Re: [PSES] EN 60950 vs EN62368

[Pete Perkins]

Cecil,

 

   IEC 62368-1 is the replacement standard for IEC 60950.  

 

   IEC 60950 is already being phased out in the CE system. 

 

   All new products should be certified under IEC 62368-1.  

 

:>) 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: cgitt...@rochester.rr.com  
Sent: Tuesday, February 8, 2022 3:15 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EN 60950 vs EN62368

 

Colleagues,

 

My question specially is “is EN 60950 more appropriate for commercial/business 
environments?” given that EN 62368 is aimed more at consumer?

 

Thanks,

 

Cecil

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Re: [PSES] Machinery Leakage Current

[Pete Perkins]

Mike, et al, Thanx for mentioning my name; by now you should be able to 
tell the stories as we’ve talked thru these things before.  

 

   From my experience, protection is primarily needed for cord and 
plug connected equipment where the earthing/grounding is not considered 
reliable – which includes North America.  Most such equipment is allowed to 
have higher touch current under fault conditions, where the fault current 
exceeds 5ma the GFCI provides the needed protection

 

   Since GFCIs look for the ‘lost to ground current’, the 
differential current in the power cord, they also work in circumstances where 
the earth/ground doesn’t exist  (a 2-wire installation) or where it should 
exist but doesn’t.  Many are installed in older 2-wire installations because of 
this in the USA. 

 

   RCDs rated to trip at 30mA are working right at the c1 
Ventricular Fibrillation level of IEC 60479-1 so should provide that protection 
for most people.  

 

   Not sure if RCDs are tested or rated for catching performance 
degradation in machines but you apparently have experience with that.  It would 
be nice to see a paper on that performance feature.  

 

   North American GFCIs are rated at 5mA which is the 
letgo-immobilization limit specified in IEC 60479-1.  (Yes, I know the 
allowable range is not trip at 4mA but must trip at 6mA; the rated trip current 
is still 5mA.)  You can still disengage from the current at that level, 
providing that level of protection.  

 

   Both North American GFCIs and Euro RCDs are not rated to deal 
well with high frequency signals generated by Switch Mode Power Supplies and 
Variable Speed Drives for motors.  Lots of ‘nuisance tripping’ results.  There 
is an ongoing UL project to get a handle on this and get it fixed here in NA.  

 

   Yes, EV chargers are being provided with GFCIs at higher levels, 
depending upon the installation/application parameters. 

 

:>) 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

 <http://www.researchgate.net/Peter%20Perkins> www.researchgate.net search my 
name

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

 

Entropy ain’t what it used to be

 

From: MIKE SHERMAN  
Sent: Thursday, February 3, 2022 12:48 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Machinery Leakage Current

 

Doug -- 

 

Thanks for mentioning this! 

 

Yes, I've seen these 30 mA RCDs or RCCBs before, but not an RCBO (confused? 
Google can explain these acronyms). 

 

I've even recommended these for large machinery. The ones we used had 
adjustable trip points up to 30 mA. Note that I recommended these for MACHINE 
protection, not PERSONAL protection. The theory was to monitor potential 
breakdown of the dielectric of the machine by watching the ground leakage 
current. As I recall, early on we found, before it failed completely, a 
variable speed fan drive motor with bridged dielectric that was grounding out 
through a shaft bearing. 

 

I'd love to hear what PETE PERKINS has to say about this! 

 

Personally, given that North American GFCIs for 120 VAC have trip points of 4-6 
mA, I've tended to not like to exceed that number. As I recall, Pete has 
demonstrated that even 5 mA will be a current to remember if you conduct it. 

 

That said, I think Pete told me a while back that the NEC is raising the 
allowable leakage current for EV chargers to something quite above 5 mA. I'm 
sure there's a good story behind that. 

 

Note also that GFCIs, and as I recall the RCD we were using, could fail 
silently and thus needed to be tested regularly to ensure continued protection. 

 

Mike Sherman 

On 02/03/2022 8:23 AM Doug Nix mailto:d...@ieee.org> > wrote: 

 

 

Hi Mark, 

 

I’ve seen mains filters used for 400 V 3 ph. 200A services with leakage 
currents close to 30 mA. Consider that RCBOs commonly used outside North 
America have a design trip current of 30 mA, so leakage currents above 30 mA 
will cause the RCBO to trip. None the less, these large leakage currents can be 
startling the first time you see them “in the wild”. 

 

Doug Nix 
d...@ieee.org <mailto:d...@ieee.org>  
+1 (519) 729-5704 





On 1-Feb-22, at 13:24, Stultz, Mark 
<0f79f2e10e47-dmarc-requ...@listserv.ieee.org 
<mailto:0f79f2e10e47-dmarc-requ...@listserv.ieee.org> > wrote: 

Hello, 

Is there a hard limit for leakage current for machinery in the EU?  IEC 60204-1 
provides instructions in clause 8.2.8 for “equipment having earth leakage 
currents higher than 10 mA”.  This seems quite high so we have applied the 3.5 
mA limits for class 1 stationary equipment in IEC 60335-1.  Is there another 
source for leakage current limits that is machinery-specific

[PSES] machinery that is moving while working, wot CE requirements

[Pete Perkins]

All, I have a client that is producing a machine that moves while
working - such as a fork lift or lumber carrier.  

 

   Trying to understand the CE requirements for such equipment.


 

   What Directives apply? What technical standard apply?  What
other regulatory issues arise?  

 

   Let me know what the requirements are.  

 

:>) 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

 


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Re: [PSES] IEC 62368-3:2017 evaluation of USB 2.0 ports

[Pete Perkins]

John (& Charlie),  Yes, I believe I also said that, under Euro CE marking & now 
British UKCA, self-certification is allowed but he mentioned that he was 
concerned that a test house was pressing the issue.  So, if he wants to get the 
test house marking he either has to talk them out of it or comply with the 
identified requirements.  

 

   But, let’s look at the technical requirements a bit.  The use of 
Voltage limits has been common for decades to declare circuits that are deemed 
touch safe.  This had been done under the assumption that any long time contact 
with the circuit is small area of contact and dry conditions.  For some 
applications this may not be a good assumption downstream and, since the 
allowed current (a few A in his case) is well above the 5mA 
letgo-immobilization and the 30mA VF limit, then this condition must not be 
abrogated for the circuit to remain safe to touch.  You don’t even have to go 
to single fault for this analysis.  His risk analysis would include this line 
of examination from which he would determine if this risk is acceptable and, 
thus, deem the application acceptable.  

 

:>) 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

 <http://www.researchgate.net/Peter%20Perkins> www.researchgate.net search my 
name

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

 

Entropy ain’t what it used to be

 

From: John Woodgate  
Sent: Wednesday, October 20, 2021 12:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] IEC 62368-3:2017 evaluation of USB 2.0 ports

 

Hi, Pete. Isn't Charlie's option to say, with test results, that if he plugs 
his product into a USBzilla source, it still remains safe under any 
single-fault condition?

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




On 2021-10-20 19:52, Pete Perkins wrote:

Charlie,Remember that 62368-3 was developed at the direction of 
ACOS to move the powered communication interfaces info from the 62368-1 base 
standard to a separate document that would be available for use outside of 
62368-1.  The goal is to move this from the Wild West into an orderly set of 
requirements that any product standard can use.  

 

   You claim that for the ‘simple circuit’ you mentioned the 
limited power is safe as you see it.  How does the user know if that simple 
solution is implemented in any particular product and that it is safe? 

 

   The 62368-3 standard itself seems limiting so the requirements 
are being rewritten into 2 new documents which will be more tailored to the two 
realms under which these circuits work, <60Vdc and >60Vdc.  TC108 has this work 
underway.  

 

   Whether or not any of this is required is a matter for product 
committees to specify and test labs to check.  

 

   Whether you want to use the requirements or not come down to 
your understanding of the risk associated with the use (and misuse) of products 
providing power over these communication interfaces and/or having them 
specified in a mother standard.  

 

:>) 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 <http://www.researchgate.net/Peter%20Perkins>  search my 
name

p.perk...@ieee.org <mailto:p.perk...@ieee.org> 

 

 

Entropy ain’t what it used to be

 

From: Charlie Blackham  <mailto:char...@sulisconsultants.com> 
 
Sent: Wednesday, October 20, 2021 10:12 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] IEC 62368-3:2017 evaluation of USB 2.0 ports

 

All

 

I realise there are now applications where 100W or more can be transferred, but 
for devices with only USB2.0 ports, that are coming from the same chip, is 
there really any need for testing and CB certification to this standard as part 
of an assessment to IEC 62368-1?

 

The particular products I’m looking at are powered from external 5V LPS power 
supplies that shutdown at around 4.5 A

 

I may just be being cynical, but I can’t see how the -3 standard makes such a 
product any safer, it just seems to make the test lab richer 

 

Is there something in the CB scheme rules that mandates using the -3 standard 
as well when seeking CB certificate?

 

Best regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Mead House

Longwater Road

Eversley

RG27 0NW

UK

Tel: +44 (0)7946 624317

Email:  <mailto:char...@sulisconsultants.com&g

Re: [PSES] IEC 62368-3:2017 evaluation of USB 2.0 ports

[Pete Perkins]

Charlie,Remember that 62368-3 was developed at the direction of 
ACOS to move the powered communication interfaces info from the 62368-1 base 
standard to a separate document that would be available for use outside of 
62368-1.  The goal is to move this from the Wild West into an orderly set of 
requirements that any product standard can use.  

 

   You claim that for the ‘simple circuit’ you mentioned the 
limited power is safe as you see it.  How does the user know if that simple 
solution is implemented in any particular product and that it is safe? 

 

   The 62368-3 standard itself seems limiting so the requirements 
are being rewritten into 2 new documents which will be more tailored to the two 
realms under which these circuits work, <60Vdc and >60Vdc.  TC108 has this work 
underway.  

 

   Whether or not any of this is required is a matter for product 
committees to specify and test labs to check.  

 

   Whether you want to use the requirements or not come down to 
your understanding of the risk associated with the use (and misuse) of products 
providing power over these communication interfaces and/or having them 
specified in a mother standard.  

 

:>) 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: Charlie Blackham  
Sent: Wednesday, October 20, 2021 10:12 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] IEC 62368-3:2017 evaluation of USB 2.0 ports

 

All

 

I realise there are now applications where 100W or more can be transferred, but 
for devices with only USB2.0 ports, that are coming from the same chip, is 
there really any need for testing and CB certification to this standard as part 
of an assessment to IEC 62368-1?

 

The particular products I’m looking at are powered from external 5V LPS power 
supplies that shutdown at around 4.5 A

 

I may just be being cynical, but I can’t see how the -3 standard makes such a 
product any safer, it just seems to make the test lab richer 

 

Is there something in the CB scheme rules that mandates using the -3 standard 
as well when seeking CB certificate?

 

Best regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Mead House

Longwater Road

Eversley

RG27 0NW

UK

Tel: +44 (0)7946 624317

Email:   char...@sulisconsultants.com

Web:   https://sulisconsultants.com/ 

Registered in England and Wales, number 05466247

 

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[PSES] FW: Join us Online: Micro-Thermography – Temperature Measurement in the Micrometer Range

[Pete Perkins]

For those who are wishing that temperature measurements could be made easier 
with thermal cameras, here’s an update on the technology.  

 

:>) 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

 <http://www.researchgate.net/Peter%20Perkins> www.researchgate.net search my 
name

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

 

Entropy ain’t what it used to be

 

From: InfraTec GmbH  
Sent: Wednesday, October 6, 2021 7:14 AM
To: p.perk...@ieee.org
Subject: Join us Online: Micro-Thermography – Temperature Measurement in the 
Micrometer Range

 


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Re: [PSES] SV: [PSES] Creepage and clearance requirements

[Pete Perkins]

Amund,I believe that we agree in principle.  

I am not proposing that the test report include everything that is not covered 
(a tricky business) but, rather, that it include a simple statement such as: 
this product has been evaluated as a mains product throughout and the detailed 
review of the usual isolation/insulation has not been done.   (I’m sure you 
could come up with more inclusive wording, but in the end, the reader is put on 
notice as to the restricted applicability of the evaluation.) 

 

This is a good exercise in adapting the requirements of the standard to a 
specific application.  I’m pleased that we examined this in this forum.  

 

:>) 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

 <http://www.researchgate.net/Peter%20Perkins> www.researchgate.net search my 
name

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

 

Entropy ain’t what it used to be

 

From: Amund Westin  
Sent: Tuesday, September 14, 2021 11:39 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] SV: [PSES] Creepage and clearance requirements

 

Pete,

I can follow your thoughts and that special things can happen with such a 
product in the long run. But the manufacturer will probably make designs that 
support product functionality and design as original intended. Taking into 
account future new development of HW and other functionalities will probably 
not be relevant due to, among other things, costs. But I recognize that 
increasing distances from 2mm to 6mm should not be cost driven. But if this is 
to be done after the product's first version is launched, then it will mean new 
pcb layouts and components with the costs that follow. It is not known whether 
UL or Nemko or other accredited test laboratories will point out in their test 
report that the design will not be approved if you later connect I / O lines to 
the secondary circuits on the product. If a new manufacturer or company were to 
introduce such product changes without making sure that they could reuse the 
design without having to make any changes to the original design, it must be 
said to be a strange approach. But if it is either written in test reports or 
in other documentation that safety only applies to products as it appears, then 
it is of course positive.

 

Best regards Amund

 

Fra: Pete Perkins 
Sendt: 14. september 2021 16:51
Til: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Emne: Re: [PSES] Creepage and clearance requirements

 

Amund,I support Rich’s approach.  

 

   It does leave a lingering question, though.  (removing my rose 
colored glasses and putting on my dark, pessimistic glasses)

 

   Imagine a downstream case such as this:  The unit works well and 
is popular.  A customer request comes to the manufacturer something to the 
effect that the unit works well except does not provide the full operational 
reliability in cases where there is significant EMC generated in the use area; 
they ask for an output (USB , PoE, etc) so that they can cable connect the unit 
for these applications.  A (different) company designer believes that this is 
easy to do and starts to work on this project.  If you are lucky, he consults 
the earlier safety lab report to understand the details to properly implement 
this.  

   Where in the report do you clearly state that the requirements, 
including isolation/insulation (creepage and clearance) were not evaluated and 
the ‘secondary’ is considered mains in a clear way?   

   With this understanding the designer will know that the full 
mains isolation/insulation will have to be done for the output circuit since it 
wasn’t done for the mains/secondary interface initially.  (Since, reasonably 
often, the unit won’t meet the mains/secondary requirements in some way and the 
manufacturer will not be willing to change it in this redesign cycle.)

   If this is not clearly taken care of initially then the process 
starts down the slippery slope of believing that everything was completed 
earlier and not fully reviewed at the modification step.  If not caught by the 
designer then the test lab catch will be a major complication in the project 
schedule.  If not caught by the test lab (your associate down the hall) then 
the product is inadequate and does not meet the requirements of the standard; 
hopefully this gets caught in the review but what if it doesn’t?

 

   My point is that simplifications need to be clearly stated in 
the documentation for downstream users.  Don’t leave anything to chance.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 1067

Albany, ORe  97321-0413

 

503/452-1201

 

Re: [PSES] Creepage and clearance requirements

[Pete Perkins]

Amund,I support Rich’s approach.  

 

   It does leave a lingering question, though.  (removing my rose 
colored glasses and putting on my dark, pessimistic glasses)

 

   Imagine a downstream case such as this:  The unit works well and 
is popular.  A customer request comes to the manufacturer something to the 
effect that the unit works well except does not provide the full operational 
reliability in cases where there is significant EMC generated in the use area; 
they ask for an output (USB , PoE, etc) so that they can cable connect the unit 
for these applications.  A (different) company designer believes that this is 
easy to do and starts to work on this project.  If you are lucky, he consults 
the earlier safety lab report to understand the details to properly implement 
this.  

   Where in the report do you clearly state that the requirements, 
including isolation/insulation (creepage and clearance) were not evaluated and 
the ‘secondary’ is considered mains in a clear way?   

   With this understanding the designer will know that the full 
mains isolation/insulation will have to be done for the output circuit since it 
wasn’t done for the mains/secondary interface initially.  (Since, reasonably 
often, the unit won’t meet the mains/secondary requirements in some way and the 
manufacturer will not be willing to change it in this redesign cycle.)

   If this is not clearly taken care of initially then the process 
starts down the slippery slope of believing that everything was completed 
earlier and not fully reviewed at the modification step.  If not caught by the 
designer then the test lab catch will be a major complication in the project 
schedule.  If not caught by the test lab (your associate down the hall) then 
the product is inadequate and does not meet the requirements of the standard; 
hopefully this gets caught in the review but what if it doesn’t?

 

   My point is that simplifications need to be clearly stated in 
the documentation for downstream users.  Don’t leave anything to chance.  

 

:>) 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: Richard Nute  
Sent: Sunday, September 12, 2021 3:05 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Creepage and clearance requirements

 

 

 

Hi Amund:

 

If no accessible conductive parts, then you can designate the secondary 
circuits as part of the primary circuits, which means there is no need for 
isolation between primary and secondary circuits.  No creepage or clearance 
requirements!  OVC would not apply primary-to-(a primary) secondary.

 

The plastic enclosure would probably constitute reinforced insulation 
throughout.  For electric shock, you would wrap in foil and measure touch 
current.  Should be comfortably below the limit.  And, you would need to do a 
dielectric test to the same foil at twice the voltage necessary for basic 
insulation.  Should easily pass.

 

I have assumed the antenna is within the enclosure so no accessible conductive 
parts.  If the antenna is an accessible conductive part, then the above 
scenario is not valid.  

 

Stay safe, and best regards,

Rich

 

 

 

 

From: Amund Westin mailto:am...@westin-emission.no> 
> 
Sent: Sunday, September 12, 2021 10:16 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Creepage and clearance requirements

 

IEC60950-1:

 

How about the Creepage and clearance requirements for an AC driven radio HUB 
device. 

 

*   One input: 230VAC (direct into wall socket)
*   No physical output ports, just radio communication.
*   Insulated plastic enclosure (UL94 V-0)

 

The Creepage and clearance requirements between primary and secondary circuits, 
does it make any sense as long as the device has no cables and is encapsulated 
by a plastic enclosure

I understand that there should be some Creepage and clearance to withstand OVC 
II (250V transient).

 

Best regards Amund

 

 

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Re: [PSES] Creepage and clearance requirements

[Pete Perkins]

Amund,Where does 60950 say that there are no requirements if 
you don’t have an output?  

 

:>) 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: Amund Westin  
Sent: Sunday, September 12, 2021 10:16 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Creepage and clearance requirements

 

IEC60950-1:

 

How about the Creepage and clearance requirements for an AC driven radio HUB 
device. 

 

*   One input: 230VAC (direct into wall socket)
*   No physical output ports, just radio communication.
*   Insulated plastic enclosure (UL94 V-0)

 

The Creepage and clearance requirements between primary and secondary circuits, 
does it make any sense as long as the device has no cables and is encapsulated 
by a plastic enclosure

I understand that there should be some Creepage and clearance to withstand OVC 
II (250V transient).

 

Best regards Amund

 

 

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Re: [PSES] U.S. equivalent to BS 1363...

[Pete Perkins]

John, ‘some years ago’… Just watch the date, the standard is updated from 
time to time.  

 

:>) 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: John E Allen <09cc677f395b-dmarc-requ...@ieee.org> 
Sent: Tuesday, September 7, 2021 10:58 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] U.S. equivalent to BS 1363...

 

IIRC – I downloaded that F.O.C from the NEMA website some years ago.

 

John E Allen

W. London UK

 

From: Matthew Wilson | GBE mailto:matthew.wil...@gbelectronics.com> > 
Sent: 07 September 2021 17:37
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] U.S. equivalent to BS 1363...

 

Hello Ted, that’s great, thank you very much.

 

Kind regards,

 

Matthew Wilson,

GB Electronics (UK) Ltd.

 



 

From: Ted Eckert mailto:ted.eck...@microsoft.com> > 
Sent: 07 September 2021 14:37
To: Matthew Wilson | GBE mailto:matthew.wil...@gbelectronics.com> >; EMC-PSTC@LISTSERV.IEEE.ORG 
 
Subject: RE: U.S. equivalent to BS 1363...

 

Hello Matthew,

 

I believe you are looking for NEMA WD-6.

Wiring Devices—Dimensional Specifications (nema.org) 

 

 

Best regards,

Ted Eckert

The opinions expressed are my own and do not necessarily reflect those of my 
employer.

 

From: Matthew Wilson | GBE mailto:matthew.wil...@gbelectronics.com> > 
Sent: Tuesday, September 7, 2021 1:36 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [EXTERNAL] [PSES] U.S. equivalent to BS 1363...

 

Hello all, unfortunately I'm not too familiar with U.S. standards. I am looking 
for the equivalent information of BS 1363-1 that would describe the standard 
U.S. mains plug and socket dimensions, plug pin lengths, spacings etc. I nice 
2D dimensioned drawing would be ideal.

The reason is we are needing to make sure some third party sourced plug top 
'wall wart' power supply units intended for use in the U.S. will be correct 
mechanically regards the plug & pins.

Thanks for any help, much appreciated.









Disclaimer:​ This email and any files transmitted with it are confidential and 
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​GB Electronics (UK) Ltd is a company registered in England and Wales under 
number 06210991.
​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West 
Sussex, BN12 4QY.

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Re: [PSES] Climatic conditions for ESD testing

[Pete Perkins]

John, Thanx for your response.  If true: 

 

   It's foolish at best and irresponsible in the worst case to
demand control when all the technical expertise lies within the IEC on this
subject, not the ISO.  

 

   Politics at its worst in action (we see such all the time,
unfortunately).  

 

:>) 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

 <http://www.researchgate.net/Peter%20Perkins> www.researchgate.net search
my name

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

 

Entropy ain't what it used to be

 

From: John Woodgate  
Sent: Thursday, July 29, 2021 10:22 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Climatic conditions for ESD testing

 

They did it because the motor industry wants to have all its standards in
ISO (obviously they have thousands of mechanical standards), not IEC, and
wants full control over them.


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




On 2021-07-29 17:32, Pete Perkins wrote:

Specifically for this case; why did the committee write another standard
that seems to cover the same ground as a base standard IEC 61000-4-2?  Wot's
the rationale for this additional standard?  

 

  _  


 <https://www.avg.com/internet-security> 

This email has been checked for viruses by AVG antivirus software. 
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Re: [PSES] Climatic conditions for ESD testing

[Pete Perkins]

Charlie, et al,  If the requirements are tied to the physics then they 
should be reasonable.  

A couple of papers popped up in a google search.  Here’s one.  

 

Content from this work may be used under the terms of the Creative Commons 
Attribution 3.0 licence. Any further distribution
of this work must maintain attribution to the author(s) and the title of the 
work, journal citation and DOI.
Published under licence by IOP Publishing LtdElectrostatics 2019 and 
Dielectrics 2019
IOP Conf. Series: Journal of Physics: Conf. Series 1322 (2019) 012010
IOP Publishing
doi:10.1088/1742-6596/1322/1/012010
1
A kinetic model for the electrostatic spark discharge
in atmospheric-pressure air
A Ohsawa
Electrical Safety Research Group, National Institute of Occupational Safety and 
Health,
Japan (JNIOSH), 1-4-6 Umezono, Kiyose, Tokyo 204-0024, Japan
E-mail: ohs...@s.jniosh.johas.go.jp
Abstract. This paper presents a 0-D kinetic model of electrostatic spark 
discharges consisting
of the time-dependent Boltzmann equation of electrons, a discharge-circuit 
equation, and heavy
particles’ kinetic equations to investigate the energy-transfer mechanisms from 
the electrostatic
energy given to the energy of gases by the spark discharge. In this report, the 
model is applied
to the discharges in atmospheric-pressure air under optimum conditions 
corresponding for the
minimum ignition energies of the typical flammable gases, hydrogen, ethylene 
and propane, in
three types of explosion groups for gases.

 

   Altho the article focuses on flammable gases it discusses it 
relative to air which is the basis for ESD arcs of interest in other 
situations.  

 

:>) 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

 <http://www.researchgate.net/Peter%20Perkins> www.researchgate.net search my 
name

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

 

Entropy ain’t what it used to be

 

From: Charlie Blackham  
Sent: Thursday, July 29, 2021 9:50 AM
To: Pete Perkins ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Climatic conditions for ESD testing

 

EN 61000-4-2 specifies a minimum air pressure of 860 mbar but, 

*   920 mbar is the centre of a cat 5 hurricane at sea level
*   860 mbar is about 4500m above sea level

 

Hardly the most rigorous set of criteria ever written into a standard 

 

Best regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:  <https://sulisconsultants.com/> https://sulisconsultants.com/ 

Registered in England and Wales, number 05466247

 

From: Pete Perkins <0061f3f32d0c-dmarc-requ...@ieee.org 
<mailto:0061f3f32d0c-dmarc-requ...@ieee.org> > 
Sent: 29 July 2021 17:32
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] Climatic conditions for ESD testing

 

John, You need to address your question to the committee that is 
responsible for the standard you are questioning.  

 

   Remember that the standards writing business is a BOGSAT process 
(Bunch Of Guys Sitting Around a Table).  Most of the participants are there 
because they know something about the subject (subject expert matter delegates) 
or they have some issue that they either want addressed or want to have it 
excluded from the standard (latter is usually not disclosed until deep into the 
discussion).  If the leader can come up with a comprehensive outline as to the 
subjects to be addressed then the process will be more comprehensive; if not it 
will be less organized.  

   Specifically for this case; why did the committee write another 
standard that seems to cover the same ground as a base standard IEC 61000-4-2?  
Wot’s the rationale for this additional standard?  

 

   Standards writing is not a scientific endeavor (even tho it uses 
scientific principles, such as you pointed out); It’s like sausage making – but 
don’t go into the kitchen if you aren’t ready to be involved in making the 
sausage…

   If you have strong feelings about the completeness of the 
product level standard perhaps you should be on the committee and straighten it 
out.  Don’t just grumble, get involved.  

 

:>) 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 <http://www.researchgate.net/Peter%20Perkins>  search my 
name

p.perk...@ieee.org <mailto:p.perk...@ieee.org> 

 

 

Entropy ain’t what it used to be

 

From: John Flavin mailto:jfla...@vermeer.com> > 
Sent: Thursday, July 29, 2021 5:39 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subje

Re: [PSES] Climatic conditions for ESD testing

[Pete Perkins]

John, You need to address your question to the committee that is
responsible for the standard you are questioning.  

 

   Remember that the standards writing business is a BOGSAT
process (Bunch Of Guys Sitting Around a Table).  Most of the participants
are there because they know something about the subject (subject expert
matter delegates) or they have some issue that they either want addressed or
want to have it excluded from the standard (latter is usually not disclosed
until deep into the discussion).  If the leader can come up with a
comprehensive outline as to the subjects to be addressed then the process
will be more comprehensive; if not it will be less organized.  

   Specifically for this case; why did the committee write
another standard that seems to cover the same ground as a base standard IEC
61000-4-2?  Wot's the rationale for this additional standard?  

 

   Standards writing is not a scientific endeavor (even tho it
uses scientific principles, such as you pointed out); It's like sausage
making - but don't go into the kitchen if you aren't ready to be involved in
making the sausage.

   If you have strong feelings about the completeness of the
product level standard perhaps you should be on the committee and straighten
it out.  Don't just grumble, get involved.  

 

:>) 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: John Flavin  
Sent: Thursday, July 29, 2021 5:39 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Climatic conditions for ESD testing

 

IEC 61000-4-2 specifies climatic conditions for air discharge, including
barometric pressure. ISO 10605 (ESD for road vehicles) is silent about
barometric pressure.

As I remember, air pressure influences the reproducibility of air
discharges, which I assume is why IEC 61000-4-2 specifies limit on it. (ISO
10605:2008 even says this in Annex E.)

 

So, if it's important, why is this not specified in ISO 10605?

 

 




John Flavin

Senior EMC Engineer

1860 Vermeer Road East | Pella, IA USA 50219

O: 641-621-8958

jfla...@vermeer.com  

 
 vermeer.com

 

 

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

[Pete Perkins]

MC-PSTC@LISTSERV.IEEE.ORG <mailto: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)

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www.element.com 

This communication and any attachment contain information from PCTEST 
Engineering Laboratory, LLC. and is intended for the exclusive use of the 
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From: Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org 
<mailto:0061f3f32d0c-dmarc-requ...@listserv.ieee.org> > 
Sent: Tuesday, May 25, 2021 12:39 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto: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

 <mailto:p.perk...@ieee.org> 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 <mailto: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 enginee

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

[Pete Perkins]

Yes, John,There were things that we did at 20 or 40 or even 60 
that, if we can do them, take longer now.  

 

   Some of this was things that we did when we were young and 
foolish; we’re not so young anymore.  

 

   Here in the US we’re familiar with the folk song: ‘The old Gray 
Mare ain’t what she used to be’.  

 

:>) 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

 <http://www.researchgate.net/Peter%20Perkins> www.researchgate.net search my 
name

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

 

Entropy ain’t what it used to be

 

From: john_e_al...@blueyonder.co.uk  
Sent: Friday, June 4, 2021 1:31 PM
To: 'Pete Perkins' 
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [EXTERNAL] Re: [PSES] What percentage of products pass 
first time?

 

Not bragging - given that I have quite a few “physical problems” ( arthritic 
knee, displace L3 vertibra)  that have since all but prevented me from actually 
doing most of what I previously hoped that I could be doing now ☹

 

From: Pete Perkins mailto:peperkin...@cs.com> > 
Sent: 04 June 2021 20:58
To: john_e_al...@blueyonder.co.uk <mailto:john_e_al...@blueyonder.co.uk> ; 
EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: RE: [PSES] [EXTERNAL] Re: [PSES] What percentage of products pass 
first time?

 

Ok, Quit bragging, I’ve got you both beat.  

 

:>) 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

 <http://www.researchgate.net/Peter%20Perkins> www.researchgate.net search my 
name

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

 

Entropy ain’t what it used to be

 

From: John E Allen <09cc677f395b-dmarc-requ...@listserv.ieee.org 
<mailto:09cc677f395b-dmarc-requ...@listserv.ieee.org> > 
Sent: Friday, June 4, 2021 12:54 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] What percentage of products pass 
first time?

 

Correct, but I made mine about 5 ½ yrs after the end of my last contract – so 
many other “things” I wanted to do that I’d not had time for over the previous 
many years.

 

From: John Woodgate mailto:j...@woodjohn.uk> > 
Sent: 04 June 2021 20:42
To: john_e_al...@blueyonder.co.uk <mailto:john_e_al...@blueyonder.co.uk> ; 
EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] What percentage of products pass 
first time?

 

Everyone has a choice. 

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

On 2021-06-04 20:40, john_e_al...@blueyonder.co.uk 
<mailto:john_e_al...@blueyonder.co.uk>  wrote:

No way will I be “going back to contracting”  - 6 yrs away from all that hassle 
has convinced me that it wouldn’t be worth all the hassle & stress (had quite 
enough of that whilst I was working - contract or not!), especially now that 
the UK tax regs on contract work have become more complex & difficult to 
“navigate”. ☹

 

OTOH, I thought I’d deleted my LinkedIn a/c but I still get a few “job 
opportunities” flagged up by various agencies which got my contact details from 
that site – seems that deleting those a/c’s is considerably more “difficult” 
than it should be ☹.

 

John E Allen

W.London, UK

 

From: John Woodgate  <mailto:j...@woodjohn.uk>  
Sent: 04 June 2021 19:56
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] What percentage of products pass 
first time?

 

Don't assume. I've just been hired at 83.5 years old. Not a long-term hire, nor 
well paid, but every little helps.

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

On 2021-06-04 18:54, Cortland Richmond wrote:

I retried to a few years working on contracts, and I doubt I'll be working 
again at 77 -- but it was FUN.

 


 
<http://www.avg.com/email-signature?utm_medium=email_source=link_campaign=sig-email_content=emailclient>
 

Virus-free.  
<http://www.avg.com/email-signature?utm_medium=email_source=link_campaign=sig-email_content=emailclient>
 www.avg.com 

-


This message is from the IEEE Product Safety Enginee

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

[Pete Perkins]

Ok, Quit bragging, I’ve got you both beat.  

 

:>) 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: John E Allen <09cc677f395b-dmarc-requ...@listserv.ieee.org> 
Sent: Friday, June 4, 2021 12:54 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] What percentage of products pass 
first time?

 

Correct, but I made mine about 5 ½ yrs after the end of my last contract – so 
many other “things” I wanted to do that I’d not had time for over the previous 
many years.

 

From: John Woodgate mailto:j...@woodjohn.uk> > 
Sent: 04 June 2021 20:42
To: john_e_al...@blueyonder.co.uk  ; 
EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] What percentage of products pass 
first time?

 

Everyone has a choice. 

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



On 2021-06-04 20:40, john_e_al...@blueyonder.co.uk 
  wrote:

No way will I be “going back to contracting”  - 6 yrs away from all that hassle 
has convinced me that it wouldn’t be worth all the hassle & stress (had quite 
enough of that whilst I was working - contract or not!), especially now that 
the UK tax regs on contract work have become more complex & difficult to 
“navigate”. ☹

 

OTOH, I thought I’d deleted my LinkedIn a/c but I still get a few “job 
opportunities” flagged up by various agencies which got my contact details from 
that site – seems that deleting those a/c’s is considerably more “difficult” 
than it should be ☹.

 

John E Allen

W.London, UK

 

From: John Woodgate    
Sent: 04 June 2021 19:56
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] What percentage of products pass 
first time?

 

Don't assume. I've just been hired at 83.5 years old. Not a long-term hire, nor 
well paid, but every little helps.

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




On 2021-06-04 18:54, Cortland Richmond wrote:

I retried to a few years working on contracts, and I doubt I'll be working 
again at 77 -- but it was FUN.

 


 

 

Virus-free.  

 www.avg.com 

-


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discussion list. To post a message to the list, send your e-mail to 
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All emc-pstc postings are archived and searchable on the web at: 
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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Re: [PSES] Hot surface sign

[Pete Perkins]

Scott, et al,

 

   Having worked with developing markings for 60950 and 62368-1 it 
is clear that there needs to be latitude given in the final marking depending 
upon the details of the design and the approaches that seem to be the best fit 
for the application.  

 

   At the highest level it is clear that full color, legible 
complete markings are the most desirable.  However, there are issues in making 
that work in every instance.  Joshua’s example of a marking stamped in the 
stainless steel is a good example of that; it provides the marking in a durable 
way where it is applicable.

 

   Hopefully, this type of practicality will not be forgotten in 
our work.  

 

:>) 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: Scott Xe  
Sent: Thursday, May 27, 2021 7:55 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Hot surface sign

 

Dear Josh,

 

Although the contrast of warning size is not perfect, there is no specific 
requirement given and common on the product.

 

Regards,

 

Scott

 

On Wed, 26 May 2021 at 22:14, Wiseman, Joshua 
mailto:joshua.wise...@orthoclinicaldiagnostics.com> > wrote:

Scott,

 

At my previous employer we had the symbol stamped into the stainless steel of a 
part on the commercial griddle. A traditional label would not withstand the 
heat in this instance and with-it being part of the sheet metal it me all the 
cleaning and legibility requirements. It’s hard to see but I took a snippet of 
one from a video of the griddle on YouTube.

 



 

Josh

 

Joshua Wiseman

Staff Engineer, Product Safety/EMC/Systems

 

From: Scott Xe mailto:scott...@gmail.com> > 
Sent: Wednesday, May 26, 2021 10:04 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Hot surface sign

 

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

 

In some cooking appliances, there are some hot surfaces that may cause burn 
injury and safety standards suggest putting a hot surface sign to alert the 
users.

*   Is there any specific colour requirement?  Common practice is black 
colour on yellow background or white colour on black background.
*   Is an embossed sign black on black considered as a legible sign in EU 
criteria perspective?
*   In case of ink-printed label, is it put on the top of the hot surface 
or next to the hot surface?  If on the top of surface, the colours are 
protected from heat degradation and specialized adhesives should be used to 
withstand higher temperatures.  Is there any test criteria for verification?

Thanks and regards,

 

Scott

-


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discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org> >

All emc-pstc postings are archived and searchable on the web at: 
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ 

  can be used for graphics (in well-used formats), large files, etc.

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Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) 

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 

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

[Pete Perkins]

Chas, et al,  Yes, great responses; lot’s of experience out there.  

 

   To answer your recent expression of your question we need to 
understand that the world is not static; people move around plus come and go.  

 

   Altho I get more that my share of ‘We have a product to ship 
next week that needs CE, can you come in and do that for us’ (which has led to 
some very interesting projects), most places that are working with all of this 
regulatory web of issues understand that they need to meet the requirements and 
expect the design teams to come up to speed on the details.  This is a moving 
target; how many 10s of thousands of new engineers are graduated in the world 
each year and sucked up into companies and are given significant assignments 
with minimal supervision and training.  

 

   This leads to one of my basic understandings as to what I do.  
The collective members of the project teams are like a stew and the ‘cook’ 
(company leader at some level) stirs the pot regularly to make a better 
outcome.  This provided opportunities for us knowledgeable folks to jump in and 
do handholding and informal training in all of this as part of our work on a 
project.  It’s usually satisfying if you like to help folks do their job well 
(and they accept the help).  

 

   Because of the addition of newbies regularly and the ever 
changing requirements this is a never ending cycle (and opportunity).  

 

   So, Chas, yes, the experienced folks are getting better and 
better at this stuff and they have a high pass rate with the labs.  They don’t 
stay in one place too long if they are very good.  Opportunity exists to help 
the present team improve in what they do.  

 

   Anyone want to replace me so I can really retire and get back to 
more fishing?  

 

:>) 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: Grasso, Charles [Outlook]  
Sent: Monday, May 24, 2021 12:07 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] What percentage of products pass first time?

 

Hi all – What wonderful responses.  I understand that without the proper 
processes in attention that the chances of 
passing first time is low indeed. One could argue that the first time passers 
have such a system in place and I was interested
in how much EMC has been integrated into the product design process in recent 
years!

 

Chas

 

From: Richard Nute mailto:ri...@ieee.org> > 
Sent: Monday, May 24, 2021 12:45 PM
To: Grasso, Charles [Outlook] mailto:charles.gra...@dish.com> >; EMC-PSTC@LISTSERV.IEEE.ORG 
 
Subject: RE: [PSES] What percentage of products pass first time?

 

 This message originated outside of DISH and was sent by: ri...@ieee.org 
  

 

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? ​

 

 

-

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

[Pete Perkins]

Charles, et al, You question is rather simplistic, in my opinion.  

 

   From my more than 25 years doing safety & regulatory consulting 
with dozens and dozens of companies both large and small, I find that the 
experience of the design team is the key to meeting the requirements early on.  

 

   First timers (no prior experience having an outside lab test any 
of their work for compliance) has a pretty low pass rate; no matter how much 
advice is given during the design phase.  

 

   Design teams quickly gain experience ramp up & meet compliance 
requirements on the next project or two providing the design is similar to 
their earlier experience.  

 

   This level of competence can be confounded (made worse) if there 
are substantial changes in the design team between projects.  Newbies always 
think they understand the needs and design accordingly; unless an experienced 
team manager can ferret out the issue before testing and get them to change.  

 

   Additional features (especially radios) complicate the issue, 
even for experienced design teams.  

 

   To specifically answer your question, first designs from an 
inexperienced design team generally will need another pass (or more) thru the 
lab to qualify.  Experienced teams will have a high 1st time pass rate in most 
cases.  

 

   To relate one scenario, a complex electronic research instrument 
was developed by a 3 man team of PhD physicists who struggled when going thru 
the EMC lab; they had no prior product certification experience.  I had offered 
to go to the lab with them but they thought they could handle it themselves.  
They had no concept of the needs to provide the proper isolation between major 
pieces (e.g. cables routinely pierced the chassis and made connexion well 
within the equipment).  After the 2nd failure the lab manager, a  long-time 
colleague, talked to me and said that they weren’t listening to his comments 
about needed changes to fix it.  Upon talking to them, they had dismissed him 
as just a technician (ignoring his EE training and EMC lab experience) and they 
believed that they knew better (but not good enough, as evidenced by the 
continuing failure).  So we had a ‘managerial discussion’ and I went to the EMC 
lab with them from then  on.  The baling wire fixes tried at the lab showed 
improvement when applied and led to installing proper connectors at the chassis 
interfaces along with some other changes; it finally passed.

 

   Others probably have more interesting cases to relate, too.  

 

   Does that fit with your experience?

 

:>) 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: Grasso, Charles [Outlook]  
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] EU DoC on Thumb Drive?

[Pete Perkins]

Brian,This is another method that needs to be on the list of accepted paths 
to show compliance, in my opinion.  

 

   Of course, the acceptance for any such methods need to come from 
the Euro Commission, meeting Euro legal requirements and having the buy-in of 
all the interested parties – such as the Customs Officers who are charged with 
either clearing or refusing entry to CE marked items and are looking for 
further justification (MDoC in particular).  

   I see this as a long slog to get anywhere unless some very 
influential group that the EU folks admire takes it on with a passion.  Do you 
know anyone at the WTO?  

 

   I guess, if your company is gutsy enough you can try it and see 
how it goes; sometimes changes are made in fact and later the paperwork catches 
up.  

 

:>) 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

 <http://www.researchgate.net/Peter%20Perkins> www.researchgate.net search my 
name

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

 

Entropy ain’t what it used to be

 

From: Brian Ceresney  
Sent: Friday, May 14, 2021 10:40 AM
To: Pete Perkins ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] EU DoC on Thumb Drive?

 

Hello All, 

Apologies for “hijacking the thread”, but we’ve been considering the 
now-ubiquitous(post pandemic) QR Code as a method of delivering information 
about the product – user manual, declarations for the EU, MC documentation, 
etc. A small accessible code label could really help make information 
accessible to the customer, using the cell phone. 

Does this also still fall under the “not-yet” category?

 

Best Regards, 

Brian C.

From: Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org 
<mailto:0061f3f32d0c-dmarc-requ...@listserv.ieee.org> > 
Sent: Friday, May 14, 2021 10:34 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] EU DoC on Thumb Drive?

 

CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.

 

Carl et al,

 

   This question has been asked before and the official answer 
seems to still be ‘not yet’.  

 

   Some folks in the IEEE PSES TAC/ITE interest group have been 
working to put together a draft proposal that would allow digital documentation 
(thumb drive or even website) to meet the requirements.  As noted, there are 
many interests in this way outside our usual working circle.  Nothing has 
developed from this yet; maybe sometime in the future.  

 

   Keep your hopes up though; pie in the sky is what keeps us going 
some time.   

 

:>) 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

 <http://www.researchgate.net/Peter%20Perkins> www.researchgate.net search my 
name

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

 

Entropy ain’t what it used to be

 

From: Charlie Blackham mailto:char...@sulisconsultants.com> > 
Sent: Friday, May 14, 2021 1:17 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] EU DoC on Thumb Drive?

 

Carl

 

A number of other Directives such as RED and Machinery also require DoC to be 
provided with equipment

 

In the absence of Guidance that says you can provide it electronically it is 
best to work on the basis that you must not – Customs / Market enforcement will 
expect to be able to find the DoC if they inspect the product, and if it’s not 
in print format they won’t be able to as they’re not going to load up a CD or 
USB stick, and you will be considered to be shipping “non-compliant” product

 

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: Carl Newton mailto:emcl...@gmail.com> > 
Sent: 13 May 2021 20:36
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] EU DoC on Thumb Drive?

 

Group,

I've not been able to find anything that suggests that the EU DoC can be 
provided with the product electronically for a medical device.  I sent an 
inquiry to the commission and received no response.  The MDD and MDR require 
that the DoC is shipped with each product  and I have a customer that would 
like to include it on a thumb drive document package that will ship with the 
device rather than a paper hard-copy.

Do any of you have experience with this question that you can share?  

Thanks in advance,

Carl

-
--

Re: [PSES] EU DoC on Thumb Drive?

[Pete Perkins]

Carl et al,

 

   This question has been asked before and the official answer 
seems to still be ‘not yet’.  

 

   Some folks in the IEEE PSES TAC/ITE interest group have been 
working to put together a draft proposal that would allow digital documentation 
(thumb drive or even website) to meet the requirements.  As noted, there are 
many interests in this way outside our usual working circle.  Nothing has 
developed from this yet; maybe sometime in the future.  

 

   Keep your hopes up though; pie in the sky is what keeps us going 
some time.   

 

:>) 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: Charlie Blackham  
Sent: Friday, May 14, 2021 1:17 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU DoC on Thumb Drive?

 

Carl

 

A number of other Directives such as RED and Machinery also require DoC to be 
provided with equipment

 

In the absence of Guidance that says you can provide it electronically it is 
best to work on the basis that you must not – Customs / Market enforcement will 
expect to be able to find the DoC if they inspect the product, and if it’s not 
in print format they won’t be able to as they’re not going to load up a CD or 
USB stick, and you will be considered to be shipping “non-compliant” product

 

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: Carl Newton mailto:emcl...@gmail.com> > 
Sent: 13 May 2021 20:36
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] EU DoC on Thumb Drive?

 

Group,

I've not been able to find anything that suggests that the EU DoC can be 
provided with the product electronically for a medical device.  I sent an 
inquiry to the commission and received no response.  The MDD and MDR require 
that the DoC is shipped with each product  and I have a customer that would 
like to include it on a thumb drive document package that will ship with the 
device rather than a paper hard-copy.

Do any of you have experience with this question that you can share?  

Thanks in advance,

Carl

-


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

[Pete Perkins]

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 ACMA Telecommunication Labelling Notice is required

 

2.If we have the radio modules approved for that standard, can we use that
for compliance evidence?

 

It is confusing for me that we test the equipment for two different safety
standards (IEC 61010-1 and IEC 62368-1). Normally we are using IEC 61010-1
for a controller and now Australia requires also IEC 62368-1

 

Thank you for your answer if you are able to support!!

 

 

IEC 62368-1 will only become mandatory in Australia when called up under the
ACMA’s Telecommunications Labelling Notice. It will eventually address
requirements for acoustic safety which are currently under development
within the IEC. Until such time the applicable Australian acoustic safety
requirements will remain in AS/ACIF S004 and AS/CA S042.1

Communications Alliance - 3.13 Health and safety (commsalliance.com.au)
 

 

Kind Regards / Saludos cordiales / Mit freundlichen Grüßen

 

Daniel Rodríguez

Sr. Equipment Compliance Specialist EMEA

T +34 673556249 

E  

Re: [PSES] EU Machinery Directive 2006/42/EC for motorized adjustable height table

[Pete Perkins]

Scott,The MDoC and other public references to standards used become an 
overload in the supplied documentation.  The better route is to incorporate 
these references, detailing by clause and/or whatever limitation you have 
applied, in your Technical File which supports the claim of meeting EN ISO 
12100 in the MDoC and manual provided.  

 

:>) 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: Scott Xe  
Sent: Tuesday, May 4, 2021 7:51 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU Machinery Directive 2006/42/EC for motorized adjustable 
height table

 

It applies the harmonised standard EN ISO 12100 to assess the product for the 
compliance of MD.  In the conformity report, it validates each clause using a 
few standards such as EN 60335-1, EN 527, EN 55014-1:2017+A11:2020, EN 
61000-3-2:2019, EN 62233 : 2008 etc.  Is it necessary to quote all the 
standards or just EN ISO 12100 only in the DoC inside the instructions manual?

 

Thanks and regards,

 

Scott

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Re: [PSES] e-Labeling

[Pete Perkins]

Peter,That’s a very general question.  For what type of equipment under 
what Directives and Standards are you expecting this?  

 

   For example, do you find the needed labeling  for your cell 
phone on the product itself or is it embedded in the firmware somewhere or what 
is there accompanying documentation providing it?  

 

:>) 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: 06cee064502d-dmarc-requ...@listserv.ieee.org 
<06cee064502d-dmarc-requ...@listserv.ieee.org> 
Sent: Wednesday, April 21, 2021 10:17 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] e-Labeling

 

Hello group, 

 

Do we know if EU accepts e-Labeling or not?

 

Thanks

Peter

 

 

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Re: [PSES] UL = IEC ??

[Pete Perkins]

Amund,To expand on what Rich as said, UL adapted IEC 60950
ITE products and IEC 61010 commercial/industrial electronic equipment as UL
standards early on so there have been harmonized IEC/UL requirements for
these products for 30 years; IEC 60950 has been replace by IEC 623268-1 IT&
consumer electronic products & as you know.  Other IEC standards have been
adapted by UL for the US market; IEC 60065 for TVs, IEC 60601 for med
devices and IEC 60335 for household appliances - to name some key ones -
over the years to aid manufacturers to develop products for the worldwide
market.  So a large portion of consumer/commercial products are being
designed against these harmonized requirements.   Others will be adapted as
manufacturers press UL to do so.  

Remember, tho, that the US does not accept a manufacturer's Declaration of
Conformity; only 3rd party certifications are accepted in the US so the mfgr
must get a cert mark from a US NRTL to show compliance.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain't what it used to be

 

From: Richard Nute  
Sent: Thursday, January 21, 2021 2:24 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UL = IEC ??

 

 

Hi Amund:

 

First and foremost, both the IEC and UL make money selling standards.

 

Second, UL does not adopt any IEC standard, or most other non-UL standards.

 

UL will test to an IEC standard, and may issue a CB test report, but not the
right to use their certification mark.  UL will only issue the right to use
their certification mark if the product meets the UL standard.  

 

UL writes their own standards.  If industry insists, UL will start with an
IEC standard and re-write it to meet their requirements (often justified as
meeting USA National Electrical Code requirements).  To be fair, Americans
often add more requirements, too (which are gladly accepted by UL as such
additional requirements mean additional testing and additional income).  

 

UL is an ANSI-approved standards-writing organization.  As such, virtually
all UL standards are also ANSI standards.  All other certification houses
must use UL/ANSI standards for their certification. 

 

Best regards, and stay safe!

Rich

 

 

From: Amund Westin mailto:am...@westin-emission.no> > 
Sent: Thursday, January 21, 2021 2:40 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] UL = IEC ??

 

When IEC publish a standard, do UL adopt it as is, or do they modify it? I
guess this will vary form case to case. Right?

 

Best regards Amund

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Re: [PSES] Will there be an IEC electrical safety standard for E-cigarettes?

[Pete Perkins]

Joe,

 

   IEC 60335 deals more with electromechanical products.  You
need to consider having this looked at as an electronic product.  

 

The key IEC standards for electronic products are IEC 61010 and IEC 62368-1.


 

   I would recommend that you look at IEC 62368-1 and work to
select appropriate requirements from that standard to apply to the
E-cigarette unit.  IEC 62368-1 is organized around hazards so it is
straightforward to identify the hazards then chase the requirements in the
standard.   

 

   For your case you could use the present UL standard as a
starting point to identify issues and then seek an equivalent IEC
requirement; a further investigation would have to be done for any
additional requirements for completeness.  

 

   I know that something similar to this has been done for
looking at new things like electric scooters to start building a base for a
new standard.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain't what it used to be

 

From: Joe Randolph  
Sent: Thursday, December 10, 2020 11:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Will there be an IEC electrical safety standard for
E-cigarettes?

 

Hello All:

 

In 2018 here in the USA, UL published a Standard for Safety, UL-8139,
"Electrical Systems of Electronic Cigarettes and Vaping Devices."

 

I've looked at the IEC web site to see whether a similar international
standard has emerged, but so far I have not found one.

 

Does anyone know whether such a standard is in the developmental stages
within the IEC?

 

In the meantime, the closest existing IEC standard that might be used for
electrical safety of E-cigarettes appears to be IEC 60335 for "Household and
Similar Electrical Appliances - Safety."

 

 

Thanks,

 

Joe Randolph

Telecom Design Consultant

Randolph Telecom, Inc.

781-721-2848 (USA)

j...@randolph-telecom.com  

http://www.randolph-telecom.com

 

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[PSES] electric personal transport units regulatory requirements discussion

[Pete Perkins]

PSNetters,

 

   For an electric powered personal transport unit - think
hoverboard or electric scooter or electric assisted bicycle - what are the
requirements that would be applied for CE marking? What Directives then
supporting technical standards for these?  What other regional requirements
would apply?  

 

   If a remote controlled model car was scaled up how would this
change the requirements in these markets?  

 

   Thanks for your help in this.  

 

:>) 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

p.perk...@ieee.org  

 

Entropy ain't what it used to be

 


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Re: [PSES] Short Circuit Current Rating (SCCR)

[Pete Perkins]

Lauren & Brian,

 

Be careful with considering a test.  The source must have a SSCurrent equal to 
(or greater than) the largest SCCR component (sounds like the 200kA fuse from 
your description).  This level of available current is not found in your usual 
lab setup.  

 

I have seen disastrous test results when the entire system is properly tested 
even tho it was claimed to be sufficient because of an earlier test at a lower 
SSCR setup.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: lauren.cr...@us.tel.com  
Sent: Friday, October 30, 2020 9:36 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Short Circuit Current Rating (SCCR)

 

Hi Brian, 

 

UL 508A Supplement SB has a method for this. Also the www.semi.org 
  standard SEMI S22 has a method in one of it’s ‘Related 
Information’ sections. The SEMI standard RI section includes a reprint of an 
SCCR  guide from Bussmann. The link S22 provides no longer works (it looks like 
bussmann was acquired by Cooper was acquired by Eaton since then), but it looks 
like Eaton has some useful guidance in a big guide they have for electrical 
protection in general (probably with a generous dose of Eaton products) at 
http://www.cooperindustries.com/content/dam/public/bussmann/Electrical/Resources/technical-literature/bus-ele-an-3002-spd.pdf

 

Best Regards, 

-Lauren

 

From: Brian Kunde mailto:bkundew...@gmail.com> > 
Sent: Friday, October 30, 2020 8:55 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Short Circuit Current Rating (SCCR)

 

Greetings to all. I hope this finds you well.

 

Once again the subject of SCCR has come up.  I have struggled for years to find 
a document or someone who can explain this to me.  The bottom line is I need to 
know how I would determine the SCCR for my product.  In one case in particular 
I am currently working on, it is a 3 phase motor-driven industrial device. It 
draws less than 8 amps at 230V. Internal to the device, we have three "CC" type 
fuses with a SCCR of 200KA.  However, ahead of that we have a lockout/tagout 
disconnect device that is only rated 10KA SCCR.  

 

How exactly can I determine the SCCR of my device?

 

Thank you all.  

 

The Other Brian

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Re: [PSES] removable access panels with warning decals

[Pete Perkins]

Mike,

 

   I don’t quite agree with your assessment.  

 

>From my ongoing machinery training package: 

 

   Guarding, nature and frequency

 

• Combination of different guards 

• According to location and number 

• According to nature & frequency of access 

– Fixed or interlocked for moving transmission parts 

– Fixed where access is not required during use 

– Movable with interlocking when access required for setting or maintenance 

– Moveable with interlock, or with guard locking or control guard where access 
is required during working cycle 

– Self-closing or adjustable where access cannot be totally prohibited

 

Primarily based upon: EN 953: Requirements for fixed and moveable guards plus 
associated Euro standards.  

 

   Notice it describes moveable guards, not removable guards, 
however ...  

 

   From a risk point of view, whether or not a belt guard can be 
completely removable is based upon the overall hazard rating from the analysis. 
 

 

   I prefer guards which can be hinged and swung out of the way for 
maintenance especially when they are open up and easily close down after the 
work is done.  

 

   The markings, of course, are supplementary to the primary 
protection of the guard.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: MIKE SHERMAN  
Sent: Monday, October 26, 2020 4:40 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] removable access panels with warning decals

 

Chet -- 

For completely removeable belt guards, I have sometimes put warning labels on 
both the outside of the guard and on the permanent part of the machine 
underneath the guard---as a reminder to replace it. However, no safety standard 
reference immediately comes to mind. 

Mike Sherman 

Graco Inc. 

On 10/26/2020 3:50 PM Chester Summers mailto:csummers@charlesmachine.works> > wrote: 

 

 

Greetings, all—

 

Is there a general machinery requirement that a service access panel on a mains 
powered equipment somehow be permanently attached to the machine (e.g. hinged) 
if the panel itself has warning decals affixed to it?

I looked back in the PSES archive for a safety standard reference and came up 
empty.  I’m searching for standards-based guidance on permanence of the access 
panel itself, if it happens to be completely removable and is therefore at some 
risk of being misplaced.

 

Thank you and best regards,

Chet Summers 

 

 

This email and any files transmitted with it from Charles Machine Works are 
confidential and intended solely for the use of the individual or entity to 
which they are addressed. - 
 

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This message is from 

Re: [PSES] AW: [PSES] Low Voltage Products and EN 62368-1 and -3

[Pete Perkins]

Scott et al.  

 

   I agree that the use of a certified power supply is not adequate 
to show that the operating product is safe in its application.  

 

   62368-3 is mentioned in your original post.  

 

   IEC 62368-3 Safety aspects for DC power  transfer through 
communication cables and ports; it is a Horizontal standard within the IEC.  

 

The scope of 62368-3 is: This part of IEC 62368 applies to equipment intended 
to supply and receive operating power through communication cables or ports. It 
covers particular requirements for circuits that are designed to transfer DC 
power from a power sourcing equipment (PSE) to a powered device (PD).  

 

   62368-3 uses 62368-1 as the basis for determining compliance so 
both would be invoked for evaluating your ITE units.  

 

   62368-3 was developed by TC108 at the request of ACOS to provide 
uniform common safety requirements for these interfaces which could be broadly 
applied across many product applications.  It is intended to be applied to any 
USB or PoE powered product.  It should be adapted by other product standards 
committees to their construction since it is an IEC Horizontal standard.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: Dürrer Bernd  
Sent: Wednesday, September 30, 2020 12:35 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] AW: [PSES] Low Voltage Products and EN 62368-1 and -3

 

Hi Scott,

 

please note that Annex III of the EU LVD requires a risk analysis as part of 
the technical documentation 
(https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32014L0035 

 =EN#d1e32-370-1). So you may either create your own exhaustive risk 
analysis for your products, or claim compliance with the applicable product 
safety standard EN 62368-1, to demonstrate that your complete product does not 
present a risk and complies with the safety objectives of the LVD. If your 
products include a wireless interface or other radio function, it is in the 
scope of the RED which does not have a minimum voltage limit in Article 3, 1(a) 
(https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32014L0053 

 =EN#d1e975-62-1). Therefore, for equipment powered by extra-low voltage 
the RED requires compliance with the safety objectives of the LVD and the 
applicable product safety standards.

 

Kind regards,

 

Bernd

 

Von: Scott Douglas  
Gesendet: Dienstag, 29. September 2020 22:52
An: EMC-PSTC@LISTSERV.IEEE.ORG
Betreff: [PSES] Low Voltage Products and EN 62368-1 and -3

 

Esteemed colleagues,

 

Question on EN 62368-1 and -3 related to low voltage products.

 

Products are ITE equipment with power requirement of 5v or 12v DC and less than 
4 amps, sometimes they are powered by PoE. We ship some of these products with 
an external power supply 120/230 V~ input and 5 or 12 VDC output. The EPS 
always have full certifications to normal safety standards including 62368-1. 
Other times we do not include an EPS with the product.

 

One of our factories is trying to tell us that under IEC/EN 62368-1 or -3, our 
products are required to have safety certifications, that having just the EPS 
certified to 62368-1 is not enough.

 

We have always said that since these are low voltage products (even the PoE 
ones) that safety certifications are not required for the products themselves.

 

Has something changed where these type products are now required to have safety 
approvals for the EU or US/Canada markets? Or since they are not directly 
connected to the AC Mains, they do not need safety approvals?

 

Looking for someone to either confirm my sanity or teach me a new lesson. All 
comments welcome.

 

Scott

 

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Re: [PSES] [EXTERNAL] Re: [PSES] electric shock from capacitor discharge

[Pete Perkins]

Rich et al,It’s been a while but, as I remember, servicing laser 
products used on industrial equipment required consideration of the stored cap 
charge that could be accessible to the technician.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: MIKE SHERMAN  
Sent: Wednesday, September 30, 2020 8:42 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] electric shock from capacitor 
discharge

 

I've seen some motor caps on industrial induction motors whose capacitance gave 
me pause. I think we specified a minimum bleed down time to allow before 
servicing. 

Mike Sherman 

Graco Inc. 

On 09/29/2020 10:21 PM Ted Eckert 
<07cf6ebeab9d-dmarc-requ...@listserv.ieee.org 
 > wrote: 

 

 

Hi Rich,

 

I can’t think of many cases of modern IT equipment with a significant risk of 
capacitance discharge through the plug. However, I could foresee motor-driven 
equipment where it could be an issue. The manufacturer might put a power factor 
correction capacitor across the line to compensate for the inductive load of 
the motor. The motor should bleed off the charge of the capacitor, but there 
may still be some residual charge when the user pulls the plug. You probably 
wouldn’t have that large of a capacitor on a plug-connected motor appliance, 
but it is possible.

 

It’s been more than a decade since I worked with large motor-drive appliances, 
so my memory of their workings isn’t great. I’m sure there is somebody on this 
list server who can correct any error I’ve made in my statements.

 

Ted Eckert

The opinions expressed are my own and do not necessarily reflect those of my 
employer.

 

 

From: MIKE SHERMAN mailto:msherma...@comcast.net> > 
Sent: Tuesday, September 29, 2020 5:58 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [EXTERNAL] Re: [PSES] electric shock from capacitor discharge

 

Rich -- 

 

Are you including old CRTs as capacitors? I recall that, even with the early 
Macs, you had to be careful to discharge the tube if you were going to mess 
around inside. 

 

Mike 

On 09/29/2020 4:27 PM Richard Nute mailto:ri...@ieee.org> > 
wrote:

 

 

 

I am interested in knowing what constructions, situations, and products where a 
capacitive discharge into a body could take place.

I am aware of the X and Y capacitors discharge at the prongs of a power plug.  
I don’t immediately know of other situations or products that might discharge a 
capacitor into a body.  

I would appreciate descriptions of such discharges into a body, not conjecture. 
 Preferably, normal conditions and some single-fault conditions. 

Do we need to include capacitive discharge requirements in the safety standards?

Stay safe!

Rich


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Re: [PSES] High voltage versus High tension

[Pete Perkins]

Ken et al,

 

   Remember that the standard EE definitions are: Low Voltage
(up to 600Vac), Medium Voltage (e.g. neighborhood distribution - 10s of kVs)
and High Voltage (transmission voltages maybe 100 kV and up).  

 

   What we work with in electronics is, for the most part ELV
(Extra Low Voltage) which has multiple definitions but all selected to be
'safe' in some way; the most common definition is 30Vac/42.4Vpeak (with
higher limits for DC).  Further sub definitions also exist; IEC 60950
promulgated SELV (Safety ELV) with specific requirements and has been used
by the computer and electronics folks for 40 years.  

 

   So, were the folks promoting this usage really considering
High transmission voltages?  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain't what it used to be

 

From: Ken Javor  
Sent: Monday, August 3, 2020 5:47 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] High voltage versus High tension

 

Not at all helpful, but I have always wondered why, if we speak of high
voltage, we don't also speak of high amperage and high ohmage?

Ken Javor
Phone: (256) 650-5261



  _  

From: Regan Arndt 
Reply-To: Regan Arndt 
Date: Mon, 3 Aug 2020 16:35:01 -0700
To: 
Subject: [PSES] High voltage versus High tension

Hi folks,
I never encountered this before but am curious if anyone had any problems in
using the European verbiage 'High Tension' in lieu of 'High voltage' during
their 61010 assessment on their labels and documentation. 
Unless I am mistaken on the Group & National differences, IEC 61010-1 does
not mention anything specific on allowing this alternative language. 
I also want to know if 'High tension' would be a problem in the USA and
Canada during a Field evaluation or NRTL certification? (I only ask to avoid
having 2 labels/wording on a global product)
Thanks for sharing any experiences you had.

Regan Arndt
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Re: [PSES] Risk Assessment question

[Pete Perkins]

Doug et al,

 

   Risk assessment methodology exploded in the (60s and 70s) early 
days of the aerospace program as there were a myriad of new problems coming out 
of this bleeding edge technology being implemented.  

 

   Willie Hammer’s classic training manual covered all of the 
methodologies; he gave a presentation to our professional staff in the 1980s.  
It all seemed to be more invasive than we were wanting to go in those days; we 
depended upon the standards developers to assess the risks and provide adequate 
provisions in the safety standards to cover them.  

 

   Working with machinery later opened the doors to diving deeper 
into the hazards and risks associated.  Risk assessment became a routine 
process and a well oiled process was introduced to get design teams to quickly 
evaluate them and rank them; I have my own procedure and worksheets for this.  
Yes, there are options as to the details of the methods used; these are being 
refined and consolidated with time.  

 

   More recently I worked with a clever engineer on a project for 
which he developed a comprehensive spreadsheet which collected the risk 
assessment inputs and quickly developed any of a number of ‘standardized risk 
reports’.  It is proprietary today; perhaps is will be publicly discussed 
and/or made available in the future.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: Ruth Shapira  
Sent: Wednesday, June 17, 2020 1:48 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Risk Assessment question

 

Hi Douglas,

A list of Risk Management and Functional Safety Standards you can find in 
pag.124 of the book “Electrical Product Compliance and Safety Engineering” 
published at Artech House in 2017.

Also an analysis of RM  and Methods for Failure Analysis is presented on the 
same book in Chapters 6 and 5.

I hope that above info can help you.

 

Best Regards and be safe,

Steli

 

 

 

Steli Loznen, M.Sc., SM-IEEE

VP for Technical Activities and Member of BoG IEEE-PSES

Convener IEC 62A/MT29+MT 62354

17-3 Shaul HaMelech Blvd.

Tel Aviv 6436719

Israel

Tel:+972-3-6912668

Fax:+972-3-6913988

Mobile:+972-54-4818816

e-mail: sloz...@ieee.org  

 

From: Douglas Powell mailto:doug...@gmail.com> > 
Sent: Wednesday, June 17, 2020 1:49 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Risk Assessment question

 

All,

 

Over the past several years, nearly all safety standards have incorporated Risk 
Assessment (RA) as a part of their requirements. I did an informal search and 
found that the assessment methods are used in a wide range of disciplines from 
electrical products to machinery, robotics, safety software controls, medical 
equipment, medical procedures, automotive, aerospace, traffic control and even 
tree removal in municipalities. It is very clear that safety professionals 
worldwide really do like this method and I think it lends a certain comfort to 
a safety engineer's angst in marginal situations. I probably shouldn't say it 
but in my personal opinion this is a huge CYA exercise (cover your anatomy) for 
all involved.

 

Usually the product RA goes before construction review, testing and 
certification. It is often used to identify areas not covered well by the body 
of the standard and where additional testing may be required. Virtually all 
standards describing the use of RA mention the scheme found in FMEA/FMECA of 
identifying a tasks, operations, or events and assigning numerical values to 
the parameters of interest, followed by the product of these values to identify 
level of risk. Commonly these parameters are severity, frequency of exposure, 
and possibility of avoidance. Today the use of FMEA goes far beyond design, 
manufacturing, and processes.

 

Often times, a particular standard will say something like "documents that can 
be used as guidance for the safety analysis include..." followed by a short 
list of standards from IEC, EN, ISO, ANSI, MIL STD and so on. Notable to me is 
the use of the word "can" or "may" which implies the user has some leeway in 
selecting which document they prefer. Additionally, further guidance is often 
given for "active" protection devices and software/firmware controls for safety 
function (i.e. safety integrity levels and performance levels). Once again, 
using the methodology of FMEA as a way of assigning risk levels.

 

So after all that, here is my question. Given wide-ranging product types and 
use models, the long list of risk assessment standards, has anyone produced a 
comprehensive list or matrix correlating products to applicable standards? I 
believe a list such 

Re: [PSES] [EXTERNAL] [PSES] Electrical safety testing US and Canada ... Mandatory ?

[Pete Perkins]

Amund,Ted does a nice job of summarizing the US situation
with regard to the legality of the NRTL certification for products installed
during construction, including remodeling, which is inspected in the US.  

   

There is also the issue for retail products here in the US as most large
retailers have contractual clauses in their POs which require a NRTL listing
on any electrical product which they will sell for you.  This will cover the
coffee pot purchased to use at work as discussed.  

 

So, you see that legally required means several things; it is required by
the US NEC which is invoked for the workplace by OSHA and for all
installations including industrial, commercial and residential construction
by AHJ inspection plus contractually thru the distribution chain.  

 

Finally, I'll repeat my own experience when I worked for a large electronics
company.  During the period in which talk TV shows exploded we received a
frantic call from our local field rep.  Because this studio construction was
on a fast track they ordered all the equipment which was to be installed to
be delivered before the final AHJ electrical inspection of the building.
Upon that inspection the AHJ inspector saw the boxes on the floor he went to
inspect them for their NRTL mark.  Almost none of the commercial equipment
was NRTL marked and the AHJ inspector 'red tagged' all of it - meaning that
it could not be installed until it was acceptably certified.  

Our solution was to send an experienced Safety Engineer onsite and taking
the products, one type at a time, for a NRTL review, getting all of them
updated at our local repair facility per the deficiencies and then having
the NRTL lab provide a 'Field Label' on each individual updated product.
The entire exercise took a couple of weeks (& more U$ bucks than marketing
had expected to spend) but the equipment was then acceptable to be installed
in the studio.  Our products did not delay the installation schedule.  To
avoid that dilemma again, the VP for that equipment group reluctantly agreed
to get NRTL Listing on all of their products moving ahead, a win for the
overall safety program at the company.  

 

Hopefully, for your equipment there will be harmonized technical safety
requirements between the US NRTL requirements and the Euro CE requirements
which can simplify your work by getting a CB Report which includes showing
compliance with all the Country deviations.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain't what it used to be

 

From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@listserv.ieee.org> 
Sent: Monday, May 25, 2020 7:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] [PSES] Electrical safety testing US and
Canada ... Mandatory ?

 

Hello Amund,

 

This is an oversimplification, but here is how I understand the laws and
regulations of the United States. I'll leave the discussion of Canadian
regulations to somebody who better knows those rules.

 

The Occupational Safety & Health Administration (OSHA) is a division of the
U.S. Department of Labor. OSHA has legal authority over the workplace. OSHA
runs the Nationally Recognized Testing Laboratory (NRTL
 ) program, and it requires NRTL
approval for a limited set of products
 .

 

The NRTL program covers a much wider set of standard to support the broader
requirements in the NFPA 70, the National Electrical Code (NEC). Generally,
the NEC says that products must either be Listed or be approved by the local
Authority Having Jurisdiction (AHJ). In general, that means that you either
get your product listed or it's up to the local inspector to determine if
he/she will accept the unlisted equipment.

 

The AHJ will generally check the Listing status during construction
inspections. This typically means that products that are hard-wired or
attached to building structure will get checked, but plug-in equipment might
not be checked. It's unlikely that any AHJ will check the coffee pot that
somebody brings into the employee break room. Legally, they can, but it
probably won't happen.

 

The applicability of the NEC depends on whether the local jurisdiction has
adopted it or something similar. Most jurisdictions in the United States
have either adopted a version of the NEC or have some other regulation with
a similar statement on Listing. These codes will apply to all installations,
commercial and residential.

 

There are a number of de-facto Listing requirements. For example, insurance
companies may have clauses in their policies that require Listed products be
used.

 

Regards,

Ted Eckert

The opinions expressed do not necessarily reflect those 

Re: [PSES] 61010 vs 60601

[Pete Perkins]

Steve,

 

   Everything is negotiable but it sounds like a good approach.   
61010-1 is designed for commercial electronic equipment and is adequate for 
non-patient connected equipment in most respects.  Do you need a single 
certification (only CE or US or?) or will multiple certifications (e.g. CE and 
US) be needed?  Multiple certs complicates the picture slightly as more 
standards docs need to be compared but should still work ok.  

 

   To determine how much of the present safety certification can be 
carried to the new certification, a discussion should be had with the 
certifying lab folks; you’ll probably have to work with them to get the 
knowledgeable technical folks from each group in the same room go thru the 
present report together and agree on what can be used and what is plowing new 
ground.  (The 2nd project like this will be easier for all concerned; the work 
is quite siloed in the test labs.)  

 

   For EMC there are probably a couple of options to explore.  The 
key issue revolves around the fact that medical equipment requires very low 
touch current levels compared to commercial equipment so the EMC filters don’t 
divert as much current to ground which may leave a messier conducted emissions 
level feeding back into the line; what does the commercial market expect in 
this regard.  As I remember, the 61010 group has written a special EMC standard 
for their medical applications as the medical facility doesn’t want to have 
non-medical equipment interfere with the medical equipment when operated in the 
same environment.  Again, you can tear and compare the requirements with the 
EMC lab folks and decide what additional testing is needed to cover your bases. 
 

 

   Sounds like and interesting project.  Good luck.  

   

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: sgbrody  
Sent: Thursday, May 21, 2020 12:16 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 61010 vs 60601

 

Fellow gurus,

 

I have a client who has a product certified to 60601-1 and now they have a 
non-medical application and are looking for 61010-1.

 

Can the medical cert and report be leveraged towards 61010-1 or a new report be 
started from scratch?

 

Same for EMC.

 

Thanks,

 

 

 

 

Sent from my Verizon, Samsung Galaxy smartphone

 

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Re: [PSES] EMC testing for IVD equipment

[Pete Perkins]

Joshua,Looks like they are using pressure tactics instead of
rulemaking.  

 

   Unless the pandemic pulls everything back so far that
survival will be the name of the game everywhere for some years you have
some work to do.  

 

   Your company needs to pushback.  Indirectly thru your 61010
EMC group and directly, if you have been pushed on this by the FDA or lab
claiming FDA, to get this stopped until there is a direct 'order'.  Ideally
the FDA should come to the 61010 EMC group and negotiate a change in the EMC
standard which will require the same requirements for some specific
equipment and/or tests which are acceptable - ala 60601 EMC requirements.
It is important to get the requirements in the 61010 EMC family rather than
have you working with 60601 EMC requirements; this will put pressure on the
gov't to justify their requirements technically allowing you to limit the
scope and detail of the additional requirements. 

 

   Further, if this is also an Euro CE marking issue (from Euro
medical requirements) then get all the parties into the same room to
renegotiate the EMC requirements in a way that is satisfactory to all
parties (probably will take more time).  

 

   It is important to use your industry group to bring max
pressure on doing this in an open and mutually agreeable way - modifying
your standard.  

 

   This is not an easy path; there will also be a threat of
Federal rulemaking to move it in the direction they desire.  

 

   Get your association legal folks involved early too; they
will advise on strategies to move ahead plus help pushing back on gov't
pressure.  

 

   Looks like your spare time for the next 5 years is soaked up
to get this done.  

 

   Good luck.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain't what it used to be

 

From: Wiseman, Joshua  
Sent: Monday, May 4, 2020 12:17 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC testing for IVD equipment

 

FDA has allowed IEC 61326-2-6 for a long time. Word on the street is they
are requiring IEC 60601-1-2 now but there has not been an official
announcement. We heard about it through a trade group.

 

Story is some manufacturers are being told during their 510(k) reviews and
have required rework very late in the game to meet the more stringent
requirements. Usually, by this time they are about to launch or maybe
already launched in some countries depending on the product and regulations.

 

Josh

 

Joshua Wiseman 

Systems Engineering

Staff Engineer, Product Safety/EMC

Ortho Clinical Diagnostics

 



 

From: rwell...@wellman.com 
mailto:rwell...@wellman.com> > 
Sent: Monday, May 4, 2020 2:56 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] EMC testing for IVD equipment

 

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

 

I've been out of doing EMC Compliance for Laboratory Equipment for some
years, but is this a general protocol statement in the IEC standard or an
FDA requirement? I would hope there is an FDA Guidance Document that
clarifies this?

 

Best regards,

Ron Wellman

 

From: Ruth Shapira mailto:rshap...@tauex.tau.ac.il> > 
Sent: Monday, May 4, 2020 10:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] EMC testing for IVD equipment

 

Hi Josh,

If the IVD equipment is used in a medical environment (hospital, clinic,
etc.) the applied standard is IEC 60601-1-2 ed.4 (in which are specified the
environments for use a medical electrical equipment). If the IVD equipment
is located in a laboratory area out of medical env, the IEC 62368-2-6 (IVD
Lab Equip) standard apply.

I hope that the above help.

Best Regards and lot of health,

Steli

 

 

 

 

 

Steli Loznen, M.Sc., SM-IEEE

VP for Technical Activities and Member of BoG IEEE-PSES

Convener IEC 62A/MT29+MT 62354

17-3 Shaul HaMelech Blvd.

Tel Aviv 6436719

Israel

Tel:+972-3-6912668

Fax:+972-3-6913988

Mobile:+972-54-4818816

e-mail: sloz...@ieee.org  

 

From: Wiseman, Joshua mailto:joshua.wise...@orthoclinicaldiagnostics.com> > 
Sent: Monday, May 4, 2020 6:05 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] EMC testing for IVD equipment

 

Recently there has been reports of the FDA requiring in vitro diagnostic
equipment to be tested according to IEC 60601-1-2 (Medical Equip) instead of
IEC 62368-2-6 (IVD Lab Equip).

 

Does anyone have any information about this?

 

Thanks,

Josh

 

Joshua Wiseman

Systems Engineering

Staff Engineer, Product Safety/EMC

Ortho Clinical 

Re: [PSES] Procedure to move heavy 19" rack test equipment into EMI Chambers

[Pete Perkins]

Richard,   Haven’t seen much response on this.  

 

   A couple of points from me tho.  

 

   IEC 60950 has had stability requirements for racks for years 
which is intended to include moving the rack.  They include a 10 deg tip test 
requirement which dictates how the rack is loaded – heavier equipment in the 
botton; is your ramp long enough to stay below 10 deg?  

 

   So when you push the rack up the incline why don’t you turn it 
around so that the steerable wheels are in the back to steer the unit to keep 
it on the ramp?  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: Richard Jones  
Sent: Thursday, March 12, 2020 2:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Procedure to move heavy 19" rack test equipment into EMI 
Chambers

 

Hi

 

For those running EMI Labs was wondering what procedures you use to move Test 
Racks in and out of EMI Chambers,

We use custom made ramps, which we put over the door threshold, aligning the 
front wheels on the ramp, then pushing the unit up and over into the chamber.

 

Items which seem important:

1.  Wheel Size and base dimension
2.  Swivel wheels not aligned with ramp ( Most Test racks have swivel 
wheels fitted at the front)
3.  Communication between team members to move the rack
4.  Custom Alloy ramp made from  1/4" checker plate causing a lip where it 
touch's the floor
5.  Equipment with handles in rack placed near the top, (operator may try 
to use to move test rack)
6.  Poor center of gravity (equipment position for ergonomics)

Some of our 19" test racks are quite heavy, lightning generators at 400lbs and 
other test racks such as amplifiers up to 650lbs

These are commercial units and I believe met safety requirements when purchased.

 

My questions are:

 

What procedures/solutions do you have to move equipment and avoid a tipping 
situation?

 

>From a standard point of view Is there any direction on Wheel Size, Wheel 
>base, height weight and Ramp Inclination and run off which I could use to 
>support possible improvements?

 

Thanks

 

Rich

 

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Re: [PSES] Reduced CE mark

[Pete Perkins]

Charlie,Under the circumstances you enumerated, would you then 
recommend to the manufacturer that they put the 

‘reduced’ CE mark on the RED product and also put the larger 5mm CE mark on the 
packaging?  This would seem to meet all of the requirements.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: Charlie Blackham  
Sent: Tuesday, March 10, 2020 1:41 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Reduced CE mark

 

Dave

 

The following is stated in the RED

 

Article 19 General principles of the CE marking 

1.The CE marking shall be subject to the general principles set out in Article 
30 of Regulation (EC) No 765/2008. 22.5.2014 L 153/80 Official Journal of the 
European Union EN 

2.On account of the nature of radio equipment, the height of the CE marking 
affixed to radio equipment may be lower than 5 mm, provided that it remains 
visible and legible.

 

The issue is the interpretation of “on account of the nature of”.

 

However, other Directives may also apply as noted in the RED Guide

 

If the radio equipment is subject to other pieces of EU legislation which do 
not allow the CE marking to be smaller than 5 mm, then the possibility of using 
a smaller CE mark cannot be used by the manufacturer (e.g. RoHS).

 

You are of course allowed to put the CE mark on the packaging where it is not 
possible to put it on the product (Clause 4.5.1.4 of The Blue Guide)

 

If you don’t put a 5mm CE on your product then you may find yourself having to 
justify your position to a market enforcement authority doing a “desk top” audit

 

Regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web: https://sulisconsultants.com/ 

Registered in England and Wales, number 05466247

 

From: Dave Wilson <0271c3568f8a-dmarc-requ...@ieee.org 
 > 
Sent: 10 March 2020 02:53
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Reduced CE mark

 

Hi listmembers,

 

I came across a statement on conformance.co.uk regarding CE marking and size 
requirements. Although the date shows 2020, it references the R Directive, 
so I'm not sure about that.

 

Anyway, it states that for small products it's permissible to reduce the CE 
mark to 3mm, and that this is based on earlier legislation covering marking 
text on products of less than 150mm.

 

Does anyone know what the earlier legislation was? In the past, I've found some 
surveillance authorities to be sticklers for the 5mm minimum and wondered if 
anyone has been able to cite this earlier legislation in support of a size 
reduction.

 

Cheers,

 

Dave

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Re: [PSES] IEC 61010-1:2010 hazardous DC voltage

[Pete Perkins]

Regan et al,

 

   The basic electric shock info for the levels selected in the 
product standards come from IEC 60479 series, Effects of electric shock on the 
human body…  There are two sets of curves in IEC 60479-1 based upon the data 
collected and evaluated (from the literature).  One set of curves is for AC and 
the other is for DC.  These plot three body effects; startle-reaction, 
letgo-immobilization and Ventricular Fibrillation as a function of time.  The 
names for these effects primarily come from the effect of AC currents on the 
body.  The DC effects are not as well defined physiologically but are given the 
same names for consistency.  The product committees end up picking levels which 
seem appropriate for the application and the values are not fully consistent 
between product standards, in spite of the work of the IEC to make it so.  

   A major difficulty is that the body effects are from the current 
while the product committees would like to specify voltage, which is easier to 
measure and verify compliance.  

The IEC long ago issued a simple 1201 Voltage Limits standard, aka 61201, which 
was updated using a more complete evaluation and had a myriad of curves for the 
various conditions based upon the choice of contact parameters selected.  This 
is so much more complicated than just selecting a fixed voltage for most 
conditions and is not generally used in product standards.  

   So, in short, whether one picks 60Vdc or 70Vdc is not very 
relevant in the overall human body effect picture; nor is a change of 4Vdc 
around any of these values.  

   Finally, as Rich stated, the DC value is not related to the AC 
value by the sqrt 2.  This works well for moving from AC to equivalent DC 
voltage for hi-pot testing purposes but provides no path to the human body 
effect which is different, as has been discussed here.  

 

:>) 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

  p.perk...@ieee.org

 

From: Regan Arndt  
Sent: Tuesday, February 25, 2020 8:49 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] IEC 61010-1:2010 hazardous DC voltage

 

Hi Rich.

Thanks for your feedback.

 

Correction/clarification. I was not trying to ‘convert’ to DC using 1.414 (root 
2).

I merely used that ‘multiplication factor’ (1.414 & sometimes just 1.4) based 
on the widely used/misused?/abused? that is used in the industry when 
determining ‘equivalent’ DC values, just like one commonly does when 
calculating the hipot test values. 

 

See: 
https://electrical-engineering-portal.com/what-is-hipot-testing-dielectric-strength-test
 

 , where Jignesh Parmar quotes in his article: “Therefore, if we use dc test 
voltage, we ensure that the dc test voltage is under root 2 (or 1.414) times 
the ac test voltage, so the value of the dc voltage is equal to the ac voltage 
peaks.”

 

Another classic example comes from the 60950 standard for hipot values. 1500 
VAC/2121 DC (calculation factor = 1.414)

 

That being said, I look forward to hear a response from someone on TC66 on why 
they chose 70V. 

 

It would also be great if you could do a whitepaper (& speak) on the 
understanding of how the body reacts to AC & DC for this year’s PSES symposium 
in Chicago? 

 

Regan

 

On Tue, Feb 25, 2020 at 4:07 PM Richard Nute mailto:ri...@ieee.org> > wrote:

 

 

Hi Regan:

 

The “bump” occurred from 1st edition, 1990, to 2nd edition, 2001.  The 2nd, 
2001, and 3rd, 2010, are the same.

 

Be careful with your math and DC interpretation.  The rms voltage limit is 33.  
The ac peak is 1.414 x 33 = 46.7.  The DC is 70, which is unrelated to the AC 
voltages (which is because of how the body reacts to AC and DC).  

 

As to the rationale for the change from 1st to 2nd, I suggest you find a member 
of TC66 and ask for the documents preceding the 2nd.  

 

Touch voltages are specified in IEC TS 61201.  In this standard both 30 and 33 
volts rms are listed, with very little difference in body reaction.  Same for 
60 versus 70 volts DC.  

 

Best regards,

Rich

 

 

 

From: Regan Arndt mailto:reganar...@gmail.com> > 
Sent: Tuesday, February 25, 2020 2:38 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] IEC 61010-1:2010 hazardous DC voltage

 

Dear fellow members,

 

I am trying to understand the 'rationale/history' of why TC66 bumped up the DC 
voltage by a mere 4 volts for hazardous voltages.

As 

Re: [PSES] Setting up a LV lab safety training and requirements

[Pete Perkins]

Jesse,Good to hear from you.  I'll chase this a bit and get back to you.


 

:>) 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

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: Pete Perkins  
Sent: Tuesday, February 25, 2020 10:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Setting up a LV lab safety training and requirements

 

What's a good source for Lab safety requirements and training when setting
up a new Low voltage (up to 600V) lab for a new US company?  

 

:>) 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

p.perk...@ieee.org <mailto:p.perk...@ieee.org> 

 


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[PSES] Setting up a LV lab safety training and requirements

[Pete Perkins]

What's a good source for Lab safety requirements and training when setting
up a new Low voltage (up to 600V) lab for a new US company?  

 

:>) 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

p.perk...@ieee.org  

 


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Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[Pete Perkins]

The US product certification system seems confusing to those who have not grown 
up with it and used it.  It is divided, as has been discussed, between 
commercial/industrial (OHSA regulated) and retail/consumer (local AHJ 
controlled).  

OSHA has pretty clear requirements but enforcement is primarily done by 
investigating incidents.  

Consumer requirements are generally covered by the NEC (which requires NRTL 
listing) which is adopted in more than 10,000 jurisdictions in the US and 
enforced by AHJ inspectors.   This is also enforced at the retail level in that 
sellers won’t offer anything for sale which is not NRTL Listed as a contractual 
condition to the supplier.  AHJ facilities inspection is usually completed 
before most equipment is installed but anything installed earlier – including 
lighting, heating and air conditioning and other basic electrical appliances 
are fair game and can be ‘red tagged’ as not acceptable by the AHJ inspector.  

This has all been further confused by the enormous expansion of LV components 
used ubiquitously in both the work environment and the residential environment. 
 These LV devices used to be simple and could easily be evaluated during the 
inspection as being acceptable.  Today, however, the devices are much more 
complex and can give rise to hazards which are not obvious to a casual 
inspection (There have been numerous electric shock and/or fire issues 
developed from ‘walwarts’ which are always installed to operate connected 
equipment).  

Finally, in the American tradition the final enforcement is thru the legal 
system when there are incidents.  Any product involved which is not NRTL 
certified is condemned before the party starts.  

The manufacturer should beware and provide NRTL certification in more cases 
than not.  

 

:>) 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

  p.perk...@ieee.org

 

From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org> 
Sent: Wednesday, February 19, 2020 7:13 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

 

Hello Bernd,

 

The requirement from the National Electrical Code is either an NRTL Listing or 
approval by the local Authority Having Jurisdiction (AHJ). The latter option 
means that a local electrical inspector or building inspector will look at the 
equipment to determine whether they think it is safe and appropriate. In my 
opinion, this is a far more challenging option as opposed to getting an NRTL 
Listing. If the equipment does not meet the AHJ’s approval, it will get a “red 
tag” and will not be allowed to be operated until any corrections are made. 
Many customers will only accept NRTL Listed products.

 

Manufacturers of custom equipment will often seek “field certification”. For 
this option, the manufacturer hires an NRTL to come to the installation site to 
perform certification at that location. The NRTL can do field marking of the 
equipment if it meets approval. It then would meet the requirements of the NEC.

 

The NEC has no option for self-declaration. You either need an NRTL Listing or 
you need the approval of the AHJ. 

 

Ted Eckert

Microsoft Corporation

 

The opinions experessed are my own and do not necessarily reflect those of my 
employer.

 

 

From: Dürrer Bernd mailto:bernd.duer...@wilo.com> > 
Sent: Wednesday, February 19, 2020 7:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] AW: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

 

Hello Ted, hello Regan,

 

Thank you for your clear statements on NRTL certification. Can you please 
provide some guidance on the interpretation of the National Electrical Code 
NFPA 70 (2020 edition), article 110.3, on the suitability of installation and 
use in conformity with the NEC? Informational note no. 2 explains, that this 
suitability “may” be evidenced by listing or labelling. Informative Annex A 
“provides a list of product safety standards used for product listing where 
that listing is required by the NEC.” This lists includes many product safety 
standards for consumer products like appliances that are typically plug 
connected. In the case that the NEC has been adopted by local jurisdiction and 
that the equipment is in the scope of a product safety standard listed in Annex 
A, is NRTL certification and listing then a mandatory requirement, or is there 
another option (e.g. self-declaration of the manufacturer that the product is 
suitable for installation and use in conformity with the NEC) that is accepted 
both by jurisdiction and the market?

 

Thank you and kind regards,

 

Bernd

 

Von: Regan Arndt mailto:reganar...@gmail.com> > 
Gesendet: Dienstag, 18. Februar 2020 18:01
An: EMC-PSTC@LISTSERV.IEEE.ORG 

Re: [PSES] Cable question, or 'foiled' again

[Pete Perkins]

Steve, et al,

 

So, Steve, why wouldn’t your client support buying the standard since failing 
this certification test will cost them more in whatever Plan B is.  

 

   Isn’t it the same as at the Red Sox game; you can’t tell the 
players without a program (and, oh yes, get the Crackerjacks too).  

 

   I’m trying to conjure up a picture of this dielectric test 
without seeing either the test or the results.  

Dielectric testing wire to wire was successful (at what voltage?) – is the test 
voltage 250 Vac or does that just define the needed test voltage (maybe 
1500Vac).   

Did the not-foil-connected connector rise toward the test voltage during the 
test?  Did the foil itself rise toward the test voltage during testing?  

 

   Once connected, where was the dielectric failure?  Was it to the 
connector itself or to the foil bring the dielectric voltage to the connector?  

 

   There should not be a large enough current from the dielectric 
voltage tester to cause the foil connection to fail unless it is not robust 
(wot’s your take on robustness of the foil-to-connector interface)?  

 

Could this failure have been expected (as the UL engineer seemed to expect).  

 

   Maybe you won’t (or can’t) discuss all of this in this open 
forum but, perhaps, you can get more insight into the issue and get it 
resolved.  

 

   Good luck in working thru this.  

 

:>) 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

  p.perk...@ieee.org

 

From: Bill Owsley <00f5a03f18eb-dmarc-requ...@ieee.org> 
Sent: Tuesday, January 21, 2020 1:04 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Cable question, or 'foiled' again

 

I agree.  Have found the assembly violated creepage and clearance requirements, 
and other construction, setup issues.

 

On Tuesday, January 21, 2020, 01:49:46 PM EST, Richard Nute mailto:ri...@ieee.org> > wrote: 

 

 

 

Hi Steve:

 

I suspect that the test was set up incorrectly, especially since your client 
has successfully passed the test in the past, and since UL predicted failure.  
I would ask to replicate the test, and examine the test set-up.  

 

Good luck, and best regards,

Rich

 

Ps:  See you at ISPCE!

 

 

From: Steve Brody mailto:sgbr...@comcast.net> > 
Sent: Tuesday, January 21, 2020 7:47 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Cable question, or 'foiled' again

 

Experts, 

 

I have always been one to tell others that to understand a requirement you need 
to read the standard, directive, etc.  However in this case I am trying not to 
spend $505 for a PDF copy of UL 2238 which I may never use again.  

 

I have a client whose customer is requiring a specific cable be UL approved.  
The cable is used for control, not power, and is part of a larger system.  The 
requirement was for a UL 2238 approval, but no one has been able to tell me why 
not use an a less severe standard.  

 

The cable is similar to others that my client has submitted through their UL 
approved harness house but this one is failing dielectric testing from the 
conductors to the foil shield which is connected to the connector shell.  
Conductor to conductor testing was OK. Previous submitted and approved cables 
also have the foil shield connected to the connector shell, which would be 
normal for EMC. 

 

The cable itself is from a well known manufacturer and carries approvals and is 
rated at  >300V, and may even be 600V, but I don't have the cable spec at this 
time.  The connector(s) also carry UL. 

 

Here is the quote from UL via my client: 

The shield is foil.  UL has  failed the cable because we are connecting the 
shield to the connector shell . The [UL] engineer actually said that he knew it 
would fail the 250VAC test because of this fact, and he only ran the test to 
get a data point. He said that this violates a requirement of UL 2238, and if 
we cannot change the design then we will need to find a different standard to 
apply for. We’re all confused because we’ve submitted other cables for this 
project that passed UL 2238 with the shield connected to the connector shell. 

 

Thoughts, comments, but no sticks or stones, please. 

 

Thanks all, 

 

Steve Brody 

  sgbr...@comcast.net 

C - 603 617 9116 

  stev...@productehsconsulting.com 

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Re: [PSES] Class I vs Class II safety constructions

[Pete Perkins]

Scott et al,  You are correct in that there seems to be a split between 
electrical appliances and electronic equipment and that the latter is more 
Class II than the former, there is chatter about an issue that is growing among 
class II equipments.  All of the electronic equipment which has been the 
primary user of SMPS for decades typically uses EMI filters to mitigate the 
noise generated by the switching action which get fed back into the line.  
These are used on Class I equipment where the noise is capacitively coupled to 
earth/ground to be dissipated and keep much of this noise from feeding back 
into the mains/line; likewise these filters are also used on class II equipment 
for the same purpose – however the class II equipment does not have any 
earth/ground sink in which to drain the unwanted signals.  So, apparently, this 
electrical charge is fed to the equipment chassis and the chassis voltage 
builds up until it reaches some equilibrium value.  The EMI folks discover this 
when they find that the equipment discharges to the probe before they are ready 
to induce a charge into the equipment.The voltage developed on the 
equipment seems to be a hi value but limited charge (due to the limited 
capacitance of the chassis to absorb it).  

   Altho there are not yet specific numbers, this doesn’t seem to 
be a safety hazard at this point.  However, it is also unknown as to how this 
affects the filtering of the mains noise which was the desired result.  The EMC 
lab techs don’t like the equipment to zap them first rather than the other way 
around.  

   Does anyone on this thread know of a paper on this which would 
contain some specific results?  Or of some researchers who are chasing this?  
Or have personal experience with this.  It would sure be nice to get some 
feedback on this.  

   This is a great opportunity to expand our experience and provide 
a basic understanding as to the efficacy of this process in both equipment 
applications for both safety and EMC.   

 

:>) 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

  p.perk...@ieee.org

 

From: Richard Nute  
Sent: Tuesday, January 14, 2020 12:58 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Class I vs Class II safety constructions

 

 

Hi Josh:

 

Yes, you are correct.  Both of these standards specify the equipment be Class 
I.  

 

60335-2-38 applies to commercial-use griddles.  60335-2-75 applies to  
commercial food or drink dispensing equipment.

 

Thanks, and best regards,

Rich

  

 

From: Wiseman, Joshua mailto:joshua.wise...@orthoclinicaldiagnostics.com> > 
Sent: Tuesday, January 14, 2020 11:59 AM
To: ri...@ieee.org  ; EMC-PSTC@LISTSERV.IEEE.ORG 
 
Subject: RE: [PSES] Class I vs Class II safety constructions

 

It’s been a few years, but I seem to recall there was a particular IEC/EN 
60335-2-xx standard that required tubular sheathed heaters to be grounded.  
This would force PE to be brought in.

 

Additionally, IEC 60335-2-38 and IEC 60335-2-75 have requirements for 
Equipotential grounding.  If I remember correctly IEC 60335-2-75 does not allow 
Class II products.

 

Josh

 

Joshua Wiseman 

Systems Engineering

Staff Engineer, Product Safety/EMC

Ortho Clinical Diagnostics

 



 

From: Richard Nute mailto:ri...@ieee.org> > 
Sent: Tuesday, January 14, 2020 2:38 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] Class I vs Class II safety constructions

 

 

Hi Scott:

 

I have seen no safety standards or codes that specify which products must be 
Class I and which products must be Class II, except in the USA washers and 
dryers must be Class I.  As far as I know, the decision is that of the 
manufacturer.  I have been associated with a manufacturer who has made the same 
product both ways.  In my case, one of the factors in deciding Class I or Class 
II was cost (e.g., a 3-wire cord was more expensive than a 2-wire cord).  

 

I suspect a major factor is “momentum” of the manufacturer: we made it this way 
last time, and we know how to do it this way.  

 

A product with a grounding (3-wire) power cord is a Class I product regardless 
whether it has no accessible conductive parts.  Unlike a Class II product, a 
Class I product does not bear a marking attesting that it is Class I.  

 

Note that a Class I construction necessarily includes Class II construction, 
e.g., appliance inlet which is all-insulated.  We ignore the Class II 
construction portions of a Class I product.

 

I checked our electric kettle (which has accessible metal) and electric 
coffee-maker (which has the heater plate accessible metal).  Both are 2-wire.  
Neither has the double-insulated symbol.  Both are UL-certified.  

 

Re: [PSES] Touch temperature levels

[Pete Perkins]

Kris,   This seems to be a troubling point for a number of folks.  

 

   The temperature limits in 62368-1 are based upon the
available scientific data (which is what a Hazard Based standard is all
about).  This data is only available for measurements taken at 25C, a common
lab temperature.  The skin response is non-linear with temperature so it is
not appropriate to adjust the results based upon evaluation at another
ambient test temperature.  

 

   The proper evaluation is to test the product at 25C and
confirm that it meets the limit in the table for the expected contact time
and material.  

 

   IEC TC 108 agonized over this quite a bit and have repeatedly
had the same conversation downstream in their sessions; it seems to be a
hard concept to grasp.  Recognize that the IEC recognized this approach as
the proper one and issued Guide 117 based upon the same reasoning to be
applied to all touchable surfaces.

 

   Any measurements made at any other ambient temperature are
interesting but only should be used for any other considerations that might
be of interest to the investigator.  

 

:>) 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

  p.perk...@ieee.org

 

From: Carpentier Kristiaan  
Sent: Monday, January 13, 2020 3:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Touch temperature levels

 

Hi group,

 

IEC62368-1 Table 38 defines touch temperature limits. Are these values
absolute values nomatter which ambient?

It seems some safety laboratories consider these values relative to 25C,
thus allowing a recalculation to higher touch temperatures at higher Tma,
other labs consider as absolute values.

 

Examples: TS1 limit on plastic/rubber is 77C.

Labs that stick to absolute values have a limit of 77C at 25C and also at
Tma of 45C.

Labs that allow recalculation allow 97C for Tma of 45C, which is well in
line with the 95C value of IEC60950-1.

 

Any explanatory guidance documents available?

 

Regards,

Kris

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Re: [PSES] [EXTERNAL] [PSES] FCC regulatory statements

[Pete Perkins]

All, I concur with Rich Nute.  The LED light bulb in the bathroom 
shower interferes with the FM radio used in the adjoining bedroom.   The 
solution is to shower in the dark while listening to the radio.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: Sykes, Bob  
Sent: Friday, November 1, 2019 6:01 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] [PSES] FCC regulatory statements

 

The devil is in the details (FCC Rules Part 15.5).  Comments below in [square 
brackets] are mine.

 

1.  This device may not cause harmful interference….  [to licensed devices. 
 Licensed devices are protected by the FCC Rules.  The other less obvious 
meaning of this part of the label statement is that a Part 15 device operates 
at sufferance and compliance with the technical standards does not relieve the 
equipment owner from non-interference.  It doesn’t matter if your product is 
20dB below the FCC limit.  If it is interfering, it must cease.]

 

2.   This device must accept any interference received, including 
interference that may cause undesired operation”[Part 15 devices are 
offered no protection from interference (whether generated by licensed devices 
or not).  The FCC is only interested in protecting communications, not product 
quality.]

 

-Bob Sykes

 

 

 

From: Richard Nute [mailto:ri...@ieee.org] 
Sent: Thursday, October 31, 2019 4:24 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [EXTERNAL] [PSES] FCC regulatory statements

 

CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.

 

 

“This device complies with part 15 of the FCC Rules.  Operation is subject to 
the following two conditions:  (1) This device may not cause harmful 
interference, and  (2) this device must accept any interference received, 
including interference that may cause undesired operation”

 

Hmm.  So, if the device causes harmful interference, operation is prohibited 
(1).  

 

And, if the device accepts interference that causes undesired operation, 
operation is prohibited (2).

 

A CFL causes undesirable interference with my radio.  So, operation of both the 
CFL and radio is prohibited.  

 

Is my interpretation correct?

 

Best regards,

Rich

 

 

 

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Re: [PSES] Fuse in device is mandatory or not?

[Pete Perkins]

Amed,   As John mentions the standard addresses this in 2.7.1.  The wording in 
the statement ‘In the equipment or in the installation’ means. In my opinion, 
that the fusing is required in the equipment except as described in the next 
paragraph  for Type B or permanently wired equipment where the installation 
fusing protection may be relied upon.  This restriction is also clarified by 
the CENELEC note to the clause.   

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: John Woodgate  
Sent: Friday, November 1, 2019 6:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Fuse in device is mandatory or not?

 

You only need to look at 2.7.1 in the standard to see what needs to be done.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk  
Rayleigh, Essex UK

On 2019-11-01 11:39, Matthew Wilson | GBE wrote:

If you are considering a fuse you may need to consider using two on both ‘live’ 
and ‘neutral’ with a suitable warning.  This is due to ‘EU’ mains plug 
connectors being un-polarised.  So the mains plug can be inserted either way 
around, allowing the live and neutral to the appliance to be reversed. There is 
also AFAIK no set convention as to whether sockets have the live wired to the 
left or right hole in the wall socket.

 

Fusing in the appliance will limit the available power in the event of a fault 
or disconnect the power in the event of a class I device with ‘earth fault’ 
from the ‘live’ side.  Sounds fairly like ‘must’ to me regardless of what the 
standard says! :-)  Do a documented risk assessment of the product and draw 
your own conclusions...

 

 









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From: Amund Westin   
 
Sent: 25 October 2019 13:42
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Fuse in device is mandatory or not?

 

Consider a device connected by a plug to 230VAC by an EU plug (2 pin + ground).

Must sucha device (EN60950-1) have an internal fuse? Or can it rely on fuses 
which is a part of the house installation?

 

BR Amed

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Re: [PSES] Question on 61010-2-081 particular requirement

[Pete Perkins]

Gregory,  No one has tackled this yet so . 

 

My experience is that anytime the product standard was updated the NRTL
would call for a file review of all products certified under that standard.
All the manufacturers using that certification would be notified and given a
defined time period to open a review project to show compliance with the
updated requirements.  I would expect the addition or invocation of any -2
requirements to be included in this process; they are the same as revising
the -1 standard except they are written up in separate documents to keep the
main document from becoming hugemongous and hard to work thru to include or
exclude any specific (-2) requirement.  

I believe that the cutoff date is set by the change date from the earlier
requirements to the new requirements; that is now more complicated as the EU
also sets hard specific change dates for the acceptance of various changes
in the standards.  For a worldwide harmonized standard, such as 61010
series, this is more of a fixed date than in other jurisdictions and seems
to drive some of this work in an attempt to maintain the universality of the
certification. 

Perhaps OSHA will respond directly as to their view of all of this.

Concerning the additional work and the cost, this should not be a surprise
to any manufacturer who is actively participating in the standards process
either at the National level or the International level.  The ongoing
updating work should serve as a trigger for preparing the company for the
additional cost in keeping the certification current.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain't what it used to be

 

From: Popp, Gregory - Xylem  
Sent: Wednesday, October 9, 2019 1:03 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Question on 61010-2-081 particular requirement

 

Hello Esteemed List Members,

 

My company has a product that is 3rd party certified to UL 61010-1:2012 Ed.
3.  I have been advised that a particular requirement -2-081 now applies to
the product so it must be tested in order to maintain the authorization to
mark.  My questions are;

 

1.  Does OHSA require NRTLs to expand the scope of a product's
certification when a particular requirement is released that applies to that
product?
2.  If the answer to question 1 is yes, what time period must the
testing be completed within?
3.  What have others in the community done to budget for the unexpected
testing?

 

Thank you,

 

Gregory Popp

YSI Inc.

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Re: [PSES] Grounding of metal cabinet

[Pete Perkins]

Ted et al. Since we’re discussing scenarios, let’s look at another 
case (which I’ve seen in practice).  The issue becomes more difficult when the 
power inlet is mounted directly on (and, hopefully secured) then soldered to 
the circuit board and the manufacturer’s expectation is that screwing the 
circuit board down to the metal chassis provides the correct bonding for 
grounding.  The first thing that will most likely happen is that this fault 
current will melt out the solder connection to the ground pin from the inlet to 
the circuit board and open this circuit.   There may not be any accessible 
grounded parts (screws, connectors, etc.) on the unit but it is interconnected 
by cables (egg HDMI, POE, USB etc.) which carry the chassis ground between 
units.  This fault current diverts to the ground connection provided by the 
cable which is not designed to be robust enough to carry the full fault current 
which is needed to blow the circuit breaker for the circuit providing power to 
this unit which has developed a hazardous fault.  The protection, which seems 
to be in place, cannot be fully relied upon to function as needed and interrupt 
the current to the device and provide protection.  

 

:>) 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

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org> 
Sent: Tuesday, September 24, 2019 6:55 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Grounding of metal cabinet

 

The rationale I remember learning is that the main grounding/earthing 
connection must be made in a way such that any repairs would not need to 
disconnect that main grounding connection. Let me use Mr. Woodgate’s examples. 

 

If you have an insulating terminal block, replacing the terminal block could 
disrupt the grounding connection. If the repair person fails to connect the 
ground on the load side, the device will likely still function, but it will 
have lost its safety ground. If you connect incoming ground to the chassis 
first, and then to the terminal block, replacing the terminal block would not 
disrupt the grounding connection even if the wiring on the terminal block is 
connected incorrectly.

 

However, if you have a grounding terminal block, where the ground connection in 
the block is a direct metal connection to the chassis, replacing the terminal 
block would reconnect the incoming ground to the chassis. Of course the ground 
wring to the terminal block could be done incorrectly, but you have at least 
removed some of the risk of a missing grounding connection. When using 
appliance couplers, filtered couplers can serve multiple purposes. They can not 
only provide EMC filtering, they make a direct bond between incoming ground and 
the chassis. This would serve a similar safety purpose as a grounding terminal 
block.

 

Of course, for cord connected equipment, there is the repair of replacing the 
cord that requires disconnecting the ground wire. All we can do is to make the 
design fool-resistant. Nothing can be foolproof in this world of talented fools.

 

Best regards,

Ted Eckert

Microsoft Corporation

 

The opinions experessed are my own and do not necessarily reflect those of my 
employer.

 

From: Bill Owsley <00f5a03f18eb-dmarc-requ...@ieee.org 
<mailto:00f5a03f18eb-dmarc-requ...@ieee.org> > 
Sent: Monday, September 23, 2019 9:45 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] Grounding of metal cabinet

 

Our safety regulators have insisted that power cord safety ground/earth go 
first to the metal chassis, with rare exceptions.  Exception, the majority of 
chassis is plastic, with internal metal structures to tie it all together.
Only the screw heads are exposed and tied to some of the internal metal chassis.
A complex system of wires, washers, terminals, etc. were needed to ensure it 
was all one complex earth grounded structure.  

I AM NOT a safety engineer, but I do know a few !
- Bill





 

On Monday, September 23, 2019, 07:42:11 PM EDT, Pete Perkins 
<0061f3f32d0c-dmarc-requ...@ieee.org 
<mailto:0061f3f32d0c-dmarc-requ...@ieee.org> > wrote: 

 

 

   This is a great discussion.  It took some work to get most of 
the world to use a solid, direct earth/ground connection in cabinets and 
equipment.  CSA published detailed connection diagrams and pushed direct 
connection into many product standards with good results.  The struggle has 
been since the modularization of components and units has come into play.  This 
raises questions as to how to interconnect everything together in a way  that 
preserves the integrity of the earthing/grounding connection when it is a 
principle safeguar

Re: [PSES] Grounding of metal cabinet

[Pete Perkins]

   This is a great discussion.  It took some work to get most of
the world to use a solid, direct earth/ground connection in cabinets and
equipment.  CSA published detailed connection diagrams and pushed direct
connection into many product standards with good results.  The struggle has
been since the modularization of components and units has come into play.
This raises questions as to how to interconnect everything together in a way
that preserves the integrity of the earthing/grounding connection when it is
a principle safeguard against electric shock.  As an OF (= Old Fellow, in
polite company) I prefer that the earth/ground wire be tied to the
mechanical structure of the cabinet or equipment first then carried to the
distribution components.  It is very difficult to destroy the integrity of
this earthing first philosophy.  There are many scenarios where the quick
install/quick connect terminal block can be disconnected from the earthed
rail and leave the cabinet/equipment without the needed earthing/grounding
connection.  Let's keep the focus on providing the highest integrity
protection scheme in place (and common practice).  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain't what it used to be

 

From: John Woodgate  
Sent: Monday, September 23, 2019 4:19 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Grounding of metal cabinet

 

The question is how the cabinet is earthed if the PE wire goes to a terminal
block. If  a wire comes out of the terminal block to a stud on the cabinet,
that is less reliable than a solid connection.  I suggest you take the
advice. It doesn't apply if the 'terminal block' is  not an insulating block
with metal inserts but a metal block firmly attached to the cabinet.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk  
Rayleigh, Essex UK

On 2019-09-23 11:33, Amund Westin wrote:

A flexible 1-phase AC cable is entering a metal cabinet and the PE-wire is
directly connected to an Earth terminal block (green/yellow).

Some years ago, a safety engineer told me that the earth wire should first
be connected to a ground stud inside the cabinet via a lug terminal climp
and fastened with a nut. From the stud, a green/yellow wire should connect
to the Earth terminal block.

 

I thought it's OK to go directly to the Earth terminal block, right? .

 

BR
Amund Westin

 

 

 

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Re: [PSES] Do We Need Flame Retardants in Electronics?

[Pete Perkins]

Oh yes, I remember doing safety consulting with a company on a telecom product 
but they wanted to handle all of the telecom GR issues themselves.  One morning 
the technician hauled me into a small conference room and showed me a video of 
the burn test which was started by putting a burner into the product to start 
the fire.  This compact product burned from rail to rail in the 19” rack each 
board lighting off its neighbor till all that was left was fiberglass with any 
remaining components which had not fallen out flaming to the ground; the V-1 
boards couldn’t hold back the spread of fire.  He was appalled, they didn’t 
know what to do about it.  I led him thru the sequence just watching the fire 
move along.  He took me to the ME manager who was incensed that the tech had 
shown me the video.  It took a couple of weeks but then I was called in to go 
over the fire with the product development team.  I arranged to project the 
video on the wall in front of the team so large that they could see the details 
vividly and talked them thru the two views taken of the fire -15 minutes each.  
When they understood the details they attacked the problem and finally found a 
solution that they could live with.  The solution involved reducing the 
ventilation holes in the top and bottom such that the fire choked because of 
lack of Oxygen and didn’t spread so quickly.  It took a long time to fix it and 
the ME manager was reassigned during the process.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: N. Shani  
Sent: Tuesday, September 17, 2019 10:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Do We Need Flame Retardants in Electronics?

 

Just a small addendum: while indeed GR-1089 has all kind of immunity 
requirements, it is GR-63 that has the non-electrical requirements, one of 
which is the flame spread testing.

 

Having witnessed a few of those passing or failing tests, the various RBOCs had 
their own spin on those requirements. Recall Verizon? SBC? Each with their own 
emphasis.

 

Naftali Shani, Ottawa, ON

Happily retired


On Sep 17, 2019, at 12:47, Cortland Richmond mailto:k...@earthlink.net> > wrote:

When I went to work at DSC/Alcatel USA in 1997, we had to meet GR-1089. 
Telcordia had/has a lot of immunity and ruggedness requirements.  Yes, we did 
flammability tests.I've been in the Hinsdale Central Office too (I was 
looking at an EMI complaint at one of their subscribers)  ad got the "real 
story" from some folks who'd been there when they had their famous fire. Don't 
open a door to get hoses in until  it's cooled down enough that oxygen doesn't 
turn the whole bay into an inferno...

https://www.ideals.illinois.edu/bitstream/handle/2142/95/Illinois%20Bell%20Telephone%20Fire,%201988.pdf?sequence=2

Cortland Richmond
Ret. but "on-call" at Belcan

On 9/16/2019 19:00 PM, Richard Nute wrote:

 

Well, the obvious way to determine whether flame-retardants have reduced the 
incidence of death or injury is to stop using flame-retardants and compare 
before and after.  The problem, of course, is if we are wrong…

 

This is one argument that is often used to retain ALL requirements in safety 
standards.  However, in many cases scientific or engineering analysis can show 
(or not show) that a requirement contributes to the product’s safety. 

 

I’m not aware of illness or injury due to any flame-retardant in normal 
operation of products, although there is plenty of evidence of illness and 
injury from the chemicals themselves and disposal of the products. 

 

Rich

 

 

On Mon, Sep 16, 2019 at 2:32 PM Richard Nute mailto:ri...@bendbroadband.com> > wrote:

 

https://www.scientificamerican.com/article/do-we-need-flame-retardants-in-electronics/

 “…there has never been any valid statistical demonstration that flame 
retardant chemicals of the types and concentrations used in consumer products 
have resulted in death or injury reduction,” says  

 Vytenis Babrauskas…

The article is more than 5 years old.  Nevertheless, thought-provoking. 

Enjoy!

Rich

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Re: [PSES] Do We Need Flame Retardants in Electronics?

[Pete Perkins]

Rich, et al,   Like many issues we see raging around us this is one
which got caught up in political correctness before it had a large public
face.  I personally felt that the science of flame retardants is well
understood and making a change involved adding in risks which were not well
understood therefore bad practice.  Thanx for bring this around again.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain't what it used to be

 

From: Richard Nute  
Sent: Monday, September 16, 2019 1:32 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Do We Need Flame Retardants in Electronics?

 

 

 

https://www.scientificamerican.com/article/do-we-need-flame-retardants-in-el
ectronics/

 ".there has never been any valid statistical demonstration that flame
retardant chemicals of the types and concentrations used in consumer
products have resulted in death or injury reduction," says
 Vytenis Babrauskas.

The article is more than 5 years old.  Nevertheless, thought-provoking. 

Enjoy!

Rich

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Re: [PSES] Applicable safety standard ITE equipment used on a factory floor?

[Pete Perkins]

Joe,Good question and some good feedback for you.  

 

   Even if there was another standard that might apply as long as 
the product has IT/communications functions then 62368 should be applied to 
that portion – this might also include the latest safety requirements for the 
popular USB or POE ports.  In that case it should be considered an IoT product 
and the test house should properly apply both standards.  This is a lot more 
work but results in a comprehensive set of safety requirements being applied.  
From my experience test houses are not yet up to speed on this combo approach 
so will probably have to be led along by the knowledgeable manufacturer.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: Joe Randolph  
Sent: Thursday, September 5, 2019 11:21 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Applicable safety standard ITE equipment used on a factory 
floor?

 

Ken, John, Charlie:

 

Thanks for the feedback.  It sounds as though the existing standards for ITE 
(IEC 60950-1 and IEC 62368-1) are probably a suitable match for a communication 
system that is used on a factory floor.  

 

Since most of my work is with telecom and ITE products, I’m not familiar with 
the safety standards for equipment used in a factory environment.  My concern 
was that there might be something more specific than the ITE standards that I 
normally work with.  I gather that this is not the case.

 

Regarding your remarks about the upcoming transition from IEC 60950-1 to IEC 
62368-1, I am aware of that situation and have been following it closely.  In 
fact, one aspect of this transition that has attracted my attention are the 
rather confusing requirements in IEC 62368-1 for MOVs connected to AC mains 
ports.  I wrote an article on that particular topic in the October 2018 issue 
of InCompliance Magazine.

 

I agree that for new approvals of ITE products, IEC 62368-1 is the appropriate 
choice for most countries.

 

 

Thanks,

 

Joe Randolph

Telecom Design Consultant

Randolph Telecom, Inc.

781-721-2848 (USA)

  j...@randolph-telecom.com

  http://www.randolph-telecom.com

 

From: IBM Ken [mailto:ibm...@gmail.com] 
Sent: Thursday, September 5, 2019 8:56 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] Applicable safety standard ITE equipment used on a factory 
floor?

 

Hi Joe!

60950-1 is the standard for Safety of Information Technology Equipment, but the 
presumption of conformity of this standard is going away in the EU relatively 
soon.  It will be replaced by 62368-1, which is a standard that combines the 
product scopes of information technology equipment and audio/video equipment.  
Since the function of your product sounds very much "information technology", I 
think you have identified the correct standard (unless the product performs a 
specialized function covered by another standard; is it an alarm system, for 
example?). 

 

-Ken A

 

On Wed, Sep 4, 2019 at 8:22 PM Joe Randolph mailto:j...@randolph-telecom.com> > wrote:

Hello All:

 

I have been asked whether IEC 60950-1 and IEC 62368-1 are appropriate safety 
standards for a “box” that resides on a factory floor and provides internet 
access to a variety of sensors distributed throughout the factory floor.

 

Are there other safety standards that are specific to ITE equipment used in a 
factory environment, or are IEC 60950-1 and IEC 62368-1 the most appropriate 
safety standards use for this type of product?

 

 

Thanks,

 

Joe Randolph

Telecom Design Consultant

Randolph Telecom, Inc.

781-721-2848 (USA)

j...@randolph-telecom.com  

http://www.randolph-telecom.com  

 

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For policy 

Re: [PSES] Grounding

[Pete Perkins]

Steve,You have received many good comments focusing especially on the 
rational provision of earthing/grounding including under 60204-1.  

 

   It is not clear as to which specific argument will persuade the 
customer however, perhaps you can get some movement to agreement by providing 
the CE pedigree (VDE or whoever) along with specifics about the adequacy of 
using the DIN rail earthing/grounding from an authoritative source which they 
will accept.  The DIN rail manufacturer should be helpful in supporting this 
application.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: Nyffenegger, Dave  
Sent: Tuesday, June 18, 2019 12:21 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Grounding

 

Steve, I don’t recall EN 60204-1 requiring a central earthing point, 
disallowing daisy chaining of the protective bonding circuit.  My copy is with 
2009 amendments.  Is there a newer version with this requirement?  NFPA 79 2015 
is harmonized with EN 60204-1 and I don’t think there is such a requirement in 
there either.

 

The use of the screw-less DIN rail terminal blocks for protective bonding 
connections should be fine if that is their intended purpose and they are NRTL 
approved or (for outside NA) CE marked to a standard allowed by EN 60204-1.

 

-Dave

 

From: Steve Brody [mailto:sgbr...@comcast.net] 
Sent: Tuesday, June 18, 2019 2:39 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Grounding

 

HI all,

 

I have a client with whom I am having a discussion about grounding for an EN 
60204-1 product.  The product consists of 3 sub-modules all of which use mains 
power derived from the first module where the external mains comes into the 
unit.

 

In the first module the ground from the branch circuit goes to a ground stud, 
lockwasher and nut, and from there a ground wire goes from the stud to a DIN 
rail mounted Wago terminal block designed for grounds, as it is green/yellow in 
color, which is screwless and uses spring pressure to secure the wire in place. 
 Other internal grounds in this module also connect to this block.

 

The second module receives the main ground from the first module in a similar 
arrangement, and the third module gets it's ground from the second module.

 

I have pointed out to my client that, in accordance with all safety standards I 
am aware of, and a figure in EN 60204-1 on grounds, that modules 2 and 3 must 
have ground leads that goes back to the point where the main ground comes into 
the unit originally, and not daisy chained from module to module.

 

I don't think there is anyone who will disagree with this but I did say I would 
ask the question.  Second question is do you thin there is a problem is using a 
screwless pressure connector for the grounds, as opposed to a 
stud/lockwasher/nut?

 

Thoughts and comments would be appreciated by reply to his or privately at 
stev...@productehsconsulting.com 
 

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For 

Re: [PSES] Safety test for CSA approval

[Pete Perkins]

Amund,   So I have tried to work this the other way.  I go to a 
test house that is both a NRTL approved and can provide CB reports for the 
product.  This has worked well for  my clients for many years.  

 

   Technically the CB Report should have all of the needed 
evaluation and test results for equipment which is evaluated to harmonized 
standards (eg 60950 & 61010) however the CB report should have included 
investigation to the NCs for Canada (in this case).  

 

   From discussions among colleagues it is clear that CB Reports 
provided to another test house are not all accepted in the same way.  Each test 
house has to cultivate a very good reputation for the reports to be completely 
interchangeable between test houses.  

 

   Altho it’s none of our business here which test house you have 
used, you’ll have to work thru some of these issues if there are questions 
about converting the CB Report to a CSA Report (or any other National safety 
report) with CSA itself.

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: Amund Westin  
Sent: Friday, June 14, 2019 1:14 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Safety test for CSA approval

 

Is it possible to carry out a safety test (IEC62368-1) at a CB listed test 
laboratory, and thereafter bring the CB test report forward to CSA Group for a 
CSA certification?  

Anyone who have followed this route with success or do CSA required to do the 
testing as well?

 

BR

Amund

 

 

 

 

 

 

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Re: [PSES] Labeling material recognition to UL 969

[Pete Perkins]

Dave,Good question regarding meeting the requirements
when using a standard that is harmonized for use in multiple countries.  

 

When using these standards and including the National
Deviations for more general use then the additional requirements covered by
the NB comments can be invoked, in my opinion.  

 

I have run into this in certifying products to 60950 by a
NRTL; the product bears both the NRTL listing mark as well as the CE
marking..  

 

For labels there are two specific requirements: 1) the
adhesive is proper for the substrate and sticks will and2) the printing is
durable in normal use (and cleaning).  

 

This product uses a UR label which is preprinted by the
supplier for application to the product in manufacturing.  

 

The NRTL US certification includes the labeling material
recognition in the CCL and is accepted as a CCN recognized component for
this application to the specific surface; the testing was performed to
ensure durability the conditions are met.  

 

For the CB Report (including all NDs) the label material is
identified as a UR component in the clause evaluation and shown by name,
type, rating and NA cert standard, and 'subjected to durability testing' for
acceptance on the CCL.   

 

The UR label provides the acceptance for adhering to the
substrate but the printing is evaluated for durability in this case.  This
all seems reasonable to me.

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain't what it used to be

 

From: Nyffenegger, Dave  
Sent: Saturday, June 1, 2019 12:15 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Labeling material recognition to UL 969

 

Hi Folks,

 

A few NRTLS are requiring labeling material to be recognized to UL 969 and
be included in the critical component list.  Anyone running into this?
Anyone know the justification for doing this for product to be Listed to IEC
based standards such as UL 60950-1 and UL 62368-1?  Durability is a
requirement with specific test criteria in UL 60950-1 and 62368-1 but not
that is specifically be recognized to UL 969.

 

Can durability of marking test called out in ICT standards such as
IEC/CSA/UL 60950-1 and IEC/CSA/UL 62368-1 be waived for UL 969 recognized
material?

 

Thanks

-Dave

 

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[PSES] job opportunity; product safety and environmental engineer

[Pete Perkins]

Senior Engineer, Product Safety & Environmental Compliance

Magic Leap, Plantation, FL

 


Company Description


Magic Leap is an eclectic group of visionaries, rocket scientists, wizards, and 
gurus from the fields of film, robotics, visualization, software, computing, 
and user experience.

We are growing quickly, and this is the time to get on board and play a role in 
shaping the way people will be interacting with the world tomorrow.

 


Job Description


In this role, you will be responsible for implementation of product safety and 
compliance standards worldwide for Magic Leap products. Strong technical 
leadership, project management, and organizational skills are essential to 
succeed in this role.

 


Responsibilities


Develop, manage, and implement product safety and compliance requirements for 
Magic Leap products.

Champion Design for Safety initiatives across the company. Partner with 
Regulatory Affairs and engineering teams to develop test plans (for Worldwide 
Product Safety, RoHS, REACH, CA prop 65, CMRT and energy efficiency), and 
execute plans using internal and/or external labs

Drive the failure analysis resulting from safety and compliance testing.

Perform safety risk assessment, FMEA’s

Lead product safety escalations during new product development and sustainment.

Manage cross-functionally with many different teams to resolve product safety 
issues.

Communicate safety updates to executives, and cross- functional teams.

Prioritize and complete tasks to meet deadlines.

 


Qualifications


Minimum 5 years of relevant and hands-on product safety and compliance 
experience working in high tech field.

Consumer electronics new product development experience is required.

Experience in leading safety and compliance programs in global, fast-paced, 
high volume manufacturing environment. Experience in the investigation of 
applicable requirements in regulations and standards as applicable for Magic 
Leap products worldwide (e.g., CE, UL, CPSC, WEEE, RoHS, REACH, CCC, KC, PSE, 
BSMI and other countries).

Experience certifying products to IEC62133, UL/IEC 62368 and working with 
worldwide regulatory agencies.

Application of FMEA (Failure Modes and Effects Analysis) and FTA (Fault Tree 
Analysis).

Dynamic and “can do” attitude engineer with the desire to work with a great 
team and product.

Excellent written, presentation and interpersonal skills are required.

 


Education


Bachelor’s degree (minimum) in engineering. MS or PhD preferred.

 


Additional Information


Job is based in Plantation, FL 

Excellent benefits and medical plans.

All your information will be kept confidential according to Equal Employment 
Opportunities guidelines.

 

apply now

f+ n

 

C OMP A NY |   T E A M |   D E V E L OP E R S  |   B L OG|  
 W I Z A R D S W A NT E D   |   P R E S S  |

 

 

C ONT A C T

 

C OP Y R I G H T © 2016 MA G I C L E A P , I NC .

 

C OP Y R I G H T © 2016 MA G I C L E A P , I NC .

 

p r i v a c y p o l i c y

t e r m s a n d c o n d i t i o n s

 

a l l m a t e r i a l s o n t h e s e p a g e s a r e c o p y r i g h t e d b y 
m a g i c l e a p , i n c . a l l r i g h t s r e s e r v e d . n o p a r t o f 
t h e s e p a g e s , e i t h e r t e x t o r i m a g e , m a y b e u s e d i n 
a n y f o r m o r b y a n y m e a n s , e l e c t r o n i c , m e c h a n i c a 
l o r o t h e r w i s e , w i t h o u t p r i o r w r i t t e n p e r m i s s i 
o n .a l l m a t e r i a l s o n t h e s e p a g e s a r e c o p y r i g h t e 
d b y m a g i c l e a p , i n c . a l l r i g h t s r e s e r v e d . n o p a r 
t o f t h e s e p a g e s , e i t h e r t e x t o r i m a g e , m a y b e u sed 
i n a n y f o r m o r b y a n y m e a n s , e l e c t r o n i c , m e c h a n i 
c a l o r o t h e r w i s e , w i t h o u t p r i o r w r i t t e n p e r m i s 
s i o n .

 






 


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Re: [PSES] 61010-1, UL/CSA to IEC

[Pete Perkins]

Frank,Your test house should be able to provide you with a CB Report 
showing compliance with the EU EN 61010-1 standard.  This works best when you 
ask for both the NA certs and the CB Report as part of the original project.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: Frank Tang <0d3fa4ae712a-dmarc-requ...@ieee.org> 
Sent: Thursday, May 23, 2019 2:03 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 61010-1, UL/CSA to IEC

 

Hi All,

If a product was evaluated to UL/CSA 61010-1 can EUT ship to EU nations?

If not, can UL/CSA test report data be leveraged for IEC-61010 evaluation?

 

--
Thank you and best regards.
- Frank

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Re: [PSES] 62368-1 Openings in a fire enclosure

[Pete Perkins]

And if these connectors, such as a power socket, meet the component 
requirements they are acceptable – whether or not the material is V-1.  

 

This would be a case where the component requirements override the product 
standard requirements.  (I wonder if the TC108 folks realize how often that can 
happen? And whether or not they would see it as a problem.)

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: Nyffenegger, Dave  
Sent: Friday, May 17, 2019 11:33 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 62368-1 Openings in a fire enclosure

 

Bulkhead connectors protrude through fire enclosure openings both sides all the 
time.

 

From: John Woodgate [mailto:j...@woodjohn.uk] 
Sent: Friday, May 17, 2019 2:24 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] 62368-1 Openings in a fire enclosure

 

I would agree with you if it said 'Material that fills an opening...', but it 
says 'Material for components that fill an opening...', which is just 
differently bad. It appears to apply only if there are more than one component 
in the opening, but all consist of only one material.  In that case, one can 
distinguish between the opening and the items that enter/exit through it.

But why would anyone put a component half-inside and half outside a fire 
enclosure?

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk  
Rayleigh, Essex UK
The UK is a sovereign state, not a Zollverein state

On 2019-05-17 18:58, Richard Nute wrote:

 

 

 

Hmm.  Interesting English usage statement.  

 

If something fills an opening, the opening no longer exists.  So, how do you 
know how to apply the requirement?

 

Rich

 

From: Payne, Glyn   
<0d283c0acebb-dmarc-requ...@ieee.org> 
Sent: Friday, May 17, 2019 6:40 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] 62368-1 Openings in a fire enclosure

 

Hi Experts,

 

I have a EN 62368-1 question regarding openings in a fire enclosure…

 

6.4.8.2.2 Requirements for a fire enclosure 

 

Material for components that fill an opening in a fire enclosure or that is 
intended to be 

mounted in such opening shall: 

 

*   comply with the flammability requirements of the relevant IEC component 
standard; or 
*   be made of V-1 class material; or 
*   with Clause S.1. 

 

 

For PS2 and PS3 circuits I have been told by a test house that connectors in 
fire enclosure openings only have to be V-1 class material if they are close to 
a potential ignition source (PIS).

 

My interpretation is that a fire enclosure is a fire enclosure, regardless of 
where, within a fire enclosure a fire may start and so anything filling an 
opening must be V-1.

 

I am interested to know how do other engineers interpret this clause.

 

 

Many thanks,

 

 

 

 

Glyn Payne

 

Compliance and Design Support Engineer

 

 

 

Solid State Logic UK Limited
Registered as a limited company in England and Wales (Company No:5362730) 
Registered Office: 25 Spring Hill Road, Begbroke, Oxford OX5 1RU, United Kingdom

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Re: [PSES] EMC and safety basics (process documentation)

[Pete Perkins]

Frank,Getting started in this is a lot of work.  For a product such as 
yours the requirements are similar but not the same for each market.  The work 
starts with an understanding of the technical requirements that need to be 
applied to the product in the development phase which will be demonstrated 
during the evaluation phase by the test labs for safety and EMC requirements 
etc.  This work becomes the backbone for the Technical File which supports each 
certification needed.  

 

   Too bad you missed the IEEE PSES ISPCE symposium this week in 
San Jose; the Compliance 101 track is aimed at folks just like you.  You might 
work in an area that has a local PSES chapter (check the IEEE PSES website for 
local chapters) where you can network with others doing just what you are 
doing.  

 

   There is a lot of useful info on this forum (you have obviously 
found your way here already). Keep up the good work.  

 

:>) 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

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: frankt_cpmt <0d3fa4ae712a-dmarc-requ...@ieee.org> 
Sent: Thursday, May 9, 2019 2:30 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC and safety basics (process documentation)

 

Hi Dave,

Thank you for your response. 

Product is light industrial laboratory equipment and market is US, europe, 
asia, korea. Trying to figure out which entities I contact for CoC, CE Mark, 
etc. Tried searching online for a good sources to use as information I can feed 
back to team,  but havent had success yet.

 

 

 

Sent via the Samsung Galaxy S8, an AT 5G Evolution capable smartphone

 

 Original message 

From: "Nyffenegger, Dave" mailto:dave.nyffeneg...@bhemail.com> > 

Date: 5/9/19 10:43 (GMT-08:00) 

To: Frank Tang mailto:frankt_c...@yahoo.com> >, 
EMC-PSTC@LISTSERV.IEEE.ORG   

Subject: RE: [PSES] EMC and safety basics (process documentation) 

 

Frank,

 

Answer to many these questions depend on what market(s) you are selling into.  
Your test lab will provide you with their prerequisites needed for a given 
test/certification.  These should be identified in their quotes.  Generally 
minimum requirements for safety evaluation/certifications are critical 
components list with all component info, schematics, and safety risk 
assessment.  Your NRTL will dictate some of this for the NA market.  The ‘Blue 
Guide’ on the implementation of EU product rules will help answer questions on 
what you need to do with your documentation and certifications for the EU 
market.  The EU directives themselves define some of the documentation 
requirements for the individual directives.

 

-Dave

 

From: Frank Tang [mailto:0d3fa4ae712a-dmarc-requ...@ieee.org] 
Sent: Thursday, May 09, 2019 12:53 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] EMC and safety basics (process documentation)

 

Hi Everyone,

Looking for some guidance and mentoring because I am currently in charge of 
compliance and regulatory division on my own.

Any knowledge provided will be greatly appreciated.

Have some knowledge on process for EMC testing, but need guidance for,

*   What to do after test complete and have test report in hand

*   documentation
*   application for certificate (?)
*   self declaration, etc.
*   Maintaining certification

Would also like to get some information regarding safety documentation as well,

*   Things to provide test lab before testing

*   BOM (?)
*   schematic
*   LoCC

*   What to do after test conclude with report in hand

*   Documentation process,
*   LVD
*   Machinery directive
*   etc

 

--
Thank you and best regards.
- Frank

 

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-

Re: [PSES] human skin resistance

[Pete Perkins]

Don, et al,My presentation ‘Physical body parameter calculations 
based upon electrical measurement’ given at the 2008 ISPCE is available (search 
the web).  This paper develops the complex variable analysis (phasor analysis 
to EE’s) for the usual human body model then works backwards from measured body 
current & voltage measurements to determine the skin resistance and capacitance 
for several subjects under several conditions.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: Don Gies <0d65e2e261b9-dmarc-requ...@listserv.ieee.org> 
Sent: Thursday, March 14, 2019 9:20 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] human skin resistance

 

I had written a paper, “Human Body Impedance Model at Radio Frequencies”  for 
the 2016 IEEE Symposium for Product Compliance Engineering.  This paper is on 
IEEE Xplore. 

 

Abstract— This paper examines the frequency response of human body-simulating 
impedance networks found in information and communication technology safety 
standards, then explores their reactions at radio frequencies used for wireless 
telephony.  It explores the possible existence of human-body inductance, 
resonance and skin effect.  Finally, it postulates a working model for 
evaluating the safety of high-power circuits operating at radio frequencies.

 

 

Don Gies

 <mailto:ddg...@verizon.net> ddg...@verizon.net

Mobile:  1.732.207.7828

 

From: Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org 
<mailto:0061f3f32d0c-dmarc-requ...@listserv.ieee.org> > 
Sent: Thursday, March 14, 2019 11:53 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] human skin resistance

 

The standard body models used in the safety standards to provide electric shock 
protection provide for a  ‘ combo in-and out RC skin impedance’ and a ‘body 
resistance’.  The modeled circuit used in 60990 for large area of contact is 
skin impedance of 1500 ohms and 0.22uf and the internal body resistance ‘bag of 
saltwater’ of 500 ohms; this has been the traditional European body circuit, in 
NA UL has used slightly different values; there is only a small difference in 
measured touch current between these circuits.  The large area of contact is 
considered the worst case.  

The component values in the model vary with contact area – as the contact area 
gets smaller the skin impedance resistance get higher and the capacitance 
changes because of the smaller area.  

There are several other more complex body models in the literature which seek 
to auto compensate for some of the variables encountered in electric shock 
work.  Altho they seem to provide some of advantages claimed they have not come 
into general use.

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

p.perk...@ieee.org <mailto:p.perk...@ieee.org> 

 

Entropy ain’t what it used to be

 

From: Richard Nute mailto:ri...@ieee.org> > 
Sent: Wednesday, March 13, 2019 12:07 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] human skin resistance

 

 

John referenced “skin resistance.”

 

To my knowledge, there is no research that shows skin resistance and body 
resistance as separate parameters.  We only know total body resistance, and 
that it is a variable that changes – lowers -- with applied voltage and time.

 

Having said that, a good guess that skin resistance is the predominant 
parameter at low voltages.  The “body” is comprised of water-predominate 
organs, so is likely to be a lower resistance than skin resistance and 
relatively constant with voltage.

 

We also know that capacitance parallels the total body resistance.  But, as 
with resistance, we don’t know how to apportion the capacitance to the skin and 
to the body.  

 

If you know of any such research, please let me know.  

 

Best regards,

Rich  

 

From: John Woodgate mailto:j...@woodjohn.uk> > 
Sent: Wednesday, March 13, 2019 1:30 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] classification of the output

 

We found very great differences in human  'skin resistance' at effectively zero 
voltage when designing TV tuners with touch-contact channel selection. We had 
to make the sensitivity so high that there was a risk that houseflies would 
change the channel.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-03-13 05:22, Pete Perkins wrote:

-
---

Re: [PSES] human skin resistance

[Pete Perkins]

The standard body models used in the safety standards to provide electric shock 
protection provide for a  ‘ combo in-and out RC skin impedance’ and a ‘body 
resistance’.  The modeled circuit used in 60990 for large area of contact is 
skin impedance of 1500 ohms and 0.22uf and the internal body resistance ‘bag of 
saltwater’ of 500 ohms; this has been the traditional European body circuit, in 
NA UL has used slightly different values; there is only a small difference in 
measured touch current between these circuits.  The large area of contact is 
considered the worst case.  

The component values in the model vary with contact area – as the contact area 
gets smaller the skin impedance resistance get higher and the capacitance 
changes because of the smaller area.  

There are several other more complex body models in the literature which seek 
to auto compensate for some of the variables encountered in electric shock 
work.  Altho they seem to provide some of advantages claimed they have not come 
into general use.

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: Richard Nute  
Sent: Wednesday, March 13, 2019 12:07 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] human skin resistance

 

 

John referenced “skin resistance.”

 

To my knowledge, there is no research that shows skin resistance and body 
resistance as separate parameters.  We only know total body resistance, and 
that it is a variable that changes – lowers -- with applied voltage and time.

 

Having said that, a good guess that skin resistance is the predominant 
parameter at low voltages.  The “body” is comprised of water-predominate 
organs, so is likely to be a lower resistance than skin resistance and 
relatively constant with voltage.

 

We also know that capacitance parallels the total body resistance.  But, as 
with resistance, we don’t know how to apportion the capacitance to the skin and 
to the body.  

 

If you know of any such research, please let me know.  

 

Best regards,

Rich  

 

From: John Woodgate mailto:j...@woodjohn.uk> > 
Sent: Wednesday, March 13, 2019 1:30 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] classification of the output

 

We found very great differences in human  'skin resistance' at effectively zero 
voltage when designing TV tuners with touch-contact channel selection. We had 
to make the sensitivity so high that there was a risk that houseflies would 
change the channel.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2019-03-13 05:22, Pete Perkins wrote:

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Re: [PSES] classification of the output

[Pete Perkins]

Mick, Thanx for the reply given on this thread.  

 

I am familiar with the 60479 clauses you describe.  My overall 
comment is that 60479 folks primary focus is on preventing VF (not killing 
people).  Much of what you quoted relates to such electric shock situations.  
Because of the data spread there probably are a few folks who lie below the 
curves shown in the standard.  Tasers meet these requirements yet there are 
occasional deaths with their use; the ‘almost perfect weapon’ in my opinion.  

 

In the product standards the allowed electric shock level is 
always set much lower so that the VF region is not involved.  The upper limit 
to electric shock from equipment is the Letgo-immobilization limit of 
5mArms/7mApk under fault conditions.  The long time separation to allow the 
heart to reset doesn’t come into play for this effect so it is irrelevant.  The 
peak current is the major factor that needs to be controlled.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: Mick Maytum  
Sent: Tuesday, March 12, 2019 1:03 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] classification of the output

 

Joe Randolph and I talked about “pulsed power” delivery at the 2019 ATIS-PEG 
conference last week and how it should be treated. 

 

A good starting point is the IEC 60479 series of documents on “Effects of 
current on human beings and livestock”. IEC 62368-1 mentions the time locked 
IEC TS 60479-1:2005, but the current version is IEC 60479-1:2018. The IEC TS 
60479-2:2017 variant is particularly interesting as clause 9 covers “Effects of 
current pulse bursts and random complex irregular waveforms”. For sequential 
pulses separated by > 300 ms there isn’t a cumulative effect on the heart and 
each pulse can be treated as single, non-repetitive pulse of current. For 
safety, I believe pulsed power systems will insert this separation time when 
any non-load currents are detected to delay any following power pulse. 

 

Thus only the effects of a single power pulse need to be evaluated provided the 
safety separation is >0.3 s. Primarily IEC TS 60479-2:2017 is seeking to 
establish a “no fibrillation” condition, which is higher stress level than 
you’d want for a safety standard. 

 

A 2018 ATIS-PEG conference paper on IEC TS 60479-2:2017 gave an example 
evaluation using the quoted pulsed currents produced by a TASER® gun. Safety 
tip - if anyone is pointing a TASER® gun at you, yell out you have a 
pre-existing medical condition.

 


 

Regards,

Mick 

Safety and Telecom
Standards

  mjmay...@gmail.com

https://ict-surge-protection-essays.co.uk/

 

-- Original Message --

From: "Joe Randolph" mailto:j...@randolph-telecom.com> >

To: EMC-PSTC@listserv.ieee.org  

Sent: 12/03/2019 17:54:36

Subject: Re: [PSES] classification of the output

 

Hi Pete:

 

This discussion reminds me of some things I have been hearing about “digital 
power” as a way to deliver large amounts of power while keeping the circuit 
classification to ES1 or ES2.  A company called Voltserver has been promoting 
(and deploying) this technology.

 

I know few details about the scheme, and I’m not familiar with how IEC 62368-1 
evaluates things such as touch current.

 

However, as I understand it, the “digital power” method uses a series of short 
pulses with off periods during which the power sourcing device attempts to 
detect a fault condition.  The power is immediately cut off if a fault 
condition is detected.  I have heard that the pulse frequency is in the range 
of 7 KHz, and the voltages can be up to 380 V.  The key to making this scheme 
even plausible is that the system must respond VERY quickly to a fault 
condition (such as a human touching a live conductor).

 

I’m interested in hearing your thoughts (and hopefully Rich Nute’s thoughts 
too) regarding how the touch current tests in IEC 62368-1 might apply to such a 
system.  I don’t know whether such a system would pass or fail the IEC 62368-1 
tests.  

 

Regardless of whether such a system would pass or fail the existing tests in 
IEC-62368-1, I think the important thing is to go back to first principles and 
evaluate whether the proposed “digital power” can be made sufficiently safe to 
prevent harm to humans.

 

 

Thanks,

 

Joe Randolph

Telecom Design Consultant

Randolph Telecom, Inc.

781-721-2848 (USA)

  j...@randolph-telecom.com

  http://www.randolph-telecom.com

 

 

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Re: [PSES] Brexit and impact on official languages

[Pete Perkins]

Doug et al,   A sigh of relief knowing that Ireland will champion the 
English language within the EU, unless the Francophiles push to return French 
to its former prominence in official communication.  However, Ireland may not 
continue to pursue the virginity of the English language within the EU 
communications in the same way the British have done.  John Woodgate, 
unfortunately, will not carry the same weight in all of this as in former days. 
 Americans will remain indifferent to the subtleties of the English language 
and continue in our slovenly ways.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

Entropy ain’t what it used to be

 

From: Doug Powell  
Sent: Thursday, March 7, 2019 9:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Brexit and impact on offical langugages

 

All,

 

With March 29 approaching, I've seen plenty of discussion on the impact of 
Brexit.  However, I've seen virtually nothing on official languages of the EEC. 
 And in particular how this might affect Declarations of 
Conformity/Incorporation as well as labeling and user documentation.  In the 
past, my advice has always been to start with one of the official languages and 
if requested by the end user to provide in another language this then becomes 
mandatory.  With implementation of Brexit is English no longer an official 
language of the community?  

 

This seems an interesting question to me because it seems that English / French 
will remain intact for the IEC in Brussels.  I suppose we can continue to watch 
the O.J. after the withdrawal of Britain.

 

Best to all,  Doug

 

-- 

Douglas E Powell
doug...@gmail.com  
http://www.linkedin.com/in/dougp01

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Re: [PSES] Mexico compliance approval for IT equipment

[Pete Perkins]

Johns,   Thanx for the comments.  I didn't mean for my
diatribe to be attached to Mexico in particular nor to be offensive the
them, it is a more general rant.  

 

Yes, Trump has his wall issues and May has her Brexit
issues.  The fine line between political and technical conditions sometimes
get lost in the conversation and it is appropriate to salt the ongoing
discussion with a little bit of the alternative view.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: John Allen <09cc677f395b-dmarc-requ...@listserv.ieee.org> 
Sent: Wednesday, February 27, 2019 1:59 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Mexico compliance approval for IT equipment

 

Don't forget NAFTA-related issues (especially in the "DJT Wall" context!) as
Mexico probably cannot afford to be "too liberal" in what it can accept with
the minimum of "bureaucratic rules" whilst still trying to protect its
in-house labs & certification bodies as far as it legally can!

 

John E Allen 

W. London, UK

 

From: John Woodgate [mailto:j...@woodjohn.uk] 
Sent: 27 February 2019 21:25
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] Mexico compliance approval for IT equipment

 

To be fair, Mexico is a full member of IEC and is a P-member (i.e. actively
contributing ) on 32 Technical Committees. There are nearly 200 committees,
so it does take a long time to catch up with the countries that have been
members since 1910, even if we consider only EMC and safety.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2019-02-27 21:03, Pete Perkins wrote:

My experience is that they are way behind on harmonization of requirements
with the EN/IEC technical requirements.  They are working to come into the
21st century but will, in the end, require national NOM certification even
if it is to the EN/IEC requirements; they have allowed some simpler paths in
the past but these seem to be phasing out and replaced by NOM.
Unfortunately, the NOM certification is only a 1 year certification and it
has to be renewed each year (maybe even retesting); presumably this is in
lieu of factory follow-up to maintain the certification.  Further, if your
product has a radio (wireless, Bluetooth, etc) it requires Mexican testing,
approvals and registration.  

 

>From what I see, every (developing) country wants to get into the cert &
registration game.  This has all been made easier by the development of IEC
standards which are being harmonized for the major markets and all are
easily adopted by additional countries (very little requirements development
cost, all borne by the big boys in the IEC committees).  However, in order
to have some control it is straightforward to develop a bureaucracy to
administer local certification and registration to use their mark.  If the
country doesn't have local qualified folks to deal with this, just implement
internal test houses for safety , EMC and everything else then require that
all product be tested in country to get their mark (until the lab staff is
fully qualified) after which MRAs can be developed to accept outside work to
get local acceptance. The power supply for your laptop shows the path that
everything is on.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

p.perk...@ieee.org <mailto:p.perk...@ieee.org> 

 

From: Koester, Helmut  <mailto:h.koes...@psi-laser.de>
 
Sent: Wednesday, February 27, 2019 4:53 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] Mexico compliance approval for IT equipment

 

Hello group,

 

does anybody know if it there is any way to bring IT Equipment into the
Mexican market without NOM certificate only based on CE marking and CE test
documentation? 

 

Regards

Helmut

 

 

PSi Laser GmbH
Helmut Koester
 <mailto:h.koes...@psi-laser.de> mailto:h.koes...@psi-laser.de



 

 

 

 

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Re: [PSES] Mexico compliance approval for IT equipment

[Pete Perkins]

My experience is that they are way behind on harmonization of requirements
with the EN/IEC technical requirements.  They are working to come into the
21st century but will, in the end, require national NOM certification even
if it is to the EN/IEC requirements; they have allowed some simpler paths in
the past but these seem to be phasing out and replaced by NOM.
Unfortunately, the NOM certification is only a 1 year certification and it
has to be renewed each year (maybe even retesting); presumably this is in
lieu of factory follow-up to maintain the certification.  Further, if your
product has a radio (wireless, Bluetooth, etc) it requires Mexican testing,
approvals and registration.  

 

>From what I see, every (developing) country wants to get into the cert &
registration game.  This has all been made easier by the development of IEC
standards which are being harmonized for the major markets and all are
easily adopted by additional countries (very little requirements development
cost, all borne by the big boys in the IEC committees).  However, in order
to have some control it is straightforward to develop a bureaucracy to
administer local certification and registration to use their mark.  If the
country doesn't have local qualified folks to deal with this, just implement
internal test houses for safety , EMC and everything else then require that
all product be tested in country to get their mark (until the lab staff is
fully qualified) after which MRAs can be developed to accept outside work to
get local acceptance. The power supply for your laptop shows the path that
everything is on.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: Koester, Helmut  
Sent: Wednesday, February 27, 2019 4:53 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Mexico compliance approval for IT equipment

 

Hello group,

 

does anybody know if it there is any way to bring IT Equipment into the
Mexican market without NOM certificate only based on CE marking and CE test
documentation? 

 

Regards

Helmut

 

 

PSi Laser GmbH
Helmut Koester
  mailto:h.koes...@psi-laser.de



 

 

 

 

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Re: [PSES] Standards

[Pete Perkins]

Frank,   If you are already a UL Certification customer you have access to the 
UL version of the standard which applies to your product.  This standard is a 
NA/IEC harmonized standard and includes all of the IEC text plus NA additions 
and deviations (all appropriately marked).  Check the available version of 
61010-1 to ensure that it covers the amendments you are seeking.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: Frank Tang <0d3fa4ae712a-dmarc-requ...@listserv.ieee.org> 
Sent: Friday, February 22, 2019 1:37 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Standards

 

Hi PSTC community,

Looking to purchase a copy of IEC 61010-1:2010 standard and saw there are many 
revisions.

Products will be utilized in a laboratory environment.

 

Before purchasing a copy, would like to know the difference between IEC 
61010-1:2010/AMD1:2016  and

IEC 61010-1:2010+AMD1:2016 CSV Consolidated version?

Because there is quite a price difference,CHF 170 and CHF 700 respectively.

 

--
Thank you and best regards.
- Frank

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Re: [PSES] Intro to Safety

[Pete Perkins]

Frank,   There are more standards than you can ever learn.  Most safety 
standards are written about the same way (strange, as the same risks/exposures 
exist across standards); it is reasonably straightforward to move between 
equipment safety standards.  The product certification key is to pick out the 
issues that won’t quickly fit into the usual evaluation scheme and work to 
resolve those early in the product development process.  My usual question is: 
what is different about this product than the last/earlier product which was 
certified?  This will get you on the needed path.  

 

Work to understand the bleeding edges in the regulatory world 
in which these products work.  You probably understand this for EMC but…   

Work to understand the basic differences between North American 
and European practice and standards; both are developed to provide the same 
safety for the user.  Providing the same equipment worldwide requires 
harmonizing the design and construction to meet both sets of requirements.  
They are not necessarily at odds with one another; you will need to be able to 
explain why for any specific construction one is acceptable to the other.  

Finally, Brexit will cause considerable heartburn for CE marked equipment as 
even tho the technical requirements should remain the same there will be new 
product marking and a new Manufacturer’s Declaration of Conformity.  Other 
complications could also arise.  

 

>From your comment, you are working on supplementary requirements (S2/S8, etc). 
> S2 safety requirements were originally built up from 61010; they both have 
>diverged somewhat with time.  All of these are usually built upon some other 
>requirements but can have delta differences which you need to identify and 
>track for reporting which includes showing compliance to the deltas. 

 

Network with other professionals doing similar work.  The IEEE 
PSES has chapters meeting in many cities on a regular basis.  The annual IEEE 
PSES ISPCE meeting in May will provide 3 days of opportunities to inhale good 
presentations plus network with many others.  

 

Finally, spend the next 30 years doing this and you will become 
an expert.  Good luck in your career.

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: Nyffenegger, Dave  
Sent: Friday, February 15, 2019 11:32 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Intro to Safety

 

If you will be working on CE marked machinery then review the requirements for 
the technical file in the Machinery  Directive.  Also review requirements in 
the Low Voltage Directive whether machinery or not.

 

-Dave

 

From: Frank Tang [mailto:0d3fa4ae712a-dmarc-requ...@listserv.ieee.org] 
Sent: Friday, February 15, 2019 2:15 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Intro to Safety

 

Hi Compliance Peers,

I'm fairly new to compliance, with 4-5 years EMC experience on ITE products for 
Americas, Europe, Asia, and some Nebs understanding.

Recently began a new opportunity, which encompasses EMC and Product Safety for 
automation.

Only begun reading SEMI S2/S8, and IEC 61010-1.

My questions are:

1.  Additional standards I should learn?
2.  Besides EMC and Safety testing testing what other documents is needed 
for safety, ie. critical component list?
3.  How long does the whole process take?

Any help would be great.

 

-Frank

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Re: [PSES] Brexit requirements for UK manufacturers.

[Pete Perkins]

I believe Mark’s comment is over the top.  The NRTL test houses can be drawn 
into court cases and they will confirm that the product tested met the 
requirements of the standard.  Then the argument becomes whether or not all of 
the safety issues are properly covered in the standard; today the development 
of the standard is not under the sole control of the test house.  That leaves 
some of the responsibility on the standards development folks who seem to be 
working at arm’s length from the assessment.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: John Woodgate  
Sent: Friday, January 18, 2019 7:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

 

So their certification is a sort of 'whitewash', nothing more, if, as you say, 
they bear no responsibility for the product actually being safe.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk  
Rayleigh, Essex UK

On 2019-01-18 13:53, Schmidt, Mark wrote:

If you read in to the contractual agreements you sign for these OSHA NRTL’s 
they are responsible for basically nothing and most likely would not support 
you in a court of law. However, some reputable labs that I have worked with 
that are not recognized by OSHA I believe would. Bottom Line: the manufacturer 
is ultimately responsible for their product.

 

Mark

 

 

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Re: [PSES] Brexit requirements for UK manufacturers.

[Pete Perkins]

Andrew,   Thanx for the pointer to this proposed comprehensive 
Brexit update to the UK Legislation.  This was a lot of work pulling this 
together.  Hopefully it will be used to provide a smooth transition from the 
present CE marked equipment to the new UK marking.  

 

I searched it thoroughly for the new replacement marking for CE 
(UK marking) and primarily found a reference to some other legislation; nowhere 
did I find a symbolic representation for the marking.  

 

So the actual marking seems still in doubt.  I still like my 
combo approach – ukCEeu – which brings the requirements together in the same 
way that the usNRTLc marking does for North America.  

 

However, Gert’s unique proposal seems intriguing; the letters 
UK could be shown in the Bowler Hat but I would insist on maintaining the 
mustache.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: Andrew Wood  
Sent: Thursday, January 17, 2019 2:28 AM
To: Pete Perkins ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Brexit requirements for UK manufacturers.

 

Just to clear up a bit of confusion (whilst staying well clear of politics)

 

The link given by Scott ie 
http://www.legislation.gov.uk/ukdsi/2019/978076368/schedule/25 
<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.legislation.gov.uk_ukdsi_2019_978076368_schedule_25=DwMFaQ=4Wq-glnrtRfJm80jXLZl8g=SutJAoHIYf-NiICmGTlfKdUzkvlvaPBEJjZuVg06iyw=TAMR-N5xXLQ8ntY-TivCpWr5EtO670o5pxOvEwVKlw4=i2G28X6nRmu5NWsp2BqoPi-SQ-PTVzJhYy74n0hoUzg=>
 

Is to the 619 page draft legislation, but the link takes you straight to 
Schedule 25 which is for the ATEX information.

Using the navigation options you can open the entire document as a web page or 
pdf.

 

The aim of this document is a quick fix in the event of no further deals or 
agreements.

It is a document to amend a series of existing regulations and makes the bare 
minimum changes.

For ATEX, Schedule 25 amends the Equipment and Protective Systems Intended for 
use in Potentially Explosive Atmospheres Regulations 2016.

The 28 pages of changes can be summarised as:

 

*   Harmonised standards (published in the OJ) become Designated standards 
approved by the Secretary of State
*   Notified Bodies become Approved Bodies (and the Nando database is 
replaced by  a UK equivalent) 
*   EU Declaration of Conformity drops “EU” to become a Declaration of 
Conformity
*   CE mark is replaced by UK mark.

There are various other minor logical changes referring to instructions being 
in English etc and generally changing references from EU to UK.

The basic structure and approval process seems to be as close as practical to 
the existing requirements.

 

A very quick look suggests that there are similar changes for the following 
Regulations that might be of interest:

Machinery Safety in Schedule 12

EMC in schedule 20

LVD in schedule 23

Pressure equipment in schedule 24

Radio equipment in schedule 29

 

 

The deal rejected earlier this week relates to the withdrawal agreement, which 
aimed to establish a transition period (so that for example the UK would carry 
on using the CE mark and the EU Notified Bodies would keep their status etc etc 
in return for a series of rights and obligations on both sides)

 

The 619 draft legislation is the default position (for product safety etc) if 
there is nothing else decided in the meantime.

 

Andy

 

Best Regards,

Andrew Wood
Compliance Manager - Hazardous Areas

 



 

  Visit the NEW SPOT Thermometer website at  www.spotthermometer.com 
<http://www.landinst.com/products/viralert-fever-screening-system/overview> 

 

LAND Instruments International | Stubley Lane, Dronfield, Derbyshire, S18 1DJ, 
England

DDI: +44 (0)1246 581592  | E-mail:  <mailto:andrew.w...@ametek.com> 
andrew.w...@ametek.com| Web: www.landinst.com <http://www.landinst.com/> 

 

From: Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org 
<mailto:0061f3f32d0c-dmarc-requ...@listserv.ieee.org> > 
Sent: 16 January 2019 19:47
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

 

***NOTICE*** This came from an external source. Use caution when replying, 
clicking links, or opening attachments.

Scott et al,

 

I haven’t read the 600+ UK legislation report (which was 
apparently rejected this week in the Parliament) but I am searching for the new 
UK marking – perhaps ukCEeu?  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.per

Re: [PSES] Brexit requirements for UK manufacturers.

[Pete Perkins]

Scott et al,

 

I haven’t read the 600+ UK legislation report (which was 
apparently rejected this week in the Parliament) but I am searching for the new 
UK marking – perhaps ukCEeu?  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: Scott Xe  
Sent: Wednesday, January 16, 2019 5:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit requirements for UK manufacturers.

 

Hi Ian,

 

Your assumption is correct but may have more than your thought.  You can read 
the following draft for greater detail.

 

http://www.legislation.gov.uk/ukdsi/2019/978076368/schedule/25

 

I have learnt that recently the UK government published draft Regulations of 
619 pages in case of no deal Brexit.  Unfortunately, I could not locate it yet. 
 Hope other team mates can help to explore greater info.

 

Thanks and regards,

 

Scott

 

 

Sent from Mail   for Windows 10

 

From: McBurney, Ian  
Sent: Wednesday, 16 January 2019 08:55 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Brexit requirements for UK manufacturers.

 

Dear Colleagues.

 

I have been waiting for some firm guidelines as to what will be the 
requirements for UK manufacturers after 30th March 2019

but so far nothing has been published by the relevant authorities. 

 

>From my understanding, if the UK leaves the EU without an agreement, the UK 
>will be outside the EU and there are different requirements for UK based 
>manufacturers.

 

I believe the existing manufacturers Declaration of conformity documents will 
still be valid but that a nominated representative in the EU will now be 
required. We plan to nominate our distributor in the EU (i.e. Germany) as the 
importer to satisfy this requirement.

 

Please can you let me know if my assumptions are correct?

 

Thanks in advance.

 

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  

 

Allen & Heath Ltd is a registered business in England and Wales, Company 
number: 4163451. Any views expressed in this email are those of the individual 
and not necessarily those of the company. 

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Re: [PSES] MD clarification of the DoC

[Pete Perkins]

Dave,As with you, I have helped many companies write their MDoC or MDoInc; 
I typically get called in toward the end of a design project and am asked what 
needs to be done to get CE marking on the product, and am engaged almost right 
away with a project that is on a fast track.  The MDoC is always done on the 
American company’s letterhead and is signed by the designated person who has 
the authority to commit the company (not allowed to ask the janitor to sign).  
I carefully explain to the signer that they bear personal liability under EU 
law.  I also  develop a document that lists all of the technical documents 
supporting the MDoC (the list of TF documents) which is signed off by the 
project manager or higher (which provides confidence to the MDoC signing 
manager that the details have been carefully taken care of and are organized 
for retrieval down line).  The American signer of the MDoC understands that 
they are at arms-length to EU law until they appear on EU soil (I always 
recommend careful introspection into these issues before planning a Riviera 
holiday :>).  Hence, the EU desire for an EU Authorized Rep.  

 

The inclusion of the EU AR on the same document is a company 
decision, in my opinion, and should not be done lightly.  Some companies 
consider adding a distributor or some other contact without consideration of 
the issues or consequences.  When I have the opportunity I do point out these 
issues and encourage the development of a contractual relationship with the AR 
before their name is added to the MDoC.  Because this has not been considered 
the additional time/effort involved usually interferes with the product 
introduction schedule and the need for the MDoC immediately.  

Of course, there is always room for improvement next time.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: Nyffenegger, Dave  
Sent: Wednesday, December 19, 2018 11:18 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] MD clarification of the DoC

 

Ha, ha, I have written many DoCs and DoIs with the two names for my current 
company.  Fortunately we already had resident employees in the EU that could be 
used to meet the technical file requirement.  But before I started writing the 
DoCs it was clear whomever created the prior DoCs had not a clue understanding 
the requirements and no EU resident/address was included.

 

It’s understandable that the signer of the DoC may not be in the EU as they are 
typically within the manufacturer’s organization responsible for the product 
compliance and/or manufacturing or company signatory if they are not an 
authorized rep. 

 

-Dave

 

From: Regan Arndt [mailto:reganar...@gmail.com] 
Sent: Wednesday, December 19, 2018 1:46 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] MD clarification of the DoC

 

Thanks Pete for that history lesson.

 

My confusion lies on the fact that 2 different people and addresses can be on 
the MDoC. One for the DoC as a whole and one for the compiler. If I understand 
you correctly, it seems that it will be easier for the EU courts to 
fine/imprison someone in the EU (person that 'compiles' the technical file) 
versus one outside the EU (i.e. one who can sign the MDoC (& ultimately is the 
responsible person). That's how I read itdon't know why the directive 
didn't just say the signer (responsible person) of the MDoC must be on EU soil.

 

...oh, btw, I have yet to see an example of a MDoC with 2 names and 2 
addresses though...despite seeing other multiple errors on these

 

On Tue, Dec 18, 2018 at 11:34 PM Pete Perkins 
<0061f3f32d0c-dmarc-requ...@ieee.org 
<mailto:0061f3f32d0c-dmarc-requ...@ieee.org> > wrote:

Regan,  A little ancient history:  

When the CE marking system was set up it was apparent by the early reactions 
that the developers of the system never envisioned that anyone but a European 
would sign the MDoC and be legally responsible for the equipment safety.  (I’ve 
always said they are looking for someone to arrest since there is legal 
criminal liability for signing the MDoC falsely.)  Failing to set up the 
process the way they envisioned it, 2nd best is to have a European person 
available who can bear the responsibility; don’t be fooled that the Euro 
contact only has to provide the TF upon request.  That being said, any European 
asked would not accept the responsibility lightly and want legal, contractual 
assurances that the non-European company would provide needed legal and 
financial support to defend them and the company.  Getting this done has been 
left to the Directives  and there is no uniform way applying it broadly to all 
Directives, MDoCs and pro

Re: [PSES] MD clarification of the DoC

[Pete Perkins]

Regan,  A little ancient history:  

When the CE marking system was set up it was apparent by the early reactions 
that the developers of the system never envisioned that anyone but a European 
would sign the MDoC and be legally responsible for the equipment safety.  (I’ve 
always said they are looking for someone to arrest since there is legal 
criminal liability for signing the MDoC falsely.)  Failing to set up the 
process the way they envisioned it, 2nd best is to have a European person 
available who can bear the responsibility; don’t be fooled that the Euro 
contact only has to provide the TF upon request.  That being said, any European 
asked would not accept the responsibility lightly and want legal, contractual 
assurances that the non-European company would provide needed legal and 
financial support to defend them and the company.  Getting this done has been 
left to the Directives  and there is no uniform way applying it broadly to all 
Directives, MDoCs and products yet.  (I’m surprised that the EU bureaucrats 
haven’t worked this out yet; they did it for the CE marking.)  Moreover, 
non-Euro companies have been dragging their feet on meeting this requirement 
even when it is in a Directive, such as the MD you mentioned.  This avoids the 
initial cost of setting up a contracted representative,  any ongoing cost to 
maintain the representative and, minimizes the chances of being drawn into any 
expensive legal battle over challenges – either procedural or equipment 
incident related.  It is so easy to sell over the internet and ship the CE 
marked unit to the Euro customer and have the payment flow to the manufacturer. 
 

Remember your mother’s mantra: be careful what you ask for; you 
might just get it. 

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: Nyffenegger, Dave  
Sent: Tuesday, December 18, 2018 11:16 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] MD clarification of the DoC

 

Regan, “So, a European must compile it but he can store it somewhere in i.e. 
Timbuktu. strange.”

 

I don’t take ‘compile” too literally,  they are looking for a contact in the 
EU, one that can be easily contacted who can provide a copy of the technical 
file on request.  How the person gets it or where they get it from is not of 
concern.  This individual is distinctly different than one who signs the DoC 
and different than authorized representative, although it could be the same 
person as you have pointed out.  The Blue Guide probably has some words on 
this, it’s been a while since I’ve looked at it.   Technical file requirements 
vary across directives.

 

-Dave

 

From: Regan Arndt [mailto:reganar...@gmail.com] 
Sent: Tuesday, December 18, 2018 1:44 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] MD clarification of the DoC

 

Hello folks. Hope you are all enjoying the festive season thus far!

 

I was wondering if any of you knew the rationale behind requirement #2 in the 
Machinery Directive and why the other directives do not have this? (as you can 
see, this is over & above the authorized rep (#10) signing the DoC). 

 

Excerpt below:

 

A. EC DECLARATION OF CONFORMITY OF THE MACHINERY

 

2. name and address of the person authorised to compile the technical file, who 
must be established in the Community;

 

10. the identity and signature of the person empowered to draw up the 
declaration on behalf of the manufacturer or his authorised representative.

 

It's odd because in Annex VII, in section 2, it states:

 

The technical file does not have to be located in the territory of the 
Community, nor does it have to be permanently available in material form. 
However, it must be capable of being assembled and made available within a 
period of time commensurate with its complexity by the person designated in the 
EC declaration of conformity. 

 

So, a European must compile it but he can store it somewhere in i.e. 
Timbuktu. strange.

 

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[PSES] product marking detail for FCC marking

[Pete Perkins]

Speak O oracle:  

 

My client is getting pushed by their Euro based EMC lab that
when marking a product in compliance with FCC regulations that when the
number contains a numeric zero to use a zero with a slash rather than the
zero provided on the North American keyboard.   The NA keyboard clearly
distinguishes between alpha O and numeric 0 by shape.  

 

I've not seen this done on any products here and don't
believe that it is commonly done by American manufacturers.  

 

Wot's the group experience and feedback on this?  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

p.perk...@ieee.org  

 


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Re: [PSES] NRTL approval

[Pete Perkins]

Ian,The common issues as to whether or not it needs a 3rd party
safety approval is well argued outside of this email.  

By using a harmonized safety standard you will be able to have the Euro CE
and North American NRTL evaluation all done at once and easily show needed
compliance while protecting your company from liability by meeting these
requirements.   The CB Report and CB Certificate will also provide the basis
for getting approvals in countries which are involved in the IECEEE scheme =
same technical requirements but different registration requirements. 

   Further, the USB requirements from 60950 have been
incorporated into a new standard 62368-3 (by ACOS directive) which is
intended to provide requirements to prevent hazards from being propagated
between equipments when using communications cables to power equipment since
the available power levels in these cables is increasing toward 100W.

   More food for thought.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: McBurney, Ian  
Sent: Tuesday, November 13, 2018 1:27 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] NRTL approval

 

Dear colleagues.

 

We are in the process of designing a USB bus powered audio product around
2.5W for professional/consumer use.

The product enclosure will be UL94 5VA flammability rated plastic.

Will this product have to be NRTL approved for sale in the USA/Canada?

The EU LVD doesn't apply because of the supply voltage is only 5V DC. The
GPSD probably will!

 

Many thanks in advance.

 

Ian McBurney

Lead Compliance Engineer.

 

Allen & Heath Ltd.

Kernick Industrial Estate,

Penryn, Cornwall. TR10 9LU. UK

T: 01326 372070

E: ian.mcbur...@allen-heath.com  

 

 

Allen & Heath Ltd is a registered business in England and Wales, Company
number: 4163451. Any views expressed in this email are those of the
individual and not necessarily those of the company. 

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Re: [PSES] Marine Safety question

[Pete Perkins]

Mike,Why wouldn't you want 60950-22 Requirements for Outdoor Electronic
Equipment to apply to your electronic equipment.  If the installation
environment is considered outside the scope of this standard it only means
that a risk assessment would identify these and appropriate additional
requirements would need to be met.  

If you are using a Manufacturer's Declaration you would have
to work thru this and have the proper Technical File details to show
compliance.  If you use a 3rd party compliance scheme then you need to
negotiate with them to develop the appropriate requirements including the
60950-22 requirements before any evaluation is started.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: Sundstrom, Mike  
Sent: Thursday, November 1, 2018 12:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Marine Safety question

 

Hello group,

I have a question about IEC/EN 60950-22 and if it applies to equipment
mounted on non-SOLAS marine vessels?

 

 

Thanks,

 

Michael Sundstrom

Garmin Compliance Engineer

(913) 440 1540

KB5UKT

 

"Never give up on a dream just because of the time it will take to
accomplish it.

The time will pass anyway."

Earl Nightingale

 

 

  _  


CONFIDENTIALITY NOTICE: This email and any attachments are for the sole use
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Re: [PSES] CE non-conformity statistics

[Pete Perkins]

Regan,  Thanx for chasing down these statistics; very 
interesting.  For most of the folks on this forum the most interesting are the 
technical non-conformity issues.  The best/lowest is 14% for EMC and higher 
24%/25% for safety/radio.  Doesn’t speak well for our profession and influence 
on industry.  Yes, there are many others but most of them are Technical File 
paperwork issues.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: Regan Arndt  
Sent: Wednesday, October 31, 2018 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE non-conformity statistics

 

Thanks Charlie. I checked the latest on the RED. Below is an excerpt on the 
stats. Amazing. Wonder what the penalties were. h..

  

ADCO RED report to TCAM WG on market surveillance statistics for 2016 

 

2. Results for 2016 

Totally, 13,488 R equipment has been inspected by 25 market surveillance 
authorities in 2016: Austria, Cyprus, Denmark, Estonia, Finland, France, 
Germany, Greece, Hungary, Italy, Latvia, Lithuania, Luxembourg, Malta, Norway, 
Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, The 
Netherlands and United Kingdom. About 10391 equipment were been found 
non-compliant to the provisions of the R Directive. However, due to the 
fact that not all provisions were checked by all involved market surveillance 
authorities, the effective amount of non compliant equipment may be higher. 

 

Summary of the results: * Overall : 10391 non compliant equipment (13488 
inspected equipment)

*   Declaration of conformity : 9372 non compliant DoC (13224 inspected 
equipment)
*   CE marking : 8307 non complaint CE marking (13371 inspected equipment)
*   Geographical area for use : 3773 not compliances (11750 inspected 
equipment)
*   Essential requirements : 579 technical non compliances (of 2131 
measured equipment)
*   Safety (art.3.1.a): 116 technical non compliances (of 488 measured 
equipment)
*   EMC (art 3.1.b.): 84 technical non compliances (of 583 measured 
equipment)
*   Radio (art.3.2.) : 434 technical non compliances (of 1755 measured 
equipment)
*   Technical documentation: 276 non compliances (of 651 inspected 
equipment)
*   Test reports: 236 non compliances (of 603 inspected equipment)
*   Drawings and explanations: 47 non compliances (of 212 inspected 
equipment)
*   Other elements: 79 non compliances (of 326 inspected equipment)

Regan

 

On Mon, Oct 29, 2018 at 4:47 PM Charlie Blackham mailto:char...@sulisconsultants.com> > wrote:

Regan

 

Market enforcement reports from the various “AdCos”, Administrative Cooperation 
Groups, can be found at 
http://ec.europa.eu/growth/single-market/goods/building-blocks/market-surveillance/organisation/administrative-cooperation-groups_en
 under the “Documents from the AdCo Groups)

 

As well as a number of reports on EMC, you may wish to look at the R/RED 
ones as well

 

Regards

Charlie 

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:  

 www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: Regan Arndt mailto:reganar...@gmail.com> > 
Sent: 29 October 2018 23:34
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] CE non-conformity statistics

 

Greetings fellow members,

 

Out of curiosity, has anyone been privy to any recent EU statistics for those 
manufacturers who have been subjected to customs investigations pertaining to 
CE marking, penalties, sales bans, etc. due to, not only selling an unsafe 
product but, having no CE marking on product, no DoC, insufficient technical 
files, non-compliance to the directives, etc?

The only thing I can find on the web that has something close is from Yvonne 
Halpaus of QNET, LLC where she recently published a guide on CE marking in 
2015. An excerpt is below:

Findings in earlier reports show that 37,600 items of equipment tested in 
Switzerland showed 1,100 cases of CE Conformity problems. Of 3,962 items that 
were subjected to rigorous measurements, a high proportion of the devices were 
found defective (976 altogether) and that none of these met the EMC specified 
requirements. 

In 23 cases a sales ban was imposed and legal proceedings were launched. Two 
other Member States also revealed problems when testing against the EMC & 
Machinery Directive: 33% failed the EMC tests, 47% did not meet the Machinery 
Directive formal rules and 89% had technical non-conformities. 

These negative findings were not the result of regular surveillance mechanisms, 
58% was based on examinations triggered by accidents, 33.3% following 
inspection of 

Re: [PSES] How to lose another million dollars

[Pete Perkins]

James,  Oh yes, I have another real life story.  In dealing with the
compliance issues on a product I recommended that they run a pre-compliance
EMC check and the chief electrical engineer rebutted that it was so
straightforward that they would do that last, just before releasing the
product to marketing.  His position was that this is basic engineering stuff
and any competent design engineer would get it right to begin with or a
simple fix would take care of it.With a little backpressure the pre-scan
was done and the product failed miserably.  Needless to say, it took a
number of trials to get it all properly fixed to pass; the release date was
missed and the chief electrical engineer lost his job over it.  So we see:
lunacy runs both ways.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: James Pawson (U3C)  
Sent: Friday, September 14, 2018 8:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] How to lose another million dollars

 

Hi John,

Is this an actual true story? I'm lost for words...

James

 

From: John Woodgate mailto:j...@woodjohn.uk> > 
Sent: 14 September 2018 12:57
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] How to lose another million dollars

 

Prepare for sob story. Company X has implemented the sensible policy of
making the project leader internally responsible for EMC and safety
compliance, i.e., when the product is tested by the compliance experts, it
passes or has only minor defects. 

So John Doe takes his engineering model, scheduled for production in 9
months time to Compliance and asks for pre-compliance checks. No can do, is
the reply. Our new policy is that only products whose planned release date
is 4 months or less ahead can be checked.

Truly, nothing is fool-proof because Nature keeps producing more and more
ingenious fools.

-- 
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk  
Rayleigh, Essex UK

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Re: [PSES] hot laptop

[Pete Perkins]

Dave et al,

 

   This is an ongoing issue.  TC108 worked to update the accessible 
temperature requirements in 62368-1 in the early 2000s based upon reports in 
the popular news of similar incidents.  I reviewed this in a PSES 2004 
presentation which was later converted to an article in the  PSE News, 
15v11No2.  The technical basis for reasonable requirements were drawn from 
earlier work done as discussed in the paper.  You can find this paper by 
searching for it by name online: ‘Ouch Hot Laptop’.  

   Enjoy the reading upon your new laptop (which, as stated, an 
attempt was made to rename these as notebooks to steer away from similar claims 
– but the popular name returns).  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: Nyffenegger, Dave  
Sent: Thursday, August 16, 2018 11:47 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] hot laptop

 

That’s in the plan.  This one slows down apparently when it’s not too busy.  If 
it’s just the OS running with no programs it’s cool as can be.  But if I wanted 
a laptop to only do one thing at a time I’d use MS-DOS.  With several programs 
running and multiple browsers with multiple windows it runs the CPU full out 
regardless of temp.

-Dave

 

From: Richard Nute [mailto:ri...@ieee.org] 
Sent: Thursday, August 16, 2018 2:42 PM
To: Nyffenegger, Dave; EMC-PSTC@LISTSERV.IEEE.ORG 
 
Subject: hot laptop

 

 

Get a new laptop.  Intel devices now slow down if they get too hot.  My new 
laptop barely gets warm.

Rich

 

 

From: Nyffenegger, Dave mailto:dave.nyffeneg...@bhemail.com> > 
Sent: Thursday, August 16, 2018 7:35 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] CB Certificate For Samsung Tablet - Need Contact

 

I’d like to ask the same question of my “name brand” laptop with the same 
circumstances.  The CPU runs just under 100 degrees F according to Intel 
diagnostics and the case bottom runs hot enough it can’t actually sit on a lap.

 

-Dave

 

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Re: [PSES] hipot test

[Pete Perkins]

Doug,You are correct in that the issues we are dealing with are a part of 
the Low Voltage installation (up to 600Vac and 1000Vdc in North America, higher 
in Europe) wherein all of the common equipment resides.  

 

   Having been a part of the US/TAG to IEC SC28A and now IEC 109 
technical committees I am quite familiar with Insulation Coordination in Low 
Voltage equipment.  

 

   The issues are exacerbated with voltage.  Medium voltage 
distribution (about 12kV to 75kV or so) has its own issues and Hi Voltage 
transmission (above 75kV to 1MV here in the US) even more issues.  The IEEE 
transactions on Dielectrics have continuously dealt with these issues over the 
years.  Hopefully you have tried to keep up. 

 

   Dr Klaus Stemper, as chairman, brought technical discipline to 
the work resulting in substantial improvement in the IEC 60664 series (it was 
one volume when I started).  It also brought a lot of complexity which the 
follow-on teams have tried to again simplify for ease of use.  

 

   Thanx for the chance to reminisce.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: Doug Powell  
Sent: Wednesday, August 15, 2018 1:40 PM
To: Pete Perkins ; EMC-PSTC 
Subject: Re: [PSES] hipot test

 

Pete,

 

Your statements may be true for many product types certified to 60950-1, 
61010-1, etc.  However when dealing with power conversion products that have 
secondary voltages well above mains voltages, this is no longer true.  In the 
region of 5,000 V and above, corona is a common occurrence in inhomogeneous 
fields and this has the effect of causing surface damage (carbonization) on 
insulation with any organic content.  Inorganic insulators such as ceramics and 
glass seem to be much less affected.  

 

Such phenomena is mentioned in Klaus Stimper's book, The Physical Fundamentals 
of Low-Voltage Insulation Co-ordination.

 

All the best,  Doug

 

 

 

On Wed, Aug 15, 2018 at 10:04 AM Pete Perkins 
<0061f3f32d0c-dmarc-requ...@ieee.org 
<mailto:0061f3f32d0c-dmarc-requ...@ieee.org> > wrote:

All, This discussion goes around  year after year.  

 

   The test results reported – especially Nute – show that it takes 
dozens, maybe  hundreds of hipot tests to damage adequate insulation.  

 

   In the UK, so I hear, the gov’t safety folks expect each piece 
of equipment to be hipot retested annually to demonstrate adequate insulation.  
We don’t hear a large hue and cry about failing equipment in that arena.  

 

   So from the experience and the data it is clear that both the 
engineering type hipot testing and the factory routine testing should not pose 
any problem to properly designed and manufactured products.  

 

   For line connected products it is foolishness to remove 
components for hipot testing.  If that is being done the product is not robust 
enough in the first place.  This includes DC line powered equipment since so 
much DC power is being installed and used in places where it is subject to the 
same lighting and starting impulses traditionally seen on AC line operated 
equipment.   

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: Jim Hulbert mailto:jim.hulb...@pb.com> > 
Sent: Wednesday, August 15, 2018 5:25 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] hipot test

 

I disagree with your NRTL.  If the hipot test can degrade the insulation (we’re 
talking about a single test on the production line), then the insulation system 
is not up to par.  

 

Jim


 

 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Wednesday, August 15, 2018 12:18 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] hipot test

 

The NRTL I typically use always runs the hipot test for 60 seconds for type 
testing during product certification.  The listing reports always specify a 1 
second hipot for production line testing 100% of all units.  Their claim is 
that the hipot can degrade some insulation and should be kept to a minimum.

 

-Dave

 

From: Richard Nute [mailto:ri...@ieee.org] 
Sent: Tuesday, August 14, 2018 5:34 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] hipot test

 

 

Hi Doug:

 

I've always viewed the purpose of hipot testing as verification only.  During 
engineering type testing, it is design verification. 

 

I disagree.  The hi-pot test determines the minimum elect

Re: [PSES] hipot test

[Pete Perkins]

John, your description sounds much like the failure mechanism seen is 
circuit boards which start in a small void and develop micro-arcing which feeds 
upon itself and eventually drives a large void that allows conductors to 
directly contribute current and destroy the board.  I’ve investigated some 
destructive fires in equipment from such a source. And the circuit boards don’t 
need full hipot voltages to do this, line operated units eat themselves up 
quite handily.   

   No, I don’t mean to start anew thread here.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: John Woodgate  
Sent: Wednesday, August 15, 2018 12:17 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] hipot test

 

I think it's not quite like that. Modern insulating materials don't degrade, 
but old ones did, or at least appeared to. For instance, oiled paper had 
pinholes, and a discharge caused local carbonization, which prompted more 
discharges and more carbonization.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk  
Rayleigh, Essex UK

On 2018-08-15 18:07, Richard Nute wrote:

 

Their claim is that the hipot can degrade some insulation and should be kept to 
a minimum.

 

Conventional wisdom not supported by science.

 

Best regards,

Rich

 

 

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Re: [PSES] hipot test

[Pete Perkins]

John, thanx for your note on this.  I’m not surprised that the WWW is wooly 
on this subject.  My sources for this are from my experience – with my former 
employer who had two UK shops producing products and had to deal with this 
issue as well as feedback from clients that I have had along the way in my 
consultancy who were caught up in this issue.  In either case it all seemed to 
be quite bureaucratic and inflexible when it got to the factory floor during 
HSW inspections.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: John Woodgate  
Sent: Wednesday, August 15, 2018 12:14 PM
To: Pete Perkins ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] hipot test

 

in the UK, the requirements are in fact very woolly, and it's difficult to find 
definitive information on the Web. But testing doesn't have to be done 
annually, and hi-pot only in cases of repair of hired-out equipment.  
Unfortunately, insulation resistance testing, with PASS values even below 1 
megohm in some cases, is included.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2018-08-15 17:03, Pete Perkins wrote:

All, This discussion goes around  year after year.  

 

   The test results reported – especially Nute – show that it takes 
dozens, maybe  hundreds of hipot tests to damage adequate insulation.  

 

   In the UK, so I hear, the gov’t safety folks expect each piece 
of equipment to be hipot retested annually to demonstrate adequate insulation.  
We don’t hear a large hue and cry about failing equipment in that arena.  

 

   So from the experience and the data it is clear that both the 
engineering type hipot testing and the factory routine testing should not pose 
any problem to properly designed and manufactured products.  

 

   For line connected products it is foolishness to remove 
components for hipot testing.  If that is being done the product is not robust 
enough in the first place.  This includes DC line powered equipment since so 
much DC power is being installed and used in places where it is subject to the 
same lighting and starting impulses traditionally seen on AC line operated 
equipment.   

 

:>) br,  Pete

 


 

 

 

 


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Re: [PSES] hipot test

[Pete Perkins]

Ken,   I agree.  But there is a lot of equipment being provided in a DC
operated environment where the nuisance transients exist.  I'm thinking, for
instance, of Solar and Wind-power installations which are often remote and
self-power all of the control and transmission equipment off of the exposed
internal DC power.  Hence my statement.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: Ken Javor  
Sent: Wednesday, August 15, 2018 9:34 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] hipot test

 

There is a huge difference between a transient lasting microseconds and a dc
application. The cap will load (to some extent) a transient, but it can't
load dc.

Ken Javor
Phone: (256) 650-5261




  _____  

From: Pete Perkins <0061f3f32d0c-dmarc-requ...@ieee.org
<mailto:0061f3f32d0c-dmarc-requ...@ieee.org> >
Reply-To: Pete Perkins mailto:peperkin...@cs.com> >
Date: Wed, 15 Aug 2018 09:03:57 -0700
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Subject: Re: [PSES] hipot test

All, This discussion goes around  year after year.  
 
   The test results reported - especially Nute - show that it
takes dozens, maybe  hundreds of hipot tests to damage adequate insulation.

 
   In the UK, so I hear, the gov't safety folks expect each
piece of equipment to be hipot retested annually to demonstrate adequate
insulation.  We don't hear a large hue and cry about failing equipment in
that arena.  
 
   So from the experience and the data it is clear that both the
engineering type hipot testing and the factory routine testing should not
pose any problem to properly designed and manufactured products.  
 
   For line connected products it is foolishness to remove
components for hipot testing.  If that is being done the product is not
robust enough in the first place.  This includes DC line powered equipment
since so much DC power is being installed and used in places where it is
subject to the same lighting and starting impulses traditionally seen on AC
line operated equipment.   
 

:>) br,  Pete
 
Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427
 
503/452-1201
 
IEEE Life Fellow
p.perk...@ieee.org <mailto:p.perk...@ieee.org>   <mailto:p.perk...@ieee.org>
<mailto:p.perk...@ieee.org> 
 

From: Jim Hulbert mailto:jim.hulb...@pb.com> > 
Sent: Wednesday, August 15, 2018 5:25 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] hipot test
 
I disagree with your NRTL.  If the hipot test can degrade the insulation
(we're talking about a single test on the production line), then the
insulation system is not up to par.  
 
Jim



From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Wednesday, August 15, 2018 12:18 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] hipot test
 
The NRTL I typically use always runs the hipot test for 60 seconds for type
testing during product certification.  The listing reports always specify a
1 second hipot for production line testing 100% of all units.  Their claim
is that the hipot can degrade some insulation and should be kept to a
minimum.
 
-Dave
 

From: Richard Nute [mailto:ri...@ieee.org] 
Sent: Tuesday, August 14, 2018 5:34 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] hipot test

 
Hi Doug:
 
I've always viewed the purpose of hipot testing as verification only.
During engineering type testing, it is design verification. 

I disagree.  The hi-pot test determines the minimum electric strength of the
insulation system.  Design is an indirect measure of electric strength by
selecting the distances through solid and air (clearance) insulations.
However, design rarely includes the shape of the electric field, which is a
parameter that determines electric strength.  
 
Since hipot is so stressful to insulation.

Again, I disagree.  If the design is "good" (adequate electric strength),
then the hi-pot test does not stress the insulation system.  See Agilent
Technologies Optocoupler Input-Output Endurance Voltage Application Note
1074.
 
Best regards,
Rich
 
 
 
From: Doug Powell mailto:doug...@gmail.com> > 
Sent: Tuesday, August 14, 2018 1:50 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] X & Y Cap rating due to hipot test
 

I've always viewed the purpose of hipot testing as verification only.
During engineering type testing, it is design verification.  During routine
testing for manufacturing, it is workmanship and build verification.  



During type testing many safety standards

Re: [PSES] hipot test

[Pete Perkins]

All, This discussion goes around  year after year.  

 

   The test results reported – especially Nute – show that it takes 
dozens, maybe  hundreds of hipot tests to damage adequate insulation.  

 

   In the UK, so I hear, the gov’t safety folks expect each piece 
of equipment to be hipot retested annually to demonstrate adequate insulation.  
We don’t hear a large hue and cry about failing equipment in that arena.  

 

   So from the experience and the data it is clear that both the 
engineering type hipot testing and the factory routine testing should not pose 
any problem to properly designed and manufactured products.  

 

   For line connected products it is foolishness to remove 
components for hipot testing.  If that is being done the product is not robust 
enough in the first place.  This includes DC line powered equipment since so 
much DC power is being installed and used in places where it is subject to the 
same lighting and starting impulses traditionally seen on AC line operated 
equipment.   

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: Jim Hulbert  
Sent: Wednesday, August 15, 2018 5:25 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] hipot test

 

I disagree with your NRTL.  If the hipot test can degrade the insulation (we’re 
talking about a single test on the production line), then the insulation system 
is not up to par.  

 

Jim


 

 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Wednesday, August 15, 2018 12:18 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] hipot test

 

The NRTL I typically use always runs the hipot test for 60 seconds for type 
testing during product certification.  The listing reports always specify a 1 
second hipot for production line testing 100% of all units.  Their claim is 
that the hipot can degrade some insulation and should be kept to a minimum.

 

-Dave

 

From: Richard Nute [mailto:ri...@ieee.org] 
Sent: Tuesday, August 14, 2018 5:34 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] hipot test

 

 

Hi Doug:

 

I've always viewed the purpose of hipot testing as verification only.  During 
engineering type testing, it is design verification. 

 

I disagree.  The hi-pot test determines the minimum electric strength of the 
insulation system.  Design is an indirect measure of electric strength by 
selecting the distances through solid and air (clearance) insulations.  
However, design rarely includes the shape of the electric field, which is a 
parameter that determines electric strength.  

 

Since hipot is so stressful to insulation…

 

Again, I disagree.  If the design is “good” (adequate electric strength), then 
the hi-pot test does not stress the insulation system.  See Agilent 
Technologies Optocoupler Input-Output Endurance Voltage Application Note 1074.

 

Best regards,

Rich

 

 

 

From: Doug Powell mailto:doug...@gmail.com> > 
Sent: Tuesday, August 14, 2018 1:50 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] X & Y Cap rating due to hipot test

 

I've always viewed the purpose of hipot testing as verification only.  During 
engineering type testing, it is design verification.  During routine testing 
for manufacturing, it is workmanship and build verification.  

 

During type testing many safety standards will ask for hipot verification at 
various stages, after thermal/humidity tests, after abnormal operations, etc.  
Since hipot is so stressful to insulation, it is possible to introduce latent 
failures in the test sample after performing multiple hipot tests, combining 
many hipots into one is allowable by many inspectors.  

 

During routine testing, a brief hipot is added at the end of the manufacturing 
cycle to ensure wire routing is correct (spacings are maintained), integrity of 
insulation is maintained, in cases where vibration testing is involved a test 
for chafing of wire insulation and so on.  Most safety standards have provision 
for "allowable disconnects" during the hipot such as surge suppressors and the 
like.  Also, hipot of sub-assemblies in lieu of the finished assembly if it can 
be shown that the test is representative.  

 

Best to all, Doug

 

-- 

 

Douglas E Powell

doug...@gmail.com  
http://www.linkedin.com/in/dougp01

 

-


This message is from the IEEE Product Safety Engineering Society emc-pstc 
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[PSES] CE marking of machinery that moves about

[Pete Perkins]

Colleagues, I've been dealing with CE marking of machinery for some
time but now am interested in a variation on that theme, machinery that
moves.  Think of a fork-lift or front loader each of which lifts a load and
moves it before setting it down again.  What additional requirements are
placed upon such a machine.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

p.perk...@ieee.org  

 


-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
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 at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
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For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] Safety design of shutter opening

[Pete Perkins]

Scott,

 

In watching this thread it is clear that the technical 
assessment and the regulatory certification are two separate issues but linked 
by local law so we need to be cognizant of the regulatory environment.  

 

The technical assessment (per the standard) is organized by an 
ongoing group of (fallible) folks who work very hard to cover all of the risks 
(usually) from the product manufacturers point of view (since they seem to 
dominate the technical committees).  Since the requirements are usually written 
in retrospect from experience and, usually, not organized in a top down 
approach (using the usual risk assessment tools – FMEA, etc) it is incomplete 
is some (usually) unexpected ways – as you have discovered.  When exposed, the 
standards committee then scrambles to fill the hole identified.  This is a 
never ending process, approaching perfection asymptotically.  

All this ignores the clever manufacturer who seeks out these holes and makes 
use of them to gain advantage in some way. 

 

The regulatory certification reflects the level of development 
of the National bureaucracy responsible for setting requirements.  
Additionally, the lobbying of legislators and bureaucrats by special interest 
groups affects the final rules applied.  So it ends up being a patchwork of 
requirements that need to be applied by the manufacturer.  

John Woodgate assures us that the world is happy with the UK approvals; check 
it out carefully.  Oh yes, a question – does Hong Kong or Singapore still use 
the British plug design?  What residual of this usage is still left in the 
world?   

 

All of this is the reason that you and I (and most of the 
others on this net) have a meaningful job – once we get a little experience and 
are willing to put up with the uncertainty regarding the roles of requirements 
along with the varied level of enforcement by the legal jurisdictions.  

 

You are uncomfortable with this hole in the requirements.  When 
we feel that the requirements or the application of requirements is either too 
strict or too slack our only recourse is to get (directly or indirectly) 
involved in fixing things (in which managers and technical folks excel) by 
joining a technical committee or lobbying the political process that needs 
fixing.  

 

My advice is: pick your fights carefully and pursue them with 
all you have – personal and corporate.  You may even be successful in some of 
the efforts.  

 

So much philosophizing; good luck in fixing the world.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: Scott Xe  
Sent: Monday, July 16, 2018 9:48 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety design of shutter opening

 

Dear Johns,

 

Thanks for advice abt other countries using 13A plugs & sockets!  Do they 
require specific approved bodies for issuing certification like UK?

 

Regards,

 

Scott

 

From: John Allen <09cc677f395b-dmarc-requ...@ieee.org 
 >
Reply-To: John Allen mailto:john_e_al...@blueyonder.co.uk> >
Date: Monday, 16 July 2018 at 3:45 PM
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Subject: Re: [PSES] Safety design of shutter opening

 

Also used in Malta and Cyprus (even in “Turkish” Northern Cyprus IIRC!) – and 
then there is Gibraltar.

 

John E Allen

W. London, UK

 

From: John Mcauley [mailto:john.mcau...@cei.ie] 
Sent: 16 July 2018 01:03
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] Safety design of shutter opening

 

Hi Scott

 

Ireland uses the same plug as the UK as per I.S. 401:1997 - Safety Requirements 
For Rewireable And Non-rewireable 13A Fused Plugs.

 

IS 401 is the equivalent of BS 1363.

 

Interesting issue about plugs being able to be inserted upside down in some 
extension sockets. 

 

John McAuley 

 

 

From: Scott Xe mailto:scott...@gmail.com> > 
Sent: 15 July 2018 23:32
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] Safety design of shutter opening

 

Thank you for the clarification. 

 

On Mon, 16 Jul 2018, 12:47 am John Woodgate, mailto:j...@woodjohn.uk> > wrote:

GPS applies to anything; that's why is called 'General...'. Anything can fall 
within more than one Directive, in fact all electrical products fall within 
both LVD and EMCD, as well as GPSD.

BS 136X connectors are used outside the UK; the EU is not relevant to that.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk  
Rayleigh, Essex UK

On 2018-07-15 17:33, Scott Xe wrote:

The product is for UK market only since 13A rectangular pins.  I believe only 
UK uses this type 

Re: [PSES] RED products in EMC compliance part

[Pete Perkins]

Scott,I’m not quite that hard-nosed on this issue.  I have 
recommended that manufacturer’s choose the best available path knowing that the 
 EU bureaucrats will move the goal posts again on us.  So I would say, use 
harmonized standards when it is clear that they are designated to apply else 
use tried and true methods when there is confusion and wait for clarity from 
the system.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: Scott Xe  
Sent: Thursday, June 21, 2018 8:58 AM
To: Pete Perkins 
Cc: EMC-PSTC@listserv.ieee.org
Subject: Re: [PSES] RED products in EMC compliance part

 

Pete,

 

Both you and Charlie share the esteemed and fair opinions that using other than 
harmonised standards is not a wise decision although it is allowed by the 
directive.  I have the same perception since we have no control in this route 
due to limited knowledge.  Will see how to stick to harmonised standards.

 

The test lab insisted on that EN 55020 is till valid in demonstrating EMC 
compliance although RED already has a new harmonised standard and it disappears 
in EMC list.  So far both the test lab and we cannot find any support to this 
claim.

 

Regards,

 

Scott

 

 

On 21 June 2018 at 23:18, Pete Perkins mailto:peperkin...@cs.com> > wrote:

Scott et al,

 

   Charlie is right; no matter what promise you get from your 3rd 
party NB they are not in ultimate control.  You, as manufacturer, are at the 
mercy of the regulators.  It is important for you & your company to keep the 
heat on so that there is a reasonable expectation that the work that has been 
done will be acceptable moving ahead.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: Scott Xe mailto:scott...@gmail.com> > 
Sent: Thursday, June 21, 2018 7:25 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 


Subject: Re: [PSES] RED products in EMC compliance part

 

Hi Charlie,

 

Many thanks for your kind advice!!

 

As the conformity review of this product is required by a NB, it is quite 
difficult to challenge their result due to their status but we can require them 
to issue a confirmation of continual compliance with the latest essential 
requirements of RED on the repeat orders.

 

Regards,

 

Scott

 

On 21 June 2018 at 02:46, Charlie Blackham mailto:char...@sulisconsultants.com> > wrote:

Scott

 

I understand the issue you describe, however it should be remembered that:

*   The manufacturer is always responsible , whoever advises them. If they 
are going to ask a 3rd party (lab or consultant) then they should satisfy 
themselves that the advice is correct, perhaps by asking what the 
recommendation is based on.
*   A test lab cannot issue a “Declaration of Conformity” only a 
manufacturer (or suitably contracted representative) can do that – test labs 
should (only) issue “Certificates of Conformity” as a summary of test results, 
which are not the same thing
*   Copying someone else who got it wrong isn’t much of a defence

 

In my experience, you should be prepared for challenges from market 
surveillance if you don’t apply Harmonised Standards (but whether you actually 
get challenged may be down to luck and whether your product type has been 
selected for market surveillance activity)

 

Regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:  
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>
 www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: Scott Xe mailto:scott...@gmail.com> > 
Sent: 20 June 2018 17:31
To: Charlie Blackham mailto:char...@sulisconsultants.com> >
Cc: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] RED products in EMC compliance part

 

Hi Charlie,

 

Understand that the manufacturer is free to choose any conformity assessment to 
meet the essential requirements for EMC without using a Notified Body.  However 
the manufacturer must have expert in this area to provide the appropriate 
advice.  Most of oem manufacturers lack of such luxury resource and reply on 
renowned test houses to do it for them.  Can we use the declaration of 
conformity from the test lab for selecting the right test standards for EMC 
part even those standards are not in RED and EMC harmonized lists.  Would we 
receive extra challenges from the market surveillances due to the fact that we 
use non harmonized standards.

 

Thanks and

Re: [PSES] RED products in EMC compliance part

[Pete Perkins]

Scott et al,

 

   Charlie is right; no matter what promise you get from your 3rd 
party NB they are not in ultimate control.  You, as manufacturer, are at the 
mercy of the regulators.  It is important for you & your company to keep the 
heat on so that there is a reasonable expectation that the work that has been 
done will be acceptable moving ahead.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: Scott Xe  
Sent: Thursday, June 21, 2018 7:25 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RED products in EMC compliance part

 

Hi Charlie,

 

Many thanks for your kind advice!!

 

As the conformity review of this product is required by a NB, it is quite 
difficult to challenge their result due to their status but we can require them 
to issue a confirmation of continual compliance with the latest essential 
requirements of RED on the repeat orders.

 

Regards,

 

Scott

 

On 21 June 2018 at 02:46, Charlie Blackham mailto:char...@sulisconsultants.com> > wrote:

Scott

 

I understand the issue you describe, however it should be remembered that:

*   The manufacturer is always responsible , whoever advises them. If they 
are going to ask a 3rd party (lab or consultant) then they should satisfy 
themselves that the advice is correct, perhaps by asking what the 
recommendation is based on.
*   A test lab cannot issue a “Declaration of Conformity” only a 
manufacturer (or suitably contracted representative) can do that – test labs 
should (only) issue “Certificates of Conformity” as a summary of test results, 
which are not the same thing
*   Copying someone else who got it wrong isn’t much of a defence

 

In my experience, you should be prepared for challenges from market 
surveillance if you don’t apply Harmonised Standards (but whether you actually 
get challenged may be down to luck and whether your product type has been 
selected for market surveillance activity)

 

Regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:  

 www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: Scott Xe mailto:scott...@gmail.com> > 
Sent: 20 June 2018 17:31
To: Charlie Blackham mailto:char...@sulisconsultants.com> >
Cc: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] RED products in EMC compliance part

 

Hi Charlie,

 

Understand that the manufacturer is free to choose any conformity assessment to 
meet the essential requirements for EMC without using a Notified Body.  However 
the manufacturer must have expert in this area to provide the appropriate 
advice.  Most of oem manufacturers lack of such luxury resource and reply on 
renowned test houses to do it for them.  Can we use the declaration of 
conformity from the test lab for selecting the right test standards for EMC 
part even those standards are not in RED and EMC harmonized lists.  Would we 
receive extra challenges from the market surveillances due to the fact that we 
use non harmonized standards.

 

Thanks and regards,

 

Scott

 

On 21 June 2018 at 00:12, Charlie Blackham mailto:char...@sulisconsultants.com> > wrote:

Scott

 

EN 55035 is the (only) article 3.1(b) EMC standard that is Harmonised for 
broadcast receivers under the RED.

 

As per RED article 17, the manufacturer is free to choose any conformity 
assessment to meet the essential requirements for EMC without using a Notified 
Body, but:

*   Your approach to EMC needs to be considered in your Risk Assessment 
(whether or not a Harmonised Standard is applied)
*   Market enforcement and customs would “expect” to see Harmonised 
Standards such as EN 55035:2017 listed on the DoC

 

If the DAB radio contains Bluetooth then EN 301 489-1 and -17 would also apply, 
though these won’t be in the OJ until Q4 2017 or Q1 2018

 

Regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:  

 www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: Scott Xe mailto:scott...@gmail.com> > 
Sent: 20 June 2018 16:05
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] RED products in EMC compliance part

 

Dear All,

 

We have a DAB radio with BT speaker.  It held NB a cert using EN 55032 : 2015,  
EN 55020 : 2007 + A12 : 2016, ….  for EMC part compliance last year.  Currently 
we are reviewing the continual compliance.  It is discovered that both EN 55032 
and EN 55020 disappears in the latest list of EMC harmonized standard list.  In 

Re: [PSES] UL Listing of Computer Keyboard

[Pete Perkins]

Brian,  I always appreciate your comments based upon your experience and your 
enthusiastic cynicism toward life.  
Altho I tried to separate the variables it appears that I did not do it 
sufficiently.  In my prior post I allowed as how the certification expenses are 
on a product or product family basis including associated certificate costs.  
The FUS, however, is based upon factory location and by similar equipment group 
(e.g. UL Efile #s); the inspection is based upon looking at something in each 
equipment group so not every product type is examined each FUS Qtly visit.  
Further the inspection time/cost is fixed so that the FUS cost to the mfgr is 
spread out over the units produced , whether a single product or several 
related products and includes the volume (not from the inspectors point of view 
but from the mfgrs bean counter point of view).  My example pointed to this 
type of scenario.  Perhaps this provides more clarification.  

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

IEEE Life Fellow
p.perk...@ieee.org

-Original Message-
From: Brian O'Connell  
Sent: Tuesday, June 19, 2018 10:43 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UL Listing of Computer Keyboard

FUS audit and certification and license costs are not necessarily able to be 
distributed over a larger production number; will depend on the particular 
NRTL/SCC.

For many product combinations,  there is no cost efficiency for volume or for 
factory consolidation for the respective 'regulatory' remit. The agencies will 
always find a way to structure fees and processes to extract maximum dollars 
and minimize engineering time. That is, for any given agency, invoiced line 
items will always increase, while provided services will always decrease.

Doubleplusgood. Less is more.

Brian
Senior News Reviewer of Oceania


From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org]
Sent: Tuesday, June 19, 2018 8:56 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UL Listing of Computer Keyboard

James,

   As an American I’m not privy to the inner workings of making the 
sausage called EU Directives.  However, there is a political process involved 
an all of this work and I’m sure that manufacturers and political regulators 
pushed back and forth to get to the final result for the update to the LVD.  I 
agree with your assessment that companies don’t want the extra cost of type 
approval and have prevailed at this point for this set of circumstances.  

   Somewhat related comment; since your keyboard is USB powered you 
need to understand that USB, like POE, is going to higher power delivery – 100W 
coming for USB3.  There are additional issues that need to be addressed and IEC 
62368-3 addresses power over communication cables no matter what the product 
type is; products using such comm cables will need to be assessed to ensure 
that they provide the proper protection coming and going when attached to these 
common outlet sockets.  Again, NRTL certification is appropriate for evaluating 
this equipment.  

   Finally, yes, these NRTL certifications are on a product by 
product basis; you can bunch similar models into one certification report tho.  
From experience, the FUS unit cost decreases as there is more product produced. 
 Increasing the volume of either a product model or adding more similar models 
will drive down the unit cost as the inspection time is spread over more models 
and units.  For instance for your 1K dollars/Euros or whatever, if the factory 
only produces a single unit per inspection quarter then that unit eats the 
entire cost; if the factory produces 10K units per inspection quarter then the 
unit cost is quite cheap.  

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant PO Box 23427 Tigard, 
ORe  97281-3427

503/452-1201

IEEE Life Fellow
p.perk...@ieee.org

-

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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 at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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formats), large files, etc.

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-

This message is from the IEEE Product Safety Engin

Re: [PSES] UL Listing of Computer Keyboard

[Pete Perkins]

James,

 

   As an American I’m not privy to the inner workings of making the 
sausage called EU Directives.  However, there is a political process involved 
an all of this work and I’m sure that manufacturers and political regulators 
pushed back and forth to get to the final result for the update to the LVD.  I 
agree with your assessment that companies don’t want the extra cost of type 
approval and have prevailed at this point for this set of circumstances.  

 

   Somewhat related comment; since your keyboard is USB powered you 
need to understand that USB, like POE, is going to higher power delivery – 100W 
coming for USB3.  There are additional issues that need to be addressed and IEC 
62368-3 addresses power over communication cables no matter what the product 
type is; products using such comm cables will need to be assessed to ensure 
that they provide the proper protection coming and going when attached to these 
common outlet sockets.  Again, NRTL certification is appropriate for evaluating 
this equipment.  

 

   Finally, yes, these NRTL certifications are on a product by 
product basis; you can bunch similar models into one certification report tho.  
From experience, the FUS unit cost decreases as there is more product produced. 
 Increasing the volume of either a product model or adding more similar models 
will drive down the unit cost as the inspection time is spread over more models 
and units.  For instance for your 1K dollars/Euros or whatever, if the factory 
only produces a single unit per inspection quarter then that unit eats the 
entire cost; if the factory produces 10K units per inspection quarter then the 
unit cost is quite cheap.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: James Pawson (U3C)  
Sent: Tuesday, June 19, 2018 1:56 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UL Listing of Computer Keyboard

 

Hi all,

 

Thanks very much for the illuminating replies, it’s a great help. To summarise 
(and to make sure I’ve understood):

 

*   NRTL approval legally required for selling in the USA? No.
*   NRTL / UL approval expected? Highly likely.
*   NRTL approval required for use in the workplace? Yes, not legally 
required but market expectation? Or is it a legal requirement?
*   Standard used: UL 62368-1

 

@Pete Perkins: are you saying when the LVD was recast that they tried to remove 
the lower voltage limit? Presumably this didn’t happen because companies didn’t 
want the extra workload involved with extra testing / assessment?

 

Having looked at EN 62368-1, there’s not a great deal in there that applies to 
a low power device such as a USB powered keyboard so I think it’s fair to say 
that the type approval wouldn’t take a great deal of time / cost.

 

Reading http://www.productapprovals.co.uk/ul-approval.html there appear to be 
initial and regular factory inspections associated with a NRTL listing, with 
the figure of a few thousand dollars being quoted as a typical fee for 
maintaining an NRTL mark. Does this match people’s experience?

 

If the factory already has NRTL approval for manufacturing another product, 
could one piggyback onto this approval or is it on a per product basis?

 

Thanks again

James

 

 

 

 

 

From: Pete Perkins <0061f3f32d0c-dmarc-requ...@ieee.org 
<mailto:0061f3f32d0c-dmarc-requ...@ieee.org> > 
Sent: 19 June 2018 00:27
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] UL Listing of Computer Keyboard

 

Dave, et al,

 

   I think that you are simplifying the discussion too much.  
Certainly a wall-wart with an ELV output is not an electric shock hazard but 
that is no guarantee that any NRTL wall-wart power supply will not start a fire 
in any device which it powers; that can only be determined by inspection and 
testing.  

 

James, is your keyboard wireless?  

 

   The EU has long had an ELV exclusion for equipment under the 
LVD.  But, because of the issue raised here, there was an effort to remove that 
in the last update to the LVD which, unfortunately, failed.  So a partial fix 
is that if a device has a radio in it must meet the Radio Equipment Directive 
and that RED Directive encompasses all of the hazards such that the electrical 
safety standards used under the LVD now apply except that the ELV exclusion is 
eliminated; a step in the right direction, I believe.  (So the LVD is not 
invoked of itself when meeting the RED directive but the appropriate safety 
standard is.)  

   Now it is obvious why Rich Nute’s Bluetooth mouse bears 
appropriate safety marks.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety &

Re: [PSES] UL Listing of Computer Keyboard

[Pete Perkins]

Dave, et al,

 

   I think that you are simplifying the discussion too much.  
Certainly a wall-wart with an ELV output is not an electric shock hazard but 
that is no guarantee that any NRTL wall-wart power supply will not start a fire 
in any device which it powers; that can only be determined by inspection and 
testing.  

 

James, is your keyboard wireless?  

 

   The EU has long had an ELV exclusion for equipment under the 
LVD.  But, because of the issue raised here, there was an effort to remove that 
in the last update to the LVD which, unfortunately, failed.  So a partial fix 
is that if a device has a radio in it must meet the Radio Equipment Directive 
and that RED Directive encompasses all of the hazards such that the electrical 
safety standards used under the LVD now apply except that the ELV exclusion is 
eliminated; a step in the right direction, I believe.  (So the LVD is not 
invoked of itself when meeting the RED directive but the appropriate safety 
standard is.)  

   Now it is obvious why Rich Nute’s Bluetooth mouse bears 
appropriate safety marks.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: Nyffenegger, Dave  
Sent: Monday, June 18, 2018 1:15 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UL Listing of Computer Keyboard

 

This is generally true however there are plenty of examples of products for 
sale as well as those used in the workplace that are simple in nature and/or 
non-hazardous and do not carry an NRTL mark.  For example, the stapler on your 
desk or even the phone on your desk.  If it plugs into a power outlet in the 
wall it needs NRTL.  A computer keyboard could have one but is it really 
needed?  The main reason a lot of OEMs use wall warts is they NRTL certify the 
wall wart (or more likely source one from another OEM) but not the product that 
it supplies power to as it doesn’t need it.

 

-Dave

 

From: Monrad Monsen [mailto:monrad.mon...@oracle.com] 
Sent: Monday, June 18, 2018 12:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] UL Listing of Computer Keyboard

 

Hi James, 

Please note that the OSHA Nationally Recognized Test Laboratory (NRTL) will 
verify your product to UL62368-1 standard (based on international IEC62368-1). 
The OSHA regulation mandates that employers provide a safe working environment 
for employees (and local building codes support those requirements) plus retail 
stores don’t want to be sued for selling unsafe products if someone is harmed 
or property damaged, so neither employers nor retail stores will buy or re-sell 
a product that does not have a NRTL approval. As Darren notes, NRTL labs are 
not just UL but also CSA, TUV Rheinland, TUV Sud, ETL (Intertek), Nemko, etc. A 
full listing is at the web page below:

https://www.osha.gov/dts/otpca/nrtl/nrtllist.html

 

Hope this helps.

Monrad 

 

Sent from my iPhone


On Jun 18, 2018, at 3:03 AM, CATHERINE PEARSON 
<0b0df63784fb-dmarc-requ...@ieee.org 
 > wrote:

Hi James,

 

Is UL listing mandatory for IT accessories like keyboards? 
No any NRTL certification will be sufficient, but that may not be the question 
or answer !

 

Depending where you are selling the equipment, they may expect a certain 
certification mark, 
Ive gotten many approvals for the USA market  but its the customer who needs to 
understand the requirements. 

I had explained to my customer that they can have any suitable certification 
mark and it will meet the requirements, TUV, CSA, UL etc 
However once they were selling the device, there customer would ask "Wheres the 
UL mark" 
there customer was not technical and didn't understand or care to understand 
there were alternatives, just "Wheres the UL mark" 

Ive also found this with the building inspectors who should know better ! 

 

So for that job, nothing but UL would do. 
In answer to "some retailers use it as a minimum requirement for stocking your 
products"
Yes thats correct and you dont have much chance in convincing them to do 
anything else. 
I've been discussing this with the alternative approval bodies for a while, 
that they need to improve the general public view of them so more people 
understand that UL are only one of a number of options. 

 

Ive worked with many approval bodies, some better than others, some not, 
but as a general rule, avoid the customer service agents and deal straight with 
the engineer at the testing lab and the person whos dealing with the approval.  

 

I have to mention my current experience with UL is very good, but then ive 
found myself a number of responsive people who reply to your Emails and are 
happy to discuss the project with you.


10 years ago, it was a lot 

Re: [PSES] Mains Conducted rf emissions measurements

[Pete Perkins]

Ian,

 

Altho you haven't identified the source of the noise it
certainly is due to switching equipment upstream from your lab within you
building; VSDs are very noisy at lower frequencies.  

 

I recommend that you look for an electric motor-generator
unit to power your lab.  This should be much cleaner than any switching
source.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: McBurney, Ian  
Sent: Friday, April 27, 2018 1:11 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Mains Conducted rf emissions measurements

 

Hello Ari.

 

I'm considering hiring an ac source to power the LISN but my only concern
would be that the ac source has high conducted rf emissions as I assume the
ac is derived from high frequency switching power devices.

 

regards 

 

Ian McBurney

Lead Compliance Engineer.

 

Allen & Heath Ltd.

Kernick Industrial Estate,

Penryn, Cornwall. TR10 9LU. UK

T: 01326 372070

E: ian.mcbur...@allen-heath.com  

 

 

From: Ari Honkala [mailto:ari.honk...@sesko.fi] 
Sent: 26 April 2018 17:22
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] Mains Conducted rf emissions measurements

 

As an interim solution, until you get the source fixed, would be to use UPS
on battery.

 

with best regards,

 

Ari Honkala

 

From: McBurney, Ian [mailto:ian.mcbur...@allen-heath.com] 
Sent: torstai 26. huhtikuuta 2018 13:33
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Mains Conducted rf emissions measurements

 

Dear Colleagues.

 

I am setting up a mains conducted rf emissions measuring system and am
experiencing excessive mains noise when connecting the LISN to the 240V wall
socket. The noise affects my measurements between 150kHz to 400KHz. Beyond
that and up to 30MHz I am satisfied. Is there a way of filtering out this
noise. I have tried various EMI mains filter modules but none appear to
attenuate enough at that frequency band. They are very good at attenuating
frequencies beyond 1MHz. I have tried inserting an isolation transformer
before the LISN but this appears to distort the measurements.

Can anyone recommend a solution?

 

Many thanks in advance.

 

Ian McBurney

Lead Compliance Engineer.

 

Allen & Heath Ltd.

Kernick Industrial Estate,

Penryn, Cornwall. TR10 9LU. UK

T: 01326 372070

E: ian.mcbur...@allen-heath.com  

 

 

Allen & Heath Ltd is a registered business in England and Wales, Company
number: 4163451. Any views expressed in this email are those of the
individual and not necessarily those of the company. 

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Re: [PSES] EN 55032 Testing on Wired Network Port

[Pete Perkins]

All,  Been some good discussion her about the EMC issues and why or
when to test or not test.  I especially liked John Woodgate's comment that
if the emissions are well away from the limit then why bother to test; but
this does raise the issue to how would you know? And if you had to test to
know why wouldn't you run the test and include the data in your Technical
File (which amounts to running the tests anyway and showing compliance).  

 

Additionally, it needs to be pointed out that if the Wired
Network Port is using a standard connector (RJ-45, USB etc) then it has to
be shown that the port meets the appropriate safety requirements for the
usual Network.  There have been some safety requirements in 60950 for years
but these are now being updated and upgraded in 62368-3 at the insistence of
IEC ACOS to show that the port will not damage any network equipment
attached to it nor will be damaged by connecting to the standard network.
These ports are being upgraded to handle power over these communication
lines and are all moving to 100 Watts; for instance, can a person plug their
phone into your port expecting it to charge but not damage your system?.
Evaluating the ports for safety will be a requirement no matter what type of
equipment they will be used on.  

 

Expect this to be applied broadly moving ahead.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: Gert Gremmen; ce-test  
Sent: Tuesday, April 24, 2018 4:23 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 55032 Testing on Wired Network Port

 

EMC testing is like speeding by car. Did you ever try convince an officer
that you drove too fast for only a few minutes by year if caught
over-speeding?  And what did he say ?

Ports do not need testing only if inoperable at all. And even than, from a
technical point of view it may generate interference. In my opinion, testing
requirements end completely when a port is not accessible to the end-user.

And the criterion is not troublesome emissions, the requirement is
over-the-limit emissions.

Like speeding by car, driving beyond speed-limits does not need to be
troublesome (by the absence of other cars for example, or by night).
Nevertheless, any speeding limit is enforced even if not troublesome.

But at the end, it is the manufacturer who decides if creating emissions
over the limit is acceptable or not. But do not complain if you get caught.

 

Gert Gremmen

 

On 24-4-2018 12:52, John Woodgate wrote:

 Do you even need to justify not testing, if it doesn't produces troublesome
emissions? The only justification I can see might be that it is used only
for periods of a few minutes a few times a year. 

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk  
Rayleigh, Essex UK

On 2018-04-24 11:18, itl-emc user group wrote:

A device has a wired network port used for de-bugging only.

The port is not used during normal operation of the device.

Any opinions on whether or not this port should be tested?

 

 

Regards,

David Shidlowsky| Technical Reviewer

Address 1 Bat-Sheva St. LOD 7120101 Israel

Tel 972-8-9186113 Fax 972-8-9153101

Mail :   dav...@itlglobal.org 

 

This e-mail message may contain privileged or confidential information. 

If you are not the intended recipient, you may not disclose, use,
disseminate, distribute, copy or rely upon this message or attachment in any
way. If you received this e-mail message in error, please return by
forwarding the message and its attachments to the sender.

 

 

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This message is 

Re: [PSES] BS EN 62493:2015 Assessment of lighting equipment related to human exposure to electromagnetic fields

[Pete Perkins]

Andy,

 

   I have not used 62493 so I'm not familiar with the details; I
looked it up on the IEC website to get an idea as to what it covered and
reported their summary.  

 

   In reading thru this I see several points here. 

1) The broad band radiation up to 300MHz must be for radiated emissions;  

2) light itself is very limited in frequency and bandwidth so this must
apply to the SMPS which are driving the lamps.  Interestingly enough I have
seen quite robust Touch Current measurements from LED lighting SMPS; which
will eventually be tamed by proper Touch Current measurements which include
the up to 1Mhz HF portion allowed by the human body response to HF current.
But note that these HF components exist and can give rise to both conducted
and radiated emissions;   

3) SAR measurements indicate radiated emissions which would apply to LED
systems (including their SMPS) which are worn on or close to the human body
in their application.  

 

   Perhaps someone else on this thread has more definite insight
into the application and the need for these requirements; it would be good
to hear from them.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: McCallum, Andy <andy.mccal...@mottmac.com> 
Sent: Monday, April 9, 2018 7:52 AM
To: Pete Perkins <peperkin...@cs.com>
Subject: RE: [PSES] BS EN 62493:2015 Assessment of lighting equipment
related to human exposure to electromagnetic fields

 

Pete

 

Thanks yes it is LED so not an issue. Out of interest what type of lighting
does it cover? The exemption list is quite comprehensive. 

 

Andy

 

From: Pete Perkins [mailto:peperkin...@cs.com] 
Sent: 29 March 2018 19:11
To: McCallum, Andy <andy.mccal...@mottmac.com
<mailto:andy.mccal...@mottmac.com> >; EMC-PSTC@LISTSERV.IEEE.ORG
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: RE: [PSES] BS EN 62493:2015 Assessment of lighting equipment
related to human exposure to electromagnetic fields

 

Andy,

 

   Just to clarify:  

 

Abstract; IEC 62493:2015 applies to the assessment of lighting equipment
related to human exposure to electromagnetic fields. The assessment consists
of the induced internal electric field for frequencies from 20 kHz to 10 MHz
and the specific absorption rate (SAR) for frequencies from 100 kHz to 300
MHz around lighting equipment. This second edition cancels and replaces the
first edition published in 2009. This edition constitutes a technical
revision. This edition includes the following significant technical changes
with respect to the previous edition:
a) identification of lighting product types deemed to comply with the
standard without the need for test;
b) deletion of the need for CISPR-15-compliance as a prerequisite for IEC
62493 compliance;
c) inclusion of the consequences of the ICNIPR 2010 guidelines for (up to
100 kHz);
d) adding some guidance to the Van der Hoofden test head method to improve
reproducibility of results;
e) inclusion of compliance demonstration method for products having
intentional radiators.  

 

   Does your lighting product fall under the exemption?  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: McCallum, Andy <andy.mccal...@mottmac.com
<mailto:andy.mccal...@mottmac.com> > 
Sent: Thursday, March 29, 2018 7:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] BS EN 62493:2015 Assessment of lighting equipment related to
human exposure to electromagnetic fields

 

Anyone have any experience of this standard?  Do any lighting systems get
close to the ICNIRP limits?

 

Any thoughts welcome

 

Andy

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Re: [PSES] BS EN 62493:2015 Assessment of lighting equipment related to human exposure to electromagnetic fields

[Pete Perkins]

Andy,

 

   Just to clarify:  

 

Abstract; IEC 62493:2015 applies to the assessment of lighting equipment
related to human exposure to electromagnetic fields. The assessment consists
of the induced internal electric field for frequencies from 20 kHz to 10 MHz
and the specific absorption rate (SAR) for frequencies from 100 kHz to 300
MHz around lighting equipment. This second edition cancels and replaces the
first edition published in 2009. This edition constitutes a technical
revision. This edition includes the following significant technical changes
with respect to the previous edition:
a) identification of lighting product types deemed to comply with the
standard without the need for test;
b) deletion of the need for CISPR-15-compliance as a prerequisite for IEC
62493 compliance;
c) inclusion of the consequences of the ICNIPR 2010 guidelines for (up to
100 kHz);
d) adding some guidance to the Van der Hoofden test head method to improve
reproducibility of results;
e) inclusion of compliance demonstration method for products having
intentional radiators.  

 

   Does your lighting product fall under the exemption?  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: McCallum, Andy  
Sent: Thursday, March 29, 2018 7:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] BS EN 62493:2015 Assessment of lighting equipment related to
human exposure to electromagnetic fields

 

Anyone have any experience of this standard?  Do any lighting systems get
close to the ICNIRP limits?

 

Any thoughts welcome

 

Andy

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Re: [PSES] EMC tests called up in Safety standards

[Pete Perkins]

James,

 

   The interoperability of equipment continues to get more
complicated as switching technology spreads more ubiquitously.   It is well
known that electronic protection devices (including  RCDs & GFCIs) are
suffering 'nuisance' tripping which seems to be inadequately characterized
incoming signals.  Additional EMC type tests will have to be added to harden
the units against these signals, while ensuring that that the unit properly
operates when it should.  Expect more such testing.  You can search for the
recent paper I did with students where we were able to 'trick' the GFCI into
tripping when it shouldn't; 'nuisance' tripping in action.  

 

   Historically, the HV impulse tests applied are safety tests.
These tests were given to the EMC lab engineers as the safety engineers, in
those days, didn't provide much lab availability or experience - they mostly
peeked and poked at components in the assembly assessing spacings and
similar.  Oh, how much this has changed today. 

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: James Pawson (U3C)  
Sent: Wednesday, March 21, 2018 4:41 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC tests called up in Safety standards

 

Hello all,

 

Thanks for all the interesting replies, much appreciated.

 

All the best

James

 

From: Gert Gremmen; ce-test  > 
Sent: 21 March 2018 11:07
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] EMC tests called up in Safety standards

 

The EMC tests as called out in 60335  are safety tests, contrary to those
called out under the EMCD that are functional tests only. For Europe , one
can discuss about the necessity of those tests, as the EMCD  requires
testing in all operating modes including OFF or standby and  as long as one
can prove that  an apparatus remains functional, it also could be considered
safe. I have not seen many examples of a compliant functional apparatus that
has become unsafe during an immunity test, but cannot exclude that this may
happen either. Hence this test in 60335, that might also come into view
during the required risk analysis as called out in the new LVD. For Europe
only, of course.

The difference between functional and safety related EMC is an evolving
discussion, lately triggered by accidents with hybrid and autonomous driving
cars.

Gert Gremmen

On 20-3-2018 10:27, James Pawson (U3C) wrote:

Hello experts,

 

I note that EN 60335-1 (household and similar appliances) specifically calls
up EMC immunity tests in clause 19.11.4 where the controls for the EUT are
set in the "off position" and a set of immunity tests are applied. For
something that controls a heating element, I can see why this would be a
concern.

 

A couple of questions / thoughts:

 

*   It sounds like this at least doubles the amount of immunity testing
required - one with the EUT "on" and one with it "off". Would that be how
you read this?
*   Are there any other safety standards that explicitly call up EMC
tests within them like this one does? This is the first one I've come across
where this is the case but I'm not very familiar with safety standards in
general.

 

Thanks and all the best,

James

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Re: [PSES] What EU directive covers wireline phones after withdrawal of the RTTE Directive?

[Pete Perkins]

Joe,

 

Altho no one else commented on the safety aspects, ITEq
comes under 60950, being replaced by 62368.  Maybe that's obvious to
everyone.   

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: Joe Randolph [mailto:j...@randolph-telecom.com] 
Sent: Friday, February 9, 2018 10:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] What EU directive covers wireline phones after
withdrawal of the RTTE Directive?

 

Thanks Charlie.  

 

It looks like the scope language for the new LVD/EMCD is sufficient to pick
up wireline telephones without needing the previously explicit references in
the RTTE.

 

 

Thanks,

 

Joe Randolph

Telecom Design Consultant

Randolph Telecom, Inc.

781-721-2848 (USA)

j...@randolph-telecom.com  

http://www.randolph-telecom.com

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: Friday, February 09, 2018 12:38 PM
To: Joe Randolph 
>; EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: RE: [PSES] What EU directive covers wireline phones after
withdrawal of the RTTE Directive?

 

Joe

 

TTE falls under the EMC Directive and the LVD Directive if within scope

 

More information in the European Commission "Application of Directives
2014/53/EU, 2014/35/EU and 2014/30/EU", 

ec.europa.eu/DocsRoom/documents/11983/attachments/1/translations/en/renditio
ns/pdf

 

regards

Charlie

 

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:
 www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: Joe Randolph [mailto:j...@randolph-telecom.com] 
Sent: 09 February 2018 17:24
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] What EU directive covers wireline phones after withdrawal of
the RTTE Directive?

 

Hello All:

 

Sorry to be asking such a basic question, but what is the regulatory
framework for wireline phones now that the RTTE directive has been
withdrawn?

 

I presume that the previously applicable requirements for safety and EMC
still apply.  As I recall, these were explicitly called out in the RTTE
directive.  

 

I'm just looking for the specific regulatory framework that now applies to
wireline phones.

 

 

Thanks,

 

Joe Randolph

Telecom Design Consultant

Randolph Telecom, Inc.

781-721-2848 (USA)

j...@randolph-telecom.com  

http://www.randolph-telecom.com

 

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Re: [PSES] GFCI vs GFPE

[Pete Perkins]

Dave, 

 

Sorry, my misteak.  Yes, Annex IV.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Thursday, February 1, 2018 11:13 AM
To: Pete Perkins <peperkin...@cs.com>; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] GFCI vs GFPE

 

Pete, think you  are referring to Annex IV?

-Dave

 

From: Pete Perkins [mailto:peperkin...@cs.com] 
Sent: Thursday, February 01, 2018 1:42 PM
To: Nyffenegger, Dave; EMC-PSTC@LISTSERV.IEEE.ORG 
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: RE: [PSES] GFCI vs GFPE

 

Brian, et al,

 

My quick reading of the MD (again) leads me to believe that 
saws such as this are on the special list of  Annex VIII and require that a 
harmonized standard be applied by the manufacturer (what standard applies?) or 
, pert art 12, use a NB to demonstrate adequacy in meeting the overall MD 
requirements.  I don’t see any exemption applying.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

p.perk...@ieee.org <mailto:p.perk...@ieee.org> 

 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Thursday, February 1, 2018 10:32 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] GFCI vs GFPE

 

That’s what I was questioning.  I’ve not had to certify anything like those 
direct drive products.  But as Doug pointed out earlier if attaching a blade to 
a motor shaft with a screw is considered linkage then it would fall under the 
MD if not excluded for other reasons.

 

-Dave

 

From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: Thursday, February 01, 2018 1:27 PM
To: Nyffenegger, Dave; EMC-PSTC@LISTSERV.IEEE.ORG 
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: RE: [PSES] GFCI vs GFPE

 

Dave, 

 

I’ve never heard this position taken on the machinery directive before.  So are 
you saying that anything “direct driven” or that has “direct drive” would not 
meet the definition of a “machine” and thus, not fall under the Machinery 
Directive?  So a saw blade or fan blade mounted directly on the motor shaft is 
not a machine?  

 

But add a belt, or gear, or some other form of energy transmission, and then 
the product falls under the MD.  Is that what you are saying?

 

If so, I’ll have to re-evaluate everything I’ve done for the last 10 years.  Oh 
well, what else do I have to do?  :)

 

I appreciate your comments. 

The Other Brian 

 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Wednesday, January 31, 2018 5:38 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] GFCI vs GFPE

 

The pivoting arm operated by human effort would be out of scope of machinery 
definition.  Which leaves just the motor with no real linkage to the blade 
since the blade is screwed directly to the end of the motor shaft.  A 
sophisticated saw perhaps for commercial/industrial use may have a driven arm 
and may use belts/pulleys/gears to drive the blade, would easily fit the 
machinery description.  The same question applies to an inexpensive direct 
drive table saw with no driven parts other than the motor with a blade mounted 
to the end of the shaft vs. a professional grade table saw with a pulleys and 
belt driven blade.

 

-Dave

 

From: John Woodgate [mailto:j...@woodjohn.uk] 
Sent: Wednesday, January 31, 2018 5:23 PM
To: Nyffenegger, Dave; EMC-PSTC@LISTSERV.IEEE.ORG 
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] GFCI vs GFPE

 

There is a motor and a blade, which both move and are linked. In a cut-off saw, 
If I have the term right, the whole motor and blade housing swings on a pivot 
at the back of the baseplate.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2018-01-31 21:33, Nyffenegger, Dave wrote:

I am surprised a basic cut-off saw would fit the definition of ‘machine’ for 
the MD since cut-off  saws (the one’s I’m thinking of) are basically just a 
motor with a blade mounted directly to the armature and I don’t know that the 
blade is even considered part of the product.  Not really an assembly of linked 
parts at least one of which moves, and which are joined together for a specific 
application.

 

-Dave

 

From: John Woodgate [mailto:j...@woodjohn.uk] 
Sent: Wednesday, January 31, 2018 1:58 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] GFCI vs GFPE

 

IEC 62841 is a multi-part standard with 23 documents. But it's all about 
'hand-held', so un

Re: [PSES] GFCI vs GFPE

[Pete Perkins]

116 in in the process of folding the 60745-1 (hand held motor operated 
tool) standards into the 62841 series (Electric motor-operated hand-held tools, 
transportable tools and lawn and garden machinery). See their dashboard at:

http://www.iec.ch/dyn/www/f?p=103:30:13397277133783FSP_ORG_ID,FSP_LANG_ID:4112,25

 

My reference was not from a part 2, but actually from section 21.16 of 60745-1:

"

Tools employing liquid systems shall protect the user against the increased 
risk of
shock due to the presence of liquid under conditions of normal use and the 
faults of the liquid
system.
Tools employing liquid systems shall be either:
• of class III construction;
• of class I or class II construction and be provided with a residual current 
device and comply
with 14.4, 14.5 and 14.6; or
• of class I or class II construction and be designed for use in combination 
with an isolating
transformer and comply with 14.4 and 14.5.

"

Section 14.4 describes using a salt water mix to simulate overfilling or 
misassembling and then testing for leakage.

 

I do not know whether your product falls within scope of 62841; perhaps your 
favorite NRTL could help. Your favorite NRTL might even have someone on the 
committee who could help with a question.

 

Mike

 


  _  


From: "Brian Kunde" <brian_ku...@lecotc.com <mailto:brian_ku...@lecotc.com> >
To: msherma...@comcast.net <mailto:msherma...@comcast.net> 
Cc: "EMC-PSTC" <EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Sent: Wednesday, January 31, 2018 11:58:25 AM
Subject: RE: [PSES] GFCI vs GFPE

 

Mike,

 

Thanks for your offer. I assume the requirement for RCD is limited to hand-held 
or portable power tools that uses water. This is interesting because I didn’t 
know this was a requirement.

 

In our case, the cut-off saw we are looking at weighs over 300 lbs. Defiantly 
not hand-held any probably not considered portable (depending on your 
definition).  

 

Do you know if there are similar requirements for non-hand-held electric 
saws/tools?

 

Thanks,

The Other Brian

 

From: msherma...@comcast.net <mailto:msherma...@comcast.net>  
[mailto:msherma...@comcast.net] 
Sent: Wednesday, January 31, 2018 12:29 PM
To: Kunde, Brian
Cc: EMC-PSTC
Subject: Re: [PSES] GFCI vs GFPE

 

Brian --

I think I've seen a Part 2 standard for 60745-1, as I recall, that required a 
RCD if the tool used water and the water ended up in the wrong place 
electrically. If you'd like a screen shot of the section, I can probably find 
it for you.

Mike Sherman

Graco Inc.

 


  _  


From: "Brian Kunde" <brian_ku...@lecotc.com <mailto:brian_ku...@lecotc.com> >
To: "EMC-PSTC" <EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Sent: Wednesday, January 31, 2018 11:06:36 AM
Subject: Re: [PSES] GFCI vs GFPE

 

Where Pete stated, “The Euro systems use of RCDs require this protection in 
many installations (but I’m not familiar with the installation code details)”. 
This “Code” is probably what I am seeking. 

 

Has anyone run across a Code rule that requires the Product to employ a RCCB 
within the product?  If the local electrical code requires a RCCB, cannot this 
protection be provided as part of the site protection?  Why burden the cost of 
a product where such a requirement may only be necessary in a small percentage 
of installations?

 

The main purpose of my question on this topic is cost.  Here in the USA, a GFCI 
receptacle is very inexpensive; costing around $10 at most home stores.  But a 
3-phase RCD Circuit Breaker can cost $300-$400.  On some products, such as a 
tile saw that uses water, this can more than double the cost of the entire 
product.  So knowing when and where they are required is very important. 

 

Thanks again to everyone for your consideration.  From what I have read so far 
on this topic, it is a moving target as electric codes from different states 
and countries are always evolving and the code governing the requirements of 
RCDs and GFCIs are common to change.

 

Thanks,

Brian

 

 

From: John Woodgate [mailto:j...@woodjohn.uk] 
Sent: Wednesday, January 31, 2018 11:13 AM
To: Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG 
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] GFCI vs GFPE

 

You can rely on the recent post in this thread by Pete Perkins.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2018-01-31 15:52, Kunde, Brian wrote:

Thanks for the input everyone.

 

I know that GFCI protectors in North America will trip between 4-6mA.  Do other 
countries, such as Europe, have the same requirements?  

Or are 30mA protectors used in Europe? If so, does Europe use 30mA ground fault 
protectors because of nuisance tripping even though the studies have shown that 
30mA can be fatal?  

 

These 3-phase c