RF Exposure

FCC ID: EOA-24WR

RF Exposure Info

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FCCID_3368908

                                Starkey Laboratories, Inc.
                                      TruLink Remote Model 600
                                     Bluetooth Low Energy Radio
                                              FCC 2.1093:2017

                                          Report # STAK0086.8




                                          NVLAP Lab Code: 200881-0


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 whether in the
United States or abroad.

This report must not be used to claim product certification, approval, or endorsement by NVLAP, NIST, or any
agency of the federal government of the United States of America. This Report shall not be reproduced, except in
full without written approval of the laboratory.


CERTIFICATE OF EVALUATION
                                                                                                                               2017-1-25




                                     Last Date of Evaluation: April 4, 2017
                                           Starkey Laboratories, Inc.
                                      Model: TruLink Remote Model 600



Technical Brief
Standards
Specification                                                    Method
FCC 2.1093:2017                                                  FCC 447498 D01 General RF Exposure Guidance v06


Results
Method
            Description                            Applied     Results           Comments
Clause
4.3.1       SAR Evaluation Exemption                 Yes            Pass



Deviations From Evaluation Standards
None


Approved By:


Donald Facteau, Systems Architect




This report must not be used to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the federal
government of the United States of America.

Product compliance is the responsibility of the client, therefore the evaluation and equipment modes of operation represented in this
report were agreed upon by the client, prior to evaluating. This Report may only be duplicated in its entirety. The results of this
evaluation pertain only to the sample(s) evaluated. The specific description is noted in each of the individual sections of the
evaluation report supporting this certificate of evaluation. This report reflects only those evaluations from the referenced standards
shown in the certificate of evaluation. It does not include inspection or verification of labels, identification, marking or user
information.




Report No. STAK0086.8                                EAR-Controlled Data                                                             2/9


RF Exposure Condition
                                                                                               2017-1-25




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            Hearing Aid remote
Co-located Radios                 None
Simultaneous Transmitting Radios  None
Body Worn Accessories             N/A
Environment                       Occupational/Controlled Exposure




Report No. STAK0086.8                   EAR-Controlled Data                                          3/9


 ACCREDITATIONS AND
 AUTHORIZATIONS                                                                                                                      2017.1.25




 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 – Validated by the European Commission as a Notified Body under the R&TTE Directive.

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

 Korea
    MSIP / 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:
                                   http://portlandcustomer.element.com/ts/scope/scope.htm
                                     http://gsi.nist.gov/global/docs/cabs/designations.html




Report No. STAK0086.8                                  EAR-Controlled Data                                                              4/9


    FACILITIES
                                                                                                                                                            2017.3.2




      California                Minnesota                   New York                       Oregon                      Texas                 Washington
     Labs OC01-13            Labs MN01-08, MN10            Labs NY01-04                 Labs EV01-12                Labs TX01-09             Labs NC01-05
        41 Tesla            9349 W Broadway Ave.         4939 Jordan Rd.         22975 NW Evergreen Pkwy         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                       N/A                   2834D-1, 2834D-2                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. STAK0086.8                                          EAR-Controlled Data                                                                           5/9


 REVISION HISTORY
                                                                             2017.1.25




 Revision
                        Description                     Date   Page Number
 Number
 00       None




Report No. STAK0086.8             EAR-Controlled Data                           6/9


PRODUCT DESCRIPTION
                                                                                                                  2017-1-25




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:                                TruLink Remote Model 600
Date of Evaluation:                   April 4, 2017

Information Provided by the Party Requesting the Evaluation

Functional Description of the Equipment:
The TruLink Remote operates in the 2.4 - 2.4835 GHz band and uses the Bluetooth® Low Energy protocol to
communicate with the hearing aids. The remote is paired with the hearing aid using the Bluetooth Low Energy
protocol. The remote can be paired with either a left or a right hearing aid or both a left and a right binaural pair
of hearing aids.

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




Report No. STAK0086.8                           EAR-Controlled Data                                                     7/9


SAR TEST EXCLUSION
                                                                                                          EXRPT.2017.03.16




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. STAK0086.8                         EAR-Controlled Data                                                      8/9


SAR TEST EXCLUSION
                                                                                                         EXRPT.2017.03.16




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 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)
     BT             2402             0.71136            1             5            0.220      3.0       Yes




Report No. STAK0086.8                               EAR-Controlled Data                                               9/9



Document Created: 2017-10-26 05:50:54
Document Modified: 2017-10-26 05:50:54

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