RF Exposure

FCC ID: AYV-AGLU01

RF Exposure Info

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@ clement
                               Timecode Systems Limited
                                                     AirGlu
                                              FCC 2.1093:2019
                                  902 — 928 MHz FHSS Transceiver
                                     Bluetooth Low Energy Radio

                                          Report # TMECO007.1




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                                      TESTING
                               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 whetherin the
United States or abroad


CERTIFICATE OF EVALUATION
                                                                                                                                    2018-09-14




                          Last Date of Evaluation: Wednesday, August 14, 2019
                                        Timecode Systems Limited
                                              Model: AirGlu


RF Exposure Evaluation
Standards
Specification                                                        Method
FCC 2.1093:2019                                                      FCC 447498 D01 General RF Exposure Guidance v06


Results
Method
            Description                  Applied       Results        Comments
Clause
4.3.2       SAR Test Exclusion              Yes           Pass        None



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. TMEC0007.1                                   EAR-Controlled Data                                                               2/10


RF Exposure Condition
                                                                                                     2018-07-17




The following RF Exposure conditions were used for the assessment documented in this report:
Intended Use                                 Portable
Location on Body (if applicable)             Head/Torso
How is the Device Used                       The AirGlu module would normally be fitted into professional
                                             camera/audio/recording devices, to allow easy wireless
                                             synchronization between multiple units containing the AirGlu
                                             module.
Radios Contained in the Same Host Device     902 - 928 MHz FHSS Transceiver
                                             Bluetooth Low Energy
Simultaneous Transmitting Radios              902 - 928 MHz FHSS Transceiver, Bluetooth Low Energy
Body Worn Accessories                        NA
Environment                                  General Population/Uncontrolled Exposure




Report No. TMEC0007.1                      EAR-Controlled Data                                             3/10


REVISION HISTORY
                                                                                     2018.07.17




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

00       None




Report No. TMEC0007.1             EAR-Controlled Data                                     4/10


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. TMEC0007.1                                 EAR-Controlled Data                                                                5/10


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. TMEC0007.1                                   EAR-Controlled Data                                                                   6/10


PRODUCT DESCRIPTION
                                                                                               2018-07-17




Client and Equipment Under Evaluation Information
Company Name:                     Timecode Systems Limited
Address:                          9 Mill House Elgar Business Centre
City, State, Zip:                 Hallow, WR2 6NJ
Evaluation Requested By:          Paul Scurrell
Model:                            AirGlu
Date of Evaluation:               Wednesday, August 14, 2019

Information Provided by the Party Requesting the Evaluation

Functional Description of the Equipment:
Time synchronization system utilizing both a BLE radio and a 902 - 928 MHz FHSS Transceiver.

Objective:
To demonstrate compliance with FCC RF exposure requirements for 2.1093 portable devices.




Report No. TMEC0007.1                      EAR-Controlled Data                                       7/10


 SAR TEST EXCLUSION
                                                                                                           EXRPT.2019.04.10




 OVERVIEW

Human exposure to RF emissions from portable devices (47 CFR §2.1093) used with the radiating antenna
closer than 20 cm to the user requires Specific Absorption Rate (SAR) to evaluate the environmental impact of
human exposure to radiofrequency (RF) radiation.

 COMPLIANCE WITH FCC 2.1093

“Portable devices that operate in the Cellular Radiotelephone Service pursuant to part 22 of this chapter; the
Personal Communications Service (PCS) pursuant to part 24 of this chapter; the Satellite Communications
Services pursuant to part 25 of this chapter; the Miscellaneous Wireless Communications Services pursuant to
part 27 of this chapter; the Maritime Services (ship earth station devices only) pursuant to part 80 of this
chapter; the Specialized Mobile Radio Service, the 4.9 GHz Band Service, and the 3650 MHz Wireless
Broadband Service pursuant to part 90 of this chapter; the Wireless Medical Telemetry Service (WMTS) and the
Medical Device Radiocommunication Service (MedRadio), pursuant to subparts H and I of part 95 of this
chapter, respectively, unlicensed personal communication service, unlicensed NII devices and millimeter wave
devices authorized under §§15.253(f), 15.255(g), 15.257(g), 15.319(i), and 15.407(f) of this chapter; and the
Citizens Broadband Radio Service pursuant to part 96 of this chapter are subject to routine environmental
evaluation for RF exposure prior to equipment authorization or use. All other portable 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 portable transmitting devices subject to routine environmental evaluation must contain a
statement confirming compliance with the limits specified in paragraph (d) of this section. Technical information
showing the basis for this statement must be submitted to the Commission upon request.”

The EUT will be used with a separation distance of less than 20 centimeters between the radiating
antenna and the body of the user or nearby persons and must therefore be considered a portable
transmitter per 47 CFR 2.1093(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.

Standalone radio SAR test exclusion is covered under section 4.3.1. Unless specifically required by the
published RF exposure KDB procedures, standalone 1-g head or body and 10-g extremity SAR evaluation for
general population exposure conditions, by measurement or numerical simulation, is not required when the
corresponding SAR Test Exclusion Thresholds are met as shown in the Limits section below.

Simultaneous transmission SAR test exclusion is covered under section 4.3.2. SAR test exclusion is determined
for each operating configuration and exposure condition according to the reported standalone SAR of each
applicable simultaneously transmitting antenna. When the sum of 1-g or 10-g SAR of all simultaneously
transmitting antennas in an operating mode and exposure condition combination is within the SAR limit, SAR
test exclusion applies to that simultaneous transmission configuration.




Report No. TMEC0007.1                         EAR-Controlled Data                                                   8/10


 SAR TEST EXCLUSION
                                                                                                             EXRPT.2019.04.10




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

The SAR limits for general population/uncontrolled exposure are 0.08 W/kg, as averaged over the whole body,
and a peak spatial-average SAR of 1.6 W/kg, averaged over any 1 gram of tissue (defined as a tissue volume in
the shape of a cube). Exceptions are the parts of the human body treated as extremities, such as hands, wrists,
feet, ankles, and pinnae, where the peak spatial-average SAR limit is 4 W/kg, averaged over any 10 grams of
tissue (defined as a tissue volume in the shape of a cube). Exposure may be averaged over a time period not to
exceed 30 minutes to determine compliance with general population/uncontrolled SAR limits.

For 100 MHz to 6 GHz and test separation distances ≤ 50 mm, the SAR test exclusion thresholds are 1-g for
head and body SAR and 10-g SAR for extremity SAR.

 ASSESSMENT

For 100 MHz to 6 GHz and test separation distances ≤ 50 mm, the 1-g and 10-g SAR test exclusion thresholds
are determined by the following:

[(max. power of channel, including tune-up tolerance, mW)/(min. test separation distance, mm)] · [√f(GHz)] = 3.0
for 1-g SAR and = 7.5 for 10-g extremity SAR,
where
         •      f(GHz) is the RF channel transmit frequency in GHz
         •      Power and distance are rounded to the nearest mW and mm before calculation
         •      The result is rounded to one decimal place for comparison
         •      3.0 and 7.5 are referred to as the numeric thresholds in the step b below

The test exclusions are applicable only when the minimum test separation distance is ≤ 50 mm and for
transmission frequencies between 100 MHz and 6 GHz. When the minimum test separation distance is < 5 mm,
a distance of 5 mm according to 4.1f) is applied to determine SAR test exclusion.

 METHOD OF EVALUATION – STANDALONE CONFIGURATION

The standalone SAR Test Exclusion Threshold for each radio is summarized in the following tables. The result
of the calculation is well below the exclusion threshold of 3.0, therefore the unit is excluded from SAR evaluation
and deemed compliant with FCC RF exposure requirements.

The SAR Test Exclusion Threshold is summarized in the following tables:
                        Transmit
                                 Measured Conducted         Duty    Minimum Separation Exclusion
       Radio           Frequency                                                                 Limit Compliant
                                 Output Power (mW)          Cycle      Distance (mm)   Threshold
                         (MHz)
   Bluetooth Low
                          2402               5.39             1             5            1.671     3.0      Yes
      Energy
The information in the table above was obtained from:
From client provided information for this application and Element report #TMEC0002.1.

                        Transmit
                                 Measured Conducted         Duty    Minimum Separation Exclusion
       Radio           Frequency                                                                 Limit Compliant
                                 Output Power (mW)          Cycle      Distance (mm)   Threshold
                         (MHz)
  902 - 928 MHz
                          922.2              2.92             1             5            0.561     3.0      Yes
 FHSS Transceiver
The information in the table above was obtained from:
From client provided information for this application and Element report #TMEC0007.8.




Report No. TMEC0007.1                               EAR-Controlled Data                                               9/10


 SAR TEST EXCLUSION
                                                                                                              EXRPT.2019.04.10




 METHOD OF EVALUATION – SIMULTANEOUS TRANSMISSION CONFIGURATION

KDB 447498 D01 General RF Exposure Guidance v06, Section 4.3.2(b)

“When an antenna qualifies for the standalone SAR test exclusion of 4.3.1 and also transmits simultaneously
with other antennas, the standalone SAR value must be estimated according to the following to determine the
simultaneous transmission SAR test exclusion criteria:

    1) [(max. power of channel, including tune-up tolerance, mW)/(min. test separation distance, mm)] ·
       [√𝑓(𝐺𝐻𝑧)/π‘₯], for test separation distances ≤ 50mm;

         where x = 7.5 for 1-g SAR and x = 18.75 for 10-g SAR.

    2) 0.4 W/kg for 1-g SAR and 1.0 W/kg for 10-g SAR, when the test separation distance is > 50 mm.

This SAR estimation formula has been considered in conjunction with the SAR Test Exclusion Thresholds to
result in substantially conservative SAR values of = 0.4 W/kg. When SAR is estimated, the peak SAR location is
assumed to be at the feed-point or geometric center of the antenna, whichever provides a smaller antenna
separation distance, and this location must be clearly identified in test reports. The estimated SAR is used only
to determine simultaneous transmission SAR test exclusion; it should not be reported as the standalone SAR.
When SAR is estimated, it must be applied to determine the sum of 1-g SAR test exclusion. When SAR to peak
location separation ratio test exclusion is applied, the highest reported SAR for simultaneous transmission can
be an estimated standalone SAR if the estimated SAR is the highest among the simultaneously transmitting
antennas (see also KDB Publication 690783 D01). For situations where the estimated SAR is overly
conservative for certain conditions, the test lab may choose to perform standalone SAR measurements, then
use the measured SAR to determine simultaneous transmission SAR test exclusion. Estimated SAR values at
selected frequencies, distances, and power levels are illustrated in Appendix D.

In the table below, the estimated stand-alone SAR for the 902 - 928 MHz FHSS Transceiver and Bluetooth Low
Energy radios have been estimated. The estimated values have been summed and compared to the SAR limit.
The result of the calculation is well below the limit therefore the unit is excluded from simultaneous SAR
evaluation and deemed compliant with FCC RF exposure requirements.

                                Transmit         Test        Output      Duty       Estimated
                                                                                                   Specification
           Radio               Frequency      Separation     Power       Cycle   Standalone SAR
                                 (GHz)          (mm)          (mW)                   (W/kg)           (W/kg)
    902 - 928 MHz FHSS
                                 0.92222            5         2.92         1         0.075              1.6
         Transceiver
   Bluetooth Low Energy            2.402            5         5.39         1         0.223              1.6
The information in the table above was obtained from:
From client provided information for this application, Element report #TMEC0002.1, and Element report
#TMEC0007.8.

   Estimated Summed
                               Specification
          SAR
           (W/kg)                   (W/kg)
           0.298                      1.6




Report No. TMEC0007.1                              EAR-Controlled Data                                                 10/10



Document Created: 2019-09-09 19:16:09
Document Modified: 2019-09-09 19:16:09

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