RF Exposure

FCC ID: EOA-24RMQ

RF Exposure Info

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@ clement
                                Starkey Laboratories, Inc.
                                       Mini Remote Microphone

                                              FCC 2.1093:2018
                                     Bluetooth Low Energy (DTS)

                                          Report # STAKO144.6




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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/retransfer is 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: Monday, December 31, 2018
                                        Starkey Laboratories, Inc.
                                    Model: Mini Remote Microphone


RF Exposure Evaluation
Standards
Specification                                                        Method
FCC 2.1093:2018                                                      FCC 447498 D01 General RF Exposure Guidance v06


Results
Method
            Description                  Applied       Results        Comments
Clause
4.3.1       SAR Test Exclusion              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. STAK0144.6                                   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                                 Portable
Location on Body (if applicable)             Head/Torso
How is the Device Used                       Remote microphone for use with wireless hearing aids.
Radios Contained in the Same Host Device     None
Simultaneous Transmitting Radios             None
Body Worn Accessories                        N/A
Environment                                  General Population/Uncontrolled Exposure




Report No. STAK0144.6                     EAR-Controlled Data                                               3/9


REVISION HISTORY
                                                                                     2018.07.17




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

00       None




Report No. STAK0144.6             EAR-Controlled Data                                       4/9


ACCREDITATIONS AND
AUTHORIZATIONS                                                                                                                       2018.09.04




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). Certification chambers
    and Open Area Test Sites are filed with ISED.


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. STAK0144.6                                  EAR-Controlled Data                                                                  5/9


  FACILITIES
                                                                                                                                                           2018.12.13




      California                Minnesota                   New York                        Oregon                      Texas                 Washington
    Labs OC01-17               Labs MN01-10               Labs NY01-04                   Labs EV01-12               Labs TX01-09              Labs NC01-05
         41 Tesla            9349 W Broadway Ave.         4939 Jordan Rd.        6775 NE Evergreen Pkwy #400       3801 E Plano Pkwy         19201 120th Ave NE
    Irvine, CA 92618        Brooklyn Park, MN 55445      Elbridge, NY 13060           Hillsboro, OR 97124           Plano, TX 75074           Bothell, WA 98011
     (949) 861-8918             (612)-638-5136             (315) 554-8214                (503) 844-4066              (469) 304-5255            (425)984-6600

                                                                              NVLAP
NVLAP Lab Code: 200676-0   NVLAP Lab Code: 200881-0   NVLAP Lab Code: 200761-0       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                  N/A                         2834D-1                    2834G-1                   2834F-1
                                                                              BSMI
   SL2-IN-E-1154R             SL2-IN-E-1152R                    N/A                      SL2-IN-E-1017             SL2-IN-E-1158R            SL2-IN-E-1153R
                                                                              VCCI
        A-0029                     A-0109                       N/A                          A-0108                     A-0201                    A-0110
                               Recognized Phase I CAB for ACMA, BSMI, IDA, KCC/RRA, MIC, MOC, NCC, OFCA
       US0158                      US0175                       N/A                         US0017                     US0191                    US0157




 Report No. STAK0144.6                                          EAR-Controlled Data                                                                               6/9


PRODUCT DESCRIPTION
                                                                                           2018-07-17




Client and Equipment Under Evaluation Information
Company Name:                     Starkey Laboratories, Inc.
Address:                          6600 Washington Ave. SO.
City, State, Zip:                 Eden Prairie, MN 55344
Evaluation Requested By:          Bill Mitchell
Model:                            Mini Remote Microphone
Date of Evaluation:               Monday, December 31, 2018

Information Provided by the Party Requesting the Evaluation

Functional Description of the Equipment:
This a remote microphone device for 2.4 GHz hearing aid using BLE.

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




Report No. STAK0144.6                      EAR-Controlled Data                                    7/9


SAR TEST EXCLUSION
                                                                                                          EXRPT.2017.10.02




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. STAK0144.6                         EAR-Controlled Data                                                      8/9


SAR TEST EXCLUSION
                                                                                                           EXRPT.2017.10.02




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)] · [vf(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.

The SAR Test Exclusion Threshold is summarized in the following table:
                                       Measured                        Minimum
                      Transmit                                                      Exclusion
     Radio                          Conducted Output   Duty Cycle     Separation                Limit   Compliant
                  Frequency (MHz)                                                   Threshold
                                      Power (mW)                    Distance (mm)
  Bluetooth Low
                       2440              3.641           0.0756          5            0.086      3.0      Yes
  Energy (DTS)


The information in the table above was obtained from:

Element STAK0144.1 report, Antenna Exhibit, Operational Description, and client supplied RF Exposure
Information form and associated email.

Per Bill Mitchell, Principle Regulatory Affairs Engineer, Starkey Hearing Technologies:

          "Per the Operational Description, in audio streaming mode, which is the mode the Mini Remote
          Microphone will be in almost all the time, the Mini Remote Microphone transmits one 312 uS packet
          every 4.125 mS (or about 7.6% duty cycle)."

Note: The initial network association mode has a duty cycle of less than 1%




Report No. STAK0144.6                                  EAR-Controlled Data                                              9/9



Document Created: 2019-06-07 03:00:35
Document Modified: 2019-06-07 03:00:35

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