The ARRL has filed a formal complaint with the FCC, alleging that The Home Depot home improvement chain has been illegally marketing certain RF-ballast lighting devices in violation of FCC Part 18 rules. Accompanying the League’s July 14 letter to FCC Enforcement Bureau Spectrum Enforcement Division Chief Bruce Jacobs and Office of Engineering and Technology Laboratory Division Chief Rashmi Doshi was a 20-page report prepared by the ARRL Laboratory’s Mike Gruber, W1MG. His report outlines four instances in which ARRL investigated The Home Depot’s marketing and sale to consumers of non-consumer-rated RF lighting devices.
In three cases, Home Depot sold non-consumer devices having far greater emission limits and intended for commercial use to consumers who specifically voiced an intention to use the devices in residential settings. Although notices accompanying the store’s display and with devices purchased indicated that they were for commercial use, the information did not specify that the devices could not be used in for residential purposes. In the case of products that did include such a notice, the information was not visible without opening the packaging.
“Clearly Home Depot’s marketing and sale of non-consumer ballasts is not adequate to ensure compliance with FCC Part 18 requirements,” Gruber’s report concluded. The ARRL asked the FCC to “investigate and commence and enforcement proceeding” regarding The Home Depot’s retail marketing and sale of RF lighting devices in the US.
In its letter, the League noted that it has received numerous complaints from the Amateur Radio community of “significant noise” in the bands between 1.8 and 30 MHz from so-called “grow light” ballasts and other RF lighting devices regulated under FCC Part 18 rules. Gruber said emissions from grow light ballasts were measured in the ARRL Lab to be way above both non-consumer and consumer Part 18 emissions limits.
Although otherwise legal non-consumer rated ballasts — the subject of ARRL’s complaint — are not nearly as problematic as grow lights, they can still cause interference beyond what would normally be expected or easily addressed in a residential environment. The devices at issue in the League’s complaint are only legal in commercial and industrial environments, and should not be used for residential purposes due to the higher Part 18 emission limits permitted for industrial and commercial devices.
According to the League, its investigations in several states revealed an alarming number of instances of retail sale of electronic lighting ballasts, in which non-consumer-rated ballasts were mixed in with consumer ballasts and other consumer products.
“In most of the stores surveyed, unsuspecting consumers have no way of knowing the significance of consumer vs. non-consumer ballasts,” the League said. “In some cases, ‘commercial’ grade ballasts, with their associated non-consumer emission limits, appeared to be a heavier duty or superior product. The display signage typically used implies, therefore, that commercial ballasts are also a product upgrade for home use.” The ARRL said that store display signage typically did not mention or adequately address applicable FCC Part 18 requirements, as they pertain to interference in a residential environment.
The League said consumers in three of the four instances it investigated made actual purchases of RF lighting devices at The Home Depot retail outlets and “specifically asked about residential deployment of non-consumer RF lighting ballasts.” The ARRL said it’s apparent that The Home Depot — and, by inference, other similar retail stores — is “actively and knowingly engaged” in selling commercial RF lighting products to customers for use in residential environments.
“If this activity is left unchecked the Commission will continue to note a deterioration in ambient noise levels and preclusive interfering signals for both AM broadcasters and Amateur Radio licensees in the entirety of the high-frequency bands,” the League’s complaint said.
The ARRL asked the Commission to “take appropriate action” with respect to The Home Depot and other retail outlets marketing such RF lighting devices “without delay.”
A copy of the letter was sent to The Home Depot’s Atlanta, Georgia, Store Support Center.