I don't think so. The manufacturers claim (rightly) that the FCC exempts
them from certification and verification and in fact this means there are
no FCC requirements they must meet before sale . They can thereafter
disclaim responsibility because it is the *owners' and operators'* duty to
turn off the interfering equipment. THEY don't even have to act unless
informed >by the Commission< that it is interfering.
However... even if I mistook omission for permission, it would indeed take
a Rulemaking -- a contentious one -- to fix things. (Or the Courts.) Only
the FCC regulates interference, and Congress has been relucant to see it
enforce existing Rules, let alone make them more stringent.
> [Original Message]
> From: Paul Christensen <email@example.com>
> To: <RFI@contesting.com>
> Date: 4/10/2010 9:56:50 PM
> Subject: Re: [RFI] Appliance interference and approvals (was Sears
batterycharger model #200.71222)
> > "There are no FCC *emission requirements* for equipment used in
> > appliances."
> You're confusing emissions with the certification requirement. Under
> 15.103(d), appliances are exempt from the certification requirement.
> Appliances are not exempt from the generation of harmful emissions as an
> unintentional radiator. Generally, if an appliance is causing harmful
> interference to the user of a licensed service, the fact that the
> manufacturer was not compelled to certify the appliance in no way grants
> special dispensation to the device's owner if that device produces
> interference. When put on notice, the owner of the device must still
> protect a licensed service and cease device operations until the
> interference is cured.
> I have been advocating a change to this rule for the past several years.
> Frankly, the time is ripe for a Petition for Rulemaking. I'm just not
> if the ARRL wants to take that on at the moment and the petition really
> needs a strong sponsor like the League for what it will definitely face.
> There will be significant opposition from appliance manufacturers and
> manufacturers of appliance sub-components like those that manufacture
> direct-drive, variable-speed motors and switch-mode power supplies. An
> oddity of the current rules implies, for example, that a SMPS that may
> require Part 15(B - residential) certification as a stand-alone device
> is protected from the certification requirement when it's embedded into
> What clearly does not make sense is the continuation down the current
> where the FCC's enforcement branch must become engaged in conflict
> resolution between a licensee and the owner of the
> appliance. With certification of appliances that contain any switch-mode
> technology or microprocessors, the FCC's enforcement job potentially gets
> whole lot easier and that, among other key points, would become pivotal
> Petition for Rulemaking.
> Paul, W9AC
> RFI mailing list
RFI mailing list