TCB Survey

October 3, 2006 TCBC Meeting October, 2006 Slide 1

TCB Survey

Art Wall

[email protected]


OverviewOverviewIntroductionList of questionsInformation about TCB programManufacturer pressure?Acceptability of laboratory test data?Quality, integrity and consistency of data?Improvements to the program?Elements to included in Code of Practice?TCB issues (domestic and foreign)?Summary and questions


IntroductionIntroductionContracted by TCBC to develop a “Code of Practice for TCBs” (TCB Code)First step was to interview most, if not, all TCBsInterviewed 25 of 27 TCBs, 2 Mfrs & 2 DA’sAsked a series of 11 plus questionsThe following is a summary of answers to those questions (confidentiality maintained) Only a few real surprises, but interesting nonetheless on how TCBs perceive their part of the TCB program


List of Questions List of Questions (shortened version)(shortened version)

1. What are the highlights and attributes of your TCB?2. Is the TCB program is working well? Is there room for

improvement?3. Have manufacturers placed undue pressure on TCB?4. Have lab reports been acceptable? 5. Can the quality of test reports and be improved?6. What steps should be taken to improve consistency and quality of the

TCB program?7. Are there specific suggestions for improving the consistency of

grants?8. What can the FCC do to improve the TCB program?9. Is there a integrity issue with some TCBs and can the TCBC help?10.What elements should be included in the “TCB Code?”11.Is there a difference in performance or other issues between US and

non-US TCBs?


Information about the TCB programInformation about the TCB programMost TCBs

Are a small business (or a small part of a larger business)

Have a quality system … with many variationsUse the internet for operationsfound a niche of products or clients for business model

Some TCBs use approvals to support testing (for others approval is its main business)

Most TCBs have 2 or more reviewers & certifiers … which for some TCBs are interchangeable Some TCBs have distributed operations using more than location for testing and approvalsA few TCBs cite quality and service as their stated purpose … while others are willing to live with a low error rate


Information about the TCB program Information about the TCB program (continued)(continued)

Several TCBs state that reputation is most important for their operationSeveral TCBs perform an internal audit on an annual basis … one even paid for external auditor to ensure quality … the same TCB mentioned that every meeting deals with qualitySeveral TCBs have clients sign detailed agreements giving expectations, etc.Several mentioned that they have training for their clients, who for the most part are labs representing manufacturersSeveral TCBs have detailed tracking system for handling complaints complete with steps for correcting mistakesA number of TCBs advertise 7 days for processing applications; whereas, others state approval within 2 days



Several European & US TCBs state that the majority of devices they approve come from AsiaThe manufacturers mentioned that they …

have a number of divisions with multiple plants and locationsuse a number of TCBs, but there is some attempt to consolidate TCBs usedaccredited lab acts as they agentneed to watch TCB and lab closely

One manufacturer stated that it took him 2 days to review a test report … it had a number of mistakes



All TCBs and both manufacturers state thatThe TCB program works well (several state the program exceeds expectations)The program opened up the certification process and greatly increases the speed of serviceOne TCB remarked that the FCC and TCBC have done a remarkable job of organizing and maintaining the program considering the resourcesThe TCB Council, TCBC training, monthly phone calls were cited as being extremely beneficial

Improvements would includeRelease of more productsMore enforcement and oversightPeer review



Problem areasTimeliness and quality of answers from FCCFCC takes too long for unique interpretationsSeveral TCBs are more inclined to push envelope & make decision without FCCOne TCB doesn’t believe the program will last (not a growth business)Several TCBs state the program is headed off-shoreKDB is helpful, but needs to be strengthenSample audit program, since testing is not fundable and the process leads to minimum review



Areas for improvementOne European TCB would like to see better dissemination & organization of the FCC Rules, interpretation and policiesStandardize checklists, complete with interpretationsBetter guidance for market surveillanceFCC should educate manufacturers and stick to the TCB programAn “exclusion list” tailored to the abilities of the TCBThe SAR program is confusing, at bestThe FCC should date all policies and statements



Manufacturer concernsTCB evaluators are not necessarily competent or knowledgeable of the FCC RulesConsistency and quality of approvalsSome TCBs are interpreting the Rules, when question should go to the FCCThere is a need for consistency and exchange of informationTCBs operate in its own self-interest and don’t share information (confirmed by some TCBs)


Manufacturer pressureManufacturer pressureMany TCBs report very little pressure from clients (mfrs or labs representing mfrs)This may not be true with TCBs dealing with Asian labs as their primary customers

Asian labs go to TCBs who provide the best price, speed of service and ask the fewest questionsSeveral TCBs report losing clients to other TCBs who apparently are not asking questionsAsian clients are trying to manipulate the process

Competition is severe and there is no vender loyaltyApplications used to take two weeks to review; whereas, today clients are demanding same or 2 day service.


Manufacturer pressure Manufacturer pressure (continued)(continued)

One TCB reported that Asian Labs are competent … have good report formats … competitive and look for least resistance to obtain approvalAsian manufacturers are demanding fast service, cheap prices and no questions … quality is not importantTCBs who insist on quality report losing clients … one TCB reported that the client came back when it got into troubleSeveral TCBs report losing clients to another TCB for the answer they wanted … this is less of an issue for TCBs with an establish or known list of labsOne TCB reported a forged reportOne TCB reported that 2-3 clients per year have threaten to go elsewhere, if application is scrutinized


Manufacturer pressure Manufacturer pressure (continued)(continued)

One TCB remarked that its own labs have threaten to go another TCB who does not ask questionsApplication procedures, according to one TCB, are being cut due to competitive pressure leading to lack of adequate reviewOne TCB suggested developing a marketing brochure to educate clients to include:

Code of conduct for clientsReasonable time frame for approvalGeneral rules for engaging a TCBGeneral information about the programExpectations and limitation of a TCB


Quality of test reportsQuality of test reportsTCBs dealing with known labs say the labs are knowledgeableSeveral TCBs mentioned that most labs are competent, but some are sloppy and inconsistent tending to repeat the same errorsOnly in a few instances has a TCB questioned the integrity of a labLabs also do not want to provide a sample and have gone elsewhere as a resultA number of TCBs reported that documentation for test procedures need to be improved…some labs have problems understanding the test procedures, rules and policies


Quality of test reports Quality of test reports (continued)(continued)

Several TCBs mentioned that labs find the FCC Rules, policies and test procedures are overwhelming and difficult to understand … they want better documentation and a guide for minimum requirements for testing each deviceSome TCBs would support an effort to document test procedures.Several TCBs stated that they provide training to their Labs once a year



Those TCB’s that train and work with labs have less problemsOne European TCB recommends that each TCB be responsible for helping test labs to ensure qualitySeveral TCBs recommended the TCBC work to improve documentation of test proceduresSeveral TCBs suggested that

Test report should be standardizedThere should be a standard format and checklist for applications; e.g., EN300-328 & EN 301-893One TCB suggested using the reporting format in 17025



One manufacturer stated that some labs are good, but the test results need to be reviewed carefullyThe other manufacturer said that some labs are not competent for specific tests and don’t know how to perform the test.Information from the manufacturer is not transferred to the TCB for reviewAccording to the manufacturers, tests performed are not representative of actual operationManufacturers suggest the following questions to each applicant

Are the tests performed typical of actual operation?Has the manufacturer reviewed and concur with the report?

Manufacturers believe that labs need additional guidance and training


Steps to improve TCB program?Steps to improve TCB program?One TCB suggested defining minimum criteria or check list for each equipment typeSeveral TCBs suggested developing a system measuring TCB performance … or at least system for providing feedback on a regular basis … and publicizing the resultsSeveral TCBs and manufacturers want a standardize checklist complete with interpretations and proceduresManufacturers want TCB consistency and suggested round-robin applications with known problemsOne TCB wanted the exclusion list to be more understandableAdditional training and guidance in the application of grant notes would be helpful


Steps to improve TCB program? Steps to improve TCB program? (continued)(continued)

Most TCBs & manufacturers believe equipment categories and grant notes are confusing and inconsistent … standardization of grant notes would improve consistency … especially for RF safetySeveral TCBs remarked the information on the grant (equipment category, frequency of operation and grant notes) should be standardizedOne TCB suggested a 3rd party (not FCC) review grantsManufacturers recommended that the type of device (portable or mobile) be placed on grantMany TCBs state that the FCC should manage the process and do more audits and enforcement … several state there is no consequence for poor performance … manufacturers want more training for the labs and additional enforcement



FCC actions requested by one or more TCBsAdditional guidelines for completing applicationsMore training for modular devicesBe more responsive to inquiriesImprove KDB, particularly the search functionMore information should be in rules and less reliance on KDBPublish guidelinesIncrease enforcement and audit oversightMake rules and interpretations more consistentMake FCC EAP webpage easier to followEstablish a team (gov. and non-gov.) to discuss new technology issuesMake TCB performance information available on lineEliminate 5 day grace-period for downloading exhibitions (done)

Provide dummy website (already available)



FCC actions requested by one or more TCBs (continued)

Develop examination for evaluatorsDocument and improve test procedures, including inter-modulation testing Develop examination for evaluatorsReduce, update or eliminate exclusion listDevelop yardstick so TCBs can compareProvide better documentation (standards and policy statements in a known location) … policy statements should not be left in presentationsFCC presentations should be updated (since many are now confusing, especially RFI exposure)Publish set-asides and complaintsProvide mechanism for tracking antenna changes and grant note changes when there are permissive changes


TCB integrity issues and TCBC?TCB integrity issues and TCBC?Many TCBs are not aware of real abuse of the program … other stated that there is abuse … dismissals are an indication of abuse Factors affecting consistency, according to one European TCB

PriceSpeedFinancial pressureTest lab and manufacturer pressureComplexity of the Rules

Many TCBs do not believe the TCBC cannot police TCBs … that job should be left to the FCC … one TCB stated that manufacturers should provide peer review … one TCB mentioned that the TCBC should develop and recommend the use of guidance notes for use by all TCBs


TCB integrity issues and TCBC? TCB integrity issues and TCBC? (continued)(continued)

A few TCBs believe TCBC involvement is questionable and will promote mediocritySeveral TCBs agree that the TCBC should be proactive roll, as it is doing, in providing opportunities for training, cooperation & support with FCC and promoting the “code of practice”One TCB wants the TCBC to work with the TCB after it gets into trouble with the FCCOne TCB wants a TCBC round-table to interpret the Rules without the FCCSeveral TCBs recommended “quality management” training with suggesting for resolving problem auditsSeveral TCBs argued that the TCBC is proactive and doing a great job


Input to TCB Code?Input to TCB Code?Most TCBs are unclear how the “Code” would be implemented … a number of TCBs stated the it should be incorporated into the TCB programOne or more TCBs mentioned the following for the “Code”

Specific elements of Guide 65 (ethics, impartiality, transparency & organization structure)

Mission statement (vision of public good)

Internal auditsTrainingSeeking FCC guidance when necessaryTimeliness in uploading exhibitions (done)


Input to TCB Code? Input to TCB Code? (continued)(continued)

One or TCBs mentioned the following for the “Code” (continued)

Publishing price list with conditions for reductionProcess for handling undue manufacturer pressure A well defined process to followA guidance document for reviewing applicationsSurveillance testing guidanceQuality statement about fixing problemsMinimum application review time (e.g., 5 days)

Consequences for poor performersApprove only devices for which TCB and Lab has competenceFCC guidance of relationship with clientsTeeth in the “Code” … it should be self-regulatingIndependence from clients and test labs


TCB issues (foreign & domestic)TCB issues (foreign & domestic)??A number of TCBs mentioned that they now believe there is no difference between domestic and European TCBsA few TCBs believe there is a difference in the requirement and evaluations of European TCBs … one US TCB believes there are some integrity issues with some foreign TCBsOne European DA stated that they give assessments every 3 years with annual surveillance audits … he also stated there is no difference between EN45011 and Guide 65, but there is a big difference in the interpretation documentsManufacturers believe there is a difference with foreign TCBs in their understanding of the Rules and experience with the US systemOne European TCB believes there is a perception that the FCC scrutinizes foreign TCBs more than domestic TCBs


TCB issues (foreign & domestic)? TCB issues (foreign & domestic)? (continued)(continued)

Most TCBs dealing with Asian labs are very concerned with prospect of Asian TCBs.One TCB reported there is a communication and cultural barriers with overseas labs, especially Asian labsA number of TCBs expressed a concern with the MRA process, especially with the Asian economies due to the perceived lack of control and enforcement


TCB issues (foreign & domestic)? TCB issues (foreign & domestic)? (continued)(continued)

Several TCBs requested more TCBC meetings on the West Coast … European TCBs requested TCBC meetings in EuropeTwo TCBs questioned the competency of some auditors … implying that more training and guidance may be neededAnother TCB suggested that domestic and foreign accreditors should talk with one another to develop a more consistent processOne TCB mentioned that auditors should assess the TCB, but keep their opinions to themselves … several TCBs stated that more qualified auditors are needed and the assessment should emphasize technical, as well as, quality issuesAlso, there should be a better process for monitoring evaluators and certifiers


Summary Summary (My impression and comments)(My impression and comments)While no real surprises for me in talking with TCBs and manufacturers, it was interesting to learn how TCBs operate and how they perceive their role in the FCC equipment approval programMost TCBs want the program to succeed and are willing to take whatever steps are necessary to ensure a consistent well run program, as long as all TCBs play by the same rulesA key element and current weakness of the program is the competency of test labs … additional training and documenting the test procedures would be extremely helpful … TCBs should also work with Labs to improve consistency of test resultsThe FCC and all TCBs should take appropriate step to ensure that clients do not manipulate the system … a TCB who fails to provide an adequate or consistent review of an application should be penalizedThere are also a number TCB recommendations that the FCC and accreditors may want to take into consideration to help the TCBsThe TCB “Code” was formulated considering all the comments in this survey


Thank YouArt Wall

Radio Regulatory Consultants, Inc.

[email protected]

Documents

TCB Survey