Re: [PSES] EU Machinery Regulation official version

[Scott Xe]

Dear Doug,

Thanks for your detailed explanation!  It seems the goods for the UK market
do not legally need to change to the new EU MR until an updated regulation
replacing the current one (old EU MD) is issued in the UK.

Best regards,

Scott


On Fri, 14 Jul 2023 at 09:13, Doug Nix  wrote:

> Hi Scott,
>
> Don’t I wish I could. At this point I’d need a well-tuned crystal ball. I
> don’t believe that the UK is quite sure where things will go.
>
> Since the UK is no longer a member of the EU, none of the law relating to
> the Machinery Regulation (MR) applies. For EU Members, the MR does not need
> to be transposed into national law like the directives did. It simply comes
> into force, and the members are expected to enforce it as written. But of
> for the UK? It’s anybody’s guess. They could stay with the MD since it’s
> already transposed into the The Supply of Machinery (Safety) Regulations
> 2008, UK SI 2008 No. 1597. They could modify UK SI 2008 No. 1597. They
> could lift the entire MR and adopt it as a new UK regulation.
>
> We’ll have to wait and see. As we get closer to the mandatory date they
> should start to tell people what they have in mind.
>
> My concern is that the new MR is considerably modernized, including
> clauses on AI and cybersecurity, and the former MD Annex IV list is gone,
> replaced with a more rational means of identifying dangerous machinery. If
> the UK stays with UK SI 2008 No. 1597, then they will be sliding backward
> compared to their closest neighbours. On the other hand, if they get a grip
> and decide to rejoin the EU as they likely should, then the new MR will
> come into force on the day they join.
>
> We shall see. Get your popcorn ready. It’s gonna be a wild ride I think.
>
> Best,
> Doug Nix
> d...@ieee.org
> +1 (519) 729-5704
>
> On Jul 13, 2023, at 21:04, Scott Xe  wrote:
>
>
> Dear Doug,
>>
>> Regarding the UK implementation part in your article, can you elaborate
>> the details of the UK implementation after the end of the transition date
>> of 31/12/2024?
>>
>> Thanks and regards,
>>
>> Scott
>>
>> On Thu, 6 Jul 2023 at 00:59,  wrote:
>>
>>> Thanks, Doug!
>>>
>>>
>>>
>>> Scott
>>>
>>>
>>>
>>> *From:* Doug Nix 
>>> *Sent:* Wednesday, July 5, 2023 2:24 AM
>>> *To:* Scott Xe 
>>> *Subject:* Re: [PSES] EU Machinery Regulation official version
>>>
>>>
>>>
>>> Hi Scott,
>>>
>>>
>>>
>>> If you are using the EM Machinery Regulation for CE Marking then, yes,
>>> of course it does. See articles 23 and 24 of the regulation.
>>>
>>>
>>>
>>> Doug Nix
>>> d...@ieee.org
>>> +1 (519) 729-5704
>>>
>>>
>>>
>>> On Jul 4, 2023, at 12:45, Scott Xe  wrote:
>>>
>>>
>>>
>>> Dear Doug,
>>>
>>>
>>>
>>> Many thanks for your brief and useful information!  I wonder if this
>>> regulation still requires a DoC.
>>>
>>>
>>>
>>> Best regards,
>>>
>>>
>>>
>>> Scott
>>>
>>>
>>>
>>>
>>>
>>
>

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Re: [PSES] FCC Part B questions

[Patrick]

I've been busy last couple of days and only now seeing the additional convo
around measurement uncertainty(MU).   I like the comments.  Most folks
appear to be either agnostic or in support of MU for use as a quality and
confidence builder.  I notice there are no MU-deniers??

Ok, I'll break the ice..., I think MU is a waste.  It wastes a labs (and
engineers) most precious resource: time.   I also cannot think of a single
customer, internal or external, that was ever willing to pay for this
metric.  If your experience is different, hit reply-all with an anecdote.


Here's an idea:  If customers are willing to pay, then wouldn't they also
be willing to pay for any upgrade? Would they pay for a better MU for their
product test? Maybe a lab can offer two levels of MU service?  Similar to a
how a lab offers Data Report(lower cost) vs Accredited Formal Report(full
cost)?  Maybe call it... 'Certified GMO & MU-free test data'?  Hmm, I
should trademark that idea.


Another thought... a two question survey for customers.   This is for the
P&L owner, the one that pays the invoice...

#1) Ask if they are willing to pay 10% extra for each dB of uncertainty you
remove.

#2)  Ask them if lab can ignore MU for their product and give them 10%
discount.


Drop the response here in the mail list.


... all in good fun!

As always, I wish all the best for my friends in EMI world !


Patrick.

On Wed, Jul 12, 2023, 13:53 John Woodgate  wrote:

> Quite right. We don't need to add uncertainty to EMC measurements, because
> they are uncertain enough already.😉
>
> ==
> Best wishes John Woodgate OOO-Own Opinions Only
> www.woodjohn.uk
> Rayleigh, Essex UK
>
> I hear, and I forget. I see, and I remember. I do, and I understand. Xunzi
> (340 - 245 BC)
>
>
> On 2023-07-12 21:17, Elliott Martinson wrote:
>
> A fun thing to do if you have access to a semi-anechoic chamber is use
> lots of duct tape to make sure *absolutely* *nothing* changes between
> measurements other than a certain design change--one accepted long ago that
> already went into production, which cost $$$ (cable ferrites, wrapping
> cables multiple times through ferrites, various black
> magic/witchcraft-based ideas)--and end up with evidence that a pass at a
> compliance lab years ago was misattributed to an expensive design change
> instead of a new test setup. Even all the duct tape in the world, however,
> doesn’t bring the uncertainty to 0.
>
>
>
> The standard  almost addresses this as you’re supposed to (as best as I
> can remember) adjust the EUT’s position on the turntable relative to the
> cables, which are also to be individually adjusted (position/orientation)
> to maximize emissions for each frequency “of interest” (along with mast
> height if I remember right). Try that with a console with 20+ cables at
> even one frequency… with a simplifying assumption that a cable can either
> be laid out in state “A” or state “B”, that’s still over 1 million
> combinations. Good thing for the lab techs (and whoever pays the labs’
> hourly rates) to have some “uncertainty” cushion
>
>
>
> -Elliott
>
>
>
>
>
> *From: *Brian Kunde 
> *Reply-To: *Brian Kunde 
> *Date: *Tuesday, July 11, 2023 at 9:31 AM
> *To: *
> *Subject: *Re: [PSES] FCC Part B questions
>
>
>
> If I may pile on late, keep in mind that measurement uncertainty is Plus
> or Minus (±). Years ago when I was with a previous company, we had a
> buy/sell piece of junk product that we were selling with our company's
> brand/name on it. It was audited in Sweden as part of their
> surveillance program and it failed by 2dB.  The test lab said they could
> not say it FAILED because 2dB was within their measurement uncertainty, so
> we could continue to ship and sell this product in Sweden.
>
>
>
> Has anyone else ever experienced this?
>
>
>
> Thanks,
>
> The Other Brian
>
>
>
>
>
> On Sat, Jul 8, 2023 at 8:28 AM Brent DeWitt  wrote:
>
> Hi Brian.  It's not entirely clear which measurement range you are asking
> about, but I'll assume conducted emissions in the range of 150 kHz to 30
> MHz.
>
> Short answer: You can skip QP and Avg detection if the peak detection
> level is below the Avg detection limit.
>
> No margin is "required" to pass any emissions limit.  Zero dB margin is
> still passing.  That said, measurement uncertainty in that range is
> generally 3-4 dB, so having a passing margin greater than that gives you
> some confidence that a re-test at another time and lab will still pass.
>
> Hope that helps.
>
> respectfully,
>
> Brent DeWitt
> Milford, MA
>
> On 7/8/2023 12:38 AM, Brian Gregory wrote:
>
>
>
>  Hi there,
>
>
>
> A question came up that I can't answer w/o a copy of Part 47.
>
> Does the FCC report require Quasi-Peak (QP) data, or just Avg and Peak.
> When do peak readings trigger the need to report QP?  I'm pretty sure Part
> 15 has AVG and QP limits listed.
>
>
>
> Next was what sort of margin is expected in or

Re: [PSES] EU Machinery Regulation official version

[Doug Nix]

Hi Scott,

Don’t I wish I could. At this point I’d need a well-tuned crystal ball. I don’t 
believe that the UK is quite sure where things will go.

Since the UK is no longer a member of the EU, none of the law relating to the 
Machinery Regulation (MR) applies. For EU Members, the MR does not need to be 
transposed into national law like the directives did. It simply comes into 
force, and the members are expected to enforce it as written. But of for the 
UK? It’s anybody’s guess. They could stay with the MD since it’s already 
transposed into the The Supply of Machinery (Safety) Regulations 2008, UK SI 
2008 No. 1597. They could modify UK SI 2008 No. 1597. They could lift the 
entire MR and adopt it as a new UK regulation.

We’ll have to wait and see. As we get closer to the mandatory date they should 
start to tell people what they have in mind.

My concern is that the new MR is considerably modernized, including clauses on 
AI and cybersecurity, and the former MD Annex IV list is gone, replaced with a 
more rational means of identifying dangerous machinery. If the UK stays with UK 
SI 2008 No. 1597, then they will be sliding backward compared to their closest 
neighbours. On the other hand, if they get a grip and decide to rejoin the EU 
as they likely should, then the new MR will come into force on the day they 
join.

We shall see. Get your popcorn ready. It’s gonna be a wild ride I think.

Best, 
Doug Nix
d...@ieee.org
+1 (519) 729-5704

> On Jul 13, 2023, at 21:04, Scott Xe  wrote:
> 
> 
>> Dear Doug,
>> 
>> Regarding the UK implementation part in your article, can you elaborate the 
>> details of the UK implementation after the end of the transition date of 
>> 31/12/2024?
>> 
>> Thanks and regards,
>> 
>> Scott
>> 
>> On Thu, 6 Jul 2023 at 00:59, > > wrote:
>>> Thanks, Doug!
>>> 
>>>  
>>> 
>>> Scott
>>> 
>>>  
>>> 
>>> From: Doug Nix mailto:d...@ieee.org>> 
>>> Sent: Wednesday, July 5, 2023 2:24 AM
>>> To: Scott Xe mailto:scott...@gmail.com>>
>>> Subject: Re: [PSES] EU Machinery Regulation official version
>>> 
>>>  
>>> 
>>> Hi Scott,
>>> 
>>>  
>>> 
>>> If you are using the EM Machinery Regulation for CE Marking then, yes, of 
>>> course it does. See articles 23 and 24 of the regulation.
>>> 
>>>  
>>> 
>>> Doug Nix
>>> d...@ieee.org 
>>> +1 (519) 729-5704
>>> 
>>> 
>>> 
>>> 
>>> On Jul 4, 2023, at 12:45, Scott Xe >> > wrote:
>>> 
>>>  
>>> 
>>> Dear Doug,
>>> 
>>>  
>>> 
>>> Many thanks for your brief and useful information!  I wonder if this 
>>> regulation still requires a DoC.
>>> 
>>>  
>>> 
>>> Best regards,
>>> 
>>>  
>>> 
>>> Scott
>>> 
>>>  
>>> 
>>>  
>>> 


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Re: [PSES] EU Machinery Regulation official version

[Scott Xe]

> Dear Doug,
>
> Regarding the UK implementation part in your article, can you elaborate
> the details of the UK implementation after the end of the transition date
> of 31/12/2024?
>
> Thanks and regards,
>
> Scott
>
> On Thu, 6 Jul 2023 at 00:59,  wrote:
>
>> Thanks, Doug!
>>
>>
>>
>> Scott
>>
>>
>>
>> *From:* Doug Nix 
>> *Sent:* Wednesday, July 5, 2023 2:24 AM
>> *To:* Scott Xe 
>> *Subject:* Re: [PSES] EU Machinery Regulation official version
>>
>>
>>
>> Hi Scott,
>>
>>
>>
>> If you are using the EM Machinery Regulation for CE Marking then, yes, of
>> course it does. See articles 23 and 24 of the regulation.
>>
>>
>>
>> Doug Nix
>> d...@ieee.org
>> +1 (519) 729-5704
>>
>>
>>
>> On Jul 4, 2023, at 12:45, Scott Xe  wrote:
>>
>>
>>
>> Dear Doug,
>>
>>
>>
>> Many thanks for your brief and useful information!  I wonder if this
>> regulation still requires a DoC.
>>
>>
>>
>> Best regards,
>>
>>
>>
>> Scott
>>
>>
>>
>>
>>
>

-

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