TCB Survey

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TCB Survey
Art Wall awall_at_atlanticbb.net
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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

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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

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List of Questions (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?

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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 (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 approvals
• A few TCBs cite quality and service as their
  stated purpose while others are willing to live
  with a low error rate

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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

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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

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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

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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
  off-shore
• KDB is helpful, but needs to be strengthen
• Sample audit program, since testing is not
  fundable and the process leads to minimum review

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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

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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)

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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.

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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

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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

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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 improvedsome labs
  have problems understanding the test procedures,
  rules and policies

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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

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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

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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

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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

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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

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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)

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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
  inter-modulation 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

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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

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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

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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)

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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

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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

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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

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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

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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

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Thank You

• Art Wall
• Radio Regulatory Consultants, Inc.
• awall_at_atlanticbb.net