I believe the references are 15.3(k) and 15.3(s). As to “confused yet”, I have been in that state ever since I started EMC work 30+ years ago. :(
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: Sykes, Bob [mailto:[email protected]] Sent: Friday, February 19, 2016 8:56 AM To: [email protected] Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? In addition to Mr. Ward's words of wisdom below, it is probably worth mentioning that a Class A digital device [as defined in Part 15.1(k)] aka "industrial computer" (which may be based on "PC" architecture) cannot take advantage of the "Declaration of Conformity" FCC Approval process(es). These are specific FCC approval routes that offers some flexibility, but only apply to Class B "Personal Computers" [PC as defined in Part 15.1(s)]. See Part 2 for the DoC administrative requirements [2.906 is good starting point]. There are also DoC specific labeling and test requirements found in Part 15. This DoC process has nothing to do with the CE Marking "Declaration of Conformity" To the original question poster: It may be worthwhile to take a look at the FCC Rules Part 15.31(3)(k) relating to Composite Systems. Confused yet? Glad it's Friday? -Bob Sykes From: dward [mailto:[email protected]] Sent: Thursday, February 18, 2016 3:38 PM To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? Probably one of the beneficial aspects of the FCC is that they tend to take the manufacturers word for how and where their devices are to be used. Thus, unless the documentation or other information clearly indicates one of those purposes is for use in the residential environments, the FCC accepts the manufacturers premises if it states ‘commercial use only’ or otherwise indicates how they control where the devices are used. That does not mean however that a company can go out to Best Buy and purchase a batch of laptops clearly intended for personal use and say they are ‘business computers’. They are still PCs but used in a commercial environment. So the idea that “Our company uses PCs with our products which are considered “Laboratory Equipment”. Our products only have to meet the Class A requirements…” may not be totally correct unless the computers the company actually buys is a Class A computer and not PC (Personal Computers). As 15.3s states, “…notwithstanding business applications. Such computers are considered Class B digital devices.” The guiding factor in a computer, computing device or digital device being Class B is in the following conditions: (1) Marketed through a retail outlet or direct mail order catalog. (2) Notices of sale or advertisements are distributed or directed to the general public or hobbyist users rather than restricted to commercial users. (3) Operates on a battery or 120 volt electrical supply. As the FCC rules state, the proof for classifying a digital device as other than Class B lies with the responsible party to demonstrate. Thanks 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: Kunde, Brian [mailto:[email protected]] Sent: Thursday, February 18, 2016 11:29 AM To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? I don’t think the answer can be found chapter and verse from some standard, but look at the historical evidence. Any electrical equipment, no matter what it is or what it does, what it is initially used for or how it is marketed, if it is likely to end up in homes or used in residential areas then it must meet the Class B requirements. Years ago, computers sold to the military only had to be Class A. But when old computers were replaced with new ones, the old ones found their way into people’s home. So now all computers have to be Class B. Computers with a Network Card used to only have to be Class A because “no one would ever use a network at home”. But, as soon as it became common for people to have home networks, computers and network cards had to meet Class B. So, if you use a stand-a-lone PC with an industrial device which can practically be used in homes, then the PC would have to meet Class B. Our company uses PCs with our products which are considered “Laboratory Equipment”. Our products only have to meet the Class A requirements, but the PCs have to meet Class B because no matter how we use it or what environment we use it, it is still a PC and could end up in someone’s home. I hope this was helpful. The Other Brian From: Ken Javor [mailto:[email protected]] Sent: Thursday, February 18, 2016 1:24 PM To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? Again I’m posing questions/observations, not acting as an expert, but it seems to me that a stand-alone computer, regardless of its purpose in a specific application, is not test equipment. By stand-alone, I mean not a PC embedded in a piece of test equipment. Ken Javor Phone: (256) 650-5261 _____ From: Bill Stumpf <[email protected] <mailto:[email protected]> > Reply-To: Bill Stumpf <[email protected] <mailto:[email protected]> > Date: Thu, 18 Feb 2016 17:13:21 +0000 To: <[email protected] <mailto:[email protected]> > Conversation: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? Dennis is 100% right. The exemption applies exclusively to products which are industrial, commercial, or medical test equipment. The "test equipment" classification applies to all of these categories, not only medical devices - at least this is my interpretation. So if the digital device is not test equipment, the exemption does not apply. If the exemption applies, it only pertains to the technical requirements of Part 15. The general operation requirements of 15.5 always apply. As to the Class A/B application, you have to look at how the device is marketed. If it is not marketed to the consumer and is not intended to be used in the home, then Class A applies. Bill Stumpf From: dward [mailto:[email protected]] Sent: Thursday, February 18, 2016 11:06 AM To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? In addition to the previous comment I made, it is noted that the FCC defines ISM equipment as “Equipment or appliances designed to generate and use locally RF energy for industrial, scientific, medical, domestic or similar purposes, excluding applications in the field of telecommunication.” So, unless a digital device meets the exemption requirements 15.103 and if it is not a piece of test equipment, it is subject to Part 15. Now then you must look to see if it is Class A or Class B. 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: dward [mailto:[email protected]] Sent: Thursday, February 18, 2016 8:46 AM To: 'Ted Eckert' <[email protected] <mailto:[email protected]> >; '[email protected]' <[email protected] <mailto:[email protected]> > Subject: RE: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? Several issues. First, 15.123 is not the clause exempting devices it is a clause referring to labeling of digital ready devices. Clause 15.103 is for exemption of devices. So, while it may say exempt, unintentional radiator devices are still subject to 15.5 and 15.29 with ‘strong’ recommendation to comply to part 15. (NOTE: 15.5b states “Operation of an intentional, unintentional, or incidental radiator is subject to the conditions that no harmful interference is caused and that interference must be accepted that may be caused by the operation of an authorized radio station, by another intentional or unintentional radiator, by industrial, scientific and medical (ISM) equipment, or by an incidental radiator.” 15.103 main paragraph states, “Although not mandatory, it is strongly recommended that the manufacturer of an exempted device endeavor to have the device meet the specific technical standards in this part.” So to say there are no mandatory EMC requirements is not accurate, as, while being exempt from any specific technical requirement, they are required NOT to interfere etc. It should also be noted that this exemption is ONLY for test equipment, not all digital equipment. NOTE: 15.103c says “A digital device used exclusively as industrial, commercial, or medical test equipment.” It is not saying a piece of medical test equipment and all other industrial or commercial equipment. It is saying industrial test equipment, commercial test equipment or medical test equipment. Also, be careful with the concept of fixed in regards exclusive use in these areas to exemption under 15.103. Exclusive does not mean fixed, it simply means that it is the ONLY area in which it is used, it means it cannot be taken out of the industrial, commercial or medical environment. I would think that test equipment would not be fixed and since the exemption for digital devices in these areas is for test equipment, I doubt if it means fixed. Thanks 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: Ted Eckert [mailto:[email protected]] Sent: Thursday, February 18, 2016 6:37 AM To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? Hello Michael, Whether or not EMC requirement apply in North America may depend on whether the industrial computer is in a fixed location. Digital devices that are part of industrial equipment are generally exempted. Incorporated devices are fixed in location and there is a general assumption that the environment is such that residential radio receivers, such as televisions, will not be within 3 meters of the equipment. A personal computer that has been ruggedized for use in industrial environments may still be subject to EMC requirements if it is movable. An industrial laptop, for example, may be used in a factory part of the time and in an office environment the rest of the time. I believe the key word is “exclusively” in the regulation you quoted. For a device to be exempted, it must be designed and marketed such that it is reasonably expected it will only be used in industrial environments. Best regards, Ted Eckert Microsoft Corporation The opinions expressed are my own and do not necessarily reflect those of my employer. From: [email protected] <mailto:[email protected]> [mailto:[email protected]] Sent: Thursday, February 18, 2016 2:09 AM To: [email protected] <mailto:[email protected]> Subject: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer? Hi, I am sorry if my question was answered anytime before. Nevertheless here my question: An European manufacturer has applied EN 61326-1 and EN 61010-1 for an industrial personal computer in an industrial plant for measurement purposes. What are the mandatory requirements regarding EMC in US/Canada? Is ICES-003 mandatory for Canada? If not in my understanding ICES-001 is also not applicable. Is § 15.123 "exempted devices" (A digital device used exclusively as industrial, commercial, or medical test equipment.) for US applicable? If yes, 47 CFR Part 18 is in my opion also not applicable. Therefore NO mandatory EMC requirements for equipment which are in the scope of EN 61326-1 are existing in US/Canada? Thanks for comments in advance. Michael Please be advised that this email may contain confidential information. If you are not the intended recipient, please notify us by email by replying to the sender and delete this message. The sender disclaims that the content of this email constitutes an offer to enter into, or the acceptance of, any agreement; provided that the foregoing does not invalidate the binding effect of any digital or other electronic reproduction of a manual signature that is included in any attachment. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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