Speaking as the keynoter at the EMC meeting in York, UK, last July 12th, Kerry praised the growth of EMC standards—particularly the European Union's EMC directive—during the 1990s. He cited as important achievements the introduction of generic standards and the acceptance of immunity testing as "not just for the military anymore."

Kerry noted, however, that this growth has not come without its own set of problems. "There are lots of standards now," he said, "and more coming," due in large part to IEC requirements. But at the same time, he said, the EMC SLIM directive is asking for fewer standards.

In some respects, the past is haunting current EMC standards. This resulted in part, Kerry said, because "we consulted manufacturers, but not design engineers—who are the ones working on future products." EMC standards today, he continued, are based on past traditions, such as open-area test sites, and do not adequately reflect current test technologies or product frequencies. "We have noncoherent standards, and I don't think we can carry on that way for long," he said.

Outlining his vision for future EMC development, Kerry identified six key challenges: technology convergence, increasing frequencies, digital EMC, EMC limits, network EMC, and EMC education.

"Everybody's talking about tech convergence," Kerry noted, "but nobody knows quite what it is." The core of the problem, as Kerry described it, is the expansion of electronic components into an increasing number of common appliances. Thus a television, a refrigerator, and a computer all may share the same environment, but each has its own standard.

As clock speeds increase, so do frequencies. For Kerry, the question to be addressed is how high standards should go, and at what cost. "We've got to minimize the cost of testing to industry while protecting up to 18 GHz—but not for all products." Similarly, Kerry said, digital EMC introduces new concerns. The rise of digital radio will lead to increased digital interference, and that will require the development of new test methods.

Addressing what he called "a very touchy subject," Kerry said that he becomes "defensive" about the issue of EMC limits. "I believe we've got to look at having realistic limits. Should we move to generic limits? I personally believe that generic standards have a big future." Current standards, Kerry asserted, "aren't that good," but form a basis for improvement. There is an ongoing need to define protection levels for various products, he added, but development of these levels must go hand in hand with increasing consumer awareness of the problems.

Standards for products, Kerry stated, are not sufficient by themselves. The "missing link" is network standards. "It is no use connecting two [compliant] products together," he argued, "and then assuming that there is no problem with EMC." The answer, he continued, will entail design and installation guidelines.

For all the work that remains to be done with standards, Kerry indicated that the greatest challenge lies in another area altogether—education. "I believe it is the key for the future," he said, "and that we have to put a lot more effort into it." As EMC issues become more widespread, the educational need is not for EMC specialists, but for a much broader constituency. Indeed, Kerry predicted that soon "there will not be EMC engineers, but engineers with strengths in EMC." In addition, installation and maintenance engineers, who have traditionally had little training in EMC issues, will be obliged to pay them more attention.

Above all, Kerry concluded, the public must be educated. Standards alone cannot succeed, he implied, until the public is persuaded that they simply "cannot use all their gadgets everywhere."

On August 17, 1999, the FCC's Office of Engineering and Technology (OET) issued Public Notice DA 99-1640, providing further information on the accreditation requirements for telecommunication certification bodies (TCBs). Initial accreditation requirements for TCBs were specified in the Commission's Report & Order (R&O) adopted on December 17, 1999 (FCC 98-338; GEN Docket 98-68), which amended FCC Parts 2 and 68 of the rules to allow private-sector entities to issue equipment authorizations. Under current rules, the Commission must issue equipment approvals.

A significant provision of the Public Notice governs TCB acceptance of test data, subcontracting, and TCB auditing requirements. Under this requirement, a TCB is allowed to accept test data from a manufacturer or independent laboratory for equipment certification. The TCB is also permitted to perform the product testing itself, or to subcontract a portion or all of the required testing to an independent laboratory. TCBs remain responsible for the tests and are required to maintain oversight of the subcontractor and to perform periodic surveillance activities, including product compliance testing.

Other major provisions relate to the FCC's TCB designation process and qualification criteria. Under the new requirements, TCBs must be accredited to ISO/IEC Guide 65 (1996), General requirements for bodies operating certification systems, and ISO/IEC Guide 25, General requirements for the competence of calibration and testing laboratories. TCBs must be accredited by the National Institute of Standards and Technology (NIST), or by a NIST-approved accrediting body. It is anticipated that NIST will issue a
Federal Register Notice to announce the acceptance of applications from organizations interested in providing these accreditation services.

TCBs must also be capable of testing equipment to a core set of equipment tests for each equipment accreditation scope, according to the notice. TCBs can certify to one or more of the following equipment scopes:

A. Unlicensed Radio-Frequency Devices

While TCBs are not required to have the capability to perform each required test, they must possess the minimum testing capabilities specified for each type of equipment.

Accreditation and designation of a TCB to certify licensed PCS and UNII devices and to determine RF exposure for hand-held transmitters has been withheld until the FCC has published the appropriate procedures. Both U.S. and foreign entities are allowed to become TCBs.

Copies of the documents are available at http://www.fcc.gov/Engineering_Technology/
Orders/1998/fcc98338.pdf/ and at http://www.fcc.gov/Bureaus/Engineering_Technology/
PublicNotices/1999/da991640.do.