>We now have radiated immunity testing at 3V/m, but I have never seen a product fail this testing at this low level.
I am operating a small Netherlands test house, and I can assure you that many products In my lab do fail 3V/m (at 80%AM) initially. Any analogue measurement system (thermocouples) is very susceptible to 3V/m if no basic decoupling caps and/or serial impedance are present, connected to a decent ground plane. Regularly EUT fail right starting the test at 80 MHz, and I have seen an internal power supply of a reputable USA brand (24V 10 amps) actually switching OFF (not fold back, inoperable until power off) at 3 V/m. >Also, I never see any electrical fast transient (EFT) failures at the European mandated levels Same for EFT. Residential levels of 1000/500 V do have a huge impact on reset switches in uP systems if not correctly decoupled. Audio systems change in beepers. Crow bar protections in power supply suddenly conduct and blow a fuse, and triac regulated dimmers spontaneously ignite. Nevertheless, the levels are low, I agree and are easy to meet. That is a reasonable approach for government regulation on non-safety related functional tests. Some commercial entities simply need a kick in the ..., just to take their consumers seriously. Note that testing (in the EU) is not an obligation, you may carry out testing yourself, substantially reducing costs, or build your technical file based on similarity of design. >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 You hit the nail on the head: for most product releases ! So what would have happened with those releases that failed.... Jeopardized your brands reputation ? Gert Gremmen From: Monrad Monsen [mailto:[email protected]] Sent: Wednesday 16 September 2015 00:49 To: [email protected] Subject: Re: [PSES] RF Common Mode Immunity Test Question 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. 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. ________________________________ From: dward <[email protected]> <mailto:[email protected]> Sent: Tuesday, September 15, 2015 2:37 PM To: [email protected] 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 This communication and its attachements contain information from PCTEST Engineering Laboratory, Inc., and is intended for the exclusive use of the recipient(s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachments(s) are free from computer virus or other defect. Thank you. From: John Allen [mailto:[email protected]] Sent: Tuesday, September 15, 2015 11:01 AM To: [email protected] 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:[email protected]] Sent: 15 September 2015 18:51 To: [email protected] 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 [email protected] <mailto:[email protected]> 5601 Great Oaks Parkway San Jose, CA 95119 www.hgst.com <http://www.hgst.com> -----Original Message----- From: Gary McInturff [mailto:[email protected]] Sent: Tuesday, September 15, 2015 9:16 AM To: [email protected] <mailto:[email protected]> 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:[email protected]] Sent: Monday, September 14, 2015 11:38 PM To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] RF Common Mode Immunity Test Question In message <[email protected]>, dated Mon, 14 Sep 2015, Ed Price <[email protected]> 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 - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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