Gert
>From my perspective, most of what you say below supports the position that only equipment specifically intended for "totally heavy industrial machinery/installations" should be Class A - and "everything else" should be Class B. Just a great pity that most of the regulators (across the World?) don't seem agree with, or even understand, that approach, and thus get swayed by the industry interest groups that you allude to below L. "Industry" will often do the very least that it can get away with in order to market their products, and that's why - in reality - Brian Kunde's comments about many companies doing more than is required is only - at best - partially true as a large proportion of them just plain don't. I suspect that some are large organisations, even though most are probably SMEs which simply don't have the financial leeway to do more than is legally necessary (even if they would want to) in order to compete with the large ones - therefore it must be up to the regulators to tighten the regulations appropriately. BTW, as for the medical installation to which you refer below, if that is in the EU (which I assume that it is) then 2004/108/EC, and thereafter, require installation owners to do appropriate EMC assessments, or to get appropriate EMC "experts" to do those assessments if they themselves don't have the relevant expertise - and the forthcoming presence of Class A ITE in a "sensitive" installation should then have rang "alarm bells" even before it was operated. Therefore the hospital management failed to meet their legal EMCD requirements, as well as a failure of a general duty-of-care to their patients! John Allen W.London, UK From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] Sent: 09 December 2015 18:50 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN55032 definition of residential environment Hi Ghery, (and all other members of this group) I do not think that one needs to be member of CISPR I WG2 or WG4 in any form to be able to discuss this topic. Ample documentation is available within the national committees, to get a clear image of the discussions in CISPR I and several of my close EMC friends have been participating. A simple division in Classes A and B (or Industrial versus residential or Domestic) cannot be seen as a regulatory statement. Division in classes is a common thing within all standards and has nothing to do with regulatory aspects. Different test levels are defined for different types of equipment taking in consideration their targeted environment (being not industrial or residential) . The European Commission's opinion on this subject is clear. EN standards should create a separate set of limits for 2 classes as described. The infamous Class A statement in CISPR22 actually encourages manufacturers to test and mark their products to industrial test levels and market them in residential environments. That actually is a regulatory aspect IMHO, as it overrules the requirements from the EC and the mandates given to CENELEC in creating harmonized standards. This unlevel playing field creates a tremendous amount of extra work for manufacturers that integrate ITE OEM product in for example (most) medical equipment, or radio equipment or laboratory equipment, that do not allow or for any Class A emissions. Just Integrate a touchscreen in a lab equipment and you will see what I mean. Many industrial sectors this way pay for the profits of the IT-industry that successfully "lobbied" their way into the IT standard. (not that lobby is illegal of course, it's just a way of defending ones industry sector) So this is how it happens that I (it actually happened) encounter 30 inch EN 55022 Class A LCD monitor in a local university hospital surgeons room that was intentionally shielded to allow sensitive correlation type of ECG equipment to function correctly. Well , it did interfere. (I also found a 100 mW Wi-Fi transceiver on the ceiling, but the frequency of that carrier is simply too high to interfere with the ECG stuff) . It makes very clear how unaware even (medical electronics) professionals are when it comes to the risks of EMC. This is why we have the EMCD, why we have CISPR and EMC standards, to recognise that EMC is not like dust, one cannot see when it's dirty. Gert Gremmen ce-test, qualified testing bv Van: Ghery S. Pettit [mailto:n6...@comcast.net] Verzonden: dinsdag 8 december 2015 20:00 Aan: EMC-PSTC@LISTSERV.IEEE.ORG Onderwerp: 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:g.grem...@cetest.nl] Sent: Tuesday, December 08, 2015 9:55 AM To: EMC-PSTC@LISTSERV.IEEE.ORG 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:bstu...@dlsemc.com] Verzonden: dinsdag 8 december 2015 14:38 Aan: EMC-PSTC@LISTSERV.IEEE.ORG 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:ian.mcbur...@allen-heath.com] Sent: Tuesday, December 08, 2015 2:55 AM To: EMC-PSTC@LISTSERV.IEEE.ORG 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: ian.mcbur...@allen-heath.com Allen & Heath Ltd is a registered business in England and Wales, Company number: 4163451. 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