Chris -
The following quote from your message addresses, I believe, the essence of
the debate:
So, if we assume that the device already meets ITE standards for EMC
and
Safety? What more testing would the R&TTE directive require? I'm
just
wondering if the device would be subjected to the same technical
standards
and tests no matter which compliance path is chosen.
There is a demarcation between Telecommunication Network Equipment and
Telecommunication Terminal (Peripheral) Equipment. According to this
demarcation, EMC testing should be performed correspondingly per EN 300386-2
or CISPR 22 & 24. These standards (requirements) are not identical (the
former is a Family Product Standard and the latter are "generic" : some
standards are more equal than others). The key problem here is to determine
particular applicability of the EMC standards.
Vitaly Gorodetsky
The suitability of this information for making decision is solely with the
reader
-----Original Message-----
From: Maxwell, Chris [SMTP:[email protected]]
Sent: Tuesday, November 14, 2000 8:34 AM
To: [email protected]
Subject: RE: FW: Compliance of a USB telephone
My company doesn't have any USB products (yet), so I'm just an
innocent
bystander. But sometimes a bystander can provide a "mediating"
point of
view. (or maybe stir things up a little)
What if I were to play devil's advocate? What if we assume that the
R&TTE
directive did apply? What if we also assume that the product has
been EMC
tested in accordance with ITE EMC standards and meets EN 60950 for
safety?
What more could the R&TTE directive want? Since the USB connection
is so
indirect, I can't see where there will be any problems with
isolation from
TNV circuits, or with ringer equivalence ratings, or with power
cross ,
power induction, surge ... The modem card would take all of this
responsibility. Actually, in modern times we have to assume that
there is
any electrical connection between the PC and the network. It's very
possible that this USB device could be connected to a computer with
a
wireless or cellular modem.
It doesn't sound like the product is an intentional radiator, so I
can't
see any reason to consider the "radio" portions of the R&TTE
directive.
Even in the cellular case mentioned above. All of the radio
requirements
would be taken care of by the cellular modem's approval.
So, if we assume that the device already meets ITE standards for EMC
and
Safety? What more testing would the R&TTE directive require? I'm
just
wondering if the device would be subjected to the same technical
standards
and tests no matter which compliance path is chosen.
I'm also wondering how the term "indirectly" is interpreted. For
instance,
my electric table saw uses the same Earth ground as my phone. Are
they
indirectly connected? A computer monitor displays the information
that is
transmitted over the internet to the computer. Does this mean that
the
monitor is indirectly connected? It's just as connected as the USB
phone,
isn't it? What about the computer's speakers that can play sound
bites that
are delivered over the internet? There has to be a cutoff
somewhere. I'm
sure that there must be a "guideline" document that defines this
some more.
If there isn't, there should be.
By the way, Gary, what is the UL flame rating of asbestos underwear?
I
think maybe Nomex would be more comfortable :-)
The opinions expressed in this email are the result of my genetic
background
combined with the environment in which I grew up. My employer (and
my
parents) cannot be held liable.
Chris Maxwell, Design Engineer
GN Nettest Optical Division
6 Rhoads Drive, Building 4
Utica, NY 13502
PH: 315-797-4449
FAX: 315-797-8024
EMAIL: [email protected]
> -----Original Message-----
> From: [email protected] [SMTP:[email protected]]
> Sent: Tuesday, November 14, 2000 8:23 AM
> To: [email protected]
> Subject: RE: FW: Compliance of a USB telephone
>
>
> Let's think about this logically. I have a PC with a microphone
and
> speakers
> that allows me to speak with persons using the internet. Does that
mean
> that
> my PC, monitor, keyboard, microphone and/or speakers form part of
a
> telecommuncations terminal. I don't think so. Now I get smart and
replace
> my speaker and microphone with a headset. Has anything changed? I
don't
> think so. Now I decide to change out my headset for a handheld
device that
> includes a microphone and earphone. Has anything changed? I don't
think
> so.
>
> Richard Woods
>
> ----------
> From: H.T. Hildering [SMTP:[email protected]]
> Sent: Tuesday, November 14, 2000 4:07 AM
> To: Gary McInturff; 'Allan G. Carr'; [email protected]
> Subject: RE: FW: Compliance of a USB telephone
>
>
> Dear all,
> The R&TTE is meant for terminals. If my message was not clear
enough I
> repeat here once again the R&TTE scope (see below). I disagree
with Gary
> regarding his statement that an USB telephone, computers and other
> indirectly connected stuff are not falling under the R&TTE scope
> (connected directly or indirectly by any means whatsoever
whatsoever to
> interfaces of public telecommunications networks).
>
> Just read for yourselves what is stated in the R&TTE and conclude
for
> yourselves.
>
>
>
> >"telecommunications terminal equipment" means a product enabling
> >communication or a relevant component thereof which is intended
to be
> >connected directly or indirectly by any means whatsoever to
interfaces of
> >public telecommunications networks (that is to say,
telecommunications
> >networks used wholly or partly for the provision of publicly
available
> >telecommunications services);
>
>
> Perhaps you were confused by the former TTE directive. Indirectly
> connected
> equipment was excluded under that directive, but that's history
now.
>
>
>
> Best regards
>
> Theo Hildering
> KTL
>
> -----Original Message-----
> From: [email protected] [mailto:[email protected]] On
Behalf
> Of
> Gary McInturff
> Sent: 14 November 2000 00:01
> To: 'Allan G. Carr'; [email protected]
> Cc: H.T. Hildering
> Subject: RE: FW: Compliance of a USB telephone
>
>
> Allen,
> I agree fully with you. The response below, and in particular
"Only
> when it is IMPOSSIBLE to reach a public network, ..." is wrong for
a
> couple
> of reasons, but principally ignores the obvious. The USB (and IP)
phone is
> nothing more than a computer peripheral just like a printer or
monitor and
> cannot reach the public phone system. Even if the signals did exit
first
> the
> phone, then the computer, and then some IP switching system and
if, and
> that
> is not a certainty, the signal is then sent through a metallic
contact to
> the public phone system it is that interface that must meet the
RTT&E
> directive. The phone is at least two devices removed from metallic
access.
> More explicitly using the USB phone example. A USB interface
doesn't
> connect to any public phone system, it can't. At a minimum it
doesn't have
> the right connector. The device it plugs into, the computer
itself, is
> also
> incapable, again as a minimum it doesn't have the right connector.
In the
> best case an internally installed modem would be the first point
at which
> the RTT & E directive can be applied. Even then one should not
confuse
> what
> is actually being certified. It is the modem not the computer that
is
> powering the modem that has to meet the requirements. Modem
manufactures
> attest to the RTT & E regulations by using a computer in a type
test but
> they sure don't test one of each type of computer that is
manufactured in
> the world that happens to have a bus that will accept the modem.
> Following the "Only when it is IMPOSSIBLE...." dictum would say
that
> all computers should meet the RTT&E directive because somebody
MIGHT put a
> modem in them. Good for test labs, not so good for product prices.
> Nor should there be any concern that the public phone system is
> being left vulnerable. There indeed is a point at which all of
these
> devices, USB, IP or whichever, MAY be routed to the public phone
system
> through some metallic contact, but those devices at which that
actually
> happens are subject not only to the RTT&E but FCC part 68 among
others.
> If it doesn't look like a duck, and it can't quack then it
probably
> isn't a duck.
> I have my asbestos underwear on - fire away.
>
> Gary
> -----Original Message-----
> From: Allan G. Carr [mailto:[email protected]]
> Sent: Monday, November 13, 2000 7:07 AM
> To: [email protected]
> Cc: H.T. Hildering
> Subject: Re: FW: Compliance of a USB telephone
>
>
>
> Theo
>
> I thought I should post the consensus of our discussion on the
> applicability of the R&TTE Directive for the avoidance of doubt by
other
> readers of this newsgroup.
>
> The R&TTE applies to TERMINAL equipment - that is equipment
connected on
> the subscribers side of the NTTP (Network Test and Terminal
Point).
> Therefore a modem in a users home is covered by the R&TTE as would
a
> modem used by a company that does not have a telecommunications
> operators licence.
>
> It does not apply to NETWORK equipment - that is equipment on the
> network side of the NTTP which is owned by the PTO (licensed
Public
> Telecommunications Operator). Therefore an ISP's (Internet
Service
> Provider's) modem, typically rack mounted and sited in the local
> exchange, is Network equipment and is not within the scope of the
R&TTE.
>
> This difference may seem academic as there are no
Telecommunications
> Terminal Equipment specifications designated under the R&TTE
Directive
> and safety to EN 60 950 applies on both sides of the NTTP but the
EMC
> specifications are slightly different.
>
> EN 300 386-2 "Electromagnetic compatibility and Radio spectrum
Matters
> (ERM); Telecommunication network equipment; Electro-Magnetic
> Compatibility (EMC) requirements; Part 2: Product family standard"
> applies to Network equipment but not to Terminal equipment.
>
>
> Hope this helps
>
>
> Allan
> __________________
>
> In article <EDFA411E5E4AD2118D6F00A0C99E4BAC01DF752E@FLBOCEXU02>,
> [email protected] writes
> >
> >Forwarding a reply
> >
> >----------
> >From: H.T. Hildering [SMTP:[email protected]]
> ><mailto:[SMTP:[email protected]]>
> >Sent: Friday, November 10, 2000 11:49 AM
> >To: [email protected] <mailto:[email protected]>
> >Subject: RE: Compliance of a USB telephone
> >
> >Sorry for my late reply.
> >For applying the R&TTE directive, the intended use is the crux.
I wander
> or
> >it is possible nowadays - if computers are connected to the
internet- ,
> to
> >deny that it is not intended for communication using the
internet; for
> >example using Voice over IP!
> >I would say that every computer (and connected equipment), that
can
> >communicate to the internet is falling under the scope of the
R&TTE.
> >Consider for yourself what is stated in the R&TTE directive:
> >"telecommunications terminal equipment" means a product enabling
> >communication or a relevant component thereof which is intended
to be
> >connected directly or indirectly by any means whatsoever to
interfaces of
> >public telecommunications networks (that is to say,
telecommunications
> >networks used wholly or partly for the provision of publicly
available
> >telecommunications services);
> >Only when it is IMPOSSIBLE to reach a public network, the R&TTE
is not
> >applicable.
> >The consequence for the USB telephone is that there are no
restrictions
> on
> >the power voltage (as stated in the LVD), so the telephone must
fully
> comply
> >with all the requirements as mentioned in the safety
directive(for
> example
> >acoustical shock)
> >
> >Best regards,
> >Theo Hildering
> >KTL
> >
> >
> >
> >-----Original Message-----
> >From: [email protected] <mailto:[email protected]>
> >[mailto:[email protected]]
> <mailto:[mailto:[email protected]]>
> >On Behalf Of
> >[email protected] <mailto:[email protected]>
> >Sent: 02 November 2000 19:29
> >To: [email protected]; <mailto:[email protected];>
[email protected]
> ><mailto:[email protected]>
> >Subject: RE: Compliance of a USB telephone
> >
> >
> >Let me see if I understand this product. It is a telephone like
device
> that
> >is solely intended to be connected to the USB port of a PC and it
is not
> >intended to be connected to the telephone network.
> >If this is true, then no telephone standards, regulations or
directives
> >apply. Only the EMC directive applies in the EU. The RTTE
directive does
> not
> >apply since the device is not intended to be connected to the
telephone
> >network. The LVD does not apply since the source voltage is too
low.
> >Compliance with safety requirements of EN60950 is sufficient to
show due
> >diligence for the Liability Directive and General Product Safety
> Directive.
> >
> >
> > > Dear Group
> > >
> > > We are testing an PC telephone unit!
> > >
> > > It is a telephone terminal unit that connects to the
USB port
> of
> >the PC from
> > > which it receives power. There is no other connection,
just the
> >USB.
> > >
> > > Clearly this unit must comply with EMC requirements.
Safety
> >requirements are
> > > not mandatory but clearly they are recommended to be
performed
> >for
> >UL1950
> > > for the US and EN60950 for Europe.
> > >
> > > Two questions:
> > >
> > > 1) What about Part 68 in the US? Since unit is not
directly
> >connected to the
> > > PSTN officially it is exempt from the standard.
(Acoustics
> tests
> >are covered
> > > under UL1950)
> > >
> > > 2) What about RTTE directive in Europe? There is no
standard
> you
> >can test
> > > for. All of TBR 21 tests are not applicable.
> > >
> > > Thanks
> > > Ilan
> > >
> > > ----------------------------------------------------
> > > Ilan Cohen
> > > Manager, Telecom Division
> > > I.T.L (PRODUCT TESTING) Ltd.
> > > 26 Hacharoshet St, POB 211, Or Yehuda, Israel.
> > > Tel 972-3-5339022, Fax 972-3-5339019
> > > [email protected] <mailto:[email protected]> , website:
> >http://www.itl.co.il <http://www.itl.co.il>
> > > ----------------------------------------------------
> > >
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> --
> Allan G.Carr B.Sc.(Elec.Eng) AMIEE | AGC-Tel Consultants Ltd
> Telecommunications Consultant | Tel: +44(0)141-956-2506
> European Approvals Specialist | Fax: +44(0)141-956-5347
> 62 Crawford Road, Milngavie | Voice Mail:
+44(0)1252-30-3062
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>
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