Products today come with dozens of warnings that few people actually read. If the item includes digital circuitry – almost everything does, nowadays – the manual is supposed to include a warning mandated by the FCC. Digital circuits emit radio waves as by-product, and so have the potential to cause interference to radio communications. The FCC not only sets limits on these stray emissions, but also mandates specific warning text for the product’s instruction manual. The required wording first alerts the user to the possibility of interference. The warning for consumer devices (“Class B,” in FCC-speak) goes on to suggest specific ways to fix interference to radio or TV reception. The text for commercial and industrial devices (“Class A”) just warns against operating in residential areas.
Minnesota-based Multi-Tech Systems makes a device that attaches to an office phone system for routing cell-phone calls to and from people’s desktops. It is a Class A device that contains digital circuitry. Multi-Tech duly went through of the required procedures to ensure the stray emissions are within bounds. AT&T successfully tested the device to ensure compatibility with its cell network. With all needed approvals in place, Multi-Tech shipped several hundred units.
The trouble started with a complaint that the product was causing interference to other electronic equipment, particularly speakers and telephone landlines. Some people would just ask Multi-Tech to fix the problem or send a refund. But this party instead went to the FCC. After investigating, the FCC concluded the Multi-Tech product was unlikely to have caused the reported interference. Case closed.
The FCC’s investigators noticed the required interference warning was missing from the instruction manual. In this case, though, the warning would not have helped with the alleged interference. The warning deals only with interference to radio communications, while the complainant cited interference to non-radio equipment. Besides, this was a Class A device properly being used in offices, so the Class A warning against residential use would have been pointless.
Still, managing to salvage something for its efforts, the FCC fined the manufacturer $4,000 for having left out the warning.
Four thousand dollars strikes us as a large fine for violating a rule that, when complied with, has little or no practical effect. Moreover, this is the first time in the rule’s almost-30-year history that the FCC has penalized anyone for violating it. True, when acting against an entity that has ignored its regulations, the FCC sometimes throws in this violation along with other counts. But never before has it moved against a company on this violation alone.
Vendors: check your manuals. We provide the required language below.
The following language (or a “similar statement”) is required in the instruction manuals of most products that incorporate digital circuitry.
For Class A devices:
Note: This equipment has been tested and found to comply with the limits for a Class A digital device, pursuant to part 15 of the FCC Rules. These limits are designed to provide reasonable protection against harmful interference when the equipment is operated in a commercial environment. This equipment generates, uses, and can radiate radio frequency energy and, if not installed and used in accordance with the instruction manual, may cause harmful interference to radio communications. Operation of this equipment in a residential area is likely to cause harmful interference in which case the user will be required to correct the interference at his own expense.
For Class B devices:
Note: This equipment has been tested and found to comply with the limits for a Class B digital device, pursuant to part 15 of the FCC Rules. These limits are designed to provide reasonable protection against harmful interference in a residential installation. This equipment generates, uses and can radiate radio frequency energy and, if not installed and used in accordance with the instructions, may cause harmful interference to radio communications. However, there is no guarantee that interference will not occur in a particular installation. If this equipment does cause harmful interference to radio or television reception, which can be determined by turning the equipment off and on, the user is encouraged to try to correct the interference by one or more of the following measures:
— Reorient or relocate the receiving antenna.
— Increase the separation between the equipment and receiver.
— Connect the equipment into an outlet on a circuit different from that to which the receiver is connected.
— Consult the dealer or an experienced radio/TV technician for help.