Hi Ted,

Thanks for your opinion.  The excessive sound pressure issue occurred since
Sony Walkman era and taken up by Apple iPods in last few years.  The issue
was discussed/debated many years ago and concluded a standard for
compliance.  Both will harm our human ears at high sound level regardless of
analogue devices or digital devices.

In the past, Apple iPods could not run 10 hours per single charge of battery
pack using micro drive while Sony MP3 players was able to play music for 52
hrs per single charge of battery pack.  On the latest versions, it is easily
to achieve long hour playback.

It is a very valid point for digital devices that employ the firmware for
controlling the functionality and features.  Adding the instructional
safeguard is deadly easy to accomplish.

I guess the standard working committee does not want to control analogue
devices since there would be a strong reaction.  They also believe even they
are not controlling them, they are going to phasing out soon.  Music files
will replace CDs, DVDs or even BDs.  HMV closing down in the UK is a good
trend indicator.

Is there any particular reason for EN standards that are written with the
aid of attorney to understand?  Most of readers are normal engineers and
they find difficult in understanding/interpreting the standard easily and
correctly.  Do they have any mechanism to help the engineers to use the
standard correctly?

Regards,

Scott


On 5/2/13 5:38 AM, "Ted Eckert" <ted.eck...@microsoft.com> wrote:

> Hello Scott,
> 
> I believe that there are at least two reasons analog music players are
> exempted. The first is that the instructional safeguard in the standard is to
> provide a specific notification to the user when they exceed 85 dBA. This is
> not practical on a purely analog device. The instructional safeguard must be
> repeated  for every 20 hours cumulative listening above 85 dB, and an analog
> device cannot easily make this measurement. Second, analog devices such as a
> portable cassette tape player are not practical to use for extended periods. A
> user who wanted to listen to 10 hours of continuous music would need to carry
> around quite a few cassette tapes or would have to listen to the same tape
> over and over. 
> 
> I believe that portable CD players are within the scope of the requirement.
> However, a portable DVD player that includes a screen is different from a CD
> play.  Although it is technically possible to walk around with a DVD player
> while watching a movie, it is neither practical nor a normal use. However, I
> am not qualified to say with certainty whether a portable DVD player is
> exempted. It is possible that you can make a reasonable argument that a
> portable DVD player would not fit within the scope. However, that will depend
> on the design and features of the DVD player.
> 
> It may be best to consult an attorney who is familiar with the regulations to
> determine if a particular product is within or outside of the scope.
> 
> Regards,
> Ted Eckert
> Compliance Engineer
> Microsoft Corporation
> ted.eck...@microsoft.com
> 
> The opinions expressed are my own and do not necessarily reflect those of my
> employer.
> 
> 
> 
> -----Original Message-----
> From: Scott Xe [mailto:scott...@gmail.com]
> Sent: Monday, February 04, 2013 8:15 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: EN 60065 A12 - Sound Pressure Restriction
> 
> Dear Sir/Madam,
> 
> In this requirement, there is a following exemption.
> 
> €    analogue personal music players (personal music players without any
> kind of digital processing of the sound signal) that are brought to the market
> before the end of 2015.
> 
> NOTE 4
> 
> This exemption has been allowed because this technology is falling out of use
> and it is expected that within a few years it will no longer exist. This
> exemption will not be extended to other technologies.
> 
> I believe the old design portable DVD players with a pair of earphones and
> operated on batteries or rechargeable batteries are qualified for such
> exemption.  I am seeking advice why the digital processing of sound signal is
> so critical to this sound pressure restriction and how to identify if the
> digital processing is built in the unit or not.
> 
> Thanks and regards,
> 
> Scott
> 
> -
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