Gary, I happen to agree, but unfortunately EMC compliance is required for "own use" equipment. Section 1.2.6 of the Guide for the EMC Directive states:
"Where an apparatus is manufactured for own use, placing on the market is considered to take place at the moment of putting into service; the obligation to comply with the Directive begins with first use." My opinion doesn't matter. The condition is stated so there is no justification required. Europe is more proactive and requires compliance before harm is done. In the US we are reactive and we wait until someone dies before we do anything about it. :) Bob Heller 3M EMC Laboratory, 76-1-01 St. Paul, MN 55107-1208 Tel: 651-778-6336 Fax: 651-778-6252 ================================= From: "McInturff, Gary" <[email protected]> To: "'Bill Owsley'" <[email protected]>, "'[email protected]'" <[email protected]> Date: 09/20/2012 10:24 AM Subject: RE: [PSES] Test Fixture for Self Sent by: [email protected] 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 - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to < [email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to < [email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to < [email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
