Hey Monrad,

 

The approvals need to match the market access that you need the product
shipped to.

 

Thanks!

 

Chas

________________________________

From: [email protected] [mailto:[email protected]] 
Sent: Wednesday, August 19, 2009 11:37 AM
To: Grasso, Charles
Cc: Dan Roman; [email protected]
Subject: Re: [PSES] Approvals Required for USB Flash Drive or "Thumb Drive"

 

So we all agree on the need for testing -- both emissions and applicable
immunity testing.  

What approvals would be needed?  Does the USB Flash Drive itself need a CE
mark, FCC Class B mark, VCCI, BSMI, etc.?  Or are the approvals applied to the
system (the PC, workstation or server) and the USB Flash Drive is merely
tested to verify that this "component" does not mess up the passing emissions
profile and immunity of the system?

Thanks.

Monrad L. Monsen
Worldwide Compliance Officer
Sun Microsystems
[email protected]
303.272.9612 Office

 


Grasso, Charles wrote: 

Hello Monrad,

No brainer here!!

The definition says:

1.1.4 Inherently benign equipment

Equipment which is inherently benign in terms of electromagnetic

compatibility is excluded from the scope of the EMC Directive25.

Equipment is considered inherently benign in terms of electromagnetic

compatibility if:

• its inherent physical characteristics are such that it is incapable of

generating or contributing to electromagnetic emissions which

exceed a level allowing radio and telecommunications equipment

and other equipment to operate as intended; and,

• it will operate without unacceptable degradation in the presence of

the electromagnetic disturbance normally present in its intended

environment.

Both conditions need to be met in order to classify equipment as inherently..

 

A USB stick is NOT a benign device from an EMC standpoint. If you stick that
on the end of a 2ft cable

 (sometimes supplied with the USB stick) and run an emissions test you will be
amazed at the emissions you’ll see. 

I concur with Dan. I have seen some truly noisy manufacturers.!!

 

I agree with your choice of specifications with maybe the exception of
powerline mag field.

 

Chas

 

________________________________

From: [email protected] [mailto:[email protected]] On Behalf Of Dan Roman
Sent: Wednesday, August 19, 2009 7:11 AM
To: [email protected]; [email protected]
Subject: RE: [PSES] Approvals Required for USB Flash Drive or "Thumb Drive"

 

Monrad,

 

I have tested PCs with thumb drives attached and while most from reputable
companies easily pass Class B emission limits I have had some of the freebie
drives you get a trade shows and in the mail from vendors fail Class A limits.
 I should note that the good ones have a CE Mark and FCC Class B logo on them
and the real bad ones only had some advertising stickers!  Beware, you
apparently get what you pay for.

 

Dan

 

From: Monrad Monsen [mailto:[email protected]] 
Sent: Tuesday, August 18, 2009 8:59 PM
To: [email protected]
Subject: [PSES] Approvals Required for USB Flash Drive or "Thumb Drive"

 

What EMC and safety approvals are required for USB flash drives or "thumb
drives"?

We are preparing to source for re-sell some USB flash drives from another
company that tells us that they are exempt.  They have a Declaration of
Conformity (DOC), but no supporting test reports.  This seems flaky to me on
many levels.  

Looking at the "USB flash drive" article in Wikipedia, the devices would have
a 12 MHz clock oscillator, so I can't merely say it is passive memory. 
However, could the USB flash drive still be excluded from the scope of the
European Union EMC Directive 2004/108/EC as inherently benign equipment?  See
section 1.1.4 within the "Guide for the EMC Directive 2004/108/EC".
(http://ec.europa.eu/enterprise/electr_
quipment/emc/guides/emcguide_may2007.pdf)  I would want the device tested for
radiated emissions, as well as the EN55024 enclosure port immunity tests like
RF radiated field immunity, ESD, and power frequency magnetic field immunity.

I see that the LVD Directive 2006/95/EC limits its cope to equipment operating
in the range of 50-1000VAC and a range of 75-1500VDC.  (Article 1 of LVD
Directive 2006/95/EC)  However, "electrical components which are intended to
be incorporated into other equipment and for which a risk assessment can be
undertaken, such as transformers and electrical motors, are covered as such by
the Directive and must be CE marked."  (Section 9, "Guidelines on the
Application of Directive 2006/95/EC")  I would assume that this standard USB
flash drive would fit this description.  

Please confirm what worldwide EMC and safety approvals and testing is
required.  I definitely plan to required some systems level EMC testing that
includes the USB Flash Drive mounted on a server or PC, but I need to confirm
what agency approvals are needed for the Flash Drive to be able to sell
worldwide including the frequently regulated countries like USA, Canada,
Europe (plus Turkey), Australia, Japan (VCCI), Taiwan, China, Russia,
Argentina and Mexico.

Thanks.

-- 

Monrad L. Monsen
Worldwide Compliance Officer
Sun Microsystems
[email protected]
303.272.9612 Office

  

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