Archived — Notice No. SMSE-016-01
Notice No. SMSE-016-01 — Public Discussion on Simplifications to the Conformity Assessment Process for Telecommunications Terminal Equipment
The purpose of this notice is to invite public comments on how the conformity assessment process for telecommunications terminal equipment could be simplified in Canada. Specifically, the Department is seeking comments on the benefits that a self-declaration approach would offer to Canadian consumers.
Currently, suppliers of telecommunications terminal equipment are required to certify their products to Industry Canada's certification requirements in order to demonstrate conformity. However, industry worldwide is promoting the adoption of the Suppliers' Declaration of Conformity (SDOC) as the preferred approach to assuring product conformity.
In the U.S., the Federal Communications Commission (FCC) conducted a public consultation on the streamlining of the Part 68 registration process as part of its 2000 Biennial Regulatory Review. On , the FCC released a Report and Order (CC Docket 99-216, FCC 00-400) which transfers most of the FCC's current Part 68 functions to the private sector. Among other changes, the FCC Order gives suppliers the option of using SDOC to demonstrate conformity to the appropriate technical requirements. The text of the Order can be found at the following web site: http://www.fcc.gov/ccb/nsd/documents/PART68.HTML .
3. Possible Approach
Two self-declaration procedures can be considered as alternatives to certification: Declaration of Conformity and Suppliers' Declaration of Conformity.
Declaration of Conformity (DOC) is an equipment approval procedure under which the party responsible for the equipment's compliance (i.e. the manufacturer, importer, or assembler), has the equipment tested to ensure that it complies with the appropriate technical standards. The party performing such measurements must be a designated or recognized testing laboratory. Currently, Industry Canada's certification program requires the use of designated/recognized laboratories. according to DES-LAB or REC-LAB procedures established for Phase I of Mutual Recognition Agreements/Arrangements.
Supplier's Declaration of Conformity (SDOC), as defined in ISO/IEC Guide 22, requires responsible parties to test for and declare conformity of their own equipment with required technical criteria, or at their option, have it tested by an independent laboratory. Unlike the DOC process, SDOC does not require testing of the equipment by a designated/recognized laboratory.
The Declaration of Conformity approach seems to be the most appropriate alternative for the Canadian environment. The following scenario is offered for discussion:
I. Suppliers would demonstrate conformity to telecommunications terminal equipment requirements by providing Industry Canada with a Declaration of Conformity. Suppliers would be required to use the services of designated/recognized testing laboratories.
Some control must exist as part of any self-declaration scheme to make it trustworthy. SDOC, as implemented in the U.S., relies strongly on post-market surveillance and severe penalties for non-compliance. Currently, such controls do not exist in the Canadian regulatory environment. With DOC, control is exercised at the beginning of the process, by ensuring that testing laboratories meet some minimum criteria. Laboratory accreditation ensures that measurements are performed by competent organizations and ensures traceability of measurement results. Given that laboratory accreditation is already a requirement in Canada, moving to DOC would require a minimum of change in regulations and it could be implemented fairly quickly.
II. Certification would no longer be required or offered for telecommunications terminal equipment
The FCC Order allows, as an alternative to SDOC, certification using Telecommunications Certification Bodies (TCBs). Canada does not have any private Certification Bodies to certify telecommunications terminal equipment, and therefore DOC would be the only option in Canada to demonstrate conformity to technical requirements.
Industry Canada's Certification and Engineering Bureau would no longer certify telecommunications terminal equipment but would continue to perform other functions such as developing test requirements, providing testing services, maintaining a database of compliant equipment and providing assessment services for suppliers who want test results analysed.
III. A notification to Industry Canada would be required identifying the product subject to declaration of conformity.
The notification could include the following information for listing in the database:
- Filing Number, which consists of:
- Declaring party code (assigned by Industry Canada), and
- Unique Product Number (assigned by declaring party)
- Declaring Party Information
- Company name and address
- Contact person (name, mailing address, e-mail, fax, telephone)
- Contact point in Canada, if any
- Product Information
- Manufacturer name and address
- Model name and/or number (as it appears on the product)
- Type of equipment (from the equipment category code list)
- Ringer Equivalence Number
- Network interface type
- Multi line or single line
- Product Testing Information
- Designated/recognized testing laboratory used (name and address)
- Requirements to which the product was tested (e.g. CS-03, Part I, Issue 8, Amendment 4)
4. Invitation to Comment
Industry Canada, through this consultation, wishes to determine whether the public interest would be served by implementing a new conformity assessment process for telecommunications terminal equipment based on self-declaration. Industry Canada also seeks comments on other issues not addressed here such as labeling/marking requirements, complaint procedures, auditing, and suppliers' obligations and liabilities.
Based on the comments received and further consideration of these and any other relevant issues, the Department will, at an appropriate time, announce its decision. This Notice is available electronically at the following Internet address: World Wide Web (WWW), http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/home or can be obtained in hard copy, for a fee from:
- Tyrell Press Ltd.
- 2714 Fenton Road, Gloucester, Ontario K1T 3T7 Canada
- toll-free telephone:
- United States toll-free telephone:
- Worldwide telephone:
- DLS, St-Joseph Print Group Inc.
- 45 Sacré-CoeurBoulevard Hull, Quebec K1A 0S7 Canada
- toll-free telephone:
- Canada toll-free facsimile:
- Worldwide telephone:
- Worldwide facsimile:
Interested parties should submit their comments in electronic format (WordPerfect, Microsoft Word, Adobe PDF or ASCII TXT) to facilitate posting on the Department's Web site. Documents submitted should be sent with a note specifying the software, version number and operating system used. All comments should make reference to "Comments - Gazette Notice SMSE-016-01" and be sent to: firstname.lastname@example.org. Written submissions must be addressed to the Deputy Director, Telecommunication Engineering and Certification, Industry Canada, 300 Slater Street, Ottawa, Ontario, K1A 0C8. They must cite the Canada Gazette, Part I, the publication date, the title and the Notice reference number (SMSE-016-01).
To ensure that all comments are duly considered, submissions must be received no later than 60 days following the publication of this notice. All comments will be posted on the Industry Canada Web site (http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/home) shortly thereafter.
Spectrum Engineering Branch
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