TELECOM ACCESS STANDARDS NEWSLETTER NO. 124 September 2000 CONTENTS 1. TELEPERMIT RESERVATIONS 2. ADSL CPE ISSUES 3. ADSL TESTING 4. SUPPLY OF INFORMATION TO TEST LABORATORIES 5. SUPPLY OF INFORMATION TO CUSTOMERS 6. PTC SPECIFICATIONS IN PDF FORMAT 7. ELECTRICAL SAFETY TESTING RETURN TO MAIN INDEX 1. TELEPERMIT RESERVATIONS Now we are fully staffed, the processing time for most Telepermit applications is back to our original performance targets, with almost all dealt with in under three weeks and many during the week they are received. We introduced the Telepermit reservation option to cover those suppliers who had urgent needs for Telepermit numbers in order to label product before it was shipped from the overseas manufacturer. The main advantage of this option was subsequently lost for most analogue network products in that they required measurement of the "Ringer Number" before a label could be prepared. There was also the problem that we frequently received applications for one product, which later turned out to be several products, thus needing extra numbers. From Access Standards' viewpoint, we ended up effectively "processing" applications twice, even though the initial reservation required little detailed study. Nevertheless, the need to make reservations only further delayed the processing of full applications. All in all, the scheme had problems and did not really bring much benefit for most suppliers. In the circumstances, it is now recommended that applicants complete their testing and apply for Telepermits without first seeking reservations. The reservation fee will be saved and, in most cases, only a few days will be "lost" awaiting the Telepermit. 2. ADSL CPE ISSUES The publication of newsletter No. 123 has created a number of enquiries from suppliers and various products are being checked out with Telecom's network. Most suppliers have reported a worldwide shortage of critical components for these products, including the ADSL chipsets, flash memory, and even such relatively minor items as tantalum capacitors. This shortage has reflected on Telecom's supplies of exchange DSLAM's and modems. As reported in Newsletter No. 123, we expect to be in a fairly tight supply situation until November. Meantime, CPE suppliers can search out products, set up their distribution and support processes and gather the documentation necessary for Telepermitting these products. 3. ADSL TESTING Two local test laboratories are making progress towards accreditation as ADSL test sites and we are working with them to sort out the necessary procedures, cross-checking of test results, etc. I will announce any such accreditations in a future Newsletter and laboratory details will be published on our website. Telecom's own test laboratory is expected to drop out of this work once at least two other laboratories are available to carry out ADSL CPE test work on a competitive basis. 4. SUPPLY OF INFORMATION TO TEST LABORATORIES We still receive applications from time to time where some features of a product have not been tested. On investigation, we find that the test laboratory was handed the product with little or no documentation and it was not apparent to them that these features even existed. Suppliers are urged to provide the test laboratories with all the necessary user guides, software, and product specifications submitted in Telepermit applications. That way, the tests can be comprehensive, they can be done in one session, and delays caused by our need to have further testing carried out are avoided. As a general rule, testing needs to cover all features that relate to signals passed to or from the network, especially their levels and frequencies, and compliance with requirements defined in the relevant PTC Specification. While Telecom is not generally concerned with what might be termed "additional features", which are not actual Telepermit requirements, e.g., how many memories a telephone provides, it is important that suppliers recognise their obligations under New Zealand consumer protection legislation. In brief, this is to ensure that product capabilities are accurately stated and that no false or misleading claims have been made. For this reason, it is recommended that CPE suppliers get test laboratories to check out any claimed features, especially if there is any doubt about their correct operation when connected to the Telecom network. 5. SUPPLY OF INFORMATION TO CUSTOMERS In relation to the point made above about the accuracy of product claims, it is important that suppliers ensure that user manuals relate to operation of the product on the Telecom network and cover what the user needs to know to ensure correct operation. Many user manuals were originally prepared for one or more overseas markets. This is acceptable as long as "Telecom" operation is clearly covered. This can usually be done with local insert pages, rather than re-printing the manual as a whole. The key point is that the correct dialling codes and operating instructions are provided for local use. This includes a clear reference to any features offered by the product, which do not apply on the Telecom network. 6. PTC SPECIFICATIONS IN PDF FORMAT We are making some progress with the proposal to publish PTC Specifications "on-line", the first being PTC 270 for ADSL CPE, now available free of charge on our website. We will be publishing PTC 103 in the same format and will gradually move towards other on-line publications. Unfortunately, we are having some problems with formatting and these on-line publications may have different page breaks to the present paper versions. In such cases, we will indicate whether any actual changes have been made to the text. Where any requirements have been added or changed, we will issue a formal amendment and advise those changes in our newsletters. 7. ELECTRICAL SAFETY TESTING From time to time, we are asked about the validity of electrical safety tests carried out by overseas laboratories or the use of Compliance Certificates, as distinct from actual test reports. Our general rule is that we accept electrical safety test reports from any laboratory "recognised" by the Ministry of Consumer Affairs and listed in NZECP 3. There are many other testing laboratories around the world, which may be accepted by the Ministry. Where test reports can be made available from such laboratories, it is recommended that the supplier checks with the Ministry to make sure there is no problem. It is apparent that many of the larger overseas testing laboratories are now going "international" and extending their operations from Europe or the USA into Asian nations. Where test reports are prepared by an off-shore branch of these major laboratory organisations and effectively "endorsed" under the parent company's name, they are considered to be of equal validity to test reports prepared directly by the parent company. As such, it will not usually be necessary to check with the Ministry if the report is from an unlisted branch of a parent laboratory listed in NZECP 3. Another frequently raised issue is the use of CB Certificates. The CB scheme was originally set up in Europe to reduce the costs of gaining separate product approvals in different countries, which often have their own "special requirements" in the form of country-specific variations from a base standard, such as IEC 950 (now IEC 60950). The concept was for countries to formally join the scheme, under which a test laboratory in one member nation would test a product to the base standard and issue a CB Certificate, along with that test report, for use in other member nations. This provided for a test laboratory in each of the other member nations to simply test their own country-specific variations, with the knowledge that testing of the common requirements had already been done. Sometimes, we are sent CB Certificates without the accompanying test report. CPE suppliers should note that the actual report is still required. Although we accept overseas electrical safety tests on the basis that the NZ version of AS/NZS 3260 is essentially identical to the base standard IEC 950, another point to note is the need for traceability of product names. Often, we find that a product named "x" was tested, but a product named "y" is submitted for Telepermit. In such cases, we need a statement from the manufacturer that "x" and "y" are the same product and only the name has been changed -usually for marketing purposes. DOUG BURRUS Manager Access Standards