Whoa Anthony, back up a little.

Test reports can contain what the heck a lab likes, as long as interpretations 
are indicated as such.


These words extracted from ISO 17025, the most common test document:


Clause 5.10 covers reporting the results:


Clause 5.10.1 The results shall be reported, usually in a test report or a 
calibration certificate (see Note 1), and shall include
all the information requested by the customer and necessary for the 
interpretation of the test or calibration
results and all information required by the method used.


So, Point 1, if the customer asks for an interpretation, then the standard says 
the lab provides it.


Clause 5.10.3.1 d) where appropriate and needed, opinions and interpretations ( 
See 5.10.5 )


Clause 5.10.5 When opinions and interpretations are included, the laboratory 
shall document the basis upon which the
opinions and interpretations have been made. Opinions and interpretations shall 
be clearly marked as such in
a test report.


Point 2 ) Here a lab is told how to deal with opinions and interpretations.


As for Assessing bodies forbidding inclusion of opinions and interpretations, 
well, here is the section from the NVLAP checklist dealing with 5.10.5:



5.10.5
Opinions and interpretations


When opinions and interpretations are included, the laboratory shall document 
the basis upon which the opinions and interpretations have been made. Opinions 
and interpretations shall be clearly marked as such in a test report.


NOTE 1 Opinions and interpretations should not be confused with inspections and 
product certifications as intended in ISO/IEC 17020 and ISO/IEC Guide 65.


NOTE 2 Opinions and interpretations included in a test report may comprise, but 
not be limited to, the following:
i) an opinion on the statement of compliance/noncompliance of the results with 
requirements;
ii) fulfillment of contractual requirements;
iii) recommendations on how to use the results;
iv) guidance to be used for improvements.


NOTE 3 In many cases it might be appropriate to communicate the opinions and 
interpretations by direct dialogue with the customer. Such dialogue should be 
written down.



Perhaps a change in assessing body is in order?  


As for an organisation doing both design and test, I am all for it. In my 
visits to manufacturers test facilities from Japan to Israel, I have been most 
impressed by the majority that go well above and beyond what any 3rd party lab 
would do in testing product. They simply cannot ship millions of widgets every 
month with the threat of a recall from poor evaluation of their widget. 


My $ worth.


Derek.


-----Original Message-----
From: Anthony Thomson <[email protected]>
To: EMC-PSTC <[email protected]>
Sent: Wed, Mar 20, 2013 5:11 am
Subject: Re: [PSES] Critical component in EMC report


 
"So our EMC reports do “freeze” a  state of the product, by listing all 
relevant (in our opinion) construction details."
 
Test Reports from independent test laboratories should NEVER, NEVER EVER, 
incorporate subjective opinions. It is your duty to identify the EUT by means 
of serial numbers, h/w & s/w revisions, photographs, objective descriptions, 
declarations of the build from the client etc., and describe the test 
configuration and set-up by means of diagrams, photographs, operating 
instructions etc.
 
In fact, accreditation bodies expressly prohibit independent laboratories from 
expressing opinions.
 
Assistance in identifying EMC critical design elements would be a consultancy 
service and could only be conducted in collaboration with the design authority. 
That same consultancy organisation cannot produce an independent test report. 
 
T
 
 
 

----- Original Message -----
From: ce-test, qualified testing bv - Gert Gremmen
Sent: 03/20/13 08:48 AM
To: [email protected]
Subject: Re: [PSES] Critical component in EMC report
 

EMC testing is a service to our clients, so as to allow them to sign
 
 
their Declaration of Compliance/conformance.
 
 
The EMC test report needs to enable our customer to 
 
 
efficiently and accurately create compliant products.
 
 
A problem with many small and medium enterprises is that they actually do not
 
 
know what they exactly offered for testing.  BOMs with almost unspecified 
 
 
parts are common. Mechanical drawings of the enclosure are often
 
 
missing   and I have yet to see
 
 
a customer provide me with a professional grounding diagram for EMC.
 
 
(Listing materials, paintings and EMC fixtures for example)
 
 
 
 
 
In fact most customers do NOT know what parts of the equipment
 
 
are relevant for EMC.
 
 
How ever can they produce compliant products ?
 
 
 
 
 
So our EMC reports do “freeze” a  state of the product, by
 
 
listing all relevant (in our opinion) construction details.
 
 
Starting with a diagram part list, pcb lay-outs and technical drawing,  
component brands
 
 
and grounding details are included. Software version is recorded
 
 
as well as hardware revisions. Drawings are dated and recorded.
 
 
 
 
 
For those customers that need to provide the test reports to their customer,
 
 
we issue a “results-only version” on request.
 
 
 
 
 
Too often this has proven to be useful, as our customer can fall back
 
 
of the details in the test report to detect the cause of a sudden failure.
 
 
 
 
 
 
 
 
 
 
 
 
 
 

Regards,

Ing.  Gert Gremmen, BSc
 
 
 
 
 
 
 
 
 
 
 
[email protected]
 
 
www.cetest.nl
 
 

Kiotoweg 363
 
 
3047 BG Rotterdam
 
 
T 31(0)104152426
F 31(0)104154953
 
 
Before printing, think about the environment. 
 
 
 
 
 

 
 
 

Van: [email protected] [mailto:[email protected]] Namens Bill Owsley
Verzonden: Friday, March 15, 2013 5:34 AM
Aan: Scott Xe; Anthony Thomson; [email protected]
Onderwerp: Re: [PSES] Critical component in EMC report
 
 

 
 
 

Indeed !!!  and that is why EMC Design Engineers and Consultants continue to be 
employed.
We know the "magic" and how to deploy it.
A few are better than most the others, but that is the challenge,
finding the ones that know the proper incantations to invoke for a first time 
pass, or at least a second pass.
Test labs just tell you that the product has failed the requirements, and 
provide some data.
The engineering folks have to guess from that data just what in the hell has 
happened.
If they had a problem in the first place, means that they are not qualified to 
figure out what has failed.
Call in a consultant... he is most likely a retired Test Engineer and has lot 
of experience with ferrites and copper tape.
But if that gets you under the limits - great!!
Or call in an EMC Design Engineer.  They fix things on the pcb's and schematics.
It's not cheap, but it sure goes right to the source of problem and also fixes 
SI, signal integrity.
Your design can start at 10 MHz and ship at 200MHz with no changes to the 
layout.
The same applies today with the proper scaling as mentioned by Dr, Howard 
Johnson of the "black magic" books.

 
 
 

 
 
 




From: Scott Xe <[email protected]>
To: Anthony Thomson <[email protected]>; [email protected]
Sent: Thursday, March 14, 2013 9:25 AM
Subject: Re: [PSES] Critical component in EMC report
 
 


 
 
 

Thanks for all responded!  For large companies, they may have test facilities 
and knowledgeable engineers to vary their products before sending to 3rd part 
lab for verification/certification.  For medium and small companies, they have 
no test facilities and the engineers who may not have got the professional 
training in EMC requirements rely on the 3rd party lab for spotting out the 
failures and the advice for problem fixing.  Dealing with such companies would 
be at risk as the test report may not help them too much.

Regards,

Scott

On 14/3/13 4:40 PM, "Anthony Thomson" <[email protected]> wrote:
 
 
Scott,
 
EMC compliance is the sole responsibility of the manufacturer (or whoever 
places the product on the market). It’s entirely up to you how you control 
ongoing compliance (or not).
 
T
 
 
 
 

----- Original Message -----

From: Scott Xe

Sent: 03/13/13 03:48 PM

To: [email protected]

Subject: [PSES] Critical component in EMC report
 
 
 
It is common not to have critical component list in EMC reports issued from 3rd 
party laboratories.  Those information are essential to track if the correct 
parts to be used in mass production.  What is main reason not to have it as a 
common practice in the field?

Thanks and regards,

Scott
 
 
 
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