Q It's now self certification, so I don't need to have it tested !

The new regime does place greater emphasis on the supplier for compliance, that is true. However, as you will see from Schedule 1 of the labelling instrument (briefly summarised below) most equipment falls under compliance level 3, thereby requiring compliance testing to the applicable standards by a recognised testing authority (RTA) .

RTA is the new name for Austel listed/ accredited test houses.

Q What's changed under the new process?

Following testing by a RTA to the mandatory Section 376 standards, and after seeking permission to use the "A-Tick" (if you haven't already sought permission to use the C-Tick), you may label & sell your equipment (don't forget you must also comply with the EMC Framework). There is no requirement to submit test reports or statements of compliance direct to the ACA. Statements of compliance from test houses have no weight under the new system, it's test reports that matter! The ACA do not issue individual permit numbers for products, nor assess your variations to them (until audit !). So the process is greatly streamlined as you don't have to wait 30+ days for a permit number. You will however be audited, and test reports together with other compliance folder requirements will be inspected.

Q What is the compliance level of my equipment?

Schedule 1 of the labelling instrument outlines equipment and their applicable compliance levels.

In summary, to comply with the various compliance levels you must have for:

Compliance level 1:

a) A description of the item; and
b) A declaration of conformity.

Example: Equipment designed to connect to telex.

Compliance Level 2:

a) A test report or reports that shows that the item meets the requirements of each applicable standard; or
b) A written statement by a certification body, certifying that the item complies with each applicable standard; or
c) If section 17 of the labelling instrument applies, ie only if it is impracticable to test the item because of it’s size, location or nature, - a written statement by a competent body certifying that reasonable efforts have been made to avoid a contravention of each applicable standard.

Example: Austel TS003 as it relates to Digital CAS interface for data only.

Compliance Level 3:

a) A test report or reports from a recognised testing authority (new name for NATA accredited test house) that shows that the item meets the requirements of each applicable standard; or
b) A written statement by a certification body certifying that the item complies with each applicable standard; or
c) If section 17 applies - a written statement by a competent body certifying that reasonable efforts have been made to avoid a contravention of each applicable standard.

The majority of equipment is compliance level 3. PSTN connected data & voice equipment, ISDN BRI & PRI, leased line equipment, all fall under compliance level 3, so 95% of products tested by accredited test labs under the Austel regime, will continue to require testing.
That is not to say the standards will remain the same, and there may be relaxation of compliance criteria within the mandatory standards.
A key point is that items that fail to comply with the standards cannot be given a compliant report, and therefore suppliers cannot attest compliance with the appropriate section 376 standard.
It is also worth noting, that advise’s to industry, previously issued by Austel, have no place under the new regime, although the ACIF (Australian Communications Industry Forum) may produce them in a new format as a guide.

Q What do I need in my Telecomms compliance folder?

The labeling instrument lists the following items that need to be contained within a compliance folder. These are separate to the EMC Framework requirements, although 1 folder may contain information to satisfy both EMC & telecomms. Product Description. This may include the following:

Photographs of the item and / or brochure

A reference to the version of any software that is incorporated in the item Further sufficient information, such as a block/interconnection diagram, for a person (including ACA auditor) to determine whether the item labeled is the same as the item for which the Declaration of Conformity, test report or statement by a competent or certification body has been made.

Original or certified copies of test reports relating to the equipment, indicating compliance with all relevant section 376 standards (if compliance level 2 or 3)

Signed Declaration of Conformity (stating the item complies with s.376 standards). Copies of the declaration of conformity are available to Austest clients.

Q What if my equipment doesn't comply with the new standards?

Assuming the product is "new", ie tested to ACA standards after 1 July 1997, and fails to comply with said standards, the product cannot be marked with the "A-Tick". The following mark must be placed on non compliant equipment. The label must be durable and at least 5 mm high.

The following statement must also be provided on packaging and incorporated in documentation supplied with the non compliant item, and must be in the same font size as other text in the documentation:

Do not connect this customer equipment or customer cabling to a carrier or carriage service provider’s network or facility unless:

(a) you have the consent of the network manager; or
(b) the connection is in accordance with a connection permit or connection rules.

Connection of this customer equipment or customer cabling may cause a hazard or damage to the network or facility, or persons, with consequential liability for substantial compensation.

Q What if my equipment has an Austel (or even Telecom) permit number?

Under the permitted items standard TS100, you are allowed to market the item till the end of June 30 1998. If you intend to sell the item after that date, you have several options. The item can be re-examined to all current applicable ACA standards, or you can approach a certification body, such as Austest-BABT Certification Services, who may provide you with, following assessment of previous test reports in comparison to existing ACA standards, a statement of compliance. This statement of compliance can then form part of your compliance folder attesting compliance to the new ACA compliance regime. The item must then be labelled as per the new ACA regime, ie with the A-Tick, C-Tick and one of several options including supplier code #.

Q How can we make sure that our compliance folders are sufficient to satisfy an audit by the ACA?

In most cases, for less than $1000 we can audit your companies compliance folders ON-SITE, and provide feedback regarding missing or insufficient documents and compliance evidence. We systematically examine your compliance folders to highlight insufficient or missing documentation. This audit report can then become part of your compliance documentation, and give peace of mind prior to being audited by the ACA.

Q UNIVERSAL TIP:

Involve your test house from the design stage of a product. No, we're not just say this to earn more money ! Redesigning printed circuit boards (EMC and safety), and finding compliant isolating components (safety and interworking) is easy at the design stage, expensive and frustrating after the product has been made and ready to sell.
It will save you money !

Q ELECTRICAL SAFETY

Most products fail electrical safety due to inadequate isolation between differing voltages within a product. For example, a mains powered fax machine needs to have re-inforced isolation between mains (240Vrms) and secondary low voltage circuits. It also needs supplementary isolation between internal telehone connected circuitry (TNV) and low voltage circuits. This isolation across barriers varies widely dependent upon circuit potentials and how they are used. Once again, comsultation at the preliminary design stage of a product can save many hours of board and component rework, not to mention expense and delay. TIP: Use an electrical safety test house at the design stage of a product. A preliminary look at a product for safety may cost as little as $100 and save thousands in avoiding retrofitted boards and components.

Q EMI/EMC 1

When performed correctly, pre-compliance testing before submitting a product for final test gives confidence that the product will either pass 1st go, or require only minimal changes. Our preconformance open area site is available for checking emissions during prototype stage, measuring the effect different components have on your overall system. Alternatively our main site is available for such measurements at a fee competitive to hiring EMC equipment and performing your own tests. TIP:Do pre-compliance testing early and often. To incorporate sound EMC techniques, the problem areas must be isolated (test early), and the design must not alter previously devised protection techniques (test often).

Q EMI/EMC 2

TIP:When modifying a mains powered product or telephone interface to suppress emissions, take care to ensure the change has not altered electrical safety requirements. Use a consultant or test house that has intimate knowledge of both electrical safety and EMC standards, or be faced with unnecessary retesting.

Q EMI/EMC 3

TIP: Use the slowest logic possible. Fast transitions and higher clock speeds contain more unwanted energy (and harmonics). Energy distribution is affected by rise & fall times, duty cycle, the shape of the clock waveform & PCB layouts.

Q EMI/EMC 4

TIP: The response of an EMI receiver has a typical bandwidth of 120KHz for radiated & 9KHz for conducted emissions. If several harmonics from 2 or more clocks fall within the bandwidth of the receiver, the measured field strength will be higher than either of the individual harmonics, with an increase of up to 6dB. Where you can, select your clock frequencies to avoid such clashes. If designing a product, the program "Clock Architect" from TKC may be helpful. Click Here to go to the TKC Web page to obtain a trial version of this handy program.

Q EMI/EMC 5

TIP:The ground connection on your printed circuit board is not a waste outlet where all unwanted emissions flow. PCB groundplanes and surfaces of enclosures are not 'infinite current sinks'. Although good grounding is part of the solution to unwanted emissions, it should not be the only technique.

Q INTERWORKING 1

TIP:When sourcing a product for the Australian or NZ Telecom markets, make sure it complies with similar safety and EMC requirements in other countries. A modem that passes German or UK requirements will require less modification than a product designed for the domestic North American market.

Q INTERWORKING 2

TIP:If your principal focus is Australia, although NZ or other counties may be next on your list, design your product (or have it tested) with these countries in mind. One product may be suitable for several markets.