WIRELESS COMPLIANCE

Design for Compliance: A Tool for Reducing Time-to-Market

Gordon Hurst

Compliance can be used to accelerate time-to-revenue in wireless product development.

Consider Company A. A well-known global wireless communications company, Company A was ready to announce its new platform of radios for wireless network interconnection. The engineering was expert, producing a platform of products in multiple frequencies that featured innovations set to outperform similar equipment on the market. Projections from marketing determined that the product was a good year ahead of the competition. Plans were made to send each frequency product to the lab for testing against product-specific standards for compliance certification. It was at this point that Company A learned that globally

recognized standards did not yet address the product's technology for spectrum use and efficiency. Testing could not begin until standards were revised. The company launched an aggressive lobbying of the standards bodies and eventually placed the product on the market—nine months later.
 
It is an understatement to say that today's global market for electronics and communications products is competitive. Multiple suppliers are vying for opportunities. Simultaneously, product life cycles are shortening in the face of accelerating innovation and earlier product replacements. For businesses to succeed in this environment of compressed windows for revenue generation, it is as important to release products quickly as it is to deliver technical excellence.

As with Company A in the case study above, product compliance is often viewed as a project step occurring near the end of the product development process. As shown, however, the attention given to compliance issues directly affects a company's ability to meet schedules for timely product delivery.

In addition, market surveillance inspections—the practice in many countries of performing random compliance checks on products being sold—are intensifying. Ensuring that products meet compliance standards throughout a product's entire life cycle is essential.

Consider Company B. Company B's wireless system had completed a full suite of compliance testing and was certified in many countries. At some point during the system's life cycle, an oscillator vendor decided to change a specification, introducing faster rise times. Engineers were delighted with the change, as component counts reduced and reliability increased. Management was similarly happy with the obvious cost reductions. The system change was implemented and the product continued to ship globally. Some months later, however, a potential client discovered that harmonics generated as a result of the faster rise times caused the system to fail radiated emission limits. Needless to say, the potential client purchased equipment from the competition.

Situations such as those described in these brief case studies for Company A and Company B give evidence that it is imperative to understand, consider, work within, and plan for product compliance from the very earliest stages of product development and throughout the life of the product. Such devastating situations underscore the need for a design for compliance program, which would be implemented through an effective compliance management plan. These scenarios also emphasize that the compliance program must be an integral part of the product design cycle—not a separate or follow-along plan.

Compliance: An Interactive Environment

It is important to understand that compliance does not hinder innovation. Rather, innovation influences the compliance environment. Interaction between product development and compliance is key. For Company A, it was the failure to recognize the partnership between compliance and innovation that led to its error in planning. The mistake then sacrificed the company's advantage of time in its product release program.

Figure 1 illustrates the interaction of product development with compliance from the very initial stages of product discovery through the term of a product's production. At the point of product discovery, for example, a company's marketing group assesses needs for new products among its customer groups in various markets, and it prepares the product requirements documentation.

At this stage of discovery, there also should be discovery of existing compliance standards regulating or affecting the product being considered. It is imperative to highlight discontinuities between technologies or product plans and the standards that shape the environment in which the product will be sold. Likewise, if standards do not yet exist for the product concept, the early identification of this gap allows time for corrective action during the design stage. Wireless regulations and compliance issues also can be complex, even for the simplest of products. State-of-the-art, innovative development programs may indicate the need to change core standards or regulations—something that requires careful planning.

Figure 1. The questions to be considered at each stage of compliance.

As with this first step in product development, compliance issues affect each subsequent step of the product development and deployment process—enabling or otherwise impacting the development, delivery, or sustainability of products in the market. As the wireless market continues to evolve, the industry can expect to see the emergence of new compliance requirements and technologies. This calls for continuous due diligence in the monitoring of the regulatory environment.

Implementation of a design for compliance strategy must be a significant objective of the overall product development goal of the manufacturer. Success requires commitment on the part of management to allocate resources in the beginning of a project, so that targeted benefits can be realized. In start-up environments or in companies with downsized staffs, this may require contracting with compliance management consultants. Investment in this area protects the company's product development investments in the longer term.

Compliance Management Plan

Success with a design for compliance program requires performance to an effective compliance management plan. The following section outlines basic rules and guidelines for a program aimed at realization of the design for compliance benefits detailed in Table I.
In the compliance management plan, consideration of several fundamental components is essential:

• Regulatory environment.
• Compliance testing.
• Product compliance certification processes and procedures.
• Requirements for ongoing compliance through a product life cycle.

Regulatory Environment

Research of the regulatory environment for new products takes time, but the rewards can be significant. Researchers first need to ask where and to whom the product will be marketed. The answers to these questions will help determine whether existing standards meet the needs of the product being developed (see the sidebar "Regulatory Environment: Key Considerations" below).

Compliance Testing

It is important to view compliance testing as a natural progression along the road to generating revenue for the company. In this light, compliance testing is a validation of internal processes. It should not be seen, as it is by many, as the "final hurdle" of obligation before a product can ship out the door.

Selection of the appropriate test laboratory is critical. This selection can impact the core of a company's promise of quality to its customers, and it plays a crucial part in a company's future success. As a compliance partner, a compliance testing laboratory should be capable of bringing more than just testing to the table. A true partner should bring a background in all aspects of regulatory standards, compliance management, testing and reporting, and certification.

Creation of a suitable test strategy, which can be difficult and extremely confusing, is one area in which the compliance partner should be able to assist. Identification of test cases is crucial to the success of a product. There are a number of relevant points to consider before undertaking a full complement of compliance testing:

• Identification of all product variants.
• Compilation of documentation package.
• Formulation of test configurations and system setups.
• Definition of the following items:
• Degree of pretesting required.
• Requirements for customized testing software.
• Product environmental conditions.
• Performance degradation criteria.
• Handling of compliance failures.

Product Variants

Identification of product variants may initially seem straightforward; however, if multiple vendors manufacture critical components, the process becomes more complicated. This is especially true if multiple locations are used for the manufacturing of the same product.

It is critical to identify the number of different vendors supplying critical subsystems or components (e.g., transceivers). Product manufacturing locations (if more than one) must also be identified. In addition, the number of variants (technical differences) and test candidates must be specified. Note: not all variants require complete compliance testing; partial testing can be accepted provided that a solid rationale is well documented.

Documentation Package

Prior to the start of testing, it is important to compile a complete documentation package. This information (or a subset thereof) will be requested by many interested parties (e.g., test laboratories, certification authorities, clients, and OEMs). Compilation at this stage saves time, and it can help to ascertain cases in which information is not readily available. Documentation will consist of, but not be limited to, the following items:

• Detailed product description, including environmental criteria.
• Schematics, assembly drawings, and bills of materials.
• Software revisions.
• Product manual, including installation, operation, and
maintenance instructions.

Test Configurations and System Setups

Creating a list of all tests, and identifying test setups and the variants selected, is the next step. Following this, it is important to determine all ancillary equipment required for each test. If products operate with an integral antenna, for example, it is possible to consider providing a connector (suitable RF type) for conducted measurements and an integral antenna for radiated measurements (mandatory).

It is important to note that European standards demand measurement of receiver parameters (performance and interference criteria). A suitable test setup is required for this type of measurement. Receiver testing can be extremely difficult, if not impossible, when testing products using an integral antenna.

Complete Compliance Testing

An entire test program consists of several elements: precompliance testing, customized software, environmental conditions, performance degradation criteria, and compliance failures.

Precompliance Testing. In an ideal world, all variants would be fully tested prior to the complete compliance program; however, in practice, this may not be the case. Risk assessment helps minimize the degree of pretesting. If pretesting is conducted in-house, it is important to ensure calibration integrity of all test equipment. Many engineers have experienced occasions when out-of-calibration test equipment has been used for pretesting, only to propagate subsequent problems. It is important to log all results and test configurations, because these will be used to validate full compliance measurements.
Customized Software (When Necessary). Some wireless technologies can require a limited level of customizable software in order to achieve complete compliance testing. In many cases, the following parameters must be individually selectable: frequency channels (low, middle and high), data rate (if several to choose from), output power, and modes of operation.

Environmental Conditions. The environmental test conditions must be fully defined. These include temperature range (nominal, minimum, and maximum), humidity range, and voltage range (ac or dc)—nominal, minimum, and maximum (+ve or –ve polarity). For battery-operated systems, it is also necessary to ensure that the methodology is available to vary the voltage level.

Performance Degradation Criteria. European immunity testing demands that manufacturers declare performance degradation criteria. Keep in mind that simply declaring, "Maintains the link," does not define system degradation. With the proliferation of multiple wireless products, system degradation is becoming an increasingly important parameter.

Compliance Failures. Knowing how compliance failures will be handled during pretesting or complete compliance is essential. A strategy specifying the company's process for handling failures needs to be considered. For example, will the component or subassembly be replaced, or will this problem be fed back into the company quality management system for failure investigation and corrective action at the source?

Product Compliance Certification

With the conclusion of the complete compliance testing and resolution of outstanding compliance issues, the test reports, together with a signed Declaration of Conformity (DoC), become integral components of the documentation package. These items are used in the application for product compliance certification.

Ongoing Compliance

With compliance testing complete and certification procurement under way, the danger is in thinking that product compliance issues can now be put on the back burner or forgotten about altogether. This is not the case. Passing of formal testing by selected samples does not imply that all manufactured products will exhibit similar characteristics. Remember also that in certain countries, the manufacturer must sign a DoC indicating that all products—not just those that were tested on a one-off basis—will comply with the essential requirements.

Characteristics can and do change in the manufacturing process, and these changes need to be managed on an ongoing basis. (Remember Company B.) Ongoing compliance is without doubt the least controlled and most misunderstood area in most manufacturing companies; nonetheless, it is the most important aspect of managing life cycle compliance.

Risk Assessment

Difficult decisions must be made when addressing ongoing product compliance issues. Clearly, risk assessment is an integral part of the process. Consider the following two common situations:

• Component obsolescence—implementation of engineering change order (ECO). Does component obsolescence or vendors changing component specifications sound familiar? The standard design-review process would assess system performance based on the proposed change.
• Decision making—ensuring ongoing compliance. Who in the company is responsible for decisions regarding impacts on ongoing compliance and the degree that retesting would be required? If ongoing compliance is not affected by a change, what happens to the next and subsequent ECO implementations? Will decisions be made based on isolated ECOs or considered along with others not triggering a retest?

Because of situations such as those described above, it is important to consider including a regulatory compliance section in the ECO documentation trail. The following should be addressed as a minimum: potential effects on regulatory compliance, parameters at risk, risk analysis, degree of retesting (proposed test suite), retest results, and anticipated and actual cost of testing.

The situation described in the case study of Company B could have developed into something much worse. It also could have been avoided altogether if attention had been given to ongoing compliance in the ECO process. Control and implementation of a strategy addressing ongoing compliance further minimize the risk of being caught by market surveillance authorities. Such a strategy significantly reduces company liability.

Conclusion

The worldwide market is placing ever-growing demands on mandatory compliance. With shorter product life cycles, an increasingly complex and evolving wireless regulatory environment, and company financial constraints, today's compliance personnel are facing considerable challenges. However, the adoption of a design for compliance program, implemented through use of an effective compliance management plan, is one area in which excellent opportunities exist to increase product revenues, improve corporate image and reputation, and decrease company liability.

The time spent up front in defining and planning a product compliance strategy will be the most important event in the product life cycle. This early investment will reap benefits in reducing time-to-market and accelerating time-to-revenue with new product introductions.

A design for compliance philosophy for wireless product development and product-life management has many elements: consideration of the regulatory environment, compliance testing, product compliance certification, and ongoing compliance. These elements, and the way in which they are planned, scheduled, and supported throughout the product life cycle, dictate the level of success of the product and, to a greater extent, the success of the company. An early investment in the compliance cycle will reap rewards in profitability, competitive advantage, and market share growth.

A significant part of any successful compliance management program is the selection of an accredited wireless compliance test facility. The selection process can at best be difficult; however, once a suitable compliance partner has been appointed, the partner should bring more than just test expertise to the table. The right partner should be qualified not only through experience in compliance testing, but also through a thorough familiarity with the regulatory environment and with certification and ongoing compliance requirements. With this background, the compliance partner can provide valuable input to the overall success of a design for compliance program.

Gordon Hurst, BSc, CEng, MIEE, is the founder, president, and CEO of MiCOM Labs, an accredited wireless compliance laboratory headquartered in Pleasanton, CA. He has more than 15 years in wireless product development and global regulatory compliance management, having been general manager of StatestLabs and director of regulatory compliance for Stratex Networks Inc . He has served on the ETSI technical bodies in developing wireless standards and on the U.S. Fixed Wireless Communications Coalition (FWCC). He can be reached at gordon_hurst@micomlabs.com.