RF exposure

FCC ID: 2AF78-01046

RF Exposure Info

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FCCID_4286819

@ clement
                                            PayRange Inc.
                                                  BluKey Pro

                                              FCC 2.1091:2019
                                                       BTLE

                                          Report # PAYROO015.3




                                                                           7 n z
                                                                            > aamn‘y
                                      TESTING                                TNY
                               NVLAP Lab Code: 200630




This report must not be used to claim product certification, approval, or endorsement by NVLAP, NIST, or any
agency of the U.S. Government. This Report shall not be reproduced, except in full without written approval of the
laboratory.

EAR—Controlled Data — This document contains technical data whose export and reexport/retransferis subject to
control by the U.S. Department of Commerce under the Export Administration Act and the Export Administration
Regulations. The Department of Commerce‘s prior written approval may be required for the export or re—
export/retransfer of such technical data to any foreign person, foreign entity or foreign organization whether in the
United States or abroad


CERTIFICATE OF EVALUATION
                                                                                                                                    2018-09-14




                                Last Date of Evaluation: Tuesday, May 7, 2019
                                                PayRange Inc.
                                              Model: BluKey Pro


RF Exposure Evaluation
Standards
Specification                                                        Method
FCC 2.1091:2019                                                      FCC 447498 D01 General RF Exposure Guidance v06


Results
Method
            Description                                    Applied     Results      Comments
Clause
7.1         Maximum Permissible Exposure                     Yes         Pass



Deviations From Evaluation Standards
None


Approved By:


Donald Facteau, Process Architect




Product compliance is the responsibility of the client; therefore, the tests and equipment modes of operation represented in this
report were agreed upon by the client, prior to testing. The results of this test pertain only to the sample(s) tested. The specific
description is noted in each of the individual sections of the test report supporting this certificate of test. This report reflects only
those tests from the referenced standards shown in the certificate of test. It does not include inspection or verification of labels,
identification, marking or user information. As indicated in the Statement of Work sent with the quotation, Element’s standard
process is to always use the latest published version of the test methods even when earlier versions are cited in the test
specification. Issuance of a purchase order was de facto acceptance of this approach. Otherwise, the client would have advised
Element in writing of the specific version of the test methods they wanted applied to the subject testing

Report No. PAYR0015.3                                   EAR-Controlled Data                                                                 2/9


RF Exposure Condition
                                                                                                  2018-07-17




The following RF Exposure conditions were used for the assessment documented in this report:
Intended Use                                 Mobile
Location on Body (if applicable)             NA
How is the Device Used                       These devices allow wireless payment from smartphones to
                                             vending machines, in this case laundry devices.
Radios Contained in the Same Host Device     BTLE
Simultaneous Transmitting Radios             None
Body Worn Accessories                        N/A
Environment                                  General Population/Uncontrolled Exposure




Report No. PAYR0015.3                    EAR-Controlled Data                                             3/9


REVISION HISTORY
                                                                                     2018.07.17




Revision                                                  Date
                        Description                                    Page Number
Number                                                  (yyyy-mm-dd)

00       None




Report No. PAYR0015.3             EAR-Controlled Data                                       4/9


ACCREDITATIONS AND
AUTHORIZATIONS                                                                                                                      2019.03.08




United States
   FCC - Designated by the FCC as a Telecommunications Certification Body (TCB). Certification chambers, Open Area Test Sites, and
   conducted measurement facilities are listed with the FCC.
   A2LA - Accredited by A2LA to ISO / IEC 17065 as a product certifier. This allows Element to certify transmitters to FCC and IC
   specifications.
   NVLAP - Each laboratory is accredited by NVLAP to ISO 17025

Canada
   ISED - Recognized by Innovation, Science and Economic Development Canada as a Certification Body (CB) and as a CAB for the
   acceptance of test data.


European Union
   European Commission – Within Element, we have a EU Notified Body validated for the EMCD and RED Directives.

Australia/New Zealand
   ACMA - Recognized by ACMA as a CAB for the acceptance of test data.

Korea
   MSIT / RRA - Recognized by KCC’s RRA as a CAB for the acceptance of test data.

Japan
   VCCI - Associate Member of the VCCI. Conducted and radiated measurement facilities are registered.

Taiwan
   BSMI – Recognized by BSMI as a CAB for the acceptance of test data.
   NCC - Recognized by NCC as a CAB for the acceptance of test data.

Singapore
   IDA – Recognized by IDA as a CAB for the acceptance of test data.

Israel
   MOC – Recognized by MOC as a CAB for the acceptance of test data.

Hong Kong
   OFCA – Recognized by OFCA as a CAB for the acceptance of test data.

Vietnam
   MIC – Recognized by MIC as a CAB for the acceptance of test data.



                                                           SCOPE
                              For details on the Scopes of our Accreditations, please visit:
                                https://www.nwemc.com/emc-testing-accreditations




Report No. PAYR0015.3                                 EAR-Controlled Data                                                                  5/9


FACILITIES
                                                                                                                                         2019.03.08




       California                 Minnesota                      Oregon                       Texas                  Washington
     Labs OC01-17                Labs MN01-10                  Labs EV01-12                Labs TX01-09              Labs NC01-05
          41 Tesla             9349 W Broadway Ave.      6775 NE Evergreen Pkwy #400      3801 E Plano Pkwy         19201 120th Ave NE
     Irvine, CA 92618         Brooklyn Park, MN 55445         Hillsboro, OR 97124          Plano, TX 75074           Bothell, WA 98011
      (949) 861-8918              (612)-638-5136                 (503) 844-4066             (469) 304-5255            (425)984-6600

                                                                 NVLAP
 NVLAP Lab Code: 200676-0    NVLAP Lab Code: 200881-0     NVLAP Lab Code: 200630-0     NVLAP Lab Code:201049-0   NVLAP Lab Code: 200629-0

                                       Innovation, Science and Economic Development Canada
    2834B-1, 2834B-3            2834E-1, 2834E-3                  2834D-1                     2834G-1                   2834F-1
                                                                  BSMI
    SL2-IN-E-1154R              SL2-IN-E-1152R                 SL2-IN-E-1017              SL2-IN-E-1158R            SL2-IN-E-1153R
                                                                  VCCI
         A-0029                      A-0109                       A-0108                      A-0201                     A-0110
                        Recognized Phase I CAB for ISED, ACMA, BSMI, IDA, KCC/RRA, MIC, MOC, NCC, OFCA
        US0158                       US0175                       US0017                      US0191                    US0157




Report No. PAYR0015.3                                   EAR-Controlled Data                                                                     6/9


PRODUCT DESCRIPTION
                                                                                                       2018-07-17




Client and Equipment Under Evaluation Information
Company Name:                     PayRange Inc.
Address:                          9600 NE Cascades Pkwy, Suite 280
City, State, Zip:                 Portland, OR 97220
Evaluation Requested By:          Mike Mitchell
Model:                            BluKey Pro
Date of Evaluation:               Tuesday, May 7, 2019

Information Provided by the Party Requesting the Evaluation

Functional Description of the Equipment:
Payrange devices allow wireless payment from smartphones to vending machines, in this case laundry devices.

Objective:
To demonstrate compliance with FCC requirements for RF exposure for 2.1091 mobile/fixed devices




Report No. PAYR0015.3                      EAR-Controlled Data                                                7/9


 MAXIMUM PERMISSIBLE EXPOSURE
 (MPE)                                                                                                         EXRPT.2017.10.02




 OVERVIEW

Human exposure to RF emissions from mobile devices (47 CFR §2.1091) may be evaluated based on the MPE
limits adopted by the FCC for electric and magnetic field strength and/or power density, as appropriate, since
exposures are assumed to occur at distances of 20 cm or more from persons. ANSI C95.1:2005 + Amd 1:2010
specifies a minimum separation distance of 20 cm for performing reliable field measurements to determine
adherence to MPE limits. If the minimum separation distance between a transmitter and nearby persons is more
than 20 cm under normal operating conditions, compliance with MPE limits may be determined at such distance
from the transmitter. When applicable, operation instructions and prominent warning labels may be used to alert
the exposed persons to maintain a specified distance from the transmitter or to limit their exposure durations
and usage conditions to ensure compliance. If the use of warning labels on a transmitter is not effective or
desirable, the alternative of performing SAR evaluation with the device at its closest range to persons under
normal operating conditions may be used. The field strength and power density limits adopted by the FCC are
based on whole-body averaged exposure and the assumption of RF field levels relate most accurately to
estimating whole-body averaged SAR. This means some local values of exposures exceeding the stated field
strength and power density limits may not necessarily imply non-compliance if the spatial average of spatially
averaged RF fields over the exposed portions of a person’s body does not exceed the limits.

 COMPLIANCE WITH FCC 2.1091

 “Mobile devices that operate in the Cellular Radiotelephone Service, the Personal Communications Services,
the Satellite Communications Services, the General Wireless Communications Service, the Wireless
Communications Service, the Maritime Services and the Specialized Mobile Radio Service authorized under
subpart H of part 22 of this chapter, parts 24, 25, 26 and 27 of this chapter, part 80 of this chapter (ship earth
stations devices only) and part 90 of this chapter are subject to routine environmental evaluation for RF
exposure prior to equipment authorization or use if they operate at frequencies of 1.5 GHz or below and their
effective radiated power (ERP) is 1.5 watts or more, or if they operate at frequencies above 1.5 GHz and their
ERP is 3 watts or more. Unlicensed personal communications service devices, unlicensed millimeter wave
devices and unlicensed NII devices authorized under §§15.253, 15.255, and 15.257, and subparts D and E of
part 15 of this chapter are also subject to routine environmental evaluation for RF exposure prior to equipment
authorization or use if their ERP is 3 watts or more or if they meet the definition of a portable device as specified
in §2.1093(b) requiring evaluation under the provisions of that section. All other mobile and unlicensed
transmitting devices are categorically excluded from routine environmental evaluation for RF exposure prior to
equipment authorization or use, except as specified in §§1.1307(c) and 1.1307(d) of this chapter. Applications
for equipment authorization of mobile and unlicensed transmitting devices subject to routine environmental
evaluation must contain a statement confirming compliance with the limits specified in paragraph (d) of this
section as part of their application.”

The device will only be used with a separation distance between the antenna and the body of the user or
nearby persons as shown in the table below and can therefore be considered a mobile transmitter per
47 CFR 2.1091(b).

 COMPLIANCE WITH FCC KDB 447498 D01 General RF Exposure Guidance v06


"KDB 447498 D01 General RF Exposure Guidance v06" provides the procedures, requirements, and
authorization policies for mobile and portable devices.

Devices operating in standalone mobile device exposure conditions may contain a single transmitter or multiple
transmitters that do not transmit simultaneously are covered in section 7.1.

Devices containing multiple transmitters capable of simultaneous transmissions are covered in section 7.2.




Report No. PAYR0015.3                          EAR-Controlled Data                                                       8/9


 MAXIMUM PERMISSIBLE EXPOSURE
 (MPE)                                                                                                                                  EXRPT.2017.10.02




 LIMITS
Limits for General Population /Uncontrolled Exposure: 47 CFR 1.1310


                                  Electric Field             Magnetic Field
  Frequency Range                   Strength                   Strength                 Power Density              Averaging Time
                                                                                                      2
         (MHz)                          (V/m)                     (A/m)                    (mW/cm )                      (minutes)
       0.3 - 1.34                        614                       1.63                      *(100)                         30
       1.34 - 30                        824/f                     2.19/f                    *(180/f2)                       30
        30 - 300                         27.5                     0.073                        0.2                          30
      300 - 1500                                                                             f/1500                         30
    1500 - 100000                                                                               1                           30

f = frequency in MHz
* = Plane-wave equivalent power density

 ASSESSMENT

The exposure level for the radio is evaluated at a 20 cm distance from the radio’s transmitting antenna using the
general equation:

                                                        P *G
                                           S 
                                                       4* * R               2


Where: S = power density (mW/cm2)
P = power input to the antenna (mW)
G = numeric power gain relative to an isotropic radiator
R = distance to the center of the radiation of the antenna (20 cm = limit for MPE estimates)
P*G = EIRP

Solving for S, the maximum power density 20 cm from the transmitting antenna is determined. This level is then
compared to the applicable limit for the transmit frequency. If limits were not met at the 20 cm boundary the
evaluation distance is increased until the limit is met as shown in the table below.

For co-located radios, the ratio of the calculated level to the limit is determined. The ratios for each co-located
radio are summed. If the sum is less than or equal to one, then the device is excluded from testing and is
deemed compliant.

The standalone MPE and summed MPE ratios are summarized in the following table:

            Transmit      Measured Conducted    Duty Highest Antenna Minimum Antenna    Minimum Separation   Power Density     Limit
Radio                                                                                                                                 Compliant
        Frequency (MHz)   Output Power (mW)     Cycle   Gain (dBi)    Cable Loss (dB)      Distance (cm)       (mW/cm2)      (mW/cm2)
BTLE         2480                3.92            1          3               0                  20               0.0016         1.0        Yes
The information in the table above was obtained from:

Element Test Report PAYR0015.1 and RF Exposure Information form




Report No. PAYR0015.3                                      EAR-Controlled Data                                                                    9/9



Document Created: 2019-05-21 16:51:37
Document Modified: 2019-05-21 16:51:37

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