The recent August 1999 issue of Conformity magazine indicates that indeed
the test methodology of C63.4 does include the open chassis test and the 6
dB above limits. The article indicates a clarification was made about this
process in a recent OET notice. The notice itself wasn't identified so you
would have to search the FCC's site for it.
Before one and all start throwing daggers and putting hexes on me. I want to
point out that I am not endorsing the process, although I certainly
understand, why folk like Michael might want this type of system.
Finally, I will resist a dig at the sanity of many of the European rules.
        Gary

        -----Original Message-----
        From:   Grasso, Charles (Chaz) [SMTP:gra...@louisville.stortek.com]
        Sent:   Tuesday, August 24, 1999 4:18 PM
        To:     'michael.garret...@radisys.com'; emc-p...@ieee.org
        Subject:        RE: CE Marking requirements


        As far as I know, the EU has not adopted the insane FCC Class B
compliance
        process. So there is NO procedure for marking a motherboard as a
"compliant"
        unit. 

        What you can do is test it in a system (just like the old days) and
mark the
        motherboard based on that test ALONE.

        If I understand your requirement, you are looking to adopt the
infamous
        CE+CE=CE
        approach. Again, this has proven NOT to work especially for
emissions.

        Comments:

        (a) there is no requirement to test "open chassis" and that we can
CE mark
        the
        board as compliant as long as we have shown that it can meet the
class B
        levels
        within a chassis of our choosing.

        RESPONSE: There is no requirement NOR is there a process for "open
chassis"
        testing.
        The EMC Directive (nor the guidelines) can help you here.


        (b) we are still required to perform "open chassis" tests, however,
there is
        no
        6dB margin and the board will have to meet the EN 50022 class B
levels with
        the
        cover off.
        RESPONSE: Nonsense. There is NO "open chassis" test.

        WARNING: Be careful. The next thing the testhouse will try is the
TCF route.

        Ugh.


        Thank you
        Charles Grasso
        Advisory Engineer
        StorageTek
        1 StorageTek Drive
        Louisville CO 80027 M/S 4247.
        Tel:303-673-2908
        Fax:303-661-7115
        email:gra...@louisville.stortek.com
        RMCEMC Web Site:
http://www.ewh.ieee.org/r5/denver/rockymountainemc/




        -----Original Message-----
        From: michael.garret...@radisys.com
        [mailto:michael.garret...@radisys.com]
        Sent: Tuesday, August 24, 1999 2:44 PM
        To: emc-p...@ieee.org
        Subject: CE Marking requirements



        Well group, if you care to help out another American confused by the
        specific
        requirements for Europe, I would appreciate it.  I seem to be
getting
        varying
        stories from different test houses as to what is required for one of
our
        products.  These are big enough players that pitting one against
another is
        not
        something I want to undertake at this point.

        We currently manufacture a motherboard which is sold both by itself
and with
        a
        chassis which includes power supply, hard drive and floppy.  We are
        currently
        going through our internal EMC validation to ensure that we meet
both FCC
        Class
        B and EN 55022 Class B levels.  Our experience on previous products
has been
        if
        we clear emissions, we haven't had problems in other areas, but
we'll be
        testing
        to EN 55024 of immunity, as well.

        The issue arises when we discuss testing of the system versus
testing of the
        motherboard alone.  Within the US, the FCC regulations permit an
additional
        6dB
        margin for "open chassis" measurement, so long as those frequencies
fall
        back
        within the class B levels with the cover on.  This does not appear
to be a
        problem for our product.

        We have been told by different parties that for Europe,

        (a) there is no requirement to test "open chassis" and that we can
CE mark
        the
        board as compliant as long as we have shown that it can meet the
class B
        levels
        within a chassis of our choosing

        and

        (b) we are still required to perform "open chassis" tests, however,
there is
        no
        6dB margin and the board will have to meet the EN 50022 class B
levels with
        the
        cover off.

        We're having a little more difficulty making things work using the
(b)
        approach.
        I am specifically concerned about staying far enough below the
levels that
        we're
        not going to potentially pass today and fail 6 months from now due
to a
        slight
        drift in tolerances of components, test equipment or test engineers'
        dispositions.

        I have the texts of the EMC directive, as well as the test
requirements
        specified in the above documents and I'm happy to wade through them
if you
        can
        point me in the right direction.  I will be heading that direction
in the
        next
        day or two if I don't receive a response.  I'm hoping, however, that
someone
        in
        the group can shave a few hours of exceptionally captivating reading
from my
        life by pointing me in the right direction.

        Regards,

        Michael Garretson
        Compliance Engineer
        RadiSys Corporation



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