[PSES] WEEE Directive Compliance for Small Operators

2013-11-19 Thread Carl Newton
Group,
 
I'm working with a startup that will import ITE into the EU.  They market
entirely via the internet so they have no distribution there.  They've
received a quote from one of the large well-known WEEED compliance
organizations, but it exceeds 12K euros/year and they expect to sell less
than 2 kg of WEEE into the entire EU within in 2014.  This cost is
unmanageable for this small startup at this point.  Do any of you have
experience in satisfying WEEED compliance responsibilities for very small
organizations with no presence within the EU?  Please feel free to contact
me privately if you can help.
 
Thanks very much,
 
Carl

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Re: [PSES] Job Opening for EMC Engineer

2013-11-19 Thread CR
I suspect many of us came into EMC unconventionally. I certainly did. I 
walked into a job in EMC at Wang Labs after retiring from an Army career 
that had me in the Signal Corps and Transportation Corps in 
communications and repairing Avionics (also supervising and 
instructing). I had been playing with electronics since age 12, when I 
used a TV focus coil to build in my bedroom what some might call a 
rail-gun.


On retiring from the Army I was a single parent with a pension that only 
paid the rent. I wanted work as an instructor, but without a degree, the 
only people who made an an offer paid less than I'd gotten on Active 
Duty. Luckily, my my brother passed a copy of my resume' to his 
neighbor, who worked for a large computer firm now defunct, Wang Labs. I 
was able to show them I knew how to use the equipment and already had a 
high enogh security clearance for Tempest work, so I was in.


Having come up through the lab, I look for not merely theory, but a feel 
for systems and problems. A couple of my later employers had me 
interviewing job applicants and I got an (undeserved, IMO) reputation 
for being a difficult interviewer, handing candidates a ferrite bead, 
for example, and asking, What is this? What does it do? and How? or 
something like aPRD-219 
http://www.webalice.it/bruno.santalucia/UNK.JPG and asking, What is 
this and how is it used? (I own a couple.)


Most of the scrUwups I've seen were the result of engineers or managers 
(not just in EMC):
1) Ignoring (or ignorance of) basic principles of EMC design; for 
example, as Mother used to say (not really) Cortland! Put that electron 
back before he yells for his Dad!
2) Neglecting to get all parties to producing a product to ATTEND design 
reviews and point out what they can and can't do given the design and 
desired results.
3) Ignoring (again BASIC) principles of shielding and grounding even in 
testing (all too common).
4) Not talking directly to engineers and techs on projects outside their 
own areas of expertise. Everything matters. Even firmware.


5) Not looking at systems a whole; test setups, platform or user 
configurations, regulations and standard -- everything that concerns 
emissions and susceptibility in use. It took time and effort (and one 
actual RFI complaint) to convince a manufacturer of telco equipment that 
if it was on or near a residential property it had to meet FCC Class B.


It has been the rare employer whose management was on board with EMC 
problem *prevention*; perhaps surprisingly, one of my better ones was 
Tandy, whose first venture into the IBM compatible computer market in 
the late 1980's was not only yanked off the market by the FCC, but 
incurred a sizable fine for not having been submitted for testing (it 
failed). That'll motivate you! It did get a me a job there.


IMO, an organization needs both educated engineers and those who can 
hold people to basic principles; if you do all the simple things right, 
you will usually have done the complex ones too. WRT the EMC Cop role, I 
prefer the missionary position (heh).  Really, convert them, don't yell 
at them. An Outside Expert many of us, at least in the US, know, was 
called in to look at a PWB design and his first words to the CAD layout 
guy were Your board is a piece of sh*t! How not to influence people, 
etc. They did listen to my simpler and less confrontational advice 
thereafter.


I'd have LOVED to get a job applicant who could show what's wrong, 
what's right, and explain why in plain English; colleagues not in EMC 
will often want simple rules: X mils of clearance and Y mils of prepreg; 
Z mils of copper between bypass caps and devices etc. Sometimes it's 
worthwhile to make design rules simple just to get them followed... but 
one must know what the rules do, and why, and be able to teach those who 
must follow them .



I was offered a job at DSC Communications (later Alcatel USA) as a test 
engineer, and when I arrived, they gave me the choice of that or design. 
That was no choice at all; I chose design for, as I answered when asked 
why, test engineers have to fix the same problems over and over, but 
design engineers can stop them from happening, By dint of constant, 
friendly and informal oversight (I asked for and got read-only access to 
the schematics and layout of every project from my own terminal) and 
collaboration with designers in every group, I did that. I even got the 
mechanical engineers on board. (That took a lunch and learn with a 
modified stock-pot shielded enclosure and a hand held radio receiver. 
) I didn't realize then, but I would learn, that I needed to keep an eye 
on what the firmware and software did, too.


What does the EMC engineer need to be? Theoretician, practical engineer, 
teacher, tech, missionary and salesman; electronics, metals, coatings, 
insulators and chemistry; tooling, manufacturing and maintenance, all of 
that too, essentially a systems engineer with a finger in every 

Re: [PSES] EN 50581 part/range of parts

2013-11-19 Thread Piotr Galka
Lauren and others,

I have read (I believe carefully) this FAQ.

From Q8.14 and Directive Article 7(g) I see that product identification can be 
batch number. For my understanding it is not unique identification called in 
Annex VI. But OK let it be, I don't care because my products have unique 
numbers.

Q8.9 says that DoC would reference the product normally by the model number. I 
don't believe that ANNEX VI 1. No(unique identification of EEE): means 
model number, but I must all the time suppose that I don't understand English 
good enough.
Can someone tell me if unique identification of EEE can really be understand as 
model number ? I really don't believe!
If FAQ is in opposite to directive itself than I must remember of FAQ Preface: 
These FAQ reflect the views of DG Environment and as such are not legally 
binding: binding interpretation of EU legislation is the exclusive competence 
of the Court of Justice of the European Union.
I still don't know if I have to issue separate DoC for each device (I have not 
batch numbers, but individual numbers).

Q8.10 and Q9.6 directs me to EN 50581 to get presumption of conformity so it 
still looks that I need the declaration for each 100pcs of resistors I will 
order. I don't think that order saying that I order ROHS2 compliant parts and 
invoice saying that they are ROHS2 can be understand as signed contract which 
would allow me not to have supplier declaration.
How high is in your opinion probability that if Court of Justice of European 
Union will have to decide if such order and such invoice can really be 
understand as signed contract than they will say yes. It would help a lot if 
I could believe it is around 95%, but unfortunately (based on my understanding 
of English) I believe it is around 0%.

The most surprising for me is the Q7.2.
I knew that:
- carrot is the fruit,
- snail is the fish,
- Poland, Germany and some other countries have no access to the sea,
and it looks that I should add to that list that:
- light is not electromagnetic field.

Best Regards
Piotr Galka


  - Original Message - 
  From: Crane, Lauren 
  To: Piotr Galka ; EMC-PSTC@LISTSERV.IEEE.ORG 
  Sent: Friday, November 15, 2013 2:22 AM
  Subject: RE: [PSES] EN 50581 part/range of parts


  Piotr, 

   

  Reading the EU Commission's FAQ on RoHS2 might help you 
http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf. 

  Components (i.e. things not intended for direct sale to the end user) are not 
considered to be in scope of RoHS (even though they fit the definition of EEE). 
It has to do with the concept of finished product.  

   

  So, if you are going to be using the 100pcs of resistors in your product, you 
should constrain your supplier with a contract that requires them to be RoHS 
compliant, but you do not need a DoC from them. 

   

  Regards,

  Lauren Crane

  KLA-Tencor

   

  From: Piotr Galka [mailto:piotr.ga...@micromade.pl] 
  Sent: Wednesday, November 13, 2013 8:27 AM
  To: EMC-PSTC@LISTSERV.IEEE.ORG
  Subject: [PSES] EN 50581 part/range of parts

   

  To English language standard experts,

   

  How do you understand specific part and specific range of parts in last 
sentence in EN 50581:2012 Cl. 4.3.3 (a):

  Such declarations ... shall cover a specific ... part ... or a specific 
range of ... parts...

   

  According to:

  - directives understanding of putting product on the market (not type but 
single piece),

  - direct meaning of the words (as I fill them),

  it looks that:

  part = this one single part,

  range of parts = some (specified) number of the same type parts.

   

  If it is true I see problems with ROHS DoC.

  If I buy 100pcs of 0603 1k resistors should I ask the supplier for sending me 
the declaration for specified range of these 100pcs ?

  And the same for all 200 other types of elements ?

   

  The other way of understanding is:

  part = part type (resistor 0603 1k)

  range of parts = range of part types (resistor 0603 from 1ohm to 10Mohm)

   

  This looks more logical for someone trying to make ROHS DoC but:

  If they wonted to say part type or range of part types they would 
certainly said that. As they didn't said that I think they had the previous 
understanding in mind.

   

  What is the solution I don't see ?

   

  Best Regards

  Piotr Galka

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[PSES] CPSC product recall

2013-11-19 Thread Peter Tarver
For those who don't subscribe to InCompliance magazine or track recalls
through other methods, the below link is related to a US product recall of
a relocateable power tap with surge protection.

http://www.cpsc.gov/en/Recalls/2014/Schneider-Electric-Recalls-APC-Surge-P
rotectors/


Regards,

Peter L. Tarver


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[PSES] lab for MS810 stuff

2013-11-19 Thread Brian Oconnell
 Again, having trouble getting lab to respond and return correspondence.

Need a site to do a small subset of MS810 shock/vibration, and a little thermal 
stuff as part of a regression.

Must be in Southern California, prefer San Diego area.

[A note to CABs and test labs - when you provide poor response/poor work for a 
small company with a small job, you will lose the big jobs that the small 
company does for Fortune 1k corporations.]

Thanks,
Brian

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[PSES] Equipment rack for GR1089 testing - does it have to be metal?

2013-11-19 Thread Neven Pischl


Hello All, 

Is there a formal requirement, by either Telcordia/NEBS or by the major telecom 
carriers that the equipment rack (i.e. not the cable rack) be metal, when 
testing radiated immunity per the GR1089? I understand it is the usual practice 
- I have only seen such tests with a metal rack -  but I am asking if there is 
such a requirement spelled out anywhere. I can't find it in GR1089. 

If any on this list knows of it, please can you forward the document, at least 
maybe a snapshot of the relevant paragraph along with the reference if the 
document can't be forwarded. 

Thank you, Neven

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Re: [PSES] Equipment rack for GR1089 testing - does it have to be metal?

2013-11-19 Thread Mike Cantwell
Hi Nevin,

 

The rack requirement is not in GR-1089. It is a supplemental Verizon document

 

http://www.verizonnebs.com/TPRs/VZ-TPR-9305.pdf

 

Regards,

Mike

 

From: Neven Pischl [mailto:neve...@comcast.net] 
Sent: Tuesday, November 19, 2013 7:07 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Equipment rack for GR1089 testing - does it have to be metal?

 

Hello All,

Is there a formal requirement, by either Telcordia/NEBS or by the major telecom 
carriers that the equipment rack (i.e. not the cable rack) be metal, when 
testing radiated immunity per the GR1089? I understand it is the usual practice 
- I have only seen such tests with a metal rack -  but I am asking if there is 
such a requirement spelled out anywhere. I can't find it in GR1089.

If any on this list knows of it, please can you forward the document, at least 
maybe a snapshot of the relevant paragraph along with the reference if the 
document can't be forwarded.

Thank you, Neven

-


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Re: [PSES] Equipment rack for GR1089 testing - does it have to be metal?

2013-11-19 Thread Neven Pischl
Thanks Mike. I checked by searching the document for the words: metal, rack, 
frame, shelf - each separately - and can't find in the Verizon document any 
specification or requirement that the rack must be made out of metal (or not). 
ANy idea where it might be? 
Neven 

- Original Message -

From: Mike Cantwell mike.cantw...@outlook.com 
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Sent: Tuesday, November 19, 2013 5:52:21 PM 
Subject: Re: [PSES] Equipment rack for GR1089 testing - does it have to be 
metal? 



Hi Nevin, 

  

The rack requirement is not in GR-1089. It is a supplemental Verizon document 

  

http://www.verizonnebs.com/TPRs/VZ-TPR-9305.pdf 

  

Regards, 

Mike 

  


From: Neven Pischl [mailto:neve...@comcast.net] 
Sent: Tuesday, November 19, 2013 7:07 PM 
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: [PSES] Equipment rack for GR1089 testing - does it have to be metal? 


  


Hello All, 

Is there a formal requirement, by either Telcordia/NEBS or by the major telecom 
carriers that the equipment rack (i.e. not the cable rack) be metal, when 
testing radiated immunity per the GR1089? I understand it is the usual practice 
- I have only seen such tests with a metal rack -  but I am asking if there is 
such a requirement spelled out anywhere. I can't find it in GR1089. 

If any on this list knows of it, please can you forward the document, at least 
maybe a snapshot of the relevant paragraph along with the reference if the 
document can't be forwarded. 

Thank you, Neven 


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