ACTA-08-023

ADMINISTRATIVE COUNCIL FOR TERMINAL ATTACHMENTS (ACTA)

TITLE:Report of Connector Attestation Ad Hoc Group

MEETING DATE:December 11, 2008

SUBMISSION DATE:November 25, 2008

SOURCE*:Chair Connector Attestation Ad Hoc Group

PURPOSE:Information/Discussion/Decision

DISTRIBUTION TO:ACTA Members

ABSTRACT

This contribution provides a report of the ACTA Connector Attestation Ad Hoc Group. The contribution contains a description of the proposed Connector Attestation Process and a list of the next steps the Ad Hoc group will undertake to implement the process.

NOTICE

This is a draft document and thus, is dynamic in nature. It does not reflect a consensus of ACTA and it may be changed or modified. ACTA makes no representation or warranty, express or implied, with respect to the sufficiency, accuracy or utility of the information or opinion contained or reflected in the material utilized ACTA further expressly advises that any use of or reliance upon the material in question is at your risk ACTA shall be liable for no damage or injury, of whatever nature, incurred by any person arising out of any utilization of the material. It is possible that this material will at some future date be included in a copyrighted work by ACTA.

* CONTACT: Trone Bishop – Verizon – 301-236-3754;

Report of Connector Attestation Ad Hoc Group

Earlier in the year, the ACTA formed the Connector Attestation Ad Hoc group to explore the feasibility of ACTA establishing a Connector Attestation Process. Trone Bishop was appointed Chair of the group and John Bipes, Milton Bush, Mark Cassarino, Roger Hunt, Scott Lambert, and Jimmy Salinas volunteered to participate. Subsequently, Roger Hunt resigned from the ACTA.

The Ad Hoc group met by conference call on Nov. 14 and Nov. 21 and agreed to the assumptions and Connector Attestation Process described below.

Assumptions:

1. TIA-1096-A compliance is not required for:

  1. Connectors on TE that cannot be directly connected to wireline carrier networks.
  2. TE plugs and jacks that are not involved in direct connections to wireline carrier networks. For example, plugs and jacks on handsets and handset cords used to connect handsets to the base units of telephones.

2. TIA-1096-A compliance is required forTE plugs and jacks that are used to directly connect TE to wireline carrier networks. For example, the plugs and jacks furnished with a telephone that are used to connect the telephone to the network interface or customer wiring leading to the network interface.

3. Most terminal equipment manufacturers and Responsible Parties do not manufacture the plugs and jacks used on their terminal equipment and they donot have the capability to completely test all TIA-1096-A requirements for plugs and jacks. For example, the percentage of gold in the contact material and the hardness of the gold contact material are tests that need to be done the contact material prior to plug and jack manufacture.

4. Connector manufacturers design and build plugs and jacks to the TIA-1096-A standard.

5. Connector manufacturers test materials used for plug/jack contacts and the finished plug/jacks to verify compliance with TIA-1096-A.

6. Connector manufacturers institute a quality assurance program to assure continuing compliance with TIA-1096-A.

7. ACTA has the authority under 47 C.F.R. Sec. 68.320(d) to specify which records the RP must maintain in English and make available to the FCC upon request.

Proposed Process:

1. Connector manufacturer retains all records of test methods, test results, and continuing compliance in English and will make compliance file records available to the FCC upon request.

[This requirement is established under the authority given to the ACTA in 47 C.F.R. Sec. 68.320(d).]

2. Connector manufacturer attests that:

  1. Connectors meet all requirements of TIA-1096-A and indicates whether plug and jack contacts meet the requirements for:
  2. hard gold; or,
  3. an alternative material equivalent to hard gold;
  4. It has instituted a quality assurance program to assure continuing compliance with TIA-1096-A.

3. Connector manufacturer provides the attestation of TIA-1096-A compliance letter to:

  1. ACTA; and if requested,
  2. A copy of the attestation letter to terminal equipment manufacturers (or RPs) using those connectors.

4. As an aid to consumers and the industry, ACTA keeps a database list of connector suppliers that have provided attestation letters certifying compliance with TIA-1096-A.

5. Assuming the RP does not manufacture the plug and jacks and does not have the capability to completely test all requirements for the plugs and jacks, the RP must provide for each approved terminal equipment product,

  1. A letter attesting that only TIA-1096-A compliant connectors, from a supplier listed on the ACTA’s list of connector suppliers that have attested compliance with TIA-1096-A, are used in the product for direct connections to wireline carrier networks. This RP attestation letter shall be included in the test report, retained by the RP as required by Part 68, and made available to the Commission upon request.
  2. If the RP’s connector supplier does not have an attestation letter on file with the ACTA, the supplier shall provide the RP with a letter, in English, dated not more than six months prior to the terminal equipment approval date, attesting:
  3. compliance with TIA-1096-A;
  4. indicating whether plug and jack contacts meet the requirements for hard gold or an alternative material equivalent to hard gold; and,
  5. it has instituted a quality assurance program to assure continuing compliance with TIA-1096-A.

[These requirementsare established under the authority given to the ACTA in 47 C.F.R. Sec. 68.320(d).]

Next Steps:

1. Trone Bishop will write a contribution describing the proposed Connector Attestation Processand a list of the next steps the group will take to implement the process. Completed.

2. The Ad Hoc group will develop sample attestation letters to provide guidance to the industry. Completed.

2. Mark Cassarino will forward a copy of the proposed Connector Attestation Process and sample attestation letters to ATIS Counsel Tom Goode.

3. Mark Cassarino will study the feasibility, implementation time, and cost associated with the development of a Connector Attestation letter database. Under Study.

4. The Ad Hoc group would like the ACTA Council and Chair to ask Tom Goode to provide a legal review of the proposed process.

6. If the ACTA agrees to institute a Connector Attestation Process, the Ad Hoc group will develop written procedures for making Connector Attestation letter submissions to the ACTA and propose a filing fee for such services.

7. If the ACTA agrees to institute a Connector Attestation process, the Ad Hoc group will review other ACTA documents, such as those listed below, to determine if any other ACTA documents need to be revised to reflect the Connector Attestation Process.

- ACTA Operating Principles & Procedures Version 2.2

- Guidelines & Procedures Rev. 3.1

- Customer Information Requirements

- TTE Submission Form Version 1.06

- RPC Application, Maintenance and Transfer Form Version 1.0

- ACTA Credit Card Authorization Form

Addendum A –

Sample of attestation letter connector manufacturer may submit to ACTA

The connector manufacturer may submit a letter to the ACTA attesting to compliance with TIA-1096-A and the existence of a quality assurance program to ensure continuing compliance with TIA-1096-A. The connector manufacturer attestation letter shall be written in English on the connector manufacturer’s letterhead, signed by an authorized and responsible senior executive, and notarized. Below is a sample connector compliance attestation letter for filing with ACTA and submission to the Responsible Party.

(connector manufacturer’s letterhead)
To whom it may concern:
[Insert name of connector manufacturer] attests that the products listed below comply with all of the requirements of TIA-1096-A, including the requirements for hard gold contacts.
[Insert name of connector manufacturer] also attests that it has a quality assurance program to ensure continuing compliance of the products listed below with all of the requirements of TIA-1096-A, including the requirements for hard gold contacts.
I declare that these statements are true and the list provided below is accurate.
[Insert list of compliant plug and jack model numbers with descriptions]
Signed: [Signature of authorized and responsible senior executive] Date: [Insert date]
Name: [Print name of authorized and responsible senior executive]
Address: [Insert address of authorized and responsible senior executive]
Additional contact information for authorized and responsible senior executive, such as telephone number, email address, etc.
Statement of Notary
Signature of Notary
Other Notary information

Addendum B –

Sample of attestation letter Responsible Party would include in test report

when connector manufacturer has an attestation letter on file with the ACTA.

When terminal equipment uses plugs and jacks that the connector manufacturer has attested are in compliance with TIA-968-A in a letter on file with the ACTA, the Responsible Party includes a copy of the connector manufacturer’s attestation letter to the ACTA in the terminal equipment test report and also includes a letter in the test report attesting that the plugs and jacks furnished with the approved product are from a manufacturer who has an attestation letter on file with the ACTA. The Responsible Party attestation letter shall be written in English on the Responsible Party’s letterhead, signed by the Responsible Party, and notarized. Below is a sample Responsible Party attestation letter for inclusion in terminal equipment approval test report:

(Responsible Party’s letterhead)
[Insert name of responsible party] attests that the plugs and jacks furnished with the products listed below, and used for direct connection of the equipment to wireline carrier networks, are from a manufacturer who has an attestation letter on file with the Administrative Council for Terminal Attachments in the United States attesting that said plugs and jacks comply with all of the requirements of TIA-1096-A, including the requirements for hard gold contacts.
I declare that this statement is true and that the equipment list provided below is accurate.
[Insert list of approved terminal equipment]
Signed: [Signature of responsible party] Date: [Insert date]
Name: [Print name of responsible party]
Address: [Insert address of responsible party]
Additional contact information such as telephone number, email address, etc.
Statement of Notary
Signature of Notary
Other Notary information

Addendum C –

Sample of attestation letter connector manufacturer would provide to Responsible Party when connector manufacturer does not have an attestation letter on file with the ACTA.

When terminal equipment uses plugs and jacks from a connector manufacturer who does not have an attestation letter on file with the ACTA, the Responsible Party shall obtain a letter from the connector manufacturer attestingthat the plugs and jacks furnished for use with the said terminal equipment comply with TIA-1096-A and that the connector manufacturer has a quality assurance program to ensure continuing compliance of the listed connectors with TIA-1096-A. The connector manufacturer attestation letter shall be dated within 180 days of the terminal equipment approval date, written in English on the connector manufacturer’s letterhead, signed by an authorized and responsible senior executive, and notarized. Below is a sample connector compliance attestation letter to be provided to the Responsible Party for inclusion in the terminal equipment approval test report.

(connector manufacturer’s letterhead)
To [Insert name of Responsible Party]:
[Insert name of connector manufacturer] attests that the products listed below comply with all of the requirements of TIA-1096-A, including the requirements for hard gold contacts.
[Insert name of connector manufacturer] also attests that it has a quality assurance program to ensure continuing compliance of the products listed below with all of the requirements of TIA-1096-A, including the requirements for hard gold contacts.
I declare that these statements are true and the list provided below is accurate.
[Insert list of compliant plug and jack model numbers with descriptions]
Signed: [Signature of authorized and responsible senior executive] Date: [Insert date]*
{* Note – Date must be within 180 days of the terminal equipment approval date.}
Name: [Print name of authorized and responsible senior executive]
Address: [Insert address of authorized and responsible senior executive]
Additional contact information for authorized and responsible senior executive, such as telephone number, email address, etc.
Statement of Notary
Signature of Notary
Other Notary information

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