Re: [PSES] What percentage of products pass first time?

[Richard Nute]

 

 

Hi John:

 

“Therefore safety, standards compliance and EMC standards compliance REALLY 
MUST be an integral component of engineering education – and ALSO for company 
management…”

 

While I agree, in practice the only time company management addresses safety 
and other compliance matters is when an incident becomes public.  The usual 
public response from management is that “safety is foremost at our company.”  
BS!  The foremost items are: profits and growth.  A safety incident takes 
management time (reluctantly) away from profits and growth.

 

Compliance is an engineering and manufacturing process just as and equal to any 
other engineering and manufacturing process.  If done competently, it has no 
special effect on the schedule.  So, management has no need for special 
interest in compliance.  What is important is that management hires competent 
compliance employees.  

 

Stay safe, and best regards,

Rich

 

 


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Re: [PSES] What percentage of products pass first time?

[John E Allen]

Like a “lot” of people here, I never had any formal education in either safety 
or EMC compliance – I just had to learn “on the job” about “what worked and 
what didn’t”, and often in very challenging situations. 

(OTOH, I was never the “sharpest tool in the toolbox” in engineering  parlance 
– which was a “problem”  when engaging with local management which, frankly, 
mainly “didn’t to know” ☹, ) 

 

Therefore safety, standards compliance and EMC standards compliance REALLY MUST 
be an integral component of engineering education – and ALSO for company 
management - forward from where we are “now”.

 

John E Allen

W. London, UK.

 

 

From: Dennis Ward <0dbeaa892a40-dmarc-requ...@listserv.ieee.org> 
Sent: 25 May 2021 21:09
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] What percentage of products pass first time?

 

Having been in the EMC business now for going on 40+years, I concur with what 
Pete is saying.  The truth of the matter is, this field of study is sadly under 
taught and is still more hands on and learning by trial and error for the most 
part.  Yes, there are a lot of good ‘classes’ you can take, but the fact 
remains, this is more than not an OJT field.

 

As to manufacturers designing at the limit.  This is also true, and also 
problematic as it means far too many products still fail first time out.  

 

I don’t know if I would necessarily agree with the percentages reported, but it 
is getting a better.  

 

My last 20+ years has been working in the regulatory approvals end and I can 
say that failure to comply with rules and standards is still a big issue with 
manufacturers.

 

Thanks 

 


Dennis Ward
Senior Reviewing Engineer
PCTEST Engineering Laboratory, LLC.
7185 Oakland Mills Road
Columbia, MD  21045
1 410 290 6652)

dennis.w...@pctest.com   | www.pctest.com 
  | www.element.com   

This communication and any attachment contain information from PCTEST 
Engineering Laboratory, LLC. and is intended for the exclusive use of the 
recipient(s) named above.

 

From: Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org 
 > 
Sent: Tuesday, May 25, 2021 12:39 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] What percentage of products pass first time?

 

CAUTION:This email originated from outside of Element Materials Technology. DO 
NOT click links or open attachments unless you recognize the sender and know 
the content is safe. Please contact IT Service Desk if you are in any doubt 
about this email.

James,   

You don’t have to denigrate yourself as not being a guru.  You have plenty of 
experience in this as shown by your comments.  Sharing this is quite valuable 
to the others on this thread.  

   All of us started out as ignorant of any of these requirements 
because they are not taught in formal college level courses; a few exceptions 
seem to exist.  

   Some folks might get specialized training – if they work for a 
gov’t agency or a safety test organization; else it’s all OJT.  

   I don’t see that changing any time soon; the academic folks have 
their interests which continue to push mathematical analysis techniques (and 
that will continue).  More and more technical folks will get higher degrees 
[you know what BS is, MS is More of the Same and PhD is Piled higher and Deeper 
:>) ], hardly any of which is of interest at our daily working level.  
Manufacturers will continue to steal trained folks from test labs; probably not 
too bad a deal especially if the folks move back and forth to spread what 
they’ve learned going each way.  

   Finally, the standards keep getting more complex (PhD effect) 
and interrelated as issues are delved into more deeply; plus manufacturers are 
getting better trained to design near the limit without as much margin so the 
compliance is close to falling off of the edge of the world at any moment.  

 

   So keep at what you are doing as long as you enjoy it; then get 
out gracefully – keeping your reputation intact to maintain a legacy as you go. 
  

   

   Enough of Phil 101 today.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 1067

Albany, ORe  97321-0413

 

503/452-1201

 

IEEE Life Fellow

IEEE PSES 2020 Distinguished Lecturer

 

 www.researchgate.net search my name

 

[PSES] Shipping samples to UK

[Chris]

Folks,We would like to ship some non revenue samples to BT in UK.Frequency 
C-band 3.8-4.2 GHz. Does UK custom allow import of non revenue Access Point 
samples for evaluation.
Any info will help as UK rules are different compared to Europe.
Thanks in advance
Christopher

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formats), large files, etc.

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Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] What percentage of products pass first time?

[Dennis Ward]

Having been in the EMC business now for going on 40+years, I concur with what 
Pete is saying.  The truth of the matter is, this field of study is sadly under 
taught and is still more hands on and learning by trial and error for the most 
part.  Yes, there are a lot of good ‘classes’ you can take, but the fact 
remains, this is more than not an OJT field.

As to manufacturers designing at the limit.  This is also true, and also 
problematic as it means far too many products still fail first time out.

I don’t know if I would necessarily agree with the percentages reported, but it 
is getting a better.

My last 20+ years has been working in the regulatory approvals end and I can 
say that failure to comply with rules and standards is still a big issue with 
manufacturers.

Thanks

[cid:image001.png@01D75167.18F10910]
Dennis Ward
Senior Reviewing Engineer
PCTEST Engineering Laboratory, LLC.
7185 Oakland Mills Road
Columbia, MD  21045
1 410 290 6652)

dennis.w...@pctest.com | 
www.pctest.com | 
www.element.com

This communication and any attachment contain information from PCTEST 
Engineering Laboratory, LLC. and is intended for the exclusive use of the 
recipient(s) named above.

From: Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org>
Sent: Tuesday, May 25, 2021 12:39 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] What percentage of products pass first time?


CAUTION:This email originated from outside of Element Materials Technology. DO 
NOT click links or open attachments unless you recognize the sender and know 
the content is safe. Please contact IT Service Desk if you are in any doubt 
about this email.
James,
You don’t have to denigrate yourself as not being a guru.  You have plenty of 
experience in this as shown by your comments.  Sharing this is quite valuable 
to the others on this thread.
   All of us started out as ignorant of any of these requirements 
because they are not taught in formal college level courses; a few exceptions 
seem to exist.
   Some folks might get specialized training – if they work for a 
gov’t agency or a safety test organization; else it’s all OJT.
   I don’t see that changing any time soon; the academic folks have 
their interests which continue to push mathematical analysis techniques (and 
that will continue).  More and more technical folks will get higher degrees 
[you know what BS is, MS is More of the Same and PhD is Piled higher and Deeper 
:>) ], hardly any of which is of interest at our daily working level.  
Manufacturers will continue to steal trained folks from test labs; probably not 
too bad a deal especially if the folks move back and forth to spread what 
they’ve learned going each way.
   Finally, the standards keep getting more complex (PhD effect) 
and interrelated as issues are delved into more deeply; plus manufacturers are 
getting better trained to design near the limit without as much margin so the 
compliance is close to falling off of the edge of the world at any moment.

   So keep at what you are doing as long as you enjoy it; then get 
out gracefully – keeping your reputation intact to maintain a legacy as you go.

   Enough of Phil 101 today.

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 1067
Albany, ORe  97321-0413

503/452-1201

IEEE Life Fellow
IEEE PSES 2020 Distinguished Lecturer
www.researchgate.net
 search my name
p.perk...@ieee.org


Entropy ain’t what it used to be

From: James Pawson (U3C) 
mailto:ja...@unit3compliance.co.uk>>
Sent: Tuesday, May 25, 2021 1:19 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] What percentage of products pass first time?

(replying even though I’m not a guru)

Hi Charles, hope all is well with you

Speaking from my own experience. Over the last four years of running a 
consultancy, pre-compliance and low cost test EMC laboratory I would (very 
roughly) estimate that around:


  *   50% of products pass their desired radiated emissions limits without any 
modification

  *   33% or less pass all of the applicable tests first time without 
modification

The major caveats and notes here are that


  *   These figures are for customers products where the EMC performance is not 
known before testing. We do a lot of work helping people solve existing EMC 
problems but we are not counting this in these figures.

Re: [PSES] What percentage of products pass first time?

[Pete Perkins]

James,   

You don’t have to denigrate yourself as not being a guru.  You have plenty of 
experience in this as shown by your comments.  Sharing this is quite valuable 
to the others on this thread.  

   All of us started out as ignorant of any of these requirements 
because they are not taught in formal college level courses; a few exceptions 
seem to exist.  

   Some folks might get specialized training – if they work for a 
gov’t agency or a safety test organization; else it’s all OJT.  

   I don’t see that changing any time soon; the academic folks have 
their interests which continue to push mathematical analysis techniques (and 
that will continue).  More and more technical folks will get higher degrees 
[you know what BS is, MS is More of the Same and PhD is Piled higher and Deeper 
:>) ], hardly any of which is of interest at our daily working level.  
Manufacturers will continue to steal trained folks from test labs; probably not 
too bad a deal especially if the folks move back and forth to spread what 
they’ve learned going each way.  

   Finally, the standards keep getting more complex (PhD effect) 
and interrelated as issues are delved into more deeply; plus manufacturers are 
getting better trained to design near the limit without as much margin so the 
compliance is close to falling off of the edge of the world at any moment.  

 

   So keep at what you are doing as long as you enjoy it; then get 
out gracefully – keeping your reputation intact to maintain a legacy as you go. 
  

   

   Enough of Phil 101 today.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 1067

Albany, ORe  97321-0413

 

503/452-1201

 

IEEE Life Fellow

IEEE PSES 2020 Distinguished Lecturer

  www.researchgate.net search my 
name

  p.perk...@ieee.org

 

 

Entropy ain’t what it used to be

 

From: James Pawson (U3C)  
Sent: Tuesday, May 25, 2021 1:19 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] What percentage of products pass first time?

 

(replying even though I’m not a guru)

 

Hi Charles, hope all is well with you

 

Speaking from my own experience. Over the last four years of running a 
consultancy, pre-compliance and low cost test EMC laboratory I would (very 
roughly) estimate that around:

 

*   50% of products pass their desired radiated emissions limits without 
any modification

*   33% or less pass all of the applicable tests first time without 
modification

 

The major caveats and notes here are that

 

*   These figures are for customers products where the EMC performance is 
not known before testing. We do a lot of work helping people solve existing EMC 
problems but we are not counting this in these figures.
*   Most of my customers are smaller businesses that can’t afford to employ 
an engineer to just look after compliance. That job role is either split 
amongst several people or the engineer in question has to look after quality, 
manufacturing, sustaining, thermal, system, and everything else. Speaking as 
someone who has designed many products and systems in the past, trying to 
design for functionality whilst simultaneously considering best EMC performance 
is HARD. I use the metaphor of 
*   The products that pass first time generally fall into one of three 
categories

*   Products that we have design reviewed before the design was finalised
*   Retests of products that have already been through our lab once
*   Products that are very simple in nature

*   Our hit-rate at being able to solve our customers problems is around 
90-95%
*   The “ones that got away” where we were unable to help deliver a 
compliant include

*   No action taken: Products where it was deemed by the manufacturer not 
economically feasible to modify the product (e.g. product going end of life)
*   No further communications from the manufacturer so we don’t get to find 
out what happened next (no news is good news, right?)

 

I would echo the sentiments of others on this thread regarding the need to 
design in compliance from the start.

 

One of the problems with the field of compliance is that it is too often 
“learned through experience in industry” and not explicitly taught. When it is 
taught at academic level it is often a surface treatment with a theoretical 
look at shielding or maybe crosstalk with no other practical context or 
background.

 

The split between industry and academia is one of the possible causes. Yes, 
there are exceptions to this but they primarily remain exceptions. I had 
discussions with a local university about some guest lectures on compliance and 
the theme of the response was “it doesn’t really fit into any of our modules” 
and “we can’t have it as an optional lecture as none of the student

Re: [PSES] Retesting needed for EN 61010-1:2010/A1:2019??

[Charlie Blackham]

https://www.evs.ee/en/evs-en-61010-1-2010-a1-2019 gives clause by clause changes

Unfortunately you will need to review it against your product with existing 
report to see which clauses are applicable and what changes any applicable 
clauses would require

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Wiseman, Joshua 
Sent: 25 May 2021 13:06
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Retesting needed for EN 61010-1:2010/A1:2019??

When I reviewed it for our products the biggest impact for us is documentation, 
Clause 5.4.

With that said there are some changes that could impact products. For example, 
6.3.1 changed the voltages for what is deemed hazardous. I'm not sure if there 
is a list of changes anywhere, but the impact should really be based on the 
individual product.

Josh

Joshua Wiseman
Staff Engineer, Product Safety/EMC/Systems
From: Rodriguez, Daniel (ESP) 
<123de38bd494-dmarc-requ...@listserv.ieee.org>
Sent: Tuesday, May 25, 2021 7:52 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Retesting needed for EN 61010-1:2010/A1:2019??

EXTERNAL SENDER: Verify links, attachments and sender before taking action


Good morning all

I have just reviewed the EN 61010-1:2010/A1:2019 and there a lot of changes. 
Most of them seems clarifications but I am not sure if we need to retest 
equipment checked for EN 61010-1:2010 to add A1:2029
Does anyone have a clear picture:
1.if retesting is required
2.if yes there is any cases that not (or which clauses requires testing)

Thank you for your answers!

Kind Regards / Saludos cordiales / Mit freundlichen Grüßen

Daniel Rodríguez
Sr. Equipment Compliance Specialist EMEA
T +34 673556249
E drodrig...@ecolab.com
ecolab.com

CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may 
contain proprietary and privileged information for the use of the designated 
recipients named above. Any unauthorized review, use, disclosure or 
distribution is prohibited. If you are not the intended recipient, please 
contact the sender by reply e-mail and destroy all copies of the original 
message.
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Re: [PSES] Retesting needed for EN 61010-1:2010/A1:2019??

[Wiseman, Joshua]

When I reviewed it for our products the biggest impact for us is documentation, 
Clause 5.4.

With that said there are some changes that could impact products. For example, 
6.3.1 changed the voltages for what is deemed hazardous. I'm not sure if there 
is a list of changes anywhere, but the impact should really be based on the 
individual product.

Josh

Joshua Wiseman
Staff Engineer, Product Safety/EMC/Systems

From: Rodriguez, Daniel (ESP) <123de38bd494-dmarc-requ...@listserv.ieee.org>
Sent: Tuesday, May 25, 2021 7:52 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Retesting needed for EN 61010-1:2010/A1:2019??

EXTERNAL SENDER: Verify links, attachments and sender before taking action


Good morning all

I have just reviewed the EN 61010-1:2010/A1:2019 and there a lot of changes. 
Most of them seems clarifications but I am not sure if we need to retest 
equipment checked for EN 61010-1:2010 to add A1:2029
Does anyone have a clear picture:
1.if retesting is required
2.if yes there is any cases that not (or which clauses requires testing)

Thank you for your answers!

Kind Regards / Saludos cordiales / Mit freundlichen Grüßen

Daniel Rodríguez
Sr. Equipment Compliance Specialist EMEA
T +34 673556249
E drodrig...@ecolab.com
ecolab.com

CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may 
contain proprietary and privileged information for the use of the designated 
recipients named above. Any unauthorized review, use, disclosure or 
distribution is prohibited. If you are not the intended recipient, please 
contact the sender by reply e-mail and destroy all copies of the original 
message.
-


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Attachments are not permitted but the IEEE PSES Online Communities site at 
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 can be used for graphics (in well-used formats), large files, etc.

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discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web

Re: [PSES] Australia: IEC 62368-1 or IEC 61010-1 for controller with radio

[John Woodgate]

I think that an industrial controller might have high-current power 
circuits, but 62368-1 doesn't cover securing high-current cables against 
movement due to magnetic forces under fault conditions.


==
Best wishes John Woodgate OOO-Own Opinions Only
www.woodjohn.uk
Rayleigh, Essex UK
Istae nunc praetereunt nisi non ubicumque



On 2021-05-25 12:57, Rodriguez, Daniel (ESP) wrote:


Thank you all

The summary is that as AS/NZS 62368-1 is a standard defined by ACMA 
for radio equipment, we will test for this standard, additionally 
tested for EN 61010-1


/Telecommunications (Customer Equipment Safety) Technical Standard 
2018 (legislation.gov.au) 
///


Perhaps in the future it will good to test an industrial controller 
with radio communication only for EN 62368-1 as a safety standard. Any 
one has a concern about this?


Thank you

Kind Regards / Saludos cordiales / Mit freundlichen Grüßen

Daniel Rodríguez

*From:*Pete Perkins 
*Sent:* Tuesday, 11 May 2021 18:41
*To:* Rodriguez, Daniel (ESP) ; 
EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* RE: [PSES] Australia: IEC 62368-1 or IEC 61010-1 for 
controller with radio


*Caution:*This email message originated from outside of the 
organization. *DO NOT CLICK* on links or open attachments unless you 
recognize the sender and know the content is safe. If you think it is 
suspicious, please *report as suspicious*.




Daniel, The world gets more complicated by the day.  This is both the 
exciting technologically challenging part of this work as well as the 
difficult, slogging regulatory stuff, too.


Historically, 40 years ago,  61010 & 60950 (now 62368) were designed 
by folks working in overlapping businesses who understood that these 
two standards were aimed at providing safe electronic equipment 
(contrasted to electrical equipment).  61010 for commercial and 
industrial electronic equipment and 60950/62368 for consumer & 
commercial electronic equipment.  The products used the same 
components and techniques in the design for products so the 
requirements needed to be the same.  At the time there was 
consideration of making this one standard for all this equipment but 
this was a bridge too far.


Today, electronics have been incorporated in many products, the term 
IoT (Internet of Things) describes this phenomenon well.


Now this leaves us with a couple of choices; everything electronic 
goes into one or two standards or electronic devices are accepted in 
all product standards.  For the latter there has to be consideration 
as to the additional issues arising from the electronic portions, 
including the radio.


I believe that the there needs to be the latitude to include complex 
digital electronic systems in any product.  in addition to the usual 
electronic controls and displays used, electronic motor controllers 
(VSDs) are becoming more popular in consumer equipment.  If the 
product standards are too slow to incorporate the needed safeguards 
for these electronic systems then it is not unreasonable to apply 
other requirements for them (think 61010 or 62368) but this should be 
the exception. I would believe.  This is a messy solution tho.


I have worked on a ‘smart Relocatable Power Tap’, an IoT combination 
which was to be certified to North American and European CB safety 
standards (specific outlet sockets for each market).  There was 
considerable negotiation with the safety test lab to get them to 
cooperate between their internal groups on the evaluation and ensure 
that any needed test was only run once.  The project covered the power 
delivery requirements as well as the electronic systems (including the 
radio) and, altho complex, went pretty well after that.


The EMC evaluation was straightforward, the RED evaluation was 
comprehensive covering all the needed requirements.


It would seem to me that you have properly evaluated your device and 
the radio requirements should not bring about a separate evaluation.  
Are you prepared to defend your position in that regard?


In your Australian case, this can only be clarified by the AU 
authorities who need to explain what they mean by the requirement.


Perhaps, when this is resolved, you can provide all of us with an 
update as to how it is resolved.


:>) br,  Pete

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 1067

Albany, ORe  97321-0413

503/452-1201

IEEE Life Fellow

IEEE PSES 2020 Distinguished Lecturer

www.researchgate.net 
 
search my name


p.perk...@ieee.org 

Entropy ain’t what it used to be

*From:*Rodriguez, Daniel (ESP) 
<123de38bd494-dmarc-requ...@listserv.ieee.org 

Re: [PSES] Australia: IEC 62368-1 or IEC 61010-1 for controller with radio

[Rodriguez, Daniel (ESP)]

Thank you all
The summary is that as AS/NZS 62368-1 is a standard defined by ACMA for radio 
equipment, we will test for this standard, additionally tested for EN 61010-1
Telecommunications (Customer Equipment Safety) Technical Standard 2018 
(legislation.gov.au)

Perhaps in the future it will good to test an industrial controller with radio 
communication only for EN 62368-1 as a safety standard. Any one has a concern 
about this?

Thank you

Kind Regards / Saludos cordiales / Mit freundlichen Grüßen
Daniel Rodríguez


From: Pete Perkins 
Sent: Tuesday, 11 May 2021 18:41
To: Rodriguez, Daniel (ESP) ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Australia: IEC 62368-1 or IEC 61010-1 for controller with 
radio

Caution: This email message originated from outside of the organization. DO NOT 
CLICK on links or open attachments unless you recognize the sender and know the 
content is safe. If you think it is suspicious, please report as suspicious.


Daniel,  The world gets more complicated by the day.  This is both the exciting 
technologically challenging part of this work as well as the difficult, 
slogging regulatory stuff, too.

   Historically, 40 years ago,  61010 & 60950 (now 62368) were 
designed by folks working in overlapping businesses who understood that these 
two standards were aimed at providing safe electronic equipment (contrasted to 
electrical equipment).  61010 for commercial and industrial electronic 
equipment and 60950/62368 for consumer & commercial electronic equipment.  The 
products used the same components and techniques in the design for products so 
the requirements needed to be the same.  At the time there was consideration of 
making this one standard for all this equipment but this was a bridge too far.

   Today, electronics have been incorporated in many products, the 
term IoT (Internet of Things) describes this phenomenon well.

   Now this leaves us with a couple of choices; everything 
electronic goes into one or two standards or electronic devices are accepted in 
all product standards.  For the latter there has to be consideration as to the 
additional issues arising from the electronic portions, including the radio.

   I believe that the there needs to be the latitude to include 
complex digital electronic systems in any product.  in addition to the usual 
electronic controls and displays used, electronic motor controllers (VSDs) are 
becoming more popular in consumer equipment.  If the product standards are too 
slow to incorporate the needed safeguards for these electronic systems then it 
is not unreasonable to apply other requirements for them (think 61010 or 62368) 
but this should be the exception. I would believe.  This is a messy solution 
tho.

I have worked on a 'smart Relocatable Power Tap', an IoT combination which was 
to be certified to North American and European CB safety standards (specific 
outlet sockets for each market).  There was considerable negotiation with the 
safety test lab to get them to cooperate between their internal groups on the 
evaluation and ensure that any needed test was only run once.  The project 
covered the power delivery requirements as well as the electronic systems 
(including the radio) and, altho complex, went pretty well after that.
The EMC evaluation was straightforward, the RED evaluation was comprehensive 
covering all the needed requirements.

It would seem to me that you have properly evaluated your device and the radio 
requirements should not bring about a separate evaluation.  Are you prepared to 
defend your position in that regard?

   In your Australian case, this can only be clarified by the AU 
authorities who need to explain what they mean by the requirement.

   Perhaps, when this is resolved, you can provide all of us with 
an update as to how it is resolved.

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 1067
Albany, ORe  97321-0413

503/452-1201

IEEE Life Fellow
IEEE PSES 2020 Distinguished Lecturer
www.researchgate.net
 search my name
p.perk...@ieee.org


Entropy ain't what it used to be

From: Rodriguez, Daniel (ESP) 
<123de38bd494-dmarc-requ...@listserv.ieee.org>
Sent: Tuesday, May 11, 2021 12:46 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Australia: IEC 62368-1 or IEC 61010-1 for controller with radio

Good day to all!!

We have a industrial controller with radio capabilities (4G, Wi-Fi) that is 
tested for IEC 61010-1:2010.

1.Related to safety do we need to test for IEC 62368-1? According to the below 
ACM

[PSES] Retesting needed for EN 61010-1:2010/A1:2019??

[Rodriguez, Daniel (ESP)]

Good morning all

I have just reviewed the EN 61010-1:2010/A1:2019 and there a lot of changes. 
Most of them seems clarifications but I am not sure if we need to retest 
equipment checked for EN 61010-1:2010 to add A1:2029
Does anyone have a clear picture:
1.if retesting is required
2.if yes there is any cases that not (or which clauses requires testing)

Thank you for your answers!

Kind Regards / Saludos cordiales / Mit freundlichen Grüßen

Daniel Rodríguez
Sr. Equipment Compliance Specialist EMEA
T +34 673556249
E drodrig...@ecolab.com
ecolab.com

CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may 
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Re: [PSES] What percentage of products pass first time?

[McBurney, Ian]

Mike Sherman’s view exactly mirrors my experience in the 25 years I’ve been 
doing EMC testing!

Regards,

Ian McBurney
Lead Compliance Engineer
Allen & Heath Ltd.
Kernick Industrial estate,
Penryn,
Cornwall. TR10 9LU. UK.
Tel: 01326 372070
Email: ian.mcbur...@allen-heath.com

From: MIKE SHERMAN 
Sent: 24 May 2021 21:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] What percentage of products pass first time?

We have found "pre-screening" EMC testing early in the development cycle to be 
a good investment. EMC test results can be notoriously hard to predict, even 
when using EMC-savvy design principles. Extra PCB board spins are cheap in the 
context of a larger or time critical project.
Mike Sherman
Graco Inc.
On 05/24/2021 2:58 PM John E Allen 
<09cc677f395b-dmarc-requ...@listserv.ieee.org>
 wrote:


“From much experience” I can only concur with Pete, Monrad and yourself –  
safety, EMC  & RoHS compliance must be  explicitly built into the Product 
Lifecycle structure and process. Failure to do that, and to then make sure that 
that all WORKS is a route to “painful”, time-consuming and expensive results 
(“been there and seen that” – and recounted that here -  far too many times!). ☹

John E Allen
W.London, UK




From: Richard Nute mailto:ri...@ieee.org>>
Sent: 24 May 2021 19:45
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] What percentage of products pass first time?


Hi Charles:

Not what you asked for, but a set of principles for success with third-party 
testing, from a product safety point of view:


  1.  The design engineer and the product safety engineer should be able to 
predict the outcome of any test.
  2.  Testing simply confirms (or not) the prediction.
  3.  Failure of a test or other requirement at the third-party delays the 
third-party investigation which can imperil the product schedule.  To maintain 
schedule, the product must comply with all tests before it is submitted to the 
third-party.
  4.  If the product that you successfully tested fails a third-party test, 
then your or the third-party test was in error.  This can open a dialogue 
between you and the third-party as to test process.
  5.  Tests to standards requirements are either pass or fail; always record 
the measurement.  If the test requires a stimulation, then adjust the 
stimulation to the point of failure and record the measurement.  Both tell you 
the margin between pass and failure.
  6.  Provide your measurement data to the third-party when you submit the 
product.  If the third-party measurement data differs from your data, some 
third-parties will do their own investigation as to why.

In my opinion, EMC is not a black art and can follow these same principles.

Stay safe, and best regards,
Rich




From: Grasso, Charles [Outlook] 
mailto:charles.gra...@dish.com>>
Sent: Monday, May 24, 2021 7:47 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] What percentage of products pass first time?


Hello EMC gurus!



Calling all labs - In your experience how many products pass the Unintentional 
Emissions
test first time? ​




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Re: [PSES] What percentage of products pass first time?

[James Pawson (U3C)]

(replying even though I’m not a guru)



Hi Charles, hope all is well with you



Speaking from my own experience. Over the last four years of running a 
consultancy, pre-compliance and low cost test EMC laboratory I would (very 
roughly) estimate that around:



*   50% of products pass their desired radiated emissions limits without 
any modification

*   33% or less pass all of the applicable tests first time without 
modification



The major caveats and notes here are that



*   These figures are for customers products where the EMC performance is 
not known before testing. We do a lot of work helping people solve existing EMC 
problems but we are not counting this in these figures.
*   Most of my customers are smaller businesses that can’t afford to employ 
an engineer to just look after compliance. That job role is either split 
amongst several people or the engineer in question has to look after quality, 
manufacturing, sustaining, thermal, system, and everything else. Speaking as 
someone who has designed many products and systems in the past, trying to 
design for functionality whilst simultaneously considering best EMC performance 
is HARD. I use the metaphor of
*   The products that pass first time generally fall into one of three 
categories

*   Products that we have design reviewed before the design was finalised
*   Retests of products that have already been through our lab once
*   Products that are very simple in nature

*   Our hit-rate at being able to solve our customers problems is around 
90-95%
*   The “ones that got away” where we were unable to help deliver a 
compliant include

*   No action taken: Products where it was deemed by the manufacturer not 
economically feasible to modify the product (e.g. product going end of life)
*   No further communications from the manufacturer so we don’t get to find 
out what happened next (no news is good news, right?)



I would echo the sentiments of others on this thread regarding the need to 
design in compliance from the start.



One of the problems with the field of compliance is that it is too often 
“learned through experience in industry” and not explicitly taught. When it is 
taught at academic level it is often a surface treatment with a theoretical 
look at shielding or maybe crosstalk with no other practical context or 
background.



The split between industry and academia is one of the possible causes. Yes, 
there are exceptions to this but they primarily remain exceptions. I had 
discussions with a local university about some guest lectures on compliance and 
the theme of the response was “it doesn’t really fit into any of our modules” 
and “we can’t have it as an optional lecture as none of the students will 
attend”.



The number of times I hear “oh, thanks for that. No one has every explained it 
that clearly before” is worrying!



All the best

James









James Pawson

The EMC Problem Solver



Unit 3 Compliance Ltd

EMC : Environmental : Safety : CE + UKCA : Consultancy



  www.unit3compliance.co.uk  |  +44(0)1274 
911747  |  +44(0)7811 139957

2 Wellington Business Park, New Lane, Bradford, BD4 8AL

Registered in England and Wales # 10574298



From: Grasso, Charles [Outlook] 
Sent: 24 May 2021 15:47
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] What percentage of products pass first time?



Hello EMC gurus!



Calling all labs - In your experience how many products pass the Unintentional 
Emissions
test first time? ​





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