TELECOM ACCESS STANDARDS NEWSLETTER NO. 147

March 2004

CONTENTS
1. RE-LOCATION OF TELECOM’S AUCKLAND BROADBAND TECHNOLOGY LABORATORY
2. TELEPERMIT HOLDER AND SUPPLIER RESPONSIBILITIES
3. TELEPERMIT APPLICATIONS - LABEL INFORMATION
4. TELECOMMUNICATIONS RELAY SERVICE
RETURN TO MAIN INDEX



1. RE-LOCATION OF TELECOM’S AUCKLAND BROADBAND TECHNOLOGY LABORATORY

As advised in Newsletter No. 146, the Telecom test laboratory (which is now installed in the Mayoral Drive Building in Auckland) is being re-located to the “Network Integration Laboratory” in Wellington.

This move started on 29 March. As a result, there will be some disruption to the services offered by this laboratory, but it is hoped that it will be more or less back in operation in early-mid April.

New contact details will be published on our website as soon as we have them.


2. TELEPERMIT HOLDER AND SUPPLIER RESPONSIBILITIES

As far as Telecom is concerned, the Telepermit Holder is held responsible for ensuring the ongoing compliance of all items supplied and labelled with a given Telepermit number. Needless to say, the actual manufacturer is really the only party that can state whether later batches of a product have been changed in some way and, if so, give an assurance that the changes do not impact on compliance. The Telepermit holder is responsible for getting this assurance before putting any Telepermit labelled product on the local market.

The growing trend for companies to use “outsourcing” for many business functions has extended to the Telepermit system in recent years. We have always accepted the situation where a test lab or consultant will assemble a Telepermit application and its supporting documents, but have insisted that the application is signed by a New Zealand resident (a person subject to New Zealand law), who is formally authorised to do so by the proposed Telepermit holding company.

The signed undertaking in the application and the subsequent Telepermit grant then constitute a formal contract between that company and Telecom, under which Telecom gives its agreement to the connection of equipment to its network and the Telepermit holder undertakes to ensure compliance with Telecom’s requirements.

Some manufacturers wish to outsource the whole process, including the contractual obligation to ensure ongoing compliance. This partly results from the Australian self-declaration process (now adopted by the Ministry of Economic Development for EMC compliance) under which a Technical Compliance Folder (TCF) must be made available by the importer (or local manufacturer) whenever the regulatory body requests it. The responsibility for maintaining the TCF may be contracted to a test lab or other party outside the actual manufacturer’s or importer’s organisations. Some Australian companies have asked whether the chosen contractor can undertake their compliance obligations for both Australia and New Zealand.

This has led to requests for Telepermit applications to be submitted and signed by the contractor concerned, independent of whether that party is here or in Australia. This is acceptable to Telecom on the condition that we are supplied with a formal letter from the New Zealand importer authorising the contractor concerned to enter into a contract on its behalf. This means that the New Zealand importer is still, although indirectly, contracting to comply with the General Conditions of PTC 100 and any special conditions of each Telepermit grant.

What must be clearly understood is that the importer of any product into New Zealand is still responsible for the regulatory and Telepermit compliance of that product – NOT the contractor that signed the application on that importer’s behalf.

Suppliers should note that the use of “contractors” to maintain a Technical Compliance Folder or submit and sign Telepermit applications is restricted to New Zealand or Australian-resident companies. This is acceptable because of the close commercial and legal relationships between New Zealand and Australia under which Australian companies can register in New Zealand without an actual New Zealand presence.


3. TELEPERMIT APPLICATIONS - LABEL INFORMATION

Unlike the new EMC framework, under which the Ministry issues Supplier Code Numbers and that same number is marked on all of that supplier’s products, along with the “C-tick” compliance mark, the Telepermit system is based on clear identification of each make and model of CPE that may be connected to the Telecom network.

In Telecom’s case, any non-compliant or poorly performing CPE item can impact directly on the quality of service offered to our customers – not just the users of any suspect CPE, but also on those parties communicating with those users. In view of this, it is important that any of the nearly 8 000 different products now granted Telepermit can be easily identified should service problems be reported. We can accurately identify items with similar names by asking for the Telepermit number on the product label.

To make sure the product concerned is the one that the permit was actually granted to, the label and the product name need to be aligned.

In making Telepermit applications, suppliers are asked to decide on and advise the brand name and product identification that are going to be used for marketing purposes in New Zealand, especially if the “local” details are different from those of the same product sold overseas.

From time to time, model name changes are made without reference to Telecom. While a supplier is always able to make such changes, one of the conditions of each Telepermit grant is that

“The grant of this Telepermit is specific to the product with the marketing description stated on the Telepermit label artwork. The Telepermit may not be assigned to other parties or other products without Telecom approval.”

That approval will be given on request. However, as it only causes confusion if the label details and the product details do not match, Telepermit holders are reminded of their obligation to advise Access Standards of any changes in the product description.


4. TELECOMMUNICATIONS RELAY SERVICE

The Ministry of Economic Development issued a series of “Requests for Proposals” for this new service just before Christmas and we have received a number of enquiries since that time. For those readers not familiar with the term, the Telecommunications Relay Service will provide greatly improved communication facilities between “normal hearing” customers using telephones and deaf or hearing-impaired customers using “Textphones” (special telephones equipped with keyboards, displays and/or printers). In addition, it will provide a protocol conversion service so that the various types of text devices, PC’s, etc, that may be used by deaf and hearing-impaired persons are able to communicate with one another.

Many deaf and seriously hearing-impaired persons obviously cannot use even those telephones with enhanced receive amplification and/or inductive coupling to hearing aids. Instead, when this service is set up, they will be able to hire or purchase a “textphone” or make use of a PC with purpose-designed software. These devices will enable them to send to and receive text messages from a central “relay” operator. Similarly, a telephone user needing to communicate with the textphone user will phone the relay operator and ask for a text message to be sent to that user. This relay operator stays on line for the duration of the call, reaing text messages to the telephone user and typing out the telephone user’s message for the textphone user.

Needless to say, this service should provide valuable help for textphone users, especially for those simple tasks of calling a taxi or ordering products from the local shops.

The service is being based on compliance with ITU Recommendation V.18 and AS/NZS 4277, which covers the user interface. As far as Telepermit issues are concerned, any terminal equipment generally described as a “textphone” and connected to Telecom’s analogue network will be required to comply with PTC 200. At this early stage, it is not expected that there will be any “special conditions” but, once a successful contractor has been appointed for the overall system, Access Standards will liaise with that contractor to determine whether there are any special textphone requirements that need to be recognised in our PTC Specifications.

For the central equipment side of the system, the prospective suppliers will also need to comply with any PTC Specifications that are relevant to their proposed network interfaces.

The usual safety and EMC compliance requirements apply to both textphones and the central equipment.



Doug Burrus
Manager
Access Standards