Dear colleagues.

Many thanks for your responses, they have all made interesting reading.

However; I am no wiser regarding whether sports stadia or theatres would be 
considered Class A or Class B environments. As a manufacturer of a range of 
products that can be used in bedrooms through to products that can be used in 
large stadia, examples of class A and Class B would be useful. Obviously the 
"bedroom" product is easy to define but the products used in large auditoriums 
or stadia are more difficult to categorise. They are all powered from the same 
13A ac socket as the "bedroom" product.  The old standard we used to apply i.e. 
EN 55103-1:2009 did specify the environments with some examples so helped to 
define which products were Class A or Class B. It would have been helpful if EN 
55032 had a similar section.

Regards;

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


From: Brian O'Connell [mailto:oconne...@tamuracorp.com]
Sent: 09 December 2015 22:11
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN55032 definition of residential environment

Thread has some good artifacts of compliance engineering philosophy. But 
industry has determined some resultant intended side effects.


1.       EMC standards and limits are referenced by some electrical efficiency 
regulations to determine if scoped for a product.

2.       Some AHJs and governments have used the product's stated EMC limits to 
scope effective building/electrical code sections.

To wit, have seen some equipment that where the test data indicates a margin 
well below Class B limits, but the report indicates Class A compliance. So Mr. 
Pettit's assertion could be supported for these particular cases.

Brian


From: Ghery S. Pettit [mailto:n6...@comcast.net]
Sent: Wednesday, December 09, 2015 12:26 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EN55032 definition of residential environment

Again, if you feel that the division between Class A and Class B should be as 
you describe, get your national committee to push it.  Personally, my 
experience does not back up your assertion that the warning statement 
encourages manufacturers to go with Class A.  But, perhaps that was because I 
worked (I retired from them in June) for Intel and they didn't buy into that 
game.  Perhaps that was because I set the policy, or at least had a lot of 
influence on it, and I didn't buy into that game.  But, the other major 
manufacturers that I dealt with also didn't buy into it.  So, please back up 
your assertions with data.

While I agree with you that a simple division between Class A and Class B 
shouldn't be viewed as regulatory, others at higher pay grades have taken 
exception to it.

I also agree that some equipment being Class A and other equipment being Class 
B creates difficulties for companies integrating the two.  This is not a new 
issue, I remember this being a problem nearly 30 years ago for products being 
sold into the European market.  A box which connected to the telecom network 
was Class B, but anything else in the system (mainframe) only had to meet Class 
A.  So, what was the environment in the machine room?  Class A, of course.  
But, regulators had their requirements.  :)

Ghery

From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl]
Sent: Wednesday, December 09, 2015 10:50 AM
To: Ghery S. Pettit; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto: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<mailto: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<mailto: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<mailto: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<mailto: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<mailto:ian.mcbur...@allen-heath.com>
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