Apologies for the late response on this but the concerns raised (market 
surveillance, test methodologies and standards
interpretation) go right to the heart of the compliance engineering function - 
and has been this way for about 30 years!

Kris - the standards piece seems to be pretty well laid out, however you asked 
a key question at the end of your original
email that raised my interest!  

You asked:  "So to me it looks sufficient to test a typical set-up, do your 
best to not make it best case and describe everything in the report" . This 
statement embraces the issue of consistent and accurate  emissions testing 
because
with that  your concerns of failing due to a 3rd party test would be much 
reduced. 

However due to the very nature of the systems level of the test, the 
variabilities  between sites,  measurement 
uncertainty (which by itself acknowledges the variability in our test 
equipment!) and manufacturing variances makes
consistent testing challenging.   However there is one technique (that has 
fallen out of favor) that can help
to ameliorate some of these concerns and that is cable maximization.   Cable 
maximization  IS time consuming 
frustrating at times but it will minimize your risks at a 3rd part location.


Best Regards
Charles Grasso
Compliance Engineer
Echostar Communications
(w) 303-706-5467
(c) 303-204-2974
(t) [email protected]
(e) [email protected]
(e2) [email protected]


-----Original Message-----
From: Carpentier Kristiaan [mailto:[email protected]] 
Sent: Friday, September 05, 2014 8:36 AM
To: [email protected]
Subject: [PSES] Failure of Radiated emission

Hi group,

A ITE product is tested to EN55022 Radiated emission with a well defined setup 
(cables, traffic, etc...) trying to find the worst case emissions and it passes.
I think finding the real worst case emission for all frequencies with one and 
the same set-up is in practice not possible in practice.

That same product is retested by a customer or in case of market surveillance 
campaigns, then it is most likely not tested with the same set-up and results 
may fail.
Would this be an issue or is it acceptable that it is retested with the same 
set-up as the initial testing? I refer to CISPR22, clause 8.4 that states that 
the operational conditions of the EUT shall be determined acc. to typical 
use.....The operat mode and rationale shall be stated in the report.

So to me it looks sufficient to test a typical set-up, do your best to not make 
it best case and describe everything in the report.

Any other thoughts?

Best regards,
Kris Carpentier

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