1. Washington Laboratories (301) 417-0220 web: www.wll.com7560 Lindbergh Dr. Gaithersburg, MD 20879 William H. Graff, American TCB Updates for Test Reporting

2. GSM Duty Factor Test Report and supporting documentation should clearly support GPRS capabilities of the device. Please include information regarding both the GPRS classes (e.g. class 10 and class A). Test with maximum power for both body-worn and head positions as applicable. Currently the FCC has been asking on most GSM applications to verify if the GPRS capability will work while the device is transmitting in voice mode.

3. CDMA 2000 / W-CDMA The FCC has requested all TCBs to consult with them before any attempt to approve CDMA 2000 is attempted. FCC is considering whether or not to consider CDMA 2000 a new technology and therefore subject to approval exclusively by the Commission

4. Layards Devices with Neck worn lanyards or that are intended to be next to the body should be tested with 0 gap and body tissue liquid. Both Front and Back should be tested. An eyelet on the device does not necessitate use of neck lanyards. Instructions to the user should clearly support the correct uses.

5. Layards An eyelet on the device does not necessitate use of neck lanyards. Instructions to the user should clearly support the correct uses and accessories provided. If the manufacturer provides a neck lanyard with the device (in the box), or suggests to the user that this device is intended for lanyards, then it should be tested with 0cm gap.

6. Tablet Devices Tablet device screen sizes range 8-14 and weights range 2-8 lbs.

7. Tablet Type Devices Smaller devices may qualify for handheld- only operations, but filing must include strong justification for such – contact TCB or FCC for guidance if needed. Generally unless a strong justification can be made, portable may be assumed.

8. Tablet Type Devices Consumer tablet PCs are expected to have lap- held use positions per [IDB RFx 7) d) ii)]*. * - Excert from Mobile and Portable Device RF Exposure Equipment Authorization Procedures Released March 18, 2004 which states: For undefined or unclear device usage positions, where existing or standardized test procedures are not applicable, SAR should be evaluated according to the normal operating configurations which are intended for the device.

9. SAR Test Documentation Important test setup details affecting SAR should be provided in SAR Test Documentation: Belt clip and air gap thickness.

10. SAR Test Documentation PCMCIA card distance to phantom for laptop and PDA testing. P1528 device reference lines for held to ear testing.

11. USB Style Dongles Direct-connected USB (without integral cable) differs from most PCMCIA in that port alignment may be horizontal (H), vertical (V), and 180 degrees H or V, with respect to a notebook computer host

12. USB Style Dongles Grantee is responsible for SAR compliance in all such intended use positions. 1-host SAR testing is accepted for many Part 15 and some licensed-service USB-dongle transmitters. 3-host SAR test results have been filed for some licensed-service devices IDB/KDB Mar04 webpost RFx Procedures 7)b), 7)c) are applicable

13. 802.11 WLAN Devices The FCC has spent considerable amount of time reviewing these devices and experimenting with many aspects of the SAR testing. The FCC has been seriously thinking about proposing many changes to the SAR procedures used for testing for these types of devices. Remember that these are proposals, are subject to change, and may or may not be implemented.

14. 802.11 WLAN Devices Proposed Changes Include the following. Note that these are proposed changes and should not be considered final until formally released by the FCC: 1.Default channels use for test may be different than simply Low, Mid and High and will depend on power measurements of channels near the Low and High channels. This is due to the variance of bandedge channels seed in some devices where the bandedge channels have reduced power. Proposed FutureGuidelines Only

15. 802.11 WLAN Devices 2.) Certain modulations may be considered required for default testing, but others may still need to be required depending on certain set power levels. For example, 802.11g is only required to be tested if the average power is 0.25 dB > than the 802.11b power for the same channel Proposed FutureGuidelines Only

16. 802.11 WLAN Devices 3.) Higher data rates usually have lower average output. Higher data rates should be tested only when the average output is 0.25 dB > that at the lowest data rate for the default a-b/g mode test channels Proposed FutureGuidelines Only

17. 802.11 WLAN Devices 4.) Turbo modes (proprietary modes) typically operate at higher data rates requiring higher order modulations & lower average power. Turbo, half & quarter rate channels should be tested at the lowest data rate used in each proprietary mode when the average output is greater than that on the closest default a-b/g mode channels. Proposed FutureGuidelines Only

18. 802.11 WLAN Devices 5.) Switched Diversity Issue. The SAR of each antenna should be measured independently on the highest output channel in each a-b/g mode. Other channels should be tested only when the SAR vary by > 25% for the two antennas on highest output channel or > 1.2 W/kg. Proposed FutureGuidelines Only

19. 802.11 WLAN Devices 6.) MIMO Type Devices. FCC is developing Procedures. These are likely to involve simultaneous TX conditions and Proposed FutureGuidelines Only

20. 5 GHz SAR The FCC has expressed that review of SAR for devices in the 3 – 6 GHz range will hopefully be released to TCBs soon. However exact dates have not been released.

21. PCMCIA Cards For PCMCIA Cards with antennas external to the host device, the FCC is considering possible changes to their current testing requirements. 1) The 3 host policy that is typically required in certain situations may change for depending on certain acceptable margins to ensure compliance for variations among typical laptops. Proposed FutureGuidelines Only

22. PCMCIA Cards 2) The FCC is also considering test methods with use an extender card instead of a typical laptop computers and compare these measurements to those made in a typical host. Proposed FutureGuidelines Only

23. Proposed Changes The FCC also expects that any new procedures required for SAR measurements will likely also have a transition period associated with them. This is subject to be determined depending on the future release of information from the FCC.

24. FCC/TCB Training Bulletins HAC for cellphones is mandatory on for 25% of a carriers product line HAC test procedure already exists. TCBs are able to review HAC soon.

25. FCC/TCB Training Bulletins 5GHz SAR not yet released to TCBs. Notice will come in the form of a R&O Training material is in preperation

26. FCC/TCB Training bulletins SAR testing for WiFi products is being further refined. More emphasis on test software used inside WiFi transmitter and defining its characteristics. FCC will require more documentation of software, especially on/off transmitter timing characteristics.

27. FCC/TCB Training Bulletins No agreement yet on DFS testing for 802.11a. Testing with NTIA / FCC on proposed new procedure has been scheduled for November. FCC hopes to get revised DFS Test Procedure to TCBs before end of year.

28. FCC/TCB Training Bulletins Field Programmability to add DFS to existing 802.11a radios prohibited unless radio is Certified as a SDR. Factory programmability allowed using the Class II change procedure.

29. FCC/TCB Training Bulletins DFS products must go to FCC SDR products must go to FCC ***A DFS testing exclusion exists for client equipment which is under the control of a Certified access point. ***Ad-Hoc mode for clients prohibited

30. FCC/TCB Training Bulletins FCC has provided further guidance on MIMO and steered array antennas. Specific guidance is offered from FCC on Pout measurements, RF Exposure calculations, radiated Restricted Band measurements.

31. FCC/TCB Training Bulletins FCC will now allow Class II changes for RF category Portable to Mobile to be handled by TCBs.

32. FCC/TCB Training Bulletins GPS repeaters are not permitted in USA. GPS spectrum is carefully protected. No Part 15 Intentional Radiators are permitted. Reference: See 15.205

33. Questions? whgraff@atcb.com major@atcb.com jerry@atcb.com