ARRL Again Complains to FCC about Illegal Marketing of Electronic Lighting Ballasts
The ARRL has again complained to the FCC to allege illegal marketing of electronic RF lighting ballasts, operating under Part 18 of the Commission’s rules, on the part of two major retailers. Letters went out this week to the FCC Enforcement Bureau and its Office of Engineering and Technology claiming Part 18 marketing regulations violations by Lowe’s and by Walmart stores. At issue is the sale of non-consumer RF lighting ballasts to consumers who, in several instances, were told by store personnel that it was okay to install these in a residential setting. In addition, non-consumer and residential-class ballasts are intermixed in store displays with inadequate signage to direct consumers to the correct choice. Both letters asked the FCC to investigate and commence enforcement proceedings with respect to the two stores’ marketing and retail sale of RF lighting devices in the US.
“ARRL purports to show that the [retailer] is…marketing and selling to consumers (by retail sale) non-consumer Part 18 RF lighting devices which are not intended for residential deployment, to consumers who have specifically noted their intention to deploy the devices in residential applications,” ARRL Chief Counsel Chris Imlay, W3KD, said in similar complaint letters to the Commission on December 28 and December 29 (attached below). Part 18 emissions limits for consumer devices are far lower than those allowed for non-consumer devices.
“ARRL has received numerous complaints from Amateur Radio operators of significant noise in the medium (MF) and high frequency (HF) bands between 1.8 MHz and 30 MHz from ‘grow lights’ and other Part 15 and part 18 RF lighting devices,” Imlay continued. “These devices are easily capable of emitting RF noise sufficient to preclude Amateur Radio MF and HF communications (and, as well, AM broadcast station reception) throughout entire communities.”
Supporting both complaints are extensive and detailed reports by ARRL Laboratory EMC Specialist Mike Gruber, W1MG. The reports recount incidents of actual purchases of Part 18 RF lighting devices intended for commercial use to consumers who made clear to store personnel that they intended to use the devices at home. Gruber’s report includes multiple photographs that depict in-store displays of the products in question and showing signage that does not adequately explain which devices may be sold to whom.
The ARRL has asked that all non-consumer devices be removed from retail sale and marketing at the stores and to track and recall non-consumer devices already sold to consumers.
In his report, Gruber concluded that retailers should require purchasers of non-consumer Part 18 RF lighting devices to provide a valid contractor’s number. He also advised that the stores improve display signage to make it clear that non-consumer Part 18 devices may not be used in residential settings.
Earlier this year, the ARRL sent similar complaint letters to the FCC regarding the marketing of Part 18 RF lighting devices by The Home Depot. The League also has complained about specific RF lighting “grow light” devices that it has alleged exceed Part 18 emission limits.