TCB Survey

Art Wall
awall@atlanticbb.net
October 3, 2006

TCBC Meeting October, 2006

Slide 1

Overview
Introduction
List of questions
Information about TCB program
Manufacturer 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
October 3, 2006

TCBC Meeting October, 2006

Slide 2

Introduction
Contracted by TCBC to develop a Code of
Practice for TCBs (TCB Code)
First step was to interview most, if not, all
TCBs
Interviewed 25 of 27 TCBs, 2 Mfrs & 2 DAs
Asked a series of 11 plus questions
The 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
October 3, 2006

TCBC Meeting October, 2006

Slide 3

List of Questions (shortened version)

What are the highlights and attributes of your TCB?
Is the TCB program is working well? Is there room for improvement?
Have manufacturers placed undue pressure on TCB?
Have lab reports been acceptable?
Can the quality of test reports and be improved?
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?
1.
2.
3.
4.
5.
6.

October 3, 2006

TCBC Meeting October, 2006

Slide 4

Information about the TCB program

Most TCBs

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

Have a quality system with many variations
Use the internet for operations
found a niche of products or clients for business model

Some TCBs use approvals to support testing

others approval is its main business)

(for

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 approvals
A few TCBs cite quality and service as their stated
purpose while others are willing to live with a
low error rate
October 3, 2006

TCBC Meeting October, 2006

Slide 5

Information about the TCB program (continued)

Several TCBs state that reputation is most important for
their operation
Several 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
quality
Several 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 manufacturers
Several TCBs have detailed tracking system for handling
complaints complete with steps for correcting mistakes
A number of TCBs advertise 7 days for processing
applications; whereas, others state approval within 2 days
October 3, 2006

TCBC Meeting October, 2006

Slide 6

Information about the TCB program (continued)

Several European & US TCBs state that the
majority of devices they approve come from
Asia
The manufacturers mentioned that they
have a number of divisions with multiple plants
and locations
use a number of TCBs, but there is some attempt
to consolidate TCBs used
accredited lab acts as they agent
need 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
October 3, 2006

TCBC Meeting October, 2006

Slide 7

Information about the TCB program (continued)

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

Improvements would include

Release of more products
More enforcement and oversight
Peer review
October 3, 2006

TCBC Meeting October, 2006

Slide 8

Information about the TCB program (continued)

Problem areas
Timeliness and quality of answers from FCC
FCC takes too long for unique interpretations
Several TCBs are more inclined to push
envelope & make decision without FCC
One TCB doesnt believe the program will last
(not a growth business)

Several TCBs state the program is headed offshore

KDB is helpful, but needs to be strengthen
Sample audit program, since testing is not
fundable and the process leads to minimum
review
October 3, 2006

TCBC Meeting October, 2006

Slide 9

Information about the TCB program (continued)

Areas for improvement
One European TCB would like to see better
dissemination & organization of the FCC Rules,
interpretation and policies
Standardize checklists, complete with
interpretations
Better guidance for market surveillance
FCC should educate manufacturers and stick to the
TCB program
An exclusion list tailored to the abilities of the TCB
The SAR program is confusing, at best
The FCC should date all policies and statements
October 3, 2006

TCBC Meeting October, 2006

Slide 10

Information about the TCB program (continued)

Manufacturer concerns
TCB evaluators are not necessarily competent
or knowledgeable of the FCC Rules
Consistency and quality of approvals
Some TCBs are interpreting the Rules, when
question should go to the FCC
There is a need for consistency and exchange
of information
TCBs operate in its own self-interest and dont
share information (confirmed by some TCBs)
October 3, 2006

TCBC Meeting October, 2006

Slide 11

Manufacturer pressure
Many 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 questions
Several TCBs report losing clients to other TCBs who
apparently are not asking questions
Asian clients are trying to manipulate the process

Competition is severe and there is no vender loyalty

Applications used to take two weeks to review;
whereas, today clients are demanding same or 2
day service.
October 3, 2006

TCBC Meeting October, 2006

Slide 12

Manufacturer pressure (continued)

One TCB reported that Asian Labs are competent
have good report formats competitive and look
for least resistance to obtain approval
Asian manufacturers are demanding fast service,
cheap prices and no questions quality is not
important
TCBs who insist on quality report losing clients
one TCB reported that the client came back when it
got into trouble
Several 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 labs
One TCB reported a forged report
One TCB reported that 2-3 clients per year have
threaten to go elsewhere, if application is scrutinized
October 3, 2006

TCBC Meeting October, 2006

Slide 13

Manufacturer pressure (continued)

One TCB remarked that its own labs have
threaten to go another TCB who does not ask
questions
Application procedures, according to one TCB,
are being cut due to competitive pressure
leading to lack of adequate review
One TCB suggested developing a marketing
brochure to educate clients to include:
Code of conduct for clients
Reasonable time frame for approval
General rules for engaging a TCB
General information about the program
Expectations and limitation of a TCB
October 3, 2006

TCBC Meeting October, 2006

Slide 14

Quality of test reports

TCBs dealing with known labs say the labs are
knowledgeable
Several TCBs mentioned that most labs are
competent, but some are sloppy and
inconsistent tending to repeat the same errors
Only in a few instances has a TCB questioned
the integrity of a lab
Labs also do not want to provide a sample and
have gone elsewhere as a result
A number of TCBs reported that documentation
for test procedures need to be improved
some labs have problems understanding the
test procedures, rules and policies
October 3, 2006

TCBC Meeting October, 2006

Slide 15

Quality of test reports (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 device
Some TCBs would support an effort to
document test procedures.
Several TCBs stated that they provide
training to their Labs once a year
October 3, 2006

TCBC Meeting October, 2006

Slide 16

Quality of test reports (continued)

Those TCBs that train and work with labs have
less problems
One European TCB recommends that each TCB
be responsible for helping test labs to ensure
quality
Several TCBs recommended the TCBC work to
improve documentation of test procedures
Several TCBs suggested that
Test report should be standardized
There should be a standard format and checklist for
applications; e.g., EN300-328 & EN 301-893
One TCB suggested using the reporting format in 17025

October 3, 2006

TCBC Meeting October, 2006

Slide 17

Quality of test reports (continued)

One manufacturer stated that some labs are good,
but the test results need to be reviewed carefully
The other manufacturer said that some labs are not
competent for specific tests and dont know how to
perform the test.
Information from the manufacturer is not transferred
to the TCB for review
According to the manufacturers, tests performed are
not representative of actual operation
Manufacturers 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
October 3, 2006

TCBC Meeting October, 2006

Slide 18

Steps to improve TCB program?

One TCB suggested defining minimum criteria or check
list for each equipment type
Several TCBs suggested developing a system
measuring TCB performance or at least system for
providing feedback on a regular basis and
publicizing the results
Several TCBs and manufacturers want a standardize
checklist complete with interpretations and procedures
Manufacturers want TCB consistency and suggested
round-robin applications with known problems
One TCB wanted the exclusion list to be more
understandable
Additional training and guidance in the application of
grant notes would be helpful
October 3, 2006

TCBC Meeting October, 2006

Slide 19

Steps to improve TCB program? (continued)

Most TCBs & manufacturers believe equipment
categories and grant notes are confusing and
inconsistent standardization of grant notes would
improve consistency especially for RF safety
Several TCBs remarked the information on the grant
(equipment category, frequency of operation and grant notes)

should be standardized
One TCB suggested a 3rd party (not FCC) review grants
Manufacturers recommended that the type of device
(portable or mobile) be placed on grant
Many 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
October 3, 2006

TCBC Meeting October, 2006

Slide 20

Steps to improve TCB program? (continued)

FCC actions requested by one or more TCBs
Additional guidelines for completing applications
More training for modular devices
Be more responsive to inquiries
Improve KDB, particularly the search function
More information should be in rules and less reliance on KDB
Publish guidelines
Increase enforcement and audit oversight
Make rules and interpretations more consistent
Make FCC EAP webpage easier to follow
Establish a team (gov. and non-gov.) to discuss new technology
issues
Make TCB performance information available on line
Eliminate 5 day grace-period for downloading exhibitions (done)
Provide dummy website (already available)
October 3, 2006

TCBC Meeting October, 2006

Slide 21

Steps to improve TCB program? (continued)

FCC actions requested by one or more TCBs

(continued)

Develop examination for evaluators

Document and improve test procedures, including intermodulation testing
Develop examination for evaluators
Reduce, update or eliminate exclusion list
Develop yardstick so TCBs can compare
Provide better documentation (standards and policy statements
in a known location) policy statements should not be left in
presentations
FCC presentations should be updated (since many are now
confusing, especially RFI exposure)

Publish set-asides and complaints

Provide mechanism for tracking antenna changes and grant
note changes when there are permissive changes
October 3, 2006

TCBC Meeting October, 2006

Slide 22

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
Price
Speed
Financial pressure
Test lab and manufacturer pressure
Complexity 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
October 3, 2006

TCBC Meeting October, 2006

Slide 23

TCB integrity issues and TCBC? (continued)

A few TCBs believe TCBC involvement is
questionable and will promote mediocrity
Several 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 FCC
One TCB wants a TCBC round-table to interpret the
Rules without the FCC
Several TCBs recommended quality management
training with suggesting for resolving problem audits
Several TCBs argued that the TCBC is proactive and
doing a great job
October 3, 2006

TCBC Meeting October, 2006

Slide 24

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 program
One 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 audits
Training
Seeking FCC guidance when necessary
Timeliness in uploading exhibitions (done)
October 3, 2006

TCBC Meeting October, 2006

Slide 25

Input to TCB Code? (continued)

One or TCBs mentioned the following for the
Code (continued)
Publishing price list with conditions for reduction
Process for handling undue manufacturer pressure
A well defined process to follow
A guidance document for reviewing applications
Surveillance testing guidance
Quality statement about fixing problems
Minimum application review time (e.g., 5 days)
Consequences for poor performers
Approve only devices for which TCB and Lab has
competence
FCC guidance of relationship with clients
Teeth in the Code it should be self-regulating
Independence from clients and test labs
October 3, 2006

TCBC Meeting October, 2006

Slide 26

TCB issues (foreign & domestic)?

A number of TCBs mentioned that they now believe there
is no difference between domestic and European TCBs
A 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 TCBs
One 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 documents
Manufacturers believe there is a difference with foreign
TCBs in their understanding of the Rules and experience
with the US system
One European TCB believes there is a perception that the
FCC scrutinizes foreign TCBs more than domestic TCBs

October 3, 2006

TCBC Meeting October, 2006

Slide 27

TCB issues (foreign & domestic)? (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 labs
A number of TCBs expressed a concern
with the MRA process, especially with the
Asian economies due to the perceived lack
of control and enforcement
October 3, 2006

TCBC Meeting October, 2006

Slide 28

TCB issues (foreign & domestic)? (continued)

Several TCBs requested more TCBC meetings on the
West Coast European TCBs requested TCBC
meetings in Europe
Two TCBs questioned the competency of some
auditors implying that more training and guidance
may be needed
Another TCB suggested that domestic and foreign
accreditors should talk with one another to develop a
more consistent process
One 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 issues
Also, there should be a better process for monitoring
evaluators and certifiers
October 3, 2006

TCBC Meeting October, 2006

Slide 29

Summary (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
program
Most 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 rules
A 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 results
The 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 penalized
There are also a number TCB recommendations that the FCC and
accreditors may want to take into consideration to help the TCBs
The TCB Code was formulated considering all the comments in
this survey
October 3, 2006

TCBC Meeting October, 2006

Slide 30

Thank You
Art Wall
Radio Regulatory Consultants, Inc.
awall@atlanticbb.net

October 3, 2006

TCBC Meeting October, 2006

Slide 31