Well, how to answer this? I would say that I feel sympathetic to his particular
problem, but I am not in favor of eliminating rules which exist to protect the
rest of us from side effects of products they sell.
Yes, stand
ar
ds can eliminate minor manufacturers, like the family computer business dow
n the street, which is (they don't care) busy turning out RF generators. I
listen to radio, and there's no reason why even minor manufacturers should be
allowed to flood the market with interference-generating RF sources.
As usual, these statements do not reflect opinions or policies of my employer.
Regards,
Cortland
Maybe you are not sympathetic but you should be. EMC means eliminate minor
companies. The way the rules are developed in many cases have little to do
with the actual importance of the issue. Comparing regulatory requirements
to the rules of physics is like comparing apples to oranges. If we do not
question the need and validity for regulatory requirements we will find it
increasingly difficult to deliver products. There many people out there
eager to travel to far away places to develop additional requirements for
us. We should ensure the requirements are necessary not just blindly
accept everything. I applaud the people who question and probe the real
need for requirements.
Dave George
Unisys Corp.
----------
>From: owner-emc-pstc
>To: IEEE PSTMC
>Subject: Re: Shiep rules
>Date: Sunday, December 22, 1996 1:18PM
>
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>Date: 22 Dec 96 13:18:18 EST
>From: Cortland Richmond <72146....@compuserve.com>
>To: IEEE PSTMC <emc-p...@ieee.org>
>Subject: Re: Shiep rules
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>---------------------------------------------------------------------------
---
>Good day, Paul.
>
>You're suffering the pains of any other small business which has to meet
>government quality, safety or environmental regulations. It must seem that
>each
>regulation is aimed at you or at your business, and if not those, then at
your
>country. I sympathize, but not too much! You need to find ways to meet
the
>requirements, not lose sleep protesting them.
>
>>> I'm a small manufacturer located in Belgium and can't afford expensive
>>> EMC pre-compliance and compliance measuring equipment.
>
>Many businesses cannot afford expensive equipment - but they _can_ afford
>USED,
>older equipment, and it does not take much to do a quick test for high
level
>emissions. I've worked where they had only a spectrum analyzer, antenna and
>LISN
>for engineering work and still managed to produce compliant equipment.
>
> >> Can you understand with what kind of bottleneck small manufacturers are
> >> facing in front of the EMC rules?
>
>I understand this quite well. You need a local EMC expert to show how to
>comply
>with the least effort. But in reading the post further, it seems you
object
>not
>just to the EMC rules as a particular problem, but to any rules:
>
> >> Rules conceived by very intelligent and bright people bringing together
> >> all existing rules, adding as much of possible constrains, etc..
>
>The rules on EMC were actually developed by using actual radio and TV
>receiving
>equipment and measuring how much interference people using them could
>tolerate.
>Real people! THey are not a pile of rules upon other rules, though that
may
>well be what it looks like when you're under them!
>
> >> By making rules, they don't have to justify themselves as their
business,
> >> most of the time, is inside institutions or organizations who have
> >> the sovereignty to propose (impose) rules to the governments without
> >> having to justify themselves.
>
>This seems self evident. Of COURSE people making rules don't have to
justify
>a
>business on them; it is business which causes the rules to be created! But
if
>this means they don't have to worry about making a profit, that's right.
They
>don't. What is surprising, then, is that they often DO consider whether
>something is too difficult to be accomplished, that they often DO set
measures
>which are less stringent than they could be in order that they might be
>possible
>to obey.
>
> >> They are not controlled by moderated authorities and even worse usually
> >> address themselves to equipment manufacturers who all have interest
> >> to promote expensive equipment.
>
>Standards-making organizations are gathered together from among
professionals
>engaged in the area being regulated. They themselves are democratically
>structured bodies, and they must consider how their standards will be seen
by
>the people, industries and government they expect will use them. So in this
>sense, they do operate under a limit that moderates their activity. It
>certainly
>has caused standards to be delayed while differences among members from
>different countries are hammered out.
>
> >> Also University's are consulted, they are great but most of the time
> >> have no practical experience with small companies and are not facing
> >> this kind of production reality, so they add rules also.
>
>If you want to learn the rules of Physics, you ask a Physics Professor. I
>should not have to say this, but those Laws are not subject to democratic
>modification.
>
> >> But anyhow, the rule making people have to protect their job and
>authority
> >> in no way are concerned with the sometimes unjustified rules they
> >> impose and problems they cause.
>
>The answer to this is that rules (usually) are adopted to deal with real
>problems. If there were no problems, we would need no rules; the
>justification
>for EMC rules is the protection of the ability to use radio receiving and
>transmitting equipment. And this is no small thing!
>
>
> >> Did you notice, rules of other country's are not as good as theirs.
> >> Are the other country's populated with stupid people or is the
objective
> >> of this people just to keep themselves busy and protect their job?
>
>This is not precisely correct. The FCC rules on emissions, for example,
are
>about the same as the limits imposed by CISPR-22. However, as the next
>statement indicates, this may not be what is meant.
>
> >> Do you know, for instance, that in Belgium our local FCC (IBPT/BIPT)
> >> people imposes a telecom licenses for test equipment's?
> >> Yes sire, its brand new.
> >> Reason: a spectrum analyzer (or receiver) can listen to the police and
> >> other communications outside the normal broadcast range.
> >> Listen to those frequencies is strictly prohibited in Belgium.
> >> An other way to impose rules and to protect their monopolistic job.
>
>Here in the USA we do not need a license to operate a receiver, and are
>permitted to listen to most frequencies. In Europe, of course, it has long
>been
>the case that reception was considered a privilege granted by the
government,
>and the operation of a receiver required a license. It does seem excessive
>that
>Belgium should require a license for spectrum analyzers in test
laboratories ,
>but that is NOT required by the EMC directive, and Belgium, a democratic
>nation,
>should be able to deal with this on their own.
>
> >> Now, you may think that by making a European community organizations
> >> you will reduce country dependent organizations having the same
> >> purpose of existence.
> >> Wrong add it all together, increase the number of people because
> >> rules start to be more stringent and pay for that a little more tax.
> >> That's the improved rule.
> >> Its that easy.
>
>In some cases the harmonized standards may have become more stringent. In
>other
>cases, some nations did not observe a rule or a policy, and under the
>harmonized
>standards were now required to do so. I will submit that there are two
ways
>to
>deal with problems which require regulation:
>
>(1) Write a regulation which defines and prohibits the problem and then
>require
>action to fulfill its spirit or,
>
>(2) Write a regulation which defines the solutions, and then require people
to
>observe its details.
>
>When you consider that in some countries the laws and rules (for political
and
>cultural reasons) are very strict, but the enforcement is not, while in
>others,
>the rules are very loose, but enforcement is strict, you can see that
>confusion
>between these two approaches is likely to produce excesses until a rational
>approach is decided upon. The worst situation, in my view, is a system of
>strict laws and strict enforcement. It did not work well in Russia, though
>perhaps the DDR might have been able to make it go. That is a different
>discussion!
>
> >> Realize, we in Europe are so much better than you located on the other
> >> side of the big pool.
> >> Please, please, please admit, if its not evident to you, that we are
> >> so much better and can not use your rules.
>
>I found Europeans take a different approach than people here in the USA. I
>found the European approach to be, "Get permission then go ahead." while
the
>USA
>approach was "Go ahead and see if anyone objects". This is a _very_ simple
>definition of a large and complex cultural divide which cannot be done
justice
>to in one message, nor a whole thread; it would take books. In any case,
>"better" does not enter into it. One does what one's culture requires.
>
> >>I quit on the subject, disgusted.
> >> I agree there is a need for rules, but rules are made to protect people
> >> not to protect rules and the people conceiving them.
>
> >>Your comments are welcome or are you all on the "other" border?
>
>I really do understand the problem... but I suspect you do not. You real
need
>to
>bring in an expert to show how to do, inexpensively, what you must do to
build
>compliant products. You will have to decide whether this added burden is
one
>you can bear. There are other rules you already deal with, such as safety
and
>pollution control, and you had to decide whether to follow those
requirements
>as
>well. However, as far as the EMC directive goes, or the FCC Rules, I always
>consider them means to get rid of electronic pollution, and the only
>substantive
>decisions we need to take are how it is to be done.
>
>
> >>For information: Belgium is a small country of +/-10 million people
located
> >> between the Netherlands, Germany, Luxembourg, France. We don't have our
> >> own language and speak French, Flemish (Dutch) and German.
> >> So consider this when reading my "pure" English prose....
>
>Paul, your English is certainly good enough to say what you are feeling.
It
>is
>much better than my German, that's for sure.
>
>Don't give up. There are way's to deal with regulations, and this is the
>place
>to find them. Good luck, and...Merry Christmas.
>
>
>Cortland
>
>
