Some companies have attacked the Type Approval design problem in ways which are typical of production organizations suddenly faced with the requirement to incorporate a new discipline into their engineering capabilities. There is often a great deal of frantic activity by everyone, all trying to "contribute" by applying their pet ideas and intuitive concepts. There are exceptions, of course. Some companies understand that the concepts involved in the identification, location, and suppression of sources of electromagnetic emissions is an ability which comes from extensive engineering experience. If that capability did not exist in-house, they either brought it in, or hired a consultant. But others have gambled on the ability of one of their technicians or engineers to come up with some sort of miraculous fix, even though the individual had little or no experience, let alone a properly equipped laboratory. Today the FCC feels that the biggest single problem with the Games Industry is that companies come to them without either the requisite background of in-house expertise, or the support of an independent test laboratory which is both competent, knowledgeable, and properly equipped for the peculiarities of the Part 15 test procedures.
Considering the potential marketing impact of production holdups due to refusals of Type Approval by the FCC, there is little question that each company in the Industry must have access to competent engineering and well-equipped testing facilities, not only during the initial design phase and Type Approval exercise, but also during full production. There are two ways to obtain these capabilities. First, you can establish them in-house. To do this requires three things: (1) An experienced EMI engineer, (2) up to $75,000 of initial capital equipment expenditure, and (3) lab space and some sort of area for "open field" tests. To attempt to do the job by simply hiring an EMI engineer (or an EMI consultant) without giving him the tools is as unrealistic as expecting one of your design engineers to "pick it up" by reading a few articles and books.
The second approach to achieving Type Approval is to utilize the services of an independent test lab. Unfortunately, there are few labs which are properly equipped for this type of work. In order to be able to provide a high level of assurance that a particular game will, when submitted to the FCC, yield the same test results that the lab obtained, the lab must use the same equipment and procedures used by the FCC. Even then , because of the high degree of subjectivity in some of the test setups (especially in the radiated emission test), and variations in characteristics of the test equipment itself (especially in the signal line conducted test), there is still an unacceptably high chance that a game deemed "acceptable" by the lab's data will fail the FCC's Type Approval test. This is a very poor situation, and one that can be corrected only by concerted action on the part of the Industry to improve the applicable sections of the FCC's Rules and Regulations.
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