Re: [PSES] I would like to hear your thoughts please

[Gert Gremmen F4LDP]

Dear All,

Within the framework of the EMCD, all configurations shall be conform, 
so if you choose to actually test,
all configurations shall be part of the test. The subject of worse case 
is a "miroir d'alouette"... how will you ever know which
is worst case without carrying out the test ? A pre-scan is informative 
but the radiated emission test contains already a pre-scan (peak) for 
the final QP-measurement.  We already require a EMC risk analysis which 
is a kind of pre-scan too. How many pre-pre-prescans will we need to be 
sure ?
"to repeat _some_ (which?) test to make sure nothing was broken" 
it's another discipline, but that is how Boeing lost a door in flight. 
And that  is not a unregulated sector without thorough quality scans 
(understatement), and still it happens. Imagine the costs and effort for 
Boeing to rebuild their reputation ? Didn't we all learned the 
exponential graph of EMC costs versus development time ?
If you need proof (for authorities, or for yourself), nothing can 
replace the actual test.


Gert Gremmen

On 6-4-2024 0:47, Lfresearch wrote:

Hi folks,

I would like to advise a client at where to draw the line on what needs 
testing. I would like to solicit opinions besides my own. Otherwise it’s the 
fox urging the chicken coop…

So a manufacturer that makes a product of which there will be several variants. 
All use the same board, but have different sections of circuits populated. This 
may require slightly different code to run on the same uP in each case.

So.. The burning question is can we perform and analysis that postulates a 
worse case hardware/software combination and test just one configuration? Or, 
do we have to do every combination?

Or, are there some guidelines about where we draw the line of what to test and 
what can be claimed as similarity?

Off list responses are welcome too.

Thanks,

Derek Walton
LFResearch/SSCLabs.

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Re: [PSES] PSU cert issue

[Gert Gremmen F4LDP]

Formally they (customs) are right.
PSU's are equipment in their own right just as PC plug-in cards and need 
EMC (CE) marking.
Testing in a full system does not guarantee that the result is the same 
as in another system, especially not in PC world where parts change 
quicker than transport time.


I do not understand why LVD and ROHS would be taken care of and not EMC.
Wasn't the electrical safety tested as part of a full system  ? 
Not the first time that customs in a associated country (for CE) are 
more severe as the EU itself. I've seen before.
It's all part of the making sure they are fit for an EU membership (even 
if local politics dare/won't not say the "join" word yet)



Gert Gremmen

On 22-3-2024 7:53, Kurt Beneder wrote:

Dear Gilbert,

One Soulution could be:
You have to include the whole list of all separate orderable spare 
part modules to your CE Declaration.

Of course the PSU is EMC LVD etc. tested in the overall system.
Also be aware that Turkey checks the Date of Issue of your CE 
Declaration against the Date of arrival of your goods in Turkey and 
therefore whether or not you had a valid CE Declaration at the time of 
importing your spare part.


Best regards Kurt

On Fri, Mar 22, 2024 at 4:10 AM Jeffrey Gilbert 
 wrote:


Having a problem sending replacement 1U PSUs into Turkey.
Apparently they (customs) are requiring full EMC certification,
which no PSU manufacturer does. They do LVD, RoHS, but not EMC.
These are useless outside of a system they are intended to be
installed into and certified in. PSU manufacturer DoC explains
this. We certify in a full system.

I am under the impression that Turkey is supposed to be following
EU CE rules. We do not have this issue in any other country on the
planet. Has anyone else run into this problem?

Jeff


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Re: [PSES] List of Common Misuses

[Gert Gremmen]

'Misuse' is the negative of 'use', or as Mike correctly made a suggestion:

"We emphasized how to use our equipment correctly, and what the scope of 
its applications were."


The better you describe the positive, the easier it is to define the 
negative.


I have seen  many operating manuals (such  as garden equipment) even 
lacking the 'positive' ie the "intentional use" of equipment. How to 
define any misuse in such a case ?



In the standardization world 3 descriptions are used

 * Intended use - a decent description of this will automatically
   define all misuses, as not addressed in the intended use description
 * Foreseeable (mis)use
 * Unforeseeable (mis)use

The foreseeable category is the one the manufacturer shall be concerned 
with. Some equipment that is able to cut grass, can be foreseeably be 
misused in many cutting applications it was not meant for. The cutting 
can be applied to not suitable materials, the lawn mower may be misused 
to attack a meadow, or your dogs long hair. (not even suggesting your 
wife's hair). A risk analysis (risk = chance*severeness*avoid-ability) 
may help in ranking misuses and the manufacture shall define the 3 risk 
thresholds were 'physical measures' (annihilating the danger) are needed 
or "warning on the equipment" or just  "warnings in the manual"  may do 
in mitigating the hazard. Some standards have specific requirements on 
these. Risk analysis shall include as many parties as the manufacturer 
can contact, such as engineers, production workers, customers, laymen 
and others that can get in contact with your product. Do not only 
consider the operating state, but also transport, repair work, storage, 
loss of coordination between manual, product and software version 
(button changed color), or even batch or serial numbering.  No risk 
shall be considered to be too small not to be included in the analysis. 
The difference is in how the risks are addressed. This will avoid having 
a too extensive safety warning section, and at the same time the 
requirements of any auditor.


Just my 2 cents.

Gert Gremmen

On 5-10-2022 20:01, Brian Kunde wrote:
My company manufactures Laboratory Equipment such as analyzers and 
determinators. They are highly specialized equipment, yet have an 
infinite range of uses.


Even though all known residual risks are documented in the Safety 
Warning section of the manual, they will commonly request a list of 
Misuses.  There are no buttons, or settings that can be changed by the 
User that can cause a hazard.  The operational environment is clearly 
defined. So in most all cases, I am not aware of any "Misuse" that can 
cause a hazard. For some reason, this answer is not acceptable.  We 
are expected to come up with something.


Is there a standard or common list of MisUses that seem to satisfy 
this requirement?


How crazy are we to get with this?, e.g., don't use the 400lb analyzer 
while taking a bath?  Don't use it to mow your lawn?  Common


I used to work for a computer company and I couldn't believe the 
stupid warnings we had to put in the manual.


Thanks to all.

The Other Brian
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Re: [PSES] EN 62368-1 Ed 3 2020 + A11 : 2020 for GPSD

[Gert Gremmen]

Hi Scott

The OJ itself lists the required dates in he table of publication.

Gert Gremmen

On 30-8-2022 15:41, Scott Xe wrote:
On 16 Aug, the captioned HS was listed in OJ.  Does it replace the 
previous version immediately or is there a transitional period?


Thanks and regards,

Scott
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Re: [PSES] Harmonised standards

[Gert Gremmen]

Hi Brain

Method #1 and #2 are equivalent (if the were the same standard):

#2 list 3 documents that -once merged- form one harmonised standard

#1 list the original standard plus  the applicable harmonised amendment


Method 3 is not recommended IMHO.

Gert gremmen

On 24-8-2022 21:48, Brian Kunde wrote:
This topic goes a little deeper, I think.  Question being, how are the 
harmonized standards to be listed on your DoC?


It appears to me that the Commission lists standards a couple 
different ways, which adds to the confusion. For example, on the EMCD 
Harmonized Standards list, it shows it one way as:


Method #1
EN 16361:2013+A1:2016

but then for another standard shows it this way:

Method #2
EN 50065-2-1:2003, EN 50065-2-1:2003/A1:2005, EN 50065-2-1:2003/AC:2003

Using the first method, the above could be listed as

Method #1
EN 50065-2-1:2003+AC:2033+A1:2005

I thought we had a discussion a year or so ago where the plus sign "+" 
was to be replaced by the slash "/".  If that is true, then the above 
could be listed as:


Method #3
EN 50065-2-1:2003/AC:2033/A1:2005

But this method could be technically confusing thinking you are using 
only the amendment to show compliance. Yet, we all know what 
this really means, right?.


So, which is correct?  Does it really matter?  Using method #2 above 
is probably the most correct, but it is very long.  I prefer method #1 
or #3 because it is shorter and gets the point across.


Comments?

The Other Brian






On Wed, Aug 24, 2022 at 11:59 AM Scott Xe  wrote:

Hi Gert,

Thanks for your useful reply!  The EN 55032 : 2017/A11 : 2020
contains the corrigendum only, no any technical changes.  Does AC
have another condition to qualify for?

Will arrange some time for visiting the CENELEC site.

Best regards,

Scott

On Wed, 24 Aug 2022 at 21:38, Gert Gremmen 
wrote:

Hi Scott,

No only the :

EN 55032 : 2017  is the Harmonised Standard (1 documnet)
EN 55032 : 2017/A11 : 2020  is the (Harmonised) amendment only
(1 dcoument)

Both documents are needed. (did not check the OJ for you)

EN 55032 : 2017+A11 : 2020  is both documents together.

AC stands for Corrigendum, most used for plain error, typos
,wrong
references etc.

There is lots of info on the site of CENELEC on these
subjects. Worth so
spent an afternoon.

Gert Gremmen

On 24-8-2022 15:06, Scott Xe wrote:
> EN 55032 : 2017/A11 : 2020
>
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Re: [PSES] Harmonised standards

[Gert Gremmen]

Hi Scott,

No only the :

EN 55032 : 2017  is the Harmonised Standard (1 documnet)
EN 55032 : 2017/A11 : 2020  is the (Harmonised) amendment only (1 dcoument)

Both documents are needed. (did not check the OJ for you)

EN 55032 : 2017+A11 : 2020  is both documents together.

AC stands for Corrigendum, most used for plain error, typos ,wrong 
references etc.


There is lots of info on the site of CENELEC on these subjects. Worth so 
spent an afternoon.


Gert Gremmen

On 24-8-2022 15:06, Scott Xe wrote:

EN 55032 : 2017/A11 : 2020


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Re: [PSES] CE marking of a high voltage output supply for laboratory / industrial environmental use

[Gert Gremmen]

Dear Bart,

As the input is within the LVD limit, the whole equipment is.

EN 61326-1 comes to mind for EMC

EN 61010-1 for electrical safety

The output is just a "circuit" (in terms of 61010) and clearance and 
creepage requirement (up to 60 kV) are given in Table 6 and 7


There are more requirements than just clearance and creepage.

Good luck in making your equipment safe.

Gert Gremmen


On 18-8-2022 21:43, bart.de.gee...@telenet.be wrote:


Dear experts,

A client is looking for regulatory guidance to CE certify a high 
voltage output supply  (with regular AC mains 230V/50Hz input).


The supply has an output voltage upto 25kV (upto 50kHz) output.   It 
concerns a supply to be used for plasma reactor applications.


As the output voltage is not inside the  voltage limits for the Low 
Voltage Directive, the LVD directive is not applicable?


The  Machine Directive also excludes these high voltage products.

So, wondering which Directive to apply related tot he safety testing 
part.  (The General Safety Product Directive?)


Any suggestions as to which safety standard to apply for such products?

Any suggestions are highly appreciated.

Thanks !

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Re: [PSES] RED DoC and ETSI EN 301 489-1

[Gert Gremmen]

Good Morning Charlie,

Indeed, there is a different regime in art 17 for conformance to article 
3.1 (a) (safety) and 3.1 (b) (emc) , and 3.2 (radio) and 3.3 (others)


I overlooked the word EMC. Noted.

To resume, Art 17 describes the conformance procedures:

3.1 a)  Annex I + reasonable foreseeable conditions

3.1 b) Annex I

3.2  Annex I  if HS  otherwise annex III or IV

3.3 Annex I if HS  otherwise annex III or IV

Note that as ageneral rule when NO HS are applied for 3.1 a) or b)  art 
16 denies the presumption of conformity principle, which obliges the 
manufacturer to obtain proof of conformity with an additional means.


In addition, Annex V requires additional : "descriptions of the 
solutions applied "  (under (d) ) for non HS parts.



 Gert

On 26-3-2022 21:43, Charlie Blackham wrote:


Gert


Indeed, but it implies that for the RED another compliance route need 
to be choosen (see annexes to the RED)


I’m not sure what you mean by this statement – the manufacturer can 
follow Annex II and self declare where HS have been applied for 
article 3.2 (and 3.3 if applicable) irrespective of whether HS have 
been applied for Article 3.1(a) and (b) – this is laid out in Article 17.


Best regards

Charlie**

**

*Charlie Blackham*

*Sulis Consultants Ltd*

*Tel: +44 (0)7946 624317*

*Web: **https://sulisconsultants.com/* <https://sulisconsultants.com/>**

Registered in England and Wales, number 05466247

*From:*Gert Gremmen 
*Sent:* 26 March 2022 10:02
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] RED DoC and ETSI EN 301 489-1

of the standards to which they were tested.>

The trend is to not harmonise the -1 version of this (and other series) in the 
future,
the -1 instead will be normatively referenced in any of the applied subparts, 
that WILL be harmonised (once approved).
By normatively referencing, the referenced clauses from the -1 will be part of the 
"text with legal effect" in the subpart.
conformity>

This implies that you will need a third party to prove your compliance status 
i.e. a Notified Body for 2014/53/EU (art 3.2)

Indeed, but it implies that for the RED another compliance route need 
to be choosen (see annexes to the RED)

The many subparts of EN 301 489 are on their way to harmonisation.
However the process of creating standards (= adapting to EU 
requirements) is slow, and many stakeholders are involved.
Since to-be-listed standards need up to 4 HAS-assessments each 
followed by a round of modifications at ETSI,

each taking 3-9 months, the delays can be huge.
(HAS is the EU-process where candidate HS are being scrutinized for 
their suitability to be listed. To a great part this comes down
on verifying if the presented requirements can stand up in a legal 
sense, are exhaustive and precise,

contain no duplicates to EU legislation, and are to the state of the art.
In some cases a normatively referenced standard can block 
harmonisation if the referenced standard has severe deficiencies.)

Gert Gremmen

On 26-3-2022 9:21, T.Sato wrote:

Although non-harmonised standards will not give presumption of conformity,

--
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EMC Consultant
Electrical Safety Consultant

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Re: [PSES] RED DoC and ETSI EN 301 489-1

[Gert Gremmen]

years. It's also possible that EU legislation has changed during that time.>


Indeed, there is an urgent need to speed up the process of standards 
creation/modification, as both have happened, though it is more a 
process of iteration to get to a final acceptable result.


That said, the consensus process in creating standards is difficult to 
upgrade, seen how this is currently organized.


An quite ambitious effort of the Commission ( 
https://ec.europa.eu/commission/presscorner/detail/en/ip_22_661) to 
limit the decision  process  for EU-standards to EU stakeholders  (only) 
may help.


(This has of course the added inconvenience of creating a potential 
divergence between International and European versions of standards, I 
personally believe however, that the majority of the world will follow 
the EU-versions, simply because it is too expensive to create multiple 
approved versions of equipment. )


but most "field" problems are not caused by state of the art problems, 
but occur due to insufficient knowledge of technical committees on legal 
concepts, by for example allowing 2 different but (thought) equivalent 
tests for one requirement. The uncertainty caused by having the 
manufacturer make an open choice between 2 test methods is legally not 
acceptable. If test are different, than it means that there can be 
different results under different test conditions. Otherwise a single 
test would be sufficient as specification. Creating sufficient guiding 
to support 2 tests can be quite challenging, if this needs to be precise 
and exhaustive. Gert Gremmen


On 26-3-2022 11:50, John Woodgate wrote:
The 'state of the art' is quite likely to have moved on in less than 3 
years. It's also possible that EU legislation has changed during that 
time.


--
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EMC Consultant
Electrical Safety Consultant

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Re: [PSES] RED DoC and ETSI EN 301 489-1

[Gert Gremmen]

the standards to which they were tested.>

The trend is to not harmonise the -1 version of this (and other series) in the 
future,
the -1 instead will be normatively referenced in any of the applied subparts, 
that WILL be harmonised (once approved).
By normatively referencing, the referenced clauses from the -1 will be part of the 
"text with legal effect" in the subpart.




This implies that you will need a third party to prove your compliance status 
i.e. a Notified Body for 2014/53/EU (art 3.2)



 
Indeed, but it implies that for the RED another compliance route need to 
be choosen (see annexes to the RED) The many subparts of EN 301 489 are 
on their way to harmonisation. However the process of creating standards 
(= adapting to EU requirements) is slow, and many stakeholders are 
involved. Since to-be-listed standards need up to 4 HAS-assessments each 
followed by a round of modifications at ETSI, each taking 3-9 months, 
the delays can be huge. (HAS is the EU-process where candidate HS are 
being scrutinized for their suitability to be listed. To a great part 
this comes down on verifying if the presented requirements can stand up 
in a legal sense, are exhaustive and precise, contain no duplicates to 
EU legislation, and are to the state of the art. In some cases a 
normatively referenced standard can block harmonisation if the 
referenced standard has severe deficiencies.) Gert Gremmen


On 26-3-2022 9:21, T.Sato wrote:

Although non-harmonised standards will not give presumption of conformity,


--
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Electrical Safety Consultant

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Re: [PSES] Stripline - discontinuity in adjacent ground planes

[Gert Gremmen]

Any signal flowing in the SIGNAL layer, will when getting to the load 
have to choose between 2 ground layers. (when ordinary vias are used)


The signal layer with the lowest impedance is that where a good mutual 
coupling between SIGNAL current and GNDX


is assured al along. So just verify the trace of SIGNAL in both GND's 
and you have your answer.


Note that the worst situation may occur when both planes are equal, 
because the ground current may


be cut in 2 parts and you lost easy control on what happens. Therefore 
use just 1 ground plane only.


(in this 3 layer situation). Note that 1% corresponds to 40 dB, so if 
99% flows where you want it to,


1% may choose the wrong route and create a possible EMI problem and 40 
dB less is not much.


Buried via may be he answer to your plane problem, but does increase the 
costs quite alot, where the


single ground layer solution saves money.

The situation changes in 6 or 8 layer PCBS. There you will couple to the 
closest


groundplane using buried vias only.

The generic answer is : control your return current, and avoid ambiguities.

Gert Gremmen

On 18-3-2020 9:38, Amund Westin wrote:


Let’s say, part of a pcb stack looks like this  --- GND1 – SIGNAL – GND2

GND1 is solid copper fill

SIGNAL layer consists of high frequency lines LVDS, USB3.0, etc.

GND2 should be solid copper fill, but some traces are in that layer 
due to space utilization reason. These traces are crossing 90 degrees 
the traces in SIGNAL layer.


These traces in the GND2 will create gaps and therefore problems for 
the return current for the high frequency lines I SINAL layer.


But does it matter, as long as the GND1 layer is 100% filled, and 
there is no disruption of the return current path for the traces in 
the adjacent SIGNAL layer?


Best regards

Amund Westin

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Re: [PSES] Keeping cellphone noise out of audio op-amps

[Gert Gremmen]

Basically any connection to an opamp can create unwanted susceptibility.

So a small cap to ground preceded by a suitable impedance for the 
frequencies to be suppressed


will do the job.

What pins ?

Those that have a substantial length (compared to wavelength) on PCB (or 
off PCB).


By placing impedance in series with each input/output/supply the effects 
will already greatly be reduced.


Do not rely on feedback mechanism for this so the 47 pF will do a great 
job until the max freq of the opamp is exceeded.


Gert Gremmen


On 19-2-2020 13:11, John Woodgate wrote:


I see two apparent ways of keeping cellphone noise out of audio op-amps:

- 10 pF between + and - inputs;

- 47 pF (or similar) from output to inverting input.

Which is usually more effective? I suspect that the first one is, but 
I see it less often.

--
Best wishes
John Woodgate OOO-Own Opinions Only
www.woodjohn.uk
Rayleigh, Essex UK
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Re: [PSES] SV: [PSES] PCB layout technique - multilayer

[Gert Gremmen]

It s an extra layer you might allocate to that low frequency signals , 
analog signals and or extra power supply.


On 10-2-2020 10:22, Amund Westin wrote:


Thanks Gert

I want to read your advices with great attention.

Just one immediately follow-up èThis Misc layer, is it an extra layer 
for signal routing, as a Sbott3?


Mvh Amund

*Fra:*Gert Gremmen
*Sendt:* 10. februar 2020 09:57
*Til:* Amund Westin ; EMC-PSTC@LISTSERV.IEEE.ORG
*Emne:* Re: [PSES] PCB layout technique - multilayer

Just 2 hints of thousands:

If you implement 2 ground planes make sure the ground references on 
top and bottom are related to the closest ground layer .


The stack will than be:  Stop -- GND --Stop2 -- PWR - Misc - Sbott2 - 
GND -Sbott ((S=signal))


(basically you route 2 x 3 layer boards critically, and bond them 
together with a power plane in between.)


The signal should not cross the board and be tempted to flow on an 
opposite ground layer, but


will remain always close to the corresponding ground layer.

Make sure both ground layers are extremely well coupled together, esp 
on board edges


If you implement SMPS locally give it a local top layer ground area to 
connect the principal


switch elements together. Connect by a dice pattern 5 via to main GND

Good luck.

Gert Gremmen

On 10-2-2020 8:27, Amund Westin wrote: contact to the nearest ground 
layer,


I’m looking for articles about how to do good EMC layout on
multilayer PCB.

Choice of PCB layer stacking (8 or 10 layers) and basic routing
techniques are the issues of most importance right now.

Appreciate if you have some experience about good or bad layer
stacking.

Thanks!

Best regards

Amund

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Re: [PSES] PCB layout technique - multilayer

[Gert Gremmen]

Just 2 hints of thousands:

If you implement 2 ground planes make sure the ground references on top 
and bottom are related to the closest ground layer .


The stack will than be:  Stop -- GND --Stop2 -- PWR - Misc - Sbott2 - 
GND -Sbott ((S=signal))


(basically you route 2 x 3 layer boards critically, and bond them 
together with a power plane in between.)


The signal should not cross the board and be tempted to flow on an 
opposite ground layer, but


will remain always close to the corresponding ground layer.

Make sure both ground layers are extremely well coupled together, esp on 
board edges


If you implement SMPS locally give it a local top layer ground area to 
connect the principal


switch elements together. Connect by a dice pattern 5 via to main GND

Good luck.

Gert Gremmen

On 10-2-2020 8:27, Amund Westin wrote: contact to the nearest ground layer,


I’m looking for articles about how to do good EMC layout on multilayer 
PCB.


Choice of PCB layer stacking (8 or 10 layers) and basic routing 
techniques are the issues of most importance right now.


Appreciate if you have some experience about good or bad layer stacking.

Thanks!

Best regards

Amund

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Re: [PSES] CE marking quality manufacturing requirements

[Gert Gremmen]

These are phrases with a high degree of conformal viability, but most 
companies using this Route A  (SME's) do not have the slightest idea how 
to start "a quality system that entails"


In practice this can be done by :

 * Have the product be approved according to one or more harmonised
   standards (seek advice on choice)
 * Document all (CE) required modifications after compliance is
   achieved , add them to the production files, and complete it with
   the test report to obtain a "technical construction file"
 * Create the EU Declaration of Conformity (acc. to the above
   harmonised standards)
 * Freeze the product manufacturing status
 * Implement a control scheme on _purchase_ and_production_ with a
   focus on earlier failures and _improvements_ and _invisible safety
   "measures"_
 o /_Purchase_ /as components may change without notice, possibly
   driven by costs, but also by performance increase (/BTW never
   rely on unspecified /undocumented component properties -even if
   it passed tests- as these may change without notice)/
 o _/Improvements/_ as detected during the approval process are by
   definition difficult to implement for a variety of reasons (!!)
 o _/Invisible safety measures/_ shall be explicitly checked upon
   (such as insulation rings and washers)
 o _Unnotable on fail safety measures _shall be explicitly checked
   upon (such as varistors, fuse values, double/paralled safety
   features)
 * Carry out a basic safety test for electrical safety on insulation
   acc to a suitable standard
 * Define an equivalent test method that is able to detect EMC failures
   (based on approval test results) (even a properly tuned SW/VHF 
   receiver can detect sudden changes in emissions)
 * Keep a test log per serialized equipment (preferred) , batch or
   other logical production unit
 * Mark the product for inspection and verified.

This will more or less cover the most failures in production.

Please add your 2 cents


Just my few cents

Gert

On 15-1-2020 11:37, Matthew Wilson | GBE wrote:


Look at 
https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:218:0082:0128:en:PDF 



This is, “DECISION No 768/2008/EC OF THE EUROPEAN PARLIAMENT AND OF 
THE COUNCIL of 9 July 2008 on a common framework for the marketing of 
products”


See Annex II Module A1 and Module A2 in that document.

The choice is down to the manufacturer how to achieve this requirement 
but yes I think this implies, “that the quality system entail that one 
must conduct an internal product safety audit (or the like) to 
reassure themselves that there has been no deviation to the product 
design/documentation that originally supported their CE marking 
testing/declaration.”


HTH

Matthew Wilson,

Technical Director,

GB Electronics (UK) Ltd.

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*From:*Regan Arndt 
*Sent:* 15 January 2020 00:23
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] CE marking quality manufacturing requirements

Greetings team members,

I seem to recall somewhere either in a directive or the blue guide 
where it states (or implies) that part of the CE marking requirements 
entails that the manufacture must have a product quality 
system/production control..and this is where I need 
clarification: Does it imply that the quality system entail that *_one 
must conduct an internal product safety audit (or the like) _*to 
reassure themselves that there has been no deviation to the product 
design/documentation that originally supported their CE marking 
testing/declaration.


_Note that I am not referring to the module conformity assessment 
protocol which involves a notified body, but just the simple 
self-declaration scheme. My search always seems to point me towards 
the notified body modules section, where they say that the 3rd party 
conducts factory audits, etc. but there is nothing that states this 
for the non-notified body involvement._


If there is no such production verification audit required, would it 
not be prudent to do this? ….just like the NRTL program? My experience 
indicates that most manufacturers do not conduct internal product 
audits relating to CE marking unless they forced to because they also 
have a certification mark on the product (i.e. NRTL program or other 
certification scheme via a Notified Body).


Thanks for 

Re: [PSES] Intentional radiator Class A or Class B

[Gert Gremmen]

To All,

In Europe:

No recent version has been cited yet, but for the EN 301 489-1:V1.9.2 
under the EMCD. For now this is the only version "available" for 
certification without Notified Body. I can confirm that this version is 
not suitable for the RED. No harmonised cited version is available for 
the RED up to now. If you use a NB, citation is not relevant anymore, 
and any standard version can be applied, including 1.9.2, 2.2.0, 2.2.1 
and the 2.2.2 (currently under vote and expected in December) but you 
will need to convince the NB of the suitability of that standard 
covering the ERs from the directive. Not sure if the sudden relaxation 
to Class A in V2.2.0 Clause 8.2 is accepted by the NB, given the latest 
harmonized version that did not contain that relaxation. Surprising is 
that this Class A thing got into the standards but did not make it to 
the change history in Annex D in any of the 3 versions above.



Gert Gremmen


On 17-9-2019 15:11, micha...@acbcert.com wrote:


Hi Charlie,

The last presentation from ETSI that I recall on the topic, stated 
that we should be looking at EN 301 489-1 V2.x.x and newer.   We 
should not be considering the old EN 301 489-1 V1.9.2 because that is 
simply not sufficient for the RED.


Thanks,

Michael.

*From:*Charlie Blackham 
*Sent:* 17 September 2019 13:12
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] Intentional radiator Class A or Class B

Gert

EN 301 489-1 V1.9.2 was published in 2011 and is quite old now

As you know, EN 301 489-1 V2.1.1 was published by ETSI in February 
2017 and the latest draft, V2.2.0 was issued by ETSI in March 2019 – 
both contain radiated immunity requirements to 6 GHz, which are more 
extensive than those in V1.9.2, and both contain the Class A option 
for emissions, though with slightly different wording


As far as I know, V1.9.2 won’t ever be cited under the RED  - though 
nor will V2.1.1 - and the communication from ETSI suggest that the 
issues in V2.2.0 mainly revolve around equipment performance 
monitoring and criteria and not the Class A/B option for appropriate 
end environments


Are you suggesting that V1.9.2 is a better standard to apply under the 
RED than either V2.1.1 or V2.2.0?


I also know that you’re involved in the process of standard being 
published in the OJ, so any further light you can shed on this matter 
would be greatly appreciated


Regards

Charlie

*Charlie Blackham*

*Sulis Consultants Ltd*

*Tel: +44 (0)7946 624317*

*Web: https://sulisconsultants.com/ *

Registered in England and Wales, number 05466247

*From:*Gert Gremmen mailto:g.grem...@cetest.nl>>
*Sent:* 17 September 2019 11:56
*To:* Charlie Blackham <mailto:char...@sulisconsultants.com>>; EMC-PSTC@LISTSERV.IEEE.ORG 
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>

*Subject:* Re: [PSES] Intentional radiator Class A or Class B

Hi Charlie

That version of the standard 301-489-1 V2.2.1 has not yet been 
approved, yet published, so be careful


For now keep relying on V1.9.2 , that does not mention your text  on 
industrial environment, and that has not yet been cited under the RED 
either.


Gert Gremmen

On 17-9-2019 10:59, Charlie Blackham wrote:

You can use Class A for industrial locations under EN 301 489-1:

8.2.3 Limits

The ancillary equipment shall meet the class B limits given in
CENELEC EN 55032 [1], annex A tables A.4 and A.5.

*Alternatively, for ancillary equipment intended to be used
exclusively in an industrial environment or telecommunication
centres, the class A limits given in CENELEC EN 55032 [1], annex A
tables A.2 and A.3 may be used.*

If the screen is “ancillary equipment”, another EMC standard can
be used as per section 5.4, though it is more likely to be
“combined and/or integrated radio and non-radio equipment” so the
advice in EN 303 446-x can be followed

Also, of course, a RED Notified Body (NB) is only required where
the applicable article 3.2 or 3.3 Harmonised Standard is not used

The manufacturer is free to choose the EMC and safety standard
without use of NB if they wish

*Charlie Blackham*

*Sulis Consultants Ltd*

*Tel: +44 (0)7946 624317*

*Web: https://sulisconsultants.com/ *

Registered in England and Wales, number 05466247

*From:*Gert Gremmen 
<mailto:g.grem...@cetest.nl>
*Sent:* 17 September 2019 09:01
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Subject:* Re: [PSES] Intentional radiator Class A or Class B

Note that for intentional transmitters the EMCD en LVD are not
applicable (but the RED is!). And so are the standards listed for
them.

Probably as this is a transceiver with ancillary equipment (though
heavily integrated?) the  combi EN 301489-17/EN 301 489-1 will be
applicable.

The latter limits the emission Class to Class B (for ancillary
electronics) only and refers to EN 55032 a

Re: [PSES] Intentional radiator Class A or Class B

[Gert Gremmen]

Hi Charlie

That version of the standard 301-489-1 V2.2.1 has not yet been approved, 
yet published, so be careful


For now keep relying on V1.9.2 , that does not mention your text on 
industrial environment, and that has not yet been cited under the RED 
either.


Gert Gremmen

On 17-9-2019 10:59, Charlie Blackham wrote:


You can use Class A for industrial locations under EN 301 489-1:

8.2.3 Limits

The ancillary equipment shall meet the class B limits given in CENELEC 
EN 55032 [1], annex A tables A.4 and A.5.


*Alternatively, for ancillary equipment intended to be used 
exclusively in an industrial environment or telecommunication centres, 
the class A limits given in CENELEC EN 55032 [1], annex A tables A.2 
and A.3 may be used.***


If the screen is “ancillary equipment”, another EMC standard can be 
used as per section 5.4, though it is more likely to be “combined 
and/or integrated radio and non-radio equipment” so the advice in EN 
303 446-x can be followed


Also, of course, a RED Notified Body (NB) is only required where the 
applicable article 3.2 or 3.3 Harmonised Standard is not used


The manufacturer is free to choose the EMC and safety standard without 
use of NB if they wish


*Charlie Blackham*

*Sulis Consultants Ltd*

*Tel: +44 (0)7946 624317*

*Web: https://sulisconsultants.com/ *

Registered in England and Wales, number 05466247

*From:*Gert Gremmen 
*Sent:* 17 September 2019 09:01
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] Intentional radiator Class A or Class B

Note that for intentional transmitters the EMCD en LVD are not 
applicable (but the RED is!). And so are the standards listed for them.


Probably as this is a transceiver with ancillary equipment (though 
heavily integrated?) the  combi EN 301489-17/EN 301 489-1 will be 
applicable.


The latter limits the emission Class to Class B (for ancillary 
electronics) only and refers to EN 55032 as test method.


Note that RED standards are prone to changes in the close future, make 
sure you have the last version and re-check if another version may be 
listed


(cited) in the OJ-L. Use a Notified Body otherwise.

Gert Gremmen

On 17-9-2019 8:48, John Woodgate wrote:

Not exactly. The question was strictly about 'Class', which of
course can mean different things in different standards, but my
answer is, I think, correct for Europe. Intentional radiation is
excluded from the CISPR standards and is covered by the ETSI
standards cited by Charlie Blackham.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associateswww.woodjohn.uk  <http://www.woodjohn.uk>

Rayleigh, Essex UK

On 2019-09-16 23:55, peterh...@aol.com <mailto:peterh...@aol.com>
wrote:

John,

Are you saying that a product with intentional radiator only
needs to meet Class A for emissions in EU? i.e there is no
difference in terms of the limit between intentional and
unintentional radiators when it comes to EU. Is that a correct
statement?

Thanks

Peter

-Original Message-
From: John Woodgate  <mailto:j...@woodjohn.uk>
To: peterhays  <mailto:peterh...@aol.com>;
EMC-PSTC 
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Sent: Mon, Sep 16, 2019 11:34 am
Subject: Re: [PSES] Intentional radiator Class A or Class B

That should be CISPR 35, not CISPR 24 now. In Europe, it would
be Class A. The manual should say 'This product is not to be
used in a residential environment.'.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associateswww.woodjohn.uk  <http://www.woodjohn.uk>

Rayleigh, Essex UK

On 2019-09-16 17:56, peterh...@aol.com
<mailto:peterh...@aol.com> wrote:

The product is an ITE and follows CISPR 32 and CISPR 24

It will be sold globally

The product is a small touch panel.

-Original Message-
From: John Woodgate  <mailto:j...@woodjohn.uk>
To: peterhays  <mailto:peterh...@aol.com>;
EMC-PSTC 
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Sent: Mon, Sep 16, 2019 12:37 am
Subject: Re: [PSES] Intentional radiator Class A or Class B

To give a reliable answer, we need to know the type of product
or the EMC emission standard that applies (e.g. CISPR 14-1/EN
55014-1) and which countries/regions it will be sold in.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associateswww.woodjohn.uk  <http://www.woodjohn.uk>

Rayleigh, Essex UK

On 2019-09-16 03:51, 06cee064502d-dmarc-requ...@ieee.org
<mailto:06cee064502d-dmarc-requ...@ieee.org> wrote:

Dear Colleagues,

I have a client that design and manufacture products for u

Re: [PSES] Intentional radiator Class A or Class B

[Gert Gremmen]

Note that for intentional transmitters the EMCD en LVD are not 
applicable (but the RED is!). And so are the standards listed for them.


Probably as this is a transceiver with ancillary equipment (though 
heavily integrated?) the  combi EN 301489-17/EN 301 489-1 will be 
applicable.


The latter limits the emission Class to Class B (for ancillary 
electronics) only and refers to EN 55032 as test method.


Note that RED standards are prone to changes in the close future, make 
sure you have the last version and re-check if another version may be listed


(cited) in the OJ-L. Use a Notified Body otherwise.

Gert Gremmen

On 17-9-2019 8:48, John Woodgate wrote:


Not exactly. The question was strictly about 'Class', which of course 
can mean different things in different standards, but my answer is, I 
think, correct for Europe. Intentional radiation is excluded from the 
CISPR standards and is covered by the ETSI standards cited by Charlie 
Blackham.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-09-16 23:55, peterh...@aol.com wrote:

John,

Are you saying that a product with intentional radiator only needs to 
meet Class A for emissions in EU? i.e there is no difference in terms 
of the limit between intentional and unintentional radiators when it 
comes to EU. Is that a correct statement?


Thanks
Peter


-Original Message-
From: John Woodgate 
To: peterhays ; EMC-PSTC 
Sent: Mon, Sep 16, 2019 11:34 am
Subject: Re: [PSES] Intentional radiator Class A or Class B

That should be CISPR 35, not CISPR 24 now. In Europe, it would be 
Class A. The manual should say 'This product is not to be used in a 
residential environment.'.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk  <http://www.woodjohn.uk>
Rayleigh, Essex UK
On 2019-09-16 17:56, peterh...@aol.com <mailto:peterh...@aol.com> wrote:
The product is an ITE and follows CISPR 32 and CISPR 24

It will be sold globally

The product is a small touch panel.

-Original Message-
From: John Woodgate  <mailto:j...@woodjohn.uk>
To: peterhays  <mailto:peterh...@aol.com>; 
EMC-PSTC  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>

Sent: Mon, Sep 16, 2019 12:37 am
Subject: Re: [PSES] Intentional radiator Class A or Class B

To give a reliable answer, we need to know the type of product or the 
EMC emission standard that applies (e.g. CISPR 14-1/EN 55014-1) and 
which countries/regions it will be sold in.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk  <http://www.woodjohn.uk>
Rayleigh, Essex UK
On 2019-09-16 03:51, 06cee064502d-dmarc-requ...@ieee.org 
<mailto:06cee064502d-dmarc-requ...@ieee.org> wrote:


Dear Colleagues,

I have a client that design and manufacture products for use in 
non-residential environment. This product consists of a BT module. I 
am told that the product must meet Class B emissions. Is this 
correct? What if we put an statement in the user manual stating that 
this product is not to be used in residential market? Would that give 
us the pass to go to Class A?

Thank you all
Peter
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emc-pstc discussion list. To post a message to the list, send your 
e-mail to mailto:emc-p...@ieee.org>>


All emc-pstc postings are archived and searchable on the web at: 
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Attachments are not permitted but the IEEE PSES Online Communities 
site at http://product-compliance.oc.ieee.org/ can be used for 
graphics (in well-used formats), large files, etc.


Website: http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including how to 
unsubscribe)

List rules: http://www.ieee-pses.org/listrules.html

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Mike 

Re: [PSES] Relaxation of test requirements

[Gert Gremmen]

Hi Charlie,

I have no more inside information as you, i actually am an external 
consultant, working from home.


In the eighties i was involved some time in a automated translation 
project, where each language was translated into Esperanto , before 
being translated into the target language. The project never lead to a 
successful result (IT-related?), but the approach looks valuable, and 
economic.


But let me think loud:

The direct translation from each of the 24 languages into the other 23 
languages requires (if my math-skills are still up to date) 23x22  =   
506 different unidirectional translators. As one translator per language 
combination is certainly not enough , the total number of needed 
translators will be  much much higher , so i expect the translations are 
madeoftenusing one of 3-4-5  intermediate languages.


Nevertheless, i have found fragments and citations (interviews, news) 
suggesting that the primary goal is to translate 1:1 and the application 
of an intermediate language is second choice. This was notably said in 
an interview with real time translators working at the EU-parliament.


This will be specially true for the more common languages and less true 
for the less spoken languages in the EU.


But you can of course just ask them .

https://cdt.europa.eu/en/translation-department

Gert



On 24-8-2019 14:38, Charlie Blackham wrote:


Gert

You may be able to shed some light on another possible issue related 
to this – which is how translations are done within the EU:


I’ve heard that the 3 main languages are English, French and German, 
so if something is originally written in, say, Italian, it gets 
translated into one of the 3 main languages before it is translated 
into Spanish or Swedish for example.


Is that correct do you know?

Regards

Charlie

*Charlie Blackham*

*Sulis Consultants Ltd*

*Tel: +44 (0)7946 624317*

*Web: https://sulisconsultants.com/ *

Registered in England and Wales, number 05466247

*From:*Gert Gremmen 
*Sent:* 24 August 2019 13:27
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] Relaxation of test requirements

That is why i am so interested in the Euro-English topic.

Many/Some of these issues start by simple misunderstanding of the 
common language (English) used by people like me that are not natively 
speaking/writing/reading English. The lack of capabilities we all 
suffer of  (but for you lucky UK guys) leads inevitably to ambiguous 
constructions.


A German author writes a concept, together with a French engineer, 
that is corrected by a Polish Guy and read by an Italian. Finally the 
manufacturer is French, using a Spanish Test lab ?


So i am still interested in typically Euro-English statements you 
found in standards  from you all, especially if they seem to stem from 
typical language origins, and/or can lead to misunderstandings or 
ambiguous conclusions.


On 24-8-2019 13:54, John Woodgate wrote:

Hello, Gert. I agree; it's all too easy for issues that have in
fact been settled to grow into myths.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associateswww.woodjohn.uk  <http://www.woodjohn.uk>

Rayleigh, Essex UK

On 2019-08-24 12:32, Gert Gremmen wrote:

John

Nice to agree then. :-)

The new assessment system has needed fine tuning during quite
a period, and some misunderstandings might have grown to the
size of hoaxes.

Gert

On 24-8-2019 13:06, John Woodgate wrote:

We disagree much less that you might think. I'll just pick
up two points:

/here are even hints that some legal people believe that
every product of a given type, e.g electric fan, should
have the same performance! /

The hints aren't restricted to things that indeed are
common, like safety provisions, but extend to the whole
product specification.//That may be a misinterpretation,
but it's how it's seen by people who don't have your insight.

"I can assure you that manufacturers will be able to
define the properties of their equipment."

That is not how the rewrite of the EMC immunity criteria
is being constrained. It seems to have been ruled that
'manufacturer' cannot be mentioned at all.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associateswww.woodjohn.uk  <http://www.woodjohn.uk>

Rayleigh, Essex UK

    On 2019-08-24 11:51, Gert Gremmen wrote:

These very high standards (as you call it) are just
part of the requirements as given in ER3, for example,
and are being part of the current way the EU assesses
standards in the current situation, where standards
text have become part of law -so-to-say- .

Re: [PSES] Relaxation of test requirements

[Gert Gremmen]

That is why i am so interested in the Euro-English topic.

Many/Some of these issues start by simple misunderstanding of the common 
language (English) used by people like me that are not natively 
speaking/writing/reading English. The lack of capabilities we all suffer 
of  (but for you lucky UK guys) leads inevitably to ambiguous constructions.


A German author writes a concept, together with a French engineer, that 
is corrected by a Polish Guy and read by an Italian. Finally the 
manufacturer is French, using a Spanish Test lab ?


So i am still interested in typically Euro-English statements you found 
in standards  from you all, especially if they seem to stem from typical 
language origins, and/or can lead to misunderstandings or ambiguous 
conclusions.




On 24-8-2019 13:54, John Woodgate wrote:


Hello, Gert. I agree; it's all too easy for issues that have in fact 
been settled to grow into myths.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-08-24 12:32, Gert Gremmen wrote:


John

Nice to agree then. :-)

The new assessment system has needed fine tuning during quite a 
period, and some misunderstandings might have grown to the size of 
hoaxes.



Gert

On 24-8-2019 13:06, John Woodgate wrote:


We disagree much less that you might think. I'll just pick up two 
points:


/here are even hints that some legal people believe that every 
product of a given type, e.g electric fan, should have the same 
performance!

/

The hints aren't restricted to things that indeed are common, like 
safety provisions, but extend to the whole product 
specification.//That may be a misinterpretation, but it's how it's 
seen by people who don't have your insight./

/

"I can assure you that manufacturers will be able to define the 
properties of their equipment."


That is not how the rewrite of the EMC immunity criteria is being 
constrained. It seems to have been ruled that 'manufacturer' cannot 
be mentioned at all.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-08-24 11:51, Gert Gremmen wrote:


These very high standards (as you call it) are just part of the 
requirements as given in ER3, for example, and are being part of 
the current way the EU assesses standards in the current situation, 
where standards text have become part of law -so-to-say- .


> /I can't understand why the court ruling about ENs being 
'sort-of' laws hasn't been challenged./


This decision cannot be challenged anymore as it is confirmed by 
the highest EU legal authorities. It makes no sense to complain 
about a status quo.


>/Because the committee decided it was necessary./

I won't challenge the committee technical expertise, but it makes 
no sense writing about things that are not covered by title, scope 
and foreword of the standard. The standard is to describe the 
(minimum) technical requirements of the equipment in the field of 
EMC. The TC should stay on their chair, defining requirements, and 
not mix the interests of the standard with those of the manufacturer.


>/I can't understand why the court ruling about ENs being 'sort-of' 
laws hasn't been challenged.  As a result of it, the correct 
decision that some ETSI standards that left crucial provisions to 
be agreed between the manufacturer and the test house cannot be 
permitted has been vastly over-interpreted to mean effectively that 
even the word 'manufacturer' cannot be mentioned. For example, it 
is not being allowed to say that the manufacturer provides the 
performance specification of the product. There are even hints that 
some legal people believe that every product of a given type, e.g 
electric fan, should have the same performance! Do we expect all 
cars to have the same performance as a Bugatti supercar?/


This is an oversimplification of what happens in reality/. /I am 
one of the three assessors for ETSI standards and i can assure you 
that this does not happen. As it comes to performance/, /only 
aspects that _are common to all cars _(to keep your analogy) need 
to comply with a kind of common property. A analogy could be the 
performance of tyres or brakes, that need to be suitable for the 
car under test. So if you say the same "relative performance" your 
analogy makes sense and, indeed, that is what happens. All radio 
devices use a common medium (ether) and the standards have to make 
sure every apparatus uses not more spectrum space and power than 
required for its defined purpose.


>/left crucial provisions to be agreed between the manufacturer and 
the test house cannot be permitted/


Of course the manufacturer should not be able to negotiate crucial 
(test) aspects with a test-house. The interest of the manufacturer, 
is a completely different one that that of the EU maintaining 
standards and the test house, where accredited, needs to remain 
independent. N

Re: [PSES] Relaxation of test requirements

[Gert Gremmen]

John

Nice to agree then. :-)

The new assessment system has needed fine tuning during quite a period, 
and some misunderstandings might have grown to the size of hoaxes.



Gert

On 24-8-2019 13:06, John Woodgate wrote:


We disagree much less that you might think. I'll just pick up two points:

/here are even hints that some legal people believe that every product 
of a given type, e.g electric fan, should have the same performance!

/

The hints aren't restricted to things that indeed are common, like 
safety provisions, but extend to the whole product 
specification.//That may be a misinterpretation, but it's how it's 
seen by people who don't have your insight./

/

"I can assure you that manufacturers will be able to define the 
properties of their equipment."


That is not how the rewrite of the EMC immunity criteria is being 
constrained. It seems to have been ruled that 'manufacturer' cannot be 
mentioned at all.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-08-24 11:51, Gert Gremmen wrote:


These very high standards (as you call it) are just part of the 
requirements as given in ER3, for example, and are being part of the 
current way the EU assesses standards in the current situation, where 
standards text have become part of law -so-to-say- .


> /I can't understand why the court ruling about ENs being 'sort-of' 
laws hasn't been challenged./


This decision cannot be challenged anymore as it is confirmed by the 
highest EU legal authorities. It makes no sense to complain about a 
status quo.


>/Because the committee decided it was necessary./

I won't challenge the committee technical expertise, but it makes no 
sense writing about things that are not covered by title, scope and 
foreword of the standard. The standard is to describe the (minimum) 
technical requirements of the equipment in the field of EMC. The TC 
should stay on their chair, defining requirements, and not mix the 
interests of the standard with those of the  manufacturer.


>/I can't understand why the court ruling about ENs being 'sort-of' 
laws hasn't been challenged.  As a result of it, the correct decision 
that some ETSI standards that left crucial provisions to be agreed 
between the manufacturer and the test house cannot be permitted has 
been vastly over-interpreted to mean effectively that even the word 
'manufacturer' cannot be mentioned. For example, it is not being 
allowed to say that the manufacturer provides the performance 
specification of the product. There are even hints that some legal 
people believe that every product of a given type, e.g electric fan, 
should have the same performance! Do we expect all cars to have the 
same performance as a Bugatti supercar?/


This is an oversimplification of what happens in reality/. /I am one 
of the three assessors for ETSI standards and i can assure you that 
this does not happen. As it comes to performance/, /only aspects that 
_are common to all cars _(to keep your analogy) need to comply with a 
kind of common property. A analogy could be the performance of tyres 
or brakes, that need to be suitable for the car under test. So if you 
say the same "relative performance" your analogy makes sense and, 
indeed, that is what happens. All radio devices use a common medium 
(ether) and the standards have to make sure every apparatus uses not 
more spectrum space and power than required for its defined purpose.


>/left crucial provisions to be agreed between the manufacturer and 
the test house cannot be permitted/


Of course the manufacturer should not be able to negotiate crucial 
(test) aspects with a test-house. The interest of the manufacturer, 
is a completely different one that that of the EU maintaining 
standards and the test house, where accredited, needs to remain 
independent. Negotiation with its client would jeopardize its 
accreditation anyway. I can assure you that manufacturers will be 
able to define the properties of their equipment. Its true that the 
word "manufacturer" has been subject of challenges in many cases 
where there could be some misuse by (Euro-English) statements that 
allowed impacting the effectiveness of the standards tests.


An example i found is where the standard defines the requirements for 
mobile (automotive) radio and there was no minimum requirement for 
the temperature range in which the frequency stability was to be 
maintained. (environmental profile to be negotiated between 
manufacturer and test agency). The standard thus allowed the test to 
be carried out from 30-35 oC (as example). Within the EU market that 
is not a realistic minimum requirement as the equipment was for 
outdoor use, so it was suggested to add a minimum range more 
representative to EU climates.


John, thanks for your opinion anyway (but feel free to continue the 
discussions)


Gert Gremmen

On 24-8-2019 10:53, John Woodgat

Re: [PSES] Relaxation of test requirements

[Gert Gremmen]

These very high standards (as you call it) are just part of the 
requirements as given in ER3, for example, and are being part of the 
current way the EU assesses standards in the current situation, where 
standards text have become part of law -so-to-say- .


> /I can't understand why the court ruling about ENs being 'sort-of' 
laws hasn't been challenged./


This decision cannot be challenged anymore as it is confirmed by the 
highest EU legal authorities. It makes no sense to complain about a 
status quo.


>/Because the committee decided it was necessary./

I won't challenge the committee technical expertise, but it makes no 
sense writing about things that are not covered by title, scope and 
foreword of the standard. The standard is to describe the (minimum) 
technical requirements of the equipment in the field of EMC. The TC 
should stay on their chair, defining requirements, and not mix the 
interests of the standard with those of the manufacturer.


>/I can't understand why the court ruling about ENs being 'sort-of' 
laws hasn't been challenged.  As a result of it, the correct decision 
that some ETSI standards that left crucial provisions to be agreed 
between the manufacturer and the test house cannot be permitted has been 
vastly over-interpreted to mean effectively that even the word 
'manufacturer' cannot be mentioned. For example, it is not being allowed 
to say that the manufacturer provides the performance specification of 
the product. There are even hints that some legal people believe that 
every product of a given type, e.g electric fan, should have the same 
performance! Do we expect all cars to have the same performance as a 
Bugatti supercar?/


This is an oversimplification of what happens in reality/. /I am one of 
the three assessors for ETSI standards and i can assure you that this 
does not happen. As it comes to performance/, /only aspects that _are 
common to all cars _(to keep your analogy) need to comply with a kind of 
common property. A analogy could be the performance of tyres or brakes, 
that need to be suitable for the car under test. So if you say the same 
"relative performance" your analogy makes sense and, indeed, that is 
what happens. All radio devices use a common medium (ether) and the 
standards have to make sure every apparatus uses not more spectrum space 
and power than required for its defined purpose.


>/left crucial provisions to be agreed between the manufacturer and the 
test house cannot be permitted/


Of course the manufacturer should not be able to negotiate crucial 
(test) aspects with a test-house. The interest of the manufacturer, is a 
completely different one that that of the EU maintaining standards and 
the test house, where accredited, needs to remain independent. 
Negotiation with its client would jeopardize its accreditation anyway. I 
can assure you that manufacturers will be able to define the properties 
of their equipment. Its true that the word "manufacturer" has been 
subject of challenges in many cases where there could be some misuse by 
(Euro-English) statements that allowed impacting the effectiveness of 
the standards tests.


An example i found is where the standard defines the requirements for 
mobile (automotive) radio and there was no minimum requirement for the 
temperature range in which the frequency stability was to be maintained. 
(environmental profile to be negotiated between manufacturer and test 
agency). The standard thus allowed the test to be carried out from 30-35 
oC (as example). Within the EU market that is not a realistic minimum 
requirement as the equipment was for outdoor use, so it was suggested to 
add a minimum range more representative to EU climates.


John, thanks for your opinion anyway (but feel free to continue the 
discussions)


Gert Gremmen

On 24-8-2019 10:53, John Woodgate wrote:


I think this is another example of the high standard you set. Please 
see my responses below.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-08-24 09:29, Gert Gremmen wrote:


The discussion on languages and grammar has been very useful.


I would like your opinion and answers on the following standards 
clause, as found in a concept cited harmonised EMC product family 
standard:


/If hardware or software are modified subsequent to the completion of 
the tests described in this standard//
//an impact analysis shall be carried out and it shall be decided 
whether the EMC test shall be repeated as //
//a whole, in parts or not at all. Impact analysis and decision shall 
be added to the EMC test plan for theapparatus./



I have some questions on this clause:

 1. What is this clause doing in a standard describing technical
requirements for an apparatus?


/JMW: Because the committee decided it was necessary. /


 1. Shouldn't this be part of a basic standard describing the test
method?

[PSES] Relaxation of test requirements

[Gert Gremmen]

The discussion on languages and grammar has been very useful.


I would like your opinion and answers on the following standards clause, 
as found in a concept cited harmonised EMC product family standard:


/If hardware or software are modified subsequent to the completion of 
the tests described in this standard//
//an impact analysis shall be carried out and it shall be decided 
whether the EMC test shall be repeated as //
//a whole, in parts or not at all. Impact analysis and decision shall be 
added to the EMC test plan for theapparatus./



I have some questions on this clause:

1. What is this clause doing in a standard describing technical
   requirements for an apparatus?
2. Shouldn't this be part of a basic standard describing the test method?
3. Who should carry out the impact analysis (not the manufacturer of
   course) and decide on what retesting to do?
4. Why this should be made part of the test plan and not in the test
   report?

The principle of EMC- testing equipment, is that a full test is required 
upon any modification, as a modification makes it a a different 
equipment, but i also understand that a strict interpretation of this 
might lead to excessive test costs, and some test reductions are 
possible based on EMC expertise , experience in testing and knowledge of 
the equipment. I also consider that the EMC-directive is requiring as 
assessment and not testing (though testing seems an essential part of 
assessing and test reports are mentioned explicitly in the EMCD annexes.


But there is much more to say about an impact analysis than a simple 
clause .


How would you treat the problem of infinite testing, -to-be-sure-, 
versus realistic testing, and how would you implement such a "impact 
analysis" in the different standards, in the light of creating HS with 
legal effects.



Gert Gremmen




--
Independent Expert on CE marking
Harmonised Standards (HAS-) Consultant @ European Commission for RED and EMC
EMC Consultant
Electrical Safety Consultant


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Re: [PSES] Oxford comma

[Gert Gremmen]

Thank you Rich,

Congrats with your IEEE medal, i am sure you merited it !

Thanks for the comma document.

Gert Gremmen



On 23-8-2019 20:34, Richard Nute wrote:


The case of the missing Oxford comma.

https://annhandley.com/oxford-comma/

The comma wasn’t missing; it was deliberately omitted (not necessary 
according to AP Style and the managers of TC108).


Authors (writers) of IEC 62368 use the AP Style.  Many examples of “We 
invited the strippers, JFK and Stalin.”


Best regards,

Rich

*From:*Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org>
*Sent:* Friday, August 23, 2019 7:57 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] User Documents & EU Official Languages, Friday 
Question


I’ll note that even the incorrect use of punctuation can cause 
confusion in standards and regulations. Recently, a missing comma 
resulted in a $5 million legal settlement.


https://www.npr.org/sections/thetwo-way/2018/02/08/584391391/maine-dairy-drivers-settle-overtime-case-that-hinged-on-an-absent-comma

Ted Eckert

Microsoft Corporation

The opinions experessed are my own and do not necessarily reflect 
those of my employer.


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--
Independent Expert on CE marking
Harmonised Standards (HAS-) Consultant @ European Commission for RED and EMC
EMC Consultant
Electrical Safety Consultant


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Re: [PSES] User Documents & EU Official Languages, Friday Question

[Gert Gremmen]

 > I think it would be very difficult to get ambiguous language 
accepted by National Committees, the Chairman and Secretary of the 
committee and the Central Office editors.


On that topic we do differ in opinion.

I have yet to see a standard which is fully clear, complete and 
exhaustive and precise in its technical specifications.


A simple example from the scope of a recent concept standard:

/This document applies to apparatus intended for use in residential, 
commercial and light-industrial//
//environments as well as to apparatus intended for use in industrial 
environments, and includes AC-, DC-//

//or battery powered apparatus. /

What type of apparatus is included ?

Is the "or" in front of battery correctly used, should it not be "and", 
or is this an example of Euro-English (contextual comprehensible ?), and 
what would lawyers make of this.


--

On 23-8-2019 14:10, John Woodgate wrote:


Yes, of course I know about ISO/IEC Directives Part 2 and CEN/CENELEC 
IRs Part 3, but in 2005 when I wrote the document these rules were not 
widely known (and they still aren't known widely enough). What 'makes 
a difference in a legal sense' is a very big subject indeed. How 
'creative' is your lawyer? Is that 'black' or 'very dark white'?


I think it would be very difficult to get ambiguous language accepted 
by National Committees, the Chairman and Secretary of the committee 
and the Central Office editors.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-08-23 12:25, Gert Gremmen wrote:


Hi John,

Great many thank's ;<)

I will study them and use them for the benefit of standardization.

You must be aware of Internal Regulations 3 (CENELEC) that included 
some of your "must", "shall" and similar constructions to use and not 
use.


Thank you for noticing my own euro-english (must be inspired by your 
example); what i would like to know is if such "errors" create any 
difference in a legal sense.


Many of the to-be-cited-in-the-official-journal harmoni(z)(s)ed 
standards fail because of (intentional?) ambiguous language, plainly 
confusing constructions and sometimes even the -opposite of what is 
meant- is said, though the meaning is clear when read in context 
(contextual comprehensible ?) Legally some (euro english) 
constructions create problems.


So if anymore has more examples, let them come to this list !

Thanks, list members.

Gert


On 23-8-2019 11:26, John Woodgate wrote:


Hello, Gert. In my opinion, there is no 'factually wrong' for 
British English. We don't have an 'Academy' as in France.  The only 
thing you can say about 'I were going to work' is that 'were' is 
'contrary to usage', which is 'was'. Of course, some wordings may be 
more 'contrary to usage' than others.


You own message has an example of Euro-English - 'within the next 
years'. I would say 'within the next few years'. There is no 
sensible grammatical reason for including 'few', it's just 'what 
people say'.


I actually wrote a document on this subject many years ago, although 
it was not widely circulated. I have attached it.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-08-23 09:16, Gert Gremmen wrote:


Hi John (et al),

I noticed with quite interest your statement on the Euro-English; 
do you think that is where it shall go within the next years, 
eventually ?


I'd appreciate if you would provide us with other (many please) 
examples of -factually wrong- but common phrases as found in EU 
language, be it legal text or standards text.


As a not-native speaker these alterations of the "offcial British 
Enlish" go noticed for me (but for some), and i think it is 
important  to have a list of these available. In my current job at 
the EU i encounter all kind of non-native speaker created English 
language constructions, not always fully in error, and if one wants 
can understood as meant, but do create confusions in some cases.


So please, all UK and of course all US native speakers, use your 
Friday spare time and let us all know what you have found, if 
possible with some explanation, if not evident.


I will create a list and re-publish for the use of all.

Thanks

Gert Gremmen



On 23-8-2019 9:40, John Woodgate wrote:


Two points:

  *  EN standards are not 'European Norms', which were/are a very
old set of standards to do with the Coal and Steel Community,
a forerunner of the EU. ENs are 'European Standards'.

  * Nominally, 'British English' is used, but since no-one knows
exactly what that is, few people bother. There is also
'Euro-English', which has a few word-forms that are not used
by British English native speakers (e.g. 'within the next
days', different meanings of 'respectively' and 'eventually').

Best wishes
John Woodgate OOO-Own Opinions 

Re: [PSES] User Documents & EU Official Languages, Friday Question

[Gert Gremmen]

Hi John,

Great many thank's ;<)

I will study them and use them for the benefit of standardization.

You must be aware of Internal Regulations 3 (CENELEC) that included some 
of your "must", "shall" and similar constructions to use and not use.


Thank you for noticing my own euro-english (must be inspired by your 
example); what i would like to know is if such "errors" create any 
difference in a legal sense.


Many of the to-be-cited-in-the-official-journal harmoni(z)(s)ed 
standards fail because of (intentional?) ambiguous language, plainly 
confusing constructions and sometimes even the -opposite of what is 
meant- is said, though the meaning is clear when read in context 
(contextual comprehensible ?) Legally some (euro english) constructions 
create problems.


So if anymore has more examples, let them come to this list !

Thanks, list members.

Gert


On 23-8-2019 11:26, John Woodgate wrote:


Hello, Gert. In my opinion, there is no 'factually wrong' for British 
English. We don't have an 'Academy' as in France.  The only thing you 
can say about 'I were going to work' is that 'were' is 'contrary to 
usage', which is 'was'. Of course, some wordings may be more 'contrary 
to usage' than others.


You own message has an example of Euro-English - 'within the next 
years'. I would say 'within the next few years'. There is no sensible 
grammatical reason for including 'few', it's just 'what people say'.


I actually wrote a document on this subject many years ago, although 
it was not widely circulated. I have attached it.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-08-23 09:16, Gert Gremmen wrote:


Hi John (et al),

I noticed with quite interest your statement on the Euro-English; do 
you think that is where it shall go within the next years, eventually ?


I'd appreciate if you would provide us with other (many please) 
examples of -factually wrong- but common phrases as found in EU 
language, be it legal text or standards text.


As a not-native speaker these alterations of the "offcial British 
Enlish" go noticed for me (but for some), and i think it is 
important  to have a list of these available. In my current job at 
the EU i encounter all kind of non-native speaker created English 
language constructions, not always fully in error, and if one wants 
can understood as meant, but do create confusions in some cases.


So please, all UK and of course all US native speakers, use your 
Friday spare time and let us all know what you have found, if 
possible with some explanation, if not evident.


I will create a list and re-publish for the use of all.

Thanks

Gert Gremmen



On 23-8-2019 9:40, John Woodgate wrote:


Two points:

  *  EN standards are not 'European Norms', which were/are a very
old set of standards to do with the Coal and Steel Community, a
forerunner of the EU. ENs are 'European Standards'.

  * Nominally, 'British English' is used, but since no-one knows
exactly what that is, few people bother. There is also
'Euro-English', which has a few word-forms that are not used by
British English native speakers (e.g.  'within the next days',
different meanings of 'respectively' and 'eventually').

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK



--
Independent Expert on CE marking
Harmonised Standards (HAS-) Consultant @ European Commission for RED and EMC
EMC Consultant
Electrical Safety Consultant


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Re: [PSES] User Documents & EU Official Languages, Friday Question

[Gert Gremmen]

Hi John (et al),

I noticed with quite interest your statement on the Euro-English; do you 
think that is where it shall go within the next years, eventually ?


I'd appreciate if you would provide us with other (many please) examples 
of -factually wrong- but common phrases as found in EU language, be it 
legal text or standards text.


As a not-native speaker these alterations of the "offcial British 
Enlish" go noticed for me (but for some), and i think it is important  
to have a list of these available. In my current job at the EU i 
encounter all kind of non-native speaker created English language 
constructions, not always fully in error, and if one wants can 
understood as meant, but do create confusions in some cases.


So please, all UK and of course all US native speakers, use your Friday 
spare time and let us all know what you have found, if possible with 
some explanation, if not evident.


I will create a list and re-publish for the use of all.

Thanks

Gert Gremmen



On 23-8-2019 9:40, John Woodgate wrote:


Two points:

  *  EN standards are not 'European Norms', which were/are a very old
set of standards to do with the Coal and Steel Community, a
forerunner of the EU. ENs are 'European Standards'.

  * Nominally, 'British English' is used, but since no-one knows
exactly what that is, few people bother. There is also
'Euro-English', which has a few word-forms that are not used by
British English native speakers (e.g.  'within the next days',
different meanings of 'respectively' and 'eventually').

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-08-23 08:01, Doug Powell wrote:

All,

I haven't written a Friday Question in some time, so here is a new 
installment.


With the exit of Britain for the European Union (Brexit), I find it 
interesting but not surprising that English remains one of the 
official languages, at least for now. For many years there has been a 
large body of documentation provided in English and indeed, many of 
the European Norms are based on IEC standards originating in French & 
English. I wonder, will this policy change in the foreseeable future?


It has been my practice to tell clients that the minimum requirement 
for translation of user document(s) and product markings is they must 
first be in one of the official languages and upon request by the end 
user, the local language becomes a requirement as well. I haven't 
checked in some time, but the Machinery Directive may require this 
without end user involvement. In some cases, local regulatory 
requirements may dictate which languages must be used for specific 
information especially involving EHS. Incidentally, a good friend who 
is in Planetary Aeronomy and Astro-geophysics has told me, if you 
know just one of a handful of languages, you can just about go 
anywhere in the scientific world community; these being English, 
French, German, Japanese and possibly Russian.


So now there is the question of which "English" is the official 
language of the EU, British (Cambridge) English?  I suspect that 
Brits, Aussies and Americans will all have no trouble understanding 
one another, even with differences in spelling, grammar and possibly 
idioms. Or as Wikipedia puts it, these are "mutually comprehensible" 
(https://en.wikipedia.org/wiki/List_of_dialects_of_English). I 
noticed one form of English not mentioned in the Wikipedia article, 
Texas.


All the best, Doug

PS - The bottom line, every Tom, Dick and Harry should avoid cliché 
at all costs.



--

Douglas E Powell

doug...@gmail.com <mailto:doug...@gmail.com>
http://www.linkedin.com/in/dougp01
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Re: [PSES] Conducted emissions AMN/AAN layout

[Gert Gremmen]

Drilling holes in  (new) chamber is like drilling holes in your new cars 
roof for an antenna. I can imagine your hesitation. However there is (as 
long as the holes are not to big and correctly made) nothing against it. 
If it allows you to reliably position your AMN devices you  need, a 
swiss cheese will be the best solution.


Regarding the standards... standards are written by guys like you and 
me. Experts in the WG and national committees are not paid for their 
knowledge (which actually is one of the finest on the planet !) , and 
many of them will confirm that they (or their employer) actually need to 
pay to transfer their expertise to IEC. Many members will lack 
motivation (or are not allowed ) to really spend time in correcting, 
drafting and searching for problems in standards texts. Participating in 
standards work is a kind of charity, but for those who are nominated to 
defend their employers interests. So small errors are easily overlooked, 
and it seems that you found a few of them.


Please do not worry and find your own (defendable) solutions, experiment 
and verify if measurement differences occur. There will be. EMC testing 
is not an exact science and standards are should be read as a generic 
guideline. No-one will notice the differences in set-up and no-one will 
challenge them as their own experience will be similar. If your are to 
be audited, referring to the open issues in the standard might help.


Cable lay-out is the most difficult part of emission testing, and small 
difference will make sometimes 10's of dB of differences. Where the 
equipment set up and the room calibration will give you a measurement 
uncertainty (MU) of about 5 dB (if all done right) the EUT setup will 
easily add 15-20 dB to that.


Oh and if you are interested into a better test set-up than CISPR32 
(former 22), look into the CISPR 16 series,especially the chapters om 
measurement volumes.



Gert Gremmen


On 9-8-2019 21:17, Andrew Perry wrote:

My friends,

I am preparing to drill new threaded holes in our chamber floor, where 
we will perform our CISPR32 (2012) conducted emissions tests.  Looking 
at Table D.1 and figure D.2, I am trying to figure out where to place 
our two AMNs and single AAN to meet all of the distance and length 
requirements.


Our setups will look very much like figure D.2, but shape and number 
of AE will vary (naturally).  What boggles my mind is how to have 
fixed positions for the AMNs and AAN (I don't want to turn my chamber 
floor into Swiss cheese), and avoid having to rearrange the EUT on the 
test table when switching from AC port measurement to let's say, 
network port measurement. Figure D.2 seems to suggest that its layout 
permits exactly what I'm looking for.  However, reading the note of 
the figure (no longer a note in version 2015, by the way) and looking 
at the distance requirements in table D.1, I don't understand how 
figure D.2 permits EUTs to become AEs, without rearrangement.


For example, let's say you are measuring the middle EUT using the AAN, 
then how can the PSU at the left be >= 0.8m from the active AAN?  The 
note says that if the device is AE, then it shall be at a >= 0.8 m 
distance.  So this PSU now being AE, shouldn't it be at more than 0.8 
m from the AAN?  Is the figure misleading in indicating that each 
device can be EUT or AE at its current position?  Keep in mind that 
Table D.1 also states that all cables must be kept at 0.4 m from the 
vertical plane.  CISPR22 had figures that showed AMNs all over the 
place, even bonded to the vertical plane.  CISPR32 now shows all 
AMN/AAN at the 40 cm line.  D.2.2 text still allows AMN/AAN to be 
bonded to the vertical plane, but then how do you maintain the 40 cm 
distance for the cables if their endpoint is essentially at a few 
centimeters from the plane?


Another question is about this "new" insulation pad underneath the 
table.  There is a maximum thickness of 0.15m specified for this 
insulation, but no minimum.  Are the cable outer sleeves enough?  Is a 
coat of enamel paint on a metal turntable enough?  I understand that 
bare wires shouldn't make contact with ground if they're not supposed 
to, but is an insulation pad really necessary when cables are not bare?


Please let me know what your thoughts are, there must be something I'm 
not seeing here.


AP
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Re: [PSES] Ground on ship

[Gert Gremmen]

Ground is only called ground because it was usage to use the real ground 
as safety potential.


Why ? Because we humans historically  tend to connect with our feet to 
the soil, and  if any touchable conductor has the same potential


as the soil, there is no hazard. This works only in reasonably wet areas.

Grounding Safety is about the voltage_difference_ we can reach as humans 
using hand and legs to bridge distances.


In the northern countries, and in the mountains the soil is mainly rock, 
and does not conduct electricity well enough


to function as a safety "ground" (actually "safety rock"). The utility 
their relies on other mechanisms for safety then soil ground.


The soil is connected to the surface of our globe. If we could reach the 
moon with our hand, there would probably


a huge discharge current between the two bodies, because the moon is not 
grounded.


Ground is relative. Inside a metallic volume, ground has no meaning 
anymore, because you need to touch


the metal wall before you can touch ground. Inside such a volume the 
'ground" is the metal wall.


All conductive items need to be connected to the volume (=ship) wall to 
remain safe.


It makes no sense seeking for our globes soil potential (ground) inside 
a metallic volume.


Gert Gremmen








On 8-7-2019 20:19, 06cee064502d-dmarc-requ...@ieee.org wrote:

Hello group,

Is there a real ground in a ship?  i.e if a Class I product is used on 
the board of a ship, does the ground pin actually doing anything? The 
ship is floating in the ocean and I cannot understand if there is a 
real ground there or not? Can you guys educate me please?


Thank you
Peter
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Re: [PSES] Guidelines v Standards v Codes

[Gert Gremmen]

Standards are in general -at least in our businesses- created by private 
parties (as opposed to public ); "interested parties" as John says. In 
Europe we also have "directives". Grosso modo: "Directives" are  called 
"codes" on the other side of the ocean and have legal value,  standards 
do not.


A subtle variation of standards are /EU exclusive/, and they are *cited 
harmonized standards*. Cited from citation in the Official Journal 
L(egal) of the EU, Harmonized as being valid within all member states of 
the EU. Cited HS have legal effect in the EU.


Gert Gremmen

On 27-6-2019 21:08, John Woodgate wrote:


That's only one sort of standard, a performance standard. There are 
other sorts, such as 'methods of measurement' standards. In general, a 
standard is 'an agreement between interested parties'.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-06-27 19:35, Richard Nute wrote:


Hi Doug:

Way back when, Dwaine Richins, professor at University of Oregon, 
taught that a standard was “a statement of acceptable performance.”  
Keeping this definition in mind…




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Re: [PSES] Tilt test

[Gert Gremmen]

Note that while tilting most standards require the device to be blocked 
(non-skid surface) against sliding (feet) or rolling (wheels).


The new IEC 62368-1 ed 3.0 has a somewhat cryptic way of defining 3 
alternate (supposed equivalent)  tests for this:


 * The equipment is tilted in all directions such that the base of the
   equipment is at an angle up to and including 10°; *or*

 * The equipment is placed on a plane at an angle of 10° from the
   horizontal and rotated slowly through an angle of 360° about its
   normal vertical axis; *or*
 * The equipment is placed on a horizontal non-skid surface and
   subjected to a force equal
   to:
   - 50 % of the weight of the unit vertical downwards, but not more
   than 100 N. If, during
   the test, the supporting surface prevents the equipment from
   overturning, the test shall
   be repeated such that the supporting surface is not used to pass the
   test; and
   - 13 % of the weight in all horizontal directions but not more than
   250 N,

   that is applied to the worst case positions on the equipment by
   means of a suitable test
   apparatus having a flat surface of approximately 125 mm by 200 mm,
   in such a way as to
   produce the maximum overturning moment. The test may be applied at
   any height not
   exceeding 1,5 m from the base of the equipment. The test force shall
   be discontinued if
   the equipment remains stable after being tilted 10° from vertical.

The normal vertical axis in the second alternate test  to be understood 
as the axis that was vertical before tilting;  one may be tempted to 
rotate the full set up over a vertical axis,which does not provide the 
same result.


Sidenote for the EN-version to become harmonised (cited):

Standards specifying alternative tests will need to provide guidance for 
application, fully open  manufacturer alternate tests are a _legal 
problem for citation of a standard  in the EU_. Either a proof of 
equivalence of alternate tests needs to be provided, or the conditions 
on which alternates to be selected shall accompany the standards tests. 
If your product needs to be used for the EU-market in the years to come, 
make sure you comply with all alternates.


Gert Gremmen

On 12-6-2019 6:55, frankt_cpmt wrote:

Thank you for sharing your experience Ted.



Sent via the Samsung Galaxy S8, an AT 5G Evolution capable smartphone

 Original message 
From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org>
Date: 6/11/19 21:03 (GMT-08:00)
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Tilt test

Let me address the question of “how to safely perform this test”.

The proper safety precautions depend on the mass and stability of the 
equipment. Equipment doesn’t have to be too heavy to cause an injury 
if it falls over on somebody. If the equipment is large and/or very 
heavy, consider having it tested at a laboratory that has equipment 
that can do the test safely. If you don’t have that option, think 
about what precautions may be required.


I can give an example of a test I ran at a previous employer. I had to 
run a 10-degree tilt test on a standard sized equipment rack loaded to 
1500 kg. The stabilization feet were down, but they were only about 
500 mm apart between the two sides of the rack. The rack was a full 
2-meter height with the load evenly placed in the rack. This should 
have been done at an external laboratory with the proper equipment. 
However, an NRTL was there to witness testing and they insisted in 
seeing it done that day.


The first mistake was figuring out how to tilt the rack. The solution 
was to go to the parking lot and to get the jack out of the back of a 
car. The jack was designed to lift one wheel of a 1500 kg car, not 
half of a 1500 kg rack. Somehow, the jack survived the test and tilted 
the rack.


The second mistake was the placement of the test. The rack was about 1 
meter from a wall and we tilted it towards that wall. It was standard 
drywall construction, and I don’t think it would have stopped the rack 
if it fell over. The people in the office on the other side would have 
been in for a surprise.


The next mistake was not placing any limitation on the tilt. We could 
have placed straps at the top of the rack to a solid support in the 
lab. We could have limited the tilt to 11 degrees, so that if the rack 
did start to go over, it would have been stopped before it went too 
far. This probably would have also required blocking the stabilization 
feet to keep them from sliding.


There was an additional error of not properly securing all loads 
inside the rack. The full loading of the rack was simulated using 
steel plates, but they were just held in place by gravity. When the 
tilt reached 8 degrees, much of the weight shifted. We were tilting 
the rack towards its front, and only the latch on the front door kept 
the plates from sliding out of the rack.


The test was completed without incident, and that was large

Re: [PSES] GB or GC?....that is the question....

[Gert Gremmen]

Normally the specs (mm2, mOhms, screw and/or weldings)  of the GB  path 
is ensured by the type testing; the production ensures the reproduction 
of the type tested by internal production control or better, so what 
remains is to test for production ERRORS.


Assuming that no component specs in the GB can be changed (due to the 
above), the remaining test to do is to ensure the required GB path is 
there ... and if the impedance is low enough. That can be done by 100uA 
and by 25A.


That said, a mOhm contact whisker, bridging a production error may 
create a  GB path  at 50 mOhm or so may burn away at 25 A and not at 100 uA.


It's your risk analysis, due diligence, and type of equipment that 
decides for the applied current.


Gert Gremmen

and so the quality is ensured by those.

On 17-5-2019 21:08, Regan Arndt wrote:


Hello members,

I tried to search my EMC-PSTC archives (to no avail) regarding a 
debate of using either ground bond (let's assume 25A for this 
discussion) or ground continuity (resistance measured < 0.1 ohm for 
this discussion) testing _during production_.


Therefore, I would like to bring the topic up (again?) and get your 
professional opinion on these tests.


(Side note: Omnia has put out a brochure recently promoting the use of 
ground bond test in addition to ground continuity during production, 
but I am a little skeptical.)



I am a proponent for the ground continuity test during production for 
several reasons:


1.It’s safe to conduct, especially for production staff

2.Less harmful to the equipment

3.Intent is to verify the ground path is ‘secure’.

And I am an opponent to the ground bond test during production for 
several reasons:


1.Dangerous to conduct. Need astute production personnel that know 
what they are doing.


2.I consider this a type test and ‘somewhat’ damaging/stressful….(Yes, 
can be debated)…



Yes, the ground bond test is useful and a good indicator for 
determining the ampacity integrity of cables/connectors but, in my 
opinion, it should be reserved for type testing only.


_I feel that there is no reason to do the ground bond test during 
production if the manufacture controls their components in 
purchasing/design via an ECO process, etc., thus the ground continuity 
test is thereby sufficient_.


If one have no component control process, then, yes, GB is a good idea.


Note that IEC 61010-1 Annex F (Routine tests) also specifies the 
ground continuity test (and not a ground bond test)... but also 
take note that it does say the value for current is not specified.


*/F.2 Protective earth/*

/A continuity test is made between the earth pin of the appliance 
inlet or the //MAINS //plug of plug-connected equipment, or the 
//PROTECTIVE CONDUCTOR TERMINAL //of //PERMANENTLY CONNECTED EQUIPMENT 
//on the one side, and all //ACCESSIBLE //conductive parts which are 
required by 6.5.2 to be connected to the //PROTECTIVE CONDUCTOR 
TERMINAL //on the other side./


/NOTE No value is specified for the test current./

/
/

Your reply is greatly appreciated.

Thanks in advance.

Regan Arndt

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Re: [PSES] Product Declaration of Conformity with external PSU...

[Gert Gremmen]

The message was also for the group, my mistake...

It depends,

If the product is sold with a manufacturer provided adapter, then the 
product has a mains connection. -> LVD


(it is not because there is a connector between power supply and 
equipment that it becomes safe)


If the product is sold without, it has only the ELV DC connection. -> No LVD

LVD is about more than just insulation from the mains.

The whole concept of voltage limits in the LVD is wrong, the idea that a 
device is inherently safe if supplied by 24 volts (for example)  is 
evidently wrong; this is also why those limits has been removed in the RED.


Gert

On 10-4-2019 19:32, John Woodgate wrote:


Hello, Gert. Did you mean to reply only to me or to the mailing list? 
I don't understand your reasoning. The product itself runs from ELV 
DC, so, even though there is a power supply next to it in the box,  
surely the LVD doesn't apply? It does, of course, apply to the power 
supply that is supplied with it.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-04-10 17:51, Gert Gremmen / Ce-test wrote:

It depends..
If the power supply is an inherent part of the product as “put on the 
market” then the lvd should apply. If not, so the customer is 
supposed to buy an adapter himself , then the product is supposed to 
be a dc supplied product and if this supply voltage is outside the 
limits for the lvd, such as 5 or 12 voltDC , then the lvd does not apply


Gert
Verstuurd vanaf mijn iPhone

Op 10 apr. 2019 om 18:03 heeft John Woodgate <mailto:j...@woodjohn.uk>> het volgende geschreven:



I think:

/Should the product's EU Declaration of Conformity list the LVD 
directive? If so is it acceptable to list 'LVD only with specific 
'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not 
ever seen that done but don't see why that couldn't be the case./


The product is outside the LVD/.//
/

/Should the product's EU Declaration of Conformity also list the 
2009/125/EC Ecodesign directive in respect of the PSU implementing 
measures?/


The ECO Directive applies to the power supply, not the product.

/Maybe there should be two Declarations of Conformity in the box? 
One for the product and one for the PSU, where the latter is a copy 
of the PSU manufacturer's DoC?/


It seems a logical solution, and I doubt that it is explicitly 
prohibited.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-04-10 16:51, Matthew Wilson | GBE wrote:
A consumer product is powered by AA cells but also can derive its 
power from a 'wall wart' mains-DC PSU via a DC jack input on the 
product. The client who is the manufacturer of the product (as per 
the EU directive) has decided to supply a third-party wall-wart PSU 
in the box with the product. The PSU does not carry the product 
manufacturer's logo but that of the PSU manufacturer (or possibly 
its importer/distributor assuming the responsibility of 
manufacturer because it will inevitably be made in Far East).


Should the product's EU Declaration of Conformity list the LVD 
directive? If so is it acceptable to list 'LVD only with specific 
'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not 
ever seen that done but don't see why that couldn't be the case.


Should the product's EU Declaration of Conformity also list the 
2009/125/EC Ecodesign directive in respect of the PSU implementing 
measures?


Maybe there should be two Declarations of Conformity in the box? 
One for the product and one for the PSU, where the latter is a copy 
of the PSU manufacturer's DoC?


Any thoughts welcome thanks.

Regards all.



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Re: [PSES] Tamper-proof Hardware

[Gert Gremmen]

IR-3 Internal Regulations for writing standards issued by CENELEC (which 
is roughly the same as IR2 in IEC) gives information on how to write 
standards, and shows clearly that the Introduction should be informative:


From IR-3

 Introduction
13.1 Purpose or rationale
The introduction provides specific information or commentary about the 
technical content of

the document, and about the reasons prompting its preparation.
13.2 Normative or informative?
The introduction is an informative element. It shall not contain 
requirements.



Well the reader of course won't know about that, that is why there 
should not be any requirements.


Gert Gremmen

On 9-4-2019 11:36, John Woodgate wrote:


We are not so far apart. You say that the text should not have 
appeared in a numbered clause that might be assumed to be normative. I 
say that it would be better not to have a numbered clause because it 
might seem to be normative.


I think that few would assume that the normal INTRODUCTION text in an 
IEC standard is normative. See 13.2 of Directives Part 2.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-04-09 10:28, John Allen wrote:


John W

When something that ambiguous, and which that /could/ be construed as 
being a requirement, is placed in a prominent position in a standard, 
regardless or not of whether the clause in question is numbered, then 
it is obvious that it will (as it has done) raise issues and 
questions as to the potential effects on many other parts of that 
standard .


BTW: it has been widely and authoritatively stated that 62368 is 
_not_ a “Risk Assessment” standard, and appropriate rationales and 
requirements are thus given therein  – but to then include an 
undefined term which /migh/t then be construed as a “requirement” is 
an open invitation for someone to decide that “he” has to risk assess 
how “tamper-proof” a particular design safety feature actually might be.


Those are some of the reasons why I consider that the term in 
question should never have been included in the first place.


John E Allen

W. London, UK

*From:*John Woodgate [mailto:j...@woodjohn.uk]
*Sent:* 09 April 2019 09:40
*To:* John Allen; EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] Tamper-proof Hardware

I think that the major point is that Clause 0 is purely advisory. It 
seems reasonable in an advisory text to mention means to deter 
operations that might compromise safety, without going into 
exhaustive detail.  It would seem harmless, so not worthy of suppression.


I wouldn't have given the INTRODUCTION a clause number, because it 
creates an impression that it is normative. But then there are 10^6 
things in 62368-1 that I would have done differently.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk  <http://www.woodjohn.uk>
Rayleigh, Essex UK

On 2019-04-09 09:11, John Allen wrote:

Rich

Thanks for laying out the main definitions of “tamperproof”, and
for your view on why my “story” is not an example thereof (it was
only the one that I had “to-hand” at the time, and there must be
many others J) .

Maybe, therefore, similar definitions/explanations should have
been included in IEC 62368, so as to make it (much!) clearer to
designers and testing/certification personnel as to the intent of
the requirement because (obviously) there can be a considerable
spread of interpretations of the requirement - or else John
Cochran  (and probably many others!) would not ask the question.

As it stands, that “requirement” must thus be considered to be
“ambiguous” at best, and therefore _shouldn’t have been included
in a standard in that form _/(I’m sure there must be a word to
describe a definition with four different possible
interpretations, but I’m afraid I don’t know it and thus
“ambiguous” is the best that I can offer ATM!)./

//

In fact, given the definitions you quote, I would suggest that
the term should NOT have been included in the standard _at all_
because they imply the likelihood of various levels of
intentional interference/criminality on the parts of possible
perpetrators. /However/, it should not have been the intent of
the 62368 standards-writing teams to address such issues - maybe
YES if it were in a /theft/ building-intrusion/ forgery
prevention (etc.) /standard, but*NO *in a broadly-targeted
_product safety_ standard.

John E Allen

W. London, UK

*From:*Richard Nute [mailto:ri...@ieee.org]
*Sent:* 08 April 2019 23:40
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Subject:* Re: [PSES] Tamper-proof Hardware

From dictionary.com:

tamperproof

adjective

1 that cannot be tampered with; impervious to tampering

tamper

verb (used without object)

1 to meddle, especially for the purpose

Re: [PSES] Harmonised Standards ->Official EU law

[Gert Gremmen]

Lost this question, for unknown reason:


"If the Commission concludes that the standard is in compliance with the 
request and Union legislation, it will decide to publish its reference 
in the Official Journal of the European Union. As a result, and 
following a Commission decision to publish the reference in the Official 
Journal, the standard _will produce legal effects under the relevant 
Union legislation._"


found in:

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2018%3A764%3AFIN

An example standard:

COM(2018) 764

https://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/accessibility-websites-and-mobile-applications_en

And a press release:

http://europa.eu/rapid/press-release_IP-18-6491_en.htm


Gert Gremmen

On 29-1-2019 19:36, Rudd, Adam wrote:

Thank you,
Do you have a specific L###? That an update was published under. There are 
quite a few. and digging... but not seeing one with Harmonized Standards.

Adam Rudd
Senior Engineer, EMC Certification
NCR Corporation
O: 770.495.2825
adam.r...@ncr.com  |  www.ncr.com

-Original Message-----
From: Gert Gremmen [mailto:g.grem...@cetest.nl]
Sent: Wednesday, January 16, 2019 5:12 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Harmonised Standards ->Official EU law

*External Message* - Use caution before opening links or attachments

Note that publication/citation of harmonised standards in Europe from

now on (12/2018) will take place in the L section of the OJ, effectively

allowing them the status of EU -law. A first standard on Accessibility

of (governmental) Websites has already been published.



Gert Gremmen




--
Independent Expert on CE marking
Harmonised Standards (HAS-) Consultant @ European Commission for RED and EMC
EMC Consultant
Electrical Safety Consultant


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Re: [PSES] Brexit requirements for UK manufacturers.

[Gert Gremmen]

May i suggest: XXX   BC (British Compliance) , where XXX is the NoBo number

An example would be 250 BC.  (confusion with Before Christ is really 
unintended)


As a marking to replace the CE marking is suggest:

Afbeeldingsresultaat voor bowler hat clip art

The moustache is optional.

Gert


On 16-1-2019 20:46, Pete Perkins wrote:


Scott et al,

    I haven’t read the 600+ UK legislation report (which 
was apparently rejected this week in the Parliament) but I am 
searching for the new UK marking – perhaps ukCEeu?


:>) br,  Pete

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

503/452-1201

IEEE Life Fellow

p.perk...@ieee.org 

*From:* Scott Xe 
*Sent:* Wednesday, January 16, 2019 5:57 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] Brexit requirements for UK manufacturers.

Hi Ian,

Your assumption is correct but may have more than your thought.  You 
can read the following draft for greater detail.


http://www.legislation.gov.uk/ukdsi/2019/978076368/schedule/25

I have learnt that recently the UK government published draft 
Regulations of 619 pages in case of no deal Brexit.  Unfortunately, I 
could not locate it yet.  Hope other team mates can help to explore 
greater info.


Thanks and regards,

Scott

Sent from Mail  for 
Windows 10


*From: *McBurney, Ian 
*Sent: *Wednesday, 16 January 2019 08:55 PM
*To: *EMC-PSTC@LISTSERV.IEEE.ORG 
*Subject: *[PSES] Brexit requirements for UK manufacturers.

Dear Colleagues.

I have been waiting for some firm guidelines as to what will be the 
requirements for UK manufacturers after 30^th March 2019


but so far nothing has been published by the relevant authorities.

From my understanding, if the UK leaves the EU without an agreement, 
the UK will be outside the EU and there are different requirements for 
UK based manufacturers.


I believe the existing manufacturers Declaration of conformity 
documents will still be valid but that a nominated representative in 
the EU will now be required. We plan to nominate our distributor in 
the EU (i.e. Germany) as the importer to satisfy this requirement.


Please can you let me know if my assumptions are correct?

Thanks in advance.

Ian McBurney

Lead Compliance Engineer

Allen & Heath Ltd.

Kernick Industrial estate,

Penryn,

Cornwall. TR10 9LU. UK.

Tel: 01326 372070

Email: ian.mcbur...@allen-heath.com 

Allen & Heath Ltd is a registered business in England and Wales, 
Company number: 4163451. Any views expressed in this email are those 
of the individual and not necessarily those of the company.


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[PSES] Harmonised Standards ->Official EU law

[Gert Gremmen]

Note that publication/citation of harmonised standards in Europe from 
now on (12/2018) will take place in the L section of the OJ, effectively 
allowing them the status of EU -law. A first standard on Accessibility 
of (governmental) Websites has already been published.


Gert Gremmen

--
Independent Expert on CE marking
Harmonised Standards (HAS-) Consultant @ European Commission for RED and EMC
EMC Consultant
Electrical Safety Consultant


-

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Re: [PSES] EN 55032 - and other EN standards

[Gert Gremmen]

Thank you Michael,

You correctly emphasize the importance of a risk analysis in front of 
testing and standard selection.


And as well as important the fact that one needs to declare compliance  
directive, and not to the standard.


But the directives almost always allow a manufacturer to obtain 
presumption of compliance if


route A (Harmonised Standards / Manufacturers Declaration)  is used. The 
risk analysis is mandatory for


the Notified Body route. I must admit that the different directives are 
a bit vague on that, and i am


not sure why. I would prefer the risk analysis to be part of every 
approval route, where the hazards


covered by a HS are not to be  further analysed.

Gert





On 27-11-2018 12:06, Michael Derby wrote:


That’s a good summary from Gert.

I think one important thing to remember is that the EU (LVD + EMCD, or 
RED) approach to compliance is the manufacturer assessing their device 
in any way possible, to show compliance with a Directive.   It’s not a 
certification to a standard.


So, if a product has a risk of causing interference in some way, or 
causing a safety issue, or being affected by EMC, it should be 
assessed – regardless if the standard exists yet, or if the standard 
is harmonised yet, or if the harmonised standard is listed on the 
Official Journal (OJ) yet.


In an ideal situation, all devices would have an applicable harmonised 
standard which is listed on the OJ for the applicable Directive.


If industry then notes that things are changing, the standard gets 
updated (or a new standard written) and added to the OJ with a 
reasonable transition period from the old standard.


(Or, if the issue is critical, there may be no transition period, or 
standards can be withdrawn from the OJ).


That’s how it should work.

However, we’re not in this ideal situation right now, because the 
standards have not made it onto the OJ for (mostly) legal and 
administrative reasons.


(Also some technical reasons, such as performance criteria, etc.)

But this is not a show-stopper.

The manufacturer must ascertain which tests or assessments must be 
carried out on their device, to show that it will not interfere, will 
not be interfered with, will be safe, etc. Then, do those tests (or 
assessments) and create their DoC.


For example, if a new standard becomes published and there are test 
cases in there which apply to a product, a manufacturer would not say 
“I don’t have to do that yet, because that standard is not on the 
OJ”.   The EU approach is declaration to a Directive, not 
certification to a standard.


If a manufacturer knows that their device presents a safety or 
interference risk which is not covered in any of the standards, 
published or draft, it does not mean they should ignore it.   It means 
they make their own way to assess it.


This is where the manufacturer’s risk assessment becomes so 
important.   It is the starting point for any manufacturer; as a way 
for the manufacturer to determine which tests they should be doing on 
their device, and figuring out which standards they should look for.


Of course, this is no problem for selling into the EU (it’s easy to 
pick a standard which is not on the OJ and test to it – and that’s ok 
in the EU); but I do appreciate that it could be problematic for other 
non-EU regions who look for compliance to standards on the OJ, and do 
not understand the subtlety that in the EU that is not mandatory.


Michael.

*From:*Gert Gremmen [mailto:g.grem...@cetest.nl]
*Sent:* 27 November 2018 09:28
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] EN 55032

Hi All,

The document below has been published very recently and shows how and 
why...


https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2018:764:FIN

In simple language, the EC court has decided that HS are to be treated 
as EU-law (Elliot case).


This has a lot of consequences. In order to get a _privately 
originated text_ count as law, the EC has added


a number of conditions that standards need to fulfill. These find 
their base in  the New Legislative Framework.


Some of the problems with current texts are:

  * Not static (by undated references to standards), so "law"  changes
when referenced  standards update, or referenced standards are
withdrawn.
( the problem is here also that ESOs are private organisations
(ISO,CENELEC, CEN, ISO) can change EU law this way)
  * Unclear/incomplete technical specifications , link between
directives essential requirements and standards technical
specifications
  * Ambiguous test specifications, often introduced by choices a
manufacturer can make on its own, so as to avoid testing.
  * And many more, mostly of a legal interpretation nature.

The problem is not that standards are not technically suitable to show 
presumption of compliance, but that they are not suitable to be used 
as law.


Secondly, the ESOs and national committees are not (yet) fully aware 
of the co

Re: [PSES] EN 55032

[Gert Gremmen]

Hi All,

The document below has been published very recently and shows how and why...

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2018:764:FIN

In simple language, the EC court has decided that HS are to be treated 
as EU-law (Elliot case).


This has a lot of consequences. In order to get a _privately originated 
text_ count as law, the EC has added


a number of conditions that standards need to fulfill. These find their 
base in  the New Legislative Framework.


Some of the problems with current texts are:

 * Not static (by undated references to standards), so "law" changes
   when referenced  standards update, or referenced standards are
   withdrawn.
   ( the problem is here also that ESOs are private organisations
   (ISO,CENELEC, CEN, ISO) can change EU law this way)
 * Unclear/incomplete technical specifications , link between
   directives essential requirements and standards technical specifications
 * Ambiguous test specifications, often introduced by choices a
   manufacturer can make on its own, so as to avoid testing.
 * And many more, mostly of a legal interpretation nature.

The problem is not that standards are not technically suitable to show 
presumption of compliance, but that they are not suitable to be used as law.


Secondly, the ESOs and national committees are not (yet) fully aware of 
the consequences and are a bit reluctant.They have been used to create 
and approve HS on their own, where now the EC takes the lead. This 
creates problems especially for older standards, that have not been 
written with the newer standardisation requests in mind.


To assess the standards for their suitability a number of HAS-experts 
have been nominated, and the iterative process of creating suitable 
harmonised standards is active for about 6 months.


Gert Gremmen

--
Independent Expert on CE marking
Harmonised Standards (HAS-) Consultant @ European Commission for RED and EMC
EMC Consultant
Electrical Safety Consultant


On 27-11-2018 9:43, McBurney, Ian wrote:


Hello David.

I would be interested in getting more information regarding these 
legal issues with standards and the court proceedings.


Are there any published articles?

Regards;

Ian McBurney

Lead Compliance Engineer

Allen & Heath Ltd.

Kernick Industrial estate,

Penryn,

Cornwall. TR10 9LU. UK.

Tel: 01326 372070

Email: ian.mcbur...@allen-heath.com

*From:*itl-emc user group 
*Sent:* 27 November 2018 06:07
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] EN 55032

I was informed that almost all the latest versions of standards are 
being held up over legal issues since a standard was introduced as 
evidence in a court case.


CISPR 11 and others have the same issue.

*Regards,***

*David Shidlowsky***| Technical Reviewer

*Address*1 Bat-Sheva St. LOD 7120101 Israel

*Tel*972-8-9186113*Fax* 972-8-9153101

*Mail*: dav...@itlglobal.org 
<mailto:dav...@itlglobal.org>/dav...@itl.co.il 
<mailto:dav...@itl.co.il>/e...@itl.co.il


**

*rom:*John Woodgate mailto:j...@woodjohn.uk>>
*Sent:* Monday, November 26, 2018 1:29 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Subject:* Re: [PSES] EN 55032

I think it is still held up over legal issues, which may not be 
resolved any time soon.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK

On 2018-11-26 09:45, McBurney, Ian wrote:

Dear colleagues.

Does anyone know if the 2015 edition of the above standard is now
listed in the OJEU for the EMC directive?

I am struggling to find it on the website.

Many thanks in advance.

Regards;

Ian McBurney

Lead Compliance Engineer

Allen & Heath Ltd.

Kernick Industrial estate,

Penryn,

Cornwall. TR10 9LU. UK.

Tel: 01326 372070

Email: ian.mcbur...@allen-heath.com
<mailto:ian.mcbur...@allen-heath.com>

Allen & Heath Ltd is a registered business in England and Wales,
Company number: 4163451. Any views expressed in this email are
those of the individual and not necessarily those of the company. -


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Re: [PSES] SV: [PSES] EN60950-1 not listed anymore as LVD harmonized standard

[Gert Gremmen]

This is clearly marked in column (5) of the list of harmonised standards

"Date of cessation of presumption of conformity of superseded standard"

even if it is not listed in Column (2)

With the remark that EN 60950-1:2006 should not be applied for new 
presumptions of conformity.



Gert Gremmen
--
Independent Expert on CE marking
Harmonised Standards (HAS-) Consultant @ European Commission for RED and EMC
EMC Consultant
Electrical Safety Consultant


On 8-9-2018 10:14, Amund Westin wrote:


Thanks for this clarification, Loerzer.

I think we will use EN62368-1 now anyway, since 2020-12-20 is just 
around the corner.


BR Amund

*Fra:*loerzer_mob...@globalnorm.de 
*Sendt:* 8. september 2018 09:45
*Til:* 'Amund Westin' ; 
EMC-PSTC@LISTSERV.IEEE.ORG

*Emne:* AW: [PSES] EN60950-1 not listed anymore as LVD harmonized standard

Hi Amund,

that is a „long story“ (caused by the so-called James Elliott Case 
C-613/14 and the Global Garden Case T-474/15). One consequence is the 
changed publication strategy of harmonized standards in the OJEU of 
theCommission (ref.: GROW/B3/AV/dn(2015)4821974). Annex III of this 
document describes under no. 9 for the LVD the following:


“c) All rows still giving references (in column (2)) of withdrawn and 
superseded standards MUST BE REMOVED from the list. Superseded 
standards and related “dates of cessation” are given in (4) and (5) 
columns only.”


The same situation is given for RED and EMCD.

Therefore the superseded standard EN 60950-1 and the amendments GIVES 
presumption of conformity until 2020-12-20 (my birthday…).


*Von:*Amund Westin <mailto:am...@westin-emission.no>>

*Gesendet:* Samstag, 8. September 2018 09:12
*An:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Betreff:* [PSES] EN60950-1 not listed anymore as LVD harmonized standard

From June 15, 2018

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018XC0615(04) 
<https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018XC0615%2804%29>


What’s the reason? EN 62368-1 in not mandatory before 20.12.2020, so 
we should still be able to use EN60950-1:2006.


BR

Amund

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--
Independent Expert on CE marking
Harmonised Standards (HAS-) Consultant @ European Commission for RED and EMC
EMC Consultant
Electrical Safety Consultant


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Re: [PSES] FW: Industrial Printer

[Gert Gremmen; ce-test]

That is a valuable remark.

Instead one should look-out for EN 55035 to be published; until then 
equipment legally need to comply with EN 55024  and both standards 
should be considered.


The publication date of that standard is currently unknown.

The scope of the affiliated standards EN 55022 and EN 55024 is ITE,

The scope of EN55032/EN55035 will be *multimedia equipment* and is 
larger than ITE.


Gert Gremmen

HAS Consultant RED and EMC at European Commission.

On 26-5-2018 10:47, John Woodgate wrote:


EN 55024 has only a very limited future life. I would not recommend 
applying it to a new product.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2018-05-26 08:50, Gert Gremmen; ce-test wrote:


Hi David,


CISPR 32 is not relevant as this is not a Harmonised European standard.

While CISPR IEC and EN standards may have similar numberings, they 
are not the same in all aspects.


EN 55032 _is_ a Harmonised European Standard (based on CISPR32) and 
applies to both Industrial and Residential ITE products, and a 
printer is a typical ITE product. So at first view EN 55032 is the 
preferred standard.That said, i did not actually see your printers.


EN 55011 has a more extended emission frequency range, and is 
probably more expensive to test as EN 55032.


The generic standards  61000-6-1/2/3/4  are supposed to be used only 
in case of absence of suitable product group standards (such as EN 
55011 and EN 55032 for emissions and EN 55024 for immunity). As that 
is the case, (as EN 55024 has no suitable test levels for (Class A) 
industrial operation), for reliable operation in an industrial 
environment the EN 61000-6-2 is the right alternative to EN 55024.


The best combination from both performance and legal view is probable 
EN 55032 Class A and EN 61000-6-2.


You might also apply just for EN 55032 and EN 55024 to obtain 
presumption of conformity and CE-mark and take a higher of field 
problems.




Gert Gremmen

HAS Consultant RED and EMC at European Commission.


On 24-5-2018 7:01, itl-emc user group wrote:


An industrial printer has been tested to EN 55011: 2009 + A1: 2010 
and EN 61000-6-2: 2005 + AC: 2006 (latest EMCD OJ).


Another industrial printer has been tested to EN 61000-6-4: 2007 + 
A1: 2011 and EN 61000-6-2: 2005 + AC: 2006 (latest EMCD OJ).


The printers are used in an industrial environment only.

Any opinions as to whether or not CISPR 32 is relevant as well.

Thanks in advance to any responses.

*Regards,***

*David Shidlowsky***| Technical Reviewer

*Address*1 Bat-Sheva St. LOD 7120101 Israel

*Tel*972-8-9186113*Fax* 972-8-9153101

*Mail*: dav...@itlglobal.org 
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Re: [PSES] FW: Industrial Printer

[Gert Gremmen; ce-test]

Hi David,


CISPR 32 is not relevant as this is not a Harmonised European standard.

While CISPR IEC and EN standards may have similar numberings, they are 
not the same in all aspects.


EN 55032 _is_ a Harmonised European Standard (based on CISPR32) and 
applies to both Industrial and Residential ITE products, and a printer 
is a typical ITE product. So at first view EN 55032 is the preferred 
standard.That said, i did not actually see your printers.


EN 55011 has a more extended emission frequency range, and is probably 
more expensive to test as EN 55032.


The generic standards  61000-6-1/2/3/4  are supposed to be used only in 
case of absence of suitable product group standards (such as EN 55011 
and EN 55032 for emissions and EN 55024 for immunity). As that is the 
case, (as EN 55024 has no suitable test levels for (Class A) industrial 
operation), for reliable operation in an industrial environment the EN 
61000-6-2 is the right alternative to EN 55024.


The best combination from both performance and legal view is probable EN 
55032 Class A and EN 61000-6-2.


You might also apply just for EN 55032 and EN 55024 to obtain 
presumption of conformity and CE-mark and take a higher of field problems.




Gert Gremmen

HAS Consultant RED and EMC at European Commission.


On 24-5-2018 7:01, itl-emc user group wrote:


An industrial printer has been tested to EN 55011: 2009 + A1: 2010 and 
EN 61000-6-2: 2005 + AC: 2006 (latest EMCD OJ).


Another industrial printer has been tested to EN 61000-6-4: 2007 + A1: 
2011 and EN 61000-6-2: 2005 + AC: 2006 (latest EMCD OJ).


The printers are used in an industrial environment only.

Any opinions as to whether or not CISPR 32 is relevant as well.

Thanks in advance to any responses.

*Regards,***

*David Shidlowsky***| Technical Reviewer

*Address*1 Bat-Sheva St. LOD 7120101 Israel

*Tel*972-8-9186113*Fax* 972-8-9153101

*Mail*: dav...@itlglobal.org 
<mailto:dav...@itlglobal.org>/dav...@itl.co.il 
<mailto:dav...@itl.co.il>/e...@itl.co.il *Web* www.itlglobal.org 
<http://www.itlglobal.org>


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Re: [PSES] Radio modem - RED?

[Gert Gremmen / Ce-test]

If i do understand your question: 
That is why you need a technical file, several of the radio test cannot be 
applied to a modem, so it is exempted for technical reasons. It will need to 
operate while testing your system, and also during radio EMC tests. Your risk 
analysis will show what are your possibilities. And yes, it applies for RED, as 
a component in a radio (system).

Gert Gremmen 

Verstuurd vanaf mijn iPhone

> Op 27 apr. 2018 om 13:59 heeft Charlie Blackham 
> <char...@sulisconsultants.com> het volgende geschreven:
> 
> Amund
>  
> Can you provide some more information on what the “radio modem” is and what 
> the system is
>  
> Regards
> Charlie
>  
> Charlie Blackham
> Sulis Consultants Ltd
> Tel: +44 (0)7946 624317
> Web: www.sulisconsultants.com
> Registered in England and Wales, number 05466247
>  
> From: Amund Westin <am...@westin-emission.no> 
> Sent: 27 April 2018 05:38
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: [PSES] Radio modem - RED?
>  
> In a radio system, the will be several devices as the antenna, amplifiers, 
> frequency tuners, splitters and at the end a modem.
> A modem, which will be placed deep in the block chain of the radio system, 
> does it apply for RED? It’s not connected directly to an antenna and not 
> transmitting / receiving on the system frequency.
> RED guide Chapter 1.6.3.6 mentions different items that is connected to an 
> antenna, but the modem is not, it is placed further into the system.
> But if RED apply, how can you test according to a “radio system” RED standard 
> when your modem is not transmitting on that system frequency?
>  
>  
> Best regards
> Amund
>  
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Re: [PSES] EN 55032 Testing on Wired Network Port

[Gert Gremmen; ce-test]

EMC testing is like speeding by car. Did you ever try convince an 
officer that you drove too fast for only a few minutes by year if caught 
over-speeding?  And what did he say ?


Ports do not need testing only if inoperable at all. And even than, from 
a technical point of view it may generate interference. In my opinion, 
testing requirements end completely when a port is not accessible to the 
end-user.


And the criterion is not _troublesome_ emissions, the requirement is 
_over-the-limit_ emissions.


Like speeding by car, driving beyond speed-limits does not need to be 
troublesome (by the absence of other cars for example, or by night). 
Nevertheless, any speeding limit is enforced even if not troublesome.


But at the end, it is the manufacturer who decides if creating emissions 
over the limit is acceptable or not. But do not complain if you get caught.



Gert Gremmen


On 24-4-2018 12:52, John Woodgate wrote:


 Do you even need to justify not testing,if it doesn't produces 
troublesome emissions? The only justification I can see might be that 
it is used only for periods of a few minutes a few times a year.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2018-04-24 11:18, itl-emc user group wrote:


A device has a wired network port used for de-bugging only.

The port is not used during normal operation of the device.

Any opinions on whether or not this port should be tested?

*Regards,***

*David Shidlowsky***| Technical Reviewer

*Address*1 Bat-Sheva St. LOD 7120101 Israel

*Tel*972-8-9186113*Fax* 972-8-9153101

*Mail*: dav...@itlglobal.org <mailto:dav...@itlglobal.org>

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Re: [PSES] Medical device risk assessment - faulty chargers

[Gert Gremmen; ce-test]

Life is consist of risk assessments!

If you cross a road, you quickly assess the risk of safely getting to 
the other side.


What you call a scientific method, is a risk assessment based on 
physical hypotheses , but the hypothesis might be wrong tomorrow, or in 
another place. But the chance of getting bitten is that low that you can 
get away with it : Risk assessment.


What we call risk assessment in medical product safety evaluation (and 
now also in LVD and other EC directives to come), is a formal method of 
ranking the risks (visualize FMEA here). Seeing them ordered and (though 
arbitrarily quantizized) allows one to compare to earlier versions of 
the product, helps placing a red line (do not cross that risk level)and 
helps in prioritizing risks.


Risk analysis is not scientific, indeed, it is a method to get hand on 
dangers of all kind of nature.


“Injuries to a living organism can be produced only by some energy 
interchange.”


Not all risk are of energetic nature:

Trivial example:  An interpretation fault risk happened in medical 
staff  paging system where both S and 5 were used to indicate the 
location of  emergencies in numbered corridors in a hospital. At that 
time 8-segment displays were common and renumbering the corridors by not 
using the S was a proposed solution. Risk assessment allowed us to find 
other hazards that might happen if a single segment was defective. 6 
versus b, 7 versus 1. The manufacturer decided that a 7-segment display 
was not the way to go.





Gert Gremmen



On 17-4-2018 1:22, Richard Nute wrote:


… how do you test *objectively* the adequacy of a symbol like the ! in 
a triangle…


The ! is not a safeguard.  Ultimately, the safeguard is some 
prescribed behavior on the part of a person.  The manufacturer of 
equipment can only describe the desired behavior.   The behavior can 
be tested to determine its effectiveness at safeguarding a body.  
However, the manufacturer cannot enforce a behavior.  Hence, a 
behavior safeguard is not necessarily an effective safeguard as is a 
physical safeguard.


… requirement for two layers of plastic film or insulation, in case 
one layer had a pinhole…


The pinhole was a hypothesis.  We totally ignored the fact that the 
insulation system is comprised of solid-air-solid (a thin layer of air 
separated the two layers).  The voltage divides inversely according to 
the capacitance.  Most of the voltage appears across the thin layer of 
air, not the two solid insulations.  So, we built in a failure 
mechanism to thwart a hypothesis.  Fortunately, the system has 
sufficent electric strength and the transient voltages at the electric 
strength voltage are years apart and of short duration that breakdown 
during equipment lifetime is not likely.


Product safety is rife with “conventional wisdom.”

Rich

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Re: [PSES] Medical device risk assessment - faulty chargers

[Gert Gremmen; ce-test]

I believe that charging a device within the MDD when connected to a 
patient is not normal use but to be classified (foreseeable) misuse.


Some remarks:

1. An apparatus that requires charging is most often meant to be used 
while not connected to the mains; why use a battery otherwise. Most 
equipment i have encountered using 25 years of product testing included 
a clear disabling mechanism while charging.


2. Often equipment that is not designed to meet the double MOPP/MOOP 
requirements (mostly for cost reasons) uses a battery to meet 
insulation/touch current requirements "the easy way". Connecting the 
device to a charger will immediately make the device unsafe.


3. I have not yet seen a medically approved USB charger, and most 
approved IT chargers do not meet the (constructional) reinforced 
insulation requirements between primary and secondary to be  used in ME 
equipment or leakage/touch  currents.


Gert Gremmen


On 14-4-2018 0:59, Leo Eisner wrote:

Nick,

This is an in process interpretation that is being currently developed 
by IEC TC62 SC 62A WG14 and was supposed to be discussed today in our 
London meeting but the submitter of the request for interpretation was 
not able to make the meeting today.  Part of the draft interpretation 
does mention there are fake chargers out there and they definitely 
will not meet Dielectric, spacings, and leakage current limits.  Also, 
they can reboot computers connected to the network, The submitter of 
the request says: "It has been noted in health care facilities 
recently that certain ME Equipment have rebooted, close down 
prematurely, changed alarm setting, change patient setting due to 
interconnection of other electrical equipment intended to be charged 
or powered.”


USB is not the wisest choice for power as you also have data issues 
potentially depending on the Medical device and it’s connection.  The 
best solution I have seen is 1) turn off or disable patient circuitry 
when connected to USB.

2) disable the software the controls the device.
3) provide additional Reinforced or Double Insulation 2 Means of 
Patient Protection (dielectric and spacings requirements)
4) Do a thorough Risk Analysis per ISO 14971:2007 (that is what IEC 
60601-1:2005 + A1:2012) or in the EU use EN 14971:2012 with the 
associated EN 60601-1, ed. 3.1


Hope this helps,
photo   Leonard (Leo) Eisner, P.E.
Principal Consultant, Eisner Safety Consultants
Phone: (503) 244-6151 <tel:%28503%29%20244-6151>
Mobile: (503) 709-8328 <tel:%28503%29%20709-8328>
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On Apr 11, 2018, at 8:12 AM, Mike Sherman <msherma...@comcast.net 
<mailto:msherma...@comcast.net>> wrote:


There are a number of documented cases of counterfeit or knock off 
Apple USB chargers that do not pass dielectric testing; a couple have 
been suspected in shock related deaths. This is an unstated 
background to this discussion.


Mike Sherman
Graco Inc.


*From: *"Ari Honkala" <ari.honk...@sesko.fi 
<mailto:ari.honk...@sesko.fi>>
*To: *"EMC-PSTC" <EMC-PSTC@LISTSERV.IEEE.ORG 
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>

*Sent: *Wednesday, April 11, 2018 5:20:35 AM
*Subject: *Re: [PSES] Medical device risk assessment - faulty chargers

My first thought: what has the origin of the charger has to do with 
it being potentially faulty? Any device may broke; that's why there 
are requirements for single fault condition.


with best regards,

Ari Honkala

-Original Message-
From: Nick Williams [mailto:nick_willi...@conformance.co.uk]
Sent: tiistai 10. huhtikuuta 2018 19:21
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Medical device risk assessment - faulty chargers

Colleagues,

E

Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

[Gert Gremmen; ce-test]

The LVD does NOT apply.

For elektrical safety and EMC the RED will use it's proper list of 
harmonised standards.


As says:

Art 1.4

/Radio equipment//falling within//the scope of this Directive//shall 
_*not*_ be subject//to Directive//2014/35/EU,//except as//set out in 
point (a) of Article 3(1) of this Directive. /


Art 3.1(a) says :

/the protection of health//and safety of persons//and of 
domestic//animals//and the protection//of proper//ty, 
including//the//objectives//with respect//to safety requirements//set 
out in Directive//2014/35/EU,//but with no voltage limit applying; /


One cannot legally apply a directive and say at the same time that some 
part of it is not applicable. It's the _objectives as set-out in the 
LV-directive_, that are an essential requirement to the RED, not the 
directive itself. I agree that such IS somewhat obscurantist wording.


The fact that no standards for electrical safety have been published yet 
does NOT help in good understanding the directives wording, of course.


Gert Gremmen
On 4-4-2018 17:44, John Woodgate wrote:
Yes, well, it's typical obscurantist wording. The LVD DOES apply, but 
without its low-voltage limit. That is what Article 3 1 (a) says, 
quite explicitly.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2018-04-04 16:33, Charlie Blackham wrote:


The LVD is cited, but the RED is the applicable Directive, as per 
article Art. 1.4 of the RED which states


“Radio equipment falling within the scope of this Directive shall not 
be subject to Directive 2014/35/EU (LVD), except as set out in point 
(a) of Article 3(1) of this Directive.”


In due course, all product EMF standards will be harmonised under RED

Regards

Charlie

*Charlie Blackham*

*Sulis Consultants Ltd*

*Tel: +44 (0)7946 624317*

*Web: **www.sulisconsultants.com* 
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>


Registered in England and Wales, number 05466247

*From:*John Woodgate <j...@woodjohn.uk>
*Sent:* 04 April 2018 16:05
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] EU Harmonized RF Exposure Standards per RED for 
13.56 MHz RFID



Yes, I cited the wrong Directive. Wrong citations are quite common, 
due to the Commission and the SMBs citing the largely meaningless 
'/nn' numbers instead of the titles of the Directives.


. The actual situation is that the Directive concerned is the Low 
Voltage Directive. The involvement of the RED is ONLY Article 3 1 
(a), which applies the LVD without its low-voltage limit. Nothing 
else of the RED is relevant.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK

On 2018-04-04 14:51, Michael Derby wrote:

John,

I think the physical agents Directive is concerned with the
workplace, not with products.

For assessment of RF Exposure risk/safety from products, the RED
is indeed the correct Directive and it would be covered in
Article 3.1a.

Thanks,

Michael.

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

Certification Resource for the Wireless Industry

Web: www.acbcert.com <http://www.acbcert.com/>

e-mail: micha...@acbcert.com <mailto:micha...@acbcert.com>

Mobile phone:   (+44) 7939 880829   (UK area code)

Corporate office phone: USA:   (+1) 703 847 4700

*From:*John Woodgate [mailto:j...@woodjohn.uk]
*Sent:* 04 April 2018 14:38
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Subject:* Re: [PSES] EU Harmonized RF Exposure Standards per RED
for 13.56 MHz RFID

SECOND RESPONSE

I should have mentioned that exposure standards have nothing to
do with RED but are relevant to a different Directive:

DIRECTIVE 2013/35/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 26 June 2013
on the minimum health and safety requirements regarding the
exposure of workers to the risks
arising from physical agents (electromagnetic fields) (20th
individual Directive within the meaning
of Article 16(1) of Directive 89/391/EEC) and repealing Directive
2004/40/EC


John Woodgate OOO-Own Opinions Only

J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>

Rayleigh, Essex UK

On 2018-04-04 13:38, Grace Lin wrote:

Dear Members,

Is there any harmonized standards applicable to 13.56 MHz
RFID devices?

The following four standards are listed in the latest
published list standards (March 9, 2018).  It seems there is
no one applicable to a 13.56 MHz RFID device.

EN 50360:2017 Product standard to demonstrate the compliance
of wireless communication devices, with the basic
restrictions and exposure limit values related to human

Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

[Gert Gremmen; ce-test]

As LVD (2014/35) is not applicable for Radio devices and so RFID, this 
standard is set up to be harmonized


under the RED. Be it as an Electrical Safety Standard under the RED. 
Look at the provided link.



Gert Gremmen


On 4-4-2018 15:37, John Woodgate wrote:

SECOND RESPONSE

I should have mentioned that exposure standards have nothing to do 
with RED but are relevant to a different Directive:


DIRECTIVE 2013/35/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 26 June 2013
on the minimum health and safety requirements regarding the exposure 
of workers to the risks
arising from physical agents (electromagnetic fields) (20th individual 
Directive within the meaning
of Article 16(1) of Directive 89/391/EEC) and repealing Directive 
2004/40/EC

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2018-04-04 13:38, Grace Lin wrote:

Dear Members,

Is there any harmonized standards applicable to 13.56 MHz RFID devices?

The following four standards are listed in the latest published list 
standards (March 9, 2018).  It seems there is no one applicable to a 
13.56 MHz RFID device.



EN 50360:2017 Product standard to demonstrate the compliance of 
wireless communication devices, with the basic restrictions and 
exposure limit values related to human exposure to electromagnetic 
fields in the frequency range from 300 MHz to 6 GHz: devices used 
next to the ear


EN 50385:2017 Product standard to demonstrate the compliance of base 
station equipment with radiofrequency electromagnetic field exposure 
limits (110 MHz — 100 GHz), when placed on the market


EN 50401:2017 Product standard to demonstrate the compliance of base 
station equipment with radiofrequency electromagnetic field exposure 
limits (110 MHz — 100 GHz), when put into service


EN 50566:2017 Product standard to demonstrate the compliance of 
wireless communication devices with the basic restrictions and 
exposure limit values related to human exposure to electromagnetic 
fields in the frequency range from 30 MHz to 6 GHz: hand-held and 
body mounted devices in close proximity to the human body



Thank you very much and I look forward to hearing from you.

Best regards,
Grace Lin
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Re: [PSES] EMC tests called up in Safety standards

[Gert Gremmen; ce-test]

The EMC tests as called out in 60335  are safety tests, contrary to 
those called out under the EMCD that are functional tests only. For 
Europe , one can discuss about the necessity of those tests, as the 
EMCD  requires testing in all operating modes including OFF or standby 
and  as long as one can prove that  an apparatus remains functional, it 
also could be considered safe. I have not seen many examples of a 
compliant functional apparatus that has become unsafe during an immunity 
test, but cannot exclude that this may happen either. Hence this test in 
60335, that might also come into view during the required risk analysis 
as called out in the new LVD. For Europe only, of course.


The difference between functional and safety related EMC is an evolving 
discussion, lately triggered by accidents with hybrid and autonomous 
driving cars.


Gert Gremmen


On 20-3-2018 10:27, James Pawson (U3C) wrote:


Hello experts,

I note that EN 60335-1 (household and similar appliances) specifically 
calls up EMC immunity tests in clause 19.11.4 where the controls for 
the EUT are set in the “off position” and a set of immunity tests are 
applied. For something that controls a heating element, I can see why 
this would be a concern.


A couple of questions / thoughts:

  * It sounds like this at least doubles the amount of immunity
testing required – one with the EUT “on” and one with it “off”.
Would that be how you read this?
  * Are there any other safety standards that explicitly call up EMC
tests within them like this one does? This is the first one I’ve
come across where this is the case but I’m not very familiar with
safety standards in general.

Thanks and all the best,

James

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Re: [PSES] Field probe calibration

[Gert Gremmen; ce-test]

IMHO all probes are calibrated under far field conditions.

In general: Using probes in the proximity (< lambda) of anything 
conductive (including ground planes at 10 cm and including EUT) makes 
the measurement data useless.


As James correctly states, the construction of the probe makes this 
effect different per type of probe, be it the construction, the size of 
battery or electronics on board or the lead (fiber or copper) , as long 
a other conductors are in proximity the read out has no relation to 
calibration data anymore.


Using a probe near a ground plane, such as usual in automotive test set 
ups, indeed says not much about the test level of the EUT.



Repeating this test under far field conditions, preferable on an antenna 
calibration facility, might give you much better results. (not that you 
are allowed to generate this much of power on air ;<)


Gert Gremmen


On 4-3-2018 11:06, James Pawson (U3C) wrote:


Hi David,

An interesting set of results! I’m going to ask some questions that 
I’m sure you’ve already considered so please bear with me being 
Captain B. Obvious.


Do your field probes use frequency correction? I’m not familiar with a 
wide range of probes but my Narda PMM field probe has an internal 
calibration table; you tell it what the field frequency you are 
applying is and it makes the appropriate correction. However, looking 
at the typical correction data from the manual (see PDF page 12 of 
this doc: 
https://www.emctest.it/public/pages/strumentazione/elenco/Narda/EP%20600/Manuali/EP600-EP601EN-90302-2.02.pdf) 
it doesn’t look like a large difference.


Is there a difference in the probe construction between the probes 
used? Some probes like the Narda one above have two antenna per axis 
whereas ones like this Amplifier Research probe - 
https://www.arworld.us/html/18200.asp?id=636 only have one antenna per 
axis. Perhaps the proximity of copper plate makes a difference.


On the subject of copper plate, what are the differences without this 
present? What are the dimensions of it and are they significant at the 
frequencies selected?


Have you acquired just spot readings or a full frequency sweep? There 
may be some patterns in the frequency sweep data that give you more of 
a clue as to what’s happening.


An interesting puzzle and I look forward to hearing about your results 
further!


All the best

James

*From:*Schaefer, David [mailto:dschae...@tuvam.com]
*Sent:* 04 March 2018 05:22
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] Field probe calibration

I took data with 4 field probes, 3 different models. All calibrated. 
Two calibrations by the manufacturer, two by a reputable cal house.


200-1000 MHz data, 10 MHz step size, 60 V/m level. I recorded the 
forward power, and all equipment and software in the setup was the 
same, barring only the measuring field probe and associated probe 
factors. Composite values only. No 3-axis data as I don’t have 3-axis 
calibration data for all probes. Probes were 10 cm above a copper 
bench, DRG antenna 90 from the bench.


The results are not encouraging. The tables below show the results in 
watts of forward power for select frequencies.


Antenna Horizontal – values in Watts



Probe 1



Probe 2



Probe 3



Probe 4



Max-Min(Watts)

200 MHz



85.17



144.4



135.9



97.75



59.23

220 MHz



92.81



171.6



157.4



113.5



78.79

500 MHz



21.7



34.93



28.58



26.94



13.23

900 MHz



25.57



37.25



25.6



32.42



11.68

Antenna Vertical – values in Watts



Probe 1



Probe 2



Probe 3



Probe 4



Max-Min(Watts)

200 MHz



18.94



25.12



22.55



18.82



6.3

330 MHz



34.1



40.69



46.29



39.41



12.19

780 MHz



35.52



53.03



29.87



32.83



23.16

930 MHz



56.63



47.01



64.26



107.7



60.69

There are trends in the data. Probe 1 was usually the lowest. Probe 2 
was usually the highest, rarely the lowest.


If you want to talk field strength effects this will mean, depending 
on the probe, you could have an E-field 40% higher between two 
‘identical’ calibrations.  The large variance between which probe was 
highest or lowest based on freq. is troubling, as is the clear 
difference between horizontal and vertical. I took additional data 
with two probes of the same model rotated around a center axis. I 
don’t have that all compiled, but just comparing one probe against 
itself, laying on the left, right, and bottom sides, results in up 20% 
difference in required power.


I have not read IEEE 519, but plan to soon. So my question to this 
group - do you

Re: [PSES] Insulation resistance test

[ce-test, qualified testing bv, Gert Gremmen]

As far as I understand, this requirement was needed in the time that insulation 
materials 

might have hygroscopic properties. Insulation materials as wood were common in 
the past.

If they were not suitably treated, in humid circumstances insulation might drop 
to unacceptable levels.

 

 

Gert Gremmen

ce-test qualified testing

((partially) retired in France)

 

From: John Woodgate [mailto:j...@woodjohn.uk] 
Sent: Monday 19 February 2018 10:46
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Insulation resistance test

 

The flash test is necessary because there are high-voltage pulses on the 
electricity supply caused by switching operations and distant lightning. It is 
very likely that a product that fails the insulation resistance test would fail 
the high-voltage test as well.  But it is not inevitable; a 1.8 megohm 
insulation resistance passes 1.67 mA at 3 kV. 

As I said, it would be most unusual for a non-faulty modern product to show an 
insulation resistance as low as 1.8 megohms (if discharge resistors are 
disconnected).

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-02-19 09:30, Scott Xe wrote:

John,

 

I almost forgot the Megger gear that I tried it once in the lab when I studied 
radio engineering.  Thereafter I am using battery-operated tester and now more 
and more multi-purpose testers including it into one unit.

 

The main reason why I raised this query is that the flash test gives harsher 
test on safety strength than insulation resistance test.  The debate is in 
safety standards it still requires it but a lot of young engineers consider 
waste time if flash test is included.  Why do we focus on flash test?  
Probably, it is a very old test and still remain in many safety standards.

 

Regards,

 

Scott

 

From: John Woodgate  <mailto:j...@woodjohn.uk> <j...@woodjohn.uk>
Date: Monday, 19 February 2018 at 4:22 PM
To: Scott Xe  <mailto:scott...@gmail.com> <scott...@gmail.com>,  
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> <EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Insulation resistance test

 

The test is very old, and pre-dates the high-voltage test by very many years. 
You mentioned 'Megger' in your other post, yes, that was how it was done. (A 
Megger (brand name) was/is a type of magneto with an ohmmeter attached. The 
stable output voltage required for the ohmmeter is achieved by a mechanical 
governor, which limits the armature speed however fast you turn the handle.) 

The test might not be totally irrelevant for modern electronic equipment, but 
the requirements in most standards are certainly in need of revision. These 
requirements are for a minimum insulation resistance of 1 or 2 megohms. A 
modern piece of electronic equipment typically has a resistance of hundreds of 
megohms (unless condensation occurs), so a measured value of  a few megohms  
shows that something is in fact seriously wrong. I have raised this point in 
TC108 before, but no-one was willing to take action. Tradition, you know. 

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-02-19 05:45, Scott Xe wrote:

Insulation resistance test is one of most common safety tests nowadays: Flash 
test, earth continuity test, leakage current test and insulation resistance 
test.  Can someone share the history of this teat to use DC and 500 V.  The 
products are working on AC and test voltage is higher than normal operating 
voltage but much lower than the flash test.  It is a trend to skip this test on 
production line.  What are the distinct benefits for this test?

 

Thanks and regards,

 

Scott

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Re: [PSES] RED DoC and LVD

[Gert Gremmen]

I do not think that the spirit has any legal value here. My experiences in

these kind of cases is that judges read the letter and not the spirit.

 

If the letter gives no clear legal solution, the spirit may help.

But the letter is quite clear here.

 

The only unclear part is the use of except in article 1.4, that can be 
interpreted twofold:

IMHO it should read  as “other than” or  “apart from” and not as  “exception 
to” .  (see Merriam-webster)

In this latter  case it could mean that in some cases the directive IS 
applicable ….. 

 

The final wordings of 1.4 :  “this directive” , might also give some doubt to 
as what directive actually is referred to: the LVD or the RED.

 

These directive are –as stipulated before in this thread- clearly not written 
by a legal person…

 

 

 

 

Gert Gremmen

 

 

Van: John Woodgate [mailto:jmw1...@btinternet.com] 
Verzonden: maandag 7 augustus 2017 20:54
Aan: 'Gert Gremmen'; EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: RE: [PSES] RED DoC and LVD

 

I don’t think that is helpful. Agreed that the ‘Whereas’ are not legalistically 
part of the Directive, that doesn’t mean that they can be disregarded. They 
embody the reasoning underlying the Directive. In English legal idiom, they 
contain the ‘spirit’ of the Directive, while the Directive itself is the 
‘letter’. Clashing with the ‘spirit’ is often considered more serious that 
clashing with the ‘letter’.

 

With best wishes DESIGN IT IN! OOO – Own Opinions Only

 <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and 
Associates Rayleigh England

 

Sylvae in aeternum manent.

 

From: Gert Gremmen [mailto:g.grem...@cetest.nl] 
Sent: 07 August 2017 19:21
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RED DoC and LVD

 

The numbered Whereas clauses are NOT part of the directive.

The actual text of the directive starts after the stipulation

HAVE ADOPTED THIS DIRECTIVE:  , just after consideration clause number (75) and 
just before article 1:

 

The text before this phrase therefore cannot be part of it, including clause 7. 

. 

 

Gert  Gremmen

 

 

 

Van: John Woodgate [mailto:jmw1...@btinternet.com] 
Verzonden: vrijdag 4 augustus 2017 13:00
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] RED DoC and LVD

 

You have my sympathy regarding the problems with language, worth 0.001 Euro.  
Be thankful that neither mediaeval French or Latin expressions are used.

 

Yes, you need 1 firm, so that the bean counters can calculate the average 
weight per firm, and 0/0 causes their computers to crash.

 

With best wishes DESIGN IT IN! OOO – Own Opinions Only

 <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and 
Associates Rayleigh England

 

Sylvae in aeternum manent.

 

From: Piotr Galka [mailto:piotr.ga...@micromade.pl] 
Sent: 04 August 2017 11:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RED DoC and LVD

 

John,

If I knew that I would start my discussion not from 1.4 and 3.1(a) but from 
(7), 1.4 and 3.1(a) what gives more relations to consider :)

I am reading directives since 2004 when we joined EU. Till now I always assumed 
that everything before Article 1 is not important. Specially I remember in WEEE 
I think (may be in RoHS) that some point before Art 1 said that it is very 
important to not load too much small firms which was in total opposition with 
the rest of directive.

For example we had a control and they found a cap with compressed air. We use 
about one per year but since then 4 times a year we have to send a report in 
which from time to time we report 1 such cap. Till now, as I know, we don't 
need to report these four sheets of paper used for it :)
Our products (access control system) are intended to be installed and work for 
years. So after 2006 when we had to count how many kg of our products we got 
back as used-on for many years we had 0kg/year. We had to have signed agreement 
with recycling firm with recycling capabilities enough for recycling what we 
got back. My understanding was that to recycle 0 kg I need 0 firms. Now (after 
control) we know that to recycle 0kg you need 1 recycling firm :(

Regards
Piotr

W dniu 2017-08-03 o 20:37, John Woodgate pisze:

That’s not quite right. In the same way that English has 3 words for 
everything, it has a minimum of 3 meanings for any word. Some have hundreds 
(‘set’ and ‘bar’). 

 

‘Whereas’ can simply mean ‘but’. However, in Directives, it has a legal 
meaning, which is rather stronger that your translated circumlocution. I 
suppose a short equivalent would be ‘Taking full account of these relevant 
issues, …’. In legal terms, such issues could be very significant indeed, such 
as ‘Whereas such serious crimes should be punished by long-term imprisonment,…’

 

What this means is that a statement in the ‘Whereas’ is a full part of the 
Directive, not a sort of ‘note’.

 

With best wishes DESIGN IT IN! OOO – Own Opinions Only

 <http://www.jmwa.demon.co.uk/> ww

Re: [PSES] RED DoC and LVD

[Gert Gremmen]

The numbered Whereas clauses are NOT part of the directive.

The actual text of the directive starts after the stipulation

HAVE ADOPTED THIS DIRECTIVE:  , just after consideration clause number (75) and 
just before article 1:

 

The text before this phrase therefore cannot be part of it, including clause 7. 

. 

 

Gert  Gremmen

 

 

 

Van: John Woodgate [mailto:jmw1...@btinternet.com] 
Verzonden: vrijdag 4 augustus 2017 13:00
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] RED DoC and LVD

 

You have my sympathy regarding the problems with language, worth 0.001 Euro.  
Be thankful that neither mediaeval French or Latin expressions are used.

 

Yes, you need 1 firm, so that the bean counters can calculate the average 
weight per firm, and 0/0 causes their computers to crash.

 

With best wishes DESIGN IT IN! OOO – Own Opinions Only

 <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and 
Associates Rayleigh England

 

Sylvae in aeternum manent.

 

From: Piotr Galka [mailto:piotr.ga...@micromade.pl] 
Sent: 04 August 2017 11:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RED DoC and LVD

 

John,

If I knew that I would start my discussion not from 1.4 and 3.1(a) but from 
(7), 1.4 and 3.1(a) what gives more relations to consider :)

I am reading directives since 2004 when we joined EU. Till now I always assumed 
that everything before Article 1 is not important. Specially I remember in WEEE 
I think (may be in RoHS) that some point before Art 1 said that it is very 
important to not load too much small firms which was in total opposition with 
the rest of directive.

For example we had a control and they found a cap with compressed air. We use 
about one per year but since then 4 times a year we have to send a report in 
which from time to time we report 1 such cap. Till now, as I know, we don't 
need to report these four sheets of paper used for it :)
Our products (access control system) are intended to be installed and work for 
years. So after 2006 when we had to count how many kg of our products we got 
back as used-on for many years we had 0kg/year. We had to have signed agreement 
with recycling firm with recycling capabilities enough for recycling what we 
got back. My understanding was that to recycle 0 kg I need 0 firms. Now (after 
control) we know that to recycle 0kg you need 1 recycling firm :(

Regards
Piotr



W dniu 2017-08-03 o 20:37, John Woodgate pisze:

That’s not quite right. In the same way that English has 3 words for 
everything, it has a minimum of 3 meanings for any word. Some have hundreds 
(‘set’ and ‘bar’). 

 

‘Whereas’ can simply mean ‘but’. However, in Directives, it has a legal 
meaning, which is rather stronger that your translated circumlocution. I 
suppose a short equivalent would be ‘Taking full account of these relevant 
issues, …’. In legal terms, such issues could be very significant indeed, such 
as ‘Whereas such serious crimes should be punished by long-term imprisonment,…’

 

What this means is that a statement in the ‘Whereas’ is a full part of the 
Directive, not a sort of ‘note’.

 

With best wishes DESIGN IT IN! OOO – Own Opinions Only

 <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and 
Associates Rayleigh England

 

Sylvae in aeternum manent.

 

From: Piotr Galka [mailto:piotr.ga...@micromade.pl] 
Sent: 03 August 2017 16:28
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RED DoC and LVD

 

I think I don't feel 'Whereas' precisely.
In Polish directives it was replaced with 7 words: "but also hawing in 
attention, what follows:"
I feel it as "we have it in attention, and only that - no more" so I called it 
'wishful thinking'.

Piotr Gałka
MicroMade Gałka i Drożdż sp.j
Gdańsk
Polska

W dniu 2017-08-03 o 15:35, John Woodgate pisze:

 

 

With best wishes DESIGN IT IN! OOO – Own Opinions Only

 <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and 
Associates Rayleigh England

 

Sylvae in aeternum manent.

 

From: Piotr Galka [mailto:piotr.ga...@micromade.pl] 
Sent: 03 August 2017 14:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RED DoC and LVD

 

John,

The full text you can find in my first mail - still present at the end:

[JMW] Ah, well, I didn’t know to look there.

1,4.Radio equipment falling within the scope of this Directive shall not 
be subject to Directive 2014/35/EU, except as set out in point (a) of 
Article 3(1) of this Directive.

3,1. Radio equipment shall be constructed so as to ensure: (a) the 
protection of health and safety of persons and of domestic animals and 
the protection of property, including the objectives with respect to 
safety requirements set out in Directive 2014/35/EU, but with no voltage 
limit applying;

(7) seems more clear but As it is before Article 1 I understand it as a kind of 
wishful thinking set out before issuing the directive.

[JMW] No, the ‘Whereas’ are an important part of the

Re: [PSES] Chamber grounding [General Use]

[ce-test, qualified testing bv, Gert Gremmen]

>Yes, the building ground is likely to be noisy, unless you actually connect
directly >back to its earth spike

No signal, ground or supply is noisy. It is the designer that defines a
certain conductor to be clean, and references all other voltages (probably
to be filtered)  to that potential.
Inside a screened room, there is only ONE ground (reference potential), and
that is the conductive shell around the EUT (so the chamber wall itself). 

Electrical safety inside a room must be referenced to that potential, as
well as all signals measured inside. 
All cable screens are therefore connected to the conductive wall before
leaving. It is  fully irrelevant to what you connect  the outside of the
chamber , as the skin effect effectively separates all current on the
external surface from the internal surface. For extremely low frequencies,
wall thickness may be insufficient, and wall current on the external
surface can show up on the internal surface and create potential differences
on different parts of the internal wall (and possibly fields inside). The
only remedy is increasing wall thickness , dual walls,  increase
conductivity or apply a layer of  magnetic conductive shield (ferro metal Ur
> 1) .
One should prevent LF current to flow on the outside. Still it makes no
difference to what ground point you connect the room (just do not make 2
different connections).
One last problem may be the presence of LF magnetic fields on the outside,
they may create currents op to several amps on the outside surface, leading
to the problem sketched above.  (try connecting a 50-60Hz current clamp
around the metal tubing of your central heating and be surprised: the loops
in these tubes and the mains magnetic field easily creates  a few amps of
"thougth" ground faults)  .

Electrical safety at the outside of the room is obtained by simply
connecting the wall to the building's safety conductor.  

Gert

-Original Message-
From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Wednesday 19 July 2017 09:31
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Chamber grounding [General Use]

It's not my consensus! Yes, the building ground is likely to be noisy,
unless you actually connect directly back to its earth spike. Even then, the
wire you use is an inductor and may have noise induced in it. 

I am quite sure that BS 7671 and other Code standards do not recognize that
a screened room is outside their scopes. 

With best wishes DESIGN IT IN! OOO - Own Opinions Only www.jmwa.demon.co.uk
J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

-Original Message-
From: Price, Andrew (Leonardo, UK)
[mailto:andrew.p.pr...@leonardocompany.com]
Sent: 19 July 2017 07:16
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Chamber grounding [General Use]

Thanks all for the replies.

It seems that there is some divided opinion.

Some of the test houses I have spoken to state that they definitely ground
their chambers via ground spikes. This is to remove low frequency noise that
causes issues with the low frequency emc tests  that are required in
mil-std, def stan  and rtca/do-160.
One test house I spoke to stated that as a result of cost cutting an earth
spike was not fitted so earthing was taken to building ground, as a result
of this the test house has issues with low frequency noise.

The consensus of the forum is that a ground spike should not be required and
the building ground used should be enough.

This then probably raises the question of how good is the building ground?
Is there a requirement for this?
If there is noise on the building ground how can this be eliminated?

Regards
Andy



 Andrew Price
 Land & Naval Defence Electronics Division
 Prinicpal Environmental Engineer (EMC)

 Leonardo MW Ltd
 Sigma House, Christopher Martin Rd, Basildon SS14 3EL, UK
 Tel  EMC LAB : +44 (0)1268 883308
 Mobile: +44 (0)7507 854888
 
andrew.p.pr...@leonardocompany.com
 leonardocomapany.com
HELICOPTERS / AERONAUTICS / ELECTRONICS, DEFENCE AND SECURITY SYSTEMS /
SPACE

* Please consider the environment before printing this email.




Leonardo MW Ltd
Registered Office: Sigma House, Christopher Martin Road, Basildon, Essex
SS14 3EL A company registered in England & Wales.  Company no. 02426132

This email and any attachments are confidential to the intended recipient
and may also be privileged. If you are not the intended recipient please
delete it from your system and notify the sender.
You should not copy it or use it for any purpose nor disclose or distribute
its contents to any other person.


-

This message is from the IEEE Product Safety Engineering Society emc-pstc

Re: [PSES] Chamber grounding [General Use]

[ce-test, qualified testing bv, Gert Gremmen]

>I am quite sure that BS 7671 and other Code standards do not recognize that
a >screened room is outside their scopes

Of course they won't. But it is, technically.

Gert

-Original Message-
From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Wednesday 19 July 2017 09:31
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Chamber grounding [General Use]

It's not my consensus! Yes, the building ground is likely to be noisy,
unless you actually connect directly back to its earth spike. Even then, the
wire you use is an inductor and may have noise induced in it. 

I am quite sure that BS 7671 and other Code standards do not recognize that
a screened room is outside their scopes. 

With best wishes DESIGN IT IN! OOO - Own Opinions Only www.jmwa.demon.co.uk
J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

-Original Message-
From: Price, Andrew (Leonardo, UK)
[mailto:andrew.p.pr...@leonardocompany.com]
Sent: 19 July 2017 07:16
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Chamber grounding [General Use]

Thanks all for the replies.

It seems that there is some divided opinion.

Some of the test houses I have spoken to state that they definitely ground
their chambers via ground spikes. This is to remove low frequency noise that
causes issues with the low frequency emc tests  that are required in
mil-std, def stan  and rtca/do-160.
One test house I spoke to stated that as a result of cost cutting an earth
spike was not fitted so earthing was taken to building ground, as a result
of this the test house has issues with low frequency noise.

The consensus of the forum is that a ground spike should not be required and
the building ground used should be enough.

This then probably raises the question of how good is the building ground?
Is there a requirement for this?
If there is noise on the building ground how can this be eliminated?

Regards
Andy



 Andrew Price
 Land & Naval Defence Electronics Division
 Prinicpal Environmental Engineer (EMC)

 Leonardo MW Ltd
 Sigma House, Christopher Martin Rd, Basildon SS14 3EL, UK
 Tel  EMC LAB : +44 (0)1268 883308
 Mobile: +44 (0)7507 854888
 
andrew.p.pr...@leonardocompany.com
 leonardocomapany.com
HELICOPTERS / AERONAUTICS / ELECTRONICS, DEFENCE AND SECURITY SYSTEMS /
SPACE

* Please consider the environment before printing this email.




Leonardo MW Ltd
Registered Office: Sigma House, Christopher Martin Road, Basildon, Essex
SS14 3EL A company registered in England & Wales.  Company no. 02426132

This email and any attachments are confidential to the intended recipient
and may also be privileged. If you are not the intended recipient please
delete it from your system and notify the sender.
You should not copy it or use it for any purpose nor disclose or distribute
its contents to any other person.


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This 

Re: [PSES] Chamber grounding [General Use]

[ce-test, qualified testing bv, Gert Gremmen]

I agree that (national) legislation should play a role here,
but EMC chambers are NOT ordinary equipments, nor
part of a standard electrical installation.
I would not rely on electrical codes to create a safe work environment,
and have my personal opinions prevail.

We operate in a gray area, where safety is concerned.


So here good (low voltage) engineering practice suggests "permanent
connection"
and due to the specifically lethal character of the "high leakage current
device"
of the device, a second backup connection is not superfluous.

Gert


From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Tuesday 18 July 2017 21:09
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Chamber grounding [General Use]

I think the issue is far more about electrical safety than EMC. Of course
you are quite right about a Faraday cage not requiring an earth connection.
It's what happens if there is a high-current live mains to accessible metal
fault. The preferred technique depends on how such a fault is detected and
rendered harmless. National electrical codes have much to say about this,
and they don't all require the same solutions. That's why I advised the OP
to look at BS 7694, because that is what applies in Britain.


With best wishes DESIGN IT IN! OOO - Own Opinions Only
www.jmwa.demon.co.uk   J M Woodgate and
Associates Rayleigh England

Sylvae in aeternum manent.

From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: 18 July 2017 19:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Chamber grounding [General Use]

It's not so much that it needs filtering at the power frequency as it is
that that much line to ground capacitance is needed to provide 100 dB of
insertion loss down to 10 kHz (which is typical for chamber power filters).

Back to the original question -

I've had 3 and 10 meter chambers in different places over the years.  The
first chamber was built before I joined the company and the engineer worked
very hard to maintain a single point ground for the chamber.  I built a 10
meter chamber for the same company a number of years later and didn't worry
about a single point ground.  Both worked fine.  A Faraday Cage, once you
are talking high enough frequencies (and 10 kHz is high enough), doesn't
care if it is ungrounded, single point grounded or multi-point grounded.
The RF currents flow close enough to the surface that the shield is good.

Now, if you have a problem with 60 Hz power causing currents to flow through
the shield material you may have a different problem.  I've never had to
care about shielding effectiveness at 60 Hz, so skin effect hasn't been an
issue for me.  YMMV.

Ghery S. Pettit, NCE


From: Richard Nute [mailto:ri...@ieee.org] 
Sent: Tuesday, July 18, 2017 11:47 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Chamber grounding [General Use]


"But as soon as mains filters are mounted on the wall, one has to cope with
leakage currents (blind current) as large as 6 amp or more." 
6 amps!  At 230 volts, 50 Hz, Xc is 38.8 ohms.  Total C from line to earth
is 69.2 uF!  (Presumably the filter has an equal capacitance from neutral to
earth.)  Why does a chamber need so much filtering at mains frequency?

Rich


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Re: [PSES] Chamber grounding [General Use]

[Gert Gremmen]

As for the purpose of operation, EMC chambers need no grounding.
The shielding property happens by conduction of the shield material the
chamber is made from.

But as soon as mains filters are mounted on the wall, one has to cope with
leakage currents
(blind current) as large as 6 amp or more. This is definitely lethal on the
touch so I recommend a
grounding of 4-6mm2 copper in addition to the ground lead in the mains
connection.

I suggest leading both grounds to the building ground, as that is an
equipotential point, made for safety.

But again, an ungrounded chamber performs the same as a grounded one.

Gert Gremme


-Oorspronkelijk bericht-
Van: Price, Andrew (Leonardo, UK)
[mailto:andrew.p.pr...@leonardocompany.com] 
Verzonden: dinsdag 18 juli 2017 16:55
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] Chamber grounding [General Use]

Hi All

Which is the best to use?
Ground each EMC chamber via an earth spike or back to the transformer of the
supply to the building?
Which is best practice?

Regards
Andy



 Andrew Price
 Land & Naval Defence Electronics Division
 Prinicpal Environmental Engineer (EMC)

 Leonardo MW Ltd
 Sigma House, Christopher Martin Rd, Basildon SS14 3EL, UK
 Tel  EMC LAB : +44 (0)1268 883308
 Mobile: +44 (0)7507 854888
 
andrew.p.pr...@leonardocompany.com
 leonardocomapany.com
HELICOPTERS / AERONAUTICS / ELECTRONICS, DEFENCE AND SECURITY SYSTEMS /
SPACE

* Please consider the environment before printing this email.




Leonardo MW Ltd
Registered Office: Sigma House, Christopher Martin Road, Basildon, Essex
SS14 3EL A company registered in England & Wales.  Company no. 02426132

This email and any attachments are confidential to the intended recipient
and may also be privileged. If you are not the intended recipient please
delete it from your system and notify the sender.
You should not copy it or use it for any purpose nor disclose or distribute
its contents to any other person.


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Re: [PSES] USB dongle connector shield filtered grounding

[ce-test, qualified testing bv, Gert Gremmen]

I second that  Personal experience.

Often I give the advice to get rid of all these grounds and just create one 
full continuous ground plane

including DGND AGND SGND and so on. Then customer comes back and has read 
manufacturers recommendations for a chip and ignored my advice, only to fail 
again.

I wonder how the big chip manufacturers application guides are made up. 
Certainly not with EMI in mind.

Many times the performance of the system (bits or S/N ratio) also improves afte 
creating a ground plane.

 

There is one situation however, where separate grounds come into view. (rule of 
thumb) Once the ratio of biggest voltage/current in the  design exceeds 10^5. 
This happens normally only in power systems (stepper motors / smps / frequency 
regulated motor drives) or in extreme low signal processing ( uV / nA) systems. 
Care should be taken that both grounds actually become ONE for 
out-of-functional (=EMI) frequencies.

Once the signal comes in the EMI frequency range, other ways of discrimination 
between common mode interference currents and differential mode signal currents 
are necessary. (balanced signal twisted pairs, common mode coils, 
transformers).  

 

Gert Gremmen

 

 

From: Ken Wyatt [mailto:k...@emc-seminars.com] 
Sent: Wednesday 28 June 2017 22:03
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] USB dongle connector shield filtered grounding

 

Bill, thanks for the complement. One of my mentors, Dr. Tom Van Doren, of the 
University Missouri - Rolla, would say “the more different “ground” symbols he 
saw in a schematic, the more business he knew he would get”.

 

Ken


___

 

I'm here to help you succeed! Feel free to call or email with any questions 
related to EMC or EMI troubleshooting - at no obligation. I'm always happy to 
help!


Kenneth Wyatt
Wyatt Technical Services LLC

56 Aspen Dr.
Woodland Park, CO 80863


Phone: (719) 310-5418


Email Me! <mailto:k...@emc-seminars.com>  | Web Site 
<http://www.emc-seminars.com>  | Blog <http://design-4-emc.com/> 

The EMC Blog (EDN) <http://www.edn.com/blog/The-EMC-Blog> 
Subscribe to Newsletter 
<http://www.emc-seminars.com/Newsletter/Newsletter.html> 
Connect with me on LinkedIn <http://www.linkedin.com/in/kennethwyatt> 

 

On Jun 28, 2017, at 1:57 PM, Bill Stumpf <bstu...@dlsemc.com> wrote:

 

Truly outstanding analogies Ken, Ralph & Bill.  I too cringe every time I hear 
the term "ground" bandied about in EMI circles.  It's a widely misunderstood 
term that the non-initiated envision as some sort of EMI black hole that's by 
some means able to soak up all that excess RF energy.  I'm sure we all could 
tell some stories from the lab.   

 

 

Bill

 

 

From: Ken Wyatt [mailto:k...@emc-seminars.com] 
Sent: Wednesday, June 28, 2017 1:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] USB dongle connector shield filtered grounding

 

Like they say in some movies…”follow the money”. In the case of EMC issues, 
it’s usually “follow the current”. Both differential and common mode currents 
want to return to their sources in the most expedient (low-impedance) route. If 
designers fail to define a return path, invariably, some of that RF current 
radiates. Once the noise source(s) are identified, then what’s the return path? 
There will always be a return path…just not always the one you want.

 

Cheers, Ken


___

 

I'm here to help you succeed! Feel free to call or email with any questions 
related to EMC or EMI troubleshooting - at no obligation. I'm always happy to 
help!


Kenneth Wyatt
Wyatt Technical Services LLC

56 Aspen Dr.
Woodland Park, CO 80863


Phone: (719) 310-5418


 <mailto:k...@emc-seminars.com> Email Me! |  <http://www.emc-seminars.com/> Web 
Site |  <http://design-4-emc.com/> Blog

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 <http://www.emc-seminars.com/Newsletter/Newsletter.html> Subscribe to 
Newsletter
 <http://www.linkedin.com/in/kennethwyatt> Connect with me on LinkedIn

 

On Jun 28, 2017, at 11:35 AM, Ralph McDiarmid < 
<mailto:ralph.mcdiar...@schneider-electric.com> 
ralph.mcdiar...@schneider-electric.com> wrote:

 

Rather than 'ground', perhaps 'RF return' or 'counterpoise' might be better 
terms?

I think the thing that makes EMC mysterious is that the complete RF circuit is 
unseen and difficult to accurately define, given all the parasitic elements.  
The experience of 'inside' verses 'outside' the chassis envelope a prime 
example, something I encountered some years ago, but never fully understood.

Ralph McDiarmid
Product Compliance
Engineering
Solar Business
Schneider Electric


-Original Message-
From: Bill Owsley [ <mailto:00f5a03f18eb-dmarc-requ...@ieee.org> 
mailto:00f5a03f18eb-dmarc-requ...@ieee.org] 
Sent: Saturday, June 24, 2017 8:33 PM
To:  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 

Re: [PSES] RED Harmonised Standards

[ce-test, qualified testing bv, Gert Gremmen]

Yes, as now system "system" 

 is a multi-function apparatus it should comply with all applicable
standards

It should comply to EN 55012 (not CISPR12) and EN 301-489-1 or other subpart
of this series.

Note that the 301489-1 does not support Class A devices. This is especially
troublesome for IT devices, as Class A of EN 55022 is still very popular .
As soon as a wireless BT WiFi device is added, EN 301 489-1 comes into view.
And since everything goes wireless...

 

Gert Gremmen

 

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com] 
Sent: Wednesday 28 June 2017 23:06
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RED Harmonised Standards

 

If I insert a radio module into a system that is compliant to the RED and to
the latest 301 489 series, do I have to re-test the whole system towards the
301 489 series? 

 

The system already complies with other regular EMC standards (CISPR 12)
without the module. 

 

 

Sincerely, 

 

Dieter Paasche

Senior Product Developer, Electrical

CHRISTIE

809 Wellington Street North

Kitchener, ON N2G 4Y7

Phone: 519-744-8005 ext.7211

www.christiedigital.com <http://www.christiedigital.com/> 

 

This e-mail message (including attachments, if any) is confidential.  Any
unauthorized use, distribution or disclosure is prohibited.  If you have
received this e-mail message in error, please notify the sender by reply
e-mail or telephone and delete it and any attachments from your computer
system and records.

 

From: Gert Gremmen [mailto:g.grem...@cetest.nl] 
Sent: Wednesday, June 28, 2017 2:59 PM
To: EMC-PSTC@listserv.ieee.org
Subject: Re: [PSES] RED Harmonised Standards

 

As far as I understand:

 

Use EMCD HS for EM aspectsart 3.1 (No NB needed)  ; that includes the
301 489 series for EMC of auxiliary equipment  (intentionally left out of
RED should never have been on the RTTE list either as it was EMC)

Use LVD HS for electrical safety also art 3.1 (No NB Needed)

Use RED HS  for radio Art 3.2 (No NB needed) (radio properties  /  spurious
emissions: those are not EMI, but strictly harmonics and mixer products)

 

This ends the confusion there always was on EMC standards and LVD standards
in the RTTE list, 

 

>From the beginning one was supposed to use 3 directives for Radio products

 

There are still missing red standards, notably those for (GPS) Receivers,
here a NB is needed, but as there is no standard

available, what will the NB have to impose ?

 

Gert Gremmen

 

 

 

Van: Michael Derby [mailto:micha...@acbcert.com] 
Verzonden: woensdag 28 juni 2017 20:04
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] RED Harmonised Standards

 

I think they've been putting all their effort into getting the Article 3.2
standards onto the OJ as soon as they can (because those are the ones which
the manufacturer needs, to self declare without a Notified Body).

 

Most of the EN 301 489 standards are published or at least in a final draft;
so the manufacturer can use them and explain it in their risk assessment.
It may not be on the RED OJ, but that does not mandate the use of a Notified
Body.

 

 

Michael.

 

 

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com] 
Sent: 28 June 2017 16:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RED Harmonised Standards

 

 

Interesting. One additional question is I don't see any of the 301 489
series. Is this going to be published in the RED harmonized standards list,
as it is strictly speaking and EMC requirement, or is this part of the
article 3.1 b requirement:" an adequate level of electromagnetic
compatibility as set out in Directive 2014/30/EU.?"

The EMC directive only lists 301 489-1 and 301 489-34. 

 

 

 

Sincerely, 

 

Dieter Paasche

Senior Product Developer, Electrical

CHRISTIE

809 Wellington Street North

Kitchener, ON N2G 4Y7

Phone: 519-744-8005 ext.7211

www.christiedigital.com <http://www.christiedigital.com/> 

 

This e-mail message (including attachments, if any) is confidential.  Any
unauthorized use, distribution or disclosure is prohibited.  If you have
received this e-mail message in error, please notify the sender by reply
e-mail or telephone and delete it and any attachments from your computer
system and records.

 

From: Douglas Nix [mailto:d...@mac.com] 
Sent: Tuesday, June 27, 2017 2:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RED Harmonised Standards

 

Colleagues,

 

I just heard about a new Communication and list of Harmonised Standards
under the RED:

 

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2017.180.01
.0005.01.ENG
<http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2017.180.0
1.0005.01.ENG=OJ:C:2017:180:TOC> =OJ:C:2017:180:TOC

 

--

Doug Nix

d...@mac.com

-


This message is from the IEEE Product Safety Engineering Society emc-pstc
discussion list. To post a messag

Re: [PSES] RED Harmonised Standards

[Gert Gremmen]

As far as I understand:

 

Use EMCD HS for EM aspectsart 3.1 (No NB needed)  ; that includes the
301 489 series for EMC of auxiliary equipment  (intentionally left out of
RED should never have been on the RTTE list either as it was EMC)

Use LVD HS for electrical safety also art 3.1 (No NB Needed)

Use RED HS  for radio Art 3.2 (No NB needed) (radio properties  /  spurious
emissions: those are not EMI, but strictly harmonics and mixer products)

 

This ends the confusion there always was on EMC standards and LVD standards
in the RTTE list, 

 

>From the beginning one was supposed to use 3 directives for Radio products

 

There are still missing red standards, notably those for (GPS) Receivers,
here a NB is needed, but as there is no standard

available, what will the NB have to impose ?

 

Gert Gremmen

 

 

 

Van: Michael Derby [mailto:micha...@acbcert.com] 
Verzonden: woensdag 28 juni 2017 20:04
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] RED Harmonised Standards

 

I think they've been putting all their effort into getting the Article 3.2
standards onto the OJ as soon as they can (because those are the ones which
the manufacturer needs, to self declare without a Notified Body).

 

Most of the EN 301 489 standards are published or at least in a final draft;
so the manufacturer can use them and explain it in their risk assessment.
It may not be on the RED OJ, but that does not mandate the use of a Notified
Body.

 

 

Michael.

 

 

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com] 
Sent: 28 June 2017 16:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RED Harmonised Standards

 

 

Interesting. One additional question is I don't see any of the 301 489
series. Is this going to be published in the RED harmonized standards list,
as it is strictly speaking and EMC requirement, or is this part of the
article 3.1 b requirement:" an adequate level of electromagnetic
compatibility as set out in Directive 2014/30/EU.?"

The EMC directive only lists 301 489-1 and 301 489-34. 

 

 

 

Sincerely, 

 

Dieter Paasche

Senior Product Developer, Electrical

CHRISTIE

809 Wellington Street North

Kitchener, ON N2G 4Y7

Phone: 519-744-8005 ext.7211

www.christiedigital.com <http://www.christiedigital.com/> 

 

This e-mail message (including attachments, if any) is confidential.  Any
unauthorized use, distribution or disclosure is prohibited.  If you have
received this e-mail message in error, please notify the sender by reply
e-mail or telephone and delete it and any attachments from your computer
system and records.

 

From: Douglas Nix [mailto:d...@mac.com] 
Sent: Tuesday, June 27, 2017 2:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RED Harmonised Standards

 

Colleagues,

 

I just heard about a new Communication and list of Harmonised Standards
under the RED:

 

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2017.180.01
.0005.01.ENG
<http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2017.180.0
1.0005.01.ENG=OJ:C:2017:180:TOC> =OJ:C:2017:180:TOC

 

--

Doug Nix

d...@mac.com

-


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For policy 

Re: [PSES] Questions on IEC Standards Adaption

[ce-test, qualified testing bv, Gert Gremmen]

IEC -> EN  -> BS / NL /BE / DK / NF /  DIN / SE / EVS  etc

 

Most relevant changes are in between IEC to EN, in the form of Common / 
National Modifications

and the Annex to announce the ability to use in a respective directives. 
(CENELEC)

Then comes the local money machine of the  national standardization bodies 

to add a translated front page (and the new number) , and sometimes a local 
expert creates a fully translated version of the standard.

Normally you need not use a localised version, as it adds nothing to the 
product.

If you order a localised version often you get just the EN version (in one 
language only), a separate

front page and an adjusted bill (and the clause that in case of dispute, the EN 
version prevails… oh you did not buy that one, what a pity). Other countries my 
vary in price substantially. I think the British are the most expensive (now 
with a free, less than 2-years expiration time).

 

Not all national bodies operate that way. 

The Estonians deliver plain IEC/EN versions with a (for most of us ) cryptic 
Estonian frontpage at 25% of the UK price for example.  If you consider buying 
a product, buy the 2-user network version for a plain PDF version. Single user 
versions are a PITA for licensing rules and protection software.

 

Gert Gremmen

 

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Saturday 24 June 2017 16:12
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Questions on IEC Standards Adaption

 

In general, there are far too many detail differences to list. Some probably do 
not apply to your product, but it only needs one to apply to give you trouble. 
That is apart from larger differences, as explained below. But there are no 
all-embracing ‘general rules’ to predict what differences there are between the 
IEC and European versions of a standard

 

In Europe, CENELEC (for most electrical standards) takes the IEC standard and 
makes ‘Common Modifications’ and adds ‘Special National Differences’. It also 
‘translates’ the Normative and Informative References into references to 
European standards (where they exist). Then it adds Annexes about conformity 
with the Essential Requirements of European Directives and Regulations.

 

When approved as a European Standard (EN), all CENELEC countries are compelled 
to adopt it and publish as, for example BS EN 62368-1 and DIN EN 62368-1.

 

With best wishes DESIGN IT IN! OOO – Own Opinions Only

 <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and 
Associates Rayleigh England

 

Sylvae in aeternum manent.

 

From: Vincent Lee [mailto:08e6c8d35910-dmarc-requ...@ieee.org] 
Sent: 24 June 2017 14:47
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Questions on IEC Standards Adaption

 

Hi all,

 

Good morning,


What are the differences between BS EN 62368-1:2014 and IEC 62368-1 Edition 2.0 
2014-02 ?

 

I was told that usually it is after IEC has published a standard, then other 
organisations like BSI or DIN will adapt the IEC standard as their national 
standards, e.g. BS and DIN, it is true?

 

What are some the major considerations when organisations like BSI and DIN have 
in mind when adapt the IEC standards?

 

Hope to hear from you soon. Thank you.

Vincent

 

Regards, Vincent

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Re: [PSES] EN55032 host equipment...

[ce-test, qualified testing bv - Gert Gremmen]

About this clause D:

Annex D   Arrangement of EUT, local AE and associated cabling
...
Arrangements such as placing AE below the RGP or placing AE outside the
measurement area when it is normally located distant from the EUT may be
used to limit the effects of adverse AE emissions or to reduce
measurement time, as long as the arrangement can be shown not to reduce
the emissions measured from the EUT.

For this demonstration to happen one should measure EUT emissions first
without AE  may I suggest measuring EUT as a standalone device
first before 
adding a AE to mess up with the spectrum ?

Gert Gremmen

-Oorspronkelijk bericht-
Van: T.Sato [mailto:vef00...@nifty.com] 
Verzonden: dinsdag 9 mei 2017 12:23
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] EN55032 host equipment...

On Mon, 8 May 2017 22:32:38 +,
  Matthew Wilson <matthew.wil...@gbelectronics.com> wrote:

> In regards testing, for example's sake, a printer with a RS232 serial
port under EN55032 for EMC, where does the host 'laptop' PC to generate
the RS232 signals (most likely via a USB-RS232 adapter from the laptop's
USB port) get located in the test setup?
> 
> Inside the test chamber, where you might end up testing the
performance of the laptop?  Or outside the chamber via an 'extension
lead' through a suitable aperture in the chamber on the RS232 line (and
probably loaded with a set of ferrites to attenuate any external
signals)?
> 
> EN55032 does seem to conflict itself without a clear answer between
#3.1.5 and #6.2...
> 
> I'd rather check only the example printer device for EMC, which is the

> EUT of interest, rather than anyone else's laptop :-)

The standard permit to reduce emission from AEs by mitigation measures
in certain conditions, although it may not easy to demonstrate that the
mitigation measures will not reduce the emission from the EUT.


10 Compliance with this publication
...
If the AE is known to cause significant emissions, these emissions may
be reduced by mitigation measures, as long as these measures do not
reduce the emissions from the EUT. The preferred configuration is that
the AE is removed from the measurement area, as allowed by D.1


Annex D   Arrangement of EUT, local AE and associated cabling
...
Arrangements such as placing AE below the RGP or placing AE outside the
measurement area when it is normally located distant from the EUT may be
used to limit the effects of adverse AE emissions or to reduce
measurement time, as long as the arrangement can be shown not to reduce
the emissions measured from the EUT.


Regards,
Tom

--
Tomonori Sato  <vef00...@nifty.com>
URL: http://t-sato.in.coocan.jp

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Re: [PSES] EN55032 host equipment...

[ce-test, qualified testing bv - Gert Gremmen]

Matthew,

Adding a filtered SUBD-9 connector in the septum of your shielded room (or 2 
filtered connectors in series ) allows you to route RS232 cable out of the 
room, and connect it to any suitable interface. Route the EUT RS232 cable to 
the centre of your turn table and along the floor to the septum, better is 
routed through a metal tube (conduit) connected all along to the rooms wall.  
Terminate the cable with a few ferrites to trunk off the excess length. 

No need any more to search and find ($) a quiet laptop. (try to ask for one 
at the local PC store ). No need to upgrade the laptop with any new windows 
version.

I wonder how a formal test standard as 22/32 can depend on an arbitrary and 
unspecified test accessories such as a “quiet laptop”, or whatever other 
ancillary equipment in order to create formal results. 
And once you found a  "quiet laptop", you need to qualify it for all kinds of 
cable connections and screen resolutions () to ensure you are actually 
(not) getting the emissions you do not want. 

Not to mention the polluted spectrum plot with all "quiet" spuriouses that 
still get to -6dB of the limit, that can trouble your design team, and distract 
of the real problems. 

I am aware of the lack of support of CISPR 22 for the external cable setup but 
after all , no one stops you from retesting with a laptop on the table once 
your tested your peripheral as I sketched above, but do not complain if it 
fails due to some Class A harmonics of the laptops local bus that were not 
there before.....


Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking according to EC-directives:
  - Electro Magnetic Compatibility 2014/30/EC
- Electrical Safety 2014/35/EC
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From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: Tuesday 9 May 2017 01:24
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN55032 host equipment...

Matthew,

The host computer goes in the chamber (or on the OATS) 10 cm away from the 
printer on the table.  The same setup used for years in CISPR 22 or EN 55022.  
Find a quiet laptop and keep using it for future tests.

Ghery S. Pettit, NCE

From: Matthew Wilson [mailto:matthew.wil...@gbelectronics.com] 
Sent: Monday, May 8, 2017 3:33 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EN55032 host equipment...

In regards testing, for example's sake, a printer with a RS232 serial port 
under EN55032 for EMC, where does the host 'laptop' PC to generate the RS232 
signals (most likely via a USB-RS232 adapter from the laptop's USB port) get 
located in the test setup?


Inside the test chamber, where you might end up testing the performance of the 
laptop?  Or outside the chamber via an 'extension lead' through a suitable 
aperture in the chamber on the RS232 line (and probably loaded with a set of 
ferrites to attenuate any external signals)?

EN55032 does seem to conflict itself without a clear answer between #3.1.5 and 
#6.2...

I'd rather check only the example printer device for EMC, which is the EUT of 
interest, rather than anyone else's laptop :-)

Thanks for any pointers/discussion.

Matthew Wilson,
GB Electronics UK Ltd.
 

Matthew Wilson 
Technical Director

https://gbelectronics.uk
T: +44 (0)1903 244500
F: +44 (0)1903 700715
Ascot House // Mulberry Close // Woods Way
Goring-by-Sea // West Sussex // BN12 4QY // UK


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Re: [PSES] Radiated RF electromagnetic fields immunity test on ambulatory electrocardiographic system

[ce-test, qualified testing bv - Gert Gremmen]

 

You did not mention the product , but I assume that

 

IEC 60601-2-47:2012 concerns the basic safety and essential performance
of AMBULATORY ELECTROCARDIOGRAPHIC SYSTEMS

 

so you probably considering such a device.

 

 

I believe that if it is required to test essential performance, and for
thorough

the specific type of equipment a patient signal is required,  a
simulator is what you need to fulfil due diligence.

Especially if the device software autonomously draws any pertinent
conclusions from the measured signals

and the signals are not for  visual monitoring only.

 

A classical cardiographic device is basically a DM oscilloscope with a
high (assisted) CM suppression:

any device that can generate a large CM  and extremely small DM voltage
simultaneously will do.

 

In no way the testing for the integrity of stored data can be the only
compliance criterion here.

 

That said and concluded: I am not fully sure what your device is up
to...

 

Gert Gremmen

 

 

 

Van: Silvia Diaz Monnier [mailto:silvi...@inti.gob.ar] 
Verzonden: dinsdag 28 maart 2017 20:12
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: [PSES] Radiated RF electromagnetic fields immunity test on
ambulatory electrocardiographic system

 

Hi,

 

the Radiated RF electromagnetic fields immunity test according to IEC
60601-2-47:2012, 202.6.2.3, makes an addition to IEC 60601-1-2:2007.
This addition requires to check that there is no loss of any stored
data. But collateral IEC 60601-1-2:2007, on 6.2.1.10 also requires to
verify the essential performance is not affected by noise on a waveform
in which the noise could interfere the diagnosis, treatment or
monitoring.

 

Test setup of IEC 60601-2-47 for that test do not require to simulate
the patient signal. Is that correct? 

If so, why 2-47 makes an addition instead of a replacement.

If not, why the test setup do not require to use a patient signal
simulator to check essential performance as other particular standards
IEC 60601-2-25 or IEC 60601-2-27.

 

That is, taking into account both standards, is it neccesary to check
both essential performance and the no loss of storaged data? Or only the
no loss of any stored data.

 

Thanks for your help.

Best regards,

Silvia

 

 

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[PSES] RED Harmonised Standards

[ce-test, qualified testing bv - Gert Gremmen]

I did not read it on this list yet (unless a post missed by box again), but 
last week a new version of the list of Harmonised standards has been published 
(C76 10-3-2017) for the RED (2014/53/EC) 15 pages now of our beloved 
literature

Regards,

Ing. Gert Gremmen
Approvals manager



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Re: [PSES] RE_D question Marine Product

[ce-test, qualified testing bv - Gert Gremmen]

EN 60945 is used in many regulations for marine equipment.
Lloyds and Norske Veritas almost always use EN 60945 as a requirement.
EN 60945 has an extra low level limit for emissions
in de frequencies used for marine communications 156-164 MHz @ BW 9 KHz and 
goes up using 120 KHz to 2 GHz.
As far as I know (a bit dated and unchecked) the Marine Equipment Directive 
also refers to EN 60945.
As the (EMC) requirements are (in details) different from other common 
standards, one should definitely consider applying this standard. It's 
harmonised for the EMCD also. The standard is not only about EMC, it includes 
many other aspects such as heat, salt, vibration tests.


Regards,

Ing. Gert Gremmen
Approvals manager



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From: Sundstrom, Mike [mailto:mike.sundst...@garmin.com] 
Sent: Thursday 23 March 2017 20:50
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RE_D question Marine Product

Hello everyone,
I've been asked if EN 60945 will be required for CE marking a RE_D Marine 
product?

I don't think so, I'm looking for guidance on this one.
I'm thinking if you meet all applicable standards listed under RE_D you are 
done.
Have I missed something?

Thanks,

Michael Sundstrom
Garmin Compliance Engineer
2-2606
(913) 440-1540
KB5UKT

"Never give up on a dream just because of the time it will take to accomplish 
it.
The time will pass anyway."
Earl Nightingale




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Re: [PSES] SD Card ESD Testing

[ce-test, qualified testing bv - Gert Gremmen]

I have been carrying out extensive tests on ESD discharge currents on a lot of 
different credit cards with a charged user inserting cards into a ATM type of 
card reader. Client had found problems with CC-payments in dry and/or cold 
regions.
The presence of metal coating (gold card) and or wireless electronics (so 
conductors embedded in the card)had been a major factor in transferring ESD 
discharges to the card reader (being magnetic or chip contact readers) . It is 
important to realize that a galvanic connection is not required to create a 
"discharge". The displacement of charge inside the card (where the user is 
charged during card insertion) is enough to create substantial impulses in the 
readers electronics..

For SD -cards (and other cards) similar effects can be expected.


Regards,

Ing. Gert Gremmen
Approvals manager



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-Original Message-
From: Doug Smith [mailto:d...@emcesd.com] 
Sent: Wednesday 22 March 2017 00:38
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SD Card ESD Testing

The discharge will be much more energetic than a CDM event as there is MUCH 
more energy stored off the card than the card itself in this case, but passes 
through the card. The capacitance is much higher than Tom realizes below. 
Somewhere below a CDM event and an IEC event.

eration is how will the card stand up to hundreds or thousands of small, 
ubiquitous  ESD events that cannot be felt by humans but cause slow degradation 
from not only insertion but handling over several months. No one tests for that 
yet. I have designed an apparatus that does that job and it has proven very 
useful.

Doug Smith

University of Oxford, Course Tutor
Department for Continuing Education
Oxford, Oxfordshire, United Kingdom
--
Doug Smith
P.O. Box 60941
Boulder City, NV 89006-0941
TEL/FAX: 702-570-6108/570-6013
Mobile: 408-858-4528
Email: d...@dsmith.org
Web: http://www.dsmith.org
--


On Wed, 22 Mar 2017 07:27:33 +0900, "T.Sato"  wrote:

On Mon, 20 Mar 2017 19:24:23 +,
  "Grasso, Charles"  wrote:

> Aside from the obvious air discharge tests around the SD card slot 
> (with and without the SD card installed) are there any concerns regarding the 
> ESD performance of the SD card during INSERTION?

Only a guess...

SD card may be charged before insertion, and may cause discharge from those 
contacts when inserted.
This situation may slightly similar to that simulated with charged device model 
(CDM), and the discharge may be much faster than that of IEC 61000-4-2 and ISO 
10605.
However, it's capacitance is low, and I think it will not become a serious 
problem in general.

In case of Compact Flush card, I ever heard of a case where metalized label on 
the card created an unexpected path for electrostatic discharges and caused a 
problem when hold by hand and inserted to a device.

Regards,
Tom

--
Tomonori Sato
URL: http://t-sato.in.coocan.jp

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Re: [PSES] CORRECTION (wrong page) Passive Loop Emissions [General Use]

[ce-test, qualified testing bv - Gert Gremmen]

Many standards express the limits for magnetic field measurements in dBuV/m, so 
in E-field. Most also indicate the relation of 51.5 dB to be added
to convert H-field  into E-field , ignoring close field effects.
The 60 cm loop is an old beast, and so are test conventions.


Regards,

Ing. Gert Gremmen
Approvals manager



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-Original Message-
From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Tuesday 28 February 2017 10:38
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CORRECTION (wrong page) Passive Loop Emissions [General Use]

Should be easy to meet any limits using that technique!

With best wishes DESIGN IT IN! OOO – Own Opinions Only www.jmwa.demon.co.uk J M 
Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.


-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net]
Sent: Tuesday, February 28, 2017 9:25 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CORRECTION (wrong page) Passive Loop Emissions [General Use]

On 2/27/2017 11:58 PM, Brent DeWitt wrote:
> Agreed Ken.  In this case the e-field conversion is irrelevant, and 
> the specified antenna factor is what it is.

I have to concur.  I am recalling issues with the FCC's insistence on measuring 
the E-field of Access BPL emissions with a loop antenna.

Cortland Richmond

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Re: [PSES] crimp hardware for multiple conductors?

[ce-test, qualified testing bv - Gert Gremmen]

You can put 20 people in a car, but you won’t make it for far.

There are chairs for 4 (in most cars), so charge them with four people. Logic 
isn’t it ?

If a ring terminal would be made for 2 or more wires, they would allow for

two separate cable entries (and require a suitable crimping tool).

Most safety standards require both insulation and wire to be fastened to be 
acceptable

anyway, and I see no way how slippery plastic insulations van be crimped 
together.

(try crimping two wires without stripping the copper, so the crimp is only 
insulation)

Every crimp terminal seems to scream “one wire only” to you and so do the

safety standards and terminal manufacturers illustrations and specifications.

 

If one needs really more than 3-4 ring terminals on a bolt, use more bolts. 

Or use quadruple male  6.3 mm flat-stack connectors and stack them

with sufficient spacing.

https://img.conrad.de/medias/global/ce/3000_3999/3900/3930/3934/393416_BB_00_FB.EPS.jpg

 

 

Gert gremmen

 

Van: Doug Powell [mailto:doug...@gmail.com] 
Verzonden: dinsdag 21 februari 2017 16:45
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] crimp hardware for multiple conductors?

 

I've had experience with this in a few types of products, using both with 
IEC-based standards and old school UL standards.  When dealing with various 
electric codes such as NFPA 70, there are needs that must be met and the design 
of a product must be compatible. 

 

As you have stated, there is very little mentioned in product safety standards. 
 Sometime you will see a "pull out test" or some such thing and clearance and 
creepage requirements still apply. But we seldom find requirements or guidance 
to the level of detail you are asking about.  This tends to foster some rather 
bad habits by design engineers.  For example, I had to put the kibosh on a 
"star ground" where the engineer had placed a metallic standoff in a circuit 
board and proceeded to screw down at least eight ring lugs all fanned out 
around the circle, making a perfect star burst of wires.  The whole assembly 
was unwieldy and very slippery under the fastener.  It simply would not hold to 
a simple finger torque out test.  So then the engineer attempted to put all 
eight wires in a single oversized ring lug.  Doing a wire pull out test 
resulted in one or two of the wires immediately pulling free and subsequently 
all fell out.  While it was possible to get specific crimps to pass these 
simple tests, it was not manufacturable in an ongoing basis.  

 

Our solution was to leverage IPC-WHMA-A-620A Requirements and Acceptance for 
Cable and Wire Harness Assemblies.  This is not specifically mentioned in many 
safety standards and therefore does not have a lot of force behind it, but it 
is very familiar to wire and cable houses who are in the business of making 
cable harnesses.  Also, most company reliability engineers will agree with this 
document. It has very specific inspection criteria based on the "acceptance 
class" you need.  I find Acceptance Class 2 is sufficient for most products and 
also very cost effective.  

 

For the situation you brought up, I have always required no more than one or 
two conductors in a single crimp terminal of any kind and no more than two ring 
lugs per fastener.  IPC 620 has requirements that require inspection of the 
wire strands on the far side of the wire crimp portion and for the wire 
insulation under the insulation crimp portion.  For example, IPC 620 makes 
statements like this, "When attaching multiple wires to a single terminal, each 
wire shall meet the same acceptability criteria as a single wire termination. 
When attaching single or multiple wires to a terminal the combined circular mil 
area of the wires shall comply with the circular mil area range for the 
terminal" and "If multiple wires are used insulation from all wires extend past 
the insulation crimp ...". In one place, "Two wires into a single contact ..." 
is listed as a defect, "unless the contact or connector specifications indicate 
that this is acceptable." 

 

​Hope this helps,  Doug

 

 

Douglas E Powell

doug...@gmail.com <mailto:doug...@gmail.com> 

http://www.linkedin.com/in/dougp01
<http://www.linkedin.com/in/dougp01> 

 

 

 

 

On Tue, Feb 21, 2017 at 7:12 AM, John Woodgate <jmw1...@btinternet.com> wrote:

It only helps to show that this is a 'grey area', suggesting that for a quiet 
life, do not use more than one wire. 

 

In practice, two solid wires are very troublesome, but two stranded wires are 
nowhere near as difficult. The more strands the better, within the capacity of 
the crimp.

 

With best wishes DESIGN IT IN! OOO – Own Opinions Only

www.jmwa.demon.co.uk <http://www.jmwa.demon.co.uk/>  J M Woodgate and 
Associates Rayleigh England

 

Sylvae in aeternum manent.

 

From: Adam Dixon [mailto:lanterna.viri...@gmail.com] 
Se

Re: [PSES] Carbon Monoxide - Death Value

[ce-test, qualified testing bv - Gert Gremmen]

Ted, (and all other safety friends)

IMHO older cars detoriating to the level of CO coming in, will also let the 
driving wind
leak in to an amount  that CO is not a real problem anymore. ;<))

Highest risk is where ventilation is modified to recirculating, (to prevent 
pollution coming in (!!) or to boost the airco) and a small leak -whatever the 
reason- of CO happens. 

I think we should not interfere with intentional poisoning ; candidates might 
otherwise choose much dangerous alternatives to CO (dangerous to others of 
course !).

Current common CO detectors for home use  need replacement every 7 years, so 
the risk that a detector does not detect what it is intended for is not 
imaginary.

Maybe you US citizen can get Trump to write a presidential Order to stop CO ? 
And the Europeans might create a CO-directive ?


Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking according to EC-directives:
  - Electro Magnetic Compatibility 2014/30/EC
- Electrical Safety 2014/35/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC

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-Original Message-
From: Ted Eckert [mailto:07cf6ebeab9d-dmarc-requ...@ieee.org] 
Sent: Thursday 16 February 2017 21:49
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Carbon Monoxide - Death Value

I see two problems with the proposed alarm system.

First, the most common reason for accidental carbon monoxide intrusion into the 
passenger compartment is poor maintenance on an older vehicle. The exhaust 
system needs to be compromised somewhere under the vehicle and there typically 
need to be holes in the floor boards letting the carbon monoxide enter. Rust is 
the most common culprit, but it can also be other types of damage. If a car has 
been allowed to deteriorate to this point, would a carbon monoxide alarm system 
still be functioning properly? The sensors would likely need regular 
maintenance or replacement. It seems possible that many of the detection 
systems would no longer be operating properly by the time a vehicle is old 
enough for the risk to have increased.

Second, the number of vehicles on the road is high enough that even a small 
number of false-positives would completely outweigh the number of real alarms. 
There are 300,000,000 vehicles in the United States. If only 0.01% experience a 
false failure, that is still 30,000 false failures. What happens if a driver is 
going down the highway when the alarm goes off? It wouldn't take many drivers 
panicking before accidental deaths due to reactions to false failures exceeded 
the number of potential lives saved from real alarms. Even if the system just 
automatically rolls down a window, some drivers may not recognize that this is 
the alarm response. They may become fixated on trying to get the window to 
close again without noticing that traffic ahead of them has stopped. 

In some locations in the United States, there is a mandatory safety inspection 
to renew your car's registration. I'm not stating one way or another whether 
this is a good option. However, these inspections do look for exhaust leaks, 
faulty brakes and other safety issues. I lived in Missouri for 20 years and I 
found the inspections to be a hassle. At the time, I saw a lot of cars on the 
road that didn't look safe to me and I thought that the inspections were 
probably ineffective. I moved to Washington 9 years ago and I quickly learned I 
was mistaken. In Washington, I am amazed by the number of cars I see on the 
road with faulty headlights, broken taillights and even no brake lights. Those 
are just the visible safety issues. I can't tell how many have faulty exhaust 
systems that leak carbon monoxide into the passenger cabin.

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer.

-Original Message-
From: Brian O'Connell [mailto:oconne...@tamuracorp.com]
Sent: Thursday, February 16, 2017 12:07 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES]

Re: [PSES] DoC when exempted from RED 2014/53/EU

[ce-test, qualified testing bv - Gert Gremmen]

It depends. If it costs money probably they will refrain or at least be 
reluctant and prefer
a warning in chinglish on page 97 note 21. 

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking according to EC-directives:
  - Electro Magnetic Compatibility 2014/30/EC
- Electrical Safety 2014/35/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC

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Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
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From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Thursday 2 February 2017 23:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] DoC when exempted from RED 2014/53/EU

Yes, manufacturers would be well advised to take precautions not to kill 
potential customers. Can we rely on them to do that?

With best wishes DESIGN IT IN! OOO - Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

From: Pete Perkins [mailto:peperkin...@cs.com] 
Sent: Thursday, February 2, 2017 10:36 PM
To: 'John Woodgate' <jmw1...@btinternet.com>; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] DoC when exempted from RED 2014/53/EU

John, et al,  

   My point, which I believe that I made below, is that even for 
board kits which leave everything out in the open there are techniques to 
minimize the exposure problems since not all of the users are experienced or 
fully qualified to know the risks and keep themselves out of harm's way.  
   The manufacturer has the responsibility to provide a device that 
is easy to use in a 'safe' manner (the definition of which I have expanded to 
include EMC issues altho not technically safety per se).  
   It's not good enuf to hide behind 'we met all of the 
requirements' - which were mostly none.  

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

p.perk...@ieee.org

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Thursday, February 2, 2017 9:44 AM
To: 'Pete Perkins' <peperkin...@cs.com>; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] DoC when exempted from RED 2014/53/EU

I'm not quite sure of your point. The thread is about evaluation kits, which 
are very often just populated PC boards with I/O and power connectors. 
Everything is accessible, so if the board uses voltages that hurt (which is 
uncommon but not unknown), you don't touch. Equally, there are no fire 
enclosures.

With best wishes DESIGN IT IN! OOO - Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

From: Pete Perkins [mailto:peperkin...@cs.com] 
Sent: Thursday, February 2, 2017 5:21 PM
To: 'John Woodgate' <jmw1...@btinternet.com>; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] DoC when exempted from RED 2014/53/EU

John, et al,  

   It's nice to look for exemption loopholes but ... I would be 
careful in encouraging too much loosening based upon the skill of the users.  
   In today's environment many engineers and technicians are primarily 
software folks who are working with hardware to implement systems and these 
folks do not have the same training or appreciation of electrical hazards in 
equipment.  
   This comment applies equally to problems arising from EMC interference 
in applications; we know that there are a myriad of issues arising from the 
advent of multiple cell towers in operation.  Dropped call issues are usually 
dealt with by modifying software not repositioning antennas or other hardware 
fixes which are above the technicians pay grade.  
   I include radios generally in this comment because of the 
widespread use of digital radio equipment and the IoT explosion underway.     

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

p.perk...@ieee.org

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Thursday, February 2, 2017 4:

Re: [PSES] Do it yourself safety reports?

[ce-test, qualified testing bv - Gert Gremmen]

I agree with John, batteries are the most critical part. Make sure
they are properly approved, and use a fuse in their leads.

As it's an RF product, I suppose the LVD comes into play by
means of the RTTE (RED) directive.
So a full qualification is needed.
Many aspects do not apply, but the remaining
applicable chapters need evaluation.
That requires evaluation of the battery, and possibly fire and heat hazards
if the power exceeds  "limited power levels". (antenna voltage > 50 ?)
Documentation, marking  and labelling  
and a proper definition (intended use) is needed. Installation 
and safety documentation might be needed.
If the battery is chargeable and a power supply is included it needs
verification of its  documentation and needs reinforced insulation, 
both mechanically and electrically, as the secondary "live parts" are rarely 
earthed in these type
of equipment's and often must be be classified as accessible parts. 
Plastics need may not propagate fire, and should have the right V Class. 

More aspects can be applicable.

making your own test report is possible, but I doubt if it will stand up
against examination, unless you have done this before... 



Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking according to EC-directives:
  - Electro Magnetic Compatibility 2014/30/EC
- Electrical Safety 2014/35/EC
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Thank you for your co-operation.

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Wednesday 1 February 2017 09:28
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Do it yourself safety reports?

If it's battery-powered, the LVD may not apply, so in turn there is no need to 
apply 60950. But I would advise applying it as far as possible. We don't want 
more battery fires, so that is one point to look at carefully; can the battery 
be short-circuited by a fault and if so, what happens? It's certainly possible 
to do that without a test house, but of course, it has to be done carefully. 

With best wishes DESIGN IT IN! OOO – Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

From: Curtis McNamara [mailto:mcnam...@umn.edu] 
Sent: Tuesday, January 31, 2017 11:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Do it yourself safety reports?

A client is asking if it is practical to do their own 60950 safety reports for 
CE.
The device is battery powered, low power RF (they would have complete EMC 
testing done at a lab). 
Thanks in advance for your suggestions.
Thanks for all the great past advice!
    Curt
-

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Attachments are not permitted but the IEEE PSES Online Communities site at 
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This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
<emc-p...@ieee.org>
All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html
Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used 

Re: [PSES] Double Pole Mains Switches, Cord Connected Products

[ce-test, qualified testing bv - Gert Gremmen]

The general safety requirement for equipment is to be able to be `disconnected” 
; a term for having no hazardous voltage inside. 
A disconnect device is any system within reach of the user that allows to 
disconnect the apparatus form all live voltage. 
That can be double pole switch, but also a  “double pole” plug. Note the remark 
“within reach of user”; it limits the length of the mains wire to 1m50 approx. 
(though not specified in any standard).
Permanently connected equipment requires a disconnect switch (double pole) or a 
mains (wall) connection with an incorporated double pole switch in close 
proximity and suitable warnings. 

Current safety standards address this topic in a non-consistent way, which is a 
shame, as it is the first topic that comes to mind when thinking of protection 
against electric shock.


I personally think that a double pole on/off switch is much more clear, 
definite (does what is suggests)  and thus safer than a single pole.

And the French Schuko with the third (ground) plug cannot be reversed which is 
a real problem with right angled plugs, as in France sockets are placed close 
to ground.


This is clearly a topic that should   be addressed in the mandatory risk 
analysis within the low voltage directive, in addition to  blindly applying the 
standards clauses.

Gert Gremmen
Regards,

Ing.  Gert Gremmen, BSc
 

 
g.grem...@cetest.nl
www.cetest.nl

Kiotoweg 363
3047 BG Rotterdam
T 31(0)104152426
F 31(0)104154953
 
 Before printing, think about the environment.




Van: Ted Eckert [mailto:07cf6ebeab9d-dmarc-requ...@ieee.org] 
Verzonden: zaterdag 28 januari 2017 18:07
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] Double Pole Mains Switches, Cord Connected Products

Hello Mike,

Single-pole switches are acceptable and typical on plug connected single-phase 
equipment and sometimes on two-phase equipment. IEC 60950-1 has the somewhat 
cryptic marking “Double Pole/Neutral Fusing” as indication to service personnel 
that there may still be live voltage in the equipment even if the switch is 
off. The symbol is even more cryptic to the average person, but the warning is 
specified. The intention for plug connected equipment is that the plug serve as 
the disconnect. Service personnel are to unplug the equipment for servicing to 
remove all power. You may even have equipment that is rated 208/240 V. In 
Europe, it would be plugged into line and neutral whereas in North America, it 
would be plugged into two phases of either a split-phase 120/240 system or two 
phases of a 120/208 three-phase system. In North America, the switch would 
never remove voltage from within the equipment but would interrupt current. 
This is still generally acceptable for plug-connecte!
 d equipment.

Field-wired/permanently connected equipment would require a main disconnect 
that opens all phases. The installer should be aware of the polarity of the 
system and the installer should not reverse phase and neutral during wiring. In 
North America, this allows an equipment disconnect that opens the phases 
without opening neutral. As such, even with field-wired equipment, it is 
permissible to have neutral bypass the main disconnect.

It has been a while since I had to delve deeply into the electrical codes, so I 
may be a little off on the field-wired requirements. I encourage any of our 
esteemed contributors to correct my errors.

Best regards,
Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily represent those of my 
employer.

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Saturday, January 28, 2017 8:32 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Double Pole Mains Switches, Cord Connected Products

ALL European 2-pin 6 A plugs are reversible, and 3-contact plugs used on the 
Continent are reversible (there are two kinds, one with 2 power pins and 
side-contact for earth (called 'Schuko')  and one with a third pin for earth).

The standards you cite are written so that the product is safe, whichever way 
round the plug is inserted. You do not need a double-pole switch; in fact that 
can be a disadvantage, as it brings the two power conductors close together in 
an assembly with mechanical movement. A short-circuit at some stage in the life 
of the device is not improbable. Also, the insulation can fail, usually with 
smoke and small-scale flame, accompanied by a loud noise.

With best wishes DESIGN IT IN! OOO – Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

From: Mike Sherman - Original Message - [mailto:msherma...@comcast.net] 
Sent: Saturday, January 28, 2017 4:17 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Double Pole Mains Switches, Cord Connected Products

Because of the lack of polarization on many 2 pin European plugs, I have always 
recommended double pole mains switches on cord connected products for the EU 
market. However, I am

Re: [PSES] lowest emissions 4k TV?

[ce-test, qualified testing bv - Gert Gremmen]

I am sorry Ted, but that won't work. It overlooks the impact of harmonics
on capacitive reluctance.  I suggest applying left magnetized ferrite.
With right handed rotating harmonics, the left rotation of the magnetic flux 
will
double the amplitude and so will dissipation, and harmonic suppression.
Make sure the ferrite comes with the right frequencies pre-polarized.


Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking according to EC-directives:
  - Electro Magnetic Compatibility 2014/30/EC
- Electrical Safety 2014/35/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC

Web:    www.cetest.nl  (English) www.ce-test.nl (Dutch) www.cetest.fr (under 
construction)
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
and are intended for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not 
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-Original Message-
From: Ted Eckert [mailto:07cf6ebeab9d-dmarc-requ...@ieee.org] 
Sent: Tuesday 17 January 2017 01:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

What you need is a device that will not only supply inverse reactive current 
for use in unilateral phase detractors, but will also be capable of 
automatically synchronizing cardinal grammeters. Instead of power being 
generated by the relative motions of conductors and fluxes, it is produced by 
the modial interaction of magnetoreluctance and capacitive directance.
https://www.youtube.com/watch?v=MXW0bx_Ooq4

Ted Eckert
The opinions expressed are my own and do not necessarily reflect those of my 
employer, Fiat-Chrysler or the American Association of Turboencabulator 
Engineers.

-Original Message-
From: John Woodgate [mailto:jmw1...@btinternet.com]
Sent: Monday, January 16, 2017 12:37 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

Definite need for a flux capacitor or a zwitterion inductor, there. Amendment 
XVIII coming up?.

With best wishes DESIGN IT IN! OOO - Own Opinions Only www.jmwa.demon.co.uk J M 
Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.


-Original Message-
From: Ralph McDiarmid [mailto:ralph.mcdiar...@schneider-electric.com]
Sent: Monday, January 16, 2017 7:45 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

"... as long as the arrangement can be shown not to reduce the emissions 
measured from the EUT."

Hmm, I wonder how one could do that.


Ralph McDiarmid
Product Compliance
Engineering
Solar Business
Schneider Electric
    


-Original Message-
From: Ghery S. Pettit [mailto:n6...@comcast.net]
Sent: Saturday, January 14, 2017 1:57 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

The 4th paragraph of CISPR 32, Edition 1.0, Article D.1.1 states:

"Arrangements such as placing AE below the RGP or placing AE outside the 
measurement area when it is normally located distant from the EUT may be used 
to limit the effects of adverse AE emissions or to reduce measurement time, as 
long as the arrangement can be shown not to reduce the emissions measured from 
the EUT."

Note that this refers to AE that is normally located distant from the EUT.
AE that is normally located adjacent to the EUT should be co-located with the 
EUT.  See the 2nd paragraph of D.1.1.

I don't see a conflict between CISPR 32 and ANSI C63.4 in this area.

Ghery S. Pettit



-Original Message-
From: Brent DeWitt [mailto:bdew...@ix.netcom.com]
Sent: Friday, January 13, 2017 5:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

It seems that there is a potential conflict between CISPR 32 and ANSI C63.4 
with respect to AE/support equipment.  CISPR 32, as I remember, specifically 
says to minimize the emissions from the AE/support equipment while C63.4 does 
have the support equipment in the test environment.  Ghery Pettit is more 
qualified to comment, but I believe there is work going on to reconcile the two.

Brent DeWitt, AB1LF
Milford, MA

-Original Message-
From: Ken Javor [mailto:ken.ja...@emccompliance.com]
Sent: Thursday, January 12, 2017 7:20 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

Not proffering a solut

Re: [PSES] lowest emissions 4k TV?

[ce-test, qualified testing bv - Gert Gremmen]

John,

While your libertine approach might feel attractive, it means also
that the liberated spectrum area like this (by increasing B to A) also
means the same spectrum an never be used again for new purposes in the future,
or if really needed only at greatly enhanced costs.
Propagation attenuation of radio waves is approximately inverse linear with 
distance. If you calculate the service area of a transmitter for a 10dB 
relaxation (Class B -> A)
there is approx. 9-fold less ground service available. That means that
for the same service level 10 transmitters are needed, with 10 fold increased 
risk
of interference close to the transmitter .

It is much better keeping the ether clean, after all we have only one.

Short term gains may lead to future expenses, of with a good UK proverb 
"Pennies wise, pound foolish".
Or John, you might know a better one ? (in Latin ?)
Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking according to EC-directives:
  - Electro Magnetic Compatibility 2014/30/EC
- Electrical Safety 2014/35/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC

Web:    www.cetest.nl  (English) www.ce-test.nl (Dutch) www.cetest.fr (under 
construction)
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
and are intended for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not 
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Thank you for your co-operation.


-Original Message-
From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Saturday 14 January 2017 12:46
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

Interesting. I think CISPR/H should be required to study the relevance of 
emission limits designed to protect broadcasting and other services that are no 
longer used, or used only to an insignificant extent.  For example, it is 
reported that Norway is to begin a phased shut-down of its FM broadcast service 
for good technical and economic reasons, and other countries are said to follow.
Military authorities are traditionally known for commandeering and holding 
spectrum that 'they might want to use one day'. 

With best wishes DESIGN IT IN! OOO - Own Opinions Only www.jmwa.demon.co.uk J M 
Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.


-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl]
Sent: Saturday, January 14, 2017 11:05 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

That is certainly right. But there is another aspect that might play a role 
here.

Many fast digital bus concepts have been designed with Class A limits in mind.
That means when applying the (chip) manufacturer's reference design, the final 
product meets A limits only. Only with enhanced effort Class B limits can be 
met.
Some chip-sets do never meet Class B, as there outputs have substantial common 
mode currents in their outputs ( thinking of Ethernet here).
More and more EN standards now require Class B and also worldwide the trend is 
towards Class B. The application of ETSI standards for transmitter and/or 
receiver equipped electronics does not even allow for a Class A escape route. 
The new RED (Radio Directive) in the EU brings a whole new category under Class 
B (for example GPS equipped designs).

If you are trying to approve a HDMI product into a Class B world, there is 
almost no margin to comply, and any EUT design flaw problem will show as 
non-compliance.

Regards,

Ing. Gert Gremmen
Approvals manager




+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking according to 
+ EC-directives:
  - Electro Magnetic Compatibility 2014/30/EC
- Electrical Safety 2014/35/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC

Web:    www.cetest.nl  (English) www.ce-test.nl (Dutch) www.cetest.fr (under
construction)
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information that is 
confidential and/or protected by intellectual property rights and are intended 
for the sole use of the recipient(s) 

Re: [PSES] lowest emissions 4k TV?

[ce-test, qualified testing bv - Gert Gremmen]

That is certainly right. But there is another aspect that might play a role 
here.

Many fast digital bus concepts have been designed with Class A limits in mind.
That means when applying the (chip) manufacturer's reference design, the final
product meets A limits only. Only with enhanced effort Class B limits can be 
met.
Some chip-sets do never meet Class B, as there outputs have substantial common 
mode
currents in their outputs ( thinking of Ethernet here).
More and more EN standards now require Class B and also worldwide the trend is
towards Class B. The application of ETSI standards for transmitter and/or 
receiver
equipped electronics does not even allow for a Class A escape route. The new RED
(Radio Directive) in the EU brings a whole new category under Class B 
(for example GPS equipped designs).

If you are trying to approve a HDMI product into a Class B world, there is 
almost
no margin to comply, and any EUT design flaw problem will show as 
non-compliance.

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking according to EC-directives:
  - Electro Magnetic Compatibility 2014/30/EC
- Electrical Safety 2014/35/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC

Web:    www.cetest.nl  (English) www.ce-test.nl (Dutch) www.cetest.fr (under 
construction)
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
and are intended for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not 
limited to, total or partial reproduction, communication or 
distribution in any form) by persons other than the designated 
recipient(s) is prohibited. If you have received this e-mail in error, 
please notify the sender either by telephone or by e-mail and 
delete the material from any computer. 
Thank you for your co-operation.


-Original Message-
From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Saturday 14 January 2017 11:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

I think the key words 'poorly-constructed' should be noted. Any manufacturing 
defect that creates an impedance discontinuity in the signal conductors causes 
mode conversion of the differential signal, creating a small, but significant 
common-mode signal.

With best wishes DESIGN IT IN! OOO - Own Opinions Only www.jmwa.demon.co.uk J M 
Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.


-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl]
Sent: Saturday, January 14, 2017 9:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

Exactly :
Once the signal is unbalanced (whatever the reason) only shielding can 
attenuate the emissions.
But any unbalance is caused by the EUT at the  sending or  at the receiving 
end, not by the cable.


Gert Gremmen


-Oorspronkelijk bericht-
Van: Brent DeWitt [mailto:bdew...@ix.netcom.com]
Verzonden: zaterdag 14 januari 2017 2:17
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] lowest emissions 4k TV?

I did some experiments with equipment (Blu-Ray players and TVs) that showed 
that the introduction of an off-the-shelf, poorly constructed, short, cable to 
cable adapter caused a 25 dB increase in radiated emissions at 742.5 MHz in 
1080P HDMI.  The slightest introduction of skew/imbalance on the signal 
combined with a non-ideal shield system introduces enough CM noise back onto 
the outside of the shield to cause problems.  It takes only a very percentage 
of the HDMI specified differential current drive to translate to CM to make a 
1.5 meter cable shield look like a pretty efficient antenna.

Brent DeWitt, AB1LF
Milford, MA

-Original Message-
From: Ralph McDiarmid [mailto:ralph.mcdiar...@schneider-electric.com]
Sent: Friday, January 13, 2017 12:19 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

" I suspect this is just equipment originated CM current, that cannot be cured 
with a better cable; but needs a better equipment CM design. (Or a bunch of 
heavy ferrites)."

I suspect that is the crux of the issue, as it is for many ports on all kinds 
of products.


Ralph McDiarmid
Product Compliance
Solar Business
Schneider Electric




-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl]
Sent: Friday, January 13, 2017 1:01 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

Exactly. Nowadays it's easy to filter high speed ports, and in the case of 
shielded cable this is even more ea

Re: [PSES] lowest emissions 4k TV?

[ce-test, qualified testing bv - Gert Gremmen]

Exactly :
Once the signal is unbalanced (whatever the reason) only shielding can 
attenuate the emissions.
But any unbalance is caused by the EUT at the  sending or  at the receiving 
end, not by the cable.


Gert Gremmen


-Oorspronkelijk bericht-
Van: Brent DeWitt [mailto:bdew...@ix.netcom.com] 
Verzonden: zaterdag 14 januari 2017 2:17
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] lowest emissions 4k TV?

I did some experiments with equipment (Blu-Ray players and TVs) that showed 
that the introduction of an off-the-shelf, poorly constructed, short, cable to 
cable adapter caused a 25 dB increase in radiated emissions at 742.5 MHz in 
1080P HDMI.  The slightest introduction of skew/imbalance on the signal 
combined with a non-ideal shield system introduces enough CM noise back onto 
the outside of the shield to cause problems.  It takes only a very percentage 
of the HDMI specified differential current drive to translate to CM to make a 
1.5 meter cable shield look like a pretty efficient antenna.

Brent DeWitt, AB1LF
Milford, MA

-Original Message-
From: Ralph McDiarmid [mailto:ralph.mcdiar...@schneider-electric.com]
Sent: Friday, January 13, 2017 12:19 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

" I suspect this is just equipment originated CM current, that cannot be cured 
with a better cable; but needs a better equipment CM design. (Or a bunch of 
heavy ferrites)."

I suspect that is the crux of the issue, as it is for many ports on all kinds 
of products.


Ralph McDiarmid
Product Compliance
Solar Business
Schneider Electric




-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl]
Sent: Friday, January 13, 2017 1:01 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

Exactly. Nowadays it's easy to filter high speed ports, and in the case of 
shielded cable this is even more easy.
One aspect that can be a problem is cable length. USB and HDMI are limited in 
length, and in large rooms that can be a problem, needing repeaters, that can 
form  a new problem themselves.

About the cable radiating: If the signal arrives correctly at the end in an 
approved cable, the cable is not radiating. I mean it's not the mere fact that 
data is running that make the cable radiate.  That is why these cable are 
approved and characterized. A radiating signal cable (if due to the
signal) has problems with signal transfer also, especially at this data rates. 
In the case of HDMI the external screen is not needed to protect the signal as 
the data internally is grouped and internally screened (3 or 5 groups).
I suspect this is just equipment originated CM current, that cannot be cured 
with a better cable; but needs a better equipment CM design. (Or a bunch of 
heavy ferrites).

Regards,

Ing. Gert Gremmen
Approvals manager




+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking according to
+ EC-directives:
  - Electro Magnetic Compatibility 2014/30/EC
- Electrical Safety 2014/35/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC

Web:    www.cetest.nl  (English) www.ce-test.nl (Dutch) www.cetest.fr (under
construction)
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information that is 
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Any use of the information contained herein (including, but not limited to, 
total or partial reproduction, communication or distribution in any form) by 
persons other than the designated
recipient(s) is prohibited. If you have received this e-mail in error, please 
notify the sender either by telephone or by e-mail and delete the material from 
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Thank you for your co-operation.

-Original Message-
From: Ken Javor [mailto:ken.ja...@emccompliance.com]
Sent: Friday 13 January 2017 04:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

If I am qualifying a device that connects through a cable to this TV, but not 
the TV itself, why would it physically have to be part of the set-up in the 
test chamber? Why could it not simply be support equipment in an adjacent 
chamber, providing the proper interface at the end of the cable?

Ken Javor
Phone: (256) 650-5261


> From: Doug Smith <d...@emcesd.com>
> Reply-To: <d...@emcesd.com>
> Date: Thu, 12 Jan 2017 16:32:06 -0800
> To: <EMC-PSTC@LISTSERV.IEEE.ORG>, Ken Javor 
> <ken.ja...@emccompliance.com>
> Subject: Re: [PSES] lowest emissions 4k TV?
> 
> Hi Ken,
> 
> Unless you are required to include a 4k TV or other device as part of 
> your t

Re: [PSES] lowest emissions 4k TV?

[ce-test, qualified testing bv - Gert Gremmen]

Exactly. Nowadays it's easy to filter high speed ports, and in the case of 
shielded cable this is even more easy.
One aspect that can be a problem is cable length. USB and HDMI are limited in 
length, and in large rooms that can be a problem, needing repeaters, that can 
form  a new problem themselves.

About the cable radiating: If the signal arrives correctly at the end in an 
approved cable, the cable is not radiating. I mean it's not the mere fact that 
data is running that make the cable radiate.  That is why these cable are 
approved and characterized. A radiating signal cable (if due to the signal) has 
problems with signal transfer also, especially at this data rates. In the case 
of HDMI the external screen is not needed to protect the signal as the data 
internally is grouped and internally screened (3 or 5 groups).
I suspect this is just equipment originated CM current, that cannot be cured 
with a better cable; but needs a better equipment CM design. (Or a bunch of 
heavy ferrites).

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking according to EC-directives:
  - Electro Magnetic Compatibility 2014/30/EC
- Electrical Safety 2014/35/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC

Web:    www.cetest.nl  (English) www.ce-test.nl (Dutch) www.cetest.fr (under 
construction)
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
and are intended for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not 
limited to, total or partial reproduction, communication or 
distribution in any form) by persons other than the designated 
recipient(s) is prohibited. If you have received this e-mail in error, 
please notify the sender either by telephone or by e-mail and 
delete the material from any computer. 
Thank you for your co-operation.

-Original Message-
From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Friday 13 January 2017 04:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] lowest emissions 4k TV?

If I am qualifying a device that connects through a cable to this TV, but not 
the TV itself, why would it physically have to be part of the set-up in the 
test chamber? Why could it not simply be support equipment in an adjacent 
chamber, providing the proper interface at the end of the cable?

Ken Javor
Phone: (256) 650-5261


> From: Doug Smith <d...@emcesd.com>
> Reply-To: <d...@emcesd.com>
> Date: Thu, 12 Jan 2017 16:32:06 -0800
> To: <EMC-PSTC@LISTSERV.IEEE.ORG>, Ken Javor 
> <ken.ja...@emccompliance.com>
> Subject: Re: [PSES] lowest emissions 4k TV?
> 
> Hi Ken,
> 
> Unless you are required to include a 4k TV or other device as part of 
> your test setup!
> 
> Doug
> 
> On Thu, 12 Jan 2017 18:20:05 -0600, Ken Javor 
> <ken.ja...@emccompliance.com> wrote:
> Not proffering a solution here, but the amount of traffic on this 
> topic has
>> surprised me. Back in the day when most testing was on an OATS, I 
>> would have understood the concerns expressed, but nowadays most 
>> testing is performed in a SAC simulating an OATS. With the latter it 
>> is simple to use any off-the-shelf device in an external chamber just 
>> as the appropriate load interface for the test sample, and provide 
>> filtering external to the chamber necessary to clean up any emissions 
>> that could pollute the test chamber ambient. With a shielded cable, 
>> it might be as simple as running it through a stuffing tube and 
>> grounding out the rf current running external to the shield. Or there 
>> could be a high quality shielded cable used in the test chamber, 
>> which connects to a bulkhead-mounted and grounded adapter, and 
>> external to the chamber, the noisy support equipment and any crummy cable 
>> can be used.
>> 
>> Lots of possible variations, but the point is that with a SAC, we 
>> don't have to be near as picky about the support equipment.
>> 
>> Ken Javor
>> Phone: (256) 650-5261
>> 
>> 
>>> From: Ralph McDiarmid <ralph.mcdiar...@schneider-electric.com>
>>> Reply-To: Ralph McDiarmid <ralph.mcdiar...@schneider-electric.com>
>>> Date: Thu, 12 Jan 2017 20:59:57 +
>>> To: <EMC-PSTC@LISTSERV.IEEE.ORG>
>>> Conversation: [PSES] lowest emissions 4k TV?
>>> Subject: Re: [PSES] lowest emissions 4k TV?
>>>> I wonde

Re: [PSES] Thermal equilibrium - 10% rule

[ce-test, qualified testing bv - Gert Gremmen]

Those interested, i cleaned up my temperature prediction spreadsheet 
and if you want to play with it, let me know.
The math is crude, it might even have small errors.

The spreadsheet is prepopulated in column E with data from an calculated RC
network with source (green area), that you can erase, or use it to play with 
base data.
The data is rounded to a settable  number of digits.
Best performance at time sampling of  tau/50 and 2 digits minimum
of resolution of the temperature ( x.xx  degrees).
At 3 digits the prediction is spectacular.

Accuracy won't impact the results. It's the resolution that counts.
With 1 digit of resolution the results are not very usable in terms
of calculation, however your experienced engineers eye may draw conclusions 
anyway.

After an arbitrary number of samples, the sheet calculates the final temperature
tau , end of test time and creates a graph.






Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking according to EC-directives:
  - Electro Magnetic Compatibility 2014/30/EC
- Electrical Safety 2014/35/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC

Web:    www.cetest.nl  (English) www.ce-test.nl (Dutch) www.cetest.fr (under 
construction)
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
and are intended for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not 
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distribution in any form) by persons other than the designated 
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please notify the sender either by telephone or by e-mail and 
delete the material from any computer. 
Thank you for your co-operation.

From: John Allen [mailto:jral...@productsafetyinc.com] 
Sent: Monday 9 January 2017 05:19
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Thermal equilibrium - 10% rule

The subject itself can easily be a presentation at ISPCE.  Doug, what you and 
Gert have done should be a formal paper.  Please consider collaborating and 
making it happen.

John




From: Pete Perkins <0061f3f32d0c-dmarc-requ...@ieee.org>
Sent: Sunday, January 8, 2017 9:33 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Thermal equilibrium - 10% rule 
 
Doug,
 
   A great approach; it would make for an interesting ISPCE/PSES 
presentation and a paper.   Go for it.  
 
:>) br,  Pete
 
Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427
 
503/452-1201
 
p.perk...@ieee.org
 
From: Doug Powell [mailto:doug...@gmail.com] 
Sent: Sunday, January 8, 2017 10:39 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Thermal equilibrium - 10% rule
 
Richard,
 
I have tried a number of approaches in the past.  Given that most products are 
quite complex with regard to all the potential heat sources/sinks and 
interfaces I decided that anything along the lines of FEA is impractical.  
 
I also tried the time constants idea which is analogous to RC time constants.  
I found this works well enough if you have a good amount of history with the 
product itself.  Otherwise, due to the non-linear nature of the problem, it is 
difficult to predict end time or temperature until 3 to 4 time constants have 
already passed.
 
I tried using the slope of ΔT to estimate when the end of the test is pending.
 
The next attempt was to dig in a little following the equations V = Voe-(t/RC) 
and V = Vo[1-e-(t/RC)] where I substitute V for the the various temperatures 
(Vo = the absolute value of the temperature delta from start to end), C is 
analogous to product mass and R is the Rtheta of the product. With a little 
testing history, you can assume the composition of the product is similar for 
other products designed by the same company (copper, steel, plastics, air, 
liquids, etc), I solved for RC and then rearranged the algebra to solve for t 
which is time.  There are a couple of problems in that I am still unable to 
come up with a general purpose solution.  First this is a simultaneous solution 
of several unknowns which is not conducive to quick on the fly solutions.  This 
is especially true when you are in the early stages of a temperature run when 
things are still moving quickly.  As you know extrapolating outside an existing 
dataset is risky, especially when nonlinearities are invo!
 lved.  
 
I am now going back to basics.  Q = Cp * m * abs(T2-T1)
 
q = heat energy in Joules
m = mass of the product
Cp = specific heat of the product

Re: [PSES] Thermal equilibrium - 10% rule

[ce-test, qualified testing bv - Gert Gremmen]

Hi Rich,

The quotient of subsequent derivatives of equidistant samples of the 
temperature has a direct relation
to the time constant.  TC=Timestep/(1-(dtempn+1/dtempn))
Numerically this is easy to calculate in a spreadsheet
Once the time constant is known it is easy to find the temperature value of the 
63.2% of the final temperature.

samples:

time1  - Temp1
time2  - Temp2  (Temp2-Temp1) - - 
time3  - Temp3  (Temp3-Temp2) - - dtemp2/dtemp1
time4  - Temp4  (Temp4-Temp3) - - dtemp3/dtemp2

The quotients in the last column are constant for a true inverse exponential
temperature rise curve (same as a RC circuit). 

Of course , only for simple constant power heating curves that are truly 
exponential.
The third column will quickly show if the curve is exponential or not , if the 
quotients are not all the same,
something more complex is happening.

I hope this is a clear explanation


Regards,

Ing.  Gert Gremmen, BSc
 

 
g.grem...@cetest.nl
www.cetest.nl

Kiotoweg 363
3047 BG Rotterdam
T 31(0)104152426
F 31(0)104154953
 
 Before printing, think about the environment.


-Oorspronkelijk bericht-
Van: Richard Nute [mailto:ri...@ieee.org] 
Verzonden: zaterdag 7 januari 2017 20:51
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] Thermal equilibrium - 10% rule

> We have to consider that the temperatures sought are not of 
> metrological value, but to to establish a safe/non-safe result.

Yes!

> The mathematical limit of an exponential rise is easy to estimate, 
> once a few timed samples are available,

I haven't been able to come up with an equation, even though I have tried and 
sought help from folks who are more knowledgeable than me in the field of 
thermodynamics.  Please tell us your methodology.

Best wishes for the New Year!
Rich

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All emc-pstc postings are archived and searchable on the web at:
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Re: [PSES] Thermal equilibrium - 10% rule

[ce-test, qualified testing bv - Gert Gremmen]

We have to consider that the temperatures sought are not of metrological value, 
but to 
to establish a safe/non-safe result. This means that the whole time constant 
discussion is relevant
only when the final expected temperature is close to the standards limit value.
The mathematical limit of an exponential rise is easy to estimate, once a few 
timed samples are available,
and if that value is far enough above or below the limit, a conclusion is easy 
to draw.

For cyclic heating  equipment, a similar approach is not difficult.

If the cycle is unknown , there is no other option than to wait infinitely.

Unfortunately, any cyclic information is unknown if the test engineer is not 
involved with the
operating principle of the EUT, so if following a black box testing approach, 
the 
measurement will never get to completion !  ;<)

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking according to EC-directives:
  - Electro Magnetic Compatibility 2014/30/EC
- Electrical Safety 2014/35/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC

Web:    www.cetest.nl  (English) www.ce-test.nl (Dutch) www.cetest.fr (under 
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---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
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From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Saturday 7 January 2017 00:32
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Thermal equilibrium - 10% rule

Standards can't necessarily cover every possibility. For cyclical effects, I 
would say that conditions are stable if two successive temperature maxima are 
equal (within a reasonable tolerance). This doesn't necessarily work if more 
than one cycle frequency is involved, in which case you have to look for the 
repetition of the whole sequence, which might take a long time. 

For example, a 10 minute cycle and a 12 minute cycle give a sequence that 
repeats every 60 minutes. 

If you are lucky.

With best wishes DESIGN IT IN! OOO – Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: Friday, January 6, 2017 11:09 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Thermal equilibrium - 10% rule

Thanks!

I'll take a look.  I generally log with LabView or direct into an Excel 
spreadsheet, maybe I can get an Excel VB Script to post expected times.  

One of the concerns I am dealing with now is how to determine stability when 
there are cyclical operations going on.  I am using the prescribed stability 
criteria and using this on the minima/maxima of the temperature variations as 
it moves up and down.  Funny, as I sit starting at thermal data moving in this 
way, I think of it "porpoise-ing" up and down.

All the best,  Doug

-Doug


Douglas E Powell
Laporte, Colorado USA
doug...@gmail.com
http://www.linkedin.com/in/dougp01


On Fri, Jan 6, 2017 at 2:10 PM, Brian O'Connell <oconne...@tamuracorp.com> 
wrote:
Rough pseudo code for my transformer algorithm for logging and monitoring 
temperatures for normal operating conditions:

time constant = (material ksp * mass) / (24*60)
sample interval = time constant / (mass * material kx)
breakpoint flags = false

if sample interval < min interval
   sample interval = min interval

interrupts:
   temperatures to circular buffer
   log samples and windowed averages to network storage

loop:
   for each channel
      verify exponential and set breakpoint flag for each channel
      update thermal lag time
      adjust sample interval if time constant > thermal lag/2
   find least dT/dt channel
   find largest thermal lag time per ambient time per matching indices of 
windowed means
   if all breakpoint flags
      indicate done

Brian


From: Doug Powell [mailto:doug...@gmail.com]
Sent: Friday, January 06, 2017 11:11 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Thermal equilibrium - 10% rule
John,

I agree with the common sense approach and use it frequently.  It's always 
interesting to me how I can look at a screen plot of 60 thermocouples and in a 
second or two decide, "yes this is stable".  I can even estimate how m

Re: [PSES] EM Severity Levels

[ce-test, qualified testing bv - Gert Gremmen]

Hi Douglas,

Each of the Basic Standards from the series EN 61000-4-x ( esp -3,-4,-5, and 
-6) have
their own list of test levels recommended to the committees writing the product 
standard.
In general they are 1,2,3 and X.
Your product standard should not have referred to the test level number but to 
the actual level instead as this obliges customers to buy Basic  standards 
(which are not for product approvals) and costs them more.
Tell us the test phenomenon (RI,EFT,SURGE or other) and I can help you find the 
appropriate level.

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking according to EC-directives:
  - Electro Magnetic Compatibility 2014/30/EC
- Electrical Safety 2014/35/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC

Web:    www.cetest.nl  (English) www.ce-test.nl (Dutch) www.cetest.fr (under 
construction)
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
and are intended for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not 
limited to, total or partial reproduction, communication or 
distribution in any form) by persons other than the designated 
recipient(s) is prohibited. If you have received this e-mail in error, 
please notify the sender either by telephone or by e-mail and 
delete the material from any computer. 
Thank you for your co-operation.

From: Douglas Nix [mailto:d...@mac.com] 
Sent: Wednesday 21 December 2016 13:03
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EM Severity Levels

Fellow listers,

I recently ran into the following text in an EN standard:

“...unit should be tolerable for EMC severity level 3…”

I am trying to track down which IEC standard in the IEC 61000 series defines 
EMC severity levels. If you know which standard this is please let me know.

To all who celebrate Christmas, Merry Christmas! If you celebrate in other ways 
at this time of year, may the joys of the season be yours!

Doug Nix
d...@mac.com
(519) 729-5704


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Re: [PSES] EN 302 195 Distance Conversion Factor

[ce-test, qualified testing bv - Gert Gremmen]

In the close field area E-field/H-field varies with 1/(r^2) OR 1/(^3) depending 
on the source
and nature of it. In addition at close distances similar fields may have an 
opposite
vector polarity (close to EUT) and may partially cancel each other. 
In general it is not a good idea measuring close field components to draw 
conclusions
on radiated emission components at greater distances, as these components do 
not 
actually radiate.
That is why you won’t find any conversion factors for frequencies below 30 MHz,
at distances shorter than the close-far field transition zone. (lambda/2pi)

Of course measurements in this area make sense about the EMI-level  at the 
measurement point,
and that is why some standards make measurements in the close field at a 
predefined distance.
Changing that distance will make measurements incomparable.


 
Regards,

Ing. Gert Gremmen
Approvals manager



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From: Grace Lin [mailto:graceli...@gmail.com] 
Sent: Tuesday 6 December 2016 00:46
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EN 302 195 Distance Conversion Factor

Dear Members,

What is the appropriate distance conversion factor per EN 302 195, 9 kHz - 30 
MHz?  The limits were specified at 10m.  Test data was too low to be detected 
at 10m and 3m.  1m distance was used to collect some data.

EN 300 330 provides a chart for the distance conversion factors between 3m and 
10m.  It seems there is no such information in EN 302 195.

Thank you very much for your time and I look forward to hearing from you.

Best regards,
Grace Lin
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Re: [PSES] dimension of the stud for PE

[ce-test, qualified testing bv - Gert Gremmen]

What I did:

Bought the largest toroidal transformer available (2200 VA), and
used  copper tube (water pipe) or lightning conductors   to create 
one or 2 windings as a temporary
 secondary.  This gives you several volts at 400-500 A  (AC!) before
the primary gets overloaded.

Switch the primary with a solid state relay with ample capacity
 (as ring cores may/will have excessive inrush current), and
appropriate fuse. Use a 9V battery, a resistor and a momentary switch
to feed the SSR.



Feed it with an adjustable power transformer if you want 
to regulate the secundary current.
Most of us do own such a device in the voltage DIP immunity setup,
mine has 4000VA output and can be digitally controlled.
(or use the amplifier of a  Harmonics / Flicker set-up)


Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
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From: IBM Ken [mailto:ibm...@gmail.com] 
Sent: Friday 2 December 2016 00:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] dimension of the stud for PE

I too can vouch for doing the Bonding test to a few hundred amps using a 
Sorensen DC supply (and calibrated V and I meters and stopwatch...)

-Ken

On Thu, Dec 1, 2016 at 5:07 PM, Scott Aldous 
<0220f70c299a-dmarc-requ...@ieee.org> wrote:
I've done this test at several hundred amps before (not to 60950-1, but 
similar). I used an old Sorensen DC power supply (low voltage, high current), 
with external calibrated measurement for both current and voltage drop. Care 
must also be taken in connecting the power supply to the EUT to make sure it is 
low resistance.

On Thu, Dec 1, 2016 at 1:52 PM, John Woodgate <jmw1...@btinternet.com> wrote:
Reminds me of an amusing argument between a student and a 5 V 1000 A MG set, 
observed from a safe distance.
 
With best wishes DESIGN IT IN! OOO – Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England
 
Sylvae in aeternum manent.
 
From: Ted Eckert [mailto:07cf6ebeab9d-dmarc-requ...@ieee.org] 
Sent: Thursday, December 1, 2016 7:11 PM

To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] dimension of the stud for PE
 
The test of 2.6.3.4 does get interesting for high current equipment. I have 
personally run this test only on equipment rated up to 50 A. Even then, it 
required applying a 100 A test current for 4 minutes. For the 130 A rated 
product, you would have a test current of 260 A applied for 8 minutes. 
 
It may not be easy to find a ground bond tester capable of supplying this 
current. I did my testing at 100 A using a transformer salvaged from a large 
scrap uninterruptible power supply. It allowed me to step down a 15 A, 120 V 
circuit to provide the necessary current at a voltage below the 12 V limit. 
With this transformer, only a calibrated volt-meter and current-meter were 
required. 
 
One significant issue with this test setup is that additional care must be 
taken to ensure operator safety. Purchased equipment often has sensors to 
detect a faulty connection or other error that triggers the equipment to shut 
off power quickly. You likely won’t have this in equipment you build yourself 
for such testing. Proper PPE and safety precautions should be used when using 
any high-power equipment, but it may be necessary to talk with your facility 
safety staff as home-built equipment doesn’t come with a user manual telling 
you what is required for safety.
 
The lower voltage used should provide some safety benefit. However, a loose 
connection that comes in contact with an earth-grounded circuit may result in 
significant arcing. Even low voltages should be treated with respect when you 
have high current available. 
 
Ted Eckert
Microsoft Corporation
 
The opinions expressed are my own and do not necessarily reflect those of my 
employer.
 
From: Scott Aldous [mailto:0220f70c299a-dmarc-requ...@ieee.org]

Re: [PSES] DC-power conducted emissions per CISPR11: 2016

[ce-test, qualified testing bv - Gert Gremmen]

This phrase is a typical addition one finds in standards often
as the result of a compromise, where a generic test requirement
has been reduced to a subset.

Regards,

Ing. Gert Gremmen
Approvals manager



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From: Ari Honkala [mailto:ari.honk...@sesko.fi] 
Sent: Monday 28 November 2016 14:38
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] DC-power conducted emissions per CISPR11: 2016

Hi,
the wording in CISPR 11 Clause 6.2.1.1 means that the limits for the LV d.c. 
power port apply only for the DC-side of GCPCs in PV installation, nothing 
else. Repetition later in Tables is not necessary.

Therefore, when CISPR 11 is given as a reference to be applied for emissions, 
d.c. port test applies only when the product in question is a GCPC in PV 
installation.

For the use of the Delta-network with another kind of d.c. power port, a 
product standard needs to refer to CISPR 16-1-2:2014 Clause 4.7 for the AMN.

I hope this clarifies the issue,
with best regards,
Ari Honkala

From: Paolo Roncone [mailto:paoloc...@gmail.com] 
Sent: maanantai 28. marraskuuta 2016 14:56
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] DC-power conducted emissions per CISPR11: 2016

Hi all,

There's also another question that I would like to clarify. There is a 
statement in CISPR 11 (2016) - quoted text below:

"6.2.1 Limits for conducted disturbances
6.2.1.1 General
..
The limits for the LV d.c. power port specified hereafter apply only to grid 
connected power convertors (GCPCs) intended for assembly into photovoltaic 
power generating systems."

So, it seems that this dc-power CE with 150 Ω  Delta-network would not apply to 
medical devices (60601-1-2) and lab equipment (61326-1) unless they are dc-fed 
through a photovoltaic power generating system?

Anyway, I still find the CISPR11 (2016) a bit ambiguous, since this 
"photovoltaic-only" requirement is not repeated or confirmed later on in "Table 
3 – Limits for conducted disturbances of class A group 1 equipment measured on 
a test site (d.c. power port)", except for > 20kVA equipment.
Also, the definition of d.c. power port in sec.3.7:
"port used to connect to a low voltage d.c. power generating system or energy 
storage, or to another source/load
Note 1 to entry: Such a system may be for example a photovoltaic or a fuel cell 
power generating system, or also a battery." doesn't fully clarify. 

So now the question is: is the statement in sec.6.2.1.1 quoted above enough to 
exclude anything not powered through photovoltaic power generatic system from 
the dc-power conducted emissions with 150 Ω Delta-networks? 

Thanks to all who provide feedback!
Paolo

On Mon, Nov 28, 2016 at 11:32 AM, ce-test, qualified testing bv - Gert Gremmen 
<g.grem...@cetest.nl> wrote:
EN 61326-1:2013 makes a date reference to CISPR11:2009+A12010 in its Annex ZA
as well as in article 2.
Par 7.2 also refers to CISPR11:2009 .
The limit references for Class A and B do not refer to a dated CISPR11

While I am convinced this is the kind of carefulness that is common in standards
published by IEC and CENELEC, the normative consequences are that the latest
versions apply.

So yes, since the publication date of  June, 26th 2016 this new
version :

Allows for FAR room measurements
Prescribes limits for DC in/output ports and defines the delta LISN type to be 
used:

"For   measurements   at   LV   d.c.   power   ports   of   power   electronic  
 equipment,   a   modern
implementation  of  the  150 Ω  Delta-network  specified  in  CISPR 16-1-2  has 
 been  made available"

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of ele

Re: [PSES] DC-power conducted emissions per CISPR11: 2016

[ce-test, qualified testing bv - Gert Gremmen]

That may be true, but using a dated reference AND a non-dated reference in one 
article of 6 lines
(assuming one person actually writing/approving this article) is -at least- say 
"surprising".

And I assume that for the basic issues of "writing standards" CENELEC
has a final redaction quality process, checking for standards basics.

Although I must admit that I see no trace of any ISO or other quality
system on their site, where laboratories are supposed to comply 
with ISO 17025
 


Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
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-Original Message-
From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Monday 28 November 2016 12:37
To: ce-test, qualified testing bv - Gert Gremmen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] DC-power conducted emissions per CISPR11: 2016

I don't think it's careless, it's a case of the rules being complicated and not 
stressed enough by committee officers. I have a constant battle in some 
committees to convince people they should at least refer to Directives Part 2 
and preferably to the Guide to iecstd.dot as well. Some do, most don't. The 
CENELEC rules are not quite the same and are fairly inaccessible if you are not 
given the magic URL that leads to them.

With best wishes DESIGN IT IN! OOO – Own Opinions Only www.jmwa.demon.co.uk J M 
Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.


-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl]
Sent: Monday, November 28, 2016 10:57 AM
To: John Woodgate <jmw1...@btinternet.com>; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] DC-power conducted emissions per CISPR11: 2016

When the this distinction between dated AND undated references is so clearly 
made (as in EN 61326-1:2013) this SHOULD mean that  once an undated reference 
is found, it should definitely be read as undated.

If  a standard is to be applied in full, that means it should also include the 
presumed errors until a correction is published.
I agree with you (John), that probably the intention of the committee was to 
give dated references only, and that section ZA and 2 are explicitly meant to 
define this (sec 2 created by IEC, ZA created by CENELEC) .  
The standards text (apart from ZA) should then refrain from dated references at 
all or use some kind of index number to annex ZA when a standard is referred.

And it's a shame that CENELEC (as the latest responsible in the chain) is so 
careless in their published texts.


Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking
 according to EC-directives:
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Re: [PSES] DC-power conducted emissions per CISPR11: 2016

[ce-test, qualified testing bv - Gert Gremmen]

When the this distinction between dated AND undated references is so clearly 
made (as in EN 61326-1:2013)
this SHOULD mean that  once an undated reference is found, it should definitely 
be read as undated.

If  a standard is to be applied in full, that means it should also include the 
presumed errors until a correction is published.
I agree with you (John), that probably the intention of the committee was to 
give dated references only,
and that section ZA and 2 are explicitly meant to define this (sec 2 created by 
IEC, ZA created by CENELEC) .  
The standards text (apart from ZA) should then refrain from dated references at 
all or use some kind of index number to annex ZA when a standard is referred.

And it's a shame that CENELEC (as the latest responsible in the chain) is so 
careless in their published texts.


Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
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    - Electrical Safety 2006/95/EC
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-Original Message-
From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Monday 28 November 2016 11:45
To: ce-test, qualified testing bv - Gert Gremmen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] DC-power conducted emissions per CISPR11: 2016

Yes, there is an issue even with the latest Directives Part 2. It isn't clear 
whether a reference can be dated in some places in the text and dated in 
others.  In my opinion, if it's dated in Clause 2 Normative references it is 
dated throughout the document. 

With best wishes DESIGN IT IN! OOO – Own Opinions Only www.jmwa.demon.co.uk J M 
Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.


-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl]
Sent: Monday, November 28, 2016 10:32 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] DC-power conducted emissions per CISPR11: 2016

EN 61326-1:2013 makes a date reference to CISPR11:2009+A12010 in its Annex ZA 
as well as in article 2.
Par 7.2 also refers to CISPR11:2009 .
The limit references for Class A and B do not refer to a dated CISPR11

While I am convinced this is the kind of carefulness that is common in 
standards published by IEC and CENELEC, the normative consequences are that the 
latest versions apply.

So yes, since the publication date of  June, 26th 2016 this new version :

Allows for FAR room measurements
Prescribes limits for DC in/output ports and defines the delta LISN type to be 
used:

"For   measurements   at   LV   d.c.   power   ports   of   power   electronic  
 equipment,   a   modern   
implementation  of  the  150 Ω  Delta-network  specified  in  CISPR 16-1-2  has 
 been  made available"

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing Education

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Phone :  +31 10 415 24 26
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recipient(s) is prohibited. If you have received this e-mai

Re: [PSES] DC-power conducted emissions per CISPR11: 2016

[ce-test, qualified testing bv - Gert Gremmen]

I need to add to that, that referring to limits in a harmonised standard by 
referencing a (yet)
unharmonised standard is against all principles of the system.

The standard EN 61326-1:2013 annex ZA is very clear about it:

"The following documents, in whole or in part, are normatively referenced in 
this document and are
indispensable for its application. For dated references, only the edition cited 
applies. For undated
references, the latest edition of the referenced document (including any 
amendments) applies.
NOTE When an international publication has been modified by common 
modifications, indicated by (mod), the relevant EN/HD
applies."

The latter phrase suggests that EN 55011:2016 is used instead of CISPR 11:2015 
for which a DOP of 17-02-2017
is given as its status clearly references CISPR11:2015(mod)

This may give you a few months


Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
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    - Electrical Safety 2006/95/EC
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-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] 
Sent: Monday 28 November 2016 11:32
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] DC-power conducted emissions per CISPR11: 2016

EN 61326-1:2013 makes a date reference to CISPR11:2009+A12010 in its Annex ZA 
as well as in article 2.
Par 7.2 also refers to CISPR11:2009 .
The limit references for Class A and B do not refer to a dated CISPR11

While I am convinced this is the kind of carefulness that is common in 
standards published by IEC and CENELEC, the normative consequences are that the 
latest versions apply.

So yes, since the publication date of  June, 26th 2016 this new version :

Allows for FAR room measurements
Prescribes limits for DC in/output ports and defines the delta LISN type to be 
used:

"For   measurements   at   LV   d.c.   power   ports   of   power   electronic  
 equipment,   a   modern   
implementation  of  the  150 Ω  Delta-network  specified  in  CISPR 16-1-2  has 
 been  made available"

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking
 according to EC-directives:
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Phone :  +31 10 415 24 26
---
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Any use of the information contained herein (including, but not limited to, 
total or partial reproduction, communication or distribution in any form) by 
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From: Paolo Roncone [mailto:paoloc...@gmail.com]
Sent: Monday 28 November 2016 10:25
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] DC-power conducted emissions per CISPR11: 2016

Hi all,

the new 2016 edition of CISPR11 requires DC power ports conducted emissions to 
be done with a "150 Ohm CISPR Delta-network (DC-AN) – see CISPR11 ed.6.1 (2016) 
sec. 6.2.1.3, 7.3.2.3 and Annex I) instead of a "standard" 50uH/50ohm V-LISN, 
used for AC-power conducted emissions and also 

Re: [PSES] DC-power conducted emissions per CISPR11: 2016

[ce-test, qualified testing bv - Gert Gremmen]

EN 61326-1:2013 makes a date reference to CISPR11:2009+A12010 in its Annex ZA
as well as in article 2.
Par 7.2 also refers to CISPR11:2009 .
The limit references for Class A and B do not refer to a dated CISPR11

While I am convinced this is the kind of carefulness that is common in standards
published by IEC and CENELEC, the normative consequences are that the latest
versions apply.

So yes, since the publication date of  June, 26th 2016 this new
version :

Allows for FAR room measurements
Prescribes limits for DC in/output ports and defines the delta LISN type to be 
used:

"For   measurements   at   LV   d.c.   power   ports   of   power   electronic  
 equipment,   a   modern   
implementation  of  the  150 Ω  Delta-network  specified  in  CISPR 16-1-2  has 
 been  made available"

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
    - Electro Magnetic Compatibility 2004/108/EC
    - Electrical Safety 2006/95/EC
    - Medical Devices 93/42/EC
    - Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:    www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
and are intended for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not 
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please notify the sender either by telephone or by e-mail and 
delete the material from any computer. 
Thank you for your co-operation.

From: Paolo Roncone [mailto:paoloc...@gmail.com] 
Sent: Monday 28 November 2016 10:25
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] DC-power conducted emissions per CISPR11: 2016

Hi all,

the new 2016 edition of CISPR11 requires DC power ports conducted emissions to 
be done with a "150 Ohm CISPR Delta-network (DC-AN) – see CISPR11 ed.6.1 (2016) 
sec. 6.2.1.3, 7.3.2.3 and Annex I) instead of a "standard" 50uH/50ohm V-LISN, 
used for AC-power conducted emissions and also for AC power conducted 
emissions according to IEC/EN 61000-6-3, CISPR22 and other standards.

That means - to my understandiing - that DC-powered Laboratory equipment 
(tested per IEC/EN 61326-1, sec. 7.2) and Medical devices (tested according to 
IEC 60601-1-2 (sec.7.1.1) must be tested with the Delta-LISN for DC-power 
conducted emissions.

Is my understanding correct?

Best regards,
Paolo 
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Re: [PSES] Public view of this email server?

[ce-test, qualified testing bv - Gert Gremmen]

+1

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
    - Electro Magnetic Compatibility 2004/108/EC
    - Electrical Safety 2006/95/EC
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    - Radio & Telecommunication Terminal Equipment 99/5/EC
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---
This e-mail and any attachments thereto may contain information 
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From: Ed Price [mailto:edpr...@cox.net] 
Sent: Tuesday 22 November 2016 10:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Public view of this email server?

This does come as a surprise to me. I had thought that the email archive was 
searchable by being stored on the IEEE host, but I did not realize that anyone, 
anywhere in the World, could observe the conversations with a Google search 
external to the IEEE. I don’t think this is what we intended to do when this 
forum was set up as a private membership reflector email system.

I would think that many compliance professionals, knowing that their 
affiliations and comments could be publicly observed, would be cowed into 
participating at only the most superficial level of technical and legal 
content. I generally believe in a free flow of information, but knowing that 
your every word can be monitored and used for whatever purpose by anyone 
capable of a keyword search simply has to have a chilling effect on candor 
within the regulatory compliance community. Or from a different perspective, 
what value does such openness return to our members and the regulatory 
compliance community?

Since our forum still displays a notable lack of spam, I assume that membership 
in our forum (required for posting) is still personally controlled by our 
admins (and a word of thanks to them for their service). 

Ed Price
WB6WSN
Chula Vista, CA USA

From: Dan Roman [mailto:danp...@verizon.net] 
Sent: Monday, November 21, 2016 5:34 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Public view of this email server?

See the footer attached to every message:

All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html



--
Dan Roman
dan.ro...@ieee.org




 Original message 
From: "Kortas, Jamison" <jamison.kor...@ecolab.com> 
Date: 11/21/16 1:43 PM (GMT-06:00) 
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: [PSES] Public view of this email server? 
Hi All,
 
Maybe I am the only one who didn’t know this, but I found a thread in which I 
had I participated in a Google search. I did not know these emails were public 
in some way, at least enough to be found and indexed by Google.
 
Just an FYI.
 
The thread I found: 
https://www.mail-archive.com/emc-pstc@listserv.ieee.org/msg72464.html
 
-Jamison
-

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Attachments are not permitted but the IEEE PSES Online Communities sit

Re: [PSES] EU EMC Harmonized Standards (2014/30/EU) for Audio Power Amplifiers

[ce-test, qualified testing bv - Gert Gremmen]

For professional equipment
EN 55103-1 and -2 apply  !

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
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Web:www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
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From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Friday 11 November 2016 22:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU EMC Harmonized Standards (2014/30/EU) for Audio Power 
Amplifiers

EN 55032 applies, and EN 61000-3-2. Audio amplifiers are in EN 61000-3-2 Class 
A. For immunity, EN 55020 still, until EN 55035 is finalized.


With best wishes DESIGN IT IN! OOO – Own Opinions Only
www.jmwa.demon.co.uk <http://www.jmwa.demon.co.uk/>  J M Woodgate and 
Associates Rayleigh England

Sylvae in aeternum manent.

From: Grace Lin [mailto:graceli...@gmail.com] 
Sent: Friday, November 11, 2016 9:04 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU EMC Harmonized Standards (2014/30/EU) for Audio Power 
Amplifiers

Dear Members,

Could you please advise the appropriate EU EMC harmonized standards for audio 
power amplifiers?

For radiated and AC mains disturbances,  I think EN 55032 fits.  Please let me 
know if it is not.

For immunity tests,  the title of EN 55024 seems not fit very well.  Though 
CISPR 35 was published, OJ has not published it (EN 55035?).  Should a generic 
standard (EN 61000-6-1 or EN 61000-6-2) be used?

Thank you very much!

Best regards,
Grace Lin
 
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-

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-

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Re: [PSES] Bulk Current Injection

[ce-test, qualified testing bv - Gert Gremmen]

I have no definite answer either but a few suggestions….

*   To prevent RF current to flow away (re-radiate) from the test setup 
though the capacitance between cable and clamp. Necessary of the generator is 
"remote".
*   The opposite: get rid of common mode voltages on the generator 
(=amplifier) output that might couple in on the cable under test

There is probably not a real reason, but the decision was  part of was thought 
to be good craftsmanship.


Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
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Any use of the information contained herein (including, but not 
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From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Friday 11 November 2016 04:28
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Bulk Current Injection

Does anyone on this forum know why the current injection clamp must be 
grounded? I can’t think of a reason for that.

Ken Javor
Phone: (256) 650-5261


From: "Kunde, Brian" <brian_ku...@lecotc.com>
Reply-To: "Kunde, Brian" <brian_ku...@lecotc.com>
Date: Thu, 10 Nov 2016 15:22:39 +
To: <EMC-PSTC@LISTSERV.IEEE.ORG>
Conversation: [PSES] Bulk Current Injection
Subject: Re: [PSES] Bulk Current Injection

Three things to keep in mind with the 61000-4-6 Conducted Immunity test when 
using clamps;
 
1.  There two types of clamps; The Current Clamp which must be grounded via 
the BNC connector and a short strap to the Reference Ground Plane, and The EM 
clamp which most commercially available models have grounding pads on the 
bottom which touches the Reference ground plane; so with these the ground strap 
is not needed. 


2.  The entire Test Setup must not be directly grounded to Earth or the 
Ground Reference Plane. The entire EUT is slightly floating off of ground 
through the impedance created by the CDNs and placed on 10cm platforms above 
the GRP.


3.  There must always be at least TWO coupling devices in the test setup 
(see reason below).  You must provide a loop or return path for the energy you 
are injecting.

If you are testing an EUT with no I/O and only one port with a CDN attached, 
then you must add a second CDN (CDN-M1) to the chassis ground of the EUT to the 
Ground Plane. If the EUT has a dedicated ground earth terminal, you can connect 
a CDN-M1 from it to the Ground Plane. 

If the EUT does not have a ground (Class 2 device or all plastic chassis) then 
you can wrap the EUT in aluminum foil and connect it to the ground plane via a 
CDN-M1. 

The only setup picture in the standard that really shows this configuration in 
Figure F.2. Note without the CDN-M1 the EUT would only have one CDN attached. 
Like I said before; you must have at least two CDN devices in the test setup. 



It would be most difficult to do in an In-Situ setup for the 4-6 test. If you 
cannot keep the EUT from shorting directly to ground, either directly or 
through one of the EUTs, then you cannot do the test. The Standard does not 
give a test setup for in-situ testing. 


See section 7.7 when using a clamp where you cannot met the common mode 
impedance requirements:
 
“When using clamp injection, and the common mode impedance requirements cannot 
be met
at the AE side, it is necessary that the common mode impedance of the AE be 
less than or
equal to the common mode impedance of the EUT port being tested. If not, 
measures shall be
taken (e.g. by using a CDN-M1 or 150 : resistor from the AE to ground) at the 
AE port to
satisfy this condition and to prevent resonances”
 
I hope this was helpful.
The Other Brian
 
 
 
 

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Wednesday, November 09, 2016 10:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Bulk Current Injection

Are you using the 

Re: [PSES] Automated vehicles.

[ce-test, qualified testing bv - Gert Gremmen]

In IOT land the rock will warn the cars before it falls…..  ;<)

 

Gert

 

 

Van: alfred1520list [mailto:alfred1520l...@gmail.com] 
Verzonden: maandag 7 november 2016 20:39
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] Automated vehicles.

 

 

On November 7, 2016 9:03:11 AM PST, Ted Eckert 
<07cf6ebeab9d-dmarc-requ...@ieee.org> wrote:

With a little imagination, I can come up with many scenarios that appear 
“no-win”. Imagine you are driving down a mountain road with a rock face on one 
side and a long drop off a cliff on the other. Vehicle to vehicle 
communications allow your self-driving vehicle to stay close to the car in 
front of you. It is a straight road and high speeds are allowed. Now imaging a 
rock slide starts dropping a large boulder onto the roadway. The vehicle in 
front of yours may hit the rocks, but it remains intact enough to protect its 
occupants. Your vehicle can either hit the vehicle in front of you potentially 
injuring its passengers or take evasive action risking your health. What does 
the vehicle do?

 

I live in the state of Washington where rock slides are common. 

http://www.dnr.wa.gov/programs-and-services/geology/geologic-hazards/landslides 

 

http://komonews.com/news/local/rock-slide-closes-highway-2-in-central-wash 
 

http://www.nbcnews.com/id/9957369/ns/us_news-life/t/rock-slide-closes-major-highway-washington/#.WCCyMIWcGeE
 

 

 

Maybe vehicles will need to be programmed to have a much greater following 
distance in areas where there is a rock slide risk. However, there are many 
places where a tree can fall on the road, large animals can jump out or a child 
could run out into the road unexpectedly. 

 

These aren’t situations that are new with self-driving cars. They just create a 
new issue of liability. 

 

Ted Eckert

Microsoft Corporation

 

The opinions expressed are my own and do not necessarily reflect those of my 
employer.

 

From: alfred1520list [mailto:alfred1520l...@gmail.com] 
Sent: Monday, November 7, 2016 8:16 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Automated vehicles.

 

Obviously I can't think of all possibilities, but it seems to me that these 
sort of situations must be corner cases. After all I have never found myself in 
a situation where my only options are to hit a person or go down a 300 m cliff 
at 100 km/h. Further more, I won't be driving at 100 km/h when there is a cliff 
where I can go down!It's called defensive driving. I am sure defensive driving 
is programmed into all self driving cars so they are much less likely to be in 
this sort of situation. The only exceptions that I can imagine are deliberate 
acts on the part of the person.

On November 7, 2016 5:06:36 AM PST, Jim Hulbert  wrote:

So a Mercedes automated vehicle would make the decision of who lives 
and who dies. That’s incredible.

 

Jim Hulbert

 

From: Pawson, James [mailto:james.paw...@echostar.com] 
Sent: Monday, November 07, 2016 6:23 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Automated vehicles.

 

This article in The Guardian is related to your first point regarding 
human drivers “gaming” driverless cars to gain an advantage

 


https://www.theguardian.com/technology/2016/oct/30/volvo-self-driving-car-autonomous

 

“The first self-driving cars to be operated by ordinary British drivers 
will be left deliberately unmarked so that other drivers will not be tempted to 
“take them on”, a senior car industry executive has revealed.”

 

Also

 

“Meanwhile, Mercedes has made it clear that if a situation arises where 
a car has to choose between saving the lives of its occupants or those of 
bystanders, it will save the occupants. ‘If you know you can save at least one 
person, at least save that one. Save the one in the car,’ Christoph von Hugo, 
manager of driver assistance systems and active safety at Mercedes, told the 
Paris Motor Show recently.”

 

Bruce Schneier writes a lot on security issues and regularly covers IoT 
and occasionally driverless vehicles. His blog makes for interesting reading - 
https://www.schneier.com/  I’m sure it will end up being the usual round of 
addition of features, poor programming/testing (due to budget constraints), 
vulnerabilities, exploiting, patching, public outcry, legistlation, etc.

 

All the more reason to buy a bicycle.

 

James

 

 

 

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: 06 November 2016 02:17
To: EMC-PSTC@LISTSERV.IEEE.ORG

[PSES] Where have the leak proof batteries gone ?

[ce-test, qualified testing bv - Gert Gremmen]

Slightly  off-topic may be but.

Since a number of years, professional (penlite and other size) batteries
used in test en measurement equipment in my office
(notably those of Duracell (Procell)) seem not
to be leak proof anymore.

In my younger years  (and that is not that long ago) batteries
where sold as leak-proof, an important sales argument.

Is this something of the old days, or is it not
opportune anymore to build quality penlites?

I have recently been cleaning for thousands of euro's
of equipment that after an extended period of no-use
(say 1-2 years) had there battery equipment full of
liquid and white powder.

A spare 9V (new) battery of the forenamed brand 
(laying around in my service suitcase) literally exploded
in side.

My Fluke portable power analyser had to be  thoroughly cleaned
after its batteries gave up.
The problem seems worst for batteries that do not
actually get used, but empty over time.

Any recommendations for a reliable brand available
world wide ?


Regards,

Ing. Gert Gremmen
Approvals manager




+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
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Re: [PSES] Operating temperature range for consumer electronics & electrical appliances

[ce-test, qualified testing bv - Gert Gremmen]

In general 10-40 degrees Celcius is sufficient for indoor use.
Most batteries keep enough energy to get the product started/operating,
but I personally have experienced Iphones that crash when taking pictures 
outdoors in winter.
( below say 5 degrees Celcius)
Same for (some) canon cameras (probably others too) operating from ordinary 
rechargeable penlites. 

It did not prevent most manufacturers to just specify 10-40 degrees,
and since consumers never read this stuff (do consumers ever read ? If they did
so we would not call them consumers !) it obviously does not stop them
from consuming when it's cold anyway. 

When integrating products into larger systems I use this range for
non-specified products. It means that the inside temperature of these
systems should not exceed 40 degrees, and this is very confronting
to some manufacturers, used to integrate OEM stuff inside. 

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
    - Electro Magnetic Compatibility 2004/108/EC
    - Electrical Safety 2006/95/EC
    - Medical Devices 93/42/EC
    - Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

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Phone :  +31 10 415 24 26
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From: Scott Xe [mailto:scott...@gmail.com] 
Sent: Saturday 5 November 2016 17:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Operating temperature range for consumer electronics & 
electrical appliances

Hi Adam,

Thanks for your views/comments!

In summary, most of suppliers produce uniform products for all countries 
including very cold weather ones.  If the products are used indoors, the 
ambient temperature would not go to low temperature extreme.  Thus general 
consumers including those lived in very cold areas do not need special design 
of products.

If the product is transported from outdoors to customer house, a once-off 
warm-up time could be tolerated by most of consumers.

For products used in tough environment, special design is required and cost is 
higher for small group of users only. 

Regards,

Scott


From: Adam Dixon <lanterna.viri...@gmail.com>
Date: Saturday, 5 November 2016 at 7:21 PM
To: Scott Xe <scott...@gmail.com>
Cc: <EMC-PSTC@listserv.ieee.org>
Subject: Re: [PSES] Operating temperature range for consumer electronics & 
electrical appliances

Hi, Scott,

 
Apple informs its customers about temperature extremes and battery/device 
performance in an easy-to-find article titled "Keeping iPhone, iPad, and iPod 
touch within acceptable operating temperatures."  Apple users in Norway should 
have the same hardware as those in the US, so should be no unique thermal 
design for Norway. 
All consumer electronics manufacturers should have 
transportation/storage/operating temperature ranges, though it is difficult 
sometimes to locate the numbers in their documentation.  I designed with LCD 
panels for several years and there are similar design challenges with liquid 
crystal temperature behavior at high/low temperature extremes.  There was one 
panel design for worldwide use.  Only when the panel was being designed into a 
product for outdoor use (ex:  digital signage), were additional heating/cooling 
hardware added to ensure the panel itself stayed within the required liquid 
crystal temperature range. 

In the case of EU consumer electronics, the TV's listed on Tesco's site look 
quite similar to those on WalMart's and both have travelled from factories in 
Asia, so the temperature ranges are likely identical or very similar (though 
difficult to locate!).  I expect your concern is more for portable electronics 
like cell phones and tablets?  

For larger appliances like the refrigerator and washer that you mention, there 
typically would be a temperature transition time associated with the delivery 
and installation which would likely satisfy the operating range (i.e. warm up 
to within operating range before being powered on for the first time).  While 
not related to the EU consumer electronics marke

Re: [PSES] ETSI EN 302 195 V2.1.1

[ce-test, qualified testing bv - Gert Gremmen]

>Harmonised Standard covering the essential requirements of article 3.2 of the 
>Directive 2014/53/EU

This phrase can mean only one thing: meant to be used as a Harmonized standard 
in the sense of the directive as OJ publication.

ETSI should have written : "Intended to be harmonized….", as it is not the 
standard that
could claim the harmonization property, but the  OJ publication only.

The discussion if a standard is harmonized in any other way is not relevant. 
Standards are by definition
a harmonisation (in the generic sense)  instrument.

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
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Thank you for your co-operation.

From: Grace Lin [mailto:graceli...@gmail.com] 
Sent: Wednesday 2 November 2016 15:39
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] ETSI EN 302 195 V2.1.1

Dear Members,

The title on the cover page of the ETSI EN 302 195 V2.1.1 states:

"
Short Range Devices (SRD);
Ultra Low Power Active Medical Implants (ULP-AMI) and accessories (ULP-AMI-P) 
operating in the frequency range 9 kHz to 315 kHz
Harmonised Standard covering the essential requirements of article 3.2 of the 
Directive 2014/53/EU
"

This standard has not been published on OJ (as October 14, 2016).  Can a 
Declaration of Conformity list this standard to demonstrate compliance with the 
essential requirements?

Thank you very much and I look forward to hearing from you.

Best regards,
Grace Lin

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Re: [PSES] FW: [PSES] IEC 62368-1

[ce-test, qualified testing bv - Gert Gremmen]

We are all used to that odor, we work with standards right ?
They are "expired" before first print.

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
    - Electro Magnetic Compatibility 2004/108/EC
    - Electrical Safety 2006/95/EC
    - Medical Devices 93/42/EC
    - Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:    www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
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From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org] 
Sent: Thursday 20 October 2016 14:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] IEC 62368-1

John, et al,

    Just remember that this is a dynamic document and any 
circulated version will, like fish left lying around, age rather quickly and 
leave an unpleasant odor behind.  

    The up-to-date version remains within the TC 108 pile of 
records.  

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

p.perk...@ieee.org

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Thursday, October 20, 2016 12:40 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] IEC 62368-1

It's only 16 kB, so it's not size that is the problem. The copy-and paste 
version came through to me. This may help:

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

With best wishes DESIGN IT IN! OOO - Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

From: Lovell, Paul [mailto:paul.lov...@ul.com] 
Sent: Thursday, October 20, 2016 6:32 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] FW: [PSES] IEC 62368-1

Hi All,

I spoke to the Secretary of IEC TC 108 and he is happy to share the current 
state of affairs. However, it's in the form of an Excel spreadsheet which 
exceeds the maximum size permitted by this message board [I know, I tried to 
copy-and-paste it - the message bounced back].

If anyone can let me know how, I will send it on.

Best regards,

Paul


Paul Lovell
Senior Project Engineer
Health Sciences Regulatory Group
-
UL International (UK) Ltd.
Wonersh House, The Guildway, Old Portsmouth Road
Guildford, Surrey, GU3 1LR, United Kingdom.
T: +44.1483.402006
T: +44.746.908.2581
F: +44.1483.302.230
W: ul.com

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Re: [PSES] Criteria for determining industrial vs. non-industrial for EMC testing purposes

[ce-test, qualified testing bv - Gert Gremmen]

>The 'prohibition' also results in no requirement for warning notices to the 
>user – a 'shot in foot' result.

Article 18.2 2014/30/EC requires such a warning on the EUT itself if meant for 
Industrial

The EU is rather undecided -as John says- on what is "Industrial", or is it 
"Heavy Industrial"
and the generic standard for "heavy Industrial" refers to " Industrial" 
environment only, and even worse refers to the definition in CISPR11 for 
Industrial, a standard it is supposed to *guide* , instead to refer to.
But of course EN 61000-6-2 is written by Cenelec , not by the European 
Commission. A smart way of circular reasoning.


Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
    - Electro Magnetic Compatibility 2004/108/EC
    - Electrical Safety 2006/95/EC
    - Medical Devices 93/42/EC
    - Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:    www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
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From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Wednesday 19 October 2016 09:05
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Criteria for determining industrial vs. non-industrial for 
EMC testing purposes

I'm not unsure. Class A is for heavy industry, powered from MV or higher, with 
no broadcast receivers likely within 30 m.

The real difference between Europe and the Americas is that in Europe, there is 
a vain attempt to prohibit the use of Class A devices out of industrial areas, 
whereas in the Americas it is recognized that this can (fairly rarely) occur 
and requires the *user* to be warned accordingly.

The attempt to prohibit is vain because the *user* is not addressed by the 
legislation, and unless actual interference occurs, the transgression passes 
unnoticed. The 'prohibition' also results in no requirement for warning notices 
to the user – a 'shot in foot' result.

With best wishes DESIGN IT IN! OOO – Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

From: Kortas, Jamison [mailto:jamison.kor...@ecolab.com] 
Sent: Tuesday, October 18, 2016 8:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Criteria for determining industrial vs. non-industrial for 
EMC testing purposes

Thanks all – at least I am not the only one unsure. 

I am trying to establish a set of criteria that I can ask our engineers and 
marketers that will determine the classification. A decision tree, if you will. 
 This arose from a device that met the less stringent criteria, but not the 
more stringent and then what to do. To prevent the need to debate this topic 
over and over, I was hoping to establish a go forward approach.  Ideally, that 
approach would be “design for both industrial AND non-industrial and be done 
with it.” However, other factors are at play than just my druthers.

-Jamison

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Tuesday, October 18, 2016 12:44 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Criteria for determining industrial vs. non-industrial for 
EMC testing purposes

For Europe, the sources are the Generic standards, which are substantially 
consistent with CISPR 11.

With best wishes DESIGN IT IN! OOO – Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

From: Doug Nix [mailto:d...@ieee.org] 
Sent: Tuesday, October 18, 2016 5:25 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Criteria for determining industrial vs. non-industrial for 
EMC testing purposes

My understanding has always been based on the Class and Group designations in 
CISPR 11 / EN 55011 for ISM equipment (based on the 2009 edition):

5.3 Division into classes
Class A equipment is equipment suitable for use in all establishments other 
than domestic and
those directly connected to a low voltage power supply network which supplies 
buildings used
for domestic purposes.

Class A equipment shall meet class A limi

Re: [PSES] Criteria for determining industrial vs. non-industrial for EMC testing purposes

[ce-test, qualified testing bv - Gert Gremmen]

There is an on-going (silent) conflict between the European commission and a
number of  cenelec and cispr committees, notably those responsible
for EN 55032 and EN 55011.
While the EC has expressed their opinion in the generic standards,
and expressed their desire that all product committees comply with
the definitions and limit therein, the market (standard committees) does not 
comply to that,
and the EC lacks power (or will) to change that.
Therefore the discrepancy between definitions.

Note that it’s a rather complex matter as the standards are born as Worldwide 
standards (CISPR) and are “common modified” to EN versions.
So CISPR11 (world wide) becomes EN 55011 (Europe harmonised)  without
changing the “Industrial” definition. 


Regards,

Ing.  Gert Gremmen, BSc
 

 
g.grem...@cetest.nl
www.cetest.nl

Kiotoweg 363
3047 BG Rotterdam
T 31(0)104152426
F 31(0)104154953
 
 Before printing, think about the environment.



Van: Doug Nix [mailto:d...@ieee.org] 
Verzonden: dinsdag 18 oktober 2016 18:25
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] Criteria for determining industrial vs. non-industrial 
for EMC testing purposes

My understanding has always been based on the Class and Group designations in 
CISPR 11 / EN 55011 for ISM equipment (based on the 2009 edition):

5.3 Division into classes
Class A equipment is equipment suitable for use in all establishments other 
than domestic and
those directly connected to a low voltage power supply network which supplies 
buildings used
for domestic purposes.

Class A equipment shall meet class A limits.
Warning: Class A equipment is intended for use in an industrial environment. In 
the
documentation for the user, a statement shall be included drawing attention to 
the fact that
there may be potential difficulties in ensuring electromagnetic compatibility 
in other
environments, due to conducted as well as radiated disturbances.
Class B equipment is equipment suitable for use in domestic establishments and 
in
establishments directly connected to a low voltage power supply network which 
supplies
buildings used for domestic purposes.
Class B equipment shall meet class B limits.

The key in all of this is the source of power supply for the equipment. If the 
equipment is supplied from mains that are shared with domestic establishments, 
then it must meet Class B requirements IMO.

If the equipment is intended for industrial use, i.e., Class A, where the power 
supply from the mains is not shared with domestic establishments, then Class A 
performance is acceptable.

The deciding factor is the sharing of the supply with domestic establishments. 
If a location is fed from its own substation and there are no dwellings 
supplied from that substation, it’s an industrial location, and therefore Class 
A.

Doug Nix
d...@ieee.org
+1 (519) 729-5704

On 18-Oct-16, at 08:44, Kortas, Jamison <jamison.kor...@ecolab.com> wrote:

Good Morning,
 
What do you use for criteria when reviewing the intended environment in which a 
device will be placed to determine if it is industrial or non-industrial? I 
have seen and read varying opinions on what criteria to use.
 
It ranges from a transformer isolated factory to the nature of the other 
products in the immediate vicinity (a mechanical room in a grocery store = 
industrial due to the equipment in its immediate environment).
 
I am familiar with some of the definitions in places, but am not so sure that 
those are what are typically followed in practice.
 
I appreciate any thoughts. 
 
Thank you.
 
 
-


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<emc-p...@ieee.org>
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This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
<emc-p...@ieee.org>
All emc-pstc postings are archived and searchable on the web at: 
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 

Re: [PSES] When is EMI testing performed?

[ce-test, qualified testing bv - Gert Gremmen]

May i try another coding ?

While testing<>end
call (nobeer)
call collegues(headache)
call nopromotion(this year)
end while
If testresult= pass then 
call pub(beer)
else
fired(now)
end if


Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
    - Electro Magnetic Compatibility 2004/108/EC
    - Electrical Safety 2006/95/EC
    - Medical Devices 93/42/EC
    - Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:    www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
and are intended for the sole use of the recipient(s) named above. 
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recipient(s) is prohibited. If you have received this e-mail in error, 
please notify the sender either by telephone or by e-mail and 
delete the material from any computer. 
Thank you for your co-operation.


-Original Message-
From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Wednesday 5 October 2016 15:05
To: ce-test, qualified testing bv - Gert Gremmen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] When is EMI testing performed?

I'd like to write this using the puzzling math symbols 'inverted A' and 
'reversed E', but it's too much of a hassle, so you have to imagine them:

For all [EMC/EMP tests], there exists [ending]. There exists [ending] = 
[happy]. IFFI [ending] = [happy], then there exists [beer]. 

With best wishes DESIGN IT IN! OOO – Own Opinions Only www.jmwa.demon.co.uk J M 
Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.


-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl]
Sent: Wednesday, October 5, 2016 1:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] When is EMI testing performed?

Thanks Ed,

In spite of -not much to be learned- , I do appreciate sharing.
May I conclude that many EMC/EMP tests have a happy end... and beer ?

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
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From: Ed Price [mailto:edpr...@cox.net]
Sent: Wednesday 5 October 2016 13:34
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] When is EMI testing performed?

Gert:

I really don’t have all that much experience with EMP testing; in the past 12 
years, I have put three systems through HIRF & EMP using the USN facilities at 
Patuxent River, MD.

• System 1 was an airborne instrumentation pod that had a secure data link back 
to ground assets. We were lucky that the entire airborne portion of the system 
was contained in a streamline pod, so except for the intentional signal ports 
and the aircraft power interface, the pod provided complete metallic SE. We 
concentrated on bandwidth limiting the ports, filtering and limiting the power 
interface, and on mechanical build of the pod skin. We passed without incident, 
so it could be argued that we also didn’t learn anything.
• System 2 was the ground segment of an unmanned airborne vehicle secure data 
link. This was essentially a pedestal mounted parabolic tracking antenna with 
some signal processing boxes. During RS103, we found unexpected failures, 
tracing them to a rotary slip-ring joint o