Folks,

the testing of a product at a MAJOR Compliance lab has me concerned. I have 
two main concerns, they are:

1)   The test item is designed to be bolted to a large metallic structure 
which cannot be part of my set-up, it costs way to much ( $2,000,000 each ). 
So I have a fixture, which mounts all the components as they would be 
mounted, using wiring as it would be wired etc. etc. etc. Because this 
fixture is only about a cubic metre, the lab is telling me I should test as 
table top equipment. I don't think this is correct.

IMHP, table top equipment is meant to be EUTs like PC, printers, coffee 
makers, TVs etc. In most cases, the location in which they reside has very 
little metal in the proximity. OTOH, control systems like ours, are almost 
always fastened to metal objects. It is important to have this metal, or a 
simulation of it present, because I've found that otherwise, there is little 
correlation to the final installation. I also feel strongly that lifting this 
metal structure 80 cm off the ground plane is a stupid thing to do.

So, my opinion is that there needs to be a third testing consideration added 
to table top and floor mounted equipment, that of simulated installation 
testing. OK, so this would require additional work. But if this is not 
considered, then results from all these system will vary dramatically. We 
worry at great length about the setup for table top equipment, and floor 
equipment. But if systems don't fit in this category, it's open season!

2)   Since my device can be installed almost anywhere, it is supplied with a 
3 foot length of flying lead. The intent is for final customers to extend 
this cable as needed. Here the lab tells me I'm OK testing with just 3 feet 
of lead.... My product standard is EN 61326,  which allows me if my cables 
are under 10' in length, to blow away FTB and CI testing. This is ludicrous! 
I know now how some of my competitors can claim EMC compliance when they fail 
in my lab.....

I feel very strongly about issue 1, enough that I would offer to draft 
guidelines to present to whoever makes the rules. On issue 2, there has to be 
some education, at the moment the playing field is not level. I do not want 
to play the same games as others, because I feel the EMC protection we 
incorporate is really needed.

Anyone got any constructive comments?

Derek Walton

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