Just to stay with the apples:
Compliance to EN 55022 is like ordering an apple on the Internet. Your ordered it, but will you receive an apple ? Compliance with EN 55022 gives presumption of compliance only. When the product standard refuses to comply to what the EC had in mind , the EN will finally be modified. In the mean time you have bought a rotten apple. Not your fault, but you're liable. That is why I insist on this topic very hard. In a few years all these standards will be updated one after one. If one of the local authorities finds out that your product is Class A and being sold and used in Class B environments -may be because a competitor complained- then you just did not fulfill to the Essential requirements, to the EN only. Other example: You create interference at 1800 Mhz DECT frequencies. EN 55022 says -no testing above 1 Gig- . The authorities say: you interfere, you should have known EN 55022 is not enough to comply to the essential requirements. This is what they call "due diligence " in compliance testing. Same with the new liability directive and product warranty directive that will come into force. Your product must :"be safe to the current state of workmanship" , always, even 10 years after it was introduced. This means that to cover your a.. you need constant modification in the field of safeguarding your customers. Regards, Gert Gremmen, (Ing) ce-test, qualified testing =============================================== Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ =============================================== >>-----Original Message----- >>From: Pettit, Ghery [mailto:[email protected]] >>Sent: Wednesday, December 06, 2000 7:57 PM >>To: '[email protected]'; Pettit, Ghery; 'William D'Orazio'; EMC Posting >>(E-mail) >>Subject: RE: EN55024 >> >> >>Let's discuss apples vs apples and keep the discussion to ITE. Household >>appliances are not subject to EN 55022:1998, but have their own product >>specific standard. >> >>The law is 89/336/EEC, the EMC Directive (or as I like to call it, the EMC >>Professional Employment Act of 1989). It lays down, as you note, the >>essential requirement that a product not cause undue interference and that >>it operate as intended in its itended environment. No more, no less. No >>limits for emissions are provided in the EMC Directive. >> >>The question then comes up, how do we show compliance with the essential >>requirements in 89/336/EEC? The answer, of course, is to test to the >>applicable requirements that have been published in the OJ. For ITE, the >>emissions limits are contained in EN 55022:1998. Fine. I read EN >>55022:1998 and it is simply a number of modifications to CISPR 22, 3rd >>Edition. Well and good. I read CISPR 22, 3rd Edition and it >>defines Class >>A and Class B. >> >>If there are different emissions limits between various standards, that >>needs to be addressed in CISPR. My question is this - is there a >>significant interference problem in Europe from ITE? Based on a survey >>returned by over 50,000 households in the U.S., there certainly isn't one >>here. Whatever is being done, it is adequate. >> >>Peace! >> >>Ghery >> >>-----Original Message----- >>From: CE-test - Ing. Gert Gremmen - ce-marking and more... >>[mailto:[email protected]] >>Sent: Wednesday, December 06, 2000 10:39 AM >>To: Pettit, Ghery; 'William D'Orazio'; EMC Posting (E-mail) >>Subject: RE: EN55024 >> >> >> >>Hi Ghery,group, >> >>Standards are NO LAW ! >> >>My reply was directed against the Clause in EN 55022, not against the >>possibility of >>EN 55022 to define suitable environments. However, there is a standards >>writing >>committee guidance document that requests the committees not to >>deviate more >>then absolutely needed from the test levels and environmental conditions >>as described in the generic standards EN 50082-1/2. >>The standards writing committees have been very independent (members of >>CENELEC) and >>all kind of powers could and have been influencing the contents of many >>standards. Even today commercial interests find their way into harmonized >>standards. >> >>The EC requested CENELEC to create standards that are compatible to the >>Essential requirements >>of the EMC-directive, it cannot be so that a house hold kitchen >>machine need >>to comply to >>other limits then a house hold computer. The interference a receiver >>receives is not less interfering >>if it comes from a vacuum cleaner or from a modem. Same environment, same >>levels. >>The problem comes with mixed environment products. In the past products >>could escape from limits >>by a warning label "this product may cause radio interference" and the >>suggestion to increase >>distance between products. At low reception levels of FM-radio >>and the close >>distances of >>modern urban livings that solution is not sufficient anymore. >>Product group level EN-type harmonized standards are >>(in Europe) targeted towards the details of "how to test" and >>"how to judge >>performance" and >>"how to connect test gear" and only deviate from levels and >>frequency range >>in the >>benefit of the product group if absolutely necessary. >>It would be absolutely unjust if some equipment would be able to interfere >>more then >>others, just because it had a label on it saying that it would only be >>allowed to >>use it in an heavy industrial environment, if the equipment (such as a >>mainframe) >>itself suggests their application in a domestic or mixed environment. >> >>Manufacturers of Class B complying equipment could easily sue >>manufacturers >>of equivalent >>Class A equipment if their limit exceeding interference was not due to >>absolutely \ >>necessary requirements given by the nature of the product or process being >>done. >>(Fa electro-heating with RF-waves, welding and therapeutic use of >>RF-frequencies) >> >>Please Note also that the report mentioned is for the standards writing >>committees of CENELEC creating harmonized standards and is not applicable >>for IEC and/or >>CISPR versions of the same standard. >> >>Hope to got things straightened out somewhat. >> >>Regards, >> >>Gert Gremmen, (Ing) >> >>ce-test, qualified testing >> >>=============================================== >>Web presence http://www.cetest.nl >>CE-shop http://www.cetest.nl/ce_shop.htm >>/-/ Compliance testing is our core business /-/ >>=============================================== >> >> >>>>-----Original Message----- >>>>From: Pettit, Ghery [mailto:[email protected]] >>>>Sent: Wednesday, December 06, 2000 5:25 PM >>>>To: 'CE-test - Ing. Gert Gremmen - ce-marking and more...'; Pettit, >>>>Ghery; 'William D'Orazio'; EMC Posting (E-mail) >>>>Subject: RE: EN55024 >>>> >>>> >>>>Gert, >>>> >>>>All ITE equipment must meet the Class B limits? Where does it >>say that in >>>>either EN 55022:1998 or CISPR 22, 3rd Edition? Section 4.1 of >>CISPR 22 is >>>>quite clear about what equipment must meet the Class B limits. >>There are >>>>many types of ITE that do not fall into the examples provided in the >>>>document. EN 55022 does not amend this part of the document in >>its common >>>>modifications. As 89/336/EEC does not provide limits of any >>>>kind, where am >>>>I supposed to see a requirement that servers and mainframe >>>>computers (which >>>>are, indeed, ITE) must meet the Class B limits? >>>> >>>>Ghery Pettit >>>> >>>>-----Original Message----- >>>>From: CE-test - Ing. Gert Gremmen - ce-marking and more... >>>>[mailto:[email protected]] >>>>Sent: Wednesday, December 06, 2000 1:14 AM >>>>To: Pettit, Ghery; 'William D'Orazio'; EMC Posting (E-mail) >>>>Subject: RE: EN55024 >>>> >>>> >>>>Hi Group, >>>> >>>>The type of clause (see below) from EN 55022 about adding notes and >>>>restrictions >>>>to equipment is just the type the European Commission >>>>objects against their use in the EN 55022 standard. >>>> >>>>The reason is that the CENELEC was asked to propose limits and >>>>test methods, not to replace politics by limitng the applicability >>>>of their standards. >>>> >>>>The use of such a clause to sell ITE equipment to Class A limits >>>>is illegal >>>>and will not hold when the presumption of conformity to the essential >>>>requirements >>>>of the EMC-directive is being tested. >>>> >>>>Information equipment is and wil be used in all environments, therefore >>>>the distinction between such environments is artificial. >>>> >>>> >>>> >>>>Regards, >>>> >>>>Gert Gremmen, (Ing) >>>> >>>>ce-test, qualified testing >>>> >>>>=============================================== >>>>Web presence http://www.cetest.nl >>>>CE-shop http://www.cetest.nl/ce_shop.htm >>>>/-/ Compliance testing is our core business /-/ >>>>=============================================== >>>> >>>> >>>>>>-----Original Message----- >>>>>>From: [email protected] >>[mailto:[email protected]]On Behalf >>>>>>Of Pettit, Ghery >>>>>>Sent: Tuesday, December 05, 2000 11:46 PM >>>>>>To: 'William D'Orazio'; Pettit, Ghery; EMC Posting (E-mail) >>>>>>Subject: RE: EN55024 >>>>>> >>>>>> >>>>>> >>>>>>OK. EN 55022 is the ITE specific emissions standard. It does >>>>>>have two sets >>>>>>of limits with a statement that Class B is intended for >>certain product >>>>>>types which may be used in a domestic type environment and a >>>>>>statement that >>>>>>Class A products should have a warning that they may cause >>>>interference if >>>>>>used in a domestic environment. CISPR 22 does not use the term >>>>>>"industrial" >>>>>>to define an environment. It merely warns that the class A >>>>limits may not >>>>>>provide enough protection to neighboring users of the RF >>spectrum if the >>>>>>device is used in a domestic environment. >>>>>> >>>>>>Ghery >>>>>> >>>>>>-----Original Message----- >>>>>>From: William D'Orazio [mailto:[email protected]] >>>>>>Sent: Tuesday, December 05, 2000 2:37 PM >>>>>>To: 'Pettit, Ghery'; William D'Orazio; EMC Posting (E-mail) >>>>>>Subject: RE: EN55024 >>>>>> >>>>>> >>>>>>BYI, EN55011 should read EN55022. >>>>>> >>>>>>William D'Orazio >>>>>>CAE Electronics Ltd. >>>>>>Electrical System Designer >>>>>> >>>>>>Phone: (514) 341-2000 (X4555) >>>>>>Fax: (514)340-5552 >>>>>>Email: [email protected] >>>>>> >>>>>> >>>>>>-----Original Message----- >>>>>>From: Pettit, Ghery [mailto:[email protected]] >>>>>>Sent: Tuesday, December 05, 2000 5:33 PM >>>>>>To: 'William D'Orazio'; EMC Posting (E-mail) >>>>>>Subject: RE: EN55024 >>>>>> >>>>>> >>>>>>EN 55024 is the ITE specific immunity standard. It is based >>on CISPR 24 >>>>>>which makes no distinction between environments. EN 55011 is >>>>>>based on CISPR >>>>>>11 and relates to different product families. They do not >>come from the >>>>>>same subcommittees in CISPR, so it's like comparing apples >>and oranges. >>>>>> >>>>>>Ghery Pettit >>>>>>Intel >>>>>> >>>>>>-----Original Message----- >>>>>>From: William D'Orazio [mailto:[email protected]] >>>>>>Sent: Tuesday, December 05, 2000 1:22 PM >>>>>>To: EMC Posting (E-mail) >>>>>>Subject: EN55024 >>>>>> >>>>>> >>>>>> >>>>>>Gents, >>>>>> >>>>>> Why is it that EN55011 defines test levels for both industrial and >>>>>>residential environments (class A, B) and EN55024 does not? Are >>>>>>the levels >>>>>>in EN55024 applicable to all environments (obviously not) so >>>>how does one >>>>>>define the test levels for an ITE in an industrial environment? >>>>>> >>>>>>Thanks in advance, >>>>>> >>>>>> <<...>> >>>>>> >>>>>>William D'Orazio >>>>>>CAE Electronics Ltd. >>>>>>Electrical System Designer >>>>>> >>>>>>Phone: (514) 341-2000 (X4555) >>>>>>Fax: (514)340-5552 >>>>>>Email: [email protected] >>>>>> >>>>>> >>>>>>------------------------------------------- >>>>>>This message is from the IEEE EMC Society Product Safety >>>>>>Technical Committee emc-pstc discussion list. >>>>>> >>>>>>To cancel your subscription, send mail to: >>>>>> [email protected] >>>>>>with the single line: >>>>>> unsubscribe emc-pstc >>>>>> >>>>>>For help, send mail to the list administrators: >>>>>> Jim Bacher: [email protected] >>>>>> Michael Garretson: [email protected] >>>>>> >>>>>>For policy questions, send mail to: >>>>>> Richard Nute: [email protected] >>>>>> >>>>>> >>>>>> >>>>>> >>>>>>------------------------------------------- >>>>>>This message is from the IEEE EMC Society Product Safety >>>>>>Technical Committee emc-pstc discussion list. >>>>>> >>>>>>To cancel your subscription, send mail to: >>>>>> [email protected] >>>>>>with the single line: >>>>>> unsubscribe emc-pstc >>>>>> >>>>>>For help, send mail to the list administrators: >>>>>> Jim Bacher: [email protected] >>>>>> Michael Garretson: [email protected] >>>>>> >>>>>>For policy questions, send mail to: >>>>>> Richard Nute: [email protected] >>>>>> >>>>>> >>>> >>
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