The problem here is, the NARTE certified engineer probably did test a sample
that passed.   We can't blame him.  Usually, the product non-compliance
happens because the product sold isn't like the product tested.  

I think that there is an opportunity here.  

We're engineers after all; we can't help the fact that countries need EMC
limits; we also can't help the fact that marketeers want to ship at lowest
cost with a quality level as low as the general public can stomach.  

However, as engineers, we could find a way to make the spot checks cheaper and
more repeatable.  Sort of a little field probe with an LED indicator  Red =
way out, Yellow = close , Green = OK.  If the product were reliable and
inexpensive, it could be marketed to national authorities as well as
manufacturers to put at the end of their assembly lines.    Take the example
of hi-pot testing.  An actual safety test goes through all sorts of paperwork,
component checking, heat conditioning...  But, the final test at the end of
the assembly line is a simple hi-pot and ground bond.  An analogous
test/product for EMC appears to be begging for development.   Some of these
$100,000 mini - chambers are a poor excuse.  I'm talking cheap/dirty and
quick...no display, no readout of actual level...an antenna, an amplifier and
a go/no-go indicator.  

Ahhhhh! true engineers' satisfaction...we don't care if it is right or wrong. 
We'll just make a living producing the tool that the manufacturers and FCC
will use to harass each other!

Heck, the measurement could even be sampled...then you could use one digital
notch filter/amplifier and use different digital mixers to fit the measured
signal into the notch.

I wish I had the time and resources; but I have to go back to work producing
equipment that just barely scrapes by the EMC standards so my company can
ship, I can collect a paycheck and my kids can have their soccer cleats and
two boxes of corn flakes next week :-)

Chris Maxwell | Design Engineer - Optical Division
email chris.maxw...@nettest.com | dir +1 315 266 5128 | fax +1 315 797 8024

NetTest | 6 Rhoads Drive, Utica, NY 13502 | USA
web www.nettest.com | tel +1 315 797 4449 | 






> -----Original Message-----
> From: drcuthbert [SMTP:drcuthb...@micron.com]
> Sent: Friday, March 28, 2003 10:54 AM
> To:   'Mark Kirincic'; Stone, Richard A (Richard); lfresea...@aol.com;
emc-p...@majordomo.ieee.org
> Subject:      RE: OK, what's going on?
> 
> What would NARTE say about certified EMC engineers and technicians signing
off on equipment that does not make the grade? It would be great if everyone
and every company handled the issue of EMC ethically. But since the world does
not always work this way.......I favor the idea of a fine for every unit that
is shipped from a lot that statistically fails. I.E. mandatory sampling (of
boxed and shipped units) and only a certain percentage are allowed to fail,
etc. Companies would then weigh the cost of compliance against the cost of
non-compliance. 
>  
> Devils advocate speaking now: But from the viewpoint of economics this would
of course add cost to every unit shipped. Is the additional manufacturing cost
to the public offset by any savings due to lower emissions and lower
susceptibility? Would society truly benefit from better EMC enforcement or
does this serve only the EMC community?  
>  
>     Dave Cuthbert
>     Micron Technology
>  
>  
> -----Original Message-----
> From: Mark Kirincic [mailto:mkirin...@houston.rr.com]
> Sent: Thursday, March 27, 2003 8:53 PM
> To: Stone, Richard A (Richard); lfresea...@aol.com;
emc-p...@majordomo.ieee.org
> Subject: Re: OK, what's going on?
> 
> 
> To further clarify my point, all the major companies are guilty of this.  I
know of first hand information where a unit passed in Asia and failed here in
the states at the companies test lab, and they are forced by upper management
to ship the product anyway.>   These companies are trying to get their product
out the door as cheaply as possible with little to no concern about the
consequences.  I have read in some of the responses that we should fine these
companies, that is a good point but that is only a slap on the wrist and a
chance most of them are willing to take.  
>  
> In my opinion, what really needs to be done is full accountability for
failed products that the company by having the company name made public at the
FCC and CE websites and trade journals.  Also have the companies pay for
audits of all the units that are in the country that fail to meet FCC and CE
standards.  What I am saying is to charge a flat fee per unit that fails. 
Secondly, I  would prevent them form selling into a market segment if the
audit shows non compliance of multiple units.  Have the company provide future
proof of compliance before shipping which will hurt them in their pocket book
a lot more than just a simple fine.
>  
>  
> Mark J. Kirincic
> mkirin...@houston.rr.com <mailto:mkirin...@houston.rr.com>
> 
> 
>       ----- Original Message ----- 
>       From: Stone, Richard A (Richard) <mailto:rsto...@lucent.com> 
>       To: 'Mark Kirincic' <mailto:mkirin...@houston.rr.com> ; 
> lfresea...@aol.com
<mailto:lfresea...@aol.com> ; emc-p...@majordomo.ieee.org
<mailto:emc-p...@majordomo.ieee.org> 
>       Sent: Thursday, March 27, 2003 8:34 AM
>       Subject: RE: OK, what's going on?
> 
>       Mark mentioned reports,
>       a paper trail...or is it?
>        
>       Vendors doing the EMC/EMI ?,
>       who might a vendor be for say IBM or Dell?
>       would think the mfr'r would have an associate
>       there during testing like most of us do.
>        
>       Seems it would be easy to look at the report,
>       from which test lab did it,
>       are they accredited?  if yes,
>       then there shouldnt be any questions..
>       only thing I see, maybe Disparity,
>       as readings can be differnet from lab to lab.
>        
>       these days its ship now...or not at all..
>       and barely passing for PC's, since its class B
>       may be enough for the PC companies.
>       Richard,
> 
>               -----Original Message-----
>               From: Mark Kirincic [mailto:mkirin...@houston.rr.com]
>               Sent: Thursday, March 27, 2003 8:55 AM
>               To: lfresea...@aol.com; emc-p...@majordomo.ieee.org
>               Subject: Re: OK, what's going on?
>               
>               
>               I guess now its my turn to put in my two cents.  The major 
> reason that you
are having a hard time finding units that pass is that all these major
computer companies rely on their vendors to test the products to FCC and CE
limits.  Since the majority of these companies have suppliers in the Taiwan
and China all of these units pass due to pressure from the major computer
companies and the vendors themselves.
>                
>               These major computer companies then try to legitimize it by 
> getting copies
of test reports showing the units are in compliance.
>                
>               None of these companies will report each other to the 
> authorities mainly
because they can not guarantee that all of their products pass and they fear
retaliation.  Their philosophy is as long as we have this report we can sell
this product until someone catches us and then they go into a major scramble
to fix the problem that was uncovered.
>                
>               The only way to reduce this is through FCC and CE random audits.
>                
>               I have worked for several major computer companies in my 19 
> years of
experience, and they all share this philosophy. One former company was the
exception, they were deathly afraid of bad press and they went to great
extremes to make sure their products passed with adequate margin.
>                
>               I will get off my soap box now.  
>               Mark J. Kirincic
>               mkirin...@houston.rr.com <mailto:mkirin...@houston.rr.com>
>               
> 
>                       ----- Original Message ----- 
>                       From: lfresea...@aol.com <mailto:lfresea...@aol.com> 
>                       To: emc-p...@majordomo.ieee.org 
> <mailto:emc-p...@majordomo.ieee.org> 
>                       Sent: Tuesday, March 25, 2003 2:05 PM> 
>                       Subject: OK, what's going on?
> 
>                       Hi all,
>                       
>                       This e-mail has been prompted because of a number of 
> things that have all
come together. This may take a little reading, but please stick with it.
>                       
>                       Last note... this is not intended to pick on any 
> individuals, or organization, but I do want to stir the pot.
>                       
>                       I operate an engineering lab, helping clients harden 
> their designs to
meet EMC requirements. In this particular instance, I was working for a small
client, on a card  that goes in the PC . In order to test I need a host PC.
So, to save money, the card maker supplies 2 clones.
>                       
>                       Neither of the two PCs passed emissions testing with 
> the card, in fact,
above 100 MHz, they fail even the Class A limit: badly! So, before calling my
client, I pull his card, the PC is no different, I pull the monitor, then the
keyboard, then the mouse... No different.  I test just the PC chassis one at a
time. On their own, booted and then the peripherals removed. Not even close to
passing.
>                       
>                       Disgruntled, I get my office PC... Fail. I get my kids 
> PC.. over 20 dB
over the limit!
>                       
>                       So, I think so much for clones... I buy 2 Dell ( sorry, 
> no point trying
to hide names... ) desktops, both fail, quite badly. However, they have very
similar noise profiles...
>                       
>                       Can 5 PC's all fail? I think my measuring system is set 
> -up wrong. So I
verify this. I am within 1 dB of what I expect when I inject a signal from a
signal generator and account for antenna factors.
>                       
>                       Here lies the question: why can I not find a PC that 
> passes? Worse, since
they don't pass, who is chasing them down to enforce the requirements? I'm
unhappy, because I am taking a clients money to make him meet the
requirements, when it seems no one else is.
>                       
>                       Now, what's making this worse for me, is that I am an 
> EMC Lab assessor.
So, I go to labs and make them jump through hoops so that they produce, as
consistently as possible, data the characterizes a product. Exercises, like
those performed by USCEL, show that labs can have very consistent results.
Anyone that stands up and says EMC is not a field where consistency can be
achieved, should not be in the compliance business: please close your lab. So
if the test are consistent, why the HUGE variations?
>                       
>                       In the 20+ labs I have assessed, I feel that almost 
> every one had an
ethical approach. Ironically, I felt that the bigger companies I visited like
HP and Intel were exceptional: both ethically and technically. The rest of the
labs were between good to very good. So cheating is unlikely..
>                       
>                       I have now spent about 60 man-hours looking for a PC 
> that passes FCC
Class B emissions. Something that I should just be able to go to the store and
get. As yet, I have no PC. Our field, it appears, is not a level playing
field. It appears more like a rugby game in which we have no referee!
>                       
>                       So why are there no fines being levied? Especially 
> since it seems I can
find non-compliant products everywhere! Is the self policing approach out of
control?
>                       
>                       I intend to take this up with the FCC. Is there anyone 
> out there that is
supportive of this action ( which means you must be doing things right.. )? Am
I wasting my time ( in which case if this is all lip service... why should we
even test!!!! )? Or am I missing something ( I listen to 2 by 4's )?
>                       
>                       Derek Walton
>                       Owner of an EMC Lab
>                       EMC Lab Assessor
>                       NARTE EMC Engineer
>                       30 years of EMC experience 
> 


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