Every design and manufacturing facility has not just a single test fixture but 
several hundreds of them as they design, build, and produce the product. Every 
development chassis sitting in engineering labs or desks are test fixtures, 
every PCB that is plugged into a backplane for trouble shooting is a test 
fixture, every burn-in rack is a test fixture, none of which are available to 
the consumer either to - either private or public, so they are never on the 
"market" at all - there is no market. Simple turning on a device that has no 
commercial usage doesn't define a market. Trying to justify that a manufacture 
must certify internally used and controlled production and development 
equipment when they don't, and can't,  exist in the commercial world is neither 
rational nor enforceable, in my opinion.  It is such folly that I can't believe 
it is even an intent for the regulations rather I would suggest it's an 
unintended consequence. This isn't even a loophole in the protection of the 
public airways since enforcement still exists that would require any devices 
-real or for production purposes- that interfere with the public airways etc to 
be shut down or ameliorated.
There is a huge difference between 1 or 10's of units in a specific industrial 
location and thousands and millions of units in homes and offices around the 
world, and trying to enforce a problem that doesn't exist isn't a useful nor a 
pragmatic or truly enforceable exercise - even if it a purposeful intent rather 
than an unintended consequence.

Obviously this is my opinion only.


Gary

From: Bill Owsley [mailto:[email protected]]
Sent: Wednesday, September 19, 2012 8:06 PM
To: [email protected]
Subject: Re: [PSES] Test Fixture for Self

If used in a building or area under our control, I apply the standard at the 
boundary of our space.
If we interfere with ourselves - too bad.  If we impact others - so sad and fix 
it!!


________________________________
From: "[email protected]" <[email protected]>
To: [email protected]
Sent: Wednesday, September 19, 2012 8:24 AM
Subject: Test Fixture for Self


If a manufacturer builds a test fixture only to be used by the manufacturer 
(not commercially available), does the test fixture need to undergo EMC 
testing? If so, where is this called out?

Can "placing on the market" and "putting into service" be different things?

Thanks,
Bob Heller
St. Paul, MN 55107-1208
Tel: 651-778-6336
Fax: 651-778-6252

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