>> John Woodgate wrote: Telling us here won't have any effect. If you are concerned about violations, tell the regulatory authority. <<
This is worth some discussion, I think. Most of the time, EMC engineers are not cops. Among other things, we want to be sure our OWN employers are regulation "legal." Our first responsibility when we find non-compliant vendor-supplied items is, I believe, to obtain correction of the condition which led to non-compliance, so we can use the equipment we were looking at. I've seen serious engineering teams dispatched from vendors to find out what went wrong, and how fix it. This may be an old-fashioned response. There is, unfortunately, an element of specmanship in compliance. When the FCC clamped down on computer RFI in 1980, it imposed a monitor test designed to create as much radio noise as possible. Remember the first "H" test? Remember the outcry? Soon there were legalistic quarrels what size to make the H's, whether they must be highlighted, and later, even whether a DOS "H" -- which often didn't have as many high-frequency components as a Windows(tm) "H" -- met the LEGAL requirements of Part 15. Remember? Some firms spent the time to write special video software to "game" the test. Some firms, hewing to the "letter" of the law, for a while, didn't use H's for VDE 0871 testing, but random (normal) text, with fewer periodic components to break the limits. Marketing hired extra lawyers, or so it seemed. Some of us tested at the highest performance modes marketing said the system could provide. When as a result we could not qualify a system, we were sometimes accused of working for the FCC -- and not for the company. And marketing might be called upon to downgrade the features of a system so it could not be found non-compliant on audit. My personal reaction to problems with vendor compliance is to be as helpful to the vendor as my employer can afford to let me be. I PREFER to identify problems and devise cures before their teams show up. I've demonstrated problem and fix to a vendor at his own facility. We all want to make money -- and working together is easier than fighting each other. Naturally there is a quid-pro-quo. If we save a vendor from a (possible) fine and marketing sanctions, we'd expect a break on price and delivery. And a vendor might even agree. Now consider how things would work if we simply tested, failed and reported to the Commission. Monitors? Sorry! All booked up! For ten years! Come back then! If you're still in business! Back in the "good old days" there were on occasion tests of competing products to see if THEY were compliant. Not doing the due diligence needed for compliance can provide a time and price advantage for the scofflaw. In such a case, reporting to the regulatory authorities was a given. The FCC rules now in force anticipated that firms would continue to test competing products and thus perform an audit function it was no longer able to provide. In hindsight, what happened seems predictable; the new compliance regime appears to have resulted in relaxation to a level of compliance determined solely by the economics of being found out. When no one tests, that risk is low -- and when we merely buy another's import, it is infinitesimal. Cortland This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: [email protected] Dave Heald: [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
