John,
Good points and questions. Sounds like a good discussion for CISPR H. Without interference complaints being noted by regulators and reported to CISPR there would have to be a significant research project to see if the existing limits are adequate. I'm not aware of interference complaints due to inadequate limits in CISPR 22 or CISPR 32, but that doesn't mean that there aren't problems out there. As far as immunity test levels are concerned, there are valid arguments calling for higher test levels for certain tests. I haven't seen any proposals for higher test levels in CISPR 24 or CISPR 35, but that doesn't mean that such a push couldn't happen in the future. However, unless there are field failures due to perceived inadequate test levels, I don't see there being any significant efforts to raise the test levels. Do you have data that would impact this work in the future? Ghery S. Pettit From: John Allen [mailto:[email protected]] Sent: Tuesday, December 08, 2015 3:16 PM To: [email protected] Subject: Re: [PSES] EN55032 definition of residential environment Oh, and one other thing, I sometimes ponder is whether some of the immunity withstand limits (especially for radiated and conducted RF) for Class B equipment are higher enough for the "modern world" ,because: - Modern dwellings, especially in Europe and the Far East, are much smaller and more closely crowded together than they were 30-40 years ago, and so emission/immunity limits based on 10m (33 ft!) distances are now often totally unrealistic (many people live in dwellings where 10m is the distance to the next but one dwelling - not the next)! - There are vastly larger numbers of electronic products in many urban environments than there were then, and thus the cumulative electronic noise levels must be much higher now than then; - The frequency spectra of those devices is much wider now (all the way up to 5GHz+ - and rising!) than it was then! "Informed" opinions on the above would be interesting! John Allen W.London, UK From: John Allen [mailto:[email protected]] Sent: 08 December 2015 22:41 To: [email protected] Subject: Re: [PSES] EN55032 definition of residential environment On the issue of the "residential" environment, I think that whole issue is now becoming very blurred in reality with the (at least in the UK) trend to using former industrial buildings for residential use - as well as the more general diffusion of the physical barriers between residential and industrial premises, because what can now really be defined as one or the other now that businesses are being located in what would generally be considered as "residential locations" (at least in the "developed" countries)? Personally, I think that only equipment specifically intended for "totally heavy industrial machinery/installations" should be Class A - and "everything else" should be Class B. John Allen W.London, UK From: Ronald Pickard [mailto:[email protected]] Sent: 08 December 2015 19:32 To: [email protected] Subject: Re: [PSES] EN55032 definition of residential environment Hi Ian, The "residential" environment is generally understood to be the household/domestic environments where humans typically "reside". With that said and further into EN 55032 clause 4, there is a subtle and a bit of a loose Class B definition: "The Class B requirements are intended to offer adequate protection to broadcast services within the residential environment." Such residential broadcast services would typically include radio and television for personal consumption, and possibly including Wi-Fi now-a days. And, I'm not sure what "adequate protection" actually means in this case, but given Ghery's statement below, I doubt that it will get any more definitive. Best regards, Ron Pickard Regulatory Compliance Engineer Compound Photonics D | +1 (602) 883-8039 From: Ghery S. Pettit [mailto:[email protected]] Sent: Tuesday, December 08, 2015 12:00 PM To: [email protected] Subject: Re: [PSES] EN55032 definition of residential environment Disclaimer - While I am the Vice Chairman of CISPR I, the following is my personal opinion and does not necessarily reflect the opinions of the Chairman or other members of CISPR I, its working groups, national committees or IEC HQ. That said. I don't recall seeing Gert at CISPR I meetings, nor CISPR I WG2 (emissions) or CISPR I WG4 (immunity) meetings (he isn't a member of either WG). If he were present, he would know that the reason such regulatory statements are not in CISPR standards such as CISPR 22, 24 or 32 is that CISPR standards may not contain regulatory statements. Defining which products must meet Class A or Class B limits is up to regulators. There as even been discussion about the "legality" of the Class A warning label in CISPR 22 and 32. CISPR 32 does have language that gives guidance to help the user of the standard properly apply it, but a regulator is free to ignore or change this at their discretion. So, to say that CISPR I has been "notorious" is a bit of a stretch, in my opinion. There has been no serious work done to have two different immunity levels in CISPR 24 or 35 as it has not been felt to be needed. Join your national committee (or contact it) and make a proposal if you feel that such additional test levels would be warranted. A persuasive argument would be given a fair hearing. Be aware that any new requirements will take years to incorporate into a standard. Remember, CISPR I has been trying to get CISPR 35 published for nearly 15 years as it is, but feel free to make a proposal for an amendment to add different test levels for Class A products. Just remember, we've gotten along well with single limits in CISPR 24 since it was originally published in 1997, so a convincing argument will be needed. Ghery S. Pettit Vice Chairman, CISPR SC I From: ce-test, qualified testing bv - Gert Gremmen [mailto:[email protected]] Sent: Tuesday, December 08, 2015 9:55 AM To: [email protected] Subject: Re: [PSES] EN55032 definition of residential environment 1. Independent of the standards, the EMC directive requires marking on typeplate and/or documentation if an equipment is non-residential. 2. Unwilling standards committees have been "reluctant" in including the definitions in written in their standards. CISPR I has been notorious in these for years, by not even defining Class A for immunity (CISPR 24). There are ample standards and EC documents giving an appropriate definitions, in general something like: If it is predominantly used for households or is connected to a residentially used power newtwork the equipment will be residential or often said "Class B". If connected to a private power network then it should be Industrial or "Class A". One standard that comes to mind that gives a good description including examples is EN 61326-1:2013. An EC document TC210/Sec0515/INF from 2007 addresses the topic in full and includes the recommendation to include a common definition in all harmonized standards. Gert Gremmen Van: Bill Stumpf [mailto:[email protected]] Verzonden: dinsdag 8 december 2015 14:38 Aan: [email protected] Onderwerp: Re: [PSES] EN55032 definition of residential environment Ian, There is no definition of "residential" environment in the standard or the EMC Guide. For reference, the FCC classifies products into consumer (Class B) and non-consumer (Class A) categories. In Europe the manufacturer has a similar responsibility to make a product that meets the EMC requirements appropriate for the intended use of the product. For some products it is more or less up to the end user to determine if a Class A or Class B compliant product is appropriate. You will find the Class A warning statement in the EN 55032 standard, Clause 7. Class A equipment shall have the following warning in the instructions for use, to inform the user of the risk of operating this equipment in a residential environment: W arning: This equipment is compliant with Class A of CISPR 32. In a residential environment this equipment may cause radio interference. Bill Stumpf - Lab / Technical Manager D.L.S. Electronic Systems, Inc. 166 South Carter Street Genoa City WI 53128 Ph: 262-279-0210 From: McBurney, Ian [mailto:[email protected]] Sent: Tuesday, December 08, 2015 2:55 AM To: [email protected] Subject: [PSES] EN55032 definition of residential environment Dear colleagues In the 2015 edition of EN 55032 an interesting statement in clause 4. "Equipment intended primarily for use in a residential environment shall meet the class B limits. All other equipment shall comply with the Class A limits." I am unable to locate a definition for residential environment in the standard. Does anyone know of an official definition? Would sports stadia, theatres, hospitals, commercial industrial estates located in residential housing be included in residential environments? If the product is Class A, is the warning notice still required? "Warning. This is a Class A product. In a domestic environment this product may cause radio interference in which case the user may be required to take adequate measures." This used to be a requirement in EN 55022. Many thanks in advance. Ian McBurney Design & Compliance Engineer. Allen & Heath Ltd. Kernick Industrial Estate, Penryn, Cornwall. TR10 9LU. UK T: 01326 372070 E: [email protected] Allen & Heath Ltd is a registered business in England and Wales, Company number: 4163451. 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