Re: [PSES] RF Common Mode Immunity Test Question

[Monrad Monsen]

Interesting discussion regarding pros & cons on government regulations.
The companies I have worked for took it seriously that they wanted their 
products to be reliable to maintain a good name with customers.  We did 
ESD, voltage dips & interrupts, and shock & vibration testing on our 
products long before Europe came up with immunity requirements.  Had 
studies been done on typical surges seen at customer sites along with 
developing surge test equipment, we would have done surge testing as 
well even without a regulatory requirement.

What did regulation add? We now have radiated immunity testing at 3V/m, 
but I have never seen a product fail this testing at this low level.  
Instead, this testing is an overhead cost to products that may have 
small changes that would not be impacted by this particular test.  In 
actuality, our company chooses to add radiated immunity test 
requirements at 12V/m level at spot frequencies in wireless bands.  
Again, why do we do this?  Do ensure our products do well at customer 
sites and to maintain our corporate reputation.  However, it is best to 
allow the manufacturer/designer to focus efforts and cost to areas that 
benefit the customer the most ... so costs can be controlled for the 
customer (the customer ultimately pays for development work done on the 
product).

Hate to say it in this discussion list, but most reliability is gained 
by having good functional testing of the code and Beta testing.  We have 
to be careful about how much EMC testing is mandated.  Today, the 
standards committees are going beyond the original intent (reduce 
interference by mandating emissions limits) and now are trying to become 
too scientific about the exact measurement uncertainty and careful 
characterization of the nonconductive table, etc.  All of this is 
occurring even though the number of FCC interference complaints per year 
has dropped to almost non-existent.   Also, I never see any electrical 
fast transient (EFT) failures at the European mandated levels.  We 
already re-use the many of the same power supply designs and filter 
designs for many generations of products. In our case, the EFT test is a 
waste of time for most product releases, but we have to complete the 
record because of a regulatory burden (not just Europe, but now for 
South Korea).   My point is ... don't add unnecessary test cost burden.  
Let the manufacturer focus development and test time on what is of value 
to the customer.

I happen to be involved in the international standards committees 
because the main thing we want is consistency so the same product can be 
sold worldwide.  The ultimate goal should be one standard, one test, one 
mark, and worldwide acceptance.  Personally, I would prefer that FCC 
drop all use of ANSI standards and strictly adopt the international 
emissions standard.  I certainly don't want FCC to add immunity 
requirements.

Please remember that customers are smarter than some in government give 
them credit for.  They know that they get what they pay for. If they 
purchase from a solid known brand, they may pay more but they will get a 
reliable product that will last them for years to come.  However, no one 
in India would want to pay double the price for a printer compared to 
the price the same printer is offered in USA ... but India's government 
that almost mandates in-country testing forces this kind of higher 
pricing in their country. Regulation strikes again.

Research -- yes.
Regulation -- no. (Exceptions may be for a valid safety concern for 
customer or excessive interference potential neighbors.)

Monrad
Note:  All opinions expressed in this e-mail are my own and are not 
necessarily those of any company I work for or have worked for.
<http://www.oracle.com>
On 9/15/2015 1:32 PM, Rodney Davis wrote:

How many big companies survive if their only market is USA.  Pretty 
safe to say almost all major players have a European, and other 
regions of export and hence though not specifically requiring 55024 
most product sold I think would be safe to say meet immunity.


Too expensive to have a fully approved variant and a second variant 
 approved for NA.


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*From:* dward <dw...@pctestlab.com>
*Sent:* Tuesday, September 15, 2015 2:37 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] RF Common Mode Immunity Test Question

As a US citizen my premise on any government involvement is to make it 
as impossible or as hard for them to regulate anything as can be. This 
includes EMC, immunity or any other thing.  Too many fall under the 
idea that personal safety outweighs personal freedom.  That may work 
in a socialist type environment, but not in here.

Dennis Ward

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*From:*John Allen [mailto:john_e_al...@blueyonder.co.uk]
*Sent:* Tuesday, September 15, 2015 11:01 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] RF Common Mode Immunity Test Question

Ravinder

W.r.t. your 2nd para, the 1st  sentence is roughly what I said in an 
earlier post - but the 2nd sentence could be a misleading assumption 
because of what you said in the 1st para (and what I also said in my 
earlier post about bean counting for the US market!) L

John Allen

W.London, UK

-----Original Message-----
From: Ravinder Ajmani [mailto:ravinder.ajm...@hgst.com]
Sent: 15 September 2015 18:51
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] RF Common Mode Immunity Test Question

Pardon my skepticism, but I have very little faith on the US 
industries self-enforcing any kind of regulations.  When Wall Street 
analysts expect public companies to show higher profits quarter after 
quarter, lowering the cost becomes the key driver.

However most US companies ship their products overseas, and almost all 
of these countries have some form of immunity requirements, similar to 
the EU regulations.  Hence one can assume that the products built in 
US are designed to meet these requirements.

The sad thing is that in until the eighties US was leading the world 
on EMC requirements, but now has fallen behind.

My personal view.

Regards

Ravinder Ajmani

HGST, a Western Digital company

ravinder.ajm...@hgst.com <mailto:ravinder.ajm...@hgst.com>

5601 Great Oaks Parkway

San Jose, CA 95119

www.hgst.com <http://www.hgst.com>

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

From: Gary McInturff [mailto:gary.mcintu...@esterline.com]

Sent: Tuesday, September 15, 2015 9:16 AM

To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>

Subject: Re: [PSES] RF Common Mode Immunity Test Question

Well not really John - ANSI has no regulatory authority but money 
does. A business isn't likely to simply add either NRE cost or cost 
per unit without justification - poor product performance, competitive 
advantage, regulation. Poor performance isn't even a clean definition 
- if I have one failure out of 10,000 because of ESD for example - 
just ship them another one etc.

My personal opinion is that proper operation in the field is as 
important as any other functional specification but whether it's done 
through self-enforcement or governmental regulation is a thorny question.

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

From: John Woodgate [mailto:j...@jmwa.demon.co.uk]

Sent: Monday, September 14, 2015 11:38 PM

To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>

Subject: Re: [PSES] RF Common Mode Immunity Test Question

In message <009601d0ef5d$3dc51eb0$b94f5c10$@cox.net 
<mailto:009601d0ef5d$3dc51eb0$b94f5c10$@cox.net>>, dated Mon, 14 Sep 
2015, Ed Price <edpr...@cox.net <mailto:edpr...@cox.net>> writes:

>True, the FCC is essentially still following the Communications Act of

>1934 in its scope. However, telegraph rates aren?t so important

>anymore, while the issue of consumer electronics immunity certainly is.

>We expect our laws and regulations to evolve to address the important

>issues of the day, junking the obsolete and helping with new conflicts.

It is interesting that the US (ANSI) participates fully in the IEC 
committees on immunity, having four experts on each and holding the 
Convenership of one.

Immunity is for other people, right?just

--

OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk 
<http://www.jmwa.demon.co.uk> When I turn my back on the sun, it's to 
look for a rainbow John Woodgate, J M Woodgate and Associates, 
Rayleigh, Essex UK

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