ACA EMR Standard 2003: Compliance with Australian Regulations

Chris Zombolas

Australia has expanded the scope of its regulations concerning exposure to electromagnetic radiation to capture a wider range of mobile and portable transmitting equipment used close to the body.

The use of mobile and portable transmitting equipment (MPTE) has grown exponentially recently, with consumer MPTE that is operated in close proximity to the human body proliferating. To ensure that workers and the general public are protected from exposure to radio-frequency (RF) electromagnetic radiation (EMR), most countries have regulations that limit personal exposure to RF fields generated by RF transmitters operated very near the body. Human RF-exposure guidelines and evaluation methods for portable and mobile devices differ according to the proximity of the device to exposed individuals.

Devices used very close to the body are evaluated against limits for specific absorption rate (SAR). Devices not used in such proximity may be evaluated with respect to reference levels or maximum permissible exposure (MPE) limits for power density.

To market MPTE legally in Australia, suppliers must comply with the provisions of the Australian Communications Authority (ACA) regulations on EMR and SAR. The regulatory arrangements include RF EMR human exposure limits, evaluation criteria, three SAR measurement methods, and labeling requirements.

ACA has progressively extended the scope of its EMR regulations to capture a broader range of MPTE. It now covers most devices used at the ear or otherwise in close proximity to the body. Since March 1, 2003, the ACA EMR testing and approval requirements have been mandated by the Radiocommunications (Electromagnetic Radiation–Human Exposure) Standard 2003 (known as the ACA EMR standard or EMR Standard 2003) and the Radiocommunications (Compliance Labeling–Electromagnetic Radiation) Notice 2003 (known as the ACA EMR Labeling Notice).1,2

The ACA EMR standard applies to all devices that operate between 100 kHz and 100 GHz and that have an integral antenna. It mandates, for specified radiocommunications transmitters, the EMR exposure limits and the EMR evaluation criteria of the standard published by the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA).3 The ARPANSA standard has adopted the recommendations of the International Commission on Non-Ionizing Radiation Protection (ICNIRP).4 It replaces the previous interim standard AS/NZS 2772.1.5

When a product requires evaluation against the SAR limits, the evaluation must be performed using the guidelines and procedures prescribed by EMR Standard 2003.

This article details the steps necessary for MPTE to be approved to the ACA EMR requirements for marketing in Australia. The EMR regulations and SAR measurement methodologies also are discussed.

Exposure Categories

Referring to field strength, power density, and SAR requirements, the ARPANSA exposure standards define two categories of exposure upon which the guidelines are based. They recommend exposure limits for occupational/controlled/aware users and for general-population/uncontrolled/unaware users. The compliance requirements for each category are based on a person's awareness of his or her exposure and ability to exercise control over it.

Occupational/Controlled/Aware Exposure. In general, occupational/controlled exposure limits are applicable to situations in which people are exposed to RF EMR as a consequence of their employment and where they have been made fully aware of the potential for exposure and can exercise control over their exposure. This category also comprises situations when the exposure is transient, caused by incidental passage of radiation through a location so as to create exposure levels that may be higher than the general-population/uncontrolled limits, but where again the exposed person is fully aware of the potential for exposure and can exercise control over the situation by leaving the area or by some other effective means. If appropriate, warning signs and labels can be used to establish such awareness by providing prominently displayed information on the risk of potential exposure and instructions on methods to minimize exposure risks.

General-Population/Uncontrolled/Unaware Exposure. Limits in this category apply in situations in which the general public may be exposed or in which people who are exposed as a consequence of employment may not be made fully aware of the potential for exposure or cannot exercise control over their exposure. Members of the general public would come under this category when exposure is not employment related, for example, in the case of a wireless transmitter that exposes any people in its vicinity. The category also includes pregnant workers.

Warning labels placed on low-power consumer devices such as cellular telephones and walkie-talkies are not considered sufficient to allow the device to be included in the occupational/controlled category. The general-population/uncontrolled exposure limits apply to those devices.

Exposure Limits in Australia

The ARPANSA standard specifies limits of human exposure to RF fields in the frequency range of 3 kHz to 300 GHz, which are intended to prevent adverse health effects. These limits are defined in terms of basic restrictions on exposure of all or a part of the human body. However, these mandatory restrictions are specified as quantities that are impractical to measure. Therefore, reference levels–unperturbed ambient electric and magnetic fields, induced limb currents, and contact currents–that involve quantities that are more practical to measure are provided as an alternative means of showing compliance with the basic restrictions. Reference-level measurements are usually performed with a power-density or field-strength meter. In particular, the ARPANSA standard specifies:

• Basic restrictions for occupational exposure (see Table I below) with corresponding derived reference levels as a function of frequency (see Table II).

• Basic restrictions for general public exposure (see Table I) with corresponding derived reference levels as a function of frequency (see Table III).

• Equipment and usage parameters to assist in the determination of compliance with the standard.

Table I. ICNIRP/ARPANSA guidelines: basic restrictions for SAR.

Limits for Localized Exposure or Spatial Peaks. When a transmitting device is operated in close proximity to the body, whole-body exposure does not occur. The RF exposure causes localized heating of the part of the body that is very near the transmitting device. EMR Standard 2003 increased the SAR limit for localized exposure from 1.6 W/kg (measured in a 1-g tissue mass) to 2.0 W/kg (measured in a 10-g tissue mass). The basic restrictions for whole-body exposure remain unchanged.Certain MPTE used under controlled circumstances by employees of such organizations as the police department, who have been trained to be aware of and to limit potential exposure, is assessed under the occupational limits or the aware-user provisions of the ARPANSA standard. Such MPTE devices are allowed exposure limits five times higher than the MPTE intended for use by the general public.

International SAR Limits. As can be seen in Table IV, it is not possible to determine worldwide SAR compliance by testing to one limit or one standard. Manufacturers and suppliers in Australia must ensure that MPTE meets the SAR limits by testing to one of the ACA test methods.

The ACA EMR Standard

The ACA EMR standard applies to mobile stations. The term mobile station has replaced the term mobile and portable transmitting equipment that was used in the old standard, which has been superseded by the 2003 standard. A mobile station is defined as a "radiocommunications transmitter that is established for use: (a) in motion, on land, water, or in the air; or (b) in a stationary position at unspecified points on land, water, or in the air." Examples given are a wireless modem operating in a laptop computer and a handheld cellular or personal communication system (PCS) telephone with a radiating antenna in the handpiece.

Scope. The scope of the ACA EMR standard encompasses virtually all devices operating within 300 kHz to 100 GHz. ACA has broadened the scope of the SAR requirements to capture more handheld and portable devices such as push-to-talk (PTT) radios, wireless local-area network (WLAN) cards for laptop computers, wireless EFTPOS (electronic funds transfer point-of-sale) terminals, and body-worn and similar devices having integral antennas and used within 20 cm of the body. (EMR requirements for licensed transmitters are regulated under a different legislative instrument, the ACA Licence Condition Determination 2003.)

Reference-Level Measurements Acceptable. Devices operating further than 20 cm from the human body do not require SAR evaluation. However, they must comply with the ARPANSA reference levels (analogous to the FCC MPE limits) over the modified frequency range of 0.3 MHz to 100 GHz (see Tables II and III). Evaluation against the reference levels is simpler and more cost-effective than SAR measurement because a conventional power-density meter is used to perform the measurements.

SAR Evaluation Necessary. Devices operating at frequencies between 300 kHz and 100 GHz, transmitting an average of more than 20 mW of RF power, and used within 2.5 cm of the body require SAR evaluation to demonstrate compliance. Devices used at distances up to 20 cm from the human body and exceeding the power threshold specified in Table III also require SAR evaluation.

While ACA has harmonized the SAR limits with those of Europe for devices used at the ear, the FCC measurement method is used for all other devices. The ACA EMR standard contains three SAR measurement methods

• Schedule 1, known as the old ACA SAR measurement standard.6

• EN 50361, the European SAR measurement standard for mobile phones or devices used at the ear.7 The limits are specified in the product standard EN 50360.8

• Schedule 2, based on FCC SAR guidelines for devices used at the ear or within 20 cm of the human body.9,10

Schedule 1

Schedule 1 is limited to devices used at the ear and operating in the range of 800-2500 MHz. The ARPANSA standard sets the basic restrictions for human exposure and references the measurement and calculation procedures of the standard AS/NZS 2772.2;11 however, actual SAR measurement procedures are not specified in these standards.

Prior to the publication of internationally harmonized SAR standards, ACA published its own SAR measurement standard. This so-called old standard was based on the work of the International Electrotechnical Commission (IEC) and the Institute of Electrical and Electronics Engineers (IEEE), and represented current best practice for SAR measurement methodology. It was updated and included as Schedule 1 in the latest revision of the ACA EMR standard in order to facilitate a smooth transition to the new standards. It expires on March 1, 2005, after which only Schedule 2 or EN 50361 may be used.

Schedule 1 specifies the SAR evaluation procedures, though not precisely. It covers test system specifications, SAR measurement probes, test sample positioning, test conditions, properties of phantoms, and the assessment of measurement uncertainty and report requirements.

Compliance Criteria. The time- and spatially averaged SAR value must not exceed the SAR limits specified in the ARPANSA standard for each of the test positions and possible operating conditions of the mobile phone. The phone is tested in the touch position only, for the right and left sides of the head. Each test position and configuration must be tested at three frequencies, high, low, and middle, for each band and mode, with antenna retracted and extended. This means that a dual-band global system for mobile communications (GSM) phone with a fixed antenna will require at least 12 SAR scans, while a triple-band (dual-band GSM/code-division multiple-access [CDMA]) phone with extendable antenna will require 36 scans.

The test report must provide SAR distribution plots of localized SAR for all test positions, conditions, and frequencies. The sample complies if no SAR result exceeds 2 W/kg. ACA does not require an allowance to be made for measurement uncertainty when determining compliance with the SAR limit.

Phantom Properties. Two types of phantom are specified in the ACA standard, though other suitable phantoms may be used. The thickness of the phantom shell must be less than 3 mm, and the thickness at the ear position must be 6 mm. The more recently developed specific anthropomorphic mannequin (SAM) phantom specified in the latest SAR measurement standards EN 50361 and IEEE 1528 may be used.12

Tissue-Simulating Liquid. The dielectric properties of the tissue-simulating liquid for the homogeneous phantom head are given in Table V. These values are significantly different from those given in the European and FCC SAR standards. The higher values for permittivity and lower values for conductivity will result in lower SAR values than those that would be obtained using the dielectric values specified by other SAR measurement methods. Also, note that the tolerance for conductivity is 10% versus 5% for the other standards.

Measurement Variability. As mentioned, the old ACA SAR limit of 1.6 W/kg measured in a 1-g cube of tissue has now been increased to 2 W/kg measured in a 10-g cube of tissue. Evaluation of the 10-g SAR produces SAR values lower than those obtained with a 1-g tissue mass. The net effect of the latest changes is that, because measured SAR values will now be significantly lower, mobile phones that were previously noncompliant could now be compliant.

EN 50361 SAR Measurement Method

EN 50361 is a European harmonized basic standard for SAR measurements on mobile phones and similar devices used near the ear and operating in the frequency range of 300 MHz to 3 GHz. In Europe, compliance with the product standard EN 50360 may be used to demonstrate compliance with the essential safety requirements (relevant to human exposure) of the European Radio & Telecommunications Terminal Equipment Directive and Council recommendation 1999/519/EC.13,14

ACA also will accept test method EN 50361. The test report, produced by an accredited test laboratory, must include the specific requirements detailed in Section 8 of EN 50361. The method may not be used to test devices not used near the ear, for example, PTT radios and WLAN cards. (Schedule 2 must be used for such devices.)

Test Sample Configuration. The mobile phone is tested against the phantom in the cheek and tilted positions that are precisely defined in the standard and identical to FCC requirements. The phone is set for center-frequency channel at maximum transmitting power, and the SAR is measured in both tilted and cheek positions on the left and right sides of the head. The position of highest SAR on each side of the head is then tested for the upper and lower frequencies of the band. If the phone has a retractable antenna, all of these tests are performed both with the antenna extended and retracted. The entire process is repeated for each transmitting band and each operating mode.

The SAR plot for each test condition must be included in the report along with the other report requirements specified in Section 8 of the standard.

SAM Phantom. The specific anthropomorphic mannequin is based on dimensions selected from a large anthropomorphic database of male humans. The thickness of the phantom shell is specified to be 2.0 mm ± 0.2 mm except at the ear reference point, which shall be 6.0 mm ± 0.2 mm. The SAM material must have low-loss and low-permittivity characteristics. The SAM phantom is also specified by the FCC and ACA Schedule 2 measurement methods.

Tissue-Simulating Liquid. The dielectric properties of the tissue-simulating liquid are shown in Table V. Linear interpolation is used to obtain dielectric properties at other, intermediate, frequencies. Examples of recipes to obtain the stated values are given in the standard. The deviation of the permittivity and conductivity must be within ±5% of the target values.

Measurement System Validation. The SAR measurement system calibration is checked in two ways: a simplified performance check is made before each SAR measurement, and a system validation check is conducted at least once annually.

Simplified Performance Check. A simplified performance check is carried out to verify that the system operates within its specifications. It is a basic test that checks measurement repeatability to ensure that the compliance test is performed correctly. It checks for possible drift due to changes in liquid parameters caused by water evaporation or temperature change, and for performance changes due to component failures, drift, or operator errors in software parameter setup. Power at a known level is fed into a standard dipole source antenna positioned against a reference phantom filled with a reference liquid.

The measured 10-g SAR must be within 10% of the actual calibrated value. The results of the simplified performance check, including the SAR plot, must be included in the test report.

System Validation Test. The definition of system validation in EN 50361 is different from the definition in IEEE 1528. EN 50361 system validation tests the SAR measurement system against the known SAR values of selected standard reference phones. System validation data must be gathered at least once per year.

Schedule 2

The ACA EMR standard's Schedule 2 may be used to test for the compliance of devices used at the ear and those used within 20 cm of any part of the human body (body-worn devices) and that transmit in the frequency range of 150 MHz to 5.8 GHz. This method captures virtually all transmitting devices that were previously exempt from the regulations.

Schedule 2 was largely drawn from Appendices B, C, and D of FCC Office of Engineering and Technology Bulletin 65C, Supplement C.10 Compliance by means of SAR computation is excluded. An important difference is that the ACA SAR evaluation must be performed in a 10-g tissue mass while the FCC requirement calls for a 1-g tissue mass. Devices covered by Schedule 2 include mobile phones, PTT transmitters, body-worn transmitters, WLAN transmitters in laptop computers, and, generally, all transmitting devices used within 20 cm of the human body that transmit RF power at levels exceeding the ARPANSA threshold levels. The evaluation criteria are displayed in Table VI and Figures 1 and 2.

Figure 1. Evaluation criteria for products involving occupational exposure.

The measurement methodology is very similar to the EN 50361 method. Schedule 2 will generally be equivalent to EN 50361 but not to Schedule 1. The test setup and configuration of mobile phones and devices used at the ear are the same as in EN 50361; however, additional setup information for testing body-worn devices is provided. Schedule 2 prescribes use of the SAM head phantom, along with additional body (flat) phantoms for testing devices not used at the ear. The head/brain dielectric properties are equivalent to those in EN 50361, with minor deviations. The schedule gives the dielectric properties of body- and muscle-tissue-simulating liquids as well.

Test Sample Configuration. The cheek and tilted positions are specified for devices used at the ear. Body-worn and PTT devices are tested against a flat phantom. Each frequency band is tested for the upper, middle, and lower frequencies. Devices having an operating bandwidth of less than 10 MHz need only be tested at the center frequency. For WLAN laptop PCs, a total of three SAR scans is usually sufficient. The highest operating-duty factor should be used for the SAR evaluation. The tests are repeated for each operating mode and battery type. Battery droop or power drift must be factored into the final SAR result. Accessories such as headsets and microphones should be connected as in normal use and positioned against the flat phantom.

The setup for multimode devices is not the same as in the FCC method. Schedule 2 describes special tests for devices where the difference between the highest output of a low-output mode and the lowest output of the highest-output mode is more than 2 dB.

Figure 2. Evaluation criteria for products involving nonoccupational exposure.

Head and Body Phantoms. The SAM head phantom is specified for devices to be tested at the ear. Body-worn devices are tested against a flat phantom made of low-loss dielectric material of 2.0-mm thickness with a uniformity of ±0.2 mm. The length and width of the flat phantom should be at least twice the corresponding dimensions of the device under test, including its antenna. The depth of the liquid should be 15.0 cm ± 0.5 cm.

Tissue Dielectric Parameters. The head and body tissue dielectric parameters used by Schedule 2 are shown in Table VI. These dielectric parameters are slightly different from the EN 50361 values. Fine-tuning of the liquid parameters will allow the same liquid to be used for both EN 50361 and Schedule 2. The tissue dielectric values for the center frequency of the transmission band should be within 5% of the target value. The values in the table should be linearly interpolated when testing at other frequencies within the band. Because it is difficult to achieve the 5% tolerance at some frequencies, the use of 10% tolerance is allowed as an interim measure. (EN 50361 does not offer this relaxation.)

Measurement System Verification. Schedule 2 system verification tests are identical to those of the FCC method. System verification is necessary to check and track the performance of the SAR measurement system. A flat phantom and precision dipole-radiating source are specified to determine whether the measurement system meets its performance requirements. System verification checks should be performed daily within each frequency band of the test sample. The verification frequency must be within 100 MHz of the device transmitting frequency. The measured 10-g SAR must be within 10% of the target values for the specific phantom and transmitting antenna used.

Reference Phantom for System Verification. A special reference phantom of low dielectric loss and minimum dimensions is specified. The reference phantom should be at least 0.75 * long and 0.5 * wide, where * is the wavelength of the reference dipole frequency. The measured 10-g SAR must be within ±10% of the actual target calibrated reference value. Target SAR values are normally applicable only to specific matched combinations of reference dipoles and reference phantoms. A summary of these specifications is given in Schedule 2.

Measurement Uncertainty. Schedule 2 requires the documentation of measurement uncertainty for both SAR evaluations and SAR system verification. Full details must be provided in the test report. The measurement uncertainty does not have to be considered in determining compliance with the SAR limit. However, it must not exceed 30%.

Report Requirements. Schedule 2 lays down exhaustive requirements regarding data to be included in the test report. Unlike electromagnetic compatibility (EMC) regulations, the data to be provided within the SAR report are specified, and they are required for compliance.

The ACA Labeling Notice

The ACA EMR Labeling Notice contains administrative requirements for manufacturers and importers of equipment covered by the ACA EMR standard. Suppliers, whether manufacturers or importers, must label devices to indicate that they meet the requirements of the mandated standards. The labeling notice specifies three levels of compliance and two device categories.

In order to determine whether a device falls into category A or category B, its output power level, duty factor, and separation distance from the body must be identified and matched against the compliance provisions of Schedule 5, Table S1, of the ARPANSA standard.

Category A Devices. A device in this category is an aware- or unaware-user device that does not require evaluation under Section 5.2 or Section 5.3 of Schedule 5 of the ARPANSA standard because it meets the criteria of the test exemption column of Table S1. A category A device is deemed by the ARPANSA standard to comply without testing. Compliance is nevertheless mandatory, and a declaration of conformity (DoC) must be completed.

Category B Devices. A category B device is an aware- or unaware-user device that is not a category A device. It does not fit within the test exemption column of Table S1 of Schedule 5 of the ARPANSA standard. In order to establish compliance for category B devices, evaluation by means of power-density meter or spatial-peak SAR measurement must be performed.

Devices Excluded from the ACA EMR Standard. RF welders and similar apparatus, otherwise known as industrial, scientific, and medical (ISM) RF equipment, are not included within the scope of the ACA EMR regulations. In Australia, human exposure to ISM RF equipment falls under the jurisdiction of the state governments and is mandated through National Occupational Health and Safety Commission regulations. (ACA regulates RF interference from ISM equipment through the C-Tick regulations.)

Also excluded from the scope of the ACA EMR standard are RF identification device fixed stations, field-disturbance transmitters, and similar devices not transmitting RF for radiocommunications purposes. MPTE used in law enforcement, by state and federal agencies, or by the military are exempt from the ACA EMR regulations. These agencies, however, often impose their own specific EMR SAR requirements.

Compliance Level 1. Compliance level 1 applies to category A devices. Examples of compliance level 1 MPTE are analog cordless phones, remote-control toys, electronic garage- door openers, low-power WLANs, laptop computers, and WLAN PCMCIA cards, among other devices. Category A devices must transmit average RF power of no more than 20 mW or meet the nonevaluation criteria of Schedule 5, Table S1. No testing is required before labeling compliance level 1 MPTE because such equipment cannot by definition exceed the ARPANSA limits and hence does not require evaluation. A category A device may be marketed after a description of it has been prepared, a DoC has been completed, and the device has been labeled with the C-Tick or A-Tick as appropriate. It is important to note that all devices falling within the scope of the ACA EMR standard must now be labeled with a C-Tick and that a DoC must be completed.

Compliance Level 2. Compliance level 2 applies to category B devices for which the normal position of use is more than 20 cm from the body. To satisfy compliance level 2, the supplier must comply with the level 1 requirements and show conformity with the ACA EMR standard through a test report of the results of reference-level measurements conducted in accordance with AS/NZS2772.2, usually with a power-density meter. The test report must indicate compliance with the applicable exposure limits given as reference levels in tables 7 and 8 in Section 2.4 of the ARPANSA standard. Devices that fall within the boundaries of compliance level 2 are, for example, WLAN access points, cordless-phone base stations, computer WLAN cards, certain laptop computers, and similar unlicensed transmitters in which the radiating antenna is more than 20 cm from the body.

Compliance Level 3. This compliance level covers category B devices for which the normal position of use is not more than 20 cm from the body. Compliance for a Level 3 device is established by means of SAR evaluation. To fulfill compliance level 3, the supplier must comply with level 1 requirements and show conformity with the ACA EMR standard through a test report of the results of tests conducted in accordance with the appropriate SAR measurement method, whether Schedule 1, Schedule 2, or EN 50361. Compliance must be established in accordance with the spatial-peak SAR limits given in Table I, and the test report must be issued by a test laboratory specifically accredited for SAR measurements according to Schedule 1, Schedule 2, or EN 50361. Level 3 devices fall into two groups: devices used not more than 2.5 cm from the body and transmitting an average power level of more than 20 mW (in cases where the user is unaware) or more than 100 mW (for aware users), and devices used not more than 20 cm from the body and transmitting an average power level exceeding the threshold levels of Table VI.

Assessment Test Report

The ACA EMR Labeling Notice specifies the data to be included in the test report. The test report must contain a description of the measurements or evaluation methods used; results of the measurements or evaluations, including the data; and an unequivocal statement of whether or not the device tested complied. Compliance level 3 devices must be tested by a laboratory that is accredited to conduct the appropriate SAR tests. This accreditation must be granted by the National Association of Testing Authorities (NATA) or by an international body that has a mutual recognition agreement (MRA) with NATA. MRA partner accreditation bodies include the (U.S.) National Voluntary Laboratory Accreditation Program, American Association for Laboratory Accreditation, United Kingdom Accreditation Service, German Accreditation Council, and more than 30 other international bodies.

Compliance Recordkeeping

The compliance records must be kept for five years from the date of last sale of the product. They must be in English, may be kept in electronic form, and must be kept at the principal business address of the supplier in Australia. The compliance record must include:

• A signed DoC.

• The description of the device.

• The test report, including an unequivocal statement of compliance of the device and its variants.

• Identification of variants and evidence that the variants do not exceed the exposure levels of the device.

Device Variants

Variants of an MPTE device may be included on the same DoC and compliance record. Technical justification for compliance of the variant must be made in writing, must identify the variant, and must describe the difference between device and variant in sufficient detail to show that the variant is essentially the same device. While cosmetic changes involving different dielectric materials can be presumed not to degrade EMC performance, their effect on SAR is less predictable and not intuitively obvious. In general, any of the following may require the SAR to be reevaluated:

• Changes to the geometry of the device.

• Changes to the types of material used in the construction of the phone, keyboard, display, etc.

• The use of different dielectric materials in the vicinity of the antenna/transmitter circuitry, particularly when the permittivity of the material is higher.

• Changes in the operating frequency or increases in transmitted power.

• Changes in the location or alignment of the antenna.

• Changes to the displays.

• The use of alternative battery types, particularly when voltage is increased, even slightly.

• Changes to the antenna, including the fitting of so-called radiation reduction devices or performance enhancement devices.

This list of circumstantial changes is not comprehensive.

Product Labeling

The labeling of compliance level 1 products is voluntary under the EMC regulations but mandatory under the EMR labeling notice. (Compliance in any case is mandatory, however.) All level 2 and level 3 products must be labeled appropriately before they can be marketed. The required label consists of either the C-Tick mark or its alternative, the regulatory compliance mark (RCM), or else the A-Tick mark for telecommunications devices. In New Zealand, the A-Tick mark does not signify compliance with telecom standards as it does in Australia.

In addition to the relevant, applicable compliance mark, each label must also contain acceptable supplier identification. If it is not practical to attach a label to the exterior of a device, the label may be attached alternatively in the following order of preference:

1. To the outer surface of the packaging; or, if impractical,

2. To instructions for use; or, if impractical,

3. To the guarantee or certificates.

These labeling options may be used only with the written permission of ACA or, in New Zealand, the economic development ministry's Radio Spectrum Management Group (RSM). A valid reason must be given to explain why it is not practical to label the product itself.

C-Tick. The C-Tick is a certification trademark registered to ACA under the Trade Marks Act of 1995 and to RSM under Section 47 of the NZ Trade Marks Act. The mark must be used in accordance with its governing regulations and is therefore issued only to an Australian or New Zealand-based supplier. The label is expected to be durable and limited in its size, scale, and color according to the regulations.

A-Tick (Telecommunications Standards). All products subject to the Australian Telecommunications Labeling Notice must also meet the requirements of an EMC standard such as AS/NZS CISPR 22. The A-Tick mark indicates compliance with both the EMC and telecommunications requirements in Australia, but with only EMC requirements in New Zealand. The requirements for conducted emissions on telecom ports have been deferred by the revised EMC regulations until 2005 to be consistent with the Official Journal of the European Union.

Regulatory Compliance Mark. The RCM is a trademark owned by Australian and New Zealand regulators and is an alternative to the C-Tick. This mark signifies compliance with all the applicable regulatory standards, including EMC. Suppliers intending to use the RCM should register with Standards Australia in accordance with AS/NZS 4417.1 and complete the application form in AS/NZS 4417.3. The RCM is not an alternative mark to the A-Tick telecommunications compliance mark.

Supplier Identification. In addition to one of the marks, product labels must include the identification of the manufacturer, importer, or agent. In Australia, one of the following must be on the label:

• A business name and address in Australia.

• A business name registered on the national business register.

• A personal name and address in Australia of the place of business.

• An Australian company number (ACN).

• An Australian registered body number (ARBN).

• An Australian business number (ABN).

• An Australian registered trademark.

The supplier code number issued by ACA on application.

In New Zealand, one of the following options must appear on the label:

• The registered name and address of the licensee.

• A New Zealand company number of the licensee.

• A New Zealand registered trademark of the licensee.

• A registered goods and services tax (GST) number.

• The supplier code number issued by RSM on application.

Use of Marks. The C-Tick and A-Tick marks are protected symbols to be used only with the written permission of ACA and in accordance with conditions specified by that authority. The EMR labeling requirements are the same as for C-Tick labeling under the ACA EMC Framework. EMR devices connecting to the public switched telephone network must be labeled with the A-Tick. The C-Tick or A-Tick label, as appropriate, may be applied by the manufacturer, importer, or authorized representative either in Australia or overseas after obtaining written permission from ACA.

Audit Provisions

ACA conducts audits on a random basis and also in response to complaints. On written request from ACA, a company must produce compliance records within 10 days. If the records do not provide sufficient evidence that the device is compliant, the authority may request that the supplier provide a test report from an accredited test laboratory. When the compliance of a product is called into question, the ACA auditor may ask the registered supplier to provide, within 10 days, three samples of the product for testing by a NATA-accredited laboratory nominated by ACA.

Conclusion

In Australia, virtually all transmitting devices used in close proximity to the human body must comply with EMR Standard 2003 and the ACA EMR Labeling Notice. They must be evaluated against the SAR or reference-level exposure limits of the ARPANSA standard in accordance with the ACA SAR measurement method or by measurements conducted in accordance with AS/NZS 2772.2. MPTE operating within 20 cm of the body and meeting the SAR evaluation criteria must be tested for compliance against the ARPANSA aware- or unaware-user SAR limit.

The new regulatory arrangements allow manufacturers flexibility in choosing a method for SAR evaluation of MPTE destined for Australian markets. By using accredited testing, the self-declaration approval path ensures rapid time to market. Suppliers in Australia must ensure that evidence of fulfillment of administrative requirements and the prescribed documentation are available for examination by an ACA auditor.

References

1. "Radiocommunications (Electromagnetic Radiation--Human Exposure) Standard 2003" (ACA EMR Standard) (Melbourne: Australian Communications Authority, March 2003).[Au: Is city of publication correct? Ditto for Ref. 2.]

2. "Radiocommunications (Compliance Labeling--Electromagnetic Radiation) Notice 2003" (Melbourne: Australian Communications Authority, March 2003).

3. "ARPANSA Radiation Protection Standard No. 3: Maximum Exposure Levels to Radio-Frequency Fields--3 kHz to 300 GHz" (Sydney: Australian Radiation Protection and Nuclear Safety Agency, 2003).

4. International Commission on Non-Ionizing Radiation Protection (ICNIRP), "Guidelines for Limiting Exposure in Time-Varying Electric, Magnetic, and Electromagnetic Fields (up to 300 GHz)," Health Physics 74 (1998): 494-522.

5. AS/NZS 2772.1 (interim), "Radio-frequency fields, part 1, Maximum exposure levels 3 kHz to 300 GHz," (Sydney: Standards Australia, 1998).

6. ACA EMR Standard Schedule 1. ACA test method: "Specific Absorption Rate Test Method Using Phantom Model of Human Head (1): 2001."

7. EN 50361:2001, "Basic standard for the measurement of specific absorption rate related to human exposure to electromagnetic fields from mobile phones (300 MHz to 3 GHz)" (Brussels, CENELEC, 2001).

8. EN 50360:2001, "Product standard to demonstrate the compliance of mobile phones with the basic restrictions related to human exposure to electromagnetic fields (300 MHz-3 GHz)" (Brussels: CENELEC, 2001).

9. ACA EMR Standard Schedule 2, "[SAR] Measurement method for devices 20 cm or less from the human body; Information for documenting compliance."

10. FCC, Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields, OET Bulletin 65, ed. 97-01; Supplement C to OET Bulletin 65, ed. 01-01 (Washington, DC: Office of Engineering and Technology, FCC, 2001).

11. AS/NZS 2772.2:1988, "Radio-frequency radiation, Part 2: Principles and methods of measurement–300 kHz to 100 GHz," (Sydney: Standards Australia, 1988).

12. IEEE 1528:2003, "Recommended Practice for Determining the Peak Spatial-Average Specific Absorption Rate (SAR) in the Human Head Due to Wireless Communications Devices: Measurement Techniques," (New York: Institute of Electrical and Electronics Engineers, 2003).

13. "Directive 1999/5/EC of the European Parliament and of the Council of 9 March 1999 on radio equipment and telecommunications terminal equipment and the mutual recognition of their conformity," Official Journal of the European Communities no. L 91/10, April 7, 1999.

14. "Council recommendation 1999/519/EC of 12th July 1999: Limitation of exposure of the general public to electromagnetic fields (0 Hz to 300 GHz)," Official Journal of the European Communities no. L199, July 30, 1999.

Chris Zombolas is technical director of EMC Technologies Pty Ltd. (Melbourne, Australia). He can be reached at chris@emctech.com.au.