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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