Re: [PSES] IEC 62368-1: To understand chapter 5.4.11

[Piotr Galka]

Hi Glyn,

I understand that there should not be hazard in all expected situations 
(normal / abnormal use and fault condition) and USB cable is too short 
to consider transients.
What I am trying to do is to understand 62368-1 and reading it I came to 
5.4.11 that was hard for me to understand what are exact listed there 
requirements and if they touch my devices.


That laptop I described is an example of device that looks as being not 
excluded from 5.4.11, and USB is looking (for me) as being external 
circuits according to 62368-1 definition of this therm and being 
indicated in table 14.
The only way to solve this laptop problem, I see, is if we have to 
assume that the note in table 14 of not considering transients (as USB 
is wholly in the same building) makes USB being not indicated in table. 
When first time writing my question I was not sure if I can assume this. 
Now I suppose that I have to assume this (if transients are not taken 
into account than cable is not indicated in table 14).


The device I have in mind is 12V powered access controller hawing RS485 
(not isolated) and because of this RS485 I am trying to understand 5.4.11.

Now I suppose that:
1. It is permanently connected equipment so 5.4.11 not apply, and even 
it is not permanently connected (as being isolated from Mains by 12V 
supply) then
2. RS485 as being whole in one building (transients are not taken into 
account) is not indicated in table 14 so 5.4.11 not apply.


The typical 12V supply used (MEAN WELL DRC-40A) specification says:
  SAFETY STANDARDS:   UL60950-1, TUV EN60950-1 approved
  WITHSTAND VOLTAGE:    I/P-O/P:3KVAC I/P-FG:2KVAC O/P-FG:0.5KVAC

I always assumed that it is better to not Earth DC12V (its negative pole).
Reading 62368-2 5.4.11 description I confirm myself in this belief. Not 
Earthing 12V we not provide (by RS485) Earth potential to a remote 
environment making it being still save even if by any other fault the 
Mains potential can be there.

Do you agree with me?

Best Regards
Piotr Galka


W dniu 2024-05-10 o 17:26, Glyn Payne pisze:


Hi Piotr,

Maximum USB cable lengths are quite short, a few meters, and they are 
not designed to be part of the ‘building or structure’, hence 
transients are not considered for these ports. If a USB extender or 
hub is used to extend the USB and this is wired through the building 
or structure then transients would be the problem of the hub 
manufacturer and not your product.



There was/is /IEC 62368-//3/: /Safety aspects for DC power
transfer through communication cables and ports/, which is
referenced by IEC 62368-1 however this being reworked by TC108 and
as far as I can tell few people are using it in it’s present form.


When testing your product under 62368-1 the test house will
determine the maximum voltage and current the USB (or serial) port
can provide, under normal, abnormal and fault conditions, to
ensure that there is no hazard.


Best regards,


Glyn Payne

*From:*Piotr Galka 
*Sent:* Wednesday, May 8, 2024 9:28 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] IEC 62368-1: To understand chapter 5.4.11




You don't often get email from piotr.ga...@micromade.pl. Learn why 
this is important <https://aka.ms/LearnAboutSenderIdentification>




Hi Bostjan,

I know that if circuit is not going out of building it is considered 
being without transients. My doubt is mainly because in 5.4.11 says 
about circuits being external and indicated in table 14 and according 
to my understanding 3.3.1.1 USB was external and note about transients 
in table 14 for me didn't make for me USB being not indicated in table.
In my RS485 design even it is in one building I assume during storm up 
to 50V temporary difference between several grounding points and I use 
2 steps protection. I know of two such incidents that after lightning 
struck directly into the building, many systems stopped working, but 
ours did.

I acknowledge that USB is not external circuit.
Thanks a lot.

I have never bought any standard abroad and as I have written 
answering to Johns post I see that 62368-2 is not in current Polish 
Standard Committee offer.


Best regards
Piotr Galka

W dniu 2024-05-08 o 18:45, Boštjan Glavič pisze:

Hi Piotr

If circuit does not go out of building it is not considered as
circuit with transients. I think you should check other standard
like IEC 62151 and IEC 62102 which clasify external circuits.

From my experiences, and I do have quite some, USB is not
considered as external circuit in the sense of clause, where
requirements between external circuit and PE are specified.

Did you also check 62368-2?

Best regards

Bostjan

Poslano iz Outlook za Android <https://aka.ms/AAb9ysg>



    *Od:* Piotr Galka 
<mailto:piotr.ga...@micromade.pl>
*Poslano:* sreda, m

Re: [PSES] IEC 62368-1: To understand chapter 5.4.11

[Piotr Galka]

Hi James,

Thank you for drawing attention to this but my sentence was in context 
of 62368-1 only.


When in 2004 (few days after we joined EU) I went with my devices for 
the first time to EMC lab (it was an internal company laboratory that 
also offered external services) they didn't had a capacitors needed in 
surge testing transmission lines. So we tested them using only 40 ohm 
resistor. Since then I design my not isolated RS485 to withstand 25A 
50us current pulse (Surge generator loaded with 40ohm gives current 
pulse of a shape rather like its voltage pulse then its current pulse).
As I have encountered EMC problems in 90s (devices with RS485 having 
only ICs ESD protection routed between buildings standing on the top of 
hill were hanging after every storm) I was well prepared in 2004 and 
they were surprised that all my devices passed all the tests for the 
first time.


Regards
Piotr

W dniu 2024-05-09 o 13:43, James Pawson (U3C) pisze:


Hi Piotr,

Just to add to the debate:

“I know that if circuit is not going out of building it is considered 
being without transients”


If a cable is longer than 30m then most product EMC standards will 
call up a requirement for line-to-earth surge testing. Some do make it 
explicit that this should be only for cables leaving a building or 
site, some do not…


All the best

James

James Pawson

Managing Director & EMC Problem Solver

*Unit 3 Compliance Ltd*

*EMC : Environmental & Vibration : Electrical Safety : CE & UKCA : 
Consultancy*


www.unit3compliance.co.uk <http://www.unit3compliance.co.uk/> | 
ja...@unit3compliance.co.uk <mailto:ja...@unit3compliance.co.uk>


+44(0)1274 911747  |  +44(0)7811 139957

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

Registered in England and Wales # 10574298

/Office hours:/

/Every morning my full attention is on consultancy, testing, and 
troubleshooting activities for our customers’ projects. I’m 
available/contactable between 1300h to 1730h Mon/Tue/Thurs/Fri./


/For inquiries, bookings, and testing updates please send us an email 
on he...@unit3compliance.co.uk or call 01274 911747. Our lead times 
for testing and consultancy are typically 4-5 weeks./


*From:*Piotr Galka 
*Sent:* Wednesday, May 8, 2024 9:28 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] IEC 62368-1: To understand chapter 5.4.11

Hi Bostjan,

I know that if circuit is not going out of building it is considered 
being without transients. My doubt is mainly because in 5.4.11 says 
about circuits being external and indicated in table 14 and according 
to my understanding 3.3.1.1 USB was external and note about transients 
in table 14 for me didn't make for me USB being not indicated in table.
In my RS485 design even it is in one building I assume during storm up 
to 50V temporary difference between several grounding points and I use 
2 steps protection. I know of two such incidents that after lightning 
struck directly into the building, many systems stopped working, but 
ours did.

I acknowledge that USB is not external circuit.
Thanks a lot.

I have never bought any standard abroad and as I have written 
answering to Johns post I see that 62368-2 is not in current Polish 
Standard Committee offer.


Best regards
Piotr Galka

W dniu 2024-05-08 o 18:45, Boštjan Glavič pisze:

Hi Piotr

If circuit does not go out of building it is not considered as
circuit with transients. I think you should check other standard
like IEC 62151 and IEC 62102 which clasify external circuits.

From my experiences, and I do have quite some, USB is not
considered as external circuit in the sense of clause, where
requirements between external circuit and PE are specified.

Did you also check 62368-2?

Best regards

Bostjan

Poslano iz Outlook za Android <https://aka.ms/AAb9ysg>

----

*Od:*Piotr Galka 
<mailto:piotr.ga...@micromade.pl>
*Poslano:* sreda, maj 8, 2024 5:21:33 PM
*Za:* EMC-PSTC@LISTSERV.IEEE.ORG 
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Zadeva:* Re: [PSES] IEC 62368-1: To understand chapter 5.4.11



Hi Bostjan,

Thanks for your feedback, but...

I am slowly and carefully reading 62368-1 for the first time.
It defines 'external circuit' in 3.3.1.1 as "electrical circuit
that is
external to the equipment and is not mains".
I assumed one device = one equipment so I thought laptop is an
equipment. After your post I checked how equipment is defined in
62368-1
but in 3.3 there is no equipment definition so I don't know what is
equipment.
May be USB device (pendrive) connected without cable to laptop can be
assumed being its part, or even device powered by USB (mouse,
keyboard)
can be assumed being its part, but USB can be used to connect other
equipment, I think. Do laser printer being power

Re: [PSES] IEC 62368-1: To understand chapter 5.4.11

[Piotr Galka]

Hi Ralph and John,

62368-1 I have bought from PKN is in form "first and last page Polish 
and everything inside English".
I suppose they with pleasure will charge me for 62368-2 if I ask them 
for it. The only question is how much time is needed to prepare these 2 
pages.
As I remember from times when I was writing here from time to time - we 
came to conclusion that PKN prices were clearly lower then in other sources.


What I am surprised the most: Do really I (a guy from a company with 4 
employees) am the first one in Poland being interested in 62368-2 :)


Best Regards
Piotr Galka



W dniu 2024-05-08 o 23:07, Ralph McDiarmid pisze:

Signature

The IEC store has IEC TR 62368-2:2019 RLV for 553 Swiss Francs.   Ouch.

*From:*John Woodgate 
*Sent:* Wednesday, May 8, 2024 1:37 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] IEC 62368-1: To understand chapter 5.4.11

You can get 62368-2 from: https://www.evs.ee/en/iec-tr-62368-2-2019, 
but it is rather costly.


On 2024-05-08 21:00, Piotr Galka wrote:

After reading your post my decision was to buy 62368-2 but I've
just checked that in PKN (Polish Standards Committee) I can buy
62368-1 what I have done long ago but they don't have 62368-2 :( .

--
OOO - Own Opinions Only
Best wishes
John Woodgate, Rayleigh, Essex UK
Keep trying

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Re: [PSES] IEC 62368-1: To understand chapter 5.4.11

[Piotr Galka]

Hi Bostjan,

I know that if circuit is not going out of building it is considered 
being without transients. My doubt is mainly because in 5.4.11 says 
about circuits being external and indicated in table 14 and according to 
my understanding 3.3.1.1 USB was external and note about transients in 
table 14 for me didn't make for me USB being not indicated in table.
In my RS485 design even it is in one building I assume during storm up 
to 50V temporary difference between several grounding points and I use 2 
steps protection. I know of two such incidents that after lightning 
struck directly into the building, many systems stopped working, but 
ours did.

I acknowledge that USB is not external circuit.
Thanks a lot.

I have never bought any standard abroad and as I have written answering 
to Johns post I see that 62368-2 is not in current Polish Standard 
Committee offer.


Best regards
Piotr Galka


W dniu 2024-05-08 o 18:45, Boštjan Glavič pisze:

Hi Piotr

If circuit does not go out of building it is not considered as circuit 
with transients. I think you should check other standard like IEC 
62151 and IEC 62102 which clasify external circuits.


From my experiences, and I do have quite some, USB is not considered 
as external circuit in the sense of clause, where requirements between 
external circuit and PE are specified.


Did you also check 62368-2?

Best regards
Bostjan





Poslano iz Outlook za Android <https://aka.ms/AAb9ysg>


*Od:* Piotr Galka 
*Poslano:* sreda, maj 8, 2024 5:21:33 PM
*Za:* EMC-PSTC@LISTSERV.IEEE.ORG 
*Zadeva:* Re: [PSES] IEC 62368-1: To understand chapter 5.4.11

Hi Bostjan,

Thanks for your feedback, but...

I am slowly and carefully reading 62368-1 for the first time.
It defines 'external circuit' in 3.3.1.1 as "electrical circuit that is
external to the equipment and is not mains".
I assumed one device = one equipment so I thought laptop is an
equipment. After your post I checked how equipment is defined in 62368-1
but in 3.3 there is no equipment definition so I don't know what is
equipment.
May be USB device (pendrive) connected without cable to laptop can be
assumed being its part, or even device powered by USB (mouse, keyboard)
can be assumed being its part, but USB can be used to connect other
equipment, I think. Do laser printer being powered separately from mains
connected to laptop is understood as being internal part of equipment?
Laptop is probably manufactured by someone else than laser printer. They
can't assume they manufacture single equipment, I think.
In past I have read about USB being used to connect active wifi antenna
located on the roof (with few hubs to extend connection length). Having
all that in mind it is hard for me to accept that for 62368-1 USB is
equipment internal circuit.

Now.
If we assume laptop with connected to it mouse, external keyboard and
printer is one equipment then going to my field: do the access control
controller with RFID readers connected to it by RS485 is also one
equipment (all powered from one 12V supply, and located in one building)
making RS485 connection being internal equipment circuit?
I don't think so.

And I repeat my main question regarding 5.4.11: Do the access controller
permanently connected to 12V supply that is permanently connected to
mains is permanently connected equipment? I think yes. Even 12V supply
has isolation in it.
If I change understanding of equipment and assume that controller + 12V
supply are one equipment than thinks get easier - such understood
equipment is permanently connected. But is it one equipment if
controller is manufactured by someone other then 12V supply.

Best regards
Piotr Galka

W dniu 2024-05-07 o 19:49, Boštjan Glavič pisze:
> Hi Piotr
>
> USB circuit is internal circuit. There are no transients expected on 
USB. Clause 5.4.11 is not applicable for power supply with USB output.

>
> Paired conductor is a telecommunication network that we had in old 
times (analogue network, ISDN,...).

>
> I hope this helps. If you need more info, you can contact me.
>
> Best regards,
> Boštjan
>
>
>
> -Original Message-
> From: Piotr Galka 
> Sent: Tuesday, May 7, 2024 5:40 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: [PSES] IEC 62368-1: To understand chapter 5.4.11
>
> CAUTION: This email originated from outside of our organisation. Do 
not click links or open attachments unless you recognise the sender 
and know the content is safe.

>
>
> Trying to understand 62368-1...
>
> I have got laptop with type A power supply so it looks being not 
excluded from 5.4.11 by rules in 5.4.11.1.

> For me USB are external circuits indicated in Table 14, ID numbers 1 and
> 2 (I think USB is 'Paired conductor', but even not it certainly is 
'Any other conductors').
> The note in Table 14 about not taking into account transi

Re: [PSES] IEC 62368-1: To understand chapter 5.4.11

[Piotr Galka]

Hi John,

I hoped you will answer my question and I got important information from 
you. Thanks.


After reading your post my decision was to buy 62368-2 but I've just 
checked that in PKN (Polish Standards Committee) I can buy 62368-1 what 
I have done long ago but they don't have 62368-2 :( .


Even not seeing explanations the requirements should be so written that 
there should be no doubts when reading them. I really don't know how to 
read 3.3.1.1 to understand USB as internal, but I accept to understand 
it as internal.


This laptop and USB is an example that should help me to understand the 
standard and I think I got pointing in the right direction (I am using 
USB (desktop RFID card readers/writers, pen-drive like devices 
implementing crypto functions)).


Our access control devices accept 12 or 24V supply (I think 99% 
installations use 12V because such supplies/batteries are more popular). 
We use RS485 that we require the whole bus being in one building. We use 
Ethernet but when connecting many controllers to it the routers/switches 
also are close to them so we also specify that this connection have to 
be in one building.


Since 2020 we had very hard time because ATXmega microcontrollers (and 
also other ICs) we used disappeared from marked and we had to redesign 
all our products to the other IC that happened to be able to buy. The 
side effect is that all our CE declarations are outdated. I want to 
issue new ones. And because of this I want to understand 62368-1.


Best regards
Piotr Galka
P.S.
Note out of EMC-PSTC subject but connected with standards...
Recently my heart has been hurting because while the whole world is 
trying to save energy, we have been forced to issue readers that have 40 
to 400 times more energy consumption for RS485 transmission than our 
previous ones. And to not be eliminated from market we seriously think 
about doing the same change in all our devices. Standards are not 
mandatory, but if they are issued than market forces to use them. When I 
imagine how many RS485 busses work all the time all over the world...




W dniu 2024-05-08 o 17:52, John Woodgate pisze:


To fully understand IEC 62368-1, you also need to read IEC 62368-2. It 
includes a long explanatory text about 5.4.11. The committee realised 
that it was not practicable to put all the explanations into the same 
document as the requirements. The circuits feeding the USB connectors 
of a device are internal circuits. But are you actually using USB or 
are you mentioning it as an example? For your access controller 
connected to a 12V supply that is permanently connected to mains, the 
isolated low-voltage circuits in the 12 V supply equipment are 
internal circuits and are not subject to transients. Anything 
connected to the 12 V DC supply is ES1.


On 2024-05-08 16:21, Piotr Galka wrote:

Hi Bostjan,

Thanks for your feedback, but...

I am slowly and carefully reading 62368-1 for the first time.
It defines 'external circuit' in 3.3.1.1 as "electrical circuit that 
is external to the equipment and is not mains".
I assumed one device = one equipment so I thought laptop is an 
equipment. After your post I checked how equipment is defined in 
62368-1 but in 3.3 there is no equipment definition so I don't know 
what is equipment.
May be USB device (pendrive) connected without cable to laptop can be 
assumed being its part, or even device powered by USB (mouse, 
keyboard) can be assumed being its part, but USB can be used to 
connect other equipment, I think. Do laser printer being powered 
separately from mains connected to laptop is understood as being 
internal part of equipment? Laptop is probably manufactured by 
someone else than laser printer. They can't assume they manufacture 
single equipment, I think.
In past I have read about USB being used to connect active wifi 
antenna located on the roof (with few hubs to extend connection 
length). Having all that in mind it is hard for me to accept that for 
62368-1 USB is equipment internal circuit.


Now.
If we assume laptop with connected to it mouse, external keyboard and 
printer is one equipment then going to my field: do the access 
control controller with RFID readers connected to it by RS485 is also 
one equipment (all powered from one 12V supply, and located in one 
building) making RS485 connection being internal equipment circuit?

I don't think so.

And I repeat my main question regarding 5.4.11: Do the access 
controller permanently connected to 12V supply that is permanently 
connected to mains is permanently connected equipment? I think yes. 
Even 12V supply has isolation in it.
If I change understanding of equipment and assume that controller + 
12V supply are one equipment than thinks get easier - such understood 
equipment is permanently connected. But is it one equipment if 
controller is manufactured by someone other then 12V supply.


Best regards
Piotr Galka

W dniu 2024-05-07 o 19:49, Boštjan Glavič pisze:

Hi 

Re: [PSES] IEC 62368-1: To understand chapter 5.4.11

[Piotr Galka]

Hi Bostjan,

Thanks for your feedback, but...

I am slowly and carefully reading 62368-1 for the first time.
It defines 'external circuit' in 3.3.1.1 as "electrical circuit that is 
external to the equipment and is not mains".
I assumed one device = one equipment so I thought laptop is an 
equipment. After your post I checked how equipment is defined in 62368-1 
but in 3.3 there is no equipment definition so I don't know what is 
equipment.
May be USB device (pendrive) connected without cable to laptop can be 
assumed being its part, or even device powered by USB (mouse, keyboard) 
can be assumed being its part, but USB can be used to connect other 
equipment, I think. Do laser printer being powered separately from mains 
connected to laptop is understood as being internal part of equipment? 
Laptop is probably manufactured by someone else than laser printer. They 
can't assume they manufacture single equipment, I think.
In past I have read about USB being used to connect active wifi antenna 
located on the roof (with few hubs to extend connection length). Having 
all that in mind it is hard for me to accept that for 62368-1 USB is 
equipment internal circuit.


Now.
If we assume laptop with connected to it mouse, external keyboard and 
printer is one equipment then going to my field: do the access control 
controller with RFID readers connected to it by RS485 is also one 
equipment (all powered from one 12V supply, and located in one building) 
making RS485 connection being internal equipment circuit?

I don't think so.

And I repeat my main question regarding 5.4.11: Do the access controller 
permanently connected to 12V supply that is permanently connected to 
mains is permanently connected equipment? I think yes. Even 12V supply 
has isolation in it.
If I change understanding of equipment and assume that controller + 12V 
supply are one equipment than thinks get easier - such understood 
equipment is permanently connected. But is it one equipment if 
controller is manufactured by someone other then 12V supply.


Best regards
Piotr Galka

W dniu 2024-05-07 o 19:49, Boštjan Glavič pisze:

Hi Piotr

USB circuit is internal circuit. There are no transients expected on USB. 
Clause 5.4.11 is not applicable for power supply with USB output.

Paired conductor is a telecommunication network that we had in old times 
(analogue network, ISDN,...).

I hope this helps. If you need more info, you can contact me.

Best regards,
Boštjan



-Original Message-----
From: Piotr Galka 
Sent: Tuesday, May 7, 2024 5:40 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] IEC 62368-1: To understand chapter 5.4.11

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


Trying to understand 62368-1...

I have got laptop with type A power supply so it looks being not excluded from 
5.4.11 by rules in 5.4.11.1.
For me USB are external circuits indicated in Table 14, ID numbers 1 and
2 (I think USB is 'Paired conductor', but even not it certainly is 'Any other 
conductors').
The note in Table 14 about not taking into account transients for external 
circuits installed wholly within the same building is only about transients so 
I think it doesn't make USB being not indicated in table.
USB cable can be used to connect laptop to printer and in printer USB can be 
earthed, I think.
Dos this means that according to first sentence of 5.4.11.2 each USB port in 
this laptop should be separated from its other USB ports?
I don't believe there is such requirement.

My real problem to understand is as follows:
Typical access controller have several not separated from each other inputs 
(several RFID reader inputs, door state control input, tamper inputs and 
others).
I need to understand if the access controller powered from (external to
it) 12V DC buffered (= having accu in it) supply is permanently connected 
equipment or not?
To disconnect it from 12V supply you need tools, to disconnect 12V supply from 
mains you need tools, but 12V supply has isolation in it so access controller 
is not electrically connected to mains and 3.3.3.4 says about needing tools to 
disconnect from mains (if something is not connected than tools are not needed 
to make it being disconnected, I think).
Being permanently connected equipment is the easiest way for controller to be 
excluded from 5.4.11.
But if it is not permanently connected than its inputs are in the same 
situation as laptop USB ports I described first as more common to everyone.

What I miss or wrongly understand?

Regards
Piotr Galka

P.S.
Last month free time I spend browsing about 2800 EMC-PSTC posts collected by my 
mail program for few years.

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[PSES] IEC 62368-1: To understand chapter 5.4.11

[Piotr Galka]

Trying to understand 62368-1...

I have got laptop with type A power supply so it looks being not 
excluded from 5.4.11 by rules in 5.4.11.1.
For me USB are external circuits indicated in Table 14, ID numbers 1 and 
2 (I think USB is 'Paired conductor', but even not it certainly is 'Any 
other conductors').
The note in Table 14 about not taking into account transients for 
external circuits installed wholly within the same building is only 
about transients so I think it doesn't make USB being not indicated in 
table.
USB cable can be used to connect laptop to printer and in printer USB 
can be earthed, I think.
Dos this means that according to first sentence of 5.4.11.2 each USB 
port in this laptop should be separated from its other USB ports?

I don't believe there is such requirement.

My real problem to understand is as follows:
Typical access controller have several not separated from each other 
inputs (several RFID reader inputs, door state control input, tamper 
inputs and others).
I need to understand if the access controller powered from (external to 
it) 12V DC buffered (= having accu in it) supply is permanently 
connected equipment or not?
To disconnect it from 12V supply you need tools, to disconnect 12V 
supply from mains you need tools, but 12V supply has isolation in it so 
access controller is not electrically connected to mains and 3.3.3.4 
says about needing tools to disconnect from mains (if something is not 
connected than tools are not needed to make it being disconnected, I think).
Being permanently connected equipment is the easiest way for controller 
to be excluded from 5.4.11.
But if it is not permanently connected than its inputs are in the same 
situation as laptop USB ports I described first as more common to everyone.


What I miss or wrongly understand?

Regards
Piotr Galka

P.S.
Last month free time I spend browsing about 2800 EMC-PSTC posts 
collected by my mail program for few years.


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Re: [PSES] Safe powering 12V doorlock

[Piotr Galka]

Hi Bostjan,

Previously I looked in definitions list in alphabetic order and there is 
no SECONDARY CIRCUIT (in Polish adoption of not translated standard). 
But looking in not alphabetic I found it and I see my 12V is the 
SECONDARY CIRCUIT.


If the sentence I cited previously refers to products powered by 
secondary circuit (for example my 12V) I think It should be written more 
clearly. It should be not "for SECONDARY CIRCUIT" but "for devices 
powered by SECONDARY CIRCUIT" or something like this.


I remember someone told me here (I think 8..10 years ago) that literally 
understanding the 60950-1 I am right, but practice is different. I think 
it was about varistor crossing the isolation in my device powered from 12V.


It looks it is the second such situation.

Best Regards
Piotr


W dniu 2017-11-23 o 13:46, Boštjan Glavič pisze:

Hi Piotr,

This refers to products supplied by secondary circuit. Power supply is supplied 
by AC mains therefore primary circuit. For OVC II we always apply 5B. You can 
trust me on this since we approve many power supplies.

Best regards,
Bostjan



-Original Message-----
From: Piotr Galka [mailto:piotr.ga...@micromade.pl]
Sent: Thursday, November 23, 2017 1:25 PM
To: Boštjan Glavič <bostjan.gla...@siq.si>; EMC-PSTC 
<emc-pstc@listserv.ieee.org>
Subject: Re: [PSES] Safe powering 12V doorlock

Hi Bostjan,

In 5.2.2 there is the sentence: "However, for a SECONDARY CIRCUIT that is neither 
connected to protective earth nor provided with a protective screen in accordance with 
2.6.1 e), Table 5C shall be used."

I understand that, that way it depends on output which table to select.
In Definitions I don't see SECONDARY CIRCUIT but I understand 12V as being here 
SECONDARY CIRCUIT.

As it is (can be) not connected to earth and I don't know of protective screen 
I'm not sure - may be 5C applies.

Beast Regards
Piotr


W dniu 2017-11-23 o 05:49, Boštjan Glavič pisze:

Hi Piotr,

I agree with Rich.

According to specification, output also complies with LPS (Limited Power 
Source) therefore output must be SELV.

There is no PELV definition in IEC 60950-1.


About table 5B or 5C, which table you will use does not depend on output from your 
power supply but on mains voltage (main network system). For normal application we 
are using STAR system with 230V L to N voltage with OVC II --> you can use 
table 5B.

Table 5C is used for OVC III applications.

I hope this helps.

Best regards,
Bostjan

-Original Message-
From: Richard Nute [mailto:ri...@ieee.org]
Sent: Thursday, November 23, 2017 2:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safe powering 12V doorlock

Hi Piotr:

The easy way to answer your questions is to request a copy of the TUV report.

1. I suppose that 12 doorlock manufacturer can use only functional isolation 
betwean 12V and its metal casing as he can assume (I think) that he gets safe 
voltage.
If I'm wrong with it let me know.

Yes, only functional insulation between the 12 volts and the metal casing.

2. Then as doorlock metal casing can be touched by user than 12V have to be 
SELV circuit I think.

Yes.  SELV or PELV; makes no difference.

3. I'm not sure if the 12V output from this supply is SELV - is it enough to 
test the isolation with 3kV.

No, 3 kV alone is not sufficient.  The isolation must also meet creepage and 
clearance distances after being subject to a mechanical test of the isolation 
means and the conductors.

Best regards,
Rich

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Re: [PSES] Safe powering 12V doorlock

[Piotr Galka]

Hi Bostjan,

In 5.2.2 there is the sentence: "However, for a SECONDARY CIRCUIT that 
is neither connected to protective earth nor provided with a protective 
screen in accordance with 2.6.1 e), Table 5C shall be used."


I understand that, that way it depends on output which table to select.
In Definitions I don't see SECONDARY CIRCUIT but I understand 12V as 
being here SECONDARY CIRCUIT.


As it is (can be) not connected to earth and I don't know of protective 
screen I'm not sure - may be 5C applies.


Beast Regards
Piotr


W dniu 2017-11-23 o 05:49, Boštjan Glavič pisze:

Hi Piotr,

I agree with Rich.

According to specification, output also complies with LPS (Limited Power 
Source) therefore output must be SELV.

There is no PELV definition in IEC 60950-1.


About table 5B or 5C, which table you will use does not depend on output from your 
power supply but on mains voltage (main network system). For normal application we 
are using STAR system with 230V L to N voltage with OVC II --> you can use 
table 5B.

Table 5C is used for OVC III applications.

I hope this helps.

Best regards,
Bostjan

-Original Message-
From: Richard Nute [mailto:ri...@ieee.org]
Sent: Thursday, November 23, 2017 2:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safe powering 12V doorlock

Hi Piotr:

The easy way to answer your questions is to request a copy of the TUV report.

1. I suppose that 12 doorlock manufacturer can use only functional isolation 
betwean 12V and its metal casing as he can assume (I think) that he gets safe 
voltage.
If I'm wrong with it let me know.

Yes, only functional insulation between the 12 volts and the metal casing.

2. Then as doorlock metal casing can be touched by user than 12V have to be 
SELV circuit I think.

Yes.  SELV or PELV; makes no difference.

3. I'm not sure if the 12V output from this supply is SELV - is it enough to 
test the isolation with 3kV.

No, 3 kV alone is not sufficient.  The isolation must also meet creepage and 
clearance distances after being subject to a mechanical test of the isolation 
means and the conductors.

Best regards,
Rich

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Re: [PSES] Safe powering 12V doorlock

[Piotr Galka]

Hi Rich,

Thanks for confirming that isolation in doorlock can be only functional. 
This eliminates me one conception that 12V can be ELV, but second 
isolation is in doorlock.
So now, as I'm sure that 12V have to be SELV/PELV I have to ask them if 
it is.
I know that for other supplies they specify that output is SELV but here 
not, but they write that application can be access control so doorlocks


There are TUV certificates at this supply page, but not report.

I don't know if I will be able to read with enough understanding the TUV 
report. I have never seen one.


Best Regards
Piotr


W dniu 2017-11-23 o 02:28, Richard Nute pisze:

Hi Piotr:

The easy way to answer your questions is to request a copy of the TUV report.

1. I suppose that 12 doorlock manufacturer can use only functional isolation 
betwean 12V and its metal casing as he can assume (I think) that he gets safe 
voltage.
If I'm wrong with it let me know.

Yes, only functional insulation between the 12 volts and the metal casing.

2. Then as doorlock metal casing can be touched by user than 12V have to be 
SELV circuit I think.

Yes.  SELV or PELV; makes no difference.

3. I'm not sure if the 12V output from this supply is SELV - is it enough to 
test the isolation with 3kV.

No, 3 kV alone is not sufficient.  The isolation must also meet creepage and 
clearance distances after being subject to a mechanical test of the isolation 
means and the conductors.

Best regards,
Rich

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Re: [PSES] Safe powering 12V doorlock

[Piotr Galka]

Richard,

In EN50491-3 (HBES & BACS safety) ELV, SELV, PELV are defined I think 
the same way as you show. But except definition there are also Notes. I 
have only Polish translation so may be not precise writing what was in 
original.
Under SELV definition there is Note 1: SELV circuit is separated from 
PELV circuits, other SELV systems and _ground_ with simple separation, 
and from other circuits with protective separation.

simple separation - using basic isolation
basic isolation - giving basic protection

I can imagine a kind of capacitor/resistor divider from AC to PELV with 
other resistor end connected to other circuit that is grounded. If this 
grounding fails the voltage at PELV can be higher, so it is PELV and not 
SELV. If we think about Gom resistances than even if PELV would be in 
such situation 200V but 1nA it should be no problem I think. So if it 
have to be lower value resistances than if PELV is connected by this to 
other circuit is it still other circuit or they are boith the one circuit.


I think It would help everyone if examples of situations in mind would 
be just written everywhere where PELV and SELV are defined.


Regards
Piotr Galka


W dniu 2017-11-23 o 02:08, Richard Nute pisze:

For definitions of ELV, SELV, and PELV, I turn to IEC TC64, Electrical 
installations and protection against electric shock, and its publication 61140, 
Protection against electric shock – Common aspects for installation and 
equipment. TC 64 is “to lay down basic safety requirements for protection 
against electric shock for use by technical committees.” IEC 61140 is “… a 
Basic Safety Publication intended for use by technical committees in the 
preparation of standards in accordance with the principles of IEC Guide 104 and 
ISO/IEC Guide 51.”

IEC 61140 defines ELV, SELV, and PELV:

3.26
extra-low-voltage (ELV)
any voltage not exceeding the relevant voltage limit specified in IEC 61201

3.26.1
SELV system
an electrical system in which the voltage cannot exceed ELV:
– under normal conditions; and
– under single-fault conditions, including earth faults in other circuits

3.26.2
PELV system
an electrical system in which the voltage cannot exceed ELV:
– under normal conditions, and
– under single-fault conditions, except earth faults in other circuits

Most product safety standards prohibit access to ELV on the assumption that ELV 
is not adequately separated from a higher voltage.

I admit that I don't understand the statements about earth faults in other 
circuits.  I don't know how an earth fault in another circuit can increase the 
voltage of SELV or PELV.

However, in my reading of 61140, I did not find any requirement that either 
SELV or PELV could or could not be connected to earth.

Rich



-Original Message-
From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Wednesday, November 22, 2017 2:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safe powering 12V doorlock

The definition of PELV that I have is, I think, from IEC 60364, and it says 
'not electrically separated from earth', which I interpret as meaning 
'connected to earth but not necessarily with a connection that can withstand a 
large fault current'.

You must do as you see fit, but I think that if a potentially fatal fault, 
however improbable, could exist undetected, but could be neutralized by a 
simple earth connection, it would be good practice to provide the earth 
connection.

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

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Re: [PSES] Safe powering 12V doorlock

[Piotr Galka]

John,

Reading EN 50491-3 (HBES and BACS safety) it looks that for devices like 
our controller 60950-1 is right choice. I have newer found the better 
fitting standrd.

Meanwell also selected 60950-1 for their supply.
So the only unknown are the standard for doorlock and wires :).

If the connection of SELV to allow for table 5B need not be serious but 
only connection then in power cross I would not be sure if it would just 
not be burn out without other effects and hazard would be unknown.


I am not doing myself the installations but as I know there are some 
rules which have to be followed. I believe the 12V cables can not be put 
together with 230V cables.


Piotr

W dniu 2017-11-22 o 19:51, John Woodgate pisze:


But does 60950-1 apply when the application is a door lock?  In any 
case, I am not suggesting that any particular power supply is 
unreliable, but you never know what happens in installations and 
'power cross' is not an unknown hazard.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2017-11-22 18:09, Nyffenegger, Dave wrote:

In order for a power supply to meet SELV requirements it must pass all of the 
tests in the EN60950-1 standard for SELV which means component failure testing 
among other things, not simply isolation testing.  Meanwell power supplies that 
I have researched have been SELV.  Meanwell  has been very responsive if you 
contact technical support and will provide the lab reports showing the power 
supply passed the relevant SELV clauses in the standard.

If the power supply is UL approved the UL certificate available on the UL web 
site may indicate whether or not it's SELV as well as power supply class and 
other basic ratings.

-Dave

-Original Message-
From: Piotr Galka [mailto:piotr.ga...@micromade.pl]
Sent: Wednesday, November 22, 2017 12:51 PM
To:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Safe powering 12V doorlock

Dear safety experts,

Help me to make me sure that it is save to use the following power supply:
http://www.meanwell.com/webapp/product/search.aspx?prod=DRC-40
to power 12V doorlock with not earthed 12V supply.

I think that from practical point of view it is save but how it looks formally.

This supply is TUV EN60950-1 approved, and input to output is tested with 
3kVAC. There is no info if output is SELV or ELV.
Before asking them if their output is SELV I'd like to know if it has to be 
SELV, or if from info I have I can find it is SELV. I wont to use this case to 
learn myself more about safety.

Why I'm not sure.
1. I suppose that 12 doorlock manufacturer can use only functional isolation 
betwean 12V and its metal casing as he can assume (I think) that he gets safe 
voltage.
If I'm wrong with it let me know.
2. Then as doorlock metal casing can be touched by user than 12V have to be 
SELV circuit I think.
3. I'm not sure if the 12V output from this supply is SELV - is it enough to 
test the isolation with 3kV.

In EN 60950-1:2006 5.2.2 I understand that if output is not grounded or there 
is no protective screen than table 5C should be used.
I assume not earthing 12V.
I don't know if there is protective screen inside but as I can imagine such 
supply there have to be feedback and it is probably opto feedback - so can 
there be metal screen betwean LED and opto element and opto will work? I'm not 
sure if I understand well what is screen in accordance with 2.6.1 e).
  From Annex G I understand that for Overvoltage Category II transient voltage 
(Europe) will be 2k5V and from table 5C I have 5kV test needed.
So 3kV written in datasheet looks being not enough.

All till now I have written assuming the Overvoltage Category II. But reading 
Annex Z I'm not sure if access control system, as permanently installed, is 
integral building wiring or not. It seems me more like a fuse panel then 
permanently connected electric cooker. If category III then I end with 8kV 
testing - much more than 3kV.

It is TUV approved and under Applications the producer lists Access Systems so 
powering doorlock should be save. If it is true - where is my mistake.

Best Regards
Piotr Galka

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Re: [PSES] Safe powering 12V doorlock

[Piotr Galka]

Dave,

I was thinking if first ask Meanwell or here, and decided to ask here 
believing I will learn more.
Till now from Meanwell reseller in Poland I know that for some supplies 
they specify that output is SELV, but for this one there is no such 
information.


I plan to ask them following discussion here.

Regards
Piotr


W dniu 2017-11-22 o 19:09, Nyffenegger, Dave pisze:

In order for a power supply to meet SELV requirements it must pass all of the 
tests in the EN60950-1 standard for SELV which means component failure testing 
among other things, not simply isolation testing.  Meanwell power supplies that 
I have researched have been SELV.  Meanwell  has been very responsive if you 
contact technical support and will provide the lab reports showing the power 
supply passed the relevant SELV clauses in the standard.

If the power supply is UL approved the UL certificate available on the UL web 
site may indicate whether or not it's SELV as well as power supply class and 
other basic ratings.

-Dave

-Original Message-
From: Piotr Galka [mailto:piotr.ga...@micromade.pl]
Sent: Wednesday, November 22, 2017 12:51 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Safe powering 12V doorlock

Dear safety experts,

Help me to make me sure that it is save to use the following power supply:
http://www.meanwell.com/webapp/product/search.aspx?prod=DRC-40
to power 12V doorlock with not earthed 12V supply.

I think that from practical point of view it is save but how it looks formally.

This supply is TUV EN60950-1 approved, and input to output is tested with 
3kVAC. There is no info if output is SELV or ELV.
Before asking them if their output is SELV I'd like to know if it has to be 
SELV, or if from info I have I can find it is SELV. I wont to use this case to 
learn myself more about safety.

Why I'm not sure.
1. I suppose that 12 doorlock manufacturer can use only functional isolation 
betwean 12V and its metal casing as he can assume (I think) that he gets safe 
voltage.
If I'm wrong with it let me know.
2. Then as doorlock metal casing can be touched by user than 12V have to be 
SELV circuit I think.
3. I'm not sure if the 12V output from this supply is SELV - is it enough to 
test the isolation with 3kV.

In EN 60950-1:2006 5.2.2 I understand that if output is not grounded or there 
is no protective screen than table 5C should be used.
I assume not earthing 12V.
I don't know if there is protective screen inside but as I can imagine such 
supply there have to be feedback and it is probably opto feedback - so can 
there be metal screen betwean LED and opto element and opto will work? I'm not 
sure if I understand well what is screen in accordance with 2.6.1 e).
  From Annex G I understand that for Overvoltage Category II transient voltage 
(Europe) will be 2k5V and from table 5C I have 5kV test needed.
So 3kV written in datasheet looks being not enough.

All till now I have written assuming the Overvoltage Category II. But reading 
Annex Z I'm not sure if access control system, as permanently installed, is 
integral building wiring or not. It seems me more like a fuse panel then 
permanently connected electric cooker. If category III then I end with 8kV 
testing - much more than 3kV.

It is TUV approved and under Applications the producer lists Access Systems so 
powering doorlock should be save. If it is true - where is my mistake.

Best Regards
Piotr Galka

-

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Re: [PSES] Safe powering 12V doorlock

[Piotr Galka]

John,

If the output is SELV earthed (in other standards PELV) then (as I read 
60950-1) table 5B applies and test 3kV is ok. If you decide to use 5C 
table then because of earthing you can use one level lower test voltage 
(as I read Annex G) and you end also with 3kV test.
But there is no info about need to earth the 12V output of this supply, 
and I have other reasons to not earth it.
We produce access door controller and we are supposed to specify a metal 
box, power supply, battery to be used with our controller. I am just 
trying to find if I can specify this one (I like it because of its small 
dimensions).


As I understand PELV doesn't mean earthed but only not isolated from 
Earth with basic isolation. It can be isolated with functional isolation 
and it is PELV.


Where to find in 60950-1 how hard have to be earthing of SELV to allow 
for using table 5B. In 5.2.2 there is only word connected. Does that 
mean that any connection of 12V output to earth (even with 100m thin 
wire)  is enough to use table 5B?


Piotr


W dniu 2017-11-22 o 19:13, John Woodgate pisze:


We need to be very careful here. There is not a single definition of 
'SELV'. Some definitions allow the LV circuit to be earthed, some do 
not, and refer to 'Protected Extra-Low Voltage (PELV)' for SELV which 
is earthed. Non-earthed SELV is OK for some purposes, but  I don't 
like it for situations where an insulation failure (which might not be 
in the parts that are tested to 3 kV) allows the LV circuit to become 
live and for that fault to persist indefinitely undetected, which I 
think is your situation. For such applications I prefer PELV, and I 
think your 3 kV test may be acceptable for PELV, depending on which 
safety standard applies.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2017-11-22 17:50, Piotr Galka wrote:

Dear safety experts,

Help me to make me sure that it is save to use the following power 
supply:

http://www.meanwell.com/webapp/product/search.aspx?prod=DRC-40
to power 12V doorlock with not earthed 12V supply.

I think that from practical point of view it is save but how it looks 
formally.


This supply is TUV EN60950-1 approved, and input to output is tested 
with 3kVAC. There is no info if output is SELV or ELV.
Before asking them if their output is SELV I'd like to know if it has 
to be SELV, or if from info I have I can find it is SELV. I wont to 
use this case to learn myself more about safety.


Why I'm not sure.
1. I suppose that 12 doorlock manufacturer can use only functional 
isolation betwean 12V and its metal casing as he can assume (I think) 
that he gets safe voltage.

If I'm wrong with it let me know.
2. Then as doorlock metal casing can be touched by user than 12V have 
to be SELV circuit I think.
3. I'm not sure if the 12V output from this supply is SELV - is it 
enough to test the isolation with 3kV.


In EN 60950-1:2006 5.2.2 I understand that if output is not grounded 
or there is no protective screen than table 5C should be used.

I assume not earthing 12V.
I don't know if there is protective screen inside but as I can 
imagine such supply there have to be feedback and it is probably opto 
feedback - so can there be metal screen betwean LED and opto element 
and opto will work? I'm not sure if I understand well what is screen 
in accordance with 2.6.1 e).
From Annex G I understand that for Overvoltage Category II transient 
voltage (Europe) will be 2k5V and from table 5C I have 5kV test 
needed. So 3kV written in datasheet looks being not enough.


All till now I have written assuming the Overvoltage Category II. But 
reading Annex Z I'm not sure if access control system, as permanently 
installed, is integral building wiring or not. It seems me more like 
a fuse panel then permanently connected electric cooker. If category 
III then I end with 8kV testing - much more than 3kV.


It is TUV approved and under Applications the producer lists Access 
Systems so powering doorlock should be save. If it is true - where is 
my mistake.


Best Regards
Piotr Galka

-

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 <emc-p...@ieee.org>


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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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Mike Cantwell <mcantw...@ieee.org>

For policy questions, send mail to:
Jim Bacher: <j.bac...@

[PSES] Safe powering 12V doorlock

[Piotr Galka]

Dear safety experts,

Help me to make me sure that it is save to use the following power supply:
http://www.meanwell.com/webapp/product/search.aspx?prod=DRC-40
to power 12V doorlock with not earthed 12V supply.

I think that from practical point of view it is save but how it looks 
formally.


This supply is TUV EN60950-1 approved, and input to output is tested 
with 3kVAC. There is no info if output is SELV or ELV.
Before asking them if their output is SELV I'd like to know if it has to 
be SELV, or if from info I have I can find it is SELV. I wont to use 
this case to learn myself more about safety.


Why I'm not sure.
1. I suppose that 12 doorlock manufacturer can use only functional 
isolation betwean 12V and its metal casing as he can assume (I think) 
that he gets safe voltage.

If I'm wrong with it let me know.
2. Then as doorlock metal casing can be touched by user than 12V have to 
be SELV circuit I think.
3. I'm not sure if the 12V output from this supply is SELV - is it 
enough to test the isolation with 3kV.


In EN 60950-1:2006 5.2.2 I understand that if output is not grounded or 
there is no protective screen than table 5C should be used.

I assume not earthing 12V.
I don't know if there is protective screen inside but as I can imagine 
such supply there have to be feedback and it is probably opto feedback - 
so can there be metal screen betwean LED and opto element and opto will 
work? I'm not sure if I understand well what is screen in accordance 
with 2.6.1 e).
From Annex G I understand that for Overvoltage Category II transient 
voltage (Europe) will be 2k5V and from table 5C I have 5kV test needed. 
So 3kV written in datasheet looks being not enough.


All till now I have written assuming the Overvoltage Category II. But 
reading Annex Z I'm not sure if access control system, as permanently 
installed, is integral building wiring or not. It seems me more like a 
fuse panel then permanently connected electric cooker. If category III 
then I end with 8kV testing - much more than 3kV.


It is TUV approved and under Applications the producer lists Access 
Systems so powering doorlock should be save. If it is true - where is my 
mistake.


Best Regards
Piotr Galka

-

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 <emc-p...@ieee.org>

All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

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.

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:
Scott Douglas <sdoug...@ieee.org>
Mike Cantwell <mcantw...@ieee.org>

For policy questions, send mail to:
Jim Bacher:  <j.bac...@ieee.org>
David Heald: <dhe...@gmail.com>

Re: [PSES] RED DoC and LVD

[Piotr Galka]

Ted,

As I understand RED Guide you can use any appropriate standard (need not 
be harmonized), or its part to show compliance with LVD part of RED. So 
_may_be_ they will never harmonize 60950-1 or 62368-1 with RED.


Piotr

W dniu 2017-08-03 o 23:10, Ted Eckert pisze:


Legal documents are often written using terminology that has very 
specific meanings in the legal profession, and lawyers have a better 
chance of interpreting the regulations and guidance correctly. We run 
into problems when those of us without three years of law school try 
to understand the documents. The problem is further complicated by the 
translation process. Some of us are fortunate enough to work for 
companies where we have a legal staff who can help provide the 
interpretation necessary. Unfortunately for my colleagues working for 
smaller companies or independently, the cost of outside council 
providing support can be significant.


There is a related problem. The documents may not have been written by 
lawyers. Many of the elected officials and staff that write 
regulations are not familiar with the precise legal meaning of words 
and phrases. Regulations, laws and guidance documents may be written 
with good intentions only to have a legal meaning different from what 
was intended.


This isn’t just a problem in the legal profession. We engineers can be 
guilty of the same sin. I may describe a system as having negative 
feedback. We engineers would see that as good, as the system will 
settle down and stabilize. A non-engineer may see the term “negative 
feedback” and think it is bad.


As for the issue at hand, my opinion is that products that fall under 
the RED are declared to RED and not the EMC Directive and/or Low 
Voltage Directive, buy you may still want to list the applicable 
standards. IEC 60950-1 was a harmonized standard under the R 
Directive, and I hope it or IEC 62368-1 will soon be harmonized under 
RED. If so, many may feel more comfortable declaring only to RED. The 
issue I see is that some overzealous market surveillance authority may 
look at a product declared to RED and LVD and decide that the DoC is 
improper because of their reading of the Directives and guidance. It 
may seem like a no-win situation, but that is where we are.


Ted Eckert

Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those 
of my employer, the European Commission, the RED Compliance 
Association, the American Bar Association, or anybody who still 
remains sane after reading through all of the applicable regulations.


*From:*Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org]
*Sent:* Thursday, August 3, 2017 11:26 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] RED DoC and LVD

Piotr,

Isn’t it wonderful when lawyers write documents which technical 
engineers are supposed to use to meet the legal requirements.


Synonyms from my English dictionary for whereas are: while, but , 
where , however & although.   As I remember, I believe that we learned 
in grammar school how to diagram such long, convoluted documents to 
determine which clause modified which other clause (oh so long ago).


**

So, my real, clear interpretation (including all of the discussion up 
till now) is: the TV set (which contains a TV receiver) must meet the 
RED Directive requirements which include applying IEC/EN 60065 to show 
adequate safety protection but don’t claim the LVD in the MDoC (didn’t 
even address whether or not any other EMC requirements apply).


In working on such a project I’ll probably continue to be politically 
incorrect and claim as many Directives as I can find that seem to 
apply on the MDoC (a longer list always looks more impressive to the 
corporate management when they sign it off).


PS:  Oh yes, I believe that our given names come from the same 
root (altho I don’t know Polish).


:>) br,  Pete

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

503/452-1201

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

*From:*Piotr Galka [mailto:piotr.ga...@micromade.pl]
*Sent:* Thursday, August 3, 2017 8:28 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Subject:* Re: [PSES] RED DoC and LVD

I think I don't feel 'Whereas' precisely.
In Polish directives it was replaced with 7 words: "but also hawing in 
attention, what follows:"
I feel it as "we have it in attention, and only that - no more" so I 
called it 'wishful thinking'.


Piotr Gałka
MicroMade Gałka i Drożdż sp.j
Gdańsk
Polska

W dniu 2017-08-03 o 15:35, John Woodgate pisze:

With best wishes DESIGN IT IN! OOO – Own Opinions Only

www.jmwa.demon.co.uk

<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.jmwa.demon.co.uk%2F=04%7C01%7Cted.eckert%40microsoft.com%7Cc64bd8d806634848ebb408d4da9d367e%7C72f988bf86f141af91ab2d7cd

Re: [PSES] RED DoC and LVD

[Piotr Galka]

John,

If I knew that I would start my discussion not from 1.4 and 3.1(a) but 
from (7), 1.4 and 3.1(a) what gives more relations to consider :)


I am reading directives since 2004 when we joined EU. Till now I always 
assumed that everything before Article 1 is not important. Specially I 
remember in WEEE I think (may be in RoHS) that some point before Art 1 
said that it is very important to not load too much small firms which 
was in total opposition with the rest of directive.


For example we had a control and they found a cap with compressed air. 
We use about one per year but since then 4 times a year we have to send 
a report in which from time to time we report 1 such cap. Till now, as I 
know, we don't need to report these four sheets of paper used for it :)
Our products (access control system) are intended to be installed and 
work for years. So after 2006 when we had to count how many kg of our 
products we got back as used-on for many years we had 0kg/year. We had 
to have signed agreement with recycling firm with recycling capabilities 
enough for recycling what we got back. My understanding was that to 
recycle 0 kg I need 0 firms. Now (after control) we know that to recycle 
0kg you need 1 recycling firm :(


Regards
Piotr


W dniu 2017-08-03 o 20:37, John Woodgate pisze:


That’s not quite right. In the same way that English has 3 words for 
everything, it has a minimum of 3 meanings for any word. Some have 
hundreds (‘set’ and ‘bar’).


‘Whereas’ can simply mean ‘but’. However, in Directives, it has a 
legal meaning, which is rather stronger that your translated 
circumlocution. I suppose a short equivalent would be ‘Taking full 
account of these relevant issues, …’. In legal terms, such issues 
could be very significant indeed, such as ‘Whereas such serious crimes 
should be punished by long-term imprisonment,…’


What this means is that a statement in the ‘Whereas’ is a full part of 
the Directive, not a sort of ‘note’.


With best wishes DESIGN IT IN! OOO – Own Opinions Only

www.jmwa.demon.co.uk <http://www.jmwa.demon.co.uk/> J M Woodgate and 
Associates Rayleigh England


Sylvae in aeternum manent.

*From:*Piotr Galka [mailto:piotr.ga...@micromade.pl]
*Sent:* 03 August 2017 16:28
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] RED DoC and LVD

I think I don't feel 'Whereas' precisely.
In Polish directives it was replaced with 7 words: "but also hawing in 
attention, what follows:"
I feel it as "we have it in attention, and only that - no more" so I 
called it 'wishful thinking'.


Piotr Gałka
MicroMade Gałka i Drożdż sp.j
Gdańsk
Polska

W dniu 2017-08-03 o 15:35, John Woodgate pisze:

With best wishes DESIGN IT IN! OOO – Own Opinions Only

www.jmwa.demon.co.uk <http://www.jmwa.demon.co.uk/> J M Woodgate
and Associates Rayleigh England

Sylvae in aeternum manent.

*From:*Piotr Galka [mailto:piotr.ga...@micromade.pl]
*Sent:* 03 August 2017 14:22
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Subject:* Re: [PSES] RED DoC and LVD

John,

The full text you can find in my first mail - still present at the
end:

*/[JMW] Ah, well, I didn’t know to look there./*

1,4.Radio equipment falling within the scope of this Directive
shall not
be subject to Directive 2014/35/EU, except as set out in point (a) of
Article 3(1) of this Directive.

3,1. Radio equipment shall be constructed so as to ensure: (a) the
protection of health and safety of persons and of domestic animals
and
the protection of property, including the objectives with respect to
safety requirements set out in Directive 2014/35/EU, but with no
voltage
limit applying;

(7) seems more clear but As it is before Article 1 I understand it
as a kind of wishful thinking set out before issuing the directive.

*/[JMW] No, the ‘Whereas’ are an important part of the Directive,
attempting to explain how it was built up./*



Now (reading it once more and once more and) I think that
probably "shell be constructed.. with respect to ... requirements
.. in LVD" means "do everything like with LVD but don't name it as
being subject to LVD".
Understanding it that way LVD should not be listed in RED DoC, but
what for is such complex construction used (saying "no but yes").

*/[JMW] That’s right./*

Yes it is something like Gauka or Gawka with 'w' read as in what,
when (if I read it correct - I've never been in any English
speaking country :( ).

I didn’t write ‘Gawka’, because ‘w’ is pronounced in different
ways in different languages.

-

-




-

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 <emc-p...@ieee.org>

All emc-pstc po

Re: [PSES] RED DoC and LVD

[Piotr Galka]

Pete,

If I were lawyer I would call it wonderful, but I am on opposite side :)

Piotr

W dniu 2017-08-03 o 20:26, Pete Perkins pisze:


Piotr,

Isn’t it wonderful when lawyers write documents which technical 
engineers are supposed to use to meet the legal requirements.


Synonyms from my English dictionary for whereas are: while, but , 
where , however & although.   As I remember, I believe that we learned 
in grammar school how to diagram such long, convoluted documents to 
determine which clause modified which other clause (oh so long ago).


**

So, my real, clear interpretation (including all of the discussion up 
till now) is: the TV set (which contains a TV receiver) must meet the 
RED Directive requirements which include applying IEC/EN 60065 to show 
adequate safety protection but don’t claim the LVD in the MDoC (didn’t 
even address whether or not any other EMC requirements apply).


In working on such a project I’ll probably continue to be politically 
incorrect and claim as many Directives as I can find that seem to 
apply on the MDoC (a longer list always looks more impressive to the 
corporate management when they sign it off).


PS:  Oh yes, I believe that our given names come from the same 
root (altho I don’t know Polish).


:>) br,  Pete

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

503/452-1201

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:
http://www.ieee-pses.org/emc-pstc.html

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.

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:
Scott Douglas 
Mike Cantwell 

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

Re: [PSES] RED DoC and LVD

[Piotr Galka]

I think I don't feel 'Whereas' precisely.
In Polish directives it was replaced with 7 words: "but also hawing in 
attention, what follows:"
I feel it as "we have it in attention, and only that - no more" so I 
called it 'wishful thinking'.


Piotr Gałka
MicroMade Gałka i Drożdż sp.j
Gdańsk
Polska

W dniu 2017-08-03 o 15:35, John Woodgate pisze:


With best wishes DESIGN IT IN! OOO – Own Opinions Only

www.jmwa.demon.co.uk <http://www.jmwa.demon.co.uk/> J M Woodgate and 
Associates Rayleigh England


Sylvae in aeternum manent.

*From:*Piotr Galka [mailto:piotr.ga...@micromade.pl]
*Sent:* 03 August 2017 14:22
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] RED DoC and LVD

John,

The full text you can find in my first mail - still present at the end:

*/[JMW] Ah, well, I didn’t know to look there./*

1,4.Radio equipment falling within the scope of this Directive shall not
be subject to Directive 2014/35/EU, except as set out in point (a) of
Article 3(1) of this Directive.

3,1. Radio equipment shall be constructed so as to ensure: (a) the
protection of health and safety of persons and of domestic animals and
the protection of property, including the objectives with respect to
safety requirements set out in Directive 2014/35/EU, but with no voltage
limit applying;

(7) seems more clear but As it is before Article 1 I understand it as 
a kind of wishful thinking set out before issuing the directive.


*/[JMW] No, the ‘Whereas’ are an important part of the Directive, 
attempting to explain how it was built up./*




Now (reading it once more and once more and) I think that probably 
"shell be constructed.. with respect to ... requirements .. in LVD" 
means "do everything like with LVD but don't name it as being subject 
to LVD".
Understanding it that way LVD should not be listed in RED DoC, but 
what for is such complex construction used (saying "no but yes").


*/[JMW] That’s right./*

Yes it is something like Gauka or Gawka with 'w' read as in what, when 
(if I read it correct - I've never been in any English speaking 
country :( ).


I didn’t write ‘Gawka’, because ‘w’ is pronounced in different ways in 
different languages.


-



-

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Re: [PSES] RED DoC and LVD

[Piotr Galka]

John,

The full text you can find in my first mail - still present at the end:

1,4.Radio equipment falling within the scope of this Directive shall not
be subject to Directive 2014/35/EU, except as set out in point (a) of
Article 3(1) of this Directive.

3,1. Radio equipment shall be constructed so as to ensure: (a) the
protection of health and safety of persons and of domestic animals and
the protection of property, including the objectives with respect to
safety requirements set out in Directive 2014/35/EU, but with no voltage
limit applying;

(7) seems more clear but As it is before Article 1 I understand it as a 
kind of wishful thinking set out before issuing the directive.


Now (reading it once more and once more and) I think that probably 
"shell be constructed.. with respect to ... requirements .. in LVD" 
means "do everything like with LVD but don't name it as being subject to 
LVD".
Understanding it that way LVD should not be listed in RED DoC, but what 
for is such complex construction used (saying "no but yes").


Yes it is something like Gauka or Gawka with 'w' read as in what, when 
(if I read it correct - I've never been in any English speaking country 
:( ).


Piotr

W dniu 2017-08-03 o 14:45, John Woodgate pisze:


RE: Do really for native English speakers it is clear that "devices 
shall not be subject to LVD, except as..." doesn't mean "except 
as. when yes"?


Well, we would say: "devices shall not be subject to LVD, except 
as..." does mean "except as. when they are"?


But your sentence has words left out, and I can’t trace the original 
full text. I think the clearest relevant statement is ‘Whereas 7’ of 
the RED:


(7)The objectives with respect to safety requirements laid down in 
Directive 2014/35/EU are sufficient to cover


radio equipment, and should therefore be the reference and made 
applicable by virtue of this Directive. In order


to avoid unnecessary duplications of provisions other than those 
concerning such requirements, Directive


2014/35/EU should not apply to radio equipment.

This means that the RED applies the safety provisions of the LVD, 
without the administrative texts that are not about safety, since if 
they were included they would partly duplicate (even maybe contradict) 
the corresponding provisions in the RED.




Regards
Piotr Galka
P.S.
If I write ma name with Polish letter (Piotr Gałka) do you see it 
correctly?


JMW: I can see the special character, but I can’t necessarily 
pronounce your name. Is it something like ‘Gauka’?


With best wishes DESIGN IT IN! OOO – Own Opinions Only

www.jmwa.demon.co.uk <http://www.jmwa.demon.co.uk/> J M Woodgate and 
Associates Rayleigh England


Sylvae in aeternum manent.

*From:*Piotr Galka [mailto:piotr.ga...@micromade.pl]
*Sent:* 03 August 2017 12:57
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] RED DoC and LVD

My doubt comes not from less/more specific directive.
I don't consider LVD just from its scope.
But reading RED (devices shall not be subject to LVD, except as...) I 
understand that LVD not except some situations when yes.

And these 'some situations' looks as wider scope than LVD.

I know there is common understanding that if RED then no LVD but I 
don't like to relay on such sources if I can't understand why it is so.


Do really for native English speakers it is clear that "devices shall 
not be subject to LVD, except as..." doesn't mean "except as. when 
yes"?


Regards
Piotr Galka
P.S.
If I write ma name with Polish letter (Piotr Gałka) do you see it 
correctly?



W dniu 2017-08-03 o 04:49, Nyffenegger, Dave pisze:

Similar situation exists with the Machinery Directive.  The MD
guideline says not to declare the LVD on the DoC but the directive
requires meeting LVD technical requirements. There is no exclusion
in the  LVD for machinery either. I don’t think anyone argues that
    the directive that is more specific to the product prevails.

-Dave

*From:*Piotr Galka [mailto:piotr.ga...@micromade.pl]
*Sent:* Wednesday, August 02, 2017 2:39 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Subject:* Re: [PSES] RED DoC and LVD

Hi Mike,

Thanks for short and long answer :)

Reading RED Guide I understand: If RED than no EMCD and no LVD but
it is _only_ guide.
With EMCD everything is clear - in EMCD RED (R) devices are
clearly excluded from EMCD scope.

There is no such exclusion in LVD.
Reading RED I'm not sure how to read it to understand it (about
LVD) the same way as the RED Guide.
I really understand 1,4 and 3,1 (a) as RED devices are covered by
LVD (in some aspects but it looks for me as all aspects).

Regards
Piotr


W dniu 2017-08-02 o 16:19, Mike Sherman pisze:

Short answer: no.

Long answer: look at sections 9.5 and 11 of th

Re: [PSES] RED DoC and LVD

[Piotr Galka]

Hi John,

Thanks, I've got it.

Regards
Piotr

W dniu 2017-08-02 o 21:00, John Woodgate pisze:


There is a specific EC document on this subject. Unfortunately, as 
often happens, the document has been moved. So the link in the Google 
search returns 404 – Not found. However if you just search for:


Application of Directives 2014/53/EU, 2014/35/EU and 2014/30/EU

and click on the ‘hit’ heading, the PDF will download.

With best wishes DESIGN IT IN! OOO – Own Opinions Only

www.jmwa.demon.co.uk <http://www.jmwa.demon.co.uk/> J M Woodgate and 
Associates Rayleigh England


Sylvae in aeternum manent.

*From:*Piotr Galka [mailto:piotr.ga...@micromade.pl]
*Sent:* 02 August 2017 19:39
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] RED DoC and LVD

Hi Mike,

Thanks for short and long answer :)

Reading RED Guide I understand: If RED than no EMCD and no LVD but it 
is _only_ guide.
With EMCD everything is clear - in EMCD RED (R) devices are 
clearly excluded from EMCD scope.


There is no such exclusion in LVD.
Reading RED I'm not sure how to read it to understand it (about LVD) 
the same way as the RED Guide.
I really understand 1,4 and 3,1 (a) as RED devices are covered by LVD 
(in some aspects but it looks for me as all aspects).


Regards
Piotr

W dniu 2017-08-02 o 16:19, Mike Sherman pisze:

Short answer: no.

Long answer: look at sections 9.5 and 11 of the "RED Guide," the
Guide to the Radio Equipment Directive 2014/53/EU dated 19 May 2017.

Mike Sherman

Graco Inc.

----

    *From: *"Piotr Galka" <piotr.ga...@micromade.pl>
<mailto:piotr.ga...@micromade.pl>
*To: *"EMC-PSTC" <EMC-PSTC@LISTSERV.IEEE.ORG>
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Sent: *Wednesday, August 2, 2017 8:58:54 AM
*Subject: *[PSES] RED DoC and LVD

Dear list members,

I'd like to know if the RED DoC should list LVD or not.

RED says:
1,4.Radio equipment falling within the scope of this Directive
shall not
be subject to Directive 2014/35/EU, except as set out in point (a) of
Article 3(1) of this Directive.
3,1. Radio equipment shall be constructed so as to ensure: (a) the
protection of health and safety of persons and of domestic animals
and
the protection of property, including the objectives with respect to
safety requirements set out in Directive 2014/35/EU, but with no
voltage
limit applying;
Annex V (DoC) 5: relevant Union harmonisation legislation: -RED, -
Other
Union harmonisation legislation where applicable.

I really can't say that being/not being subject to LVD is clear
for me here!

My understanding:
3,1(a) - protection of persons, animals and property covers really
the
whole LVD requirements (extending its range on low voltage devices).
1,4 - Radio equipment is not subject to LVD but in aspects from
3,1(a)
it is subject to LVD.
So, as 3,1(a) covers the whole LVD requirements the RED device is
subject to LVD so LVD is applicable and should be listed in RED
equipment DoC.

May be my understanding stand up from that then till now, I have been
reading the RED in Polish version. I have opened English version for
first time when I come to copy citations from RED to this post.
Translating Polish to English it would be something like that:
1.4 Radio devices ... are not subject to LVD, except cases defined in
3,1(a).

The essence of my question is:
Do the 'except' in 1.4 should be understand that what is after
'except':
- describes aspects of LVD in which the RED devices are subject to
LVD,
- describes requirements from LVD to be applied to RED devices
without
understanding that they are subject to LVD.

Or may be my mistake is that I don't see what parts of LVD are not
covered by 3,1(a).
This leads to reading LVD Annex I and selecting points which
should be
not applied to RED devices as being not covered by 3,1(a) (can be the
next question if here the decision would be to go that way).
If I can be sure that at least one of points from LVD Annex I is not
covered by 3,1(a) than I can understand that RED devices are not
subject
to LVD and only some points from LVD Annex I should be applied as
requirements of applying RED and not requirements of applying LVD.

    I hope you help in my doubts.

Best Regards
Piotr Galka
MicroMade
Poland

-

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 <emc-p...@ieee.org> <mailto:emc-p...@ieee.org>

All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Re: [PSES] RED DoC and LVD

[Piotr Galka]

My doubt comes not from less/more specific directive.
I don't consider LVD just from its scope.
But reading RED (devices shall not be subject to LVD, except as...) I 
understand that LVD not except some situations when yes.

And these 'some situations' looks as wider scope than LVD.

I know there is common understanding that if RED then no LVD but I don't 
like to relay on such sources if I can't understand why it is so.


Do really for native English speakers it is clear that "devices shall 
not be subject to LVD, except as..." doesn't mean "except as. when yes"?


Regards
Piotr Galka
P.S.
If I write ma name with Polish letter (Piotr Gałka) do you see it correctly?



W dniu 2017-08-03 o 04:49, Nyffenegger, Dave pisze:


Similar situation exists with the Machinery Directive.  The MD 
guideline says not to declare the LVD on the DoC but the directive 
requires meeting LVD technical requirements. There is no exclusion in 
the  LVD for machinery either.  I don’t think anyone argues that the 
directive that is more specific to the product prevails.


-Dave

*From:*Piotr Galka [mailto:piotr.ga...@micromade.pl]
*Sent:* Wednesday, August 02, 2017 2:39 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] RED DoC and LVD

Hi Mike,

Thanks for short and long answer :)

Reading RED Guide I understand: If RED than no EMCD and no LVD but it 
is _only_ guide.
With EMCD everything is clear - in EMCD RED (R) devices are 
clearly excluded from EMCD scope.


There is no such exclusion in LVD.
Reading RED I'm not sure how to read it to understand it (about LVD) 
the same way as the RED Guide.
I really understand 1,4 and 3,1 (a) as RED devices are covered by LVD 
(in some aspects but it looks for me as all aspects).


Regards
Piotr

W dniu 2017-08-02 o 16:19, Mike Sherman pisze:

Short answer: no.

Long answer: look at sections 9.5 and 11 of the "RED Guide," the
Guide to the Radio Equipment Directive 2014/53/EU dated 19 May 2017.

Mike Sherman

Graco Inc.

----

*From: *"Piotr Galka" <piotr.ga...@micromade.pl>
<mailto:piotr.ga...@micromade.pl>
*To: *"EMC-PSTC" <EMC-PSTC@LISTSERV.IEEE.ORG>
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Sent: *Wednesday, August 2, 2017 8:58:54 AM
*Subject: *[PSES] RED DoC and LVD

Dear list members,

I'd like to know if the RED DoC should list LVD or not.

RED says:
1,4.Radio equipment falling within the scope of this Directive
shall not
be subject to Directive 2014/35/EU, except as set out in point (a) of
Article 3(1) of this Directive.
3,1. Radio equipment shall be constructed so as to ensure: (a) the
protection of health and safety of persons and of domestic animals
and
the protection of property, including the objectives with respect to
safety requirements set out in Directive 2014/35/EU, but with no
voltage
limit applying;
Annex V (DoC) 5: relevant Union harmonisation legislation: -RED, -
Other
Union harmonisation legislation where applicable.

I really can't say that being/not being subject to LVD is clear
for me here!

My understanding:
3,1(a) - protection of persons, animals and property covers really
the
whole LVD requirements (extending its range on low voltage devices).
1,4 - Radio equipment is not subject to LVD but in aspects from
3,1(a)
it is subject to LVD.
So, as 3,1(a) covers the whole LVD requirements the RED device is
subject to LVD so LVD is applicable and should be listed in RED
equipment DoC.

May be my understanding stand up from that then till now, I have been
reading the RED in Polish version. I have opened English version for
first time when I come to copy citations from RED to this post.
Translating Polish to English it would be something like that:
1.4 Radio devices ... are not subject to LVD, except cases defined in
3,1(a).

The essence of my question is:
Do the 'except' in 1.4 should be understand that what is after
'except':
- describes aspects of LVD in which the RED devices are subject to
LVD,
- describes requirements from LVD to be applied to RED devices
without
understanding that they are subject to LVD.

Or may be my mistake is that I don't see what parts of LVD are not
covered by 3,1(a).
This leads to reading LVD Annex I and selecting points which
should be
not applied to RED devices as being not covered by 3,1(a) (can be the
next question if here the decision would be to go that way).
If I can be sure that at least one of points from LVD Annex I is not
covered by 3,1(a) than I can understand that RED devices are not
subject
to LVD and only some points from LVD Annex I should be applied as
requirements of applying RED and not requirements of applying

Re: [PSES] RED DoC and LVD

[Piotr Galka]

Hi Mike,

Thanks for short and long answer :)

Reading RED Guide I understand: If RED than no EMCD and no LVD but it is 
_only_ guide.
With EMCD everything is clear - in EMCD RED (R) devices are clearly 
excluded from EMCD scope.


There is no such exclusion in LVD.
Reading RED I'm not sure how to read it to understand it (about LVD) the 
same way as the RED Guide.
I really understand 1,4 and 3,1 (a) as RED devices are covered by LVD 
(in some aspects but it looks for me as all aspects).


Regards
Piotr


W dniu 2017-08-02 o 16:19, Mike Sherman pisze:

Short answer: no.

Long answer: look at sections 9.5 and 11 of the "RED Guide," the Guide 
to the Radio Equipment Directive 2014/53/EU dated 19 May 2017.


Mike Sherman
Graco Inc.


*From: *"Piotr Galka" <piotr.ga...@micromade.pl>
*To: *"EMC-PSTC" <EMC-PSTC@LISTSERV.IEEE.ORG>
*Sent: *Wednesday, August 2, 2017 8:58:54 AM
*Subject: *[PSES] RED DoC and LVD

Dear list members,

I'd like to know if the RED DoC should list LVD or not.

RED says:
1,4.Radio equipment falling within the scope of this Directive shall not
be subject to Directive 2014/35/EU, except as set out in point (a) of
Article 3(1) of this Directive.
3,1. Radio equipment shall be constructed so as to ensure: (a) the
protection of health and safety of persons and of domestic animals and
the protection of property, including the objectives with respect to
safety requirements set out in Directive 2014/35/EU, but with no voltage
limit applying;
Annex V (DoC) 5: relevant Union harmonisation legislation: -RED, - Other
Union harmonisation legislation where applicable.

I really can't say that being/not being subject to LVD is clear for me 
here!


My understanding:
3,1(a) - protection of persons, animals and property covers really the
whole LVD requirements (extending its range on low voltage devices).
1,4 - Radio equipment is not subject to LVD but in aspects from 3,1(a)
it is subject to LVD.
So, as 3,1(a) covers the whole LVD requirements the RED device is
subject to LVD so LVD is applicable and should be listed in RED
equipment DoC.

May be my understanding stand up from that then till now, I have been
reading the RED in Polish version. I have opened English version for
first time when I come to copy citations from RED to this post.
Translating Polish to English it would be something like that:
1.4 Radio devices ... are not subject to LVD, except cases defined in
3,1(a).

The essence of my question is:
Do the 'except' in 1.4 should be understand that what is after 'except':
- describes aspects of LVD in which the RED devices are subject to LVD,
- describes requirements from LVD to be applied to RED devices without
understanding that they are subject to LVD.

Or may be my mistake is that I don't see what parts of LVD are not
covered by 3,1(a).
This leads to reading LVD Annex I and selecting points which should be
not applied to RED devices as being not covered by 3,1(a) (can be the
next question if here the decision would be to go that way).
If I can be sure that at least one of points from LVD Annex I is not
covered by 3,1(a) than I can understand that RED devices are not subject
to LVD and only some points from LVD Annex I should be applied as
requirements of applying RED and not requirements of applying LVD.

I hope you help in my doubts.

Best Regards
Piotr Galka
MicroMade
Poland

-

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e-mail to <emc-p...@ieee.org>


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities 
site at http://product-compliance.oc.ieee.org/ can be used for 
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Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to 
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List rules: http://www.ieee-pses.org/listrules.html

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-


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 <emc-p...@ieee.org <mailto:emc-p...@ieee.org>>


All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html


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.


Website: http:

Re: [PSES] RED DoC and LVD

[Piotr Galka]

Hi Michael,

Thanks, but that means my understanding was not correct :(

Regards,

Piotr


W dniu 2017-08-02 o 16:10, Michael Derby pisze:

Hi Piotr,

You would not have a situation where the RED and the LVD both apply to a 
product.

Product safety for radio devices (transmitter, receiver, transceiver) is covered by 
Article 3.1a of the RED.   So, you assess safety "in a similar way as the LVD", 
but you do not actually apply the LV Directive.

So, no, you should not list the LVD on your RED DoC.

Therefore, your understanding in your mail is correct.


Thanks,

Michael.



-Original Message-----
From: Piotr Galka [mailto:piotr.ga...@micromade.pl]
Sent: 02 August 2017 14:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RED DoC and LVD

Dear list members,

I'd like to know if the RED DoC should list LVD or not.

RED says:
1,4.Radio equipment falling within the scope of this Directive shall not be 
subject to Directive 2014/35/EU, except as set out in point (a) of Article 3(1) 
of this Directive.
3,1. Radio equipment shall be constructed so as to ensure: (a) the protection 
of health and safety of persons and of domestic animals and the protection of 
property, including the objectives with respect to safety requirements set out 
in Directive 2014/35/EU, but with no voltage limit applying; Annex V (DoC) 5: 
relevant Union harmonisation legislation: -RED, - Other Union harmonisation 
legislation where applicable.

I really can't say that being/not being subject to LVD is clear for me here!

My understanding:
3,1(a) - protection of persons, animals and property covers really the whole 
LVD requirements (extending its range on low voltage devices).
1,4 - Radio equipment is not subject to LVD but in aspects from 3,1(a) it is 
subject to LVD.
So, as 3,1(a) covers the whole LVD requirements the RED device is subject to 
LVD so LVD is applicable and should be listed in RED equipment DoC.

May be my understanding stand up from that then till now, I have been reading 
the RED in Polish version. I have opened English version for first time when I 
come to copy citations from RED to this post.
Translating Polish to English it would be something like that:
1.4 Radio devices ... are not subject to LVD, except cases defined in 3,1(a).

The essence of my question is:
Do the 'except' in 1.4 should be understand that what is after 'except':
- describes aspects of LVD in which the RED devices are subject to LVD,
- describes requirements from LVD to be applied to RED devices without 
understanding that they are subject to LVD.

Or may be my mistake is that I don't see what parts of LVD are not covered by 
3,1(a).
This leads to reading LVD Annex I and selecting points which should be not 
applied to RED devices as being not covered by 3,1(a) (can be the next question 
if here the decision would be to go that way).
If I can be sure that at least one of points from LVD Annex I is not covered by 
3,1(a) than I can understand that RED devices are not subject to LVD and only 
some points from LVD Annex I should be applied as requirements of applying RED 
and not requirements of applying LVD.

I hope you help in my doubts.

Best Regards
Piotr Galka
MicroMade
Poland

-

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 <emc-p...@ieee.org>

All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

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.

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:
Scott Douglas <sdoug...@ieee.org>
Mike Cantwell <mcantw...@ieee.org>

For policy questions, send mail to:
Jim Bacher:  <j.bac...@ieee.org>
David Heald: <dhe...@gmail.com>

-

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 <emc-p...@ieee.org>

All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

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.

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:
Scott Douglas <sdoug...@ieee.org>
Mike Cantwell <mcantw...@ieee.org>

For policy quest

[PSES] RED DoC and LVD

[Piotr Galka]

Dear list members,

I'd like to know if the RED DoC should list LVD or not.

RED says:
1,4.Radio equipment falling within the scope of this Directive shall not 
be subject to Directive 2014/35/EU, except as set out in point (a) of 
Article 3(1) of this Directive.
3,1. Radio equipment shall be constructed so as to ensure: (a) the 
protection of health and safety of persons and of domestic animals and 
the protection of property, including the objectives with respect to 
safety requirements set out in Directive 2014/35/EU, but with no voltage 
limit applying;
Annex V (DoC) 5: relevant Union harmonisation legislation: -RED, - Other 
Union harmonisation legislation where applicable.


I really can't say that being/not being subject to LVD is clear for me here!

My understanding:
3,1(a) - protection of persons, animals and property covers really the 
whole LVD requirements (extending its range on low voltage devices).
1,4 - Radio equipment is not subject to LVD but in aspects from 3,1(a) 
it is subject to LVD.
So, as 3,1(a) covers the whole LVD requirements the RED device is 
subject to LVD so LVD is applicable and should be listed in RED 
equipment DoC.


May be my understanding stand up from that then till now, I have been 
reading the RED in Polish version. I have opened English version for 
first time when I come to copy citations from RED to this post.

Translating Polish to English it would be something like that:
1.4 Radio devices ... are not subject to LVD, except cases defined in 
3,1(a).


The essence of my question is:
Do the 'except' in 1.4 should be understand that what is after 'except':
- describes aspects of LVD in which the RED devices are subject to LVD,
- describes requirements from LVD to be applied to RED devices without 
understanding that they are subject to LVD.


Or may be my mistake is that I don't see what parts of LVD are not 
covered by 3,1(a).
This leads to reading LVD Annex I and selecting points which should be 
not applied to RED devices as being not covered by 3,1(a) (can be the 
next question if here the decision would be to go that way).
If I can be sure that at least one of points from LVD Annex I is not 
covered by 3,1(a) than I can understand that RED devices are not subject 
to LVD and only some points from LVD Annex I should be applied as 
requirements of applying RED and not requirements of applying LVD.


I hope you help in my doubts.

Best Regards
Piotr Galka
MicroMade
Poland

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Re: [PSES] RED Harmonised Standards

[Piotr Galka]

29.06 I have send the following post but in response I'v got:

You have  been automatically removed  from the EMC-PSTC list as a result
of repeated delivery error reports from your mail system.

and I don't know if my post were send to you.
Now I hope it should work.

  my post send 29.06, sorry if you see it second time 

Reading RED Guide:
=
Hence, for the essential requirements set out in Article 3.1.a and 3.1.b 
of the RED, the
possibility to demonstrate conformity with these essential requirements 
by means
other than using the harmonised standards is not linked to the use of a 
notified body,
because the manufacturer has always the discretion to use Modula A 
(Annex II of the

RED) which does not involve a notified body.
=
I understood HS for 3.1.a and 3.1.b need not to be published as 
manufacturer need not to use HS (he can use not harminised standards) to 
use Modula A.

But reading RED I'm not sure if I see the same.

Regards
Piotr Galka




W dniu 2017-06-28 o 17:43, Scott Xe pisze:


In addition to 3.1b EMC requirements, 3.1a health & safety 
requirements are also none of HS.  It looks they deliberately arrange 
it.  Is there any particular reason behind the scene?


Regards,

Scott

*From: *"Paasche, Dieter" <dieter.paas...@christiedigital.com>
*Reply-To: *"Paasche, Dieter" <dieter.paas...@christiedigital.com>
*Date: *Wednesday, 28 June 2017 at 11:21 PM
*To: *<EMC-PSTC@LISTSERV.IEEE.ORG>
*Subject: *Re: [PSES] RED Harmonised Standards

Interesting. One additional question is I don’t see any of the 301 489 
series. Is this going to be published in the RED harmonized standards 
list, as it is strictly speaking and EMC requirement, or is this part 
of the article 3.1 b requirement:”an adequate level of electromagnetic 
compatibility as set out in Directive 2014/30/EU.?”


The EMC directive only lists 301 489-1 and 301 489-34.

Sincerely,

Dieter Paasche

Senior Product Developer, Electrical

CHRISTIE

809 Wellington Street North

Kitchener, ON N2G 4Y7

Phone: 519-744-8005 ext.7211

www.christiedigital.com <http://www.christiedigital.com/>

This e-mail message (including attachments, if any) is confidential.  
Any unauthorized use, distribution or disclosure is prohibited.  If 
you have received this e-mail message in error, please notify the 
sender by reply e-mail or telephone and delete it and any attachments 
from your computer system and records.


*From:*Douglas Nix [mailto:d...@mac.com]
*Sent:* Tuesday, June 27, 2017 2:27 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] RED Harmonised Standards

Colleagues,

I just heard about a new Communication and list of Harmonised 
Standards under the RED:


http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2017.180.01.0005.01.ENG=OJ:C:2017:180:TOC

--

Doug Nix

d...@mac.com <mailto:d...@mac.com>

-


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Re: [PSES] RED Harmonised Standards

[Piotr Galka]

Reading RED Guide:
=
Hence, for the essential requirements set out in Article 3.1.a and 3.1.b 
of the RED, the
possibility to demonstrate conformity with these essential requirements 
by means
other than using the harmonised standards is not linked to the use of a 
notified body,
because the manufacturer has always the discretion to use Modula A 
(Annex II of the

RED) which does not involve a notified body.
=
I understood HS for 3.1.a and 3.1.b need not to be published as 
manufacturer need not to use HS (he can use not harminised standards) to 
use Modula A.

But reading RED I'm not sure if I see the same.

Regards
Piotr Galka


W dniu 2017-06-28 o 17:43, Scott Xe pisze:


In addition to 3.1b EMC requirements, 3.1a health & safety 
requirements are also none of HS.  It looks they deliberately arrange 
it.  Is there any particular reason behind the scene?


Regards,

Scott

*From: *"Paasche, Dieter" <dieter.paas...@christiedigital.com>
*Reply-To: *"Paasche, Dieter" <dieter.paas...@christiedigital.com>
*Date: *Wednesday, 28 June 2017 at 11:21 PM
*To: *<EMC-PSTC@LISTSERV.IEEE.ORG>
*Subject: *Re: [PSES] RED Harmonised Standards

Interesting. One additional question is I don’t see any of the 301 489 
series. Is this going to be published in the RED harmonized standards 
list, as it is strictly speaking and EMC requirement, or is this part 
of the article 3.1 b requirement:”an adequate level of electromagnetic 
compatibility as set out in Directive 2014/30/EU.?”


The EMC directive only lists 301 489-1 and 301 489-34.

Sincerely,

Dieter Paasche

Senior Product Developer, Electrical

CHRISTIE

809 Wellington Street North

Kitchener, ON N2G 4Y7

Phone: 519-744-8005 ext.7211

www.christiedigital.com <http://www.christiedigital.com/>

This e-mail message (including attachments, if any) is confidential.  
Any unauthorized use, distribution or disclosure is prohibited.  If 
you have received this e-mail message in error, please notify the 
sender by reply e-mail or telephone and delete it and any attachments 
from your computer system and records.


*From:*Douglas Nix [mailto:d...@mac.com]
*Sent:* Tuesday, June 27, 2017 2:27 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] RED Harmonised Standards

Colleagues,

I just heard about a new Communication and list of Harmonised 
Standards under the RED:


http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2017.180.01.0005.01.ENG=OJ:C:2017:180:TOC

--

Doug Nix

d...@mac.com <mailto:d...@mac.com>

-


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e-m

Re: [PSES] How to find harmonised standard list?

[Piotr Galka]

Thanks,

I must be blind.
In my search I was there for a while, but when I saw 2004/108/EC I 
thought I found not current but historical information... and got back 
to looking for the way from directive page.


Regards
Piotr Galka
P.S.
This is third time I'm trying to answer.
This time I deleted the ec.europa page view you put in your post because 
I think it is the reason I got two times:


Your posting to the EMC-PSTC list has been rejected because it contains an
attachment of type 'IMAGE/PNG'. The EMC-PSTC list has been configured to 
reject

such attachments.
==
How do you do that, then you can put an image in the post?


W dniu 2017-06-12 o 13:31, Charlie Blackham pisze:


Try 
http://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/ 



Click onElectromagnetic compatibility (EMC)

Scroll down a bit

Regards

Charlie

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web: www.sulisconsultants.com

Registered in England and Wales, number 05466247

-Original Message-
From: Piotr Galka [mailto:piotr.ga...@micromade.pl]
Sent: 12 June 2017 12:16
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] How to find harmonised standard list?

Hi All,

For example for 2014/30/EU whatever I write in search box I always and 
with:


http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1497265372270=CELEX:32014L0030

From 2014/30/EU directive page there should be one small step to 
harmonised standards list but I can't find it.


Please let me know, what I am missing?

Regards

Piotr Galka

-



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[PSES] How to find harmonised standard list?

[Piotr Galka]

Hi All,

For example for 2014/30/EU whatever I write in search box I always and with:
http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1497265372270=CELEX:32014L0030

From 2014/30/EU directive page there should be one small step to 
harmonised standards list but I can't find it.


Please let me know, what I am missing?

Regards
Piotr Galka

-

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Re: [PSES] EN 300 330-1 H-field limit for 13.56MHz RFID

[Piotr Galka]

Andy,

=
- Original Message - 
From: White, Andy an...@qti.qualcomm.com


See comments in the brackets in the mail below

[From the standardThe equipment under test shall be switched on with 
normal modulation. The characteristics of the modulation shall be stated in 
the test report. The measuring receiver shall be tuned over the frequency 
range 9 kHz to 30 MHz, except for the frequency band within the spectrum 
mask (see clause 7.1.1.3) where the transmitter is intended to operate.


The transmitter fundamental must meet the profile in the standard i.e. 
outside 14.46MHz it is -16dBuA/m.

For transmitter harmonics the limit used from 10Mhz to 30Mhz is -3.5dBuA/m.]
=

And it is what I don't understand.

1. What is frequency band within the spectrum mask ?
For me frequency band is 13.56 +- 7kHz (and it is within the spectrum mask).

2. I understand this spectrum mask (Figure 1 in EN 302 291-1) as not for 
fundamental but for modulation products.
If the fundamental would be 14.47MHz than according to ERC 70-03 it is not 
in f or f1 band (13.553-13.567) so that standard don't apply.


So I understand that outside 14.46MHz modulation products must be 
below -16dBuA/m and spurious must be below -3.5dBuA/m. It looks that I have 
to analyse at each f if the emission is because of modulation or spurious. 
Do I really have to do it ?


To do that I should have a possibility to have transmitter on without 
modulation. RFID reader switches the carrier and asks if any transponder is 
in field so it modulates the carrier. If not it switches the carrier off, if 
yes the carrier exists a little longer to read the whole transponder answer. 
The tests in my opinion should be possible with device working as it is 
intended to do.


Piotr Galka

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Re: [PSES] EN 300 330-1 H-field limit for 13.56MHz RFID

[Piotr Galka]

Larry,

The problem I am asking is in EN 302 291-1 the same. Table 4 - Outside 
12,66M-14,46M = -16dBuA/m at 10m, table 6 - 10MHz-30MHz = -3.5dBuA/m at 10m.
I'd be happy if you can say something about it.


I have considered EN 302 291-1/-2 also but:

1. I'm not sure if you are right.
EN 300 330-1 addresses RFID in its several places (for example higher H-field 
of carrier suggests that this standard considers powering the tag).
EN 302 291-1 says it is for Data Communication - for me it means NFC = yes, 
RFID = not sure/rather not. RFID is not only data communication, it is powering 
one side by the other side and data communication = I'm not sure if RFID is in 
EN 302 291-1 scope.
When you do search for RFID you will find it 16 times in EN 300 330-1 and 
only 1 time in EN 302 291-1 (Annex C (informative) - bibliography).

2. As I understand EN 302 291-1 I have to have antenna 50 ohm output 
(switchable (internal/50 ohm) or second sample with 50 ohm) and it would be not 
so simple for me to prepare it. IC has symmetrical output. At one leg we have 
L, C to GND, C, C to GND, antenna. In theory the antenna circuit is seen as 
having only real part of impedance at IC pins, but it is before LC (called EMC 
filter). I am not sure of R at any other point in that circuit, and making 50 
ohm output before EMC filter has no sense in my opinion.

3. As I understand EN 300 330-1 I can do with Test fixture instead of 50 ohm 
output and I see no problem with it.

Because of 1, 2 and 3 I have selected EN 300 330-1/-2.

Piotr


  - Original Message - 
  From: Larry Stillings 
  To: 'Piotr Galka' ; EMC-PSTC@LISTSERV.IEEE.ORG 
  Sent: Saturday, December 28, 2013 4:36 PM
  Subject: RE: [PSES] EN 300 330-1 H-field limit for 13.56MHz RFID


  Piotr,

  Have you also looked at EN 302 291-1 / -2 for the type of product you 
describe in the header of your email? 

  That would be the product specific standard for 13.56 MHz RFID, vs using the 
generic standard EN 300 330-1 / - 2.

  Larry



--
  From: Piotr Galka [mailto:piotr.ga...@micromade.pl] 
  Sent: Saturday, December 28, 2013 9:53 AM
  To: EMC-PSTC@LISTSERV.IEEE.ORG
  Subject: [PSES] EN 300 330-1 H-field limit for 13.56MHz RFID


  All,

  From G.2 transmitter radiated spectrum shall be in most range (9kHz-30MHz) at 
-16 dBuA/m.
  From 7.5.3 Transmitter spurious domain emission (when operating) can be 
higher (-3.5dBuA/m in 10-30MHz range).

  What is the difference between transmitter radiated spectrum and transmitter 
spurious domain emission ?

  When I switch off transmitter to switch off transmitter radiated spectrum 
than I also don't have transmitter spurious emission (when operating).

  So when transmitter is operating what limit should I use:
  in range 14.01MHz - 14.46 MHz : -10dBuA/m or -3.5dBuA/m
  in range 14.46MHz - 30MHz : -16dBuA/m or -3.5dBuA/m

  Best Regards
  Piotr Galka
  -
  

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[PSES] EN 300 330-1 H-field limit for 13.56MHz RFID

[Piotr Galka]

All,

From G.2 transmitter radiated spectrum shall be in most range (9kHz-30MHz) at 
-16 dBuA/m.
From 7.5.3 Transmitter spurious domain emission (when operating) can be higher 
(-3.5dBuA/m in 10-30MHz range).

What is the difference between transmitter radiated spectrum and transmitter 
spurious domain emission ?

When I switch off transmitter to switch off transmitter radiated spectrum than 
I also don't have transmitter spurious emission (when operating).

So when transmitter is operating what limit should I use:
in range 14.01MHz - 14.46 MHz : -10dBuA/m or -3.5dBuA/m
in range 14.46MHz - 30MHz : -16dBuA/m or -3.5dBuA/m

Best Regards
Piotr Galka

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Re: [PSES] EN 50581 part/range of parts

[Piotr Galka]

Lauren,

After a week of trying to find how the need for unique identification of EEE 
should be in practice realised I have completely new idea.

Annex VI of ROHS2 looks like a recipe what point after point should be in DoC.
Why identification of device is mentioned two times - in 1. and 4. ?
Putting the device number at position 1. seems for me being the evident 
nonsense, having in mind how the typical DoC looks like (We declare... that 
device...).

You mentioned three sides battling how to understand point 1.
I'd like to be recognised as first being in fourth side.
The fourth side: We (I hope I will not be alone) think point 1 is an error - it 
should call for No... (unique identification of document):

If we assume this - everything becomes clear and logically coherent.
For me it is as logic as 2+2=4.

ROHS2 is based on Decision 768/2008/EC. So I looked there with hope to find the 
correct source version of DoC contents list.
Unfortunately there is 1. ... unique identification of the product, and 4. 
 (identification of product).
I can't find any reason for identifying product two times in one document.
So I think Decision is the source of this error in RoHS.
Some bank papers are called products :), may be someone working before in bank 
was editing the Decision ?
May be it is possible to find same paper written before without this error.
I will not try to do it. I am not good in looking for EU papers. About three 
weeks ago I asked the helpdesk to show me how from main new-eu-law page to go 
to the all directives list page (if I have to find all directives covering my 
product the only way is to start from the list of all). I hope they are still 
looking for that way to let me know :).

It seems for me impossible that since 2008 no one has noticed this error. So 
many translators working on Decision, people working on ROHS2, translators 
working on ROHS2, national bodies putting ROHS2 into national law. Too long 
list to not find anyone thinking.

I see two possibilities:
1. It is not an error - extremely hardly to believe for me.
2. All people there become used to any illogicality and just not notice the 
next one (one more, one less - who cares) - easier to believe for me.

Am I the only seeing that King is nude. ?

Isn't it the last time to protect EMC and LVD from that error?
Has anyone over there enough power and time to do it?

About carrot and fish...
How do you think:
1. If Pb (and others) would be in electronic equipment and in manual and both 
land at waste dump. Where from the water would take it faster to the ground?
2. Do the amount of CDs landing at waste dump is so small that if there are 
some restricted substances in their plastic it is much less care than in 
electronic devices?
May be the direct RoHS scope interpretation saying manuals and CDs need also be 
RoHS is reasonable ;)

Best Regards
Piotr Galka

  - Original Message - 
  From: Crane, Lauren 
  To: Piotr Galka ; EMC-PSTC 
  Sent: Thursday, November 21, 2013 1:13 AM
  Subject: RE: [PSES] EN 50581 part/range of parts


  Piotr, 

   

  This topic illustrates a concept that can be called the supremacy of 
practicality. 

   

  I agree with you that the RoHS directive calls for No . (unique 
identification of the EEE): in the DoC. What I have learned is that the EU 
legislation as a collective is not really sure what this means, exactly. 

   

  There appear to be two/three sides battling. Side 1 - people who think each 
product unit should have a unique number and that should be placed in a unique 
DoC for that particular unit. Side 2 - people who think only a general product 
descriptor (e.g., model name) should be required in the DoC. Side 3 - people 
who think a DoC can cover several unique units provided the unit number range 
(serial number range) is expressed in the DoC. 

   

  Currently both the Low Voltage Directive and the EMC Directive are being 
recast. You can observe parliament and the council struggling with this issue. 
Here, for example, is an excerpt from a current mid-process document for the 
EMC Directive recast regarding the requirements for the DoC. 

   

  Commission Proposal -  No . (unique identification of the apparatus): 

  Parliament Position - No . (identification of the apparatus):

  Council Position - Product/Apparatus (product, batch, type or serial number 
)

  Expected compromise/outcome - [Council Position]

   

  As long as DoCs reasonably express the identification of covered products, I 
think in the current legislative environment, any practical solution will be 
acceptable. There is certainly enough evidence that 1 - there is a preference 
that one DoC be provided for all applicable directives (rather than a separate 
DoC for each applicable directive) and 2 - directives are not completely 
harmonized on how the covered product(s) must be identified. 

  

   

  50581 allows supplier declarations, confirming that the restricted substance 
content

Re: [PSES] EN 50581 part/range of parts

[Piotr Galka]

Peter,

I think all your 3 levels should be considered under point 4 of DoC content 
(RoHS2 Annex VI) according to manufacturer needs.
The problem I am speaking about is point 1 of this content, which I suppose 
should not be about product identification but about DoC unique 
identification.


Regards
Piotr Galka

- Original Message - 
From: Peter Tarver ptar...@enphaseenergy.com

To: EMC-PSTC@LISTSERV.IEEE.ORG
Sent: Friday, November 22, 2013 6:44 PM
Subject: Re: [PSES] EN 50581 part/range of parts



From: Piotr Galka
Sent: Friday, November 22, 2013 05:15

The fourth side: We (I hope I will not be alone) think
point 1 is an error - it should call for No... (unique
identification of document):


I will propose yet another position.  This position appears to me to
logically suit the intent of the RoHS Dir.

For a product with a given model designation, there may be multiple 
product
revisions that don't affect the overarching model designation.  I've 
worked

at companies that had three levels of product identification (others may
have more), each of which was marked on the product for traceability
purposes that aided in customer support and failure analyses.

Level 1: A model designation that is generally unvarying, but may have a
revision code that changes only for large changes in functionality that
marketing wants to make customers aware of.

Level 2: A part number for the product that is used coincident with the
model designation that contains a suffix that is allowed to change more
frequently than the model designation.

Level 3: A lower level part no. that changes frequently (even with every
minor ECO or MCO addressing minor cosmetic issues as well as with more
substantive changes) and may or may not change a suffix only.

To address the RoHS Dir. for a product following the above (or a similar
scenario), each level of product identification that can be or is RoHS
compliance affecting must be identified in the DoC.  This might include 
only
the first two levels in the above example.  As the revision levels roll 
up,

a new DoC should be issued that covers the relevant product identifier
levels.

It is completely illogical that every S/N should be identified.  For
products that have high production rates, this is ridiculously onerous. 
Not

that politicians are immune to being illogical or ridiculous, either by
design or through ignorance or negligence. ☺


Regards,

Peter Tarver


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Re: [PSES] EN 50581 part/range of parts

[Piotr Galka]

Lauren and others,

I have read (I believe carefully) this FAQ.

From Q8.14 and Directive Article 7(g) I see that product identification can be 
batch number. For my understanding it is not unique identification called in 
Annex VI. But OK let it be, I don't care because my products have unique 
numbers.

Q8.9 says that DoC would reference the product normally by the model number. I 
don't believe that ANNEX VI 1. No(unique identification of EEE): means 
model number, but I must all the time suppose that I don't understand English 
good enough.
Can someone tell me if unique identification of EEE can really be understand as 
model number ? I really don't believe!
If FAQ is in opposite to directive itself than I must remember of FAQ Preface: 
These FAQ reflect the views of DG Environment and as such are not legally 
binding: binding interpretation of EU legislation is the exclusive competence 
of the Court of Justice of the European Union.
I still don't know if I have to issue separate DoC for each device (I have not 
batch numbers, but individual numbers).

Q8.10 and Q9.6 directs me to EN 50581 to get presumption of conformity so it 
still looks that I need the declaration for each 100pcs of resistors I will 
order. I don't think that order saying that I order ROHS2 compliant parts and 
invoice saying that they are ROHS2 can be understand as signed contract which 
would allow me not to have supplier declaration.
How high is in your opinion probability that if Court of Justice of European 
Union will have to decide if such order and such invoice can really be 
understand as signed contract than they will say yes. It would help a lot if 
I could believe it is around 95%, but unfortunately (based on my understanding 
of English) I believe it is around 0%.

The most surprising for me is the Q7.2.
I knew that:
- carrot is the fruit,
- snail is the fish,
- Poland, Germany and some other countries have no access to the sea,
and it looks that I should add to that list that:
- light is not electromagnetic field.

Best Regards
Piotr Galka


  - Original Message - 
  From: Crane, Lauren 
  To: Piotr Galka ; EMC-PSTC@LISTSERV.IEEE.ORG 
  Sent: Friday, November 15, 2013 2:22 AM
  Subject: RE: [PSES] EN 50581 part/range of parts


  Piotr, 

   

  Reading the EU Commission's FAQ on RoHS2 might help you 
http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf. 

  Components (i.e. things not intended for direct sale to the end user) are not 
considered to be in scope of RoHS (even though they fit the definition of EEE). 
It has to do with the concept of finished product.  

   

  So, if you are going to be using the 100pcs of resistors in your product, you 
should constrain your supplier with a contract that requires them to be RoHS 
compliant, but you do not need a DoC from them. 

   

  Regards,

  Lauren Crane

  KLA-Tencor

   

  From: Piotr Galka [mailto:piotr.ga...@micromade.pl] 
  Sent: Wednesday, November 13, 2013 8:27 AM
  To: EMC-PSTC@LISTSERV.IEEE.ORG
  Subject: [PSES] EN 50581 part/range of parts

   

  To English language standard experts,

   

  How do you understand specific part and specific range of parts in last 
sentence in EN 50581:2012 Cl. 4.3.3 (a):

  Such declarations ... shall cover a specific ... part ... or a specific 
range of ... parts...

   

  According to:

  - directives understanding of putting product on the market (not type but 
single piece),

  - direct meaning of the words (as I fill them),

  it looks that:

  part = this one single part,

  range of parts = some (specified) number of the same type parts.

   

  If it is true I see problems with ROHS DoC.

  If I buy 100pcs of 0603 1k resistors should I ask the supplier for sending me 
the declaration for specified range of these 100pcs ?

  And the same for all 200 other types of elements ?

   

  The other way of understanding is:

  part = part type (resistor 0603 1k)

  range of parts = range of part types (resistor 0603 from 1ohm to 10Mohm)

   

  This looks more logical for someone trying to make ROHS DoC but:

  If they wonted to say part type or range of part types they would 
certainly said that. As they didn't said that I think they had the previous 
understanding in mind.

   

  What is the solution I don't see ?

   

  Best Regards

  Piotr Galka

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[PSES] EN 50581 part/range of parts

[Piotr Galka]

To English language standard experts,

How do you understand specific part and specific range of parts in last 
sentence in EN 50581:2012 Cl. 4.3.3 (a):
Such declarations ... shall cover a specific ... part ... or a specific range 
of ... parts...

According to:
- directives understanding of putting product on the market (not type but 
single piece),
- direct meaning of the words (as I fill them),
it looks that:
part = this one single part,
range of parts = some (specified) number of the same type parts.

If it is true I see problems with ROHS DoC.
If I buy 100pcs of 0603 1k resistors should I ask the supplier for sending me 
the declaration for specified range of these 100pcs ?
And the same for all 200 other types of elements ?

The other way of understanding is:
part = part type (resistor 0603 1k)
range of parts = range of part types (resistor 0603 from 1ohm to 10Mohm)

This looks more logical for someone trying to make ROHS DoC but:
If they wonted to say part type or range of part types they would certainly 
said that. As they didn't said that I think they had the previous understanding 
in mind.

What is the solution I don't see ?

Best Regards
Piotr Galka

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Re: [PSES] EMC requirements for developer/evaluation boards

[Piotr Galka]

Some 'experts' were recruited at some stage as 'advisers', but 
the selection seems to have been based on criteria other than technical 
expertise.


As always :) or rather
As always :(

Piotr Galka

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Re: [PSES] EMC requirements for developer/evaluation boards

[Piotr Galka]

Hi Gert,


It's not a absolute requirement for these board to be sold
as a bare PCB. It has consequences for the prices of course but
that is valid for each device, not for development boards only.


Not agree.
I hardly can imagine not development board sold without enclosure and 
destined to normal use without enclosure so enclosures are real need in that 
case (adds something else, not only price). If you can find some such 
products it will be only few so not it is valid for each device.

For development board enclosure is really not needed.
Specially for boards with some area to assemble your own circuits working 
with circuits originally on board. Enclosure would function as just delivery 
packaging so as device should be tested in configuration as in normal use 
(it is logical) the device should be tested without such enclosure.



And it is not because you can touch a chip, that it need to be
tested. Standards speak about likely to be touched in normal use.
Connector internal pins on my Ipad are accessible too, but most standards 
do
not include them for ESD testing. It may be wise to do so, but that is 
another story.


Yes, it is another story, but touching of connector internal pins can be (up 
to some level) understood as not likely, but touching internal circuits on 
development board is likely. Each time you take such board in your hand you 
touch some conducting things connected to some elements and probably IC pins 
on it.



Your opinion about the EC in these, in casu their authors, is not mine.
EC texts do generally excel in quality, what need not be the same as
clear to us,  or in line with our needs. Note that they are
addressed to the member states and their legal advisors and not to
the end users. If unclear on a special subject, than it
certainly is the case because the subject is not well enough defined, or
it would open a way to avoid requirements by what i call
smart naming or smart selling.

When I was discovering how directives work I understood (may be wrongly) 
that directives need to be directly written into member law. It has to be so 
because if it would not be so than they would not do the main job they are 
intended to - to make the whole market the one market with the same rules.
As I remember I have read long time ago that one member was 1 year late in 
adopting one directive and (during that year) some firms did something 
according to the directive and not to the member law and later the firms won 
in court (it was something about hotels as I remember, but not sure).
So in my opinion no other law source should be so clear as directives should 
be. Any unclear point in them has the effect of many unclear in member laws 
(and long discussions here :) ).


If I during first reading of directive (not reading any other directives 
before) see some problems in it I don't believe no one noticed it. I think 
they noticed, and I don't understand why they didn't do anything with it.


Regards
Piotr Galka 


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Re: [PSES] EMC requirements for developer/evaluation boards

[Piotr Galka]

Hi Gert,


To Piotr: ESD test are normally carried out on enclosure
and connector shielding, not to internal circuits.
HCP and VCP discharge are designed for this.



My logic is:
The idea of ESD test is to check possible events which can happen in normal 
use of device.

The possible source of ESD are human fingers.
Human fingers touches enclosure and not internal circuits because enclosure 
is between fingers and internal circuits.
So ESD is tested on enclosure and on HCP and VCP = all expected ESD that can 
happen to and near device.
If device has plastic enclosure than in real ESD to something near device 
has higher probability than to device (which is close to 0%).


If there is no enclosure than human fingers can touch directly internal 
circuits so following the idea of testing all possible ESD events in my 
opinion ESD should be also tested to internal circuits. I think that for 
such device the ESD to internal circuits has much higher probability than to 
something near (HCP and VCP). There is no idea to testing something less 
probable and not testing something more probable.


If the prototype board is to be used only in ESD protected environment than 
testing ESD to internal circuits can have no sense but testing ESD to HCP 
and VCP also has no sense.


But generally I think that prototype board should be excluded from EMC at 
all and it should be written in the first EMC directive version long time 
ago.
When I first time read EMC (in 2002 - two years before we (Poland) joined 
EU) the question about prototype board was my first thought.
Being not clear solved in directive that subject makes me to have clear 
opinion about its authors.


Best Regards
Piotr Galka

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Re: [PSES] EMC requirements for developer/evaluation boards

[Piotr Galka]

Hi John,

If prototype board can't get CE mark because of EMC may be it can get CE mark 
because of other directive.
I'm not on time (probably wrong English) (I have speed a year developing new 
devices and now I will spend next year on CE bureaucracy - I dream to times 
when developing/bureaucracy was 90%/10%).
I have heard that during I was busy ROHS become CE.
If the prototype board are not excluded from ROHS you have the way to put CE on 
it and avoid entering Europe without any marking or DoC.
Many prototype boards use some RF communication - than may be RTTE will help 
you to make DoC and put CE on it.

Best Regards
Piotr Galka
  - Original Message - 
  From: EMC Guy 
  To: EMC-PSTC@LISTSERV.IEEE.ORG 
  Sent: Friday, October 25, 2013 5:47 PM
  Subject: Re: [PSES] EMC requirements for developer/evaluation boards


  Hi Brian,


  Your summary is exemplary.  It points out exactly what I have also read in 
the Guide, that lead me to believe that a Developer Kit might by excluded from 
the EMC Directive. Particularly the End User definition.


  Which brings me to the second part of the problem: entering Europe without 
any marking or DoC whatsoever.  Do you know of an established method to declare 
the non-applicability of CE-marking related directives, so the customs 
officials do not deny entry each time one of these boards is shipped to Europe. 
 Something that would resemble FCC Form 740 for example.


  To John Woodgate: Thanks for the lead on Farnell, I have asked them the 
question, I'll post their answer if I ever get one.


  John




  On Fri, Oct 25, 2013 at 10:25 AM, Kunde, Brian brian_ku...@lecotc.com wrote:

The Guide for the EMC Directive may be somewhat helpful.

As it is sold, do you feel this type of product is really an Apparatus? 
It has no function as sold. Don't you have to incorporate it with other 
Components to make it work? Isn't it really a Component or sub-assembly 
incorporated with other Components or sub-assemblies to create a Prototype 
Apparatus not intended to be marketed?

Can you classify it as a Component or Sub-Assembly which is NOT 
Intended for Incorporation into an Apparatus???
Referring to the Guide for the EMC Directive 2004/108/EC (8th February 
2010), look at the Flow Charts starting on page 10; then go to Flow-Chart 2 on 
page 16.
A Component or Sub-Assembly NOT Intended for Incorporation into an 
Apparatus would be Excluded from the EMC Directive.

An Apparatus must also be intended for the End User. Though in this case, 
the End User would be an Engineer with knowledge of Electronics which would 
most likely include at least some knowledge of EMC. On page 17 of the guide 
where it describes what an End User is, see the text that says, Generally an 
end-user is deemed to have no qualifications in the field of electromagnetic 
compatibility.  Products not intended for the End User is Excluded from the 
EMC Directive.

In the scope of the EMC Directive, it says, When compliant with the 
provisions of the EMC Directive, equipment
may be placed on the market and/ or put into service in the Community 
territory, freely moved and operated as designed and intended in the expected 
electromagnetic environment.  So what is the expected electromagnetic 
environment for a product like this? It is intended to be used Temporarily in 
an engineering lab or Research and Development lab. What is the Expected EMC 
Environment of such an area where prototype electronic devices without any EMC 
testing is commonly operated for long periods of time? Though I cannot find any 
text that specifically excludes prototype electronic devices operating in an 
RD environment, it is kind of a no brainer.

Hope this is somewhat helpful.

Brian



-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: Friday, October 25, 2013 6:22 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC requirements for developer/evaluation boards

In message
caey+zhmv+erfxd--dvutjklyva7wbr1dtjdkjxfqyj6m5lg...@mail.gmail.com,
dated Fri, 25 Oct 2013, EMC Guy emc.guy@gmail.com writes:

.  My literature research did not come up with anything helpful,
especially for Europe

As I explained, you will not find anything explicit about this issue.
Wherever you are, you can ask Farnell, but the answers will be 
Europe-oriented.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk If 
dictionaries were correct, we would only need one, because they would all give 
the same information.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EMC requirements for developer/evaluation boards

[Piotr Galka]

Hi Gert,
  The boards you mention are supposed to comply with the requirements.
  and probably are.



How do you expect them to pass ESD test ?

The rationale (in my opinion) is to select any point where (during normal use) 
ESD can probably happen and have any effect.

If the board has not case, but is intended to be installed in some case (like 
PC extension boards) then during normal use ESD can attack only the case and 
such board should be tested installed.

If the board is expected to be used without the case then ESD can attack any 
point accessible for human fingers.



Best Regards

Piotr Galka

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Re: [PSES] safety 60950 and surge suppression circuits

[Piotr Galka]

Hi Joe,

I was asking the question like yours about 5 years ago here. Until now I'm not 
sure how to understand this all.

My device was USB-RS485 interface powered from 12V DC (user should select 
himself some AC/DC or use 12V battery backuped power source).
As RS485 can be up to 1200m and I assumed it can go out of building so it is 
TNV-? (don't remember number) and has to be isolated.
My isolation was 4kV (ADuM series Analog Devices magnetic isolators with very 
thin (some um) isolation barrier inside).
I was worry that if the device is connected to USB (potentially grounded) and 
someone touches RS485 than ESD from his finger can damage my isolation. I have 
read that in real live even 25V ESD from finger can happen (woman 35kV).
This was my reason to use SPD.
Reading 60950 I found that voltage of my SPD must be related to voltage 
powering my device so there is nothing against SMB 20V transil to be used.
I was told that I'm not right and even in 60950 it looks that it is the voltage 
powering my device the standard tells about AC voltage system under which I am 
using the device.
I didn't understood why I should understand standard differently than it is 
written but OK let it be.

I can imagine that somewhere there is 12V (or 24, or 48) power distributed in 
building. In that situation 60950 calls for 1kV (not sure it was 5 years ago) 
isolation of out of building telecommunication lines allowing to short the 
isolation with for example 20V SPD.

Like you I don't understand it.

Piotr Galka

  - Original Message - 
  From: Joe Randolph 
  To: ri...@ieee.org 
  Cc: EMC-PSTC@LISTSERV.IEEE.ORG 
  Sent: Thursday, June 06, 2013 12:08 AM
  Subject: Re: safety 60950 and surge suppression circuits


  Hi Rich:

  Thanks for insight on this.  I think your remarks, copied below, explain the 
logic behind clause 6.1.2, but still leave questions about the thinking behind 
clause 6.2.

  The hazard that is mitigated by the isolation barrier is that of a fault in 
the equipment across the
  isolation barrier to the telephone line.  Down the telephone line, an 
unsuspecting telephone serviceman
  is working on the line expecting only normal telephone voltages.  This 
isolation must be retained even
  in the event of a lightning strike on the telephone line that otherwise could 
damage the isolation
  barrier.

  So, we have three situations.  First, isolation between equipment circuits 
and telephone circuits to
  prevent injury to a telephone serviceman.  Second, preservation of that 
isolation in the event of a
  transient (lightning) voltage that could come into the equipment on the 
telephone line.  Third, in 
  the event of an over-voltage on the telephone line, the SPD prevents circuit 
damage within the 
  equipment (but the SPD is expected to fail open).  


  CLAUSE 6.1.2

  Clause 6.1.2 is the one that addresses the problem of hazards within the 
equipment getting onto the phone line and injuring a telephone service person 
who is working on the network.  I think the origin of this requirement comes 
from the old UK standard BS 6301, and was based on the possibility that a 
mis-wired mains plug could result in the equipment ground wire being connected 
to a live mains wire (this fault mechanism is more common in the UK than in 
most other countries due to the way consumers deal with conflicting plug 
configurations).  So, in this case, an equipment chassis that is supposed to be 
grounded becomes hot.  

  Clause 6.1.2 requires that any SPD connected across the barrier have a 
breakdown threshold that would not turn on for normal mains voltages.  So, for 
clause 6.1.2, I would summarize your explanation as follows:

  1) The actual goal of the requirement is to always maintain a barrier that 
will not break down for normal mains voltages (about 400 volts peak for Europe) 
.
  2) If there is no SPD across the barrier to protect the barrier from 
lightning damage (or if the SPD is present but has failed open), the barrier 
must withstand an expected worst-case lightning surge of about 2100 volts peak 
(verified with a 1500 VRMS hipot test).

  The above rationale is interesting because it says that the purpose of the 
SPD is to protect the isolation barrier.  This makes sense except that it 
ignores that possibility that the SPD could fail short.  If all SPDs were gas 
tubes, ignoring the fail-short possibility might be a reasonable assumption, 
but with the solid state SPDs that are now in common use, a fail-short 
mechanism is actually more likely than a fail-open.  In fact, many solid state 
SPDs are explicitly designed to fail short when overstressed.  MOVs, which have 
been used for many years in various telecom protection circuits, also have a 
fail-short mechanism that is probably more common than fail-open.


  CLAUSE  6.2

  Clause 6.2 is concerned with protecting equipment users from hazardous 
voltages that may appear on the phone network (presumably lightning and power 
cross

Re: [PSES] Machinery Directive silly question?

[Piotr Galka]

Nick,

These conversation made me to look for the Machinery Directive (I have never 
read before). Having no time to read the whole I made a fast search for word 
'moving' but I can't find the place the machinery is defined as anything 
containing moving parts as I understand from conversation here.


Being under 'silly question' subject let me ask some questions.

Where from it comes that moving part makes equipment the machinery?
Do the minimal size or moving distance of that part is defined?
In Article 1(k) I don't see telecommunication equipment. Is it excluded as 
information technology or not ?
Do the classical phone with ring has moving parts and is covered by 
Machinery Directive?
Do the cell-phone signalling incoming call by vibration has moving parts and 
is covered by Machinery Directive ?
Do any device which is not excluded by Article 1, but has loudspeaker is 
covered by Machinery Directive?
Do the device using MEMS technology (contains micro moving parts) has moving 
parts and is covered by Machinery Directive?


Best Regards

Piotr Galka
MicroMade
Poland



- Original Message - 
From: Nick Williams nick.willi...@conformance.co.uk

To: Peter Merguerian pmerguerian2...@yahoo.com
Cc: Mark Hone mh...@wellmandefence.co.uk; EMC-PSTC@LISTSERV.IEEE.ORG
Sent: Monday, April 30, 2012 10:24 PM
Subject: Re: Machinery Directive silly question?


This is incorrect. This approach was permitted by 98/37/EC but 2006/42/EC 
no longer permits this kind of analysis.


Regards

Nick.

On 30 Apr 2012, at 18:33, Peter Merguerian wrote:


Mark,

You need to do a comprehensive  risk assessment and determine if the risk 
of injury to persons using or servicing the equipment  is more mechanical 
or more electrical. You may have a moving part that is inside the 
equipment and inaccessible. How fast is that moving part? How is it 
secured? Is it accessible to a service person? Can the interlock of 
access doors be defeated? Lots and lots of questions that your 
engineering team need to ask

before deciding which Directive must be applied.




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Re: [PSES] Machinery Directive DOC Questions

[Piotr Galka]

Brian,
 
Sorry for answering having no answer for your question, but the New Year and 
your question make me to have some basic thoughts.
10 years ago I spend 90% of my time designing new electronic devices (doing 
that I like the best since I was 10).
Now it is hard to get 10% for designing, I must spend 90% on papero-logy.
Everything goes to the moment no one will be doing anything except very 
important analyses, documentation, reports, . generally papers.
I suppose soon I will have to count each single atom in my product (may be I 
missed something and it is not soon but now).
Today I heard on the radio that EU destined plenty Euros for program to have 
for each road turn a certificate of safety (firstly I supposed may be we have 1 
April today). They were speaking about new study specialisation and a lot of 
people who wont to be the road auditors because big part of these Euros will 
land in their pockets.
In my opinion it is the right way to catastrophe, and I don't understand why we 
all are going that way.
It looks there are people who wants check/count everything what can be count. 
Why not assign one people to each tree in forest with task to count leaves and 
measure its growth each day. 

Piotr Galka
MicroMade
Poland


  - Original Message - 
  From: Kunde, Brian 
  To: 'EMC-PSTC@LISTSERV.IEEE.ORG' 
  Sent: Wednesday, January 04, 2012 6:38 PM
  Subject: Machinery Directive DOC Questions




  Our company makes laboratory equipment (the red-headed step child) which has 
no defined category of its own so it generally falls under the LVD unless it 
has a moving part to which it is now subject to the machinery directive (which 
is a new nightmare for me). But like many products produced these days, our 
products are built-to-order with dozens of variations and possibly hundreds of 
different combinations. We evaluate each model family in its maximum 
configuration with all possible variations installed for EMC and Safety which 
generally includes a sample loader or autoloader (moving parts). So we 
evaluate, test, and declare compliance to the Machinery Directive and generate 
a DOC for that product family.



  Question #1



  When a customer orders a configuration that does not include the sample 
loader (moving part), can we still declare compliance to the MD or in these 
cases do we have to generate a different DOC declaring to the LVD? In this 
case, would we have to establish a system to produce custom DOCs for each 
device produced depending on the options ordered by the customer? 





  Question #2



  Because the MD requires an accompanying unique signed DOC for each such 
device built and to include the specific model number (based on options 
ordered) and serial number, how do most companies logistically handle this? I 
don’t imagine that each company has a “Managing Director” sitting at the end of 
the product line signing, copying, packing, and filing the DOC for each product 
built. So how can this be reasonably done and still meet the intent of the 
Directive?  



  Thanks to all in advance.



  The Other Brian










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Re: CE logo dimension in small products

[Piotr Galka]

 

- Original Message - 
From: Pickard, Ron mailto:ron.pick...@intermec.com  
 
Article 10  Annex III of the LVD:

Article 10: “The CE conformity marking referred to in Annex III shall be
affixed by the manufacturer or his authorised representative established
within the Community to the electrical equipment or, failing that, to the
packaging, the introduction sheet or the guarantee certificate so as to be
visible, easily legible and indelible.”

Correct me if I wrongly understand English, but because of failing that I
suppose 'or' here is equivalent to XOR gate logic.

 

Piotr Galka

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Re: Cigarette socket in vehicles

[Piotr Galka]

By the way.
I don't understand why cars still don't have specialised sockets for
electronic equipment.
The cigarette sockets likes to lose contact (it is my experience).
 
Piotr Galka
 

- Original Message - 
From: Scott Xe mailto:scott...@gmail.com  
To: emc-p...@ieee.org 
Sent: Monday, January 19, 2009 2:38 PM
Subject: Cigarette socket in vehicles


I have learnt that cigarette sockets supply two voltages: 12 or 24 
volts. 
12-volt sockets are widely used in light duly vehicles while 24-volt sockets
in heavy duty vehicles.  The sockets are identical in terms of configuration
and dimensions.  Is there any mechanism to prevent a 12-volt equipment from
being plugged in a 24-volt socket?

 

Thanks,

 

Scott

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Re: First EUP Regulation implementation regarding standby power

[Piotr Galka]

- Original Message - 
From: Gert Gremmen g.grem...@cetest.nl

 I believe *your* focus should be directed towards:
 can my design be used in such amounts that
 a considerable amount of otherwise spoiled energy
 can be saved, and can a small effort on our companies
 side contribute to the energy wealth of future generations


Considering the fact that if device is used in heated location than reducing 
its power (active and stand-by) saves no energy I came to: Let's start from 
reducing outdoor devices stand-by mode ? ;-)

Piotr Galka 

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Re: 375MHz from 10/100Base-T

[Piotr Galka]

Ryan,
 

Proper layout is the fix, the transformer has the straddle signal 
ground and
chassis ground planes. These planes should never overlap.

 

Another trick I found is to stitch a 2kV/0.001micro farad SMD capacitor
across sig gnd and chassis gnd.

 

 

I don't understand why to avoid capacitance between signal gnd and chassis gnd
planes and at the same time use the capacitor between them ?
 
Regards
 
Piotr Galka
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Re: Deviation of Performance Criteria - other question.

[Piotr Galka]

Ron,

I suppose the questions from my post you understood as my assertions. I've 
just asked based on what I should assume it is no 'apparatus'.
My product is in my opinion finished (no more assembly by producer or user 
is planned) and will be marketed commercially.

I have in mind the open (without case) boards question just from the 
beginning of my interest in EMC (2 years before we joined EU in 2004) 
because since 1992 we have in our offer the microcontroller education system 
with some open boards connected when needed. After reading old Directive and 
its guide and later the new Directive and its guide I am still not sure if 
after 2004 we sell it legally or not and designing new (this time analogue) 
education system I'd like to be sure.

Best regards

Piotr Galka


- Original Message - 
From: Pickard, Ron ron.pick...@intermec.com
To: EMC-PSTC emc-p...@ieee.org
Cc: Piotr Galka piotr.ga...@micromade.pl
Sent: Wednesday, November 12, 2008 5:04 PM
Subject: RE: Deviation of Performance Criteria - other question.


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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Re: Deviation of Performance Criteria - other question.

[Piotr Galka]

- Original Message - 
From: John Woodgate j...@jmwa.demon.co.uk

 Then you use the procedure given in Annex III of the 2004/108/EC Directive 
 to get a formal acceptance of your solution by a Notified Body. You can 
 then, under Article 7, apply the CE mark.


And probably it is the only solution (if I really need - am I) to be sure 
that I'm right.
Thank you John.

Reading this Annex it looks that I first have to have the device and then 
can ask if it is OK.
The better would be to have the accepted specifications first - if they 
don't agree for higher emission I can do some steps I described earlier even 
they are not the best from education point of view.
I hope I would not need to follow the procedure for each board which I 
suppose to be ready in few months delays between each other.

Piotr Galka 

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Re: Deviation of Performance Criteria - other question.

[Piotr Galka]

- 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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Re: Deviation of Performance Criteria - other question.

[Piotr Galka]

- Original Message - 
From: John Woodgate j...@jmwa.demon.co.uk

 In the early days of the old Directive, it was considered that educational 
 products did not have to be tested but that Article 4 applied: if 
 interference occurred it must be prevented.

 I don't see anything about this in a quick scan of the current Directive 
 or its guidelines, but I think it should be obvious that educational 
 products have to be treated as a special case. Maybe they are not 
 'apparatus' as defined in the Directive, as they are not 'finished 
 appliances'.

Thank you John.

In 2002 my conclusion about old Directive was that _ONLY_ products destined 
for EMC education can be not tested, as they must violate EMC to show EMC 
problems. All others should be tested (I don't know where from my conclusion 
comes). It is why I gave up those days.
I am mainly a designer. My target is to spend 90% time designing, and 10% 
reading all about EMC, LVD, ROHS,. and standards. Because of this I 
can't be well oriented in any of them.
I have read the ROHS/WEEE interpretation where 'finished appliances' were 
discussed based on the question if they have end user needed function. In my 
understanding education PCB has end user needed function - education.
It has not its special case, but it will newer have such case (it is not the 
module used as part of other apparatus).
My problem is if it is in the EMC scope.
The basestation for this PCB models has its case and I think is 'apparatus'. 
The generator I have described is in that basestation. But the 15cm 
unshielded wire is used only when PCB model is used.
The basestation will be well ESD protected.
Do I have to use this 15cm wire when testing basestation, or test it with 
model not needing generator, or needing 10Hz sinus, or without any model ?
Selecting test that way is certainly not the right way.
There are such systems on the market, and I'm sure use unshielded cables. 
What is the way I don't know.
May be 3MHz TTL at such wire is well under the emission levels, but I don't 
think so.

Where should I ask my questions to have the problem solved once for always?

Piotr Galka

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Re: Deviation of Performance Criteria - other question.

[Piotr Galka]

From: John Woodgate j...@jmwa.demon.co.uk
 
 You should take the problem to the Polish National Standards body and 
 ask the relevant committee to submit your case to CENELEC TC210 for an 
 official 'interpretation'. It may be that TC210 would also need to refer 
 your case to the Commission's 'EMC Working Party'.
 
Do you know that way takes few weeks/months/years ?

Piotr Galka

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Re: Deviation of Performance Criteria - other question.

[Piotr Galka]

From: John Woodgate j...@jmwa.demon.co.uk

 And you seem to think that the emissions would be excessive anyway, so 
 it's doubtful that you would get a positive report from the Notified Body.

My main problem is how to make evident in papers that it is CE OK if 
education circuits can be ESD damaged because I don't see any solution to 
that.

I should be able to limit the emission just making square being not square 
and persuade the pupil that it is really square what they see ;-)

Regards

Piotr Galka 

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Re: Deviation of Performance Criteria - other question.

[Piotr Galka]

- Original Message - 
From: John Woodgate j...@jmwa.demon.co.uk

I should be able to limit the emission just making square being not square 
and persuade the pupil that it is really square what they see ;-)

 Instead of work-arounds, there should be an EMC standard (or a pair, for 
 emissions and immunity) for such educational products.

I don't expect such standards will allow for higher emission then others. 
There is possibility that in next classroom there is TV working.

Except described (method 1) I see other methods of emission limiting:
2) - not allowing the pupil to make connections as they wont, but making 
them permanent when test board is installed (limiting the board flexibility 
of use).
3) - using shielded cables (BNC seems to me too big, but for smaller 
shielded connectors I don't give long live at school environment).
As in 2 and 3 signal wires are not accessible you must add something to 
allow for oscilloscope probe connection.

At the moment method 1 seems to me the easiest so the best one.

Now I believe there is nothing I just missed in these subjects. Thanks John.
But still don't know how existing at market education systems manage with 
ESD problem.

Regards

Piotr Galka
P.S. Live was easy and pleasant before 2004 ;-) 

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Re: Deviation of Performance Criteria - other question.

[Piotr Galka]

- Original Message - 
From: Cortland Richmond k...@earthlink.net


 1) Use less than 9 KHz for a clock.
1MHz generator is standard in such systems.
AM and FM receivers are a kind of basic electronic in my opinion so I'd like 
to allow for taking frequency characteristics of 465kHz and 10.7MHz filters, 
and see AM and FM demodulators working.

 2) Note that the equipment is not complete (a breadboard isn't, after all)
 and so not subject to the standards for completed equipment.

It is used by end user and there is nothing planned to be added to it so why 
it is not complete?
Typical breadboard isn't complete as it is destined to be installed in some 
case.

 3) Use a SELV power limited supply.
Right.

Regards

Piotr Galka 

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Deviation of Performance Criteria - other question.

[Piotr Galka]

 
Dear Experts please help me to answer my question(s) I have since few years.
I planned to ask it later, but it looks very close to that conversation
subject so I ask now.
 
I plan to produce the electronic education system.
If I have the PCB with single transistor amplifier (or some OpAmp circuit) to
allow pupil to measure it I have to make all pins accessible at least to allow
for connecting the scope probe. I think I cannot protect each pin against ESD
because my protection elements will certainly disturb the measurement results
making them different from theory - for me unacceptable from education point
of view.
I expect during EMC tests ESD can destroy that transistor, or OpAmp (really
each education board can be destroyed by ESD). At the same time I don't expect
real problems in practical use of it.
In my opinion the right standard is 61326 which fortunately allows for
deviation for ESD criteria, but even it don't allow the DUT being destroyed by
ESD.
When I read here that new version don't allows for previously allowed
deviations I came to seeing no way how I can do that education equipment with
accordance with right standard.
On the other way I don't expect that in EU practical electronic education is
forbidden now and should be replaced with simulation only ;-)
 
If there is someone who knows what is the solution please tell me.
May be some notes in TCF and instruction are enough.
Each such experiment PCB is low price and low volume product so I don't
consider asking for external official opinion for each of it.
 
The other EMC problem with that design:
It is typical (and I assume also) to use unshielded short (10 - 15cm) wires to
make the connections by pupil at such devices.
The function generator (1Hz to 3MHz, better to 10MHz) is the standard part of
such system.
Do I have to hardly filter the main (sin/triangle/square) output to have
nothing above 30MHz making the square not being the square ?
But the generator should also have the TTL output which can also be connected
by such 15cm cable to some circuit under test.
I suppose (not sure) that such TTL signal in 15 cm unshielded wire will
violate allowed emission levels.
I have read 61326 two years ago and don't remember now.
Is there any point saying that if the generator is intended to generate the
signal that it's emission at generated frequency can be higher than limit ?
If yes than if the generator has square output the harmonics of the main
frequency are also considered the intended signal ?
 
As with the ESD I also expect no EMC problems with this generator in practical
use because the highest frequency will be used may be 10 minutes per year and
far away from neighbours with their TV sets.
 
I have planed to make such system since more than 10 years, but gave up in
2002 when I read that shortly (when we join EU in 2004) all devices on the
market will have to be ESD protected.
Now I'd like to realise my dream, but don't know how to solve two described
problems.
 
I believe you can help me.
 
Best Regards
 
Piotr Galka   piotr.ga...@micromade.pl
 
 

- Original Message - 
From: Kunde, Brian mailto:brian_ku...@lecotc.com  
To: Ted Eckert mailto:ted.eck...@microsoft.com  ;
EMC-PSTC@LISTSERV.IEEE.ORG 
Sent: Wednesday, November 05, 2008 8:24 PM
Subject: RE: Deviation of Performance Criteria



As Doug mentioned in his email, the allowance of deviations appear to 
have
been removed in the 2006 version of the EN 61326-1 standard which I believe
becomes mandatory in February 2009.  Can anyone else confirm this or is there
some other statement in the 2006 version that I’m not seeing that allows the
deviation? 

 

Thanks,

The Other Brian

 





From: Ted Eckert [mailto:ted.eck...@microsoft.com] 
Sent: Wednesday, November 05, 2008 1:53 PM
To: Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Deviation of Performance Criteria

 

As I read EN 61326, it allows the manufacturer to specify the 
performance
criteria for each test.  The standard only requires that equipment shall not
become dangerous or unsafe as a result of the application of the tests.  Table
2 is only an example of evaluation of immunity test results.  The note states
“…performance criteria B and/or C may be accepted provided that both the
specification and the test report highlight such deviation(s) for the relevant
combination(s) of function and test.”

 

The standard does require that the deviations be listed in the 
specifications
in addition to the test report.  If the published specifications do not
describe the deviations, the manufacturer may be considered in noncompliance
with the standard.  If they have declared compliance via the standard, this
could be an issue.  If the manufacturer has chosen not to use the standards
route but claims compliance

Re: CE marking in-house equipment.

[Piotr Galka]

- Original Message - 
From: John Woodgate j...@jmwa.demon.co.uk

 What is 'it'? The Subject is CE marking, but 'it' is the RTTE Directive. 
 While the CE mark is directed only to Customs and regulators, the 
 Directive affects everyone.

Affects everyone and requires CE marking. Am I wrong ?

Piotr Galka
MicroMade
Poland

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