Actually Earl - I am in complete agreement with you. I think you
may have misunderstood my comments. Let me explain:

1. On the CE+CE maybe = CE comment. No question here. I agree.
Many systems fail emissions (maybe immunity) testing due to 
incompatible combinations. BUT... As I am sure you know, the 
FCC has a Class B compliance system that allows for exactly that. 
PCs can be 
assembled from sutiably marked components (such as video cards)
and marketed WITHOUT furthur testing. This results in non-compliant 
units (admitted by the FCC) released on the market place with
NO intent by the FCC to enforce the rules.

(BTW - The Australians have released an equivalent scheme
with the  proviso that a metal enclosure be used)

2. Here is the crux of my issue with the FCC. The logic and the
physics don't match. To illustrate: A recent thread has described
the origin of the emissions standards and generally everyone 
agrees what a jolly good thing it is too.  That being the case,
how could the the FCC put into law a process that allows for
systems to be released on the market place WITHOUT testing. 
To me the existing FCC Class B procedures render the emissions 
standard irrelevant. After all why should any manufacturer concern
themselves with the standard when the FCC blatenly ignore it
themselves?

3. If you have monitored this list recently, you should
have seen my comments regarding the emissions limits.
To reiterate: Raise the limits 20db but make EVERYONE
test. Although this may seem ridiculous - compared to the
FCC Class B process it makes a lot of sense. This process
maintains the INTENT of the emissions spec in the first place
- that is to maintain a KNOWN level of interference.

OK -OK so folks will bleat about cycle time etc...
So an alternate solution is to truely engineer the EMC at the
component level. Design tests/procedures to adequately test
at the componet level AND (this is key) have the regulatory
agencies redesign the emissions limits to meet the 21st Century.

Call me if you want to chat furthur.

-----Original Message-----
From: Morse, Earl [mailto:[email protected]]
Sent: Friday, June 18, 1999 3:36 PM
To: Grasso, Charles (Chaz); 'Lou Gnecco'; [email protected]
Subject: RE: NEAR/ FAR FIELD CORRELATION ISSUES


I beg to differ.

It is ludicrous to believe that components or for that matter subassemblies
can be certified and then combined to make a compliant system.

CE + CE doesn't always equal CE

The reduction of emissions is highly  reliant on component placement.  The
same parts can be arranged on circuit boards in compliant and non-compliant
patterns.  Same with subassemblies.

While the current measurement techniques are difficult they are about as
close to the "truth" as we can get.  Even if that means an 8 dB swing from
site to site.

The reason that we see PCs consistently fail by as much as 20 dB is because
of a lack of enforcement.  Many computer manufacturers sneak through the
requirements with their one of a kind golden units never to worry about
compliance again.  Very few get caught and it is worth the bucks to keep the
production lines going rather than shutdown the lines.

Who was the last computer manufacturer you heard of that was forced to
shutdown until an EMC problem was fixed?  I have a book of test reports on
competitor's products.  They fall into the categories of compliant, near
compliant (looks like they tried), and fails miserably (didn't try, didn't
care, and outright lied on any self declarations).  The failing companies
seem to be doing just as brisk a business as the passing companies without
having to worry about the cost of EMC.


Earl Morse
Portable Division EMC Design
Compaq Computer Corporation
Phone:  281.927.3607
Pager:  713.717.0824
Fax:  281.927.3654
Email:  [email protected] <mailto:[email protected]> 


                -----Original Message-----
                From:   Grasso, Charles (Chaz)
[mailto:[email protected]]
                Sent:   Friday, June 18, 1999 10:33 AM
                To:     'Lou Gnecco'; [email protected]
                Subject:        RE: NEAR/ FAR FIELD CORRELATION ISSUES


                I cannot agree more!! We, not the government, need to
                drive the technology for EMC.

                I have followed this thread with interest. I have long
believed
                that if EMC was to maintain credibility we (EMC ) would have
to
                come up with a method of demonstrating compliance in spite
of the
                many and varied combinations. One way is to test at the
component
                level - like our Safety brethren - and call the assembly of
tested
                components good!!

                This is methodology can be made consistent with good
engineering 
                design practice unlike the existing FCC rules for Class B
equipment.
                On the surface the FCC Rules appear to be similar to
component level
                testing - but under the hood, they are completely different.
There are
                PCs out there that fail by as much as 20dB. 

                I am all for a more logical and consistent design approach
to EMC!!

                Thank you
                Charles Grasso
                Advisory Engineer
                StorageTek
                2270Sth 88th Street
                Louisville CO 80027 M/S 4247.
                Tel:303-673-2908
                Fax:303-661-7115
                email:[email protected]
                Web Site:
http://www.ewh.ieee.org/r5/denver/rockymountainemc/




                -----Original Message-----
                From: Lou Gnecco [mailto:[email protected]]
                Sent: Friday, June 18, 1999 6:52 AM
                To: [email protected]
                Subject: Re: NEAR/ FAR FIELD CORRELATION ISSUES



                For this to work, the government would have to change the
rules completely,
                setting a new set of near field procedures and  limits. This
is doable but
                hard to sell.

                        A good way to start would be if we did it. If
someone in industry
                writes up a procedure and a set of limits, then everyone
could use that as a
                "straw man", (criticizing and refining it) until eventually
most people
                agreed.
                        Eventually it could become an industrial (such as
IEEE) standard.
                Then the govt would find it much easier to adopt it as is or
after making
                their own modifications. 

                lou 


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