ik0
Title: Re: Good to know - FCC regulations
Post by: PRR on May 09, 2014, 10:25:47 PM
> 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.
Title: Re: Good to know - FCC regulations
Post by: amz-fx on May 10, 2014, 08:36:00 AM
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
Title: Re: Good to know - FCC regulations
Post by: SeanCostello on May 11, 2014, 05:23:03 PM
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
Title: Re: Good to know - FCC regulations
Post by: armdnrdy on May 11, 2014, 05:42:46 PM
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.
Title: Re: Good to know - FCC regulations
Post by: R.G. on May 11, 2014, 10:32:36 PM
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.
Title: Re: Good to know - FCC regulations
Post by: seedlings on May 12, 2014, 11:19:38 AM
Does this court case address sales on the used market of untested EH gear?

CHAD
Title: Re: Good to know - FCC regulations
Post by: PRR on May 12, 2014, 10:33:59 PM
> 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).
Title: Re: Good to know - FCC regulations
Post by: amptramp on May 13, 2014, 09:46:33 AM
Quote from: armdnrdy on May 09, 2014, 06:26:57 PM
Quote from: Jdansti on May 09, 2014, 06:14:52 PM
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.
Title: Re: Good to know - FCC regulations
Post by: wavley on May 13, 2014, 10:23:11 AM
Quote from: amptramp on May 13, 2014, 09:46:33 AM
Quote from: armdnrdy on May 09, 2014, 06:26:57 PM
Quote from: Jdansti on May 09, 2014, 06:14:52 PM
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.
Title: Re: Good to know - FCC regulations
Post by: italianguy63 on May 13, 2014, 10:27:12 AM
Speaking of soldering with no ventilation.  Has anybody seen Jimi lately?  He has been quiet.  MC
Title: Re: Good to know - FCC regulations
Post by: Seljer on May 13, 2014, 10:30:13 AM
Quote from: amptramp on May 13, 2014, 09:46:33 AM
Quote from: armdnrdy on May 09, 2014, 06:26:57 PM
Quote from: Jdansti on May 09, 2014, 06:14:52 PM
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)  :D
Title: Re: Good to know - FCC regulations
Post by: wavley on May 13, 2014, 10:50:09 AM
Quote from: italianguy63 on May 13, 2014, 10:27:12 AM
Speaking of soldering with no ventilation.  Has anybody seen Jimi lately?  He has been quiet.  MC

I saw him post some stuff this morning, I was starting to worry!

I need to add about my little rant that it was not FCC stuff that they were self certifying, it was FAA.
Title: Re: Good to know - FCC regulations
Post by: italianguy63 on May 13, 2014, 10:53:23 AM
QuoteI need to add about my little rant that it was not FCC stuff that they were self certifying, it was FAA.

I wonder which governing body certifies Burst Boxes?  I expect the radiation from them is extremely dangerous.
Title: Re: Good to know - FCC regulations
Post by: duck_arse on May 13, 2014, 11:02:32 AM
Quote from: italianguy63 on May 13, 2014, 10:53:23 AM
QuoteI need to add about my little rant that it was not FCC stuff that they were self certifying, it was FAA.

I wonder which governing body certifies Burst Boxes?  I expect the radiation from them is extremely dangerous.

that would have to be IAEA. I saw one powered by plutonium.
Title: Re: Good to know - FCC regulations
Post by: Govmnt_Lacky on May 13, 2014, 11:18:32 AM
Has anyone seen compliance stickers on those funky gold or silver boxes with the weird horse-dude on them? Or, their red-colored offspring?  ::)  :icon_lol:
Title: Re: Good to know - FCC regulations
Post by: italianguy63 on May 13, 2014, 11:22:19 AM
For what they cost.. they should be able to afford the sticker.
Title: Re:
Post by: slacker on May 13, 2014, 11:23:58 AM
The mojo in those pedals neutralises any harmful emissions.  Their offspring that Mad Mike now sells do indeed come with cute little FCC stickers.
Title: Re: Good to know - FCC regulations
Post by: wavley on May 13, 2014, 11:46:14 AM
Quote from: duck_arse on May 13, 2014, 11:02:32 AM
Quote from: italianguy63 on May 13, 2014, 10:53:23 AM
QuoteI need to add about my little rant that it was not FCC stuff that they were self certifying, it was FAA.

I wonder which governing body certifies Burst Boxes?  I expect the radiation from them is extremely dangerous.

that would have to be IAEA. I saw one powered by plutonium.

I think that there is no one governing body that can certify all that is inside a circuit box with a burst button switch, it's going to look like a race car with all of those little stickers.

Do you think I need to get this box certified by the FAA?

(http://fbcdn-sphotos-b-a.akamaihd.net/hphotos-ak-ash3/t1.0-9/p417x417/167078_1777962844949_4524985_n.jpg)
Title: Re: Good to know - FCC regulations
Post by: italianguy63 on May 13, 2014, 12:39:57 PM
WTF?

QuoteI saw one powered by plutonium.

It sure isn't powered by that.

I think you should donate it to the Boy Scouts, Peter Pan, or the YMCA.  Maybe George Michael is still making music someplace.... 
Title: Re: Good to know - FCC regulations
Post by: Digital Larry on May 13, 2014, 12:55:09 PM
Quote from: Govmnt_Lacky on May 13, 2014, 11:18:32 AM
Has anyone seen compliance stickers on those funky gold or silver boxes with the weird horse-dude on them? Or, their red-colored offspring?  ::)  :icon_lol:

Those are all analog, eh?  So most likely no reason for FCC stickering.  However, maybe the EIEIO monitors pedals with farm animals on them.
Title: Re: Good to know - FCC regulations
Post by: italianguy63 on May 13, 2014, 01:14:31 PM
KLOWNs have a charge pump.  naughty naughty.
Title: Re: Good to know - FCC regulations
Post by: duck_arse on May 14, 2014, 09:41:31 AM
but .... this.

http://www.diystompboxes.com/smfforum/index.php?topic=76932.msg965144#msg965144

right there on the label. and ....

Quote from: vigilante397 on March 23, 2014, 04:36:47 PM
Quote from: Jdansti on March 23, 2014, 03:48:03 PM
Do you have to shove garbage in it to make it work?  ;)

Still working on that mod. This is the older version that still runs on plutonium :P
Title: Re: Good to know - FCC regulations
Post by: samhay on May 14, 2014, 09:51:49 AM
^but .... this.
I wonder if it is finally time for a new kind of burst box - one that spits out a huge (FCC (un)approved) RF pulse whenever you stomp on it?
Title: Re: Good to know - FCC regulations
Post by: italianguy63 on May 14, 2014, 10:03:18 AM
Quoteone that spits out a huge (FCC (un)approved) RF pulse

I think that is called an Old School pinball machine... I bet they make all kinds of RF racket.  Unshielded relays and solinoids and such... humbug.
Title: Re: Good to know - FCC regulations
Post by: kaycee on May 16, 2014, 04:56:19 PM
I seriously doubt that it is actually legal to sell any DIY pedal on the open market, in the UK at least.

The ROHS (restriction of hazardous materials) regs mean that any NOS parts are ruled out because they haven't ever been tested, and their manufacturing process can't be verified now. ROHS is meant to address the amount of environmentally harmful materials in an electronic device, so that when it goes to landfill or for recycling for disposal its not as toxic as it could be. Mainstream suppliers have to be able to verify that the components they have sourced comply with these regs. Mr. Chang's Hong Kong ebay emporium does not, so if you or your supplier gets their stock from him, your probably not complying, certainly can't prove that you are.

Next, if you think that you can just make and sell something that plugs (indirectly via a power source admittedly) into the mains without regard to the legal directives, specifications and testing of the relevant departments, you probably haven't heard of trading standards. If your pedal has a short, or causes a short and bursts into flame, gradually heats up and melts a carpet etc, etc once again, hot water. And if you think restricting to just battery usage is the answer, try shorting one and holding onto it for a while!

Possibly the DIY pedal selling universe is being more than a bit cavalier with the relevant laws and regs pertaining to the sale of electronic devices and mostly getting away with it because of the law of averages that disasters don't happen that often to draw attention to it.

 
Title: Re: Good to know - FCC regulations
Post by: Lurco on July 25, 2014, 03:12:41 AM
You never walk alone:
http://www.commlawblog.com/2014/04/articles/unlicensed-operations-and-emer/another-big-audio-manufacturer-makes-another-big-settlement/
http://www.commlawblog.com/2013/12/articles/unlicensed-operations-and-emer/fine-print-not-fine-enough-another-audio-company-settles-with-the-fcc/
http://www.commlawblog.com/2012/08/articles/enforcement-activities-fines-f/fcc-consent-decree-puts-whammy-on-fender/
http://www.commlawblog.com/2012/03/articles/enforcement-activities-fines-f/audio-manufacturer-pays-72k-to-settle-with-fcc/
http://www.commlawblog.com/2011/05/articles/enforcement-activities-fines-f/fcc-settles-for-big-bucks-over-audio-gear-wait-audio/
http://www.commlawblog.com/2007/06/articles/enforcement-activities-fines-f/1-million-equipment-fine-confirmed/
Title: Re: Good to know - FCC regulations
Post by: armdnrdy on July 25, 2014, 03:41:37 AM
It looks like the FCC has found a new "honey hole"!

Very sad that these companies are preyed upon by such sharks!
Title: Re: Good to know - FCC regulations
Post by: R.G. on July 25, 2014, 09:19:09 AM
In feudal-system Europe, and probably other places, the king's tax collector wandered the countryside with his gang of armed "protection" officers, and collected taxes. He collected all he could, and then kept whatever was over what the king demanded.

In the private enterprise system there are things that are "profit centers", aka "cash cows", but at least there are competitors. Governments quickly notice that they have no competitors to underprice them.

Has anyone else noticed the rise of independent "regulatory agencies" showing up with SWAT-team armed enforcement agents? The EPA just pulled this scenario. It's becoming the norm for agencies to show up not with the local police for enforcement, but their own military-armed agents.

Does this bother anyone else? Or am I just getting spooky in my old age?
Title: Re: Good to know - FCC regulations
Post by: Ice-9 on July 25, 2014, 09:31:21 AM
I'm just glad I won't be around in a few hundred years' time when the whole planet is ruled under a totalitarian system and no one is able to do anything remotely independent of what we are told to do. Oh and of course the backdrop has to be dark and sinister.  :icon_wink:
Title: Re: Good to know - FCC regulations
Post by: amptramp on July 25, 2014, 07:51:45 PM
Quote from: Ice-9 on July 25, 2014, 09:31:21 AM
I'm just glad I won't be around in a few hundred years' time when the whole planet is ruled under a totalitarian system and no one is able to do anything remotely independent of what we are told to do. Oh and of course the backdrop has to be dark and sinister.  :icon_wink:

You will be due for reincarnation by then.
Title: Re: Good to know - FCC regulations
Post by: aron on July 25, 2014, 08:02:02 PM
OK that was funny in a weird sort of way.