Re: Short circuit tests in GR-1089

2002-11-25 Thread Jon Curtis
This was resolved a couple of NEBS conferences ago.  All the main RBOCs 
were present and they agreed that a fuse was a special case.  The fuse 
is designed to open, therefore operation of the fuse is normal and allowed.


This may be a semantic strech, but that's where the current NEBS 
interpretation lies.


All other parts of the board must remain undamaged.  The no fire 
hazard is a significant weakening of the general interpretation and 
probably represents aggressive engineering judgement.


Jon.

j...@aol.com wrote:


Hello All:

I am hoping that some of you can help clarify the intent of requirement R9-20 
in Telcordia GR-1089.  Taken literally, the requirement says that there shall 
be no damage to equipment, conductors, or components when the DC power supply 
is shorted at the load.  This could even be interpreted to preclude the use 
of a fuse that has to be replaced.


One test lab has told me that as long as no fire hazard is created from this 
test, it is considered to have been passed.  Needless to say, this differs a 
bit from the literal interpretation.


I guess it would help if I had a better feel for the overall goal of the 
short circuit testing.  Any insight on this would be most appreciated.



Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848
http://www.randolph-telecom.com


 



Re: Australian compliance to ARE: creepage v breakdown voltage

2002-03-19 Thread Jon Curtis
Yes, NATA has informed us that the RTA list is being updated soon. 
Curtis-Straus (USA) is also accredited to perform testing to AS/ACIF S043.


Jon Curtis

Kevin Richardson wrote:


Kristiaan,

 

Equipment which falls under TLN Category A50 is required to comply 
with ACA TS001:1997 (Compliance Level 3) and AS/ACIF S043 - Parts 1, 2 
 3 as appropriate (Compliance Level 3 from 1 Jan 02).  You said 
deemed to comply but I presume you mean need to comply so this is 
correct.


 

Compliance Level 3 does indeed require test reports be from an 
Recognised Testing Authority (RTA). 

Compliance Level 3 requirements are spelt out in the TLN Section 
4.6(1) and 4.6(2). 

Yes there are other options to compliance with Compliance Level 3 
instead of a test report from an RTA as listed in 4.6(2).


NOTE:  4.6.(2)(c) I do not think could be applied as there is no 
reason a Category A50 device could not be tested in a lab.  In 
addition, 4.6(2)(d), 4.6(2)(e), 4.6.(2)(f) and 4.6(2)(g) do not apply 
to Category A50 equipment.


 


The only compliance options therefore for a Category A50 device would be:

1.  a test report from an RTA; or

2.  a written statement from a certification body.

 

 

The NATA RTA listing is not up-to-date even though the last revision 
was dated 7 Mar 02.


 

Apart from BABT TUV Product Services lab in Santa Clara, USA, there 
are at least 2 other labs that I am aware of accredited to S043:


a)  Austest (Sydney, Australia); and

b)  Comtest (Melb, Australia)

 

Details for these labs can be found in the RTA listing on the NATA web 
site you referenced.


 


Best regards,
Kevin Richardson

Stanimore Pty Limited
Compliance Advice  Solutions for Technology (including Australian 
Agent Services)

(Legislation/Regulations/Standards)
Ph:   02-4329-4070   (Int'l: +61-2-4329-4070)
Fax:  02-4328-5639   (Int'l: +61-2-4328-5639)
Mobile:  04-1224-1620   (Int'l: +61-4-1224-1620)
Email:k...@compuserve.com
 (kevin.richard...@ieee.org - alternate email)

The material transmitted in this message or contained in attachments 
to this message may contain confidential and/or privileged material 
and is intended only for the addressee. Any use of or reliance upon 
this material by persons or entities other than the addressee is 
prohibited. If you receive this in error, please notify the sender and 
destroy any copies of the material immediately.


-Original Message-
From: owner-emc-p...@majordomo.ieee.org 
[mailto:owner-emc-p...@majordomo.ieee.org] On Behalf Of 
kristiaan.carpent...@alcatel.be

Sent: Saturday, 16 March 2002 3:12 AM
To: Emc-Pstc Post
Subject: Australian compliance to ARE: creepage v breakdown voltage


Hello,

According to the latest version of the Telecommunication Labelling 
Notice 2001, products in the Category A50 are deemed to comply with 
ACA TS-001-1997 and AS/ACIF S043-2001. No problem for TS-001, but S043 
needs Compliance level 3 only since January 1rst 2002.
The general approach is that testing for S043 must be done by a 
Recognised Testing Authority.
After verifying the latest list of RTA´s 
http://www.nata.asn.au/downloads/rtalist.pdf of March 7th, only 1 lab 
seems to be listed as RTA and it is not even located in Australia, but 
in the US.
From my reading of the Labelling Notice, Schedule 3 seems to give 
however other possibilities to comply, like a Certification or 
Competent body.

Any-one can shed some light on this issue?

Regards,
Kris Carpentier



--
Jon D. Curtis, P.E.

Director of Engineering
Curtis-Straus LLC NRTL TCB

One Stop Laboratory for NEBS, EMC, 
Product Safety, and Telecom Testing.

527 Great Road
Littleton, MA 01460 USA
Voice 978-486-8880  Fax 978-486-8828
email: jcur...@curtis-straus.com
WWW.CURTIS-STRAUS.COM




Re: Laser Safety

2002-03-06 Thread Jon Curtis


See laser notice 50 from the FDA. 
http://www.fda.gov/cdrh/radhlth/laser.html


It's allowed, but you have to change the certification statement to 
indicate that you are using the notice.


Jon Curtis
Curtis-Straus LLC

John Juhasz wrote:


I tried looking real hard for free downloadable ANSI specs
and couldn't find them - I had to buy them.

Regarding labelling, there have been efforts (not sure
of the status at this time - is there anyone out
there who knows?) to harmonize the EN 60825 and
21CFR1040 to make it easier on manufacturers. 
As the final laser classifications are parallel

(it's the methodology that has differences)
the FDA, in the interest of manufacturer satisfaction(?) 
has been allowing the use of the Classification/Warning

labels as described in EN 60825. But you still have to
add the FDA-CDRH label This product complies with FDA
Radiation Performance Standard 21 CFR Subpart J 


Hope this helps.

John Juhasz
Fiber Options
Bohemia, NY

-Original Message-
From: Davis, Mike [mailto:mda...@c-cor.net]
Sent: Wednesday, March 06, 2002 9:26 AM
To: 'Doug Mckean'; 'John Juhasz'; 'Mark Schmidt';
emc-p...@majordomo.ieee.org
Subject: RE: Laser Safety


I agree with Doug and with John but, I have the same question. And I will
add, Doug is speaking of the FDA-CDRH requirement for the US. But, to
ascertain what the European mode is, this requires a single-fault condition
for classification as described by John Juhasz. That, I understand. John, is
there a free downloadable copy of ANSI Z136.1 and .2 specs?

I have used the calculations to determine the classification of a laser
based on the no fault and a single fault mode. These lasers are operating in
a pulsed mode at a 50% duty cycle. I have attached a sample calculation of a
1310nmn and a 1550nm laser that I used to determine that the lasers either
do or do not fall within the Class 1 laser classification. Another
question...

Can the same label be used for FDA as for IEC? Has anyone had any feedback
or problems with laser labels that deviated from recommended markings by the
21 CFR or IEC 825-1?



---
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/

To cancel your subscription, send mail to:
majord...@ieee.org
with the single line:
unsubscribe emc-pstc

For help, send mail to the list administrators:
Ron Pickard:  emc-p...@hypercom.com
Dave Heald:   davehe...@mediaone.net

For policy questions, send mail to:
Richard Nute:   ri...@ieee.org
Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
   http://ieeepstc.mindcruiser.com/
   Click on browse and then emc-pstc mailing list




--
Jon D. Curtis, P.E.

Director of Engineering
Curtis-Straus LLC NRTL TCB

One Stop Laboratory for NEBS, EMC, 
Product Safety, and Telecom Testing.

527 Great Road
Littleton, MA 01460 USA
Voice 978-486-8880  Fax 978-486-8828
email: jcur...@curtis-straus.com
WWW.CURTIS-STRAUS.COM




---
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/

To cancel your subscription, send mail to:
majord...@ieee.org
with the single line:
unsubscribe emc-pstc

For help, send mail to the list administrators:
Ron Pickard:  emc-p...@hypercom.com
Dave Heald:   davehe...@mediaone.net

For policy questions, send mail to:
Richard Nute:   ri...@ieee.org
Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
   http://ieeepstc.mindcruiser.com/
   Click on browse and then emc-pstc mailing list


Re: Laser Safety

2002-03-06 Thread Jon Curtis
 Use caution once again.  IEC 60825-2 is NOT single fault.  You need to 
go further and consider if a condition is reasonable foreseeable even 
if you need multiple faults to get there.  Often there is congruence 
between single fault and reasonably foreseeable, but not always.


From 60825-2:
reasonably foreseeable event
event the occurrence of which under given circumstances can be predicted 
fairly accurately,

and the occurrence probability or frequency of which is not low or very low.
Examples of reasonably foreseeable events might include the following: 
component failure,
fibre cable break, optical connector disconnection, operator error or 
inattention to safe

working practices.
Reckless use or use for completely inappropriate purposes is not to be 
considered as a

reasonably foreseeable event

The assessment of hazard levels shall always consider worst case 
conditions, including
reasonably foreseeable fault conditions (see 4.4.3). Consequently, it 
may be necessary to
include multiple fault conditions, the probability of which shall be 
judged by the

responsible organization.
NOTE Whereas IEC 60825-1 refers to single fault conditions, it may be 
reasonably foreseeable that more

than one fault will combine to cause a dangerous situation.

FDA laser notice 50 issued in July of 2001 allows you to harmonize with 
IEC 60825-1, so as long as you slightly modify your FDA certification 
statement label to note that you are using the deviations in Notice 50 
you can use the IEC 60825 labels.  The FDA is contemplating a rule 
making to adopt the IEC versions and has therefore put manufacturers on 
notice that they will not take enforcement action against those choosing 
to use the IEC standards.  Note that you still have additional 
administrative requirements under the CDRH rules.


Jon Curtis
Curtis-Straus LLC

Davis, Mike wrote:


I agree with Doug and with John but, I have the same question. And I will
add, Doug is speaking of the FDA-CDRH requirement for the US. But, to
ascertain what the European mode is, this requires a single-fault condition
for classification as described by John Juhasz. That, I understand. John, is
there a free downloadable copy of ANSI Z136.1 and .2 specs?

I have used the calculations to determine the classification of a laser
based on the no fault and a single fault mode. These lasers are operating in
a pulsed mode at a 50% duty cycle. I have attached a sample calculation of a
1310nmn and a 1550nm laser that I used to determine that the lasers either
do or do not fall within the Class 1 laser classification. Another
question...

Can the same label be used for FDA as for IEC? Has anyone had any feedback
or problems with laser labels that deviated from recommended markings by the
21 CFR or IEC 825-1?





Subject:

Re: Laser Safety
From:

Doug Mckean dmck...@corp.auspex.com
Date:

Tue, 5 Mar 2002 17:16:54 -0500
To:

emc-p...@majordomo.ieee.org


Do the acid test type question ... 

During normal use, what are you exposing the end user to? 

For instance, with a laser pointer using a Class IIIb 
laser that emits unprotected from the pointer, the 
pointer is Class IIIb. 

If instead, you are using a Class IIIb laser for fiber optic 
communication and the entire beam is contained within 
the fiber, no lasing is emitted from the product during 
normal operation and/or service or maintainance, then 
you *could* declare the telco product as Class I. 

- Doug McKean 




---
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/

To cancel your subscription, send mail to:
majord...@ieee.org
with the single line:
unsubscribe emc-pstc

For help, send mail to the list administrators:
Ron Pickard:  emc-p...@hypercom.com
Dave Heald:   davehe...@mediaone.net

For policy questions, send mail to:
Richard Nute:   ri...@ieee.org
Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
   http://ieeepstc.mindcruiser.com/
   Click on browse and then emc-pstc mailing list



--
Jon D. Curtis, P.E.

Director of Engineering
Curtis-Straus LLC NRTL TCB

One Stop Laboratory for NEBS, EMC, 
Product Safety, and Telecom Testing.

527 Great Road
Littleton, MA 01460 USA
Voice 978-486-8880  Fax 978-486-8828
email: jcur...@curtis-straus.com
WWW.CURTIS-STRAUS.COM




Re: Laser Safety

2002-03-06 Thread Jon Curtis


Use caution with this approach.  IEC 60825-2 is specifically for Optical 
Fiber Communications Systems (OFCS) and requires the consideration of 
fiber breaks exposing humans to the laser energy contained within. 
60825-2 is referenced in 60825-1 and must be considered for OFCS. 
Additionally, you need to consider where the fiber goes as a break 
might occur downstream and expose not only direct users of the equipment.


Jon Curtis
Curtis-Straus LLC

Doug Mckean wrote:

Do the acid test type question ... 

During normal use, what are you exposing the end user to? 

For instance, with a laser pointer using a Class IIIb 
laser that emits unprotected from the pointer, the 
pointer is Class IIIb. 

If instead, you are using a Class IIIb laser for fiber optic 
communication and the entire beam is contained within 
the fiber, no lasing is emitted from the product during 
normal operation and/or service or maintainance, then 
you *could* declare the telco product as Class I. 

- Doug McKean 




---
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/

To cancel your subscription, send mail to:
majord...@ieee.org
with the single line:
unsubscribe emc-pstc

For help, send mail to the list administrators:
Ron Pickard:  emc-p...@hypercom.com
Dave Heald:   davehe...@mediaone.net

For policy questions, send mail to:
Richard Nute:   ri...@ieee.org
Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
   http://ieeepstc.mindcruiser.com/
   Click on browse and then emc-pstc mailing list




--
Jon D. Curtis, P.E.

Director of Engineering
Curtis-Straus LLC NRTL TCB

One Stop Laboratory for NEBS, EMC, 
Product Safety, and Telecom Testing.

527 Great Road
Littleton, MA 01460 USA
Voice 978-486-8880  Fax 978-486-8828
email: jcur...@curtis-straus.com
WWW.CURTIS-STRAUS.COM




---
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/

To cancel your subscription, send mail to:
majord...@ieee.org
with the single line:
unsubscribe emc-pstc

For help, send mail to the list administrators:
Ron Pickard:  emc-p...@hypercom.com
Dave Heald:   davehe...@mediaone.net

For policy questions, send mail to:
Richard Nute:   ri...@ieee.org
Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
   http://ieeepstc.mindcruiser.com/
   Click on browse and then emc-pstc mailing list


Re: Initial Laser Reports submitions to the CDRH-FDA?

2002-02-27 Thread Jon Curtis

Go to

http://www.fda.gov/cdrh/radhlth/laser.html

and check out the reporting guides on product reports and annual reports.

Jon Curtis.

jsarell...@tuvam.com wrote:


Hello Group,

Does anyone know what is the procedure to follow for laser report 
submittals to the CDRH?

this is not a medical laser. It conforms to laser classification Class I.
any comments, advice is appreciated.

Regards,

Jorge Sarellano
TUV PRODUCT SERVICE
Compliance Engineer
Phone 408-919-3744
Fax 408-919-0585

Visit http://www.tuvam.com and discover the new CEU Mark, multiple 
markets one solution!




--
Jon D. Curtis, P.E.

Director of Engineering
Curtis-Straus LLC NRTL TCB

One Stop Laboratory for NEBS, EMC, 
Product Safety, and Telecom Testing.

527 Great Road
Littleton, MA 01460 USA
Voice 978-486-8880  Fax 978-486-8828
email: jcur...@curtis-straus.com
WWW.CURTIS-STRAUS.COM