I have noted what you say about copying to the list address. I normally send ONLY to the list address.

On 2020-01-15 19:02, Joe Randolph wrote:

Hi John:

Yes, solid insulation can be provided using thin sheets to solve certain problems in confined spaces..  For the product in question, the main challenges of adding reinforced insulation are the creepage and clearance distances.  That is the main reason I want to avoid having to implement double insulation.

I think my immediate task is to determine whether the circuit in question can pass the “protective impedance” requirements in 60335-1.  That’s going to take a week or so because I do not presently have a working sample of the product.  Apparently, I could use the protective impedance classification even in a Class 2 product, so the ambiguity that was bothering me in the Class 3 definition may be avoidable.

BTW, I noticed that the last two emails you sent to me were not copied to the EMC-PSTC list server.  For my earlier response I assumed this was a simple oversight and I added the list server to my response.  I decided not to do that this time, just in case your omission was intentional.  On the other hand, if was not intentional, I thought you should know that it is happening.

I very much appreciate your insights and suggestions on my touch current question and several other topics that have come up on the EMC-PSTC list server.

Thanks,

Joe Randolph

Telecom Design Consultant

Randolph Telecom, Inc.

781-721-2848 (USA)

[email protected] <mailto:[email protected]>

http://www.randolph-telecom.com

*From:* John Woodgate [mailto:[email protected]]
*Sent:* Tuesday, January 14, 2020 1:27 PM
*To:* Joe Randolph <[email protected]>
*Subject:* Re: [PSES] Touch current in IEC 60335-1 for Household Appliances

I am wondering if you are over-estimating the requirements for double or reinforced insulation. It's difficult to be sure whether you are, but quite a thin sheet of PET plus an air-gap provides double insulation.  A somewhat thicker PET sheet can provide reinforced insulation.

On 2020-01-14 18:09, Joe Randolph wrote:

    Hi Rich:

    Thanks, I think I am starting to better understand my options.
    Following is my current understanding:

    1)If the internal non-SELV circuit */does not meet/* the
    requirements in clause 8.1.4 for “protective impedance,” the
    product will be Class 2 per clause 3.3.10 and double insulation
    will be required around the internal non-SELV circuit.  This
    includes meeting all the criteria for double insulation, including
    creepage distance, clearance distance, distance through solid
    insulation, and an electric strength.

    2)Even if the internal non-SELV circuit */does meet/* the
    requirements in clause 8.1.4 for “protective impedance,” I still
    can’t use the Class 3 classification per clause 3.3.2, due to the
    way that clause 3.3.12 is presently worded.

    3)However, if the internal non-SELV circuit */does meet/* the
    requirements in clause 8.1.4 for “protective impedance,” I can use
    the Class 2 classification per clause 3.3.10, but also use the
    “protective impedance” provisions in clause 8.1.4.  The key
    distinction is that with the protective impedance provisions, the
    internal non-SELV circuit would not be considered to be a “live
    part.”  And, if it is not a “live part,” no insulation is required.

    What I would like to avoid is the requirement to separate the
    internal non-SELV circuit from accessible parts (including the USB
    port) with double insulation.  It appears to me that the physical
    construction requirements for double insulation would require
    considerable changes to the present design. At present, the
    internal non-SELV circuit shares the same return path as the USB
    circuit, so there is no isolation between the two circuits.

    Your explanation of how an electric shock risk requires that
    current flow through the human body is very helpful for understand
    the underlying principles.  It would appear that with only one
    pole of the internal non-SELV circuit accessible (at the USB
    port), it would not be difficult to prevent current from flowing
    when performing the accessibility tests.

    However, to keep a test lab happy, I also need to demonstrate
    compliance with the actual wording of 60335-1.  If it turns out
    that I have to provide double insulation, it is not clear to me
    that I can avoid placing a double insulation barrier between the
    internal non-SELV circuit and the accessible USB port.

    Based on the underlying principles of electric shock, it would
    appear that  the internal non-SELV circuit could share the same
    return path as the USB port, provided that double insulation is
    provided between the internal non-SELV circuit and all other
    accessible parts.  With this construction, there would be no path
    for current to flow.

    I’m just not sure whether a test lab, when performing a
    construction review of the required double insulation, would agree
    that no insulation is required between the internal non-SELV
    circuit and the USB port.

    My preference would be to use the approach outlined in item 3
    above, where there would be no requirement for insulation at all
    (only a requirement for the “protective impedance”).  I plan to
    have some tests performed to determine whether the internal
    non-SELV circuit can be classified as having a “protective
    impedance.”  Based on just a review of the circuit diagram, I
    think it has a 50/50 chance of meeting the requirement for
    protective impedance.

    If it does meet the requirement for protective impedance, do you
    think that the approach described in Item 3 above would be
    acceptable under 60335-1?


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