Derek:

About the only place I would like to fall is on the side of truth and integrity.

I’ll drop some bright blue comments into your response below

This is long; too bad I don’t get paid by the word!


Ed Price
WB6WSN
Chula Vista, CA USA

From: DEREK WALTON [mailto:[email protected]]
Sent: Wednesday, April 17, 2019 8:47 PM
To: Edward Price
Cc: EMC-PSTC
Subject: Re: [PSES] Question re: Measuring a signal in a noisy environment

Whoah Ed,

you just landed along side Ken and Ghery!

Derek, I’m not aiming my comments at you, you are simply in the sequence of the 
thread. But however I have landed, I feel I’m in good company. I don’t know why 
you would “strongly oppose some of my views” because I always thought that I 
was on the side of reason and sweetness.

I have to strongly oppose some of your views on what the test lab should or 
shouldn’t Know/do. Wow, have you any idea of the variety of equipment that 
roles in the lab door, and the complexity of it? NO, it is NOT the labs job to 
understand the EUT, other than how to interpret the standard so it can be 
tested. It is totally unreasonable to expect a test person to muse the 
subtleties of sub micron silicon one day then the ramifications of 10,000 psi 
hydraulic pumps the next. I doubt few could listening in.

I spent 44 years doing multiple phases of EMC, about 8 years in an independent 
test lab, about 18 years in an in-house lab doing mostly military testing for 
multiple divisions of a big conglomerate plus some outside commercial testing, 
about 2 years of consulting and about 16 years running a 2-man in-house test 
lab doing military and outside commercial testing. So yes, I have some ideas 
about testing variety, as I have tested everything from stereo tuners to 
mainframe computers, power tools to encrypted data links, aircraft APU’s to 
Abrams thermal sights, Atlas to Stinger to Tomahawk, Sony & Medtronic, Ohio 
class launch consoles & Apollo ALSEP to a whole lot of stuff what goes zoom and 
boom. I did FCC 15 & 18, man-worn electronics and GPS.

Having had the luxury of “visiting" well over 350 labs around the globe over 
the last 23 years I’ve gathered quite a bit of insight on lab operations and 
their clients. I happen to have worked in one for 40 years and owned one or two 
for 30+ years. So much of the email thread is huff and puff. IN the sales world 
it would be called FAD: fear and disillusionment.

On every EMC job I undertook, I owned the job, from planning to test report. I 
felt it was my responsibility to understand the support needs of the EUT, to 
review the operational modes of the EUT, to anticipate setup and operational 
problems and to anticipate issues associated with support equipment and 
possible chamber interface degradation. It was not my area of expertise to know 
the inner workings of the EUT or the support equipment, but it was my 
responsibility to think of them as big black boxes with a controlled perimeter, 
and to know how the EUT box related to support boxes and the whole outside 
World.

I didn’t expect my customer to be an expert in either the standard or the test 
process. My customer came to me because I had the testing facilities and I knew 
how to expertly operate those facilities to deliver a competent test and 
understandable & accurate test data. Ultimately, I sold reliable answers, not 
specification interpretations.

Lets set some records straight:
The majority of labs do a superb job with all the constraints they are under.

And yet this particular lab did NOT do a superb job.
They advertised expertise and competence, but delivered polluted data.
Can we find out why?
You know what they say about rocket explosions? The majority of the parts 
worked fine.

An ISO 17025 assessment cannot prevent mistakes, but it does make provisions 
for just about all foreseeable, and quite a few unforeseeable problems.

Mistakes happen, but systems are established to catch those mistakes. If a very 
basic mistake happens, and is not noticed, then the “mistake catching system” 
seems to be a tad less than superb.

Not having your chamber ambient under control, and not knowing it, is a massive 
failure of lab performance. I fault the tech for not seeing the noise during 
data acquisition, the managing EMC Engineer for allowing an environment in 
which this can happen, and the assessment system for blessing an operational 
environment where this fundamental type of problem can exist. I think fixing 
this is best started top-down.

The technical reason for the noise intrusion may not be easy to fix, but for 
the data pollution to go unnoticed is very unprofessional.

Everyone can have a bad day: that includes test engineers/technicians.

I have had bad test days, but I always operated under the assumption that 
things will break and the process will scream out of control, so I include 
periodic confidence checks. An attenuator might get cooked, a current probe 
gets dropped, an antenna gets bent, a coax might go lossy or the software might 
decide it was time for a negative miracle. You build “check measurements” into 
your operational testing so that you can be flagged that something has gone 
wrong before you have wasted a lot of time creating incorrect data. (The type 
and frequency of these confidence tests is always debatable; it depends on your 
tolerance for risk.)

Technology evolves, and what’s true at one point may not be true sometime 
later. Unless everything is checked to the nth degree, EVERY time, things will 
escape notice.
For all those calling out check after check, I bet under the same breath they 
are complaining about the cost of testing!

Absolutely true, but what is the true cost of bad data? Catch the problem after 
4 hours and it’s embarrassing. Not catching it at all can cascade into many 
wasted man hours, schedule slippage, wasted redesign effort and wasted 
retesting effort. And maybe at the worst, your customer goes home and you begin 
a new day with a new customer, ready to repeat your faulty process. How many 
customers will you fail before somebody notices a pattern?

And for the record, those critical of overseas test labs should go and pay a 
visit: most times they are careful to incredible levels running tests.

Who said anything about where the lab was located? But now that you mention 
that, there are some cultures where certain types of errors happen with greater 
frequency. The aviation industry has worked hard to eliminate flight crew 
historic cultural attitudes which have contributed to accidents. There is no 
reason that similar attitudes are not present in some test labs.

If a manufacture brings a device in for testing, no-one, that’s NO-ONE knows it 
better than he does. He has a responsibility to understand the testing his 
device will be subjected to and its behavior, heck, he’s supposed to have 
designed the device to pass the test! That includes support equipment too!

Until your customer has “gone around the track a few times,” he probably knows 
very little about the details that can cause his product to not comply. Oh 
sure, every so often you get a customer who has his own in-house pre-compliance 
group that really knows their stuff, and they walk in with excellent support 
equipment and an EUT that they know is 15 dB on the safe side of the standards. 
All they need is a proper test lab to run through the tests and give them a 
formal blessing. From my experience, that might happen once a year. You have to 
be prepared for the customer who brings in a rat’s nest collection of Radio 
Shack components nailed to a sheet of plywood, with all I/O lines and 
powerlines Ty-wrapped into a single, thick bundle.

I will readily admit that my experience grows more obsolete with each passing 
year, but, in the battle between human nature and procedural controls, the 
smart money is on human nature.

A lab should help someone who’s a novice in the EMI field to avoid pitfalls, 
that’s professional curtesy. It’s also in the labs interest as they don’t want 
someone packing up and leaving a few hours into the day and leaving the rest of 
the day not generating revenue.

This topic is huge, and I hear so called experts spout contentious opinions 
that are ill founded. It’s particularly distasteful especially in a 
professional form such as this as it forms false opinions in peoples minds, 
especially as some of these experts have a high platform from which to 
pontificate. There isn’t a rampant problem in the testing community, and many 
hardworking technicians, engineers, managers, QA people, Assessors, assessing 
bodies and even test witnesses would be very aggrieved to hear some of these 
statements.

Well, in this forum we already don’t name names, so I think that’s about as 
much cover as I’m willing to give some place that has royally screwed up. My 
“professional colleagues” will just have to learn to live with “distasteful” 
situations. I value honesty and integrity more than taste. Notice that I’m not 
suggesting execution for mistakes, but if mistakes are not talked about and 
critically examined, there is little pressure to correct what has caused the 
mistake.

I’m not sure what you mean by someone having a “high platform” (as I’m retired, 
I don’t think I even have a platform), and I never thought of myself as a 
“pontificator” (although I do regularly argue with my Spell Checker). I also 
think that there is no “rampant problem” in the testing community, but that’s 
not to say that every lab I have seen has an equal commitment to quality (I 
have been an independent lab, been an in-house lab, done testing for other labs 
and sent overflow work to other labs; I think I have seen every angle of the 
business except being an assessor). I can recall a few nameless labs where I 
knew trouble was in their future, either because they were terminally frugal, 
their tech management had no curiosity or their business management was 
pressing them to cut corners.

Testing is a team mentality,

And YOU are the coach, ultimately responsible for whoever trips, drops the ball 
or who doesn’t read the playbook.

not a glass wall mentality.

Don’t know about a glass wall, but testing people certainly have a glass 
ceiling. In a large company, compliance testing is a near guarantee of never 
making Vice-President.

And valid data is the responsibility of BOTH parties.

Valid data is more the lab’s responsibility than the customer’s. If pressed, I 
would put the ratio at about 80/20.

It requires capable people who have a systematic work approach.

And the hallmark of a good system is the inclusion of sufficient internal 
controls to limit the damage of mistakes.

So unless ALL the full details are known spreading scuttlebutt or opinions of 
what could have/should have, is NOT helpful.

ALL the full details are NEVER known until the autopsy.

Most people in this forum are very hesitant to properly describe a problem they 
have; they will sanitize it and give hints and do everything possible to make 
the issue as generic as they can. As such, it is difficult to make any helpful 
suggestions without a bit of speculation. After a few rounds of speculation, a 
few facts get sprinkled into the thread and just maybe there is some resolution.

But Derek, when somebody tells me that their product was declared non-compliant 
because the test lab measured noise external to the shielded enclosure, that 
information runs a bit higher than “scuttlebutt.”

My 10 cents as I have to go back and tend to a test I’ve been running since 6am.

Hmm, automated testing? Nothing like a computer to ease you into a disaster. 
Been there, done that! ☺

Shalom.

Derek.


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