RE: Australia C-Tick and safety requirements

2009-02-23 Thread Pickard, Ron
 by Peter in
an earlier email, i.e.:

 

Non-prescribed electrical equipment 

A person who sells non-prescribed electrical equipment must comply with
section 120 of the Regulation.  Generally speaking all non-prescribed
electrical equipment must comply with the safety criteria of AS/NZS3820
(Essential safety requirements for low voltage electrical equipment).  This
would include, but not be limited to: 

 

*a test report showing compliance to the relevant Australian product
standard; 

*if no relevant Australian product standard exists, a test report
showing compliance to another relevant standard such as AS/NZS3350.1,
AS/NZS60335.1 or AS/NZS 3100; 

*a certificate of approval issued as per relevant Australian/NZ
legislation; 

*another method consistent with clause 5 of AS/NZS 3820

 

Usually, the easiest way means of complying is by way of the 1st option of
using a test report showing compliance with with the relevant Australian
product standard.  

 

 

Consumer Protection Laws

Consumer protection laws by way of the Australian Trade Practices Act also
require the device be safe and fir for purpose.  Safe is defined as
complying with the relevant Australian product safety standard or generic
safety standard where no product standard exists so by default, in complying
with the Electrical Regulations of the various Australian States/Territories
you comply with the consumer protection laws.  While the consumer protection
laws concern all aspects of safety, not just electrical safety, by complying
with the Australian product safety standard you would be considered to have
taken all reasonable precautions.

 

 

Safety of a Telecommunications Device

The Australian telecommunications regulations have specific safety
requirements and require the product Compliance Folder includes, apart from
other things, a test report to AS/NZS 60950.1 from an RTA (Recognised Testing
Authority).  A listing of RTA test labs is maintained by NATA (National
Association of Testing Authorities).  A CB test lab is not necessarily an RTA
so a CB test report may not be acceptable.

 

The issue mentioned by Ron about ACMA auditors not accepting a test report to
IEC 60950.1 + Australian National deviations etc should not occur where:

*   the IEC 60950.1 report also clearly states compliance with Australian
National deviation according to AS/NZS 60950.1:2003 (the report should clearly
spell out the Australian standard, including the version); and 
*   the test report is from an RTA listed test lab; and 
*   is an endorsed test report (i.e. clearly states the test report is
produced under the test labs accreditation to test to that standard and
identify the accrediting organisation etc)

 

Hope this helps along with the input from others.

 

 

Best regards, 
Kevin Richardson 

Stanimore Pty Limited 
Compliance Advice  Solutions for Technology 
(Legislation/Regulations/Standards/Australian Agent Services) 
Ph:   02-4329-4070   (Int'l: +61-2-4329-4070) 
Fax:  02-4328-5639   (Int'l: +61-2-4328-5639) 
Mobile:  04-1224-1620   (Int'l: +61-4-1224-1620) 
Email:kevin.richard...@stanimore.comorkevin.richard...@ieee.org 
URL: www.stanimore.com 

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-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Pickard, 
Ron
Sent: Saturday, 21 February 2009 4:34 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Australia C-Tick and safety requirements

Dan, Jim et al,

 

I believe the Australian document that you were requesting is the ACMA’s
EMC Handbook, which can be accessed at:

http://www.acma.gov.au/webwr/aca_home/
ublications/reports/industry/manuals/emcbook.pdf
http://www.acma.gov.au/webwr/aca_home/
ublications/reports/industry/manuals/emcbook.pdf 

 

The ACMA does not impose safety requirements for C-tick (ACMA) or RCM
(Regulatory Compliance Mark, owned by AU  NZ regulators) markings, but I
believe the “state authorities” that Peter refers to do and are the
provincial electrical authorities (refer to Appendix D) which must ensure that
equipment attaching to the electrical power grid is safe and in almost all
cases pertains to power supplies

RE: Australia C-Tick and safety requirements

2009-02-20 Thread Pickard, Ron
Dan, Jim et al,

 

I believe the Australian document that you were requesting is the ACMA’s EMC
Handbook, which can be accessed at:

http://www.acma.gov.au/webwr/aca_home/p
blications/reports/industry/manuals/emcbook.pdf
http://www.acma.gov.au/webwr/aca_home/
ublications/reports/industry/manuals/emcbook.pdf 

 

The ACMA does not impose safety requirements for C-tick (ACMA) or RCM
(Regulatory Compliance Mark, owned by AU  NZ regulators) markings, but I
believe the “state authorities” that Peter refers to do and are the
provincial electrical authorities (refer to Appendix D) which must ensure that
equipment attaching to the electrical power grid is safe and in almost all
cases pertains to power supplies and power cords. Please note that in some
cases, registration will be needed. Also, Appendix E may also apply to your
product.

 

So, it is a good idea to also include an acceptable Australian/New Zealand
safety report and the electrical authority’s acceptance, where applicable,
into the product’s DofC and the compliance folder.

 

In regard to your last question, although a CB certificate/report with AU/NZ
deviations does indeed cover your product for safety in Australia  New
Zealand, the ACMA has been a bit persnickety during compliance folder audits
about it preferring actual AS/NZS 60950-1 reports generated from NATA
accredited labs. If anyone can point to an actual ACMA requirement on this
point, we all would be grateful.

 

I hope this answered your questions and as always, I stand to be corrected
where needed. Comments?

 

I look forward to your reply.

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com mailto:ron.pick...@intermec.com 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Jim Robson
Sent: Friday, February 20, 2009 10:47 AM
To: pmerguerian2...@yahoo.com; EMC-PSTC@LISTSERV.IEEE.ORG; Dan Roman
Subject: RE: Australia C-Tick and safety requirements

 

Peter,

 

I have been researching this issue also.  Can you tell me what Australian
document says that C-tick marked ITE (non-Telco) equipment must comply (and/or
be tested to) with AS/NZS 60950? 

 

The Telecommunications Labelling (Customer Equipment and Customer Cabling)
Notice 2001 definitely calls out AS/NZS 60950 for Telco equipment.

 

The Radiocommunications Labeling (EMC) Notice 2008 which covers ITE does not
call out AS/NZS 60950.

 

You also wrote does not require a safety approval from a state authority. 
Do mean AS/NZS 60950 testing must be done at an approved lab and then cite
AS/NZS 60950 on the Declaration of Conformity?

 

Regards, 

Jim Robson

 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of peter
merguerian
Sent: Friday, February 20, 2009 7:43 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG; Dan Roman
Subject: Re: Australia C-Tick and safety requirements

For safety, this is not a perscribed equipment and therefore does not require
a safety approval from a state authority

 

However, the product must still comply with the Australia safety requirements
in AS/NZS 60950.1. This standard is harmonized with IEC60950-1 so if you
comply with the standard and its' Austrlia devioations, you're good to go.

 

Peter Merguerian

--- On Fri, 2/20/09, Dan Roman dan.ro...@dialogic.com wrote:

From: Dan Roman dan.ro...@dialogic.com
Subject: Australia C-Tick and safety requirements
To: EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG
Date: Friday, February 20, 2009, 7:23 AM

Hello all,

 

I’m passing along two questions for a friend that I cannot answer 
because
they are outside of my product area of expertise.  The product in question is
a passive line filter for use with a PC.  It contains overvoltage and line
filtering components (some coils, caps, and MOVs). 

  

1.  Does the C-Tick mark for non-telecom equipment require both EMC 
and
safety declarations?  I know that for the telecom equipment my company
produces, the ACA requires telecom, safety, and EMC (A-tick and C-tick) but I
don’t know if the safety portion is a telecom specific requirement or not. 
If the answer is the C-Tick is for EMC only, are there other requirements for
safety or other marks that would apply to this product in Australia?  I am
sure there must be. 

2.  Does a passive device like this fall under EMC requirements?  
CISPR
22/EN55022 don’t specify a lower frequency limit exempting products, so this
passive line filter connected to a 50 Hz supply would appear to need testing. 
Everything I deal with has clocks in excess of 1 GHz these days so this
question never came up where I work! 

  

It is always interesting getting questions outside of your normal day 
to day
experience.
-- 
Dan Roman, N.C.E.
Product Regulatory Engineer
Dialogic Research Inc.
1515 State Rt. 10
Parsippany, NJ 07054-4538

RE: EN 60950-1 Safety Report Template

2009-01-28 Thread Pickard, Ron
Carl,

 

The TRF's are indeed copyrighted and they can be purchased at the IEC's
webstore or your company can become IECEE members whereby the TRFs are
available to you free of charge from the CB Scheme website's member area.

 

Brian has the right idea though and aside from the CB report fairy, if you
have the time and/or inclination, you should be able to create your own
template format from an EN test report.

 

As Ted suggested, you might be able to wangle a copy from a NRTL or other
agency you've been working with, but that’s not too likely a possibility.

 

So, you might have to step up and put down some green to buy it. It may very
well be cheaper in the long run.

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com

 


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Brian O'Connell
Sent: Wednesday, January 28, 2009 12:45 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: EN 60950-1 Safety Report Template

 

The IEC TRFs are copyrighted.

 

The last CB test report issued for one of your products ?

 

A CB test report that has been published on-line by another

company for one of their products ?

 

The CB report fairy ? 

 

 

From: Carl Newton [mailto:emcl...@gmail.com] 

Sent: Wednesday, January 28, 2009 9:29 AM

To: EMC-PSTC@LISTSERV.IEEE.ORG

Subject: EN 60950-1 Safety Report Template

 

I seem to recall a few years ago there was a thread here in which

a list member was looking for a report template for EN 60950-1,

similar to a CB Scheme type of report.  The idea is simply to use

that template to create a safety report in support of an LVD

self-declaration.  Does anybody out there have such a thing that

they are willing to share?  Or can you point me toward such an

item online somewhere?

 

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RE: New Turkey Requirement

2009-01-26 Thread Pickard, Ron
Tim,

 

It was my experience in a past life that Turkey, especially Turkish Customs,
has for the last few years been quite fanatical about enforcing/validating CE
compliance of products entering Turkey. Turkish Customs was very particular
for newly manufactured products (products held at Customs until they were
satisfied). I also remember that Turkish Customs only accepted
telecom/radiocom compliance via EU/ETSI standards (we even had to provide test
reports on occasion). This I believe was started with their application for
membership into the EU and has, however, turned into an over zealous barrier
of trade of sorts.

 

The components you’ve listed might be considered to be apparatus under the
new EMC Directive depending on their intended availability to the end user. I
suggest that you read through the new EMC Directive and its Guide, both
available on the Europa website, and how they relate to components. From that,
you might get the reasoning of Turkish Customs.

 

IHTH.

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com mailto:ron.pick...@intermec.com 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of peter
merguerian
Sent: Sunday, January 25, 2009 2:06 PM
To: emc-p...@ieee.org; emcp...@aol.com
Subject: Re: New Turkey Requirement

 

This is not new. Turkey has for many years ollowed the EU guidelines for CE
Markings and DoC. They must be enforcing it now for FRU apparatus.

 

One exception is wireless/telecom homologations - Turkey still requires
approvals by their telecom/radiocom regulator 

 

Best Regards,

 

Peter

 



--- On Fri, 1/23/09, emcp...@aol.com emcp...@aol.com wrote:

From: emcp...@aol.com emcp...@aol.com
Subject: New Turkey Requirement
To: emc-p...@ieee.org
Date: Friday, January 23, 2009, 4:22 PM

Hello group,

 

Have anyone heard of a new requirement by Turkey start this month for 
CE?
They are asking to have CE DoC for all sub-assemblies (Field Replaceable
Units) example is memory DIMMs, SFP's, PCI cards etc. that are used in network
servers or appliances. This is based on EMC directive which was released in
2004.

 

Thanks,

Tim Pierce

TAP Engineering 

 





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RE: In house test equipment

2009-01-23 Thread Pickard, Ron
Hi Grace,

 

Pardon my lack of intimate familiarity of the inner workings of BSMI, but what
is the meaning of “the third department of BSMI”? Does BSMI actually have
a “third department”?

 

Also, do you know what the problem with BSMI’s website (www.bsmi.gov.tw
http://www.bsmi.gov.tw/ ) is as it reports an “unknown www server” error
when attempting access? I am guessing that their web server is currently
disabled for the moment. Or, is the web address different?

 

Please advise. I look forward to your reply.

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com mailto:ron.pick...@intermec.com 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Grace Lin
Sent: Friday, January 23, 2009 5:54 AM
To: emc-p...@ieee.org
Subject: Re: In house test equipment

 

You may address your question to the third department of BSMI. - Grace

On 1/19/09, codymil...@micron.com codymil...@micron.com wrote: 

Hi all,

 

I have a question regarding Taiwan regulatory requirements. We have some in
house custom bench top test equipment we have designed and use in our company.
We would like to send a couple units to our plant in Taiwan. Do I need to have
the equipment tested to meet Taiwan regulator standards. We do not sell this
item and we at most will ship a couple units into our Taiwan facility.

 

Thanks,

Cody

 

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RE: CE logo dimension in small products

2009-01-22 Thread Pickard, Ron
John et al,

 

Unfortunately, this CE marking disparity very likely originated from the CE
Marking Directive itself, which amended several directives with inconsistent
CE marking requirements. Subsequent repealing directives simply carried those
inconsistencies forward.

 

However, I agree that a definitive text should be referenced (or copied
verbatim) instead of creating separate and different requirements per
directive. But, since this situation has existed for many years now, it's
unlikely to be corrected any time soon.

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate
Sent: Thursday, January 22, 2009 10:26 AM
To: emc-p...@ieee.org
Subject: Re: CE logo dimension in small products

 

In message 

9d3c09c155d9904299b427d6d2b1bf97032a9...@int-ev1.corpnet.intermec.com, 

dated Thu, 22 Jan 2009, Pickard, Ron ron.pick...@intermec.com 

writes:

 

I would have thought that there would've been better consistency 

regarding the CE marking procedure specified in CE marking related EU 

directives.

 

Indeed; it is something that is often complained about to the 

Commission, but so far nothing has happened.

 

What should happen is that each Directive should refer to, not quote, a 

definitive text, presumably in the CE Directive itself.

-- 

OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk

Things can always get better. But that's not the only option.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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RE: Safety Experts: Limited Voltage Pwr Supplies vs. Non-Limited Voltage Power Supplies

2009-01-21 Thread Pickard, Ron
Hi Christine,

 

It’s always a joy experiencing part substitutions, eh? And, LPS actually
refers to a Limited Power Source as defined in the IEC60950-1 series.

 

Anyway, have you had a chance to review the other power supply’s applicable
safety report(s)? Whether it is or is not LPS will be determined (and your
comfort level) during that review. That missing LPS marking could simply be an
oversight on the part of that manufacturer or it’s not a LPS. The fact is
that you really won’t know until you look at the reports, and I hope that
that manufacturer will make the safety report(s) available to you.

 

Also I believe that the LPS marking is an accepted industry practice, not a
regulatory requirement. If anyone disagrees with this, please provide a
compelling argument.

 

IHTH.

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com mailto:ron.pick...@intermec.com 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Christine
Rodham
Sent: Wednesday, January 21, 2009 12:39 PM
To: emc-p...@ieee.org
Subject: Safety Experts: Limited Voltage Pwr Supplies vs. Non-Limited Voltage
Power Supplies

 

Hi List Members,

 

We have a vendor that provides us a unit that uses an external power supply (
90- 240VAC)

The power supply is labeled LPS after the model number which means: Limited
Voltage Power Supply.

 

They recently changed vendors to another power supply with the EXACT same
rating Except it was not marked as a LIMITED voltage power supply.

 

Our supplier says this is not a compliance / safety issue because both
supplies are recognized by UL and have the same voltage and current rating.

 

So the $64, dollar question is can you use a non- LPS in place of a LPS if
they have the same rating?

 

Thanks in advance,

 

Thank you in advance!

 

Christine Rodham

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RE: Safety Experts: Limited Voltage Pwr Supplies vs. Non-Limited Voltage Power Supplies

2009-01-21 Thread Pickard, Ron
Christine,

 

As I and others have stated, the LPS requirement comes from IEC/EN/UL/etc
60950-1 safety standards, but this is of course assuming that 60950-1 is the
safety standard that that manufacturer employed, which may not be acceptable
to your product’s safety requirements. And as others have indicated, you
will probably need to address other issues in your product if that new power
supply is not LPS regardless.

 

The addition of that new power supply will probably not be as simple as you
might have envisioned. So, get a copy of the new power supply’s safety
report(s), validate LPS (or not), and work with your NRTL  CB NCB to
determine what you need to do to make the new power supply acceptable for your
product. Your product’s safety reports will likely need to be updated to
reflect the new power supply anyway.

 

IHTH.

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com mailto:ron.pick...@intermec.com 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Christine
Rodham
Sent: Wednesday, January 21, 2009 2:38 PM
To: emc-p...@ieee.org
Subject: Re: Safety Experts: Limited Voltage Pwr Supplies vs. Non-Limited
Voltage Power Supplies

 

List Members,

 

Thanks for all the great replies! 

Would it make sense to see if the end product can pass safety with the non-LPS
power supply?

 

Is the the LPS clause just a CB scheme requirement or is it required for NRTL
approval also?

 

Best regards,

 

Christine Rodham

Christine Rodham chrisrod...@yahoo.com wrote:

Hi List Members,

 

We have a vendor that provides us a unit that uses an external power 
supply (
90- 240VAC)

The power supply is labeled LPS after the model number which means: 
Limited
Voltage Power Supply.

 

They recently changed vendors to another power supply with the EXACT 
same
rating Except it was not marked as a LIMITED voltage power supply.

 

Our supplier says this is not a compliance / safety issue because both
supplies are recognized by UL and have the same voltage and current rating.

 

So the $64, dollar question is can you use a non- LPS in place of a 
LPS
if they have the same rating?

 

Thanks in advance,

 

Thank you in advance!

 

Christine Rodham

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RE: Electrical product recall request

2009-01-13 Thread Pickard, Ron
Scott et al,

 

To answer your question, typical of the case that most, if not all, of the
subscribers of this forum can attest, electronic products are subject to
government and industry regulations concerning product safety, electromagnetic
noise radiation/immunity and wireless/wired telecommunication. Compliance
engineering is a term to describe the engineering activities to ensure that
products conform to these regulations. Mostly compliance engineering focuses
its attention on published regulatory and industry standards, ensuring that
products are in compliance with those regulations. Regulatory standards are
those adopted by national governments and are almost exclusively mandatory.
Industry standards (Bluetooth, GSM, UMTS, Wibree, RS-xxx, EIA/TIA, etc.) are
those standards where compliance may be needed but are not legally mandatory.
And in some instances, such as the EU and the US, there is a need to review
and interpret government legislation such as the EU’s Directives and the
US’s Code of Federal Regulations. In that aspect, compliance engineering
does mimic the legal profession.

 

In the limited amount of time that I have today, I wanted to quickly answer
your question in a nutshell and hope that the above has adequately answered
your question. And, if anyone cares to interject, add or correct the above in
any way, please do.

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com mailto:ron.pick...@intermec.com 



From: Scott Xe [mailto:scott...@gmail.com] 
Sent: Tuesday, January 13, 2009 7:42 AM
To: Pickard, Ron; 'Nick Williams'
Cc: emc-p...@ieee.org
Subject: RE: Electrical product recall

 

Hi Ron,

 

Thanks for your useful information and helpful guidance.  What is a compliance
engineer?  Is it responsible for ensuring the products in compliance with all
legal requirements?

 

Scott

 

From: Pickard, Ron [mailto:ron.pick...@intermec.com] 
Sent: 2009年1月13日 03:54 AM
To: Nick Williams; Scott Xe
Cc: emc-p...@ieee.org
Subject: RE: Electrical product recall

 

Nick,

The operational guidelines link for businesses (for dangerous consumer
products) to which you refer is at: htt
://ec.europa.eu/consumers/safety/rapex/guidelines_business_en.htm. It's stated
to be new there, but the actual linked document is dated 2004, so I guess
we’ll have to wait for the revised edition.

 

Scott,

As others from the hoards of us legally unwashed have given sound advice and
good references for your company to develop a recall plan, the recall plan
that your company develops may likely have to pass scrutiny with your legal
dept/management and some likely legal/contractual issues. Also, googling
“safety recall plan” should give you several links for you to understand
what a recall plan will look like and how to develop one.

 

I hope you find this useful, but please note that I am a compliance engineer
and in no way resemble a lawyer, attorney, barrister, counsel(or), legal
eagle, ambulance chaser, etc, etc. Therefore, the above is not legal advice
and should not be considered as such. If it was, I would be charging you at
least $500/hr (with a retainer).

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com mailto:ron.pick...@intermec.com 


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams
Sent: Monday, January 12, 2009 1:06 PM
To: Scott Xe
Cc: emc-p...@ieee.org
Subject: Re: Electrical product recall

 

There is information at the following sites which will be of assistance to you:

 

http://ec.europa.eu/consumers/safety/rapex/index_en.htm

 

http://www.berr.gov.uk/whatwedo/consume
s/Safety/products/unsafe-notification/index.html

 

Somewhere in this lot there is a guidance document which provides a 

basis for an assessment of whether a recall is necessary. I can send 

you a copy if you cannot find it in the links on the above pages.

 

At a seminar in November last year, we were told that this guidance 

is being revised and a new model for assessment has been agreed. 

Heaven only knows if/when this might make it out into the public 

domain.

 

Nick.

 

 

At 00:45 +0800 13/1/09, Scott Xe wrote:

It is a quite common terms in the industry and mostly related to 

safety hazard.  We would like to establish a process for the product 

recall.  Is there any important rules or guidance to follow for a 

meaningful and absolutely necessary recall?

 

Thanks and regards,

 

Scott

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[Bulk] RE: Requirements in Ghana

2009-01-13 Thread Pickard, Ron
Hi Anders,

 

You should be able to find what you’re looking for on Ghana’s National
Communication Authority (NCA) website at http://www.nca.org.gh/index.asp.

 

Ghana’s Ministry of Communication’s website might also be useful at
http://www.moc.gov.gh/.

 

IHTH.

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com mailto:ron.pick...@intermec.com 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Anders
Svensson B
Sent: Tuesday, January 13, 2009 2:56 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Requirements in Ghana

 

Dear experts, 

Anyone who knows the requirements for Ghana for EMC, Product Safety, SAR,
Radio, environmental etc. 

The product have WLAN 802-11 b/g and GSM 850/900/1800/1900 bands and UMTS band
FDDI/II and V functionality. 

 

All input is welcome! 

 

Best regards 
Anders 

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RE: Electrical product recall

2009-01-12 Thread Pickard, Ron
Nick,

The operational guidelines link for businesses (for dangerous consumer
products) to which you refer is at: htt
://ec.europa.eu/consumers/safety/rapex/guidelines_business_en.htm. It's stated
to be new there, but the actual linked document is dated 2004, so I guess
we’ll have to wait for the revised edition.

 

Scott,

As others from the hoards of us legally unwashed have given sound advice and
good references for your company to develop a recall plan, the recall plan
that your company develops may likely have to pass scrutiny with your legal
dept/management and some likely legal/contractual issues. Also, googling
“safety recall plan” should give you several links for you to understand
what a recall plan will look like and how to develop one.

 

I hope you find this useful, but please note that I am a compliance engineer
and in no way resemble a lawyer, attorney, barrister, counsel(or), legal
eagle, ambulance chaser, etc, etc. Therefore, the above is not legal advice
and should not be considered as such. If it was, I would be charging you at
least $500/hr (with a retainer).

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com mailto:ron.pick...@intermec.com 


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams
Sent: Monday, January 12, 2009 1:06 PM
To: Scott Xe
Cc: emc-p...@ieee.org
Subject: Re: Electrical product recall

 

There is information at the following sites which will be of assistance to you:

 

http://ec.europa.eu/consumers/safety/rapex/index_en.htm

 

http://www.berr.gov.uk/whatwedo/consume
s/Safety/products/unsafe-notification/index.html

 

Somewhere in this lot there is a guidance document which provides a 

basis for an assessment of whether a recall is necessary. I can send 

you a copy if you cannot find it in the links on the above pages.

 

At a seminar in November last year, we were told that this guidance 

is being revised and a new model for assessment has been agreed. 

Heaven only knows if/when this might make it out into the public 

domain.

 

Nick.

 

 

At 00:45 +0800 13/1/09, Scott Xe wrote:

It is a quite common terms in the industry and mostly related to 

safety hazard.  We would like to establish a process for the product 

recall.  Is there any important rules or guidance to follow for a 

meaningful and absolutely necessary recall?

 

Thanks and regards,

 

Scott

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FCC HAC acceptance

2009-01-09 Thread Pickard, Ron
Greeting to all in this new year,

 

I was just reviewing the FCC’s HAC requirements, which made me wonder how
well the FCC’s HAC requirements are accepted globally, or if at all. Are
there any countries that accept the FCC’s HAC requirements? And, are there
any other countries that also impose their own HAC requirements? If you know
of any, what are those requirements?

 

I look forward to your reply(ies).

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com mailto:ron.pick...@intermec.com 

 

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RE: 5 Meter Chamber For EMI Qualification Testing

2009-01-09 Thread Pickard, Ron
Hi Grace,

 

Then for the sake of consistency, does the BSMI also confirm 3m distance is
acceptable per CNS13438, or not? Just curious.

 

I look forward to your reply.

 

Best regards,

 

Ron Pickard

Intermec Technologies

Cedar Rapids, IA

(319) 369-3142

ron.pick...@intermec.com mailto:ron.pick...@intermec.com 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Grace Lin
Sent: Friday, January 09, 2009 8:45 AM
To: Grasso, Charles
Cc: emcp...@aol.com; emc-p...@ieee.org
Subject: Re: 5 Meter Chamber For EMI Qualification Testing

 

Hi Charles and others,

 

BSMI confirms data taken at 3m per CNS13439 requirements is acceptable.

 

Regards,

Grace Lin

 

On 1/8/09, Grasso, Charles charles.gra...@echostar.com wrote: 

Hi Grace – CNS13439 requires a 3m test to prove compliance. Do you
know if this will be an issue for the BSMI?

 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Grace Lin
Sent: Tuesday, January 06, 2009 9:40 AM
To: emcp...@aol.com; emc-p...@ieee.org
Subject: Re: 5 Meter Chamber For EMI Qualification Testing

 

David, Tim, and Others:

 

It is still an issue in Taiwan.  BSMI do not feel comfortable to accept 3m
data due to the near field concern.  If CISPR 22 (or its replacement)
committee explicitly accepts 3m data, BSMI will accept 3m data.
 

Regards,
Grace

 

On 1/6/09, Heald, David david.he...@garmin.com wrote: 

Tim,

  I know that this has been an issue in Taiwan in the past - I had a
submission rejected a few years ago for this reason. 

I'll defer to someone with more recent experience with Korea since the
regulating agencies just changed there - the last approval I completed there
was at my last job just before the change occurred (now I'm realizing that I
haven't sought approval for a non radio device for a long time in Korea so
there's another reason to defer to someone else).  

As for 1-4, for most devices, you're dealing with self-declaration or its
equivalent.  This is up to you to determine if your results indicate
compliance in a 10m chamber since a 10m chamber is the common reference
indicated in most emissions standards.  Taking the assumption you state into
account, you should be in good condition.  It would be a good idea to obtain
some correllational data to a 10m chamber to confirm you're getting similar
results (and use some engineering judgement in the near field).

 

This is a short response to a complex issue, but I hope it was somewhat
helpful.  

 

Best Regards,

-Dave

 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of emcp...@aol.com
Sent: Monday, January 05, 2009 5:39 PM
To: emc-p...@ieee.org
Subject: 5 Meter Chamber For EMI Qualification Testing

 

Hello Group,

 

I would like to know if radiated emission test data taken at a 3 meter
distance in a 5 meter semi-anechoic chamber is valid for qualification testing
for the following:

 

Please assume that the chamber is fully validated with volumetric NSA.

 

1. FCC/Industry Canada

2. VCCI (Japan)

3. Australia/New Zealand

4. Europe

5. Taiwan

6. Korea

 

I ask this question because I have been hearing that some countries do not
accept 3 meter chamber data.

 

Thanks for your help.

 

Tim Pierce

 



New year...new news. Be the first to know what is making headlines
http://www.aol.com/?ncid=emlcntaolcom0026 .

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RE: 5 Meter Chamber For EMI Qualification Testing

2009-01-09 Thread Pickard, Ron
Hi Grace,

 

Thanks for the speedy reply. Since BSMI was confirmed to allow 3m data per
CNS13439, I had to ask about CNS13438 even though I expected they wouldn’t.
Sometimes, surprises can be discovered in places you will least expect and I
was somehow trolling for such a surprise, but alas….

 

Also, I have appreciated your contributions to this list and hope you continue
to do so.

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com mailto:ron.pick...@intermec.com 



From: Grace Lin [mailto:graceli...@gmail.com] 
Sent: Friday, January 09, 2009 11:09 AM
To: Pickard, Ron
Cc: emc-p...@ieee.org
Subject: Re: 5 Meter Chamber For EMI Qualification Testing

 

BSMI confirms test data taken at 3m per CNS13438 is NOT acceptable. - Grace

 

On 1/9/09, Pickard, Ron ron.pick...@intermec.com wrote: 

Hi Grace,

 

Then for the sake of consistency, does the BSMI also confirm 3m distance is
acceptable per CNS13438, or not? Just curious.

 

I look forward to your reply.

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com mailto:ron.pick...@intermec.com 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Grace Lin
Sent: Friday, January 09, 2009 8:45 AM
To: Grasso, Charles
Cc: emcp...@aol.com; emc-p...@ieee.org 

Subject: Re: 5 Meter Chamber For EMI Qualification Testing

 

Hi Charles and others,

 

BSMI confirms data taken at 3m per CNS13439 requirements is acceptable.

 

Regards,

Grace Lin

 

On 1/8/09, Grasso, Charles charles.gra...@echostar.com wrote: 

Hi Grace – CNS13439 requires a 3m test to prove compliance. Do you
know if this will be an issue for the BSMI?

 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Grace Lin
Sent: Tuesday, January 06, 2009 9:40 AM
To: emcp...@aol.com; emc-p...@ieee.org
Subject: Re: 5 Meter Chamber For EMI Qualification Testing

 

David, Tim, and Others:

 

It is still an issue in Taiwan.  BSMI do not feel comfortable to accept 3m
data due to the near field concern.  If CISPR 22 (or its replacement)
committee explicitly accepts 3m data, BSMI will accept 3m data.
 

Regards,
Grace

 

On 1/6/09, Heald, David david.he...@garmin.com wrote: 

Tim,

  I know that this has been an issue in Taiwan in the past - I had a
submission rejected a few years ago for this reason. 

I'll defer to someone with more recent experience with Korea since the
regulating agencies just changed there - the last approval I completed there
was at my last job just before the change occurred (now I'm realizing that I
haven't sought approval for a non radio device for a long time in Korea so
there's another reason to defer to someone else).  

As for 1-4, for most devices, you're dealing with self-declaration or its
equivalent.  This is up to you to determine if your results indicate
compliance in a 10m chamber since a 10m chamber is the common reference
indicated in most emissions standards.  Taking the assumption you state into
account, you should be in good condition.  It would be a good idea to obtain
some correllational data to a 10m chamber to confirm you're getting similar
results (and use some engineering judgement in the near field).

 

This is a short response to a complex issue, but I hope it was somewhat
helpful.  

 

Best Regards,

-Dave

 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of emcp...@aol.com
Sent: Monday, January 05, 2009 5:39 PM
To: emc-p...@ieee.org
Subject: 5 Meter Chamber For EMI Qualification Testing
 

Hello Group,

 

I would like to know if radiated emission test data taken at a 3 meter
distance in a 5 meter semi-anechoic chamber is valid for qualification testing
for the following:

 

Please assume that the chamber is fully validated with volumetric NSA.

 

1. FCC/Industry Canada

2. VCCI (Japan)

3. Australia/New Zealand

4. Europe

5. Taiwan

6. Korea

 

I ask this question because I have been hearing that some countries do not
accept 3 meter chamber data.

 

Thanks for your help.

 

Tim Pierce

 



New year...new news. Be the first to know what is making headlines
http://www.aol.com/?ncid=emlcntaolcom0026 .

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This message is from

RE: Cables On The Floor

2008-12-10 Thread Pickard, Ron
Hi Ed,

Google spherical cow and you'll be enlightened. And given the concept,
I'm quite sure the term could find its way into a status report or two.
:-)

Best regards,
 
Ron Pickard
ron.pick...@intermec.com

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Price,
Edward
Sent: Wednesday, December 10, 2008 11:17 AM
To: emc-p...@ieee.org
Subject: RE: Cables On The Floor

 -Original Message-
 From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf 
 Of John Woodgate
 Sent: Wednesday, December 10, 2008 12:21 AM
 To: emc-p...@ieee.org
 Subject: Re: Cables On The Floor
 
 In message
 9d04b979323dcd428297dda95108893e0120c...@bb-corp-ex2.corp.cubic.cub,
 dated Tue, 9 Dec 2008, Price, Edward ed.pr...@cubic.com writes:
 

 You would think that the odds of stepping on the cable would 
 be 285 to 1.
 
 You might, initially, but think about this. To make the math 
 easier, assume a square room and 289 footprints (17^2). So 
 there are 24 footprints along a diagonal. Lay a cable along 
 that diagonal, and all 24 footprints cover it, to a greater 
 or lesser extent. Then there are 23 new footprints along the 
 other diagonal, then 15 new ones along each side... So with 6 
 cables we have 107 footprints on them, out of 289.
 
 Admittedly, this includes 'spherical cow' type 
 approximations, but it shows a trend.
 --

 John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK


I'll defer to your logic, as I was sick the day they explained
combinations and permutations to us. BTW, I'm almost afraid to ask, but
what's a spherical cow?

I think that might great to be able to authoritatively cite that in my
next lab status report!

Ed Price
ed.pr...@cubic.com WB6WSN
NARTE Certified EMC Engineer
Electromagnetic Compatibility Lab
Cubic Defense Applications
San Diego, CA  USA
858-505-2780
Military  Avionics EMC Is Our Specialty

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RE: Outlet Connector 250VAC 2.5 amps

2008-12-10 Thread Pickard, Ron
Hi TOB,

You might find what you're looking for from Shurter at:
http://www.schurter.com

They have quite an assortment of panel mount IEC 60320 style power input
connector products, filtered and unfiltered.

Best regards,
 
Ron Pickard
ron.pick...@intermec.com


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of
pat.law...@slpower.com
Sent: Wednesday, December 10, 2008 3:30 PM
To: emc-p...@ieee.org
Subject: Re: Outlet Connector 250VAC 2.5 amps

You're almost there.  'Outlet' versions of the IEC 320 connectors you 
mentioned would be type C5 or C7.  See
http://en.wikipedia.org/wiki/IEC_connector#C7_and_C8_connectors

However, I don't know where you would buy a chassis-mount version of a
C5 
or C7.

Pat Lawler
EMC Engineer
SL Power Electronics Corp.
6050 King Drive, Bldg. A

emc-p...@ieee.org wrote on 12/10/2008 11:31:49 AM:
 I'm looking for an AC Outlet connector similar to the IEC 60320 C6 
 or C8, but an outlet instead of an inlet.  I need to run AC power 
 out of my product to a small external device which mounts on the 
 side (lab equipment) and will only draw less than 2 amps at 230 
 Vrms. I do not want to use the large Appliance outlet connector. Any
 suggestions?  I checked Interpower and Power Dynamics but no luck.  
 Wouldn't such an application require the ground pin to mate first 
 and break last?  If so then I would be able to use just any connector.

 
 The Other Brian
 
  
 _ 
 
 LECO Corporation Notice:  This communication may contain 
 confidential information intended for the named recipient(s) only. 
 If you received this by mistake, please destroy it and notify us of 
 the error.  Thank  you. 

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RE: FCC testing approved transmitter module in host product

2008-11-17 Thread Pickard, Ron
Hi Bob,

 

If your product utilizes a detachable antenna, a dummy load may replace the
antenna per ANSI C63.4 (13.1.3.1). The term “detachable” in this standard
is not defined, so is left to interpretation. Technically speaking, if an
antenna internally or externally connects to a transmitter via connector, then
the antenna could be considered to be detachable. Therefore, the detachable
antenna may be replaced with a dummy load during AC conducted emissions
testing.

 

However, you know your product’s design and if the RFID antenna is
detachable or not. As a suggestion, consult with your test lab to decide if
your antenna would be considered to be detachable and if use of a dummy load
would be acceptable in your case.

 

IHTH. Please note that the above is my expressed opinion only, except for the
standard reference.

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com mailto:ron.pick...@intermec.com 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of bob syes
Sent: Monday, November 17, 2008 9:22 AM
To: emc-p...@ieee.org
Subject: FCC testing approved transmitter module in host product

 

Worldly Experts,

I am having a problem with a product meeting FCC Class A conducted limit at
13.56 MHz due to radiated signal from internal RFID unit coupling into AC
supply conductors.

The host product complies with Class A limits without RFID module
transmitting.  RFID has FCC modular approval, but was compliance tested for
conducted emissions using a dummy load in place of the antenna.  Is it
therefore acceptable to also test host product (for FCC Class A compliance)
with module transmitting into dummy loads instead of actual antenna?

A search of the FCC knowlege database did not turn up any clues.

adTHANKSvance
Bob Sykes
EMC Engineer

 

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HAC and the FCC

2008-11-17 Thread Pickard, Ron
To all,

 

The FCC is in the process of imposing HAC requirements for digital wireless
phones. I am asking those intimately knowledgeable with that process if this
requirement would also apply to specific B2B products that also include
digital wireless phone capability?

 

I am asking this group as earlier requests to the FCC for clarification on
this point remain unanswered. If there is a specific FCC point of contact for
this, please provide me with the contact details.

 

I look forward to your reply.

 

Best regards,

 

Ron Pickard

ron.pick...@intermec.com mailto:ron.pick...@intermec.com 

 

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RE: Deviation of Performance Criteria - other question.

2008-11-12 Thread Pickard, Ron
Piotr,

Please also consult the EU's EMC Directive guidance document for further
clarification, which can be found at:
http://ec.europa.eu/enterprise/electr_equipment/emc/guides/emcguide_may2
007.pdf

As you have mentioned, your equipment is not a finished product and is
not being put onto the market in the classic sense, but your students
may likely be considered as being end users from the directive's
perspective. Even if not being marketed commercially, it may still be
considered to be placed on the market when being put into service as
described in the Guide. However, if your device, as you describe it, may
be considered as a sub-assembly being made available use by students
(end user), then it is considered as an apparatus and the EMCD applies.
However, if your device may be considered as being inherently benign
(see Guide), the EMCD may not apply. 

But, even if your device must comply with the directive, an assessment
(you have the freedom to define/describe that assessment) should
demonstrate conformance with the essential requirements of the directive
(Article 5, Annex I). IMHO, your previous arguments posted in this
thread could form the basis of that assessment.

Please note that the Guide provides flowcharts that might be helpful in
your navigation of this applies/or not decision process for the EMCD.

So, my advice to you would be to read the directive (Article 4.3 may be
of interest) AND the Guide thoroughly to understand what applies to your
device and what doesn't and your situation. Finally, it may be wise to
consult with someone very familiar with the technical and legal aspects
of the EMCD to provide you with a firm basis for you to proceed.

I hope that you understood my reply as I tried to describe my opinions
well enough in English for you. I also understand that this may have
raised more questions for you, which may not be a bad thing. Education
is good thing, don't you think? Personally, this forum has been a
wonderful learning experience for me over the years, and I hope for
others as well. Maybe this will spawn more comments from our more
learned colleagues, thereby adding to a consensus on this subject.

IHTH and please note that my contributions above are solely my opinions
only. 
 
Best regards,
 
Ron Pickard
ron.pick...@intermec.com

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Piotr
Galka
Sent: Wednesday, November 12, 2008 4:54 AM
To: EMC-PSTC; Sterner, David (NY80)
Subject: Re: Deviation of Performance Criteria - other question.

- Original Message - 
From: Sterner, David (NY80) david.ster...@honeywell.com


Under EMC directive 2004/108/EC, apparatus means any finished
appliance or combination thereof made commercially available as a
single
functional unit, intended for the end user and liable to generate
electromagnetic disturbance, or the performance of which is liable to
be
affected by such disturbance.

As your classroom lab equipment does not seem to fit this definition,
some provisions of the directive are therefore non-applicable.  Marking
is another issue.

I'd really like to understand you, but I'm not good at English (really I

hardly understand not electronic English).
So please tell me what do you suggest ?
My equipment:
- is not finished appliance ?
- is not commercially available ?
- is not functional unit ?
- pupil at school are not end users ?
- it not generates electromagnetic disturbance and can't be affected by
such 
disturbance ?
and why do you think so ?

I'd be very happy if I can be sure my equipment does not fit this
definition 
but it looks I miss some point you see it.

Best Regards

Piotr Galka

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