Response to FCC questions 17631 (same as above)

FCC ID: HN21555-900

RF Exposure Info

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FCCID_132205

                            ROGERS LABS, INC.
                                           th
                            4405 West 259 Terrace
                            Louisburg, KS 66053
                            Phone / Fax (913) 837-3214


January 11, 2001

Federal Communications Commission
Equipment Approval Services
P.O. Box 35815
Pittsburgh, PA 15251-3315

Applicant:       INTERMEC TECHNOLOGIES CORPORATION
                 6001 36th Avenue West
                 Everett, WA 98203-9280
                 Phone: (505) 856-8054

RE: Correspondence Reference Number: 17631

Equipment:                    FCC ID: HN21555-900


Gentlemen:

Please find enclosed the response to request for additional information regarding the submittal for grant of
certification of Intentional Radiators operated in the frequency range of 902 – 928 MHz. It has been
requested that the information contained in the block diagrams, operational description and schematics of
the application be held confidential per Section 0.459.

A copy of the information request has been reproduced here for reference.

To:                Scot Rogers, Rogers Labs, Inc
From:              Joe Dichoso
                   jdichoso@fcc.gov
                   FCC Application Processing Branch

Re:             FCC ID HN21555-900
Applicant:                                                Intermec Corporation
Correspondence Reference Number:                17631
731 Confirmation Number:                                  EA98687


The RF safety issues are numbered below.
FYI, you did address the following which was requested via e-mail with correspondence number 17505.
please address it separately. FYI, with regard to the output power issues, you are using the formula to
calculate the conducted output power but list it as EIRP.
EIRP= (E*d)^3/30. P(conducted)= (E*d)^2/30G.
EIRP= P*G.

The only other item is whether or not the device meets the definition of a FHSS system. We are on the
"lookout for TAG readers that send only a CW signal to the TAG. These do not meet the definition as they
do not meet the have a carrier that is modulated with information and the information is written to the tag.
Please describe the information that is modulated onto the the carrier and verify that the information is
written to the TAG.


ROGERS LABS, INC.                     INTERMEC TECHNOLOGIES CORPORATION
4405 W. 259th Terrace                 MODEL: 1555 Hand Held Reader
Louisburg, KS 66053                   Test #: 000815                FCCID#: HN21555-900
Phone/Fax: (913) 837-3214             Test to: FCC Parts 2 and 15           FCCresponseletterref16801.doc   01/11/2001


l Page 2                                                                                     January 11, 2001




RF SAFETY ISSUES...

Intermec, EA 98687 -

1. The response to output power is incorrect. When EIRP is computed from measured field strength, there
should not be any adjustments for the antenna gain. The antenna gain should have already been
considered in the field strength results. Please review the applicable equations, computations and clarify
accordingly.

2. Rules in 15.247 requires peak conducted output to be listed on the grant. The SAR report has indicated
a conducted output of 29.8 dBm, which implies it is feasible to measure peak conducted output for this
device. Please provide the peak conducted output measurements for the applicable channels.

3. The antenna is at the front of this device. The bottom side (touching) SAR was positioned with the
antenna tilting away from the phantom (non-touching). This generally results in lower SAR and will not be
acceptable for future filings. For the current filing, since this is a hand-held only device and RF exposure is
not expected to become an issue, therefore, additional testing is not requested. Please confirm that the RF
exposure statement submitted earlier that requires a 4 cm separation distance from the bodies of users and
bystanders will be incorporated in the manual.

Note: Output is Unknown, submitted incorrect EIRP, need to re-confirm conducted output in SAR report.

Proposed Grant Condition - This transmitter operates in a specific hand-held RF tag reader. The device
has been tested for SAR compliance for typical hand-held use and must be operated in a person's hands
with a separation distance of 4 cm or more from the body of users and bystanders (except for hands and
wrists) to satisfy RF exposure compliance. Users must be informed of the operating requirements for
satisfying RF exposure compliance. The highest reported SAR values are Body: 0.57 W/kg; Hands: 2.97
W/kg.

Kwok Chan




ROGERS LABS, INC.                  INTERMEC TECHNOLOGIES CORPORATION
4405 W. 259th Terrace              MODEL: 1555 Hand Held Reader
Louisburg, KS 66053                Test #: 000815                FCCID#: HN21555-900
Phone/Fax: (913) 837-3214          Test to: FCC Parts 2 and 15                     FCCresponseletterref17631a.doc 01/11/2001


l Page 3                                                                                      January 11, 2001




RESPONSE
1. Note: The EIRP numbers given in the initial application were incorrect and have since been corrected.
The conducted output power of the unit has been measured and is reported below. The corrected
calculations for the EIRP are giving in the following table. The measured 128 dBuv was first converted to
                                                               (dBuv-120/20)
volts per meter at three meters using the equation E(v/m)=10                 and using this to calculate the EIRP
                                2
from the equation EIRP(w)=(Ed) /30.

      FSM (dBuv)                  Calculated volts/meter          Calculated EIRP
      128                         2.512                           1.89

2. The output power of the unit was measured at the manufacturer service port for three frequencies.

      Frequency (MHz)                         Output Power (dBm)
      902.6                                   29.8
      915.0                                   29.7
      927.4                                   29.6

3. The SAR test report was based on the conducted power measurements shown above. The report
indicates the testing was performed with phantom touching the bottom of the unit. Thus simulating the
position of the hand around the handle of the product. The antenna, as pictured on page 29 of the
certification report, is positioned closest to the bottom of the unit thus placing the handle closest. The two
element antenna pattern has the active element placed in the middle of the board. The operator warning
paragraph on page 5 of the owners manual states that for compliance the front of the unit must maintain a
distance of at least 4 cm from the front of the device to any bystanders and the operators body and parts
also. Please advise if you require another copy of the owners manual uploaded to the FCC web site.

Please use this corrected data and continue processing the application for a grant of certification.

Should you require any further information, please contact the undersigned.
Thank you for your consideration in this matter.
Sincerely,


Scot Rogers
Rogers Labs, Inc.
Enclosures




ROGERS LABS, INC.                   INTERMEC TECHNOLOGIES CORPORATION
4405 W. 259th Terrace               MODEL: 1555 Hand Held Reader
Louisburg, KS 66053                 Test #: 000815                FCCID#: HN21555-900
Phone/Fax: (913) 837-3214           Test to: FCC Parts 2 and 15                     FCCresponseletterref17631a.doc 01/11/2001



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Document Modified: 2019-10-28 13:24:07

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