Washington Laboratories (301) web: Lindbergh Dr. Gaithersburg, MD William H. Graff, American TCB Overview of Hearing Aid Compatibility (HAC)

Presentation Overview This presentation is an introductory overview of the FCC Perspective to Cellphone HAC requirements and recent information released by the FCC regarding this new requirement. Detailed test methods or setups are not covered in this presentation.

What does HAC compatibility mean? That a device does not cause interference to hearing aid. That a Hearing Aid is immune to external interference which may be caused by a wireless device. That a device provides output for T-Coil so that the hearing aid can be used. Note that even with best intentions, compatibility between 2 particular random devices can not be fully guaranteed due to variances of design of all devices.

Historical Perspective – Wireline Phones During the 1970’s changes in audio transducers caused some hearing aids to no longer work with some telephones. In the 1980’s, FCC and IC implemented HAC standards for telephone connecting to the public network as part of Part 68 and CS-03 standards (wireline devices). These standards addressed only H-field performance of the telephone handsets (H-field magnitude, spatial distribution, and frequency response).

Historical Perspective - Move Toward Wireless Phones In the 1990’s, new digital technologies were found to cause audible interference in certain hearing aids Mobile phones were exempt from HAC in earlier years due to lack of applicable ratings and measurements standards. The Telecom Act of 1996 mandated compatibility, but not enough action was taken by manufacturers.

Historical Perspective – Wireless Devices ANSI C63.19 was approved in 2001 as a relevant rating and measurement standard New FCC regulation as of July 10 th 2003 mandated a certain level of availability of HAC handsets – both manufacturers and the carriers must make HAC wireless phone available to individuals using hearing aids.

Historical Perspective – Wireless Devices Since 2003, the use of wireless phones has increased dramatically. Wireless phones are used everyday for safety, business and personal use. The FCC has noted that it is more vital than ever for individuals with hearing impairment to have access to digital wireless phones.

FCC Implementation Report and Order (R&O) FCC removed exemption of certain digital wireless devices therefore making HAC required by certain mobile phones falling under Part 22, 24, and 90. ANSI C was originally referenced in the associated rules given in 47 CFR section Public Notice DA A1 accepts an updated standard draft version 2005 of C63.19.

FCC Implementation Additionally in June 2005, the FCC reaffirmed the timetable for development and sale of digital wireless phones that are HAC compliant and later on July 11 published a consumer advisory about this.

FCC Implementation - Carriers September 16, 2005 The 5 largest U.S. wireless carriers (Sprint, Nextel, Verizon Wireless, Cingular, and T-Mobile) must: oEither make 4 HAC handsets available for each air interface or oEnsure that 25% of their handset models are HAC compatible. oHAC compliance is for RF Emissions Rating M3 to 20.19(b)(1)

FCC Implementation – Manuf. September 16, 2005 Each manufacturer of handsets used with public mobile services for use in the United States or imported for use in the United States must: oMake 2 HAC handsets per air interface that meet with RF Emissions Rating of M3 to 20.19(b)(1)

FCC Implementation - Carriers During 2006 the 5 largest U.S. wireless carriers must: oBy September 16, 2006 make 5 HAC handsets available for each air interface must be compliant with with RF Emissions Rating of M3 oBy September 18, Models of each interface must comply with inductive coupling Rating of T3 to 20.19(b)(2)

FCC Implementation – Manuf. September 18, 2006 Each manufacturer of handsets used with public mobile services for use in the United States or imported for use in the United States must: o2 Models of each interface must comply with inductive coupling Rating of T3

FCC Implementation - Carriers By February 18, 2008, manufactures and carriers alike: oEnsure that 50% of their handset models are HAC compliant with RF Emissions Rating of M3 oThe results based upon our experience with business competition is that individual manufacturers must agree to HAC compatibility now or be shut out of the USA market in the future

FCC Implementation There is a legal term described as the “De minimis exception” for certain manufacturers or service provides that offer 2 or fewer handset models in the U.S. These providers are exempt from HAC requirements. But manufacturers that offer 3 or more handset models at any given time must make at least one complaint phone every 2 years.

FCC Implementation Much of this information has been published in a consumer advisory for public awareness of the FCC’s position and some implementation dates However, please note that this mainly addresses the carriers and does not adequately address the manufactures.

FCC Implementation Manufacturer information can be found in sections 20.19(c) An amendment to was published July 27, 2005, in the Federal Register under 70 FR The effective date is August 28, 2005.

FCC Implementation So it appears that while the FCC has tried to make phase in periods as straight forward as possible, suffice it to say we all feel: “Everything Is Now Clear as Mud!!”

FCC Implementation Specific questions regarding how your offerings are affected by HAC requirements, or how many units are required to be HAC compliant should be addressed to the FCC’s Wireless Telecommunications Bureau (WTB) directly. Note this is NOT the same branch of the FCC from which you obtain Equipment Authorizations

FCC Implementation WTB Contact Information: There are specific contacts at WTB that you should reach if you have questions regarding the phase in requirements and how they apply to your company. However I do not have the specific contact information today, but expect to have it shortly. If you require this information, please contact us and we will be glad to forward to you!

Additional Carrier Expectations All carriers owned and operated retail outlets must make live, in-store testing available to consumers. Carriers are encouraged to include HAC information on “call-out cards” as part of handset displays. Wireless service providers are encouraged to provide a 30-day trial period or adopt a flexible return policy. This allows individuals with hearing aids sufficient time to choose suitable phones.

FCC Rules 47 CFR All digital transmission modes in all frequency bands contained in a HAC phone must meet Level M3 or M4 levels. oAssumes held to ear usage.

FCC Rules Note: o20.19 (b)(1)-- The original U rating previously given in C63.19 – 2001 is now equal to an M rating in C o20.19 (b)(2)-- The original UT rating previously given in C is equal to a T rating in C

FCC Rules f) Labeling Requirements oHandsets used with public mobile services that are hearing aid compatible, as defined in §20.19(b) shall clearly display the rating, as defined in 20.19(b)(1)/(2) on the packaging material of the handset. An explanation of the ANSI C63.19–2003 M-rating system shall also be included in the owner's manual or as an insert in the packaging material for the handset. oAlthough the manufacturer is required to place this information on the package, it is not necessary to provide this during your equipment Certification Process.

FCC Rules Relevant user information (i.e. users manual) should be provided that: oIs complete, clear and easily understood by the average consumer. oExplains the HAC rating system for both the wireless device and hearing aids and their use as a pair.

FCC Rules oExplains how to use the device (i.e. including specific instructions about antenna positioning if applicable i.e. “the antenna should be extended for best compatibility…”). oProvides details of any special user selectable HAC modes (i.e. acceptable modes might be back light off, BT off, Tcoil on, and similar. Note that RF power cannot be reduced and basic phone functionality must be preserved.)

Manufacturer Expectations Manufactures need to start phasing in HAC compliant phones as soon as possible to meet FCC deadlines. HAC handset packaging must have prominent exterior labeling indicating the handset’s technical rating and have more detailed information included inside the package. This information will allow end users to quickly and easily determine which handsets are compatible with their hearing aids.

HAC Test Standards/Regulations ANSI C63.19 – 2001 and 2005 editions Title: American National Standard for Methods of Measurement of Compatibility between Wireless Devices and Hearing Aids Note: Europe and other regions are expected to follow with HAC requirements in the future.

HAC Test Standards/Regulations The 2005 editions was recently accepted by C63 but is currently a draft. The FCC has commented that they expect few changes, and any changes are likely not expected to impact the technical nature of the document.

HAC Test Standards/Regulations While approvals can be done to the 2001 or 2005 editions, the FCC does not expect many applications to follow the 2001 edition. Additionally, please note that approval to the 2001 edition will likely slow down and complicate the review process. Where possible, ensure compliance to the 2005 edition.

The “M” Ratings M1 – M4 Phones: - A phone which has low interference-causing emission (H- and E-field) is given a higher “M” rating. The rating is based upon a peak field strength as measured over a 5 x 5 cm grid in the region of the ear piece.

The “T” Ratings T1 – T4 Phones: - A phone is rated for quality of desired signal in T- coil mode. The rating is based on measurement of audio band magnetic signal strength, signal to noise and frequency response.

Test Evaluation – M Rating Considerations All normal ear configurations should be described and tested. One exception is that if the device has an extendable antenna, then only the extended position needs to be tested. User instructions are not considered sufficient to test a subset of operational conditions.

Test Evaluation – M Rating Considerations Options that can affect HAC must be tested (i.e. form factors, batteries, metallic face plates, etc.) If a Tcoil exists in the device, the measurement grid for M ratings shoiuld be centered and performed on both the acoustic and Tcoil locations.

HAC Test Equipment We expect that several manufacturers will be coming out with appropriate test equipment for wireless device HAC tests. However currently this equipment is already offered by both Aprel and ETS/Lindgren.

HAC Test Equipment Aprel:

HAC Test Equipment ETS/Lindgren:

Certification Applications Applications for M ratings can currently be submitted to TCB’s that have been to FCC training on HAC. Applications including T coil data or that require special accessories to be HAC compliant can currently only be submitted to the FCC directly.

Certification Applications Additionally please note that an HAC approval can be added to an existing model via a Class II Permissive Change. This assumes that there is not any hardware changes necessary to make the phone HAC compliant.

Certification Applications The FCC expects a very complete and comprehensive test report for HAC to be provided. The level of detail and data is similar in many ways to the current SAR reports you may be familiar with.

Certification Applications For example, the report should include: All contour plot with device and grid overlays, measurement uncertainity, summary of all values, measurement system description and factors, detailed EUT information (such as modulations, modes, etc), calibration information, validation information, etc.

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