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TCB Survey

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Title: TCB Survey


1
TCB Survey
Art Wall awall_at_atlanticbb.net
2
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

3
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

4
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?

5
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

6
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

7
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

8
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

9
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

10
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

11
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)

12
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.

13
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

14
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

15
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

16
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

17
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

18
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

19
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

20
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

21
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)

22
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

23
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

24
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

25
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)

26
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

27
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

28
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

29
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

30
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

31
Thank You
  • Art Wall
  • Radio Regulatory Consultants, Inc.
  • awall_at_atlanticbb.net
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