I'll only add that the descriptions and examples in the 61000 generics are pretty clear. Like everything else with EMC, there are shades of grey. _______________________________________________________________________________
Ralph McDiarmid | Schneider Electric | Solar Business | CANADA | Regulatory Compliance Engineering From: "Ghery S. Pettit" <[email protected]> To: [email protected], Date: 12/10/2015 09:15 AM Subject: Re: [PSES] EN55032 definition of residential environment Ian, I’m not a lawyer, nor do I play one on TV, but in my opinion (worth exactly what you are paying for it) these would be examples of Class A environments. They aren’t domestic environments. Others may disagree, but that’s how I view it. From: McBurney, Ian [mailto:[email protected]] Sent: Thursday, December 10, 2015 3:39 AM To: [email protected] Subject: Re: [PSES] EN55032 definition of residential environment 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: [email protected] From: Brian O'Connell [mailto:[email protected]] Sent: 09 December 2015 22:11 To: [email protected] 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:[email protected]] Sent: Wednesday, December 09, 2015 12:26 PM To: [email protected] 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. J Ghery From: ce-test, qualified testing bv - Gert Gremmen [ mailto:[email protected]] Sent: Wednesday, December 09, 2015 10:50 AM To: Ghery S. Pettit; [email protected] 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:[email protected]] Verzonden: dinsdag 8 december 2015 20:00 Aan: [email protected] 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:[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] - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to < [email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> Allen & Heath Ltd is a registered business in England and Wales, Company number: 4163451. 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To post a message to the list, send your e-mail to < [email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> ______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. ______________________________________________________________________ - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to < [email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
