TCB RF Exposure Training
RF Exposure (RFx) Coming Attractions
Goals for Exclusion List Handoff
Exposure Categories and Considerations
Collocated Devices
Tim Harrington, FCC/OET/EAB
February 13-15, 2002
TCB Exclusion List April ‘02 Handoff Target
• Handoff Prerequisites:
– Updated power and distance exclusion thresholds
– PTT test procedures and power thresholds
– MPE test procedures; partial-body MPE procedures
under review and development (e.g., R. Tell IEEE
– Possible collocation procedures
• Other audience suggestions? - group discussion
at end of this presentation and/or during meeting
February 2002
FCC - TCB RFx Training
Device Categories & Exposure Conditions
• Fixed: d >> 20 cm, outdoor, permanent-mount, high
power, multiple Tx; intended tower- or roof-mount
• Mobile: d ≥ 20 cm, indoor, moveable, single Tx;
meant for vehicle-mounted or transportable,
relocatable, indoor-wall-mount
• Portable: d < 20 cm, relatively low power, single Tx;
SAR limits apply 0 cm to 20 cm
• For palmtop, extremity limit may apply for portable
condition of user’s hand, while mobile condition
applies for user’s head/body
• For high power PTT, controlled limit may apply to
user while uncontrolled limit applies to bystander
February 2002
FCC - TCB RFx Training
Device Categories & Exposure Conditions
Fixed Transmitters
Mobile Transmitters
Portable Transmitters
Antennas mounted on
Outdoor, Permanent
Broadcast, Base Stations
Antennas operated under
Non-Permanent or Indoor
Vehicles, Desktops
Antennas or Devices
operated at
Close Proximity to Persons
Cellular & PCS Phones
Far-Field Plane-Wave
Equivalent Exposure to
Single or Multiple
High Power Transmitters
Exposures typically in
Near-to-Far Transition
Regions of Transmitters
Single, Standalone Antennas
Exposures in the
Near-Field of
Low Power, Portable
From: August 2001 FCC - TCB Training on SAR Review
February 2002
FCC - TCB RFx Training
MPE Basic Considerations
• Far-field power density equation can be used for MPE
estimation only for d ≥ 20 cm
• MPE estimation equation typically does not apply in nearfield d < 20 cm (portable exposure condition)
• SAR limits apply for all distances less than 20 cm
∴ MPE estimation for d < 20 cm is immaterial by rules
• MPE estimation cannot be used for routine evaluation of
mobile devices in lieu of measurement or computer
simulation of equivalent geometry
• Be careful about allowing unsupported compliance claims
in users manuals and elsewhere in filing, especially
anything based on MPE estimation
• Example: PCMCIA in laptop is not mobile - see below
February 2002
FCC - TCB RFx Training
SAR Testing for MPE Compliance
2.1091(d)(3): compliance with exposure guidelines for devices in this
section can be accomplished by the use of warning labels and by
providing users with information concerning minimum separation distances
from transmitting structures and proper installation of antennas.
For consideration under mobile conditions, must demonstrate that 20 cm
spacing will be maintained
SAR data for specific distance(s) and device configuration(s) reviewed to
evaluate compliance as a mobile device per 2.1091(d)(4). SAR data for
limited configurations may not support all portable exposure conditions, so
device will not be designated as “portable”
SAR data and specific test configurations may be listed in the users
manual to inform end-users of compliance at the specific distance(s), in
lieu of other mobile device exposure statements normally required under
“Limited portable” criteria based on SAR tested at d may receive sanction;
filing should show reasonable expectation/proof that d will be maintained
February 2002
FCC - TCB RFx Training
Part 15 RFx Review
47 CFR 15.247(b)(4): “Systems operating under the provisions of this
section shall be operated in a manner that ensures that the public is not
exposed to radio frequency energy levels in excess of the Commission’s
Suppl C Sect. 3 RFx for SS Tx:
– “If a transmitter is designed to operate next to the body of its user or
at close proximity to persons, a RF evaluation may be requested
according to 47 CFR §1.1307(c) and (d).”
– “If a device, its antenna or other radiating structures are operating at
closer than 2.5 cm from a person’s body or in contact with the body,
SAR evaluation may be necessary when the output is more than 50
– 100 mW, depending on the device operating configurations and
exposure conditions.”
– “It should be emphasized that categorical exclusion from routine
environmental evaluation must not be interpreted as an exemption
from compliance with the RF exposure requirements in
February 2002
FCC - TCB RFx Training
Laptop Considerations
• For antennas internal or external to lid/LCD, compliance
typically evaluated assuming mobile conditions
• If device has capability to be used on lap, warning labels
or manual statements are not sufficient to stop people
from lapheld use
• Card slots or external and internal antennas mounted in
the keyboard section are usually less than 20 cm from
user’s body ⇒ lapheld use necessitates compliance
with SAR limits; MPE estimation does not apply
• When power and/or SAR is relatively low, will consider
approval concept for device families – similar size and
shape cases; card slot and internal or external antennas
in same relative location for each model; nearby
shielding and grounding structure topologies
substantially similar; direct-contact SAR tested
February 2002
FCC - TCB RFx Training
Draft - Palmtop and Laptop Positions
• At flat phantom:
– Back/bottom in direct contact
– Front/top – keyboard near contacting, lid opened back
– Edge with card/antenna face broadside
– Laptop edge containing card facing phantom
– For antenna near corner of side, maybe do nearest side
– Direct-contact configurations may reduce SAR ⇒ may
also need small-gap position, e.g., 2 or 3 mm
• Flip-up antenna test positions: 1) handheld or lapheld
back-panel on flat phantom with antenna a) up, b) down,
2) bystander antenna up parallel to flat phantom a) edge
containing antenna, b) next closest edge/corner
February 2002
FCC - TCB RFx Training
Draft - Palmtop - Hand SAR Concepts
Hand typically does not contact or enclose antenna, many palmtop
devices unlikely to exceed 4 W/kg 10-g extremity limit, for antenna
approximately 1-2 cm from hand
Appropriate hand-held/-operated instructions = mobile possible
Recent trend to designate as hand SAR that position with device in
direct contact with flat phantom; by that logic, may need direct contact
of at least case side/edge closest to antenna also
Such positions present incorrect loading and proximity for normally
unobstructed antennas
To avoid misrepresentation, call this for example “direct-contact SAR,”
not hand SAR
To better simulate hand loading with flat phantom, place device near
edge with antenna sticking out; however, this may lead to probe
boundary effect or special probe cal. issues
February 2002
FCC - TCB RFx Training
RFx Considerations for Mobile Part 15 Modules
No portable modules - operating configurations and exposure
conditions for final product must be defined
Because of near-field conditions, SAR tested in one specific
host is unlikely to represent SAR patterns in other host
Module compliance evaluated for mobile conditions,
preferably for specific host devices (LMA), or OEM installation
SAR compliance shown means compliance for MPE limit
SAR test distance not listed on grant (unless body-worn); test
distance and configurations should be shown in user manual
Must specify antenna/connector options, details
Detailed installation and operating instructions included to
ensure 20 cm separation
PCMCIA is not module
February 2002
FCC - TCB RFx Training
Draft - Collocated SAR Evaluation
Oct ‘01 IEC 62209 Proposal: For devices that can transmit on more than one
frequency band at the same time (multiple transmitters), the maximum
exposure is obtained by the following process: the zoom scan volume is
extended to cover the entire area of exposure. The SAR distribution is
assessed on exactly the same grid at all frequencies which can transmit
simultaneously. For each point of this extended zoom scan the SAR values of
those frequencies which can transmit simultaneously are summed and the
post-processing is applied to this extended zoom scan. The maximum
exposure is the highest spatial peak SAR determined for the single and
combined frequency exposures.
IEC draft seems to sidestep the issues of frequency-dependent liquids and
probe cal
Possible SAR test protocol for TxAB with 2 center frequencies:
February 2002
probe cal. @
f (TxA)
f (TxA)
f (TxB)
f (TxB)
FCC - TCB RFx Training
liquid @
f (TxA)
f (TxA)
f (TxB)
f (TxB)
Draft - Collocated RFx Evaluation
• Options for evaluating compliance:
– 1. Report max SAR from matrix of test combinations
for each band and device mode
– 2. Sum up single-Tx SAR values in each band,
independent of SAR field patterns
– 3. Spatial superposition of SAR distributions for each
• May consider free-space near-field H-field mapping –
removes tissue-equivalence and tissue-specific probe
cal. issues
• Maybe pursue single liquid for all frequencies, and apply
probe “shaped-response” design and cal. principles
February 2002
FCC - TCB RFx Training
Draft – Bluetooth Threshold Powers
BT power exclusion-rule-of-thumb: 1.6mW/g × 1g ⇒ 1.6mW-conducted
needed to hit limit assuming all power transferred to ideal 1g of tissue
General collocation conditions:
– 1) A 1mW device can be collocated with another mobile device
– 2) For portable configurations with antenna in direct-contact, 1mW device
can be collocated when the aggregate power does not exceed 5mW
– 3) For other portable configurations (no contact and distances to 20 cm),
the 1mW device can be collocated when aggregate does not exceed
A handset with Bluetooth has single FCC ID but two separate filings for Parts
15 and 22/24; each filing must refer to the other application number
If SAR is to be done:
– SAR should be done with BT ON at host-device band for usual Suppl C
– SAR should be repeated with BT OFF for the previous simultaneous-Tx
configuration (position, antenna, frequency) with highest SAR
February 2002
FCC - TCB RFx Training
Draft - Collocated RFx Considerations
• Define TxA+TxB ≡ TxAB as TxA and TxB collocated and
simultaneous-on; if either TxA or TxB needs routine
evaluation, routine evaluation needed for TxAB
• Given separate exclusion power thresholds TA and TB,
below which separate evaluation not needed, e.g.,
TA=8W and TB=4W, if PA/TA + PB/TB ≤1, composite
(aggregate) evaluation not needed
• If TxA, TxB each have separate existing grants, and sum
PAB is within threshold, Class II may be used on each to
collocate with other
• Threshold levels Ti(f ) to be determined; CENELEC
product standard EN 50360:2001 uses 20mW
February 2002
FCC - TCB RFx Training
Draft - Collocated RFx Considerations
• Example: TxAB has been approved without RFx
evaluation for collocation within threshold TAB
• Example1: Add TxC, where C requires routine
evaluation. Now exclusion no longer applies
⇒TxABC requires routine evaluation
• Example2: Add TxC. If composite power now
exceeds threshold, i.e., PA/TA + PB/TB + PC/TC > 1
(cf., OET65, C95.1 Annex D) C is responsible for
composite RFx evaluation of all
• Multiple Tx: may need new FCC ID on composite
as soon as Txk added such that ΣPi/Ti>1
February 2002
FCC - TCB RFx Training
Other Collocation Considerations
• Hot-key or other software control for simultaneous or not;
software controls to detect plug-in, other Tx conditions
• TxA/B mutual effects and mutual perturbations expected
to change SAR distributions
• Experience with dual-mode Part 22/24 handsets shows
that small layout changes re-directs RF current flow and
changes SAR
• If antennas are separated far enough apart on host
device, e.g., 20 cm or as determined by appropriate
near-field analysis, RFx evaluation of each Tx as
individual may be possible
• Example: if documentation indicates 802.11b (2.4GHz)
and 802.11a (5GHz) capability ⇒ check for collocation
February 2002
FCC - TCB RFx Training
Device is PCMCIA card with built-in antenna
If exposure at closer than 20 cm can occur, compliance with SAR limits
must be evaluated
EMC report was done with typical host laptop, means 20 cm spacing from
lap cannot be expected to be normal use position
Exh. 11: “The antenna of the product, under normal use condition, is at least
20 cm away from the body of the user. Warning statement for keeping 20
cm separation distance and the prohibition of operating next to a person has
been printed on the users manual. So, this product is classified as the
Mobile Device.”
Exh. 8: “IMPORTANT NOTE: Federal Communications Commission (FCC)
Radiation Exposure Statement
– This equipment complies with FCC radiation exposure limits set forth for an
uncontrolled environment.
– This equipment should be installed and operated with minimum distance 20cm
between the radiator & your body.
– This transmitter must not be co-located or operation in conjunction with any other
antenna or transmitter.”
February 2002
FCC - TCB RFx Training
Laptop 80mW LAN PCMCIA and Excl. List
Part 15 Portable Transmitter Category VI): The following portable transmitters
authorized under Part 15 do not qualify for TCB approval: e) §15.247 spread
spectrum transmitters that v) operate with the device and its antenna at 5 cm
or more from a person’s body; by design, the antenna provides a separation
distance of less than 2.5 cm from a person’s hands, wrists, feet and ankles,
and either the peak conducted or peak radiated (EIRP) output power exceeds
1) 100 mW for the 2.4 GHz band
Section L: §15.247 Spread Spectrum Portable Transmitter operating with the
device and its antenna at a separation distance of at least 5 cm from all
– Grant Conditions2 – This device and its antenna(s) must operate with a separation
distance of at least 5 cm from all persons and must not be co-located or operating
in conjunction with any other antenna or transmitter. [This device must transmit
with a source-based time-averaging duty factor not exceeding -- %.]3 End-users
must be provided with specific operating instructions for satisfying RF exposure
compliance requirements.
– TCB must verify the device does not operate in the 5.7 GHz band; by design, the
antenna operates with a separation distance of at least 2.5 cm from a person’s
hands, wrists, feet and ankles, and the peak conducted and peak radiated (EIRP)
output power does not exceed 100 mW for 2.4 GHz band
February 2002
FCC - TCB RFx Training
See y’all in April !
prefer email
phone 301 362 3039
February 2002
FCC - TCB RFx Training