[RFI] Appliance interference and approvals (was Sears battery charger model #200.71222)

Christopher E. Brown cbrown at woods.net
Sat Apr 10 18:12:38 PDT 2010

This I think is the big issue.  Even 30 years ago what did these devices 
have, a few switches, maybe a motor or some heating elements.

Ok, some switch and brush arcing.

Now they all have an onboard computer, switch mode supply and if it has a 
motor a VFD....

Personal opinion, we need the ARRL and many thousands of hams pushing the 
FCC to

1) Remove the appliance exemption.  It was valid at the time, but this 
time is long past.

2) Rewrite the emmisions limits in part 15.  Starting with the CE 
standards might be a good idea, lower limits and the testing starts at a 
lower freq.

3) Update the testing spec to better simulate real world installations.

We know this is viable, after all there is no shortage of consumer devices 
available in markets with much stricter limits than the US.

On Sat, 10 Apr 2010, Cortland Richmond wrote:

> There are no FCC *emission requirements* for equipment used in appliances.
> Section 15.103 Exempted devices.
> The following devices are subject only to the general conditions of
> operation in Sections 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. Operation shall not
> resume until the condition causing the harmful interference has been
> corrected. Although not mandatory,
> it is strongly recommended that the manufacturer of an exempted device
> endeavor to have the device
> meet the specific technical standards in this Part.
> (a) A digital device utilized exclusively in any transportation vehicle
> including motor vehicles
> and aircraft.
> (b) A digital device used exclusively as an electronic control or power
> system utilized by a
> public utility or in an industrial plant. The term public utility includes
> equipment only to the extent that it
> is in a dedicated building or large room owned or leased by the utility and
> does not extend to equipment
> installed in a subscriber's facility.
> (c) A digital device used exclusively as industrial, commercial, or medical
> test equipment.
> (d) A digital device utilized exclusively in an appliance, e.g., microwave
> oven, dishwasher,
> clothes dryer, air conditioner (central or window), etc.
> ...
> (i) Responsible parties should note that equipment containing more than one
> device is not
> exempt from the technical standards in this Part unless all of the devices
> in the equipment meet the
> criteria for exemption. If only one of the included devices qualifies for
> exemption, the remainder of the
> equipment must comply with any applicable regulations. If a device performs
> more than one function and
> all of those functions do not meet the criteria for exemption, the device
> does not qualify for inclusion
> under the exemptions.
> Just noticed Dep't: The thermostats may not be exempt as they are not IN an
> appliance. Dunno if anyone has tried this approach.
> Anyway, they ALL have to abide by 15.5:
> ...
> (b) Operation of an intentional, unintentional, or incidental radiator is
> subject to the conditions
> that no harmful interference is caused and that interference must be
> accepted that may be caused by the
> operation of an authorized radio station, by another intentional or
> unintentional radiator, by industrial,
> scientific and medical (ISM) equipment, or by an incidental radiator.
> (c) The operator of a radio frequency device shall be required to cease
> operating the device upon
> notification by a Commission representative that the device is causing
> harmful interference. Operation
> shall not resume until the condition causing the harmful interference has
> been corrected.
> And 15.29:
> (b) The owner or operator of a radio frequency device subject to this Part
> shall promptly furnish
> to the Commission or its representative such information as may be
> requested concerning the operation of
> the radio frequency device.
> Since these interfere with AM broadcast reception, perhaps complaining to
> the STATIONS might get FCC action where our gripes might not.
> Cortland
> KA5S
>> [Original Message]
>> From: myles landstein <myles.landstein at gmail.com>
>> To: Jim Brown <jim at audiosystemsgroup.com>
>> Cc: RFI at contesting.com <RFI at contesting.com>
>> Date: 4/10/2010 4:08:27 AM
>> Subject: Re: [RFI] Sears battery charger model #200.71222
>> You added  a good  point.
>> The  issue  from  variable speed motor controls   is  pretty  serious.
>> I live in an apartment that   upgraded     the elevator system   about
> 2yrs ago.
>> Prior  my noise level was s0 or s1
>> Noise level now  is   s9   all bands! for a  30ft  radius /min
>> Discovered  the noise source is a  Maganek600 motor controller.  Manuf.
> told me,  they don't  need  FCC approvals  because it has  a Canadian rating
>> They also told me they never had  any previous complaints  (right)
>> You all make a good  point,  stuff like this should  never  be allowed
>> 73,
>> N2EHG
>> Myles
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