Consultation on New Requirements for Wireless Device Testing … · 2017. 9. 1. · 10. Submitting comments ... business and public institutions. Consultation on New Requirements

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SMSE-011-17

August 2017

Spectrum Management and Telecommunications

Consultation on New Requirements for Wireless Device Testing Laboratories

Consultation on New Requirements for Wireless Device Testing Laboratories SMSE-011-17

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Contents 1. Intent ........................................................................................................................................ 3 2. Mandate ................................................................................................................................... 3 3. Legislation ............................................................................................................................... 3 4. Policy objective ....................................................................................................................... 3 5. Background .............................................................................................................................. 4 6. Proposed changes to accreditation bodies for non-MRA countries ........................................ 5 7. Proposed changes to testing laboratories ................................................................................. 6 8. Proposed scope of accreditation requirements for testing laboratories ................................... 7 9. Proposed transition period and renewal period for accreditation of testing laboratories ........ 8 10. Submitting comments ............................................................................................................ 8 11. Obtaining copies ..................................................................................................................... 9 Annex A—Procedure for the recognition of accreditation bodies for non-MRA countries ......... 10 Annex B—Procedure for the recognition of foreign testing laboratories ..................................... 14 Annex C—Testing laboratory technical assessment checklist ..................................................... 21 Annex D—Proposed changes to related documents ..................................................................... 26


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1. Intent

1. The purpose of this consultation is to seek comments on proposed changes to the conformity assessment process related to wireless equipment subject to certification (Category I equipment). 2. In this document, Innovation, Science and Economic Development Canada (ISED or the Department) is seeking comments related to conformity assessment on proposed:

• changes to allow accreditation bodies to be recognized by ISED and perform accreditation to testing laboratories located in non-MRA countries;

• changes to ISO/IEC 17025, General requirements for the competence of testing and calibration laboratories scope of accreditation for testing laboratories; and

• transition period and renewal period for the accreditation of testing laboratories. 3. Following the consultation, applicable technical standards and conformity assessment procedures may be updated accordingly.

2. Mandate 4. The Minister of Innovation, Science and Economic Development, through the Department of Industry Act, the Radiocommunication Act and the Radiocommunication Regulations, with due regard to the objectives of the Telecommunications Act, is responsible for spectrum management in Canada. As such, the Minister is responsible for developing goals and national policies for spectrum resources use and for ensuring effective management of the radio frequency spectrum resource.

3. Legislation 5. The Minister of Innovation, Science and Economic Development is provided the general powers for spectrum management in Canada pursuant to section 5 of the Radiocommunication Act and sections 4 and 5 of the Department of Industry Act. Under the Radiocommunication Act, the Minister has the power to establish standards, rules, policies and procedures with regards to radiocommunications, including technical aspects related to broadcasting. The Governor in Council may make regulations with respect to spectrum management pursuant to section 6 of the Radiocommunication Act; these regulations have been prescribed under the Radiocommunication Regulations.

4. Policy objective 6. A thriving wireless telecommunications industry drives the adoption and use of digital technologies and enhances the productivity of the Canadian economy and its international competitiveness. We are proposing measures that will enhance our already robust certification process for the benefit of Canadian consumers, business and public institutions.

https://www.iso.org/standard/39883.html


http://laws.justice.gc.ca/eng/acts/I-9.2/index.html

http://laws.justice.gc.ca/eng/acts/R-2/FullText.html

http://laws.justice.gc.ca/eng/regulations/SOR-96-484/index.html


http://laws-lois.justice.gc.ca/eng/acts/t-3.4/



http://laws.justice.gc.ca/eng/acts/I-9.2/index.html



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7. In developing this consultation paper, ISED has been guided by the policy objectives of the Telecommunications Act, and the Spectrum Policy Framework for Canada (SPFC), which states that the objective of the spectrum program is to maximize the economic and social benefits that Canadians derive from the use of the radio frequency spectrum resource. These objectives and enabling guidelines, as listed in the SPFC, remain relevant for guiding ISED in delivering its spectrum management mandate. Through the Innovation and Skills Plan and its focus on people, technologies and companies, the Government of Canada is committed to promoting innovation-led growth across all sectors of the Canadian economy. Today’s economy is digital. The ubiquity of digital technologies and services across sectors is a defining feature of this digital economy. A world-class communications infrastructure, including equipment, can create a platform for sustainable growth, allowing Canadian companies to take advantage of the latest technologies to better compete globally. Consequently, ISED’s objective for the release of this consultation is to:

• enhance quality, competency and efficiency of wireless testing laboratories to prepare for the next generation of technologies (e.g. 5G, Internet of Things, etc.);

• promote innovation with fair and open markets; and • support deployment and timely availability of robust wireless equipment.

5. Background

8. Compliance with domestic technical standards is necessary in order to prevent radiocommunication interference, and harm to the Canadian public telecommunications networks, and to ensure the safety of users. All wireless devices entering Canada must meet the applicable ISED technical standards and labelling requirements. 9. Manufacturers, importers, distributors and vendors have a legal obligation to ensure that wireless devices deployed in the Canadian marketplace have been certified or comply with Canadian technical standards, and that the equipment sold in the Canadian marketplace continues to meet those standards during the entire product life-cycle. 10. There are many stages in the end-to-end regulatory process for the certification of wireless products. The stages typically include: manufacturers designing their product to meet ISED’s technical standards requirements; testing the product by a testing laboratory; submitting test results to a recognized certification body; and publishing the certified products on ISED’s Radio Equipment Listing (REL). Furthermore, market surveillance is carried out to verify that products in the marketplace continue to comply with relevant standards. 11. As part of the conformity assessment regime, the accreditation process demonstrates that testing laboratories are technically competent and able to produce precise and accurate test results and calibration data. The accreditation of testing laboratories is a rigorous process involving an extensive review of documentation and on-site visits by representatives of an accreditation body. This well-established process is repeated at regular intervals, normally every two years, and is based on a standard developed by the International Standard Organization (ISO/IEC 17025, General requirements for the competence of testing and calibration

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laboratories), and endorsed by the Standards Council of Canada. In Canada, wireless testing laboratories are required to demonstrate the general requirements described in the ISO standard, and be registered with ISED. 12. Wireless products are becoming more prevalent on the market. The increasing complexity of the equipment and the intricacies of the regulatory requirements demand more technical expertise from stakeholders involved in the conformity assessment process. Accredited testing laboratories generally submit higher quality test reports, therefore providing greater confidence in the competencies of these testing laboratories to perform compliance assessments to domestic technical rules. 13. Other countries have recently implemented accreditation requirements for testing laboratories. For instance, the Federal Communications Commission (FCC) has released new rules1 requiring that all wireless and radio frequency (RF) exposure testing laboratories be subject to a recognition requirement based on accreditation, effective June 12, 2017. In line with other countries, the Department is proposing to further strengthen the conformity assessment process by mandating the accreditation of testing laboratories performing compliance measurements to ISED’s technical standards for wireless devices.

6. Proposed changes to accreditation bodies for non-MRA countries 14. In the past, most countries including Canada, required telecommunications equipment to be tested and certified within their own territories. With the globalization of trade in telecommunications equipment, exporters considered it redundant to conduct conformity assessment in the importing country since these assessments were already performed in the exporting country as part of the testing and production processes. As such, Mutual Recognition Agreements/Arrangements (MRAs) were implemented to expedite the trade of telecommunications equipment. 15. MRAs have enabled the participating countries to mutually recognize the competence of each other’s testing laboratories and certification bodies through accreditation bodies (AB) and subsequently, mutually accept the conformity assessment results (test reports and certification). This expedited the approval process and resulted in faster times to market and savings in regulatory compliance costs for manufacturers, thereby reducing product costs for consumers. 16. Currently, numerous testing laboratories for wireless products are located in non-MRA countries. To ensure these testing laboratories can continue to perform compliance testing towards ISED technical standards for wireless products and therefore not impact trade, the Department is proposing to recognize accreditation bodies able to perform the accreditation of these testing laboratories. 17. The proposed Procedure for the recognition of accreditation bodies for non-MRA countries in annex A of this document describes the criteria and procedure for the recognition of

1 FCC Report and Order (FCC 14-208) and Memorandum Opinion and Order and Order on Reconsideration (FCC 16-74).


https://apps.fcc.gov/edocs_public/attachmatch/FCC-14-208A1.pdf




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AB by ISED to perform accreditation of testing laboratories to ISO 17025 in non-MRA countries.

A. ISED seeks comments on: 1. Proposed procedure to recognize accreditation bodies in non-MRA countries

(annex A)

7. Proposed changes to testing laboratories 18. To ensure that Canada continues to have a world-class telecommunications infrastructure, it is crucial that wireless devices sold on the Canadian market meet our technical standards in order to prevent radiocommunication interference and be safe for Canadian use. Maintaining a robust compliance assessment process is key in ensuring that equipment meets regulatory requirements. 19. Therefore, ISED is proposing to further strengthen its conformity assessment scheme related to certification by requiring testing laboratories to be accredited to the latest ISO/IEC 17025 by a recognized accreditation body and be recognized by ISED to perform measurements to Radio Standards Specifications (RSS) and Broadcasting Equipment Technical Standards (BETS). 20. In order to be recognized by the Department, testing laboratories would have to follow the latest recognition procedure for foreign testing laboratories Procedure for the Recognition of Designated Foreign Testing Laboratories (REC-LAB) and designation procedures for Canadian testing laboratories Procedure for Designation and Recognition of Canadian Testing Laboratories (DES-LAB). 21. The proposed procedure in annex B of this document describes the criteria and procedure for recognition by ISED of foreign testing laboratories to test to Canadian requirements for wireless products. The procedure for recognition of Canadian testing laboratories (DES-LAB) will be updated with the same requirements. 22. In addition, a proposed technical assessment checklist in annex C of this document ensures specific items are evaluated during the assessment of test laboratories by a recognized accreditation body. This checklist would need to be submitted to the Department as part of the recognition process. 23. With the above proposed changes, other related documents will need to be updated. ISED has compiled a table in annex D listing documents that would be impacted.


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B. ISED seeks comments on: 1. Proposed procedure for recognition of testing laboratories (annex B) 2. Proposed technical assessment checklist (annex C) 3. Changes to other documents related to the accreditation of testing laboratories

(annex D)

8. Proposed scope of accreditation requirements for testing laboratories 24. To ensure that testing laboratories can be specialized in certain areas of testing, ISED is proposing a minimum scope of accreditation based on specific Radio Standards Specifications (RSS) and Broadcasting Equipment Technical Standards (BETS). For instance, a testing laboratory may choose to be accredited to a single RSS or BETS. In terms of RSS standards, every RSS refers to RSS-GEN, General Requirements for Compliance of Radio Apparatus (with the exception of RSS-102, Radio Frequency (RF) Exposure Compliance of Radiocommunication Apparatus (All Frequency Bands)). Therefore, testing laboratories wishing to be accredited to any RSS, other than RSS-102, must also have RSS-GEN in their scope of accreditation. 25. For example, a lab specialized in testing Radio Local Area Network (RLAN) equipment would have RSS-GEN and RSS-247, Digital Transmission Systems (DTSs), Frequency Hopping Systems (FHSs) and Licence-Exempt Local Area Network (LE-LAN) Devices as a minimum on the scope of accreditation. 26. In the case of RF exposure, RSS-102 covers different types of assessments requiring distinct specialized test equipment depending on wireless equipment under test. With a view of keeping the scope to a minimum, the Department is proposing to split the accreditation to RSS-102 in the following three (3) categories:

− RSS-102 (SAR or specific absorption rate) − RSS-102 (RF exposure evaluation ) − RSS-102 (NS or nerve stimulation)

27. The above suggested split will allow testing laboratories to choose and obtain accreditation based on their specific area of expertise.







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28. As a summary, below are sample scopes of accreditations that may be sought out by testing laboratories. Laboratory 1 Laboratory 2 Laboratory 3 Laboratory 4 Laboratory 5 RSS-102 (SAR) RSS-GEN RSS-GEN BETS-1 RSS-102 (SAR) RSS-102 (NS) RSS-210 RSS-247

RSS-102 (SAR)

C. ISED seeks comments on: 1. Proposed scope of accreditation for testing laboratories 2. Recommendation on any other RSS or BETS that should be split in separate

categories

9. Proposed transition period and renewal period for accreditation of testing laboratories 29. ISED proposes a six (6) month transition period following the publication of a decision and relevant procedures related to this consultation to allow testing laboratories sufficient time to acquire their accreditation. Furthermore, ISED proposes that each test laboratory renew their accreditation every two (2) years. 30.

D. ISED seeks comments on: 1. Proposed transition period of six (6) months following the publication of the

decision and relevant procedures 2. Proposed accreditation renewal period every two (2) years for testing laboratories

10. Submitting comments 31. ISED invites interested parties to submit their comments (in Microsoft Word or Adobe PDF) to the following email address: ic.consultationradiostandards-consultationnormesradio.ic@canada.ca.

32. In addition, respondents are asked to specify comment numbers for ease of referencing (e.g. C.1).

mailto:ic.consultationradiostandards-consultationnormesradio.ic@canada.ca



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33. All submissions should cite the Canada Gazette, Part I, the publication date, the title and the notice reference number (SMSE-011-17). Parties should submit their comments no later than 60 days after its publication, to ensure consideration. 34. ISED will also provide interested parties with the opportunity to reply to comments from other parties. Reply comments will be accepted 30 days following the posting of all comments received on the ISED website.

11. Obtaining copies 35. All spectrum-related documents referred to in this paper are available on the Spectrum Management and Telecommunications website at www.ic.gc.ca/spectrum. 36. For further information concerning the process outlined in this document or related matters, contact: Director of Regulatory Standards, Engineering, Planning and Standards Branch Innovation, Science Economic Development Canada 235 Queen Street (6th Floor, East Tower) Ottawa, Ontario K1A 0H5 Telephone: 613-797-2253 Fax: 343-291-1269 Email: ic.consultationradiostandards-consultationnormesradio.ic@canada.ca




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Annex A—Procedure for the recognition of accreditation bodies for non-MRA countries

1. Purpose This annex describes the criteria and procedure for the recognition of accreditation bodies (AB) by Innovation, Science and Economic Development Canada (ISED) to perform accreditation of testing laboratories to ISO/IEC 17025 in non-MRA countries.

2. Definitions Accreditation: a procedure by which an authoritative body gives formal recognition that a body or person is competent to carry out specific tasks. Accreditation body (AB): an authoritative body that performs accreditation to conformity assessment bodies by assessing them against international voluntary standards. Certification: an attestation by a recognized certification body that a product conforms to specified ISED requirements. Certification body (CB): a recognized independent organization that conducts certification of radiocommunication equipment to Canadian regulatory requirements. Conformity assessment body: a body engaged in the performance of procedures for determining whether the relevant requirements in technical regulations or standards are fulfilled. Testing laboratory: responsible to determine the applicable test procedures and to properly test to those requirements.

3. Related documents The following documents as well as other information can be found on ISED’s Spectrum Management and Telecommunications website. DES-LAB—Procedure for Designation and Recognition of Canadian Testing Laboratories REC-LAB—Procedure for the Recognition of Designated Foreign Testing Laboratories

4. Introduction ISED administers the equipment authorization program under authority delegated to it by the Minister. This program is one of the principal ways ISED ensures that telecommunication, radiocommunication and digital devices used in Canada operate effectively without causing

http://www.ic.gc.ca/spectrum





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harmful interference and otherwise comply with ISED’s technical requirements. All telecommunication, radiocommunication and digital devices subject to equipment authorization must comply with ISED’s technical requirements prior to its distribution, lease, offer for sale, sell or import. ISED’s telecommunications and radiocommunications equipment regulatory process requires that equipment be authorized in accordance with one of three schemes:

a) Supplier’s Declaration of Conformity (sDoC) b) Declaration of Conformity (DoC), or c) Certification

The specific provisions of the three schemes apply to various types of devices based on their relative likelihood of causing harmful interference, human exposure to radio frequency, protection to the network and the significance of the effects of such interference from the particular device at issue. To be ISED-recognized, a laboratory must first be accredited by an ISED-recognized accreditation body2 as meeting applicable international standards and comply with the requirements with REC-LAB – Procedure for the Recognition of Testing Laboratories in Canada. This document describes the procedures for the recognition of such accreditation bodies to perform accreditation services in non-MRA countries.

5. Accreditation body recognition procedure for non-MRA countries The basic criteria that ISED will use to determine the acceptability of new accreditation bodies in non-MRA countries is specified in this procedure. Under this procedure, an applicant must submit information that demonstrates how it satisfies the requirements of each of the four elements listed below. To ensure the continued integrity of the accreditation program, ISED will periodically review the accreditation process and maintain close coordination with each of the organizations that it has recognized to perform accreditations. The following procedure will be used by an accreditation body seeking to be recognized by ISED as an accreditation body.

1. Submit request. An applicant must submit a written request for such recognition to IC and provide the information described below.3

2. General information. The accreditation body provides general information about its organization, including: (a) contact information

2 A future list of recognized accreditation bodies allowed to perform accreditation services in non-MRA countries will be available on the ISED web page. 3 The application for the recognition of an accreditation body may be submitted electronically to the Manager, Telecom Equipment Regulatory Requirements, Engineering, Planning and Standards Branch.


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(b) a general description of the organization (c) description of the scope of work for which it is seeking recognition

(d) the specific country in which the accreditation body is seeking to perform laboratory

accreditations for ISED’s technical requirements

(e) evidence that it is authorized by the government in each country to operate and perform accreditation services including accredit testing laboratories to ISED requirements

(f) legal constraints, if any, with regards to the accrediting body’s authorization to

operate in the specific country in which it plans to perform accreditations (i.e. has the required licenses and approvals necessary to operate a business)

(g) evidence of ability to perform assessments in each country it plans to accredit testing

laboratories. The accreditation body must describe the process it will use to address laboratory performance issues, including the withdrawal or suspension of the accreditation of a testing laboratory

(h) description of the process the accreditation body will use to designate testing

laboratories

3. Technical qualifications. In order to demonstrate its credentials and qualifications to

perform accreditation of testing laboratories to ISED requirements, an applicant shall provide, at a minimum, evidence of: (a) successful completion of the latest ISO/IEC 17011, “Conformity assessment –

General requirements for accreditation bodies accrediting conformity assessment bodies” peer review, such as being a signatory to an accreditation agreement that is acceptable to ISED.4 The accreditation body must describe the procedures it has in place to ensure the impartiality and objectivity of its activities as required by 4.3 of ISO/IEC 17011 (for example, the accreditation body shall not offer or provide conformity assessment services that CABs perform, consultancy activities, or any other service that would affect its impartiality).

(b) expertise and capability to accredit electromagnetic compatibility (EMC), of radio

testing laboratories to the latest ISO/IEC 17025, “General requirements for the competence of testing and calibration laboratories.”

4 Examples of laboratory accreditation body arrangements (agreements) include the: International Laboratory Accreditation Cooperation (ILAC); European co-operation for Accreditation (EA); Asia Pacific Laboratory Accreditation Cooperation (APLAC); Inter-American Accreditation Cooperation (IAAC).


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(c) accreditation personnel/assessors with specific technical experience to ISED’s technical requirements.

4. Decision. ISED will make a determination of recognition based on the information provided in support of an application. Upon meeting the above requirements, ISED will recognize and maintain a list of recognized accreditation bodies on its webpage.

6. Disclosure of information ISED will not disclose the application status for recognition to any third party until the recognition process has been completed.

7. Disclaimer The recognition of an accreditation body by ISED does not imply or otherwise suggest the recognition of a testing laboratory or that the recognized accreditation body is an agent or representative of ISED. ISED does not accept any responsibility for the effects or consequences of services provided by the recognized accreditation body for users of such services.

8. Retaining recognition During operations as a recognized accreditation body, the accreditation body shall continue to meet the requirements of this document and shall maintain its accreditation status. The accreditation body shall provide evidence of its accreditation status and scope upon request by ISED. The accreditation body will be recognized for a period of two years after which time renewal of recognition using this document should be sought. Accreditation bodies shall not advertise their recognition status that is outside the scope of their recognition.

9. Suspension or withdrawal of recognition The accreditation body is required to take immediate corrective action to ISED’s satisfaction, if required. Where it is found after a review that a recognized accreditation body does not comply with the requirements of this procedure, the recognition may be withdrawn. An accreditation body whose recognition has been suspended or withdrawn will be removed from the list of recognized accreditation bodies on the ISED website.


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An accreditation body whose recognition has been suspended or withdrawn shall cease advertising its recognition.

Annex B—Procedure for the recognition of foreign testing laboratories 1. Purpose This annex describes the criteria and procedure for recognition by Innovation, Science and Economic Development Canada (ISED) of foreign testing laboratories to test to Canadian requirements for telecommunications terminal equipment, radio apparatus and broadcasting equipment. 2. Definitions Bureau: Innovation, Science and Economic Development Canada’s Certification and Engineering Bureau (CEB). Certification: is the conformity assessment scheme used for Category I radio and broadcasting equipment. Certification body (CB): a recognized independent organization which conducts certification of radiocommunication equipment to Canadian regulatory requirements. Conformity assessment body (CAB): a body engaged in the performance of procedures for determining whether the relevant requirements in technical regulations or standards are fulfilled. Declaration of Conformity (DoC): is the conformity assessment scheme used for telecommunications apparatus that connect directly to the public switched telephone network. Department: Innovation, Science and Economic Development Canada (ISED). Designating authority (DA): a body with authority to designate, monitor, suspend designation, or withdraw designation of conformity assessment bodies under its jurisdiction. Designation: the nomination by a designating authority (DA) of a conformity assessment body as competent to perform conformity assessment activities under the terms of an agreement or arrangement. Recognition: the process by which ISED accepts a designated foreign testing laboratory as competent to test Canadian requirements. Testing laboratory: responsible to determine the applicable test procedures and to properly test to those requirements.


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Supplier’s Declaration of Conformity (SDoC): is the conformity assessment scheme used for Category II radio and broadcasting equipment. 3. Related documents The following documents, as well as other information, can be found on ISED’s Spectrum management and telecommunications website. Category I Equipment Standards List CB-02, Recognition Criteria, and Administrative and Operational Requirements Applicable to Certification Bodies (CBs) for the Certification of Radio Apparatus (This document contains the requirements and conditions which that will be evaluated by the Department before recognizing a CB.) CS-03, Compliance Specification for Terminal Equipment, Terminal Systems, Network Protection Devices, Connection Arrangements and Hearing Aids Compatibility (Technical Specifications List – Parts I to VIII, prescribe network protection and other mandatory technical requirements for terminal equipment.) DES-LAB, Procedure for Designation and Recognition of Canadian Testing Laboratories REC-LAB, Procedure for the Recognition of Accreditation Bodies for non-MRA Countries RSS-Gen, General Requirements for Compliance of Radio Apparatus 4. Criteria for recognition In order to be recognized by ISED all testing laboratories subject to Declaration of Conformity (DoC) or Certification must: a) be accredited to latest ISO/IEC 17025 – General Requirements for the Competence of Calibration and Testing Laboratories by an accreditation body located in an MRA country or by a recognized accreditation body for non-MRA countries listed on the ISED’s website b) be designated by an MRA partner for testing laboratories located in MRA countries or be designated by a recognized accreditation body for non-MRA countries c) include in the scope of designation a list of Canadian standards, specifications, or parts thereof, for which recognition is sought (this list shall be included in the scope of accreditation of the testing laboratory)



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5. Accredited testing laboratory recognition procedure The following procedure is used for all testing laboratories to be recognized by ISED as an accredited testing laboratory and thus is deemed competent to test products subject to DoC or Certification. Step 1 – Laboratory accreditation

(a) MRA countries: Seek accreditation from one of the accreditation bodies recognized by your designating authority (DA).

(b) Non-MRA countries: Seek accreditation from one of the recognized accreditation bodies listed on the ISED webpage for your country.

(c) Obtain latest ISO/IEC 17025 – General requirements for the competence of calibration and testing laboratories accreditation with a scope covering the applicable ISED requirements and test methods.

(d) Have the recognized accreditation body complete and sign the ISED Testing Laboratory Technical Assessment Checklist (see annex C of this document).

Step 2 – Designation

(a) Once the accreditation process is completed, a request for recognition is submitted to ISED. For MRA countries, the party submitting the request is known as the DA. For non-MRA countries, the testing laboratory needs to submit its designation request to the accreditation body.

(b) For accreditation bodies in MRA countries, the DA is defined in the MRA. In

MRA countries, the DA reviews the accreditation information and determines whether the testing laboratory meets the requirements for designation. Once the DA determines that the requirements have been met, it designates the testing laboratory to ISED by providing the information listed below for review and recognition by ISED.

Step 3 – ISED recognition

(a) ISED will review the information submitted regarding the testing laboratory.

(b) ISED will determine whether to recognize the testing laboratory.

(c) ISED will notify the DA of the decision on requests for recognition for laboratories located in MRA countries. For testing laboratory located in non-MRA countries, ISED with inform the accreditation body of its decision.

(d) A list of recognized accredited testing laboratories is provided on the ISED web page.




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6. Supporting information The following information is required to be included in the request for recognition as an accredited testing laboratory:

(a) name, location, mailing address and contact information; (b) designation number for non-MRA countries; (c) latest ISO/IEC 17025 Certificate of Accreditation; (d) scope of accreditation ; (e) expiration date of the accreditation (ISED requires that a testing laboratory must

be re-evaluated by the accreditation body at least every two years) ; (f) a completed ISED Testing Laboratory Technical Assessment Checklist

(see annex C) i. a completed checklist shall be provided for the designation of a newly

accredited testing laboratory ii. a statement indicating continued compliance with a previously submitted

checklist is acceptable for a renewal of a recognized accredited testing laboratory

(g) a statement that the test laboratory complies with all provisions of this procedure.

For testing laboratories located in MRA countries, the required information may only be submitted by the DA, and should not be submitted directly to ISED from the testing laboratory. Information regarding MRAs and the designation procedures can be found on the ISED MRA webpage. 7. Scope of accreditation Testing laboratories can be recognized to test to the following scope of accreditation:

• RSS-Gen and any RSS • RSS-102 (SAR or specific absorption rate), RSS-102 (RF Exposure Evaluation ) and/or

RSS-102 (NS or nerve stimulation) • CS-03 Parts • BETS

8. ISED testing laboratory technical assessment checklist The checklist identifies specific items to be evaluated during the technical assessment of a testing laboratory, to determine the capability and competence of that laboratory to perform testing needed to show compliance with ISED regulatory requirements. The checklist is intended to serve as a guide, and provides a minimum list of items to be included in the technical evaluation of the testing laboratory as part of the complete ISO/IEC 17025 assessment. The checklist is not intended to replace good engineering judgment of the technical assessor(s) or a thorough evaluation of the facility. As such, other related items not shown on the

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checklist may be evaluated by the assessor(s). The accreditation body shall attest that all responses on this checklist are complete and accurate. 9. Test reports All test reports shall be generated by the testing laboratory that tested the device. Testing is required to be performed by ISED recognized testing laboratories. A device must be tested at an ISED-recognized test laboratory. It is not acceptable for an ISED-recognized test laboratory to simply review a test report based on a non-recognized test laboratory assessment; all testing must be completed at the recognized test facility. For each test performed, the test report shall specify the location where each test was performed, and the person(s) who performed each test. 10. List of accredited testing laboratories A list of recognized accredited testing laboratories can be found on the Spectrum Management and Telecommunications website. 11. Procedure The designating authority (MRA countries) or the recognized accreditation body (non-MRA countries) shall provide the standards or specifications for which recognition is sought, along with the following documentation, using the online application: (a) a signed and dated covering letter (b) a copy of the accreditation certificate proving that the testing laboratory has been

accredited to the latest edition of ISO/IEC 17025 (c) a copy of the Scope of Accreditation (d) a copy of the completed testing laboratory technical assessment checklist It is important that the information submitted by the applicant matches the ISO/IEC 17025 Certificate and Scope of Accreditation and that the accreditation is valid at the time of application. The recognition application will be evaluated by ISED on a first-come, first-served basis. Upon recognition, ISED will issue a confirmation letter to the foreign DA (MRA countries) or a confirmation email to the recognized Accreditation Body (non-MRA countries). The confirmation will state the standards or specifications for which recognition has been granted. The testing laboratory will be added to the list of recognized testing laboratories available on the Spectrum Management and Telecommunications website. If ISED requires more information to make a decision, it will contact the foreign DA (MRA countries) or the recognized Accreditation Body (non-MRA countries).



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12. Disclosure of information

ISED will not disclose the status of applications for recognition to any third party until the recognition process has been completed.

13. Disclaimer

The recognition of a testing laboratory by ISED does not imply or otherwise suggest approval of a product or that the recognized testing laboratory is an agent or representative of ISED. ISED does not accept any responsibility for the effects or consequences of services provided by the recognized testing laboratory for users of such services.

14. Retaining recognition For MRA countries, DAs shall notify ISED, in writing, of any changes that may affect the continued ability of foreign testing laboratories to carry out the activities for which they were recognized. For recognized testing laboratories located in non-MRA countries, the testing laboratory shall notify the recognized accreditation body directly of any changes that may affect the continued ability to carry out the activities for which they were recognized. This includes changes in:

(a) business address and contact information (b) accreditation scope and status, and/or (c) subsequent reassessments

During operations as a recognized testing laboratory, the testing laboratory shall continue to meet the requirements of this document and shall maintain its accreditation status. The testing laboratory shall provide evidence of its accreditation status and scope upon request by the Department. The testing laboratory will normally be recognized for the duration of its designation. Testing laboratories shall not advertise their recognition status that is outside the scope of their recognition. 15. Suspension or withdrawal of recognition When a recognized testing laboratory is the subject of an investigation for non-compliance with this procedure, a recognition suspension may be issued upon consultation with its DA. The testing laboratory is required to take immediate corrective action to ISED’s satisfaction. Where it is found after formal review that a recognized testing laboratory does not comply with the


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requirements of this procedure, the recognition may be withdrawn. Such action, however, will only take place after a comprehensive consultation between ISED and the DA. If a testing laboratory’s designation is suspended or withdrawn by the DA, the recognition will also be suspended or withdrawn by ISED. A testing laboratory whose recognition has been suspended or withdrawn will be removed from the list of recognized testing laboratories. A testing laboratory whose recognition has been suspended or withdrawn shall cease advertising its recognition. For testing laboratories recognized in non-MRA countries, the suspension or withdrawal of recognition can be immediate.


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Annex C—Testing laboratory technical assessment checklist Laboratory name Laboratory contact Accreditation body Date of assessment Completed by (Assessor name(s))

Scope of accreditation (Indicate standards covered by assessment: e.g. RSS-GEN, RSS-247, RSS-102 (SAR), etc.)

Type of assessment

I. SCOPE OF ASSESSMENT (The laboratory shall possess or demonstrate access to appropriate ISED standards, and measurement methods, consistent with their scope of accreditation. Has the test laboratory been assessed and found to be capable and competent to perform testing to the standards listed below?) Y N N/A 1. Have all the applicable RSS and BETS standards for

the scope of interest been assessed?

Y N N/A 2. ANSI C63.4-2014, American National Standard for Methods of Measurement of Radio-Noise Emissions from Low-Voltage Electrical and Electronic Equipment in the Range of 9 kHz to 40 GHz.

Y N N/A 3. ANSI C63.10-2013, American National Standard for Testing Unlicensed Wireless Devices.

Y N N/A 4. ANSI C63.26-2015, American National Standard of Procedures for Compliance Testing of Licensed Transmitters.

Y N N/A 5. ANSI C63.17-2013, American National Standard Methods of Measurement of the Electromagnetic and Operational Compatibility of Unlicensed Personal Communications Services (UPCS) Devices.

Y N N/A 6. Has RSS-102: Radio Frequency (RF) Exposure Compliance of Radiocommunication Apparatus (All Frequency Bands), latest issue been assessed for the scopes of interest?

Y N N/A 7. IEEE 1528: Recommended Practice for Determining the Peak Spatial-Average Specific Absorption Rate (SAR) in the Human Head from Wireless Communications Devices: Measurement Techniques or IEC 62209-1: Measurement procedure for the assessment of specific absorption rate of human exposure to radio frequency fields from hand-held and body-mounted wireless communication devices - Part 1: Devices used next to the ear (Frequency range of 300 MHz to 6 GHz)


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Y N N/A 8. IEC 62209-2 (Body): Human exposure to radio frequency fields from hand-held and body-mounted wireless communication devices – Human models, instrumentation, and procedures – Part 2. Procedure to determine the specific absorption rate (SAR) for wireless communication devices used in close proximity to the human body (frequency range of 30 MHz to 6 GHz).

Y N N/A 9. Is the testing laboratory familiar with ISED DRS Notices, Supplementary Procedures (SPRs), and accepted FCC KDB procedures and capable of testing devices subject to said notices/procedures?

Y N N/A 10. Can the testing laboratory demonstrate access to all of the accepted supplementary procedures and notices published by ISED?

Y N N/A 11. Does the testing laboratory possess or can demonstrate access to all ISED standards and any normative reference standards in their desired scope of the assessment?

Y N N/A 12. Is any measurement software used by the testing laboratory documented in the test report? Has the testing software been properly validated?

Y N N/A 13. For each type and size of equipment under test (EUT) to be measured, does each radiated emission test facility comply with the conditions and requirements of the appropriate test procedure? (i.e. is the test volume large enough to encompass the EUT?)

Y N N/A 14. Are LISN(s), filters, and isolation transformers, if used, properly installed? Is the LISN bonded to the ground reference plane?

Y N N/A 15. Does the radiated emission test site(s) meet the site validation requirements of 5.4 of ANSI C63.4-2014 for the frequency range of 30 MHz to 1 GHz?

Y N N/A 16. Does the radiated emission test site(s) meet the site voltage standing wave ratio (Svswr) site validation requirements of International Special Committee on Radio Interference (CISPR) CISPR 16-1-4:2010 for the frequency range of 1 GHz to 18 GHz?

Y N N/A 17. Was the test site validation for performing radiated emissions measurements completed in the last three years?

Y N N/A 18. Does the test laboratory have all of the appropriate test equipment to cover the required frequency range per the scope of accreditation for the measurements to be performed by the testing laboratory?

Y N N/A 19. Does the test laboratory have an up-to-date description of measurement facilities?


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II. EMISSION TESTS Y N N/A 20. Are the AC power-line conducted emission tests

performed in accordance with the applicable parts of the applicable RSS standards?

Y N N/A 21. Are the guidelines in ANSI C63.4 followed for large EUTs, including in-situ measurements, if appropriate?

Y N N/A 22. Is the conducted emission test setup in accordance with ANSI C63.4 with the required separation between the EUT and any conducting surfaces maintained and is the Vertical coupling plane the correct dimensions?

Y N N/A 23. Is the EUT connected to one LISN and all the peripherals connected to one or more LISNs or a power strip to one LISN; i.e. per ANSI C63.4-2014?

Y N N/A 24. Is the testing laboratory using any adaptors (i.e. power bars) on the input to the LISN and has it been properly characterized and included in any test results?

Y N N/A 25. For each type of EUT, are measurements made over the correct frequency ranges and the correct detectors and bandwidth as required by the applicable standards?

Y N N/A 26. Are the radiated emission tests performed in accordance with the proper standard?

Y N N/A 27. Were radiated emission tests observed, and is the radiated emission test setup in accordance with proper standard?

Y N N/A 28. Does the radiated emission measurement represent the maximized cable configuration and worst case mode of EUT operation?

III. SAR TESTS Y N N/A 29. Does the SAR system meet the standardized

requirements in the referenced standards listed in the above Scope of Assessment?

Y N N/A 30. Does the laboratory have the proper equipment (TSL, dipoles, VNA for dielectric measurements, etc.) to cover the entire frequency range listed in the scope of IEEE 1528, IEC 62209-1 and IEC 62209-2?

Y N N/A 31. Was the SAR measurement system validated in accordance with the proper standards and at the proper intervals (i.e. annually/after probe calibration/etc.) and is it being tracked?

Y N N/A 32. Are the SAR measurements performed in accordance with the proper standards (including dielectric measurements/system checks/SAR evaluation/etc.)?

Y N N/A 33. Were SAR measurements observed, and is the test setup in accordance with the proper standards?


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IV. RF EXPOSURE EVALUATION AND NERVE STIMULATION TEST Y N N/A 34. Does the laboratory have the proper equipment to

cover the entire frequency range listed in the scope of IEEE C95.3?

Y N N/A 35. Are the RF Exposure Evaluations conducted in accordance with IEEE C95.3?

Y N N/A 36. Does the laboratory have the proper equipment to cover the entire frequency range listed in the scope of ISED SPR-002, Supplementary Procedure for Assessing Compliance with RSS-102 Nerve Stimulation Exposure Limits?

Y N N/W 37. Are the NS measurements conducted in accordance with SPR-002?

V. TEST REPORTS (Assessor should request to review several sample test reports for various types of products.) Y N N/A 38. Have several sample test reports for various

types of products been reviewed for accuracy?

Y N N/A 39. Does each of the test reports contain all the required information based on the RSS being assessed (e.g. reporting requirements of RSS-Gen or RSS-102)?

Y N N/A 40. Does the test report reference the standard used and specify any deviations?

Y N N/A 41. Is the rationale for selecting and arranging the EUT clearly stated, and are the components of the EUT system clearly identified?

Y N N/A 42. Does the test report include photographs or detailed sketches of the EUT configuration?

Y N N/A 43. Does the measurement report include a sample calculation with all conversion and correction factors used?

Y N N/A 44. Does the testing laboratory use external resources/subcontractors to perform testing, and if so do they have procedures in place to ensure that the external resources are properly accredited and ISED recognized?

Y N N/A 45. If external resources/subcontractors are used to perform testing, do the test reports clearly identify the work performed by the external resources/subcontractors and the results of the testing?





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VI. PERSONNEL COMPETENCY (The following is a list of general or lead-in questions, which are intended to be used as a guide to assess competency of laboratory personnel. Additional specific questions should be used to determine the technical competency of the personnel performing the measurement.) Radio Laboratory Personnel Y N N/A 46. Are laboratory personnel able to obtain recent

ISED standards and appropriate test procedures?

Y N N/A 47. Has each laboratory personnel responsible for testing been able to demonstrate performing a measurement of an applicable device?

Y N N/A 48. Do the test personnel know how to determine if an emission is from the EUT or is an ambient signal? Do the test personnel know how to handle an emission that is close to, or coincident with, an ambient signal?

Y N N/A 49. Can the test personnel explain the ISED requirements for testing a product in accordance with the requirements of the standards in the desired scope and is the test personnel knowledgeable of the testing conditions prescribed in the appropriate standard for different types of products?

Y N N/A 50. Arrange for one of the laboratory personnel, at each type of site, replicate at least three frequency points for site attenuation, and at least three test points for the Svswr. Is the test performed correctly, and is the site attenuation data or Svswr at these frequencies consistent with the previously recorded data? Note: Select frequencies from previous data that have both low and high deviations from the NSA and Svswr.

SAR Laboratory Personnel Y N N/A 51. Has each laboratory personnel responsible for

testing been able to demonstrate performing a SAR measurement on an applicable device?

Y N N/A 52. Are the test personnel knowledgeable of the SAR measurement procedures and requirements in RSS-102 and referenced standards/DRS Notices/SPRs/FCC KDBs?

Y N N/A 53. Are the test personnel knowledgeable of the SAR exemption limits and test reduction requirements in RSS-102 and referenced standards/DRS Notices/SPRs/FCC KDBs?


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Annex D—Proposed changes to related documents

Procedure name Section Issue

RSS-GEN (Issue 5) (General

Requirements for Compliance

of Radio Apparatus)

Sections 3.2 and 6.1, 6.2

3.2 Reference to RF Exposure (RSS-102) split into RSS-102 (SAR), RSS-102 (MPE) and RSS-102 (NS) 6.1 Testing Laboratory Requirements (to replace 6.1 Test Site Facilities) Testing laboratories performing measurements for RSS must be recognized and listed on ISED’s website. The procedure for testing laboratories to be recognized and listed is described in DES-LAB and REC-LAB for Canadian labs and foreign labs, respectively. Test sites currently listed with the CEB Test Site filing program will remain registered for six months from the date this proposal comes into effect. After which, the CEB Test Site filing program will only maintain accredited test sites. 6.1.1 Test Site Facilities - Accredited Site (replaced w/REC-LAB procedure link) 6.1.2 Test Site Facilities - Non-accredited Site (removed) 6.2 Test Report "In the test report, the applicant for equipment certification shall include the test site facilities' IC registration number."

DES-LAB (Issue 6)

(Procedure for Designation

and Recognition of

Canadian Testing

Laboratories)

Section 5.0 Changes in Section 5 reflect the same new requirements as found in REC-LAB


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CB-02 (Issue 8) (Recognition Criteria and

Administrative and

Operational Requirements Applicable to

Certification of Radio

Apparatus)

5.1 CB Requirements

Changes in section 5.1 related to test reports from accredited labs and RSS-102 sections.

Documents

Consultation on New Requirements for Wireless Device Testing … · 2017. 9. 1. · 10. Submitting comments ... business and public institutions. Consultation on New Requirements