[RFI] ARRL Again Complains to FCC about Illegal Marketing of Electronic Lighting Ballasts

Ed-K0iL eddieedwards at centurylink.net
Sun Jan 3 01:46:03 EST 2016

After reading the ARRL's actions with Lowe's and Wal-Mart, thought I'd share
some experience and info on electronic ballast at Home Depot.  

While replacing a dead ballast recently, I discovered that The Home Depot
personnel have no idea which ballasts are meant for residential and which
are for commercial/office.  Nothing in the display area indicates if they're
for residential or commercial use, and the three Home Depots employees I
asked could not tell me either.

I found the T8 replacement GE PRO-LINE ballasts they sell states it meets
Part 18 but it's only on the body of the ballasts in the smallest print they
could use.  I believe based on their wording, after I found a magnifier
lense and my glasses, the more expensive units are NOT for consumer use
(Part 18 Class A) and states "Commercial Grade" on the red lettering box of
4 (model GE232MV-N-DIY or GE432MV-N-DIY).  Nearly everything I found on Home
Depot's web pages are this type.

The less expensive GE ballasts (GE232HO-N-DIY & GE296HO-N-DIY, the "HO" may
be for HOME?) mentions Part 18 and states for consumer use (has Gold
PRO-Line lettering not red).  

Price & print color is perhaps the only way the average person can tell the
difference.  So hope all your DIY neighbors are cheap and only buy the lower
costs ballasts.  Commercial electricians however may think they're doing
your neighbor a favor installing the "better" and more expensive ballast
since he probably gets a commercial rate discount for quantity purchases.  

I also found the complete 4 ft 2-light fixtures made by Lithonia with the
ballast made by Accupro (Model No. AP-RC-232IP-102-1) states it complies
with 47 CFR Part 18 "consumer limits".  
On their spec sheets I found online 
[ http://www.lithonia.com/specsheets.aspx?cid=67054 ]
%20ballast.pdf ] 
it states: "Ballast shall comply with the limits of FCC Part 18C Class B
(residential) and Class A".  I've had these installed for years with no
noticeable RFI even with my roof mount antenna only about 15-20 ft away from

73, de ed -K0iL

-----Original Message-----
From: ARRL Web site [mailto:memberlist at www.arrl.org] 
Sent: Tuesday, December 29, 2015 5:27 PM

ARLB038 ARRL Again Complains to FCC about Illegal Marketing of Electronic
Lighting Ballasts

ARRL Bulletin 38  ARLB038
>From ARRL Headquarters
Newington CT  December 29, 2015
To all radio amateurs 

ARLB038 ARRL Again Complains to FCC about Illegal Marketing of Electronic
Lighting Ballasts

The ARRL has again complained to the FCC to allege illegal marketing of
electronic RF lighting ballasts, operating under Part 18 of the Commission's
rules, on the part of two major retailers. Letters went out this week to the
FCC Enforcement Bureau and its Office of Engineering and Technology claiming
Part 18 marketing regulations violations by Lowe's and by Walmart stores. At
issue is the sale of non-consumer RF lighting ballasts to consumers who, in
several instances, were told by store personnel that it was okay to install
these in a residential setting. In addition, non-consumer and
residential-class ballasts are intermixed in store displays with inadequate
signage to direct consumers to the correct choice. Both letters asked the
FCC to investigate and commence enforcement proceedings with respect to the
two stores' marketing and retail sale of RF lighting devices in the US.

"ARRL purports to show that the retailer is...marketing and selling to
consumers (by retail sale) non-consumer Part 18 RF lighting devices which
are not intended for residential deployment, to consumers who have
specifically noted their intention to deploy the devices in residential
applications," ARRL Chief Counsel Chris Imlay, W3KD, said in similar
complaint letters to the Commission on December 28 and December 29. Part 18
emissions limits for consumer devices are far lower than those allowed for
non-consumer devices.

"ARRL has received numerous complaints from Amateur Radio operators of
significant noise in the medium (MF) and high frequency (HF) bands between
1.8 MHz and 30 MHz from 'grow lights' and other Part
15 and part 18 RF lighting devices," Imlay continued. "These devices are
easily capable of emitting RF noise sufficient to preclude Amateur Radio MF
and HF communications (and, as well, AM broadcast station reception)
throughout entire communities."

Supporting both complaints are extensive and detailed reports by ARRL
Laboratory EMC Specialist Mike Gruber, W1MG. The reports recount incidents
of actual purchases of Part 18 RF lighting devices intended for commercial
use to consumers who made clear to store personnel that they intended to use
the devices at home. Gruber's report includes multiple photographs that
depict in-store displays of the products in question and showing signage
that does not adequately explain which devices may be sold to whom.

The ARRL has asked that all non-consumer devices be removed from retail sale
and marketing at the stores and to track and recall non-consumer devices
already sold to consumers.

In his report, Gruber concluded that retailers should require purchasers of
non-consumer Part 18 RF lighting devices to provide a valid contractor's
number. He also advised that the stores improve display signage to make it
clear that non-consumer Part 18 devices may not be used in residential

Earlier this year, the ARRL sent similar complaint letters to the FCC
regarding the marketing of Part 18 RF lighting devices by The Home Depot.
The League also has complained about specific RF lighting "grow light"
devices that it has alleged exceed Part 18 emission limits.

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