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

[Paul Christensen]

> "There are no FCC *emission requirements* for equipment used in 
> appliances."

You're confusing emissions with the certification requirement.  Under Part 
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 harmful 
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 sure 
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 but 
is protected from the certification requirement when it's embedded into an 
appliance.

What clearly does not make sense is the continuation down the current road 
where the FCC's enforcement branch must become engaged in conflict 
resolution between a licensee and the owner of the interference-generating 
appliance.  With certification of appliances that contain any switch-mode 
technology or microprocessors, the FCC's enforcement job potentially gets a 
whole lot easier and that, among other key points, would become pivotal in a 
Petition for Rulemaking.

Paul, W9AC