[PSES] Position at Microsoft

[Ted Eckert]

There is a job opening for a Senior Product Safety Engineer at Microsoft. 
Anybody interested can find more information here.
Senior Product Safety Engineer | Microsoft 
Careers<https://jobs.careers.microsoft.com/global/en/job/1669081/Senior-Product-Safety-Engineer>

Ted Eckert
Principal Safety & Energy Engineer
Microsoft


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Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

[Ted Eckert]

There are many directives that are not CE marking directives, including both 
the GPSD and GPSR. Other examples are WEEE and the energy/ecodesign 
requirements for products. For example, computers must comply with 617/2013, 
but the CE mark is not specified to show compliance. Many energy directives 
have the labels with the A-G ratings as proof of compliance.
Energy label and ecodesign 
(europa.eu)<https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/energy-label-and-ecodesign_en>

Ted Eckert
The opinions expressed in this message are my own and do not necessarily 
reflect those of my employer.

From: Ralph McDiarmid 
Sent: Wednesday, November 1, 2023 2:03 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

I found that too, but isn’t the GPSD a “new approach” directive ?   I am sure 
it must be; it was certainly published after 1985.  By that criterion alone, it 
seems appropriate to apply the mark.

From: John Mcbain mailto:johnmcb...@ieee.org>>
Sent: Wednesday, November 1, 2023 1:49 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

Correct. Or more specifically -

https://single-market-economy.ec.europa.eu/single-market/ce-marking_en#:~:text=It%20is%20compulsory%20only%20for,origin%20of%20a%20product%20either.

Best regards,
John McBain


On Wed, Nov 1, 2023 at 1:20 PM John Woodgate 
mailto:j...@woodjohn.uk>> wrote:

Somewhere in all the Byzantine rules, there is a ban on applying the CE mark if 
no Directive or Regulation that demands it applies to the product.
On 2023-11-01 19:58, Ralph McDiarmid wrote:
Furthermore, I have not found anything document which says that you cannot CE 
mark a product having a DofC listing the GPSR.  The proviso that you can issue 
a DofC against Directive 2001/95/EC but cannot CE mark the product is not 
stated anywhere in the official website of the EU (Europa.eu) or in the GPSD.  
Perhaps it’s just well hidden.


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Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

[Ted Eckert]

Hello Amund,

The GPSR is not a CE-marking Directive, and products that fall under the GPSR 
can be placed on the market without safety information on the Declaration of 
Conformity if they do not fall under any other Directive that requires a 
declaration for safety. However, that is only related to what is on the 
Declaration of Conformity, affecting the ability to properly import a product 
into the EU.

However, regulations on the import of products are not the only regulations 
affecting product safety requirements. Product liability law exists in the 27 
EU member states. If you have a professional product meeting the requirements 
you propose, and there is some allegation of a safety issue, the customer can 
seek remedies from the importer, distributor, and/or manufacturer. Your ability 
to defend your company in court will be significantly diminished if you have no 
documentation showing that a safety analysis has been done.

In general, all of the economic actors involved in selling products carry the 
responsibility of making sure the products they sell meet legal requirements. 
It will be up to your legal department to determine the risk of placing a 
product on the market without a safety evaluation. The need for producing 
safety documentation might not be limited only to the RED, LVD, or GPSR.

Best regard,
Ted Eckert

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


From: Amund Westin 
Sent: Wednesday, November 1, 2023 12:41 AM
To: Ted Eckert ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: SV: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

Thanks Ted,

As I read your comments and take they into an example - ... consider a 
professional electronic product, which can't be bought or even used by 
consumers, will not under any circumstances be covered by GPSD/GPSR. Right?
And if product is low powered (not within LVD), then maybe only EMC apply. Then 
the product could be put on the market without any safety related tests  Is 
that correct?


BR
Amund


Fra: Ted Eckert
Sendt: 31. oktober 2023 16:10
Til: Amund Westin mailto:am...@westin-emission.no>>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Emne: RE: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)


Hello Amund,



The GPSR has these definitions. I recommend you use them as the basis to 
determine if you are providing "consumer products" as covered by the scope of 
the GPSR.



"'product' means any item, whether or not it is interconnected to other items, 
supplied or made available, whether for consideration or not, including in the 
context of providing a service, which is intended for consumers or is likely, 
under reasonably foreseeable conditions, to be used by consumers even if not 
intended for them".



"'consumer' means any natural person who acts for purposes which are outside 
that person's trade, bushiness, craft or profession".



There is no clear line drawn between consumer and professional equipment, and 
the GPSR is intended to cover professional equipment that is likely to be 
purchased for personal use by some consumers. Products that fall into this grey 
area may need to be reviewed on a case-by-case basis. I would recommend that if 
you determine a product is not within the scope, your technical file include a 
clear explanation of why it is out of scope.

Best regard,
Ted Eckert

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






-Original Message-
From: Amund Westin mailto:am...@westin-emission.no>>
Sent: Tuesday, October 31, 2023 7:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)



General Product Safety Directive ... Do I interpret correct that GPSD only 
apply to consumer products? Not for any professional products?

And the new General Product Safety Regulation (GPSR) do the same?





BR

Amund



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Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

[Ted Eckert]

Hello Amund,



The GPSR has these definitions. I recommend you use them as the basis to 
determine if you are providing "consumer products" as covered by the scope of 
the GPSR.



"'product' means any item, whether or not it is interconnected to other items, 
supplied or made available, whether for consideration or not, including in the 
context of providing a service, which is intended for consumers or is likely, 
under reasonably foreseeable conditions, to be used by consumers even if not 
intended for them".



"'consumer' means any natural person who acts for purposes which are outside 
that person's trade, bushiness, craft or profession".



There is no clear line drawn between consumer and professional equipment, and 
the GPSR is intended to cover professional equipment that is likely to be 
purchased for personal use by some consumers. Products that fall into this grey 
area may need to be reviewed on a case-by-case basis. I would recommend that if 
you determine a product is not within the scope, your technical file include a 
clear explanation of why it is out of scope.

Best regard,
Ted Eckert

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






-Original Message-
From: Amund Westin 
Sent: Tuesday, October 31, 2023 7:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)



General Product Safety Directive ... Do I interpret correct that GPSD only 
apply to consumer products? Not for any professional products?

And the new General Product Safety Regulation (GPSR) do the same?





BR

Amund



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Re: [PSES] BBC news article re Li-ion batteries...

[Ted Eckert]

I can give additional background on the reason why these fires have become 
common in New York. A large number of residents of New York City use delivery 
services for goods and food, such as Uber-Eats, DoorDash, and GrubHub. The 
adoption of these delivery services accelerated during the COVID lockdown, and 
it has become a major business in the city. The drivers for these services are 
contractors, not employees, and they get paid based on delivery without 
reimbursement for expenses. Driving a car is expensive, and finding parking is 
very hard. Delivery people who drive cars often lose money because they incur 
too many parking tickets. The delivery people have switched to battery-powered 
electric scooters and bicycles.

These small electric vehicles are optimal for the delivery services since they 
can move around stopped traffic easily, and they can be brought inside the door 
of a building for a delivery, avoiding the risk of parking fines or the vehicle 
getting stolen. However, the batteries will only last for a few hours of use at 
most. The delivery people want the option of using the electric bicycle or 
scooter all day to try to make more money. The common solution is to remove the 
battery that came with the vehicle and replace it with a much larger 
after-market replacement. The delivery services do not pay well, so people look 
for the cheapest option they can find for a large battery. The regulations in 
the United States make it easy to order something online that has undergone no 
safety testing at all. The result is that a battery of dubious quality is 
placed in an electric bicycle by a person with dubious technical skills. No 
effort may have been made to match the charger with the battery. The battery 
may not be provided with the physical protection necessary to avoid damage 
during use. The question isn’t why there are so many fires, but why there 
aren’t more considering the circumstances.

In the United States, there is reasonable indemnification of the test 
laboratories. The test laboratories accredited under the OSHA Nationally 
Recognized Test Laboratory (NRTL) system have a reasonable level of protection. 
If a product carrying one of their certification marks fails, they can be sued, 
but it would be hard for that law suit to make it to court. The test 
laboratories will indicate that they tested samples on a given date and found 
those samples to meet the technical requirements of the standard at that time. 
Their report does not state that the samples were safe. It only states that 
they passed testing of specific requirements. The legal system places the 
responsibility for safety onto the manufacturer.

The challenges that I see are that battery manufacturers willing to ignore 
safety might be willing to forge safety certification marks and documents. I 
strongly suspect you can buy product online and have them shipped to the UK or 
Europe with a Declaration of Conformity based on nothing. I suspect 
manufacturers will claim their products meet requirements without testing or 
documentation to back it up. If the manufacturer is located outside of Europe 
and has no legal presence there, they can sell on line and avoid 
responsibility. I strongly suspect that this is why there are stricter 
requirements for online importers and distributors in the new GPSR.

The overall issue is not new. Insufficient testing, forged or missing 
documentation, irresponsible actors shipping from the far side of the world and 
the other problems have existed for a while. However, the large size of the 
batteries in these scooters and bicycles, and the common charging of them 
indoors in buildings with a large number of residents, creates an issue where a 
failure can jeopardize many more lives in a single incident.


Ted Eckert

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

From: Matthew Wilson | GBE 
Sent: Friday, July 28, 2023 2:11 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] BBC news article re Li-ion batteries...

I thought this news article that was on the BBC TV broadcast bulletins 27th 
July might be of interest.

“Batteries for e-bikes should be regulated in the same way as fireworks, heavy 
machinery or medical devices because of the fire risk they pose, a charity [UK 
based Electrical Safety First] has said”

https://www.bbc.co.uk/news/technology-66304564


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Re: [PSES] [EXTERNAL] [PSES] Stability

[Ted Eckert]

Hi Steve,

I don't know what would apply in Europe. However, I can suggest taking a look 
at UL 
1678<https://www.shopulstandards.com/ProductDetail.aspx?productId=UL1678>. It's 
intended to cover carts for audio/video equipment, but it does address 
potential hazards that might affect a products such as you are describing. It 
looks at both static and dynamic stability, including stability when being 
rolled over bumps, such as a door threshold, and over gaps, such as when 
exiting an elevator. UL 1678 considers issues such as handle strength, braking, 
and load strength.

Best regards,
Ted Eckert
Microsoft

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

From: Steve Brody 
Sent: Saturday, July 22, 2023 12:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] Stability

A client has a product which is a mobile cart intended for a laboratory setting 
in which it can be moved to whatever lab station it is needed at.  It is on 
casters and when wheeled to the working location, leveling feet which are 
located in the center of the castor mount, are lowered and locked into position 
to keep the cart from moving and to ensure it is level.

The product will be evaluated to EN 60204-1, but there is no reference to 
stability in this standard.

First question is should EN 61010-1, 7.4, be used to evaluate stability, and if 
not then what?

Assuming yes, the first sentence of 7.4 says; 'Equipment and assemblies of 
equipment not secured to the building structure before operation should be 
physically stable.'

Second question is does this section apply to the cart only when in position 
for use, or also when being moved from location to location?

Because when in use the cart is supported by [properly rated] feet, then the 
tests for castors should no longer apply?.

That is the third question.

Your thoughts and comments are requested and appreciated, as always.

Thanks,

Steve Brody
sgbr...@comcast.net<mailto:sgbr...@comcast.net>
C - 603 617 9116


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Re: [PSES] [EXTERNAL] Re: [PSES] EU Machinery Regulation official version

[Ted Eckert]

Hello Brian,

I can only partly answer your questions. See article 52, “Transitional 
provisions”. It notes that EU member states must accept products declared to 
2006/42/EC until 14 January 2027, so there is a fairly long transition period. 
However, there is additional information on the transition of market 
surveillance and safeguard procedures under the new Directive (Chapter VI) with 
a date of 13 July 2023.

I expect the European Commission to update this 
webpage<https://single-market-economy.ec.europa.eu/single-market/european-standards/harmonised-standards/machinery-md_en>
 in the near future. Hopefully, they will include guidelines for the new 
Machinery Directive on that page.

Best regards,
Ted Eckert

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

From: Brian Kunde 
Sent: Friday, June 30, 2023 10:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] EU Machinery Regulation official version

Is there a good source of information on the application of this new directive? 
 Are there any good articles or summaries comparing the new directive to the 
old?  Are there implementation dates? Can we declare compliance to the new 
directive now, or are their other hurdles that need to be put into place?

Is there a source for good comments and discussion on this?  I have only just 
started to dig into it.

Thanks to all.
The Other Brian



On Thu, Jun 29, 2023 at 2:12 PM Lauren Crane 
<1afd08519f18-dmarc-requ...@listserv.ieee.org<mailto:1afd08519f18-dmarc-requ...@listserv.ieee.org>>
 wrote:
FYI – now published in the OJ -- 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R1230

Best Regards,
-Lauren


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Re: [PSES] [EXTERNAL] [PSES] Tracking standards updates

[Ted Eckert]

Hi Brian,

The IEC webstore<https://webstore.iec.ch/> has a "Just Published" section. You 
can subscribe to a weekly email update or you can use the RSS feed. That's 
probably the fastest and easiest way to get IEC updates. You can also look at 
the work of individual technical committees. For example, if you are looking 
for code changes in Europe, check the TC 64 
site<https://www.iec.ch/dyn/www/f?p=103:23:FSP_ORG_ID:1249> occasionally. 
The documents will only be available to TC members and members of other TCs 
with liaisons to TC 64, but you can at least see what standards are being 
updated or have recently been updated.

Ted Eckert
Microsoft

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

From: Brian Gregory 
Sent: Monday, June 19, 2023 10:21 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] Tracking standards updates

You don't often get email from 
brian_greg...@netzero.net<mailto:brian_greg...@netzero.net>. Learn why this is 
important<https://aka.ms/LearnAboutSenderIdentification>

Good afternoon compliance colleagues,

Have a curiously open-ended question from a major OEM who's very 
process-oriented.
So, I'm gathering ideas on how to track standard updates and changes in 
multiple markets (US, EU, etc.).

I'm familiar with IAEI for collaborating with NA inspectors on NEC updates, and 
know that UL & ETL have various update notice/networks, but have no idea how to 
track IEC updates, nor residential code changes for someplace like the UK.  
This is applicable mostly for safety, perhaps a little on EMC.

thanks!

"Colorado" Brian
720-450-4933

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Re: [PSES] [EXTERNAL] Re: [PSES] USB Type C requirements for the EU

[Ted Eckert]

Hi Cecil,

The regulation states "the possibility to acquire radio equipment without any 
charging device and without cables". It isn't an issue of what would 
technically work. It's what the European Parliament wants. The device must have 
a USB connector, and the customer must have the option of purchasing the device 
without a power supply or cable.

Best regards,
Ted Eckert
Microsoft

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


From: cgitt...@rochester.rr.com 
Sent: Monday, February 13, 2023 6:59 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] USB Type C requirements for the EU

Hi Ted,

Thank you very much for your response.

Ear buds come with a charge case that is USB C.  Is that OK?

And if so, why can't a USB C cable to magnet pins work?

As long as a standard USB C charger works, isn't that the intent?

Best Regards.

Cecil

-----
From: "Ted Eckert" 
<07cf6ebeab9d-dmarc-requ...@listserv.ieee.org<mailto:07cf6ebeab9d-dmarc-requ...@listserv.ieee.org>>
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Cc:
Sent: Monday February 13 2023 8:57:19AM
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] USB Type C requirements for the EU
Hi Cecil,

The device must have a USB connector for charging. You must provide the 
customer the option of buying the product without either an external power 
supply or charging cable. The intent of the regulation is that consumers should 
be able to buy new devices that can be charged with their existing USB power 
supplies and cables.

Best regards,
Ted Eckert
Microsoft

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

From: cgitt...@rochester.rr.com<mailto:cgitt...@rochester.rr.com> 
mailto:cgitt...@rochester.rr.com>>
Sent: Monday, February 13, 2023 5:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [EXTERNAL] Re: [PSES] USB Type C requirements for the EU

You don't often get email from 
cgitt...@rochester.rr.com<mailto:cgitt...@rochester.rr.com>. Learn why this is 
important<https://aka.ms/LearnAboutSenderIdentification>
Hi Charlie,

Thank you very much for your response.

Does this mean a USB Type C connector has to be on the device or can a cable 
that has USB C with let's say a magnetic connector on the device end be used?

Thanks!

Best Regards

Cecil

-
From: "Charlie Blackham"
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Cc:
Sent: Monday February 13 2023 3:41:54AM
Subject: Re: [PSES] USB Type C requirements for the EU
Cecil

Directive (EU) 
2022/2380<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Feur-lex.europa.eu%2Feli%2Fdir%2F2022%2F2380=05%7C01%7Cted.eckert%40microsoft.com%7C520c1294eea2460f05a008db0dd2e3d9%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C638118972405759520%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=Eyw6WKa9CH4L687s3NvMWRTXyTw59JMjb9dF6MaNE%2Fk%3D=0>
 amending the RED with the "common charger" published on 7th December 2022

Applies to all products in scope placed on the market after 28 December 2024 
except for laptops, where the date is 28 April 2026

EU Directive and Regulations apply to each and every individual product, so 
there is no grandfathering for existing designs.


Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
https://sulisconsultants.com/<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fsulisconsultants.com%2F=05%7C01%7Cted.eckert%40microsoft.com%7C520c1294eea2460f05a008db0dd2e3d9%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C638118972405915750%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=aFstyadNNCndDQh3xnBolh6xSA838iechbz5bm3CD%2Fo%3D=0>
Registered in England and Wales, number 05466247

From: cgitt...@rochester.rr.com<mailto:cgitt...@rochester.rr.com> 
mailto:cgitt...@rochester.rr.com>>
Sent: 13 February 2023 01:13
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] USB Type C requirements for the EU

What is the implementation date for USB Type C that products need to comply 
with the Directive?

Is there any exemption or grandfathering for current products that are used 
already in the market?

I appreciate any input.

Thank you.

Cecil Gittens
-


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

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Re: [PSES] [EXTERNAL] Re: [PSES] USB Type C requirements for the EU

[Ted Eckert]

Hi Cecil,

The device must have a USB connector for charging. You must provide the 
customer the option of buying the product without either an external power 
supply or charging cable. The intent of the regulation is that consumers should 
be able to buy new devices that can be charged with their existing USB power 
supplies and cables.

Best regards,
Ted Eckert
Microsoft

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

From: cgitt...@rochester.rr.com 
Sent: Monday, February 13, 2023 5:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] USB Type C requirements for the EU

You don't often get email from 
cgitt...@rochester.rr.com<mailto:cgitt...@rochester.rr.com>. Learn why this is 
important<https://aka.ms/LearnAboutSenderIdentification>
Hi Charlie,

Thank you very much for your response.

Does this mean a USB Type C connector has to be on the device or can a cable 
that has USB C with let's say a magnetic connector on the device end be used?

Thanks!

Best Regards

Cecil

-
From: "Charlie Blackham"
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Cc:
Sent: Monday February 13 2023 3:41:54AM
Subject: Re: [PSES] USB Type C requirements for the EU
Cecil

Directive (EU) 
2022/2380<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Feur-lex.europa.eu%2Feli%2Fdir%2F2022%2F2380=05%7C01%7Cted.eckert%40microsoft.com%7C25ff9a3c67524bfc464008db0dc93660%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C638118930089515210%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=SKYIZyCps2zZ0GdLyE8VVeKbe4Kc%2B2P18DToU1L%2FRuE%3D=0>
 amending the RED with the "common charger" published on 7th December 2022

Applies to all products in scope placed on the market after 28 December 2024 
except for laptops, where the date is 28 April 2026

EU Directive and Regulations apply to each and every individual product, so 
there is no grandfathering for existing designs.


Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
https://sulisconsultants.com/<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fsulisconsultants.com%2F=05%7C01%7Cted.eckert%40microsoft.com%7C25ff9a3c67524bfc464008db0dc93660%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C638118930089515210%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=ikfvSk54%2Fyjuh4dEcN47u2Utc3nrN3TuNDsuVpGbupM%3D=0>
Registered in England and Wales, number 05466247

From: cgitt...@rochester.rr.com<mailto:cgitt...@rochester.rr.com> 
mailto:cgitt...@rochester.rr.com>>
Sent: 13 February 2023 01:13
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] USB Type C requirements for the EU

What is the implementation date for USB Type C that products need to comply 
with the Directive?

Is there any exemption or grandfathering for current products that are used 
already in the market?

I appreciate any input.

Thank you.

Cecil Gittens
-


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Re: [PSES] [EXTERNAL] [PSES] Testing 2 cubic foot plywood enclosure to UL 2043 Fire Test for Heat and Smoke in Air Handling Space

[Ted Eckert]

Hello Chuck,

I can't say with certainty, but it's highly unlikely that plywood would pass 
the test. I wouldn't expect any wood products to pass tests for use in air 
handling spaces.

Best regards,
Ted Eckert

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

From: Chuck August-McDowell 
Sent: Wednesday, December 21, 2022 2:57 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] Testing 2 cubic foot plywood enclosure to UL 2043 
Fire Test for Heat and Smoke in Air Handling Space

You don't often get email from 
chu...@meyersound.com<mailto:chu...@meyersound.com>. Learn why this is 
important<https://aka.ms/LearnAboutSenderIdentification>
Hi,

Happy Holiday's everyone.

I'm writing for an opinion or comment on whether a one to two cubic foot square 
box made of one-half inch thickness hardwood plywood will pass the UL 2043 Fire 
Test for Heat and Visible Smoke Release for Discrete Products and Their 
Accessories Installed in Air-Handling Spaces.

I am curious about how all-wood boxes perform or lack there-of.

Thank you,


Chuck McDowell

NOTICE: This email may contain confidential information. Please see 
https://meyersound.com/legal/#email-policy for our complete policy. -


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[PSES] Open position at Microsoft

[Ted Eckert]

There is an open position at Microsoft for a product safety engineer with 
experience in incident investigation. This position is for Redmond Washington.

More information is available at the following link.
In-Market Product Safety Incident Investigation Engineer in Redmond, 
Washington, United States | Engineering at 
Microsoft<https://careers.microsoft.com/us/en/job/1457887/In-Market-Product-Safety-Incident-Investigation-Engineer>

Regards,
Ted Eckert
Microsoft

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Re: [PSES] [EXTERNAL] [PSES] High Touch Current and GFCIs

[Ted Eckert]

Hi Brian,

Yes, it will trip. I have even worse news for you. It may trip if your touch 
current is less than 5 mA. We use the human body model for touch current 
measurement, and it's frequency limited. I had a product that was less than 1.5 
mA touch current when measured with IEC 60990 methods, but it measured 9 mA 
when measured by a meter that went up to 100 kHz frequency response. There was 
a lot of high-frequency current blocked by the touch current network. However, 
the product regularly tripped GFCIs, since GFCIs don't necessarily have a 
low-pass filter.

The Y-caps on many IT product power supplies might allow current at higher 
frequencies onto the ground which could trip GFCIs. Plug a bunch of IT products 
into the same GFCI circuit, and the risk of nuisance tripping goes up.

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

From: Brian Kunde 
Sent: Wednesday, August 24, 2022 1:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] High Touch Current and GFCIs

If I have a rake of electrical equipment with a single power cord and a 
combined touch current exceeding 6mA, and I plug the rake into a circuit with a 
GFCI, will it trip?

Thanks.

The Other Brian
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Re: [PSES] [EXTERNAL] [PSES] Safety for e-scooters, e-bikes

[Ted Eckert]

By coincidence, there was a notice in today's Federal Register that OSHA is 
extending UL's scope of recognition to add two standards.

  *   UL 2272: Standard for electrical systems and personal e-mobility devices
  *   UL 2849: Standard for electrical systems for eBikes

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

From: Douglas E Powell 
Sent: Friday, August 12, 2022 2:26 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] Safety for e-scooters, e-bikes

All,

My Friday question is about storage/charging of e-scooters and e-bikes. It 
seems that these days more and more people are using these devices and fire 
safety is a growing concern. It seems my news feed has a new instance every few 
days.  Some of these cases are very tragic outcomes, in that the owner brings 
these devices just inside the door to their apartment for overnight charging.  
Of course, if there is a lithium fire, it is rather violent and blocks the exit 
for the occupants.

I am not very familiar with which safety standards are available in North 
America and Europe, and do they have requirements to address such concerns in 
the user documentation?  I do know that some building owners are taking matters 
into their own hands and requiring these devices be charged outdoors; which may 
have varying success in mitigating building fires.  In any case, many e-scooter 
owners are probably not very keen on leaving their property where it can be 
easily stolen.

Thoughts?

-Doug

Laporte, Colorado USA
LinkedIn<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.linkedin.com%2Fin%2Fcoloradocomplianceguy%2F=05%7C01%7Cted.eckert%40microsoft.com%7Cc9e9a9f3e2954464402e08da7ca96ba4%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637959364369664940%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=CDrDKIswhEfpV%2Fmm61vNnocmmFbLkH6I5WQ0QL%2BHmrk%3D=0>

(UTC -06:00) Mountain Time (US-MDT)

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Re: [PSES] [EXTERNAL] [PSES] who regulates road trains?

[Ted Eckert]

By a strange coincidence, a coworker forwarded this article to me this morning 
covering the same subject. It has more information on the amusement park ride 
registration system.
Standard Issue Fun - The 
Prepared<https://theprepared.org/features-feed/astm?utm_source=newsletter_medium=email_campaign=2022-07-28_cid=24769ac393_eid=9a28cbc6c6>

Best regards,
Ted Eckert

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


From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@listserv.ieee.org>
Sent: Thursday, July 28, 2022 6:22 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] [PSES] who regulates road trains?

Hi Gary,

I can only speak of requirements in the United States. I believe these fall 
under the requirements for amusement park rides. ASTM F24 has the standards, 
with subcommittee F24.60 possibly handling these types of rides.
F24.60 Jurisdiction Page 
(astm.org)<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.astm.org%2Fget-involved%2Ftechnical-committees%2Fcommittee-f24%2Fsubcommittee-f24%2Fjurisdiction-f2460=05%7C01%7Cted.eckert%40microsoft.com%7C93469490ed414eb7c55b08da709c3da3%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637946113604295721%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=PS2ZP2EPTEirTomYEan92hByT%2Fj9DNtRefbgtDANhEY%3D=0>

Inspections and requirements for rides at amusement parks and fairs is usually 
governed at the state level in the United States. Inspection regimes can vary 
significantly from location to location. There was an infamous amusement park 
in New Jersey named Action Park that was involved in so much litigation that it 
got the nickname "Class Action Park".
Action Park - 
Wikipedia<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fen.wikipedia.org%2Fwiki%2FAction_Park=05%7C01%7Cted.eckert%40microsoft.com%7C93469490ed414eb7c55b08da709c3da3%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637946113604451989%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=%2BNHCw7fODd%2Bq18LWr9J9jrcN8oX5A7e0LjZyhUoT59Y%3D=0>

Best regards,
Ted Eckert

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


From: Gary Tornquist <05big...@gmail.com<mailto:05big...@gmail.com>>
Sent: Wednesday, July 27, 2022 9:53 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [EXTERNAL] [PSES] who regulates road trains?


Hi All,
Kind of off-the wall question, but would you know who regulates road trains?

These are wheeled vehicles with one typically battery powered engine in the 
front pulling several passenger coaches behind.  These slow vehicles typically 
operate in controlled environments such as zoos, amusement parks and resorts to 
get people short distances.
Not for public roads as far as I can tell.

See an example here:
https://www.tdiproductionsolutions.com/portfolio/delga/<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.tdiproductionsolutions.com%2Fportfolio%2Fdelga%2F=05%7C01%7Cted.eckert%40microsoft.com%7C93469490ed414eb7c55b08da709c3da3%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637946113604451989%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=NqS%2Bue%2BoBIvVTz5FvkKBWZomBsm6t0P%2FaHX9p2cIsKY%3D=0>

So would they fall under the Department of Transportation?  OSHA?  Or something 
else?

Cheers,
Gary Tornquist
Product Safety Consultants
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Re: [PSES] [EXTERNAL] [PSES] who regulates road trains?

[Ted Eckert]

Hi Gary,

I can only speak of requirements in the United States. I believe these fall 
under the requirements for amusement park rides. ASTM F24 has the standards, 
with subcommittee F24.60 possibly handling these types of rides.
F24.60 Jurisdiction Page 
(astm.org)<https://www.astm.org/get-involved/technical-committees/committee-f24/subcommittee-f24/jurisdiction-f2460>

Inspections and requirements for rides at amusement parks and fairs is usually 
governed at the state level in the United States. Inspection regimes can vary 
significantly from location to location. There was an infamous amusement park 
in New Jersey named Action Park that was involved in so much litigation that it 
got the nickname "Class Action Park".
Action Park - Wikipedia<https://en.wikipedia.org/wiki/Action_Park>

Best regards,
Ted Eckert

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


From: Gary Tornquist <05big...@gmail.com>
Sent: Wednesday, July 27, 2022 9:53 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] who regulates road trains?


Hi All,
Kind of off-the wall question, but would you know who regulates road trains?

These are wheeled vehicles with one typically battery powered engine in the 
front pulling several passenger coaches behind.  These slow vehicles typically 
operate in controlled environments such as zoos, amusement parks and resorts to 
get people short distances.
Not for public roads as far as I can tell.

See an example here:
https://www.tdiproductionsolutions.com/portfolio/delga/<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.tdiproductionsolutions.com%2Fportfolio%2Fdelga%2F=05%7C01%7Cted.eckert%40microsoft.com%7C8bda77ecd263463a7def08da70551bb2%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637945809148177364%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=Zh0wM5Xh%2BFJzP2U82jDNObdM6gbgY9l96Qk1jkbovoo%3D=0>

So would they fall under the Department of Transportation?  OSHA?  Or something 
else?

Cheers,
Gary Tornquist
Product Safety Consultants
-


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[PSES] Safety Engineer - Open Position at Microsoft

[Ted Eckert]

Microsoft has an open position for a product safety engineer at our Redmond 
Washington location.
(2) Product Safety Engineer | Microsoft | 
LinkedIn<https://www.linkedin.com/jobs/view/2968436141/>

Ted Eckert
Principal Safety & Energy Engineer
Microsoft


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[PSES] Product Safety opening at Microsoft

[Ted Eckert]

There is an open position for a product safety engineer at Microsoft. More 
information is here.
Product Safety Engineer in Redmond, Washington, United States | Hardware 
Engineering at 
Microsoft<https://careers.microsoft.com/us/en/job/1298678/Product-Safety-Engineer>

Regards,
Ted Eckert
Microsoft

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Re: [PSES] [EXTERNAL] [PSES] IP Code Question

[Ted Eckert]

Hi Brian,

It is reasonable to state that an IP22 device is not intended for outdoor use 
or where exposed to water. A much higher IP rating would be required for 
reliable operation outdoors, and most people who purchase outdoor equipment 
would not accept a product with only an IP22 rating.

Ted Eckert
The opinions expressed are my own and do not necessarily represent those of my 
employer.

From: Brian Kunde 
Sent: Monday, February 14, 2022 6:23 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] IP Code Question

An IP code of IPx2 implies the enclosure protects against the ingress of water 
drops at 15° tilt.  Now, most PC enclosures protect the electronics from 
occasional exposure to water drops, but it is not designed to be exposed to 
water drops continuously.  So can you rate an electronic device IP22, for 
instance, but not intend it to be used outside or in an environment where it is 
exposed to water on a regular basis?

Thanks for your input.
The Other Brian
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Re: [PSES] [EXTERNAL] [PSES] Magnets as reliable fasteners

[Ted Eckert]

Hi Gary,

I have a consideration a bit different from what Doug and Mark have discussed. 
My concern is that magnets inside of an electrical panel could attract foreign 
objects. Loose screws, bolts or other hardware could be attracted to the 
magnets resulting in reduced clearances, or in the worst case, a short circuit. 
They could create a challenge for maintenance on the panels as extra care would 
be needed. I can even foresee service personnel shutting off the panel for 
maintenance and using the magnets as an impromptu tool holder. If they forget 
that a tool is held in place, there could be an electrical incident when the 
panel is reenergized.

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

From: Gary Tornquist <05big...@gmail.com>
Sent: Tuesday, February 8, 2022 6:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] Magnets as reliable fasteners

Hello experts,
Can magnets be used to fasten line voltage assemblies to the inside of an 
electrical panel?
To restate my concerns, if strong enough could they be considered to reliably 
maintain creepage and clearance distances, as well as not overstressing wires 
terminating at the assembly?
And how strong is strong enough?  Test T2 calls for pushing on parts in the 
most unfavorable direction with 10 newtons of force for 5 seconds - is this an 
appropriate test?

The application is in stationary equipment that does not include motors, so 
vibration should not be a concern.

I welcome advice - this is the first time I've seen such proposed construction 
and I don't know a standard such as 62368 to mention it.

Cheers,
Gary Tornquist
Product Safety Consultants
Opinions expressed are my own, not of my employer or client
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Re: [PSES] [EXTERNAL] [PSES] Nyloc Nuts

[Ted Eckert]

Hello Chris,

Some reviewers might reject the construction without a lock washer for a 
different reason. A split or star-tooth lock washer will cut through paint, 
oxidation, or coatings on a surface giving additional bonding contact. I've had 
reviewers who didn't trust the bonding connection through the threads of the 
nut and stud and insisted of a backup through the mating surface of the base of 
the nut. Please note that I'm not saying that this is the correct 
interpretation. It's only one that I've run into.

I can also imagine objections due to the force needed to put a nyloc nut on in 
the first place. An inexperienced person might not fully tighten the nut as it 
will provide more resistance to tightening as it is screwed further onto the 
stud. I can see it being easier to have the nut not fully tightened as a result.

Again, I'm not stating that these are reasons the construction will get 
rejected. They are just possible objections of a reviewer.

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

From: Chris Wordley 
Sent: Monday, November 15, 2021 6:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] Nyloc Nuts

Hello

We sometimes come across products that employ a Nyloc nut as the sole means of 
securing (preventing accidental loosening of) a protective earth connection on 
a threaded stud.

I've heard various views on the acceptability of this type of construction - 
some consider it OK provided the temperature is not high enough to cause the 
nylon insert to soften, others think that a separate spring/serrated washer is 
required since the nylon cannot be depended on in the longer term.

I'd be interested to hear the views of others, particularly any CB or similar 
labs. I failed to uncover any IECEE decisions on this subject.

Best Regards

Chris
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Re: [PSES] UL 510 Flame retardant tape

[Ted Eckert]

Hi Charlie,

IEC TR 62368-2 doesn't provide much guidance on clause M.4.3 other than that 
lithium batteries should be considered Potential Ignition Sources.

In general, a polymeric fire enclosure isn't necessarily going to contain a 
fire. V-1 and V-0 materials will burn through, and the standard does not 
require 5-VA to completely contain a flame. However, the enclosure can slow the 
propagation of a fire. For many smaller lithium-ion batteries, a fire enclosure 
will contain the fire long enough for much of the energy to be released, 
reducing the risk that the fire will spread to flammable materials outside of 
the enclosure. A user holding or wearing a device with a lithium battery will 
likely have time to react and separate themselves from the device should the 
battery fail exothermically.

I can't state whether a thin film or tape would be suitable. I can only suggest 
a risk analysis.

Best regards,
Ted Eckert
The opinions expressed are my own and do not necessarily reflect those of my 
employer or TC 108.

From: Charlie Blackham 
Sent: Sunday, October 10, 2021 8:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] UL 510 Flame retardant tape

Rich, Ted, All

The product has an outer enclosure that provides suitable mechanical strength 
and the battery is IEC62133 compliant charged and discharged via a suitable chip

There's a product requirement for a yellow enclosure, and we can't find a 
suitable yellow plastic with enough fire retardancy.

The issue is that Clause M.4.3 mandates a fire enclosure and it's never clear 
(to me anyway) whether some batteries actually have their own fire enclosure as 
I don't see this listed anywhere, and you might get for Conditions of 
Acceptability for a Recognised Component PSU.

If a LiIon battery really does "cook off" I'm not sure what enclosure would 
actually contain it - I guess it might be as much about whether the enclosure 
provides more fuel, but I'm not sure as to the intent of the clause in the 
standard

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
https://sulisconsultants.com/<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fsulisconsultants.com%2F=04%7C01%7Cted.eckert%40microsoft.com%7C4596811e7f144457823a08d98bfef963%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637694750432063193%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000=Hs9DP3uv4zELUqMFw3o9n1v1G8bx3IebCAW2VpQby1Y%3D=0>
Registered in England and Wales, number 05466247

From: Richard Nute mailto:ri...@ieee.org>>
Sent: 08 October 2021 22:42
To: Charlie Blackham 
mailto:char...@sulisconsultants.com>>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] UL 510 Flame retardant tape


Hi Charlie:

Rather than guess:

https://www.kaptontape.com/PDF/Kapton_Films_Datasheet.pdf<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.kaptontape.com%2FPDF%2FKapton_Films_Datasheet.pdf=04%7C01%7Cted.eckert%40microsoft.com%7C4596811e7f144457823a08d98bfef963%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637694750432073186%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000=s2aNcZKd39Cu4OC2mi41q4S5lys3s%2Fpztnwit8B1RTA%3D=0>
https://www.dupont.com/content/dam/dupont/amer/us/en/products/ei-transformation/documents/DEC-Kapton-HN-datasheet.pdf<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.dupont.com%2Fcontent%2Fdam%2Fdupont%2Famer%2Fus%2Fen%2Fproducts%2Fei-transformation%2Fdocuments%2FDEC-Kapton-HN-datasheet.pdf=04%7C01%7Cted.eckert%40microsoft.com%7C4596811e7f144457823a08d98bfef963%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637694750432073186%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000=vuMMQdJ7kFIOxwXI3rp3BclV1eQYe2Pk0gtLpMdhvCU%3D=0>
https://www.dupont.com/content/dam/dupont/amer/us/en/products/ei-transformation/documents/EI-10167-Kapton-General-Specifications.pdf<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.dupont.com%2Fcontent%2Fdam%2Fdupont%2Famer%2Fus%2Fen%2Fproducts%2Fei-transformation%2Fdocuments%2FEI-10167-Kapton-General-Specifications.pdf=04%7C01%7Cted.eckert%40microsoft.com%7C4596811e7f144457823a08d98bfef963%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637694750432083178%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000=%2FujrQWLQsG%2BYLGZ9G7yj9Saf1wTMaD6F24zvDgUftjw%3D=0>

After looking at the above specs, I'm inclined to believe that Kapton tape will 
provide an acceptable fire enclosure (as good as any other plastic material).  
It is tough stuff!  And relatively expensive.

If you are going to test it (as suggested by Ted), I suggest a side-by-side 
test with the alternate fire enclosure plastic material.

Note that IEC 62368-1 uses IEC 60695-11-10 for flammability rating r

Re: [PSES] UL 510 Flame retardant tape

[Ted Eckert]

Hello Charlie,

I apologize for not answering your question directly, but I would like to 
respond based on the general intent. Kapton tape is flame resistant, but I 
recommend that you take samples and apply a flame to see how it reacts. My 
personal opinion is that Kapton tape won't contribute fuel to a fire, but it 
isn't likely to contain it either. Thin film material might not be suitable if 
the intent is to slow the progression of a fire to keep it from reaching other 
flammable material.

Consider fabricating the proposed tape enclosure on a few sample batteries and 
intentionally fault them to induce an exothermic reaction. The results may give 
an indication whether you want to pursue this path further.

Best regards,
Ted Eckert

The opinions expressed are my own and do not necessarily reflect those of my 
employer or TC 108.

From: Charlie Blackham 
Sent: Friday, October 8, 2021 6:25 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] UL 510 Flame retardant tape

All

Various Kapton tapes are sold as Flame Retardant, some seem to reference UL 94 
and others UL 510.

The scenario is a product falling under EN 62368-1 and the secondary lithium 
battery needs a fire enclosure and rather than using the product enclosure, one 
could be made for the battery using a suitable plastic or manual application of 
retardant tape.

Is there any correlation between UL 510 and UL94 when considering creating a 
Fire Enclosure for a battery as per Clause M.4.3 ?



Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Mead House
Longwater Road
Eversley
RG27 0NW
UK
Tel: +44 (0)7946 624317
Email: char...@sulisconsultants.com<mailto:char...@sulisconsultants.com>
Web: 
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Registered in England and Wales, number 05466247

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Re: [PSES] Additional AC power cords in the same shipment

[Ted Eckert]

Hello Gary,

My previous employer had a number of products that had low-volume production, 
and where it was cheaper to include multiple cords rather than to create 
multiple regional SKUs. There were generally no issues with including multiple 
cords as long as each cord was clearly marked with the country/region it was 
intended for. This could be done with a tag on the cord or by placing the cord 
in a clearly marked bag. The instructions provided with the product also 
provided detailed information on which cord was to be used for each region.

This method generally gets expensive as your countries of sale increase. As 
others have noted, there are a lot of different plug configurations, many of 
which may appear physically compatible, but are not considered compatible by 
local regulatory authorities.

Best regards,
Ted Eckert
The opinions expressed are my own and do not necessarily reflect those of my 
employer.

From: Greg McClure 
Sent: Wednesday, October 6, 2021 5:37 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] Additional AC power cords in the same shipment

In our experience:

Argentina, Australia and China (PRC) cords are mutually exclusive and cannot be 
bundled together.

Brazil no longer accepts any cord that looks like a US NEMA 5-15 plug.

India and South Africa cords are mutually exclusive unless you can get one that 
carries certifications for both countries.

Japan, Taiwan and the US are mutually exclusive due to different certification 
requirements for the plugs and cordage.

There may be ways around some of these but they tend to drive up the cost of 
the cordset.


Gregory H. McClure
Lexmark Product Safety
Product Safety Team Lead
859-232-3240 office

From: Gary Tornquist <05big...@gmail.com<mailto:05big...@gmail.com>>
Sent: Wednesday, October 6, 2021 1:38 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Additional AC power cords in the same shipment

Hi All,
I would like to get your experience and opinions on including 'extra' ac power 
cord in shipments of IT equipment.  To minimize the number of SKU's that need 
to be maintained in the supply chain it can be useful to include AC power cords 
suitable and certified for multiple different countries in the same box.  The 
intent is that the customer uses the cord appropriate to his country and 
disposes of the rest.  Customs of some countries may object, but others are OK 
with this practice.

Do you know of countries where this is OK?  And others where is isn't?

Cheers,

Gary Tornquist
Sr. Consultant

Your Outsourced Compliance Department

[DD1479DB]
1618 236th Ave NE
Sammamish, WA 98074
(425) 279-3996
http://www.productsafetyinc.com<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.productsafetyinc.com%2F=04%7C01%7Cted.eckert%40microsoft.com%7Cad153d55d4644ba5366908d988c60b0e%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637691206461943395%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000=rEJeuxfDSOcMLQC1hWFgMBBjIM1pI6W1dyzC3zGx8Y4%3D=0>


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Re: [PSES] [EXTERNAL] Re: [PSES] Suitable Test equipment for Touch temperature Testing in accordance with EN 62368-1

[Ted Eckert]

Hi Philip,

I would like to see progress towards the acceptance of infrared thermography 
for certification. However, I can see some potential issues.

  *   I haven't seen software for many IR cameras that does good data logging. 
I work on some products that have cyclical temperature changes. There are 
situations where I need to see a graph of touch temperature over time before I 
can make an assessment, particularly when I'm just trying to determine if 
temperatures have stabilized.
  *   I don't know how well IR thermography will work when there are different 
materials. I have a product that has metal, plastic, fabric and glass in close 
proximity. I believe that the variety of materials might increase the 
uncertainty of measurement for an IR camera. This isn't an issue if taken into 
account, but it might be a challenge where touch temperatures are close to the 
limit.
  *   It's becoming more common to find IR camera calibration services, but 
"more common" doesn't mean cheap or easy.

I think the technology has reached a point where IR cameras could be used for 
testing, but I would want to see internationally accepted procedures before I 
would consider it. I'm sure that there are experts in the field who could help. 
I use IR cameras to find hot spots for my testing, and they have been 
invaluable, particularly where the hottest points change depending on the mode 
of operation.

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

From: Philip Stevenson 
Sent: Wednesday, September 22, 2021 10:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] Suitable Test equipment for Touch temperature 
Testing in accordance with EN 62368-1

Thank Rich for your reply. That is my view as well. I use thermocouples for 
temperature rise measurements.

Regards

Philip Stevenson

Sent from Mail<https://go.microsoft.com/fwlink/?LinkId=550986> for Windows

From: Richard Nute<mailto:ri...@ieee.org>
Sent: 22 September 2021 17:57
To: 'Philip Stevenson'<mailto:pw...@hotmail.co.uk>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] Suitable Test equipment for Touch temperature Testing in 
accordance with EN 62368-1



Hi Phillip:

As far as I know, 62368-1 does not specify the method for measuring touch 
temperatures.  Be aware that certification houses usually measure touch (and 
all other) temperatures with a thermocouple.

Stay safe, and best regards,
Rich


From: Philip Stevenson mailto:pw...@hotmail.co.uk>>
Sent: Wednesday, September 22, 2021 7:42 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Suitable Test equipment for Touch temperature Testing in 
accordance with EN 62368-1

Dear List Members

I am looking for advice of whether the use of an Infra Red (IR) Digital 
Thermometer is suitable for performing Touch temperature Testing in accordance 
with EN 62368-1. Provided that factors for the different surface materials are 
applied to the temperature measurements?

If you prefer to reply to me directly instead of vis the listing please do so 
at pw...@hotmail.co.uk<mailto:pw...@hotmail.co.uk>.

Thanks in advance for your help.

Regards

Philip Stevenson



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

[Ted Eckert]

Hello Matthew,

I believe you are looking for NEMA WD-6.
Wiring Devices—Dimensional Specifications 
(nema.org)<https://www.nema.org/Standards/view/Wiring-Devices-Dimensional-Specifications>

Best regards,
Ted Eckert
The opinions expressed are my own and do not necessarily reflect those of my 
employer.

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

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

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

Thanks for any help, much appreciated.

[cid:image003.png@01D7A3B2.8858B4E0][cid:image002.png@01D7A3B2.88418360]
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Re: [PSES] [EXTERNAL] [PSES] Over Reliance on Automated Safety Controls (Friday question)

[Ted Eckert]

Hi Doug,

Let me ask your question a different way. Haven't humans always used technology 
to provide some level of safety that allows us to use or time and mental 
capacity for other tasks?

Millenia ago, hunter-gatherer groups had many things to be fearful of. 
Surviving the night might require keeping a fire going to stay warm in the 
winter. It might require having somebody stay up to keep an eye open for wild 
animals or other groups of humans who might be hostile. We might not think of 
the solutions to these problems as technology, but they were. As we built 
cities with walls and homes with more efficient heating systems, we stopped 
worrying about these issues.

Medical technology has made us safer and allowed us to stop thinking about many 
health issues that used to be more common. Food-safety technology has improved, 
and we don't need to spend as much time thinking about curing and preserving 
foods to make them safe for consumption. In both cases, a failure of the safety 
system has dramatic results. How often do we hear of a case of contaminated 
food leading to a salmonella or e-coli outbreak?

I live my life without thinking about issues that my ancestors from 200, 1000 
or 10,000 years ago had to be concerned with. The safety issues aren't gone, 
they are just managed by the technology of modern life. I recognize that I am 
complacent, but I'll let technology free me to think of other things.

For reference, I live at the urban-wilderness interface. Running into large 
animals is a possibility in my neighborhood. It's common enough that we have to 
have rules about garbage cans to reduce interaction with bears.
Bears Like Our Garbage! - Issaquah 
Highlands<https://www.issaquahhighlands.com/bears-like-our-garbage/>

Ted Eckert
The opinions expressed are my own and do not necessarily represent those of my 
employer, humanity in general, or the large carnivores of western Washington.


From: Douglas E Powell 
Sent: Friday, September 3, 2021 7:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] Over Reliance on Automated Safety Controls (Friday 
question)

All,

My question is probably philosophical.

With the advent of Safety rated PLCs, Safety Relays, and other solid state and 
programmable safety devices in certified and listed products, are we at risk of 
becoming over reliant on automated safety systems. I'm thinking in terms of IEC 
61508, ISO 12100, UL 1998, UL 991, and many others. While I agree that use of 
programmable devices for safety control is in our future, it seems we, as a 
society, are putting a lot of reliance in this. It is well known that zero risk 
is impossible, but it also seems that "people these days" routinely ignore the 
risks, and it is my view that humans have a very bad history of correctly 
estimating risk out in the wild. It's not my intention to pick on autonomous 
vehicles only, since I've seen this sort of care-less behavior played out in 
other places as well.

Some keywords I have in mind:

  *   Automation Dependency
  *   Automation Bias
  *   Automation Induced Complacency
In general, do you feel we are becoming a society that relies too much on 
technology and automation to keep us safe from harm? I'm looking for an open 
discussion on this and what do you feel will be in store for us in the future.

-Doug


Douglas E Powell
Laporte, Colorado USA
doug...@gmail.com<mailto:doug...@gmail.com>
http://www.linkedin.com/in/dougp01
<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.linkedin.com%2Fin%2Fdougp01=04%7C01%7Cted.eckert%40microsoft.com%7C49fe9945d84e4b210fee08d96ee34d5a%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637662744821901045%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000=elTTbeQDBWK8wL5Pi1cIRAHBfQ4DYgi1AXPRITvYfJ8%3D=0>
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Re: [PSES] [EXTERNAL] [PSES] Touch temperature limits for accessible parts

[Ted Eckert]

Hello Scott,

IEC 62368-1 clause 3.3.7.4 defines "normal operating condition" as the "mode of 
operation that represents as closely as possible the range of normal use that 
can be reasonably expected". It specifies the range of possible uses, not the 
"typical" use. Note 1 for the clause makes it clear that the most unfavorable 
default conditions must be considered for normal use.

If your charger is permanently connected to the device that it is charging, is 
it possible to load the device such that it continuously draws the maximum 
power from the charger? If the charger has a connector, allowing different 
loads to be connected, could the user charge a series of devices, one after the 
other, keeping the charger at maximum power for an extended time? "Normal" does 
not mean "likely" or "common". "Normal" is what is allowed and foreseeable.

In the United States, a number of mountain and southwestern states have freeway 
speed limits up to 80 miles per hour. The vast majority of cars in the United 
States will never travel at 80 mph for extended periods. If you did a survey, I 
would expect you to find that, on average, the typical American car spends less 
than 0.1% of the time at 80 mph. However, travelling continuously at that speed 
is allowed and possible, and a small subset of drivers will drive at that speed 
regularly. It's neither typical nor common, but it is "normal" and must be 
considered a normal condition.

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

From: Scott Xe 
Sent: Thursday, September 2, 2021 8:02 AM
To: Ted Eckert 
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [EXTERNAL] [PSES] Touch temperature limits for accessible parts

Dear Ted,

Many thanks for your good considerations!  I need to re-assess this issue 
inclusive of those conditions.  I have one conflicted point about the touch 
temperature of 80 degC which is at full load.  As you may know it, the full 
load may happen at the initial charging and the charging current will gradually 
decrease.  In general, it may not be so hot in normal conditions.  What is your 
view on this?

Kindest regards,

Scott

On Thu, 2 Sept 2021 at 21:43, Ted Eckert 
mailto:ted.eck...@microsoft.com>> wrote:
Hello Scott,

Touch temperatures are measured at an ambient of 25 C. However, there are a 
number of additional considerations.

  *   What are normal operating conditions? Is it true that the user would 
never touch the charger while it is in operation? There is no chance that they 
would try to disconnected it from the car's socket while it is at maximum 
temperature?
  *   If the user could disconnect it, how long do they need to hold it to pull 
it out of the car's socket? Consider all users. For example, somebody with 
arthritis and a poor grip might need more time to disconnect the charger.
  *   Think about how TS2 limits apply to touch temperatures. What are the 
abnormal and fault conditions?
  *   Even if the standard would only require testing at 25 C, you need to 
consider that a car charger will be used at much higher ambient temperatures. 
Have you done a hazard analysis based on the specific use of this device?
  *   Will elevated temperatures on the charger result in customer complaints? 
If the charger gets very hot, will it be perceived as unsafe?

Ted Eckert
The opinions expressed are my own and do not necessarily reflect those of my 
employer, TC 108 or the Society of Automotive Engineers.

From: Scott Xe mailto:scott...@gmail.com>>
Sent: Thursday, September 2, 2021 6:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [EXTERNAL] [PSES] Touch temperature limits for accessible parts

I am looking for advice on temp measurements and the requirements. I have an 
in-car charger with a temp of 80 degC on external plastic enclosure at max 
load.  Referring to EN 62368-1, the max temp is from 48 - 94 degC depending on 
the time to be touched to operate the equipment.  During operation, it is 
unnecessary to touch the external enclosure except plugging in and taking out 
from cigarette socket.  Is it deemed to apply 94 degC?

Should the max temp be measured at room temp of 25 degC or the maximum 
operating temp?  If at max operating temp, how to derive the max temp limits in 
such conditions?

Thanks and regards,

Scott
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Re: [PSES] [EXTERNAL] [PSES] Touch temperature limits for accessible parts

[Ted Eckert]

Hello Scott,

Touch temperatures are measured at an ambient of 25 C. However, there are a 
number of additional considerations.

  *   What are normal operating conditions? Is it true that the user would 
never touch the charger while it is in operation? There is no chance that they 
would try to disconnected it from the car's socket while it is at maximum 
temperature?
  *   If the user could disconnect it, how long do they need to hold it to pull 
it out of the car's socket? Consider all users. For example, somebody with 
arthritis and a poor grip might need more time to disconnect the charger.
  *   Think about how TS2 limits apply to touch temperatures. What are the 
abnormal and fault conditions?
  *   Even if the standard would only require testing at 25 C, you need to 
consider that a car charger will be used at much higher ambient temperatures. 
Have you done a hazard analysis based on the specific use of this device?
  *   Will elevated temperatures on the charger result in customer complaints? 
If the charger gets very hot, will it be perceived as unsafe?

Ted Eckert
The opinions expressed are my own and do not necessarily reflect those of my 
employer, TC 108 or the Society of Automotive Engineers.

From: Scott Xe 
Sent: Thursday, September 2, 2021 6:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] Touch temperature limits for accessible parts

I am looking for advice on temp measurements and the requirements. I have an 
in-car charger with a temp of 80 degC on external plastic enclosure at max 
load.  Referring to EN 62368-1, the max temp is from 48 - 94 degC depending on 
the time to be touched to operate the equipment.  During operation, it is 
unnecessary to touch the external enclosure except plugging in and taking out 
from cigarette socket.  Is it deemed to apply 94 degC?

Should the max temp be measured at room temp of 25 degC or the maximum 
operating temp?  If at max operating temp, how to derive the max temp limits in 
such conditions?

Thanks and regards,

Scott
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--

[PSES] Safety Engineer position at Microsoft

[Ted Eckert]

There is an open position for a product safety engineer in Microsoft's Mixed 
Reality group, located in Redmond.

https://careers.microsoft.com/us/en/job/1105262/Senior-Product-Safety-Engineer-Mixed-Reality
https://www.linkedin.com/jobs/view/2649150232<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.linkedin.com%2Fjobs%2Fview%2F2649150232=04%7C01%7CTed.Eckert%40microsoft.com%7C3bdb6bbc01f84d6c2e3c08d94df35c8d%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637626529892843633%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000=LCvP1%2Fnzdj4juOHOfG7cL7NcgJgkjB83mPPobYBIWKc%3D=0>

The links provide more information for applying if you are interested.

Regards,
Ted Eckert
Microsoft

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Re: [PSES] test lab for 140 MPH wind testing

[Ted Eckert]

Hi Charlie,

You might find a lab on this list.
Testing Laboratories for Wind Load Resistance and Windborne Debris Resistance 
(texas.gov)<https://www.tdi.texas.gov/wind/testlabs.html>

Ted Eckert
Microsoft Corporation

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



From: Charlie Blackham 
Sent: Tuesday, April 20, 2021 7:55 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] test lab for 140 MPH wind testing

All

I'm looking for a laboratory who can test a 1m x 1m basestation antenna for 
resilience to hurricane wind gusts

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Mead House
Longwater Road
Eversley
RG27 0NW
UK
Tel: +44 (0)7946 624317
Email: char...@sulisconsultants.com<mailto:char...@sulisconsultants.com>
Web: 
https://sulisconsultants.com/<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fsulisconsultants.com%2F=04%7C01%7Cted.eckert%40microsoft.com%7Cd44894749f6c41b6135d08d9040c5253%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637545273992920881%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000=spm299cen18GfXylTQ2nVqyhPDteVPuT%2FCWpqI%2FvsvA%3D=0>
Registered in England and Wales, number 05466247

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Re: [PSES] Question on 12V accessory outlet and IEC 62368-1

[Ted Eckert]

Hello David,

IEC 62368-1 bases flame ratings on a number of factors. One of them is the 
available power. Each circuit is rated by the available power under worst-case 
conditions. A power source that can supply no more than 15 W under those 
conditions is PS1. Between 15 - 100 W is PS2 and over 100 W is PS3. This is a 
simplification, but it gives the general idea. The requirement for the flame 
rated plastics is based on the lighter outlet being PS2 or higher.

Again, this is a bit of a simplification, but a PS1 circuit is considered low 
enough energy that a fault isn't likely to cause ignition. A PS2 circuit has 
enough energy to cause ignition of flammable materials, but not so high of 
energy that it could cause a significant fire. A PS3 circuit is considered to 
be capable of igniting and sustaining a larger fire and it has stricter 
requirements for flammability of materials and fire enclosure design.

We can even look at it in a historical perspective. Few cars now ship with a 
cigarette lighter. The outlet is just an auxiliary 12 V power port. However, it 
was originally designed as a cigarette lighter, so it needs to provide enough 
power to heat the lighter to the point where it will cause ignition of the 
cigarette. Based on that, it should be obvious that there is enough power to 
cause ignition.

Ted Eckert
The opinions expressed are my own and do not necessarily reflect those of my 
employer or TC 108.

From: David Huff 
Sent: Monday, March 15, 2021 2:35 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] Question on 12V accessory outlet and IEC 62368-1

All,
I am working on a charging device which will be plugged into a 12V accessory 
outlet (cigarette lighter outlet)  I am trying to get it qualified to 
IEC62368-1:2018.  (the device it charges is falling under IEC62368-1)

The reviewer is insisting that my cigarette lighter plug must be UL94 flame 
rated to V1.  Most of the cables I see out there are HB rated, and VW-1 cords.  
This IEC standard is new to me, but appears more geared to devices with higher 
voltage cords than a 12V DC source.  Am I missing something, or is it overkill 
for that high of a flame rating for a 12V device?  Any supporting documents or 
ideas are welcome here.

I am also finding most companies have no idea of the flame rating of components 
like these items.

Thanks,
David
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Re: [PSES] [EXTERNAL] [PSES] Australia safety standard for consumer-grade AC mains surge protectors

[Ted Eckert]

Hi Joe,

I used to work for APC/Schneider Electric. I went to their Australian site and 
they have downloadable certificates for their surge strips.
Downloads for SurgeArrest Essential | Schneider Electric 
(apc.com)<https://www.apc.com/au/en/download/range/61874-SurgeArrest+Essential/doc-group-type/10592551894-Agencies+Approvals/?appSource=APC>
The only safety certificate shows AS/NZS 3112:2011+A1,A2; AS/NZS 3122:2005.

Regards,
Ted Eckert

The opinions expressed are my own and do not necessarily reflect the views of 
my employer or APC/Schneider Electric

From: Joe Randolph 
Sent: Friday, January 22, 2021 6:42 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] Australia safety standard for consumer-grade AC 
mains surge protectors

I am looking into consumer-grade "surge protectors" for use on the AC mains, 
such as modules that plug directly into an ordinary AC mains outlet, or 
so-called "power strips" or "power boards" that contain some form of surge 
protection.

In the USA, the applicable safety standard for such devices is UL 1449.

I have not been able to identify the applicable safety standard for such 
devices in Australia.  Does anyone know what the applicable safety standard is 
for Australia?  My efforts to use a web search have led only to frustration, 
with a lot of links to standards that are not relevant.

What I'm trying to determine is what safety standards (if any) a manufacturer 
of such devices must have their product comply with.  And, what is the 
traceability path from the product label to the standard that the product 
complies with.


Thanks,

Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848 (USA)
j...@randolph-telecom.com<mailto:j...@randolph-telecom.com>
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Re: [PSES] [EXTERNAL] Re: [PSES] Will there be an IEC electrical safety standard for E-cigarettes?

[Ted Eckert]

Hello Joe,

The EU sees electronic cigarettes as a nicotine delivery devices, and thus a 
medical product. There are limits to the amount of nicotine that can be 
delivered by the devices. This approach means that the devices on the market in 
the EU are quite different from what you see in the United States. In the EU, 
you will find electronic cigarettes most commonly used for a replacement for 
smoking. The U.S. took a different approach and the market has more vaping 
devices. It doesn't take as much energy to deliver the low doses of nicotine 
allowed in the EU and smaller batteries can be used. It's more common to find 
vaping devices in the U.S. with larger batteries.

Electronic cigarettes | Santé publique 
(europa.eu)<https://ec.europa.eu/health/tobacco/ecigarettes_fr>
Update on European Regulation, Electronic Cigarettes | BSI America 
(bsigroup.com)<https://www.bsigroup.com/en-US/medical-devices/News-center/E-updates/2016-Enews/Update-on-European-Regulation-Electronic-Cigarettes/>

The following podcast has some information on the difference in approaches 
starting at 28 minutes.
The Truth About the Vaping Crisis (Ep. 398) - Freakonomics 
Freakonomics<https://freakonomics.com/podcast/vaping-nicotine/>

Ted Eckert
Microsoft Corporation

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


From: Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org>
Sent: Thursday, December 10, 2020 11:32 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] Will there be an IEC electrical safety standard 
for E-cigarettes?

Joe,

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

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

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

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

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

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 1067
Albany, ORe  97321-0413

503/452-1201

IEEE Life Fellow
IEEE PSES 2020 Distinguished Lecturer
p.perk...@ieee.org<mailto:p.perk...@ieee.org>

Entropy ain't what it used to be

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

Hello All:

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

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

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

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


Thanks,

Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848 (USA)
j...@randolph-telecom.com<mailto:j...@randolph-telecom.com>
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Re: [PSES] [EXTERNAL] Re: [PSES] Electric Current Abroad

[Ted Eckert]

As John noted, some are a “bit different”. For example, you will occasionally 
find Scott transformers<https://en.wikipedia.org/wiki/Scott-T_transformer> in 
Japan. Then there is Brazil where you could find practically anything. 
Single-phase could be 110 V, 120 V, 127 V, 220 V or 230 V. It can vary within 
different locations in a city.

Ted Eckert
Microsoft Corporation

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



From: John E Allen <09cc677f395b-dmarc-requ...@listserv.ieee.org>
Sent: Wednesday, October 28, 2020 3:00 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] Electric Current Abroad

That worldstandards  list is, in reality, inaccurate w.r.t. the 3-phase 
voltages in the UK, and in countries where UK design practice prevails, where 
the “real world” 3-phase (STAR/WYE config) was/is around  415V (even  though 
the UK now “conforms” to the long-ago EU agreed level of 380V  because 380V 
+10% is 418V - i.e. = 415V, or “near enough”).  In reality that means the 
1-phase voltage is around 240-245V (recently measured 243V upstairs in this 
house).

Thus one should take that list with the proverbial “pinch of salt” as the “real 
world” voltages in some countries may be a “bit different” to the nominal ones.

John E Allen
West London, UK

From: Scott Aldous 
<0220f70c299a-dmarc-requ...@listserv.ieee.org<mailto:0220f70c299a-dmarc-requ...@listserv.ieee.org>>
Sent: 28 October 2020 21:19
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Electric Current Abroad

Hi Doug,

Have you seen the list from worldstandards? It doesn't cover the phase 
configurations directly but does have a column for number of wires.

https://www.worldstandards.eu/electricity/three-phase-electric-power/<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.worldstandards.eu%2Felectricity%2Fthree-phase-electric-power%2F=04%7C01%7Cted.eckert%40microsoft.com%7C95e92ee86677454ea8df08d87b8d1659%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637395194073397525%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000=EyfZMKjgvCYvimgM%2Bp79za%2BffqgUkGZwwCAvO8AvQ1Q%3D=0>

On Wed, Oct 28, 2020 at 1:48 PM Douglas Powell 
mailto:doug...@gmail.com>> wrote:
All,

In the distant past I struggled to learn what were the expected electrical 
voltage, frequency, and phase configurations (delta, wye, high-leg, etc) for 
commercial/industrial facilities in various countries. I know about IEC 60038 
standard voltages, but standard voltages don't always represent real life in 
specific locales. What I wanted was a good country-by-country listing for three 
phase power. The source I most often used was 
"http://www.ita.doc.gov/media/Publications/pdf/current2002FINAL.pdf<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.ita.doc.gov%2Fmedia%2FPublications%2Fpdf%2Fcurrent2002FINAL.pdf=04%7C01%7Cted.eckert%40microsoft.com%7C95e92ee86677454ea8df08d87b8d1659%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637395194073407494%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000=%2BPgczaXTNxb9l9muvirDA1W0SiZfo5fwXkUlBUnEpiE%3D=0>".
 A 2002 reprint of the 1998 document, and now a broken link. After a generic 
search of  
www.ita.doc.gov<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.ita.doc.gov%2F=04%7C01%7Cted.eckert%40microsoft.com%7C95e92ee86677454ea8df08d87b8d1659%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637395194073407494%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000=kgNk62JOps4%2BJdjaH7j7L%2FVmmtV9IjuO2aHo%2BOllS3U%3D=0>,
 It seems it is no longer available.

Yes, I realize the information was getting old but finding no up to date 
alternative, I searched elsewhere.  And besides, It's not likely that such 
things like this change rapidly.

Google Books: 
Link<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fbooks.google.com%2Fbooks%3Fid%3D0hAdYfH_feQC%26newbks%3D1%26newbks_redir%3D1%26dq%3DElectric%2520Current%2520Abroad%26pg%3DPA1%23v%3Donepage%26q%3DElectric%2520Current%2520Abroad%26f%3Dfalse=04%7C01%7Cted.eckert%40microsoft.com%7C95e92ee86677454ea8df08d87b8d1659%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637395194073417489%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000=VGUN80nYeZqaItXYEFY7N3507RDfaGufiGv%2FFPmVR8A%3D=0>
Wayback Machine: 
Link<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fweb.archive.org%2Fweb%2F20130423040219%2Fhttp%3A%2Fwww.ita.doc.gov%2Fmedia%2FPublications%2Fpdf%2Fcurrent2002FINAL.pdf=04%7C01%7Cted.eckert%40microsoft.com%7C95e92ee86677454ea8df08d87b8d1659%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637395194073417489%7CUnknown%7CTWFpbGZsb3d8eyJW

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

[Ted Eckert]

Hi Rich,

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

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

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


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

Rich --

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

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




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

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

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

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

Stay safe!

Rich

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Attachments 

Re: [PSES] Safety and Energy Certification Job Opening

[Ted Eckert]

Hello all,

I have an additional open position for a Product Safety Engineer. The original 
position I posted is for somebody familiar with A/V-ITE safety standards and 
the certification process and applications are still being accepted. This 
additional position focuses more on hazard analysis and risk assessment.

https://careers.microsoft.com/us/en/job/907286/Product-Safety-Engineer
https://www.linkedin.com/jobs/view/2150971107/

Best regards,
Ted Eckert
Microsoft

From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@listserv.ieee.org>
Sent: Friday, September 11, 2020 4:43 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] Safety and Energy Certification Job Opening

Hello all,

Microsoft has a new open position for a Safety and Energy Certification 
engineer.
https://careers.microsoft.com/us/en/job/897312/Safety-Energy-Compliance-Engineer<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fcareers.microsoft.com%2Fus%2Fen%2Fjob%2F897312%2FSafety-Energy-Compliance-Engineer=02%7C01%7Cted.eckert%40microsoft.com%7Cb9834252fcdc4ad4ecc808d856ac71b8%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637354645940586743=L5Yt7Ma6bTmNa9qm4RsCTlgft8hOB9%2BeKGgZgqXw4BI%3D=0>
https://www.linkedin.com/jobs/view/2011579672/<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.linkedin.com%2Fjobs%2Fview%2F2011579672%2F=02%7C01%7Cted.eckert%40microsoft.com%7Cb9834252fcdc4ad4ecc808d856ac71b8%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637354645940596742=sw5vycXSImRvNWeYIWob1W%2Fu43Q79QbIgaa9ykTHTYQ%3D=0>

This person will have the opportunity to work on all Microsoft consumer product 
lines including Surface, Xbox and HoloLens. Please see the job postings for 
details on the responsibilities.

Best regards,
Ted Eckert
Microsoft

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

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Re: [PSES] Demonstrating Compliance to the LVD w/o using 62368

[Ted Eckert]

Hi Chuck,

The biggest change that I have seen is for touch temperatures. IEC 60950-1 
allows continuous contact with plastic at 75 C. Even glass is allows a 
continuous temperature of 70 C. Imagine using one of those new glass-bodied 
cell phones with it at that temperature. IEC 62368-1 reduces the continuous 
contact temperature limit to 48 C for all materials.

There were probably many older laptop computers with plastic cases that could 
exceed 48 C on the bottom surface during use. Those laptops would not comply 
with IEC 62368-1.

This isn't the only item to consider, but it's the one I'm most familiar with. 
There are additional issues related to fire enclosures where a product could 
pass IEC 60950-1 but fail IEC 62368-1 2nd Edition. However, these issues have 
largely be resolved with IEC 62368-1 3rd edition. TC 108 recognized that there 
were many constructions allowed under IEC 60950-1 that were shown to be 
acceptable through years of use, yet disallowed by IEC 62368-1 2nd edition. 
Many issues were resolved with the update.

Ted Eckert
Microsoft Corporation

The opinions experessed are my own and do not necessarily reflect those of my 
employer or TC 108.



From: Chuck August-McDowell 
Sent: Thursday, September 17, 2020 11:33 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] Demonstrating Compliance to the LVD w/o using 
62368

Hi Charles,

Only slightly off your topic "Has anyone experienced having an ITE product that 
complies with IEC60950 requirements, but does not comply with some portions IEC 
62368?"
I work on the audio side so our base standard is 60065. So to rephrase the 
question;
"Has anyone experienced having an audio product that complies with IEC 60065 
requirements, but does not comply with some portions IEC 62368? "
I was informed during factory audit the Hipot test voltage changed from 1500 
VAC to 1768 VAC ?

Oh, and outdoor use also changes from IEC 62368 2ed, calls for using 60950-22 
at current editions, which the 2005 edition did not require a dust test, but 
new (required) 2nd edition requires a dust test, where as 60065 required only 
IPX4 testing.

Let the testing begin!

Respectfully,

Chuck August-McDowell


From: Charles Jackson mailto:cjack...@nvidia.com>>
Sent: Wednesday, September 16, 2020 7:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Demonstrating Compliance to the LVD w/o using 62368


[EXTERNAL EMAIL]
Has anyone experienced having an ITE product that complies with IEC60950 
requirements, but does not comply with some portions IEC 62368?  In particular 
the use of a non-LPS psu.  Is there some sort of risk analysis that can be done 
to prove up conformance to the directive based on 60950 with or without 
supplemental test??

Thanks in advance
Chuck
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For he

[PSES] Safety and Energy Certification Job Opening

[Ted Eckert]

Hello all,

Microsoft has a new open position for a Safety and Energy Certification 
engineer.
https://careers.microsoft.com/us/en/job/897312/Safety-Energy-Compliance-Engineer
https://www.linkedin.com/jobs/view/2011579672/

This person will have the opportunity to work on all Microsoft consumer product 
lines including Surface, Xbox and HoloLens. Please see the job postings for 
details on the responsibilities.

Best regards,
Ted Eckert
Microsoft


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Re: [PSES] Question - not EMC

[Ted Eckert]

Hi Gary,

As Greg noted, there are specific length limits in the U.S. for information 
technology equipment based on NFPA 70, the National Electrical Code. There are 
different length limits for other types of products in NFPA 70.

  *   Range hoods, in-sink food disposals and some other fixed kitchen 
appliances must have cords 450 - 900 mm in length.
  *   Countertop kitchen appliances have a very short limit for the cord. The 
intent is to keep them away from sources of water and to make it less likely 
that they will be used in locations other than the kitchen counter.
  *   ITE cord length is intended to reduce the risk of the use of extension 
cords with the minimum, but to also reduce the risk of running cords across a 
room with the maximum length. The ITE cord length minimum of 1.5 meters is also 
to ensure that table-top or desk-top ITE does not need an extension cord to 
reach an outlet near the floor.
  *   Vacuum cleaners and similar appliances will be allowed much longer cords 
and will have a far greater minimum limit.

The question comes down to what "instruments" are classified as. That will 
determine where they fall under NFPA 70 and what the cord requirements might be.

Ted Eckert
Microsoft Corporation

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



From: Greg McClure 
Sent: Wednesday, September 9, 2020 9:01 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] Question - not EMC

Gary,

It may depend on which standard you are using to certify your product. Here are 
3 references from an investigation I performed in 2014:


  1.  UL 60950-1, Annex NAE, Clause 3.2.5, Cord-connected equipment - "The 
length of a power supply cord shall not exceed 4.5 m (14.76 ft)" [NEC 400.8, 
645.5(B)]
  2.  UL 60950-1, Annex NAE, Clause 3.2.5, Cord-connected equipment - "The 
minimum length of a power supply cord shall be 1.5 m unless it is intended for 
a special installation, such as dedicated equipment intended to be mounted near 
a receptacle. ..." [NEC 210]
  3.  US National Electrical Code Handbook 2008 Section 210.52 - "Receptacles 
are required to be located so that no point in any wall space is more than 6 ft 
(1.83 m) from a receptacle. This rule intends that an appliance or lamp with a 
flexible cord attached may be placed anywhere in the room near a wall and be 
within 6 ft (1.83 m) of a receptacle, thus eliminating the need for extension 
cords.   ..." (emphasis added)


Gregory H. McClure
Lexmark Product Safety
Product Safety Team Lead
859-232-3240 office

From: Darnel, Gary 
mailto:gary.dar...@thermofisher.com>>
Sent: Wednesday, September 9, 2020 11:51 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Question - not EMC

I have a general question, I hope someone here knows the history on it.


Is there is a length restriction on power cords for instruments?  I am not 
referring to extension cords.  But either hard connected cord, or the the 
removeable C13/C14 style cords?

If so, what is it, and why is it?  Discounting the EMC issues, what, if any, is 
the safety issue with a long power cord?  Which standards spell out this 
length?  What testing or rationale supports this?


Many thanks,

Regards,

Gary


Gary Darnel, P.Eng.
Senior R Engineer
Laboratory Automation








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Re: [PSES] [EXTERNAL] [PSES] High voltage versus High tension

[Ted Eckert]

Hello Regan,

I’ve only seen “high tension” in reference to overhead power lines. I cannot 
recall the term ever being used with equipment. There may be a more basic 
question than whether or not it would be accepted by an NRTL during a field 
evaluation. Would the meaning of a label stating “high tension” be clear to the 
user? Warning labels should be as clear as possible and intuitively understood. 
Most Americans likely wouldn’t know what the hazard would be if a piece of 
equipment was marked “high tension”.

Best regards,
Ted Eckert

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

From: Regan Arndt 
Sent: Monday, August 3, 2020 4:35 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] High voltage versus High tension

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

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

[Ted Eckert]

Hello Amund,



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



The Occupational Safety & Health Administration (OSHA) is a division of the 
U.S. Department of Labor. OSHA has legal authority over the workplace. OSHA 
runs the Nationally Recognized Testing Laboratory 
(NRTL<https://www.osha.gov/dts/otpca/nrtl/>) program, and it requires NRTL 
approval for a limited set of 
products<https://www.osha.gov/dts/otpca/nrtl/prodcatg.html>.



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



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



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



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



Regards,

Ted Eckert

The opinions expressed do not necessarily reflect those of my employer, OSHA, 
the Department of Labor or any local electrical inspectors.



-Original Message-
From: Amund Westin 
Sent: Monday, May 25, 2020 6:09 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] Electrical safety testing US and Canada ... 
Mandatory ?



Sorry for bringing up this issue again, but I have lost my history for all 
previous IEEE mails  ...



I know (assume ...) that UL, CSA, FM and others are voluntary for showing 
compliance.

But that is actually required by law in US and C?





Thanks!



Best regards

Amund



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This message is from t

Re: [PSES] UL Listed Fuse vs Recognized

[Ted Eckert]

I forgot to add a link. There is a little more information here.
https://code-authorities.ul.com/wp-content/uploads/2014/09/CircuitBreaker_MG.pdf


From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@listserv.ieee.org>
Sent: Monday, May 11, 2020 1:04 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] UL Listed Fuse vs Recognized

Hello John,

Others can probably provide a better answer than I can, but I'll make an 
attempt.

Fuses and circuit breakers are extremely safety-critical. The Listed 
overcurrent protectors are typically for building power distribution. Long ago, 
replacing blown fuses was a common task for a homeowner. The fuses had to be 
designed to a higher level of safety because the installation was somewhat 
uncontrolled. The Listed versions are tested to a level where it acceptable for 
handling by general users rather than by instructed or trained personnel. The 
Listed overcurrent protectors should fail gracefully with high currents from 
ground faults.

Recognized overcurrent protectors are generally not acceptable for branch 
circuit protection where they could be reset or replaced by a general uses. UL 
has different standards for Molded Case Circuit Breakers and Supplementary 
Overcurrent Protectors, with the latter often being the Recognized components. 
As the standard name implies, they supplement the branch circuit protection and 
do not replace it. Recognized fuses may often ben internal to a device where 
they are within a fire enclosure and only accessible to service personnel.

This is a bit of an oversimplification, but I hope it helps clear it up a 
little.

Regards,
Ted Eckert

The opinions expressed do not necessarily reflect those of my employer or UL.

From: John Allen 
mailto:jral...@productsafetyinc.com>>
Sent: Monday, May 11, 2020 11:19 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [EXTERNAL] [PSES] UL Listed Fuse vs Recognized

Hi,

I hope everyone is good, healthy and being safe.

Does anyone have an accurate explanation of how a fuse can be UL Listed vs UR?  
 A fuse cannot stand alone as with other UL Listed products.

UL categories are JDYX, JDYX2

Thank you and Be Safe,

John

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Re: [PSES] UL Listed Fuse vs Recognized

[Ted Eckert]

Hello John,

Others can probably provide a better answer than I can, but I'll make an 
attempt.

Fuses and circuit breakers are extremely safety-critical. The Listed 
overcurrent protectors are typically for building power distribution. Long ago, 
replacing blown fuses was a common task for a homeowner. The fuses had to be 
designed to a higher level of safety because the installation was somewhat 
uncontrolled. The Listed versions are tested to a level where it acceptable for 
handling by general users rather than by instructed or trained personnel. The 
Listed overcurrent protectors should fail gracefully with high currents from 
ground faults.

Recognized overcurrent protectors are generally not acceptable for branch 
circuit protection where they could be reset or replaced by a general uses. UL 
has different standards for Molded Case Circuit Breakers and Supplementary 
Overcurrent Protectors, with the latter often being the Recognized components. 
As the standard name implies, they supplement the branch circuit protection and 
do not replace it. Recognized fuses may often ben internal to a device where 
they are within a fire enclosure and only accessible to service personnel.

This is a bit of an oversimplification, but I hope it helps clear it up a 
little.

Regards,
Ted Eckert

The opinions expressed do not necessarily reflect those of my employer or UL.

From: John Allen 
Sent: Monday, May 11, 2020 11:19 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] UL Listed Fuse vs Recognized

Hi,

I hope everyone is good, healthy and being safe.

Does anyone have an accurate explanation of how a fuse can be UL Listed vs UR?  
 A fuse cannot stand alone as with other UL Listed products.

UL categories are JDYX, JDYX2

Thank you and Be Safe,

John

-


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Re: [PSES] [EXTERNAL] [PSES] Energy related Products (ErP) requirements

[Ted Eckert]

Hello Scott,


  1.  A television will fall under the Lot 
5<https://ec.europa.eu/info/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/energy-label-and-ecodesign/energy-efficient-products/televisions_en>
 requirements. The EPS still falls under Lot 
7<https://ec.europa.eu/info/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/energy-label-and-ecodesign/energy-efficient-products/external-power-supplies_en>
 even if it is sold with a television.
  2.  The cell phone would still be subject to Lot 
6/26<https://ec.europa.eu/info/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/energy-label-and-ecodesign/energy-efficient-products/mode-standby-and-networked-standby_en>
 when plugged in through the EPS. The EPS still falls under Lot 
7<https://ec.europa.eu/info/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/energy-label-and-ecodesign/energy-efficient-products/external-power-supplies_en>
 even if it is sold with a cell phone.

Regards,
Ted Eckert
The opinions expressed are my own and do not necessarily reflect those of my 
employer or the European Commission.

From: Scott Xe 
Sent: Thursday, May 7, 2020 6:46 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] Energy related Products (ErP) requirements

I have some queries about the application of ErP requirements seeking esteemed 
advice.  The following products are involved.

  1.  TV + EPS (sold together)
  2.  Mobile Phone + EPS (sold together)
For product 1, should ErP requirements for TV or EPS be applied or both.

For product 2, should ErP requirements for EPS be applied since mobile phone 
alone is not within the scope of ErP requirements.  Thus is only EPS subject to 
the ErP requirements?

Thanks and regards,

Scott


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Re: [PSES] UL 60065 7th & 8th Edition

[Ted Eckert]

Hello Ian,

New products will not be eligible to be certified to UL 60065 starting December 
20th. However, products already certified to UL 60065 as of that date will 
continue to retain their certification and do not need to be updated to the new 
standard. However, at some point in the future, a date may be announced when 
existing certifications will need to be transitions. I would expect that to be 
a number of years off in the future.
https://ctech.ul.com/en/knowledge-center/ul-62368-1-effective-date-information/

Regards,
Ted Eckert
The opinions expressed are my own and do not necessarily reflect those of my 
employer, UL or any other NRTL.

From: McBurney, Ian 
Sent: Thursday, May 7, 2020 6:56 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] UL 60065 7th & 8th Edition

Dear Colleagues.

Does anyone know if products approved to the above standard will still be able 
to be NRTL marked after 20th December 2020? This is the date the EN version can 
no longer be used to declare conformity with the EU LVD. I would like to know 
if the same event will happen in the USA, or when it is likely to occur.

Many thanks in advance.


Ian McBurney
Compliance Engineer
Allen & Heath Ltd.

Allen & Heath Ltd is a registered business in England and Wales, Company 
number: 4163451. Any views expressed in this email are those of the individual 
and not necessarily those of the company.
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Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[Ted Eckert]

Hello Bernd,

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

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

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

Ted Eckert
Microsoft Corporation

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


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

Hello Ted, hello Regan,

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

Thank you and kind regards,

Bernd

Von: Regan Arndt mailto:reganar...@gmail.com>>
Gesendet: Dienstag, 18. Februar 2020 18:01
An: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Betreff: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

OSHA & the related NRTL mandatory certification is only for the 
commercial/office/industrial workplace. OSHA has no jurisdiction in the 
consumer environment.
The FCC is for both environments.

Regan

On Mon, Feb 17, 2020, 8:29 PM 
<06cee064502d-dmarc-requ...@ieee.org<mailto:06cee064502d-dmarc-requ...@ieee.org>>
 wrote:
Thank you Ted, Rich and Regan,

The product is classified as IT and is sold to pro market. i.e it is used by 
professional and not consumer market. There two types of products. Class I as 
well as Class III. They are mainly used in corporation conference rooms.

With that in mind, what are your thoughts about mandatory NRTL certification as 
well as FCC?

Thanks
Peter
-Original Message-
From: Ted Eckert 
<07cf6ebeab9d-dmarc-requ...@ieee.org<mailto:07cf6ebeab9d-dmarc-requ...@ieee.org>>
To: EMC-PSTC mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Sent: Mon, Feb 17, 2020 6:16 pm
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
Hello Peter,

Let me add to Rich and Regan’s comments.

The question for residential installations isn’t as clear as for the workplace. 
Most jurisdictions in the United States have adopted the National Electrical 
Code which requires many electrical and electronic products to either be Listed 
or to be investigated and approved by the local Authority Having Jurisdiction. 
In practice, this typically will apply to hard-wired products or products 
attached to building structure. The enforcement is typically through an 
electrical inspection which will often not cover plug-connected devices.

In the workplace, any product that has a direct connection to the mains will 
need NRTL approval. At the other end of the spectrum, a product like a USB 
mouse or remote control using alkaline batteries likely won’t need NRTL 
approval. In theory, I believe an OSHA inspector could enforce the NRTL 
requirement on any electrical product, but that won’t necessarily be what 
happens in practice.

That being said, you can choose not to get NRTL approval for your product. 
However, you need to understand the risks your product may pose. If you sell 
products to commercial customers, are you meeting their needs? Will your 
products be acceptable to them? If you have a low-voltage dev

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

[Ted Eckert]

Hello Peter,

Let me add to Rich and Regan’s comments.

The question for residential installations isn’t as clear as for the workplace. 
Most jurisdictions in the United States have adopted the National Electrical 
Code which requires many electrical and electronic products to either be Listed 
or to be investigated and approved by the local Authority Having Jurisdiction. 
In practice, this typically will apply to hard-wired products or products 
attached to building structure. The enforcement is typically through an 
electrical inspection which will often not cover plug-connected devices.

In the workplace, any product that has a direct connection to the mains will 
need NRTL approval. At the other end of the spectrum, a product like a USB 
mouse or remote control using alkaline batteries likely won’t need NRTL 
approval. In theory, I believe an OSHA inspector could enforce the NRTL 
requirement on any electrical product, but that won’t necessarily be what 
happens in practice.

That being said, you can choose not to get NRTL approval for your product. 
However, you need to understand the risks your product may pose. If you sell 
products to commercial customers, are you meeting their needs? Will your 
products be acceptable to them? If you have a low-voltage device that isn’t 
mains connected, you will need to understand your customer’s needs before you 
make any determination about skipping NRTL approval.

Let’s use the USB mouse example. If you sell a USB mouse that has no NRTL 
approval, you can state that you are selling a product to the general public 
for home use where NRTL approval for a mouse is clearly not required. You can 
then argue that any business that purchases it is making their own decision on 
whether to accept a non-NRTL product. However, it is up to you, your employer 
and your employer’s legal department on whether you should take this approach.

Ted Eckert
The opinions expressed do not necessarily reflect those of my employer, OSHA or 
the U.S. Department of Labor.

From: Richard Nute 
Sent: Monday, February 17, 2020 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] Mandatory certification


Hi Peter:

I can only speak to NRTL certification.

If your product can be used in a workplace, then NRTL certification is 
mandatory.

In most non-workplace locations, safety certification is mandatory.  A local 
authority specifies the acceptable certification houses.  Most local 
authorities specify the NRTL certification houses.

Certification by a NRTL certification house is accepted almost universally in 
the USA.

Best regards,
Rich


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Re: [PSES] [EXTERNAL] [PSES] Construction Site Power Cords, Germany

[Ted Eckert]

Hi Mike,

The scope of IEC 62841-1 covers the following:

  *   Hand-held tools
  *   Transportable tools
  *   Lawn and garden machinery

I think that is what is intended by the German requirement. If you have a 
portable table saw, it would probably be considered “comparable work 
equipment”. Transportable equipment intended to be moved from job site to job 
site would still be in scope even if the equipment is not hand held.

Best regards,
Ted Eckert
Microsoft

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

From: MIKE SHERMAN 
Sent: Tuesday, January 28, 2020 6:05 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] Construction Site Power Cords, Germany

A German insurance document, DGUV Information 203-006 ( Selection and operation 
of electrical systems and equipment on construction and assembly sites ),  has 
a requirement for either rubber or polyurethane jacketed power cables in its 
section 5.15:
"   Hand-held power tools and comparable work equipment
These must at least correspond to protection class IP 2X and be equipped with a 
mains connection cable of type H07RN-F [rubber] or H07BQ-F [polyurethane].   "

Does anyone know what is meant by "comparable work equipment"?


thanks,
Mike Sherman
Graco Inc.
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Re: [PSES] [EXTERNAL] [PSES] EPS efficiency

[Ted Eckert]

Hi Dan,

Adoption has been slow and this is one of the rare situations where the U.S. 
Department of Energy has been the first to adopt a new energy requirement. As 
far as I am aware, only the United States, Canada and European Union have 
enacted regulations for Level VI.

Best regards,
Ted Eckert
Microsoft Corporation

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



From: Dan Roman <0d75e04ed751-dmarc-requ...@ieee.org>
Sent: Friday, January 24, 2020 8:03 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] EPS efficiency

Happy Friday!
Does anyone know of a list of countries that are now requiring Level VI 
compliance and which may still be at Level V or lower? I know the EU change is 
coming soon and is a Level VI hybrid.
--
Dan Roman, N.C.E.
IEEE Senior Member
dan.ro...@ieee.org<mailto:dan.ro...@ieee.org>
dan.n2...@verizon.net<mailto:dan.n2...@verizon.net>
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[PSES] Job opening

[Ted Eckert]

Microsoft has an open position for a product safety engineer. This position 
will focus on hazards analysis and risk assessment for Microsoft's consumer 
products. The role does not involve directly obtaining safety certifications 
and we are looking for a candidate with a focus on risk assessment rather than 
standards knowledge.

Additional information is available at either the Microsoft or LinkedIn pages 
for the position.

https://careers.microsoft.com/us/en/job/760899/Product-Safety-Engineer<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fcareers.microsoft.com%2Fus%2Fen%2Fjob%2F760899%2FProduct-Safety-Engineer=02%7C01%7CTed.Eckert%40microsoft.com%7C87dd6320c68842aeda9008d783198130%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637122017868880189=ARtNIdWWsNZvOw4OjS%2BEEZ62F6CtxLkpaYxWA1wiN2Q%3D=0>

https://www.linkedin.com/jobs/view/1645274659/<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.linkedin.com%2Fjobs%2Fview%2F1645274659%2F=02%7C01%7CTed.Eckert%40microsoft.com%7C87dd6320c68842aeda9008d783198130%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637122017868890188=H2YxqmZDOAxnUvij4jRdC4d9IO5er295RMKAfjwj%2Fno%3D=0>

Regards,
Ted Eckert
Senior Engineer, Safety & Energy Compliance
Microsoft Corporation




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Re: [PSES] [EXTERNAL] Re: [PSES] act of God versus safety

[Ted Eckert]

Hi Rich

David Lazarus is discussing contract law, which is one of the areas where I 
conceded that “Acts of God” does play a role. The Florida Supreme Court 
statement is given as a response to a situation where a hurricane knocked out 
power to homeowners. The agreement between the homeowners and the utility for 
the delivery of power would fall under contract law, not product liability law.

If an “Act of God” were a plausible defense in a product liability case, I 
would have expected to have heard of it by now. However, it may be the case 
that plaintiff’s’ attorneys know what the limits would be. Acts of nature 
generally are not held against a manufacturers. Hurricanes and flood frequently 
result in vehicles getting submerged. I am unaware of the owner of a car being 
able to successfully bring a claim against the manufacturers for the vehicle 
failing to operate properly after being submerged.

It’s an interesting area to think about, but I suspect it’s up to lawyers and 
not engineers to discuss the boundaries.

Best regards,
Ted

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

From: Richard Nute 
Sent: Monday, December 30, 2019 11:34 AM
To: Ted Eckert ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [EXTERNAL] Re: [PSES] act of God versus safety



Hi Ted:

I picked the reference from David Lazarus’ December 24th column from the LA 
Times:

https://www.latimes.com/business/story/2019-12-24/acts-of-god-consumer-contract<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.latimes.com%2Fbusiness%2Fstory%2F2019-12-24%2Facts-of-god-consumer-contract=02%7C01%7CTed.Eckert%40MICROSOFT.COM%7Cfd3a059ef7b345ffe72b08d78d5f4053%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637133312573764680=wFNnJvmvjPHxIczW%2Bi9mtuOyTDpbvSabRryV%2Bf97VRw%3D=0>

He says, “… that “acts of God” is cited so frequently as an excuse for not 
meeting corporate obligations.”

In considering the safety of a product, if a product met the standard but still 
caused an injury, could or would a corporation invoke that the injury was an 
“act of God” to absolve itself from liability as corporations appear to do for 
other obligations?

We’re all biased here.  We are “good guys.”  We believe it behooves the 
manufacturer to take all steps – none of which are “acts of God” -- to prevent 
injury from a product.

Best wishes for the holiday season,
Rich

PS:  Many would say that the eruption of the White Island volcano was an “act 
of God.”  While volcanic activity was monitored, volcanologists did not predict 
the violent eruption.  Either the volcanologists were not good enough, or the 
eruption was an “act of God”?



From: Ted Eckert 
<07cf6ebeab9d-dmarc-requ...@ieee.org<mailto:07cf6ebeab9d-dmarc-requ...@ieee.org>>
Sent: Monday, December 30, 2019 8:11 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] act of God versus safety

First, I am not licensed to practice law in any jurisdiction. Take what I say 
as the view of an engineers with only limited experience in this area.

The term “Act of God” generally is limited to contract law and to insurance 
law. It is also generally limited to natural events such as earthquakes, 
tornados and such. It is unlikely that a court in the United States would 
accept a claim of an “Act of God” in a product liability case. Rich gives a 
brief statement from a 1944 Florida case, but that statement neither includes 
context nor takes into account decades of case law and precedent that provide 
the current interpretation of the phrase.

As engineers, it can be fun to play with ideas such as “Act of God”, but it 
should be clear that this is just an attempt at humor and has little effect on 
liability in product design.

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

From: John Woodgate mailto:j...@woodjohn.uk>>
Sent: Sunday, December 29, 2019 6:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [EXTERNAL] Re: [PSES] act of God versus safety


Does that prove that at least one god exists?

Best wishes

With seasonal felicitations

John Woodgate OOO-Own Opinions Only

Rayleigh, Essex UK 
www.woodjohn.uk<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7CTed.Eckert%40MICROSOFT.COM%7Cfd3a059ef7b345ffe72b08d78d5f4053%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637133312573764680=i3FjundlENN8QbZmHzTAILzSs91s2EjkTolnEl26%2Bek%3D=0>
On 2019-12-30 02:09, Scott wrote:
If you do a thorough hazard analysis, an act of god is obvious!

Scott
Sent from my iPhone

On Dec 29, 2019, at 8:37 PM, Doug Powell 
<mailto:doug...@gmail.com> wrote:

Rich,

While many standards do indeed refer to foreseeable events, misuse, etc. I'm 
not certain this would automatically confer Act of God status to an unforeseen 
event. This hypothetical event m

Re: [PSES] [EXTERNAL] Re: [PSES] act of God versus safety

[Ted Eckert]

First, I am not licensed to practice law in any jurisdiction. Take what I say 
as the view of an engineers with only limited experience in this area.

The term “Act of God” generally is limited to contract law and to insurance 
law. It is also generally limited to natural events such as earthquakes, 
tornados and such. It is unlikely that a court in the United States would 
accept a claim of an “Act of God” in a product liability case. Rich gives a 
brief statement from a 1944 Florida case, but that statement neither includes 
context nor takes into account decades of case law and precedent that provide 
the current interpretation of the phrase.

As engineers, it can be fun to play with ideas such as “Act of God”, but it 
should be clear that this is just an attempt at humor and has little effect on 
liability in product design.

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

From: John Woodgate 
Sent: Sunday, December 29, 2019 6:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] act of God versus safety


Does that prove that at least one god exists?

Best wishes

With seasonal felicitations

John Woodgate OOO-Own Opinions Only

Rayleigh, Essex UK 
www.woodjohn.uk
On 2019-12-30 02:09, Scott wrote:
If you do a thorough hazard analysis, an act of god is obvious!

Scott
Sent from my iPhone


On Dec 29, 2019, at 8:37 PM, Doug Powell 
 wrote:

Rich,

While many standards do indeed refer to foreseeable events, misuse, etc. I'm 
not certain this would automatically confer Act of God status to an unforeseen 
event. This hypothetical event may be a case of degrees and not of two 
extremes, especially in the case of a formerly unforeseeable and now 
preventable situation. Isn't this how many standards are developed over the 
years?

I still remember shoe stores in the 1950s that offered real-time x-ray of how 
well shoes fit the customer's feet. An unforeseeable hazard at the time and now 
incredibly obvious. Would injury in the former time be an Act of God?

Best wishes, Doug
From: ri...@ieee.org
Sent: December 29, 2019 5:19 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Reply-to: ri...@ieee.org
Subject: [PSES] act of God versus safety



The Florida state Supreme Court ruled in 1944 that an act of God is “an act or 
occurrence so extraordinary and unprecedented that human foresight could not 
foresee or guard against it.”

If a product that complies with a safety standard injures a person, is the 
injury an act of God?

Best wishes for the holiday season,
Rich


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Re: [PSES] [EXTERNAL] [PSES] Does Hong Kong require same EMC/Safety/RoHS approvals and labeling as China?

[Ted Eckert]

Hello Monrad,

Hong Kong still has a completely separate regulatory regime from China. You 
will likely find importing to Hong Kong far simpler than Chinese approvals. As 
far as I am aware, most products will not require marking for Hong Kong. It 
will likely require minimal work if you don't have radios in the products.

Best regards,
Ted Eckert
Microsoft Corporation

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

From: Monrad Monsen 
Sent: Tuesday, November 19, 2019 5:37 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] Does Hong Kong require same EMC/Safety/RoHS 
approvals and labeling as China?

Does Hong Kong require the same EMC/Safety/RoHS approvals and labeling as 
China?  My focus is on regulation of automated data processing products like 
servers, PCs, disk arrays, switches, power distribution units (PDUs) and rack 
integrated systems.  For example, China requires that servers and PCs be 
labeled with a CCC mark for EMC & Safety and also Environment Friendly Use 
Period (EFUP) labeling for RoHS.  Is this required for Hong Kong as well?

Of course, Hong Kong is a Special Administrative Region under the People's 
Republic of China since 1 July 1997, but they have a "high degree of autonomy" 
in all matters except foreign and defense affairs for the subsequent 50 years.  
The products I support already have CCC & EFUP labeling and approvals so the 
topic has not come up until now when we might be importing a few 3rd party 
products into Hong Kong.

Thanks.

Monrad Monsen


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

[Ted Eckert]

I would read the FCC two-part statement a little differently.

Let's start with the second statement. It indicates that equipment must accept 
interference. It uses "must", so this is a requirement. This just indicates 
that the product falls under a category where there are no immunity 
requirements mandated by the FCC. It's a warning to the user. If they find that 
their device is misbehaving due to interference from other devices, the user is 
being told that it isn't the fault of the FCC.

The first statement is harder to figure out. I can start with the signal words. 
"Must" means a requirement, "should" indicates a recommendation, and "may" 
indicates an option. What does "may not" mean? A prohibition should be "must 
not" or "shall not". A recommendation against would be "should not". However, 
as written it could be interpreted to mean that the equipment might not cause 
harmful interference. I don't know if that is what is intended, but that is how 
it could be interpreted if read literally.

The way I look at it, these statements are to make it clear to the user that 
the FCC is absolving itself of any fault for accepting the certification of the 
device. First, if your equipment causes interference with other devices, blame 
the manufacturer and not the FCC. Second, if your equipment is susceptible from 
interference from other devices, blame the manufacturer and not the FCC.

Ted Eckert
Microsoft Corporation

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


From: John Woodgate 
Sent: Thursday, October 31, 2019 1:37 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] FCC regulatory statements


Precisely. That's bureaucracy for you. Isn't there also a US law that requires 
you to listen on a radio for Homeland Security broadcasts? Everyone is guilty 
of something.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7Cea38c0d7efb748b956b408d75e421315%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C637081510206510755=rNoUm8JBfg7GQC%2BrWjgsvddk4amt0ATF26Oj5uLm8Zk%3D=0>

Rayleigh, Essex UK
On 2019-10-31 20:24, Richard Nute wrote:

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

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

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

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

Is my interpretation correct?

Best regards,
Rich



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Re: [PSES] Power supply 60335 or 60950...

[Ted Eckert]

Hello Matthew,

This may be an oversimplification. However, a basic guide is that IEC 60335-1 
would be appropriate if the end-product uses a motor to do its primary function 
or is intended for cooking. The standard generally covers appliances. IEC 
62368-1 is appropriate if the end-product creates, modifies or transmits data, 
audio, video or other signals as its primary function. The product as you 
described it in your original message would seem to me to be information 
technology equipment and not a home appliance. As such, I would expect IEC 
62368-1 to be the more appropriate standard.

Ted Eckert
Microsoft Corporation

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

From: Matthew Wilson | GBE 
Sent: Thursday, October 24, 2019 2:38 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] Power supply 60335 or 60950...

Thank you all for your replies, much appreciated.  I do offer apologies for the 
use of ‘jack plug’ and ‘jack socket’ which of course suggests a non-suitable 
connector akin to ‘headphone jack’. Quite righty as pointed out not a good idea 
at all.  I remember a long time ago wrecking a Sinclair ZX81 which had such a 
jack socket for power.  And the same sort for connecting to the tape recorder.

The power supply will use the more usual circular DC 2.1mm dia. power connector 
and socket on the device.  They happen to be called ‘DC Jacks’ within our 
sphere which I mangled in my original email.

The product doesn’t have to work with a phone, it has manual input buttons on 
it too. The consumer would miss out on some features by not using the 'app'.

I agree 62368-1 is more appropriate as it is now the state of the art but 
commercially when ‘wall wart’ power supplies are at the price they are being 
offered for a product that will sell out before December 2020 it seems use of 
the ‘current’ 60950 or 60335 standards will overrule the correct compliance 
engineering!

Anyway I have put that to the potential vendors regarding 62368-1.

The question still remains, I guess, that is a power supply to 62368-1 right 
for household use over 60335-1?

Thanks


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Re: [PSES] [EXTERNAL] Re: [PSES] Power supply 60335 or 60950...

[Ted Eckert]

Hello Matthew,

I may be able to suggest an approach that may make the solution more cost 
effective. You can fight high-quality and properly certified USB-A output 
external power supplies that are manufactured in high enough volume that they 
are cost competitive. The cost of one of these power supplies with the added 
cost of a custom USB to jack plug will likely be less than the cost of a power 
supply with an attached custom cable.

I agree with John in regards to the selection of a power input connector. A 
barrel connector or micro-USB connector might be a better choice for a power 
input. USB to barrel jack cables are becoming quite common.

You will need to consider whether to use USB-A or USB-C if you consider that 
approach. USB-C will limit the available power to 5 VDC, 3.0 A if there is no 
data connection to the load to negotiate higher power levels. This may affect 
what the available current should be used for fault testing on your customer’s 
device.

Ted Eckert
Microsoft Corporation

The opinions experessed are my own and do not necessarily reflect those of my 
employer or the USB Implementers Forum.

From: John Woodgate 
Sent: Thursday, October 24, 2019 3:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] Power supply 60335 or 60950...


Since it works with a phone, 62368-1 applies. I would not rely on 60950-1 
because of the incidence of fires and electric shock.  Bedrooms and nurseries 
are especially sensitive locations. Also, note that a jack plug is shorted when 
inserting or withdrawing. That is why the concentric connectors are used 
instead on portables and everything else.  What happens if you plug the 5 V DC 
into a headphone socket, too? Not a good connector to use.

If the client insists on what appears to be a very marginally safe course of 
action, I think you have to consider your professional position.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7C96422da41e7b4a2eaf8508d758700817%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C637075110512325495=Nhxvah8DlB8hG93oCawfgkehAl%2BAXs5WVeQFiYcyeLM%3D=0>

Rayleigh, Essex UK
On 2019-10-24 11:34, Matthew Wilson | GBE wrote:
A client has a product, to be used by consumers typically in a bedroom or 
child's nursery, which has a microcontroller and is Wi-Fi enabled so it can 
present data to 'the cloud' and interact with a mobile phone 'app' to change 
some parameters on the device. We have been asked by the client with help in 
sourcing a power supply for it from Far East sources. They want a 'wall wart' 
type plug in device with a 2 metre lead to a jack plug. The product requires 5V 
DC up to 1A and has a jack socket DC input. Cost is, of course, a key driving 
factor but there are some very keen priced items available out of the FE.

Ignoring 62368-1 for now, as there is still just over a year to go before this 
becomes mandatory and it appears the majority of 'cost effective' PSU 
manufacturers are not up-to-speed with this standard yet. They probably will 
wait till the last minute, or relying on the 'get-out' 4.1.1 clause in 62368-1.

The question is what standard should the PSU meet? 60950-1 or 60335-1? 60950-1 
is for IT equipment, 60335-1 is Household and similar electrical appliances. 
Both standards might apply. If it was a laptop power supply 60950-1 would even 
though the laptops are sold and used in the home.

One potential PSU manufacturer, however, does claim both 60950-1 and 60335-1 
for the same product. Is that possible with one design?

I know this might also spark a debate about risks of FE manufacturers, 
conformity of production and so on like the excellent blog post here 
https://www.unit3compliance.co.uk/tag/power-supply/<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.unit3compliance.co.uk%2Ftag%2Fpower-supply%2F=02%7C01%7Cted.eckert%40microsoft.com%7C96422da41e7b4a2eaf8508d758700817%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C637075110512335489=cQSPEDjqU4zbW5aE8LBqgUnOAORDuJsYzJHjrMiNuvU%3D=0>
 We have a presence on the ground in the FE to verify any manufacturers and all 
the three potential suppliers identified so far have listings on TUV or 
Intertek and have also provided conformity documentation supported by 
legitimate third parties.

Any thoughts welcome.

Thanks for reading.

Regards,



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Re: [PSES] Grounding of metal cabinet

[Ted Eckert]

In my opinion, board-mounted AC inlets are inadvisable at best. The problems 
extend to more than the risk of an open circuit during a ground fault. The AC 
inlet is used for connection of a flexible cord, and that cord will flex. 
Movement of the cord will put strain on the connector’s solder joints on the 
board. At some point, the strain will lift a pad, pull out the through-plating, 
crack the solder or otherwise interrupt the connection. This could happen on 
the ground pin leading to an open ground connection, or it could happen on a 
current-carrying pin leading to arcing, I personally prefer to see flying leads 
from an AC inlet to the circuit board. Flexible stranded wires should be used, 
and the ground pin should go directly to the chassis. It isn’t the most 
inexpensive solution, but I believe it reduces the possibility of a safety 
issue.

Best regards,
Ted Eckert
Microsoft Corporation

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

From: Pete Perkins 
Sent: Tuesday, September 24, 2019 10:30 AM
To: Ted Eckert ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Grounding of metal cabinet

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

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 1067
Albany, Ore  97321-0413

503/452-1201

IEEE Life Fellow
p.perk...@ieee.org<mailto:p.perk...@ieee.org>

Entropy ain’t what it used to be

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

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

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

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

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

Best regards,
Ted Eckert
Microsoft Corporation

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

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

Our safety regulators have insisted that power cord s

Re: [PSES] Grounding of metal cabinet

[Ted Eckert]

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

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

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

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

Best regards,
Ted Eckert
Microsoft Corporation

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

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

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

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





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



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



:>) br,  Pete



Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 1067

Albany, Ore  97321-0413



503/452-1201



IEEE Life Fellow

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



Entropy ain’t what it used to be



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



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

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7Cc5d624bb977847beec2408d740ab67fd%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C637048977245765905=spnE6aXfHr7UAFO31TVLojkdhSSuidZEmmVEemhnn2s%

Re: [PSES] Microsoft job opening

[Ted Eckert]

Hello all,

Microsoft has two open position for safety and compliance.

The first is for a compliance engineer focusing on safety certification and 
energy compliance. This position will focus on industry standards such as IEC 
60950-1 and IEC 62368-1. More information can be found at the Microsoft careers 
site<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fcareers.microsoft.com%2Fus%2Fen%2Fjob%2F694395%2FSafety-Energy-Compliance-Engineer=02%7C01%7Cted.eckert%40microsoft.com%7Cc17633ebc5984102a15d08d73096ca30%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C637031296513256106=IQ47n5C%2Bd1bgP4Dl%2BLI4QBM4fw92v5B%2BAaYXsRl2b7g%3D=0>
 or on 
LinkedIn<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.linkedin.com%2Fjobs%2Fview%2F1448150505=02%7C01%7Cted.eckert%40microsoft.com%7Cc17633ebc5984102a15d08d73096ca30%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C637031296513256106=Unsy570%2BI6GEPv7zAvEyQWqfh%2FvtWaiyaHSrvdARSZs%3D=0>.

The second position is for an engineer focusing on hazard analysis and risk 
assessment for product safety. This position will look at user interaction with 
consumer products and assess safety requirements above and beyond the industry 
standards. More information can be found at the Microsoft careers 
site<https://careers.microsoft.com/us/en/job/706257/Product-Safety-Engineer> or 
on LinkedIn<https://www.linkedin.com/jobs/view/1485290315/>.

Feel free to contact me if you have any questions.

Best regards,
Ted Eckert
Senior Engineer, Safety & Energy Compliance
Microsoft Corporation

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

[Ted Eckert]

I seem to recall that long ago, when televisions had vacuum tubes, high voltage 
and high power, fires were an issue. I'm not positive, but I thought that the 
requirements for flame retardants came from investigations of a number of fires 
of plastic enclosed televisions. I believe that the basis for the requirement 
is sound. It's been decades since flammable plastics were commonly used for IT 
and A/V products. The fact that there have been few issues may be due to the 
effectiveness of flame retardants.

Ted Eckert
Microsoft Corporation

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

From: Pete Perkins <0061f3f32d0c-dmarc-requ...@ieee.org>
Sent: Monday, September 16, 2019 1:46 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Do We Need Flame Retardants in Electronics?

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

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 1067
Albany, Ore  97321-0413

503/452-1201

IEEE Life Fellow
p.perk...@ieee.org<mailto:p.perk...@ieee.org>

Entropy ain't what it used to be

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



https://www.scientificamerican.com/article/do-we-need-flame-retardants-in-electronics/<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.scientificamerican.com%2Farticle%2Fdo-we-need-flame-retardants-in-electronics%2F=02%7C01%7Cted.eckert%40microsoft.com%7C6f8624a753274fc2dda608d73ae6f790%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C637042635984040539=ub7KtAnUqaUapbaX027V6wPDQk2RvtChpLUtsSzI0so%3D=0>

 "...there has never been any valid statistical demonstration that flame 
retardant chemicals of the types and concentrations used in consumer products 
have resulted in death or injury reduction," says Vytenis 
Babrauskas<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.scientificamerican.com%2Farticle%2Fdo-furniture-flame-retardants-save-enough-lives-justify-environmental-damage%2F=02%7C01%7Cted.eckert%40microsoft.com%7C6f8624a753274fc2dda608d73ae6f790%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C637042635984050495=k0o04eDHG0IbRIzN9hu559U5Pt3dlddOXHZngjKEt2c%3D=0>...

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

Enjoy!

Rich
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[PSES] Microsoft job opening

[Ted Eckert]

Hello all,

Microsoft has an open position for a compliance engineer focusing on safety and 
energy. More information can be found at the Microsoft careers 
site<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fcareers.microsoft.com%2Fus%2Fen%2Fjob%2F694395%2FSafety-Energy-Compliance-Engineer=02%7C01%7CTed.Eckert%40microsoft.com%7Cbe510a10ffdd43a9bf1e08d7308f8f8d%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C637031265452714141=4oWoyl9qbeJucgZvW%2Fc4JyjrBcCM16PtADtT3Ye2joo%3D=0>
 or on 
LinkedIn<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.linkedin.com%2Fjobs%2Fview%2F1448150505=02%7C01%7CTed.Eckert%40microsoft.com%7Cbe510a10ffdd43a9bf1e08d7308f8f8d%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C637031265452724149=pvQL%2F1Ts57UMntKAbK0wb5iBgZf2EVpmJhLrXnIySDs%3D=0>.

Feel free to contact me if you have any questions.

Best regards,
Ted Eckert
Senior Engineer, Safety & Energy Compliance
Microsoft Corporation



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Re: [PSES] User Documents & EU Official Languages, Friday Question

[Ted Eckert]

Don’t forget Malta. English is one of the official languages.

Ted Eckert
Microsoft

The opinion expressed are my own and do not necessarily reflect those of my 
employer or the country of Malta.


From: Dan Roman <0d75e04ed751-dmarc-requ...@ieee.org>
Sent: Friday, August 23, 2019 5:10 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] User Documents & EU Official Languages, Friday Question

There's always Ireland...
--
Dan Roman, N.C.E.
IEEE Senior Member
dan.ro...@ieee.org<mailto:dan.ro...@ieee.org>
dan.n2...@verizon.net<mailto:dan.n2...@verizon.net>
On Aug 23, 2019, at 7:06 PM, Doug Powell 
mailto:doug...@gmail.com>> wrote:
Thanks all,

As always, the discussion is interesting and also surprising in some ways.

Have a great weekend,

Doug


Douglas E Powell
Laporte, Colorado USA
doug...@gmail.com<mailto:doug...@gmail.com>
http://www.linkedin.com/in/dougp01
<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.linkedin.com%2Fin%2Fdougp01=02%7C01%7Cted.eckert%40microsoft.com%7C157229a318354241215908d728277b5c%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C637022022355757139=TpXTdfguS8cuZkJH9UibACwS17f2eSVzsXsIvSefRYw%3D=0>

On Fri, Aug 23, 2019 at 1:01 AM Doug Powell < 
doug...@gmail.com<mailto:doug...@gmail.com>> wrote:
All,

I haven't written a Friday Question in some time, so here is a new installment.

With the exit of Britain for the European Union (Brexit), I find it interesting 
but not surprising that English remains one of the official languages, at least 
for now. For many years there has been a large body of documentation provided 
in English and indeed, many of the European Norms are based on IEC standards 
originating in French & English. I wonder, will this policy change in the 
foreseeable future?

It has been my practice to tell clients that the minimum requirement for 
translation of user document(s) and product markings is they must first be in 
one of the official languages and upon request by the end user, the local 
language becomes a requirement as well. I haven't checked in some time, but the 
Machinery Directive may require this without end user involvement. In some 
cases, local regulatory requirements may dictate which languages must be used 
for specific information especially involving EHS. Incidentally, a good friend 
who is in Planetary Aeronomy and Astro-geophysics has told me, if you know just 
one of a handful of languages, you can just about go anywhere in the scientific 
world community; these being English, French, German, Japanese and possibly 
Russian.

So now there is the question of which "English" is the official language of the 
EU, British (Cambridge) English?  I suspect that Brits, Aussies and Americans 
will all have no trouble understanding one another, even with differences in 
spelling, grammar and possibly idioms. Or as Wikipedia puts it, these are 
"mutually comprehensible" ( 
https://en.wikipedia.org/wiki/List_of_dialects_of_English<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fen.wikipedia.org%2Fwiki%2FList_of_dialects_of_English=02%7C01%7Cted.eckert%40microsoft.com%7C157229a318354241215908d728277b5c%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C637022022355757139=pfTkgiDnLoJRr07ztNE98TZCCiTRNFVOoONAxeCR%2FPI%3D=0>).
  I noticed one form of English not mentioned in the Wikipedia article, Texas.

All the best, Doug

PS - The bottom line, every Tom, Dick and Harry should avoid cliché at all 
costs.


--

Douglas E Powell

doug...@gmail.com<mailto:doug...@gmail.com>
http://www.linkedin.com/in/dougp01<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.linkedin.com%2Fin%2Fdougp01=02%7C01%7Cted.eckert%40microsoft.com%7C157229a318354241215908d728277b5c%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C637022022355767142=tPn0HrzHUWBOFgx6tfKnzEQHLALGgDYAVUGzHpDyDIs%3D=0>


--

Douglas E Powell

doug...@gmail.com<mailto:doug...@gmail.com>
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Attachment

Re: [PSES] User Documents & EU Official Languages, Friday Question

[Ted Eckert]

I'll note that even the incorrect use of punctuation can cause confusion in 
standards and regulations. Recently, a missing comma resulted in a $5 million 
legal settlement.
https://www.npr.org/sections/thetwo-way/2018/02/08/584391391/maine-dairy-drivers-settle-overtime-case-that-hinged-on-an-absent-comma

Ted Eckert
Microsoft Corporation

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

From: John Woodgate 
Sent: Friday, August 23, 2019 7:34 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] User Documents & EU Official Languages, Friday Question


You have 'yet to see' because you are setting a very high standard. In your 
example, 'apparatus' without any qualification (I.e. adjective, such as 
'electronic') means 'all apparatus'. 'Includes... or' is strictly wrong simply 
because there are in fact no two cases (like 'apples or pears'). When you ask 
'Is AC powered apparatus included?, the answer is 'Yes'. If you ask 'Is battery 
powered apparatus included?, the answer is also 'Yes'. So 'and' is better.

There are many cases in English usage of small words being chosen wrongly. A 
classic case is 'This is different than that', which should be 'This is 
different from that'. But any difference in real meaning is microscopic at 
most. For example, 'You are taller from me' is wrong (and isn't said anywhere 
in Britain as far as I know); that should be 'than'.

Electrical and electronics engineers are not selected for language skills. 
Amongst that population there is a selection process that puts those with more 
language skills into standards committees, where they become the proactive 
members who do most of the work. Many other members are not proactive and 
prefer not to write anything but just agree or disagree.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7Cba8aba57238b4149a21c08d727d7007c%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C637021676703689572=GZaQrRlfNuMQC5uN0WPt%2FCy5ndixsa9r24dJHuyzqdg%3D=0>

Rayleigh, Essex UK
On 2019-08-23 15:04, Gert Gremmen wrote:

 > I think it would be very difficult to get ambiguous language accepted by 
 > National Committees, the Chairman and Secretary of the committee and the 
 > Central Office editors.

On that topic we do differ in opinion.

I have yet to see a standard which is fully clear, complete and exhaustive and 
precise in its technical specifications.

A simple example from the scope of a recent concept standard:

This document applies to apparatus intended for use in residential, commercial 
and light-industrial
environments as well as to apparatus intended for use in industrial 
environments, and includes AC-, DC-
or battery powered apparatus.

What type of apparatus is included ?

Is the "or" in front of battery correctly used, should it not be "and", or is 
this an example of Euro-English (contextual comprehensible ?), and what would 
lawyers make of this.
--
On 23-8-2019 14:10, John Woodgate wrote:

Yes, of course I know about ISO/IEC Directives Part 2 and CEN/CENELEC IRs Part 
3, but in 2005 when I wrote the document these rules were not widely known (and 
they still aren't known widely enough). What 'makes a difference in a legal 
sense' is a very big subject indeed. How 'creative' is your lawyer? Is that 
'black' or 'very dark white'?

I think it would be very difficult to get ambiguous language accepted by 
National Committees, the Chairman and Secretary of the committee and the 
Central Office editors.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7Cba8aba57238b4149a21c08d727d7007c%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C637021676703689572=GZaQrRlfNuMQC5uN0WPt%2FCy5ndixsa9r24dJHuyzqdg%3D=0>

Rayleigh, Essex UK
On 2019-08-23 12:25, Gert Gremmen wrote:

Hi John,

Great many thank's ;<)

I will study them and use them for the benefit of standardization.

You must be aware of Internal Regulations 3 (CENELEC) that included some of 
your "must", "shall" and similar constructions to use and not use.

Thank you for noticing my own euro-english (must be inspired by your example); 
what i would like to know is if such "errors" create any difference in a legal 
sense.

Many of the to-be-cited-in-the-official-journal harmoni(z)(s)ed standards fail 
because of (intentional?) ambiguous language, plainly confusing constructions 
and sometimes even the -opposite of what is meant- is said, though the meaning 
is clear when read in context (contextual comprehensible ?) Legally some (euro 
english) constructions create problems.

So if anymore has more examples, let them come to this list !

Thank

Re: [PSES] Product safety leading edge

[Ted Eckert]

In my opinion, increasing environmental compliance requirements are putting the 
development of new flame retardants at the forefront of safety technology. We 
are seeing more restrictions on halogenated flame retardants which eliminates a 
lot of the long-standing methods used for plastics. There is also a growing 
demand for manufacturers to use post-consumer recycled materials, which is more 
difficult to do with many flame retardant plastics.

Ted Eckert
Microsoft Corporation

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

From: Dan Roman <0d75e04ed751-dmarc-requ...@ieee.org>
Sent: Friday, July 26, 2019 10:35 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Product safety leading edge

Hazard-based safety engineering rather than strictly prescriptive standards is 
one obvious leading edge change.  There are always technology specific advances 
such as USB power supply output levels.
I'm sure others will have other examples.
--
Dan Roman, N.C.E.
IEEE Senior Member
dan.ro...@ieee.org<mailto:dan.ro...@ieee.org>
dan.n2...@verizon.net<mailto:dan.n2...@verizon.net>
On Jul 26, 2019, at 10:13 AM, David Schaefer 
mailto:david.schae...@element.com>> wrote:
All,


As an EMC engineer I’m aware of new technologies and challenges in EMC testing 
- 5G and IoT, time domain measurements, risk management, millimeter wave, etc.


Idle curiosity made me wonder – what are leading topics on the Product Safety 
side?


Thanks,

[cid:D50E60C78219435D@9ECF52DA712700D9]
David Schaefer
Department Manager, EMC
Element Materials Technology
9349 W Broadway Ave
Brooklyn Park, MN 55445, United States
O +1 612 638 5136 ext. 4003
david.schae...@element.com<mailto:david.schae...@element.com>
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Re: [PSES] Ground on ship

[Ted Eckert]

I agree with Mr. Woodgate.

The issue is whether there is a risk of a voltage between the conductive 
enclosure of a device and exposed conductive materials in the environment. The 
“ground” system only needs to ensure that there won’t be a voltage difference 
between a device’s exposed parts and anything the user can touch in the 
environment. If the metal structure of the ship is used as the “ground” and the 
ground pin of outlets is connected to the metal structure of the ship, and the 
ship’s generator uses the metal structure as a grounding reference, the system 
should function similarly to the grounding system of a properly wired structure 
on solid land.

Ted Eckert
Microsoft Corporation

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

From: John Woodgate 
Sent: Monday, July 8, 2019 11:39 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Ground on ship


'Ground' only means 'the places which we agree have zero volts on them', 
nothing more. So wherever that is, on a ship or an aircraft (or inside an 
appliance with a  2-core power cable), that is 'ground'.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
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Rayleigh, Essex UK
On 2019-07-08 19:19, 
06cee064502d-dmarc-requ...@ieee.org<mailto:06cee064502d-dmarc-requ...@ieee.org>
 wrote:
Hello group,

Is there a real ground in a ship?  i.e if a Class I product is used on the 
board of a ship, does the ground pin actually doing anything? The ship is 
floating in the ocean and I cannot understand if there is a real ground there 
or not? Can you guys educate me please?

Thank you
Peter
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Re: [PSES] Trial of units compliance but without FCC Id

[Ted Eckert]

Hello Daniel,

See 47 CFR 2.803 and 
2.805<https://www.ecfr.gov/cgi-bin/text-idx?SID=34e64287ba99136579e096975f8487d7=true=sp47.1.2.i=div6>
 for the marketing and operation of radio frequency devices prior to 
authorization.

Best regards,
Ted Eckert
Microsoft Corporation

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

From: Rodriguez, Daniel (ESP) 
Sent: Friday, June 21, 2019 6:37 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Trial of units compliance but without FCC Id

Good morning all

There is any FCC rule that allows temporary deploy a limited number of devices 
for customer testing with you FCC Id?. This device has been tested and pass  by 
the lab but is pending of review by the TCB. I mean to conduct a limited trial 
of units that are compliance but without FCC Id label

Thank you for your answer

Kind Regards / Saludos cordiales / Mit freundlichen Grüßen
Daniel Rodríguez

CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may 
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Re: [PSES] Tilt test

[Ted Eckert]

Let me address the question of “how to safely perform this test”.

The proper safety precautions depend on the mass and stability of the 
equipment. Equipment doesn’t have to be too heavy to cause an injury if it 
falls over on somebody. If the equipment is large and/or very heavy, consider 
having it tested at a laboratory that has equipment that can do the test 
safely. If you don’t have that option, think about what precautions may be 
required.

I can give an example of a test I ran at a previous employer. I had to run a 
10-degree tilt test on a standard sized equipment rack loaded to 1500 kg. The 
stabilization feet were down, but they were only about 500 mm apart between the 
two sides of the rack. The rack was a full 2-meter height with the load evenly 
placed in the rack. This should have been done at an external laboratory with 
the proper equipment. However, an NRTL was there to witness testing and they 
insisted in seeing it done that day.

The first mistake was figuring out how to tilt the rack. The solution was to go 
to the parking lot and to get the jack out of the back of a car. The jack was 
designed to lift one wheel of a 1500 kg car, not half of a 1500 kg rack. 
Somehow, the jack survived the test and tilted the rack.

The second mistake was the placement of the test. The rack was about 1 meter 
from a wall and we tilted it towards that wall. It was standard drywall 
construction, and I don’t think it would have stopped the rack if it fell over. 
The people in the office on the other side would have been in for a surprise.

The next mistake was not placing any limitation on the tilt. We could have 
placed straps at the top of the rack to a solid support in the lab. We could 
have limited the tilt to 11 degrees, so that if the rack did start to go over, 
it would have been stopped before it went too far. This probably would have 
also required blocking the stabilization feet to keep them from sliding.

There was an additional error of not properly securing all loads inside the 
rack. The full loading of the rack was simulated using steel plates, but they 
were just held in place by gravity. When the tilt reached 8 degrees, much of 
the weight shifted. We were tilting the rack towards its front, and only the 
latch on the front door kept the plates from sliding out of the rack.

The test was completed without incident, and that was largely due to the 
mechanical engineers designing the product to pass the test. There were still 
plenty of opportunities for things to go wrong. The NRTL engineer left the 
facility happy with the results. Only after that did I realize how poorly 
designed the test setup was.

In summary, think about the worst possible things that could happen during your 
test. Figure out ways to design them out of your test setup. If you can’t 
eliminate a risk, consider taking the product to a facility that can run the 
test more safely. If you are not sure what the hazards may be, consult with 
your facilities Employee Health and Safety (EH) staff.

Ted Eckert
Microsoft Corporation
The opinions expressed do not necessarily reflect those of my current or former 
employers.

This email message may contain confidential and privileged information.  Any 
unauthorized use is prohibited.  If you are not the intended recipient, please 
contact the sender by reply email and destroy all copies of the original 
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From: Frank Tang <0d3fa4ae712a-dmarc-requ...@ieee.org>
Sent: Tuesday, June 11, 2019 1:18 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Tilt test

Hi Engineering community,
I'm trying to find information regard tilt testing, such as minimal tilt angle 
based on system weight, how to safely perform this test, etc; can someone 
direct me to site(s) or standards I can reference?
Google for once isn't helping.

--
Thank you and best regards.
- Frank
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Re: [PSES] Stacking Grounds on a Stud

[Ted Eckert]

Hello Brian,

Let’s start with the easy question first, the order of stacking lugs on a 
single stud. The equipment’s protective earthing conductor should go on the 
bottom and have a lock washer and nut on top of it before any other bonding 
conductors are added. The rationale is that you don’t want service personnel to 
have to remove the main earthing lug to remove any other parts. If the main 
earthing lug is bolted below other lugs, there is a lower risk of it being 
disturbed in any servicing procedure. There is one advantage of placing a lock 
washer and nut over each additional lug added. If two lugs are under the same 
nut, there is a chance that they could rotate against each other loosening the 
nut above them and compromising the connection. I recommend a separate bonding 
stud for each lug if the equipment is expected to require servicing that 
removes bonding conductors to remove parts.

If you have a welded, press fit or similarly fixed stud, you likely do not need 
to mask of the paint or coating around the stud. The flat faces of the nuts 
will make good electrical contact with the grounding lugs and the threads of 
the nut will have good electrical contact with the stud. However, I have had at 
least one NRTL tell me that they wanted the paint masked off in a ring around 
the stud. That NRTL was in the minority. I’ve had differing opinions on whether 
split or star-tooth lock washers are better at cutting through paint, coatings 
or oxidation. I take no position on that, and it shouldn’t matter based on a 
connection through the threads.

Bolts and screws pose a different problem. These may not make as good of 
electrical connection to the chassis. Lock washers that cut through coatings 
and oxidation will likely be required. That being said, I have a personal 
aversion to bolts and screws for bonding. The exception is where there is a 
threaded insert or otherwise set of well formed threads in the chassis where 
the bolt will make a good connection through the threads. Screws are too easy 
to strip out if overtightened, thereby compromising the bonding.

I’m sure these rules are written down somewhere, but I don’t know where that 
would be. I would be interested in knowing, because I assume there are written 
rules somewhere that would tell me that everything I just wrote is wrong.

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

From: Brian Kunde 
Sent: Friday, June 7, 2019 6:10 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Stacking Grounds on a Stud


My question(s) is about stacking ground lugs on a single stud for the 
Protective Earth Terminal inside of a piece of electrical equipment (IT or Lab 
Equipment).

Where is it documented how to properly stack ground lungs?


I have seen this done several ways:

1. A welded stud or just a bolt (#6 or #8 machine screw) pushed through a hole, 
 with the Power Cord Ground Conductor lug stacked FIRST, followed by additional 
lugs. I have seen this with and without locking washers between the lugs.
2. I have seen the above with Nuts or Locking Nuts between each Lug.  This 
method seems much more reliable to me but the nuts take up a lot more space 
limiting the number of lugs that can be stacked.

3. I have seen the above on black oxide, anodized aluminum, or powder coated 
painted metal with not attempt to scrape off the non-conductive material to 
ensure a good bond.



I just evaluated a 3rd party product that had a #6 machine screw pushed through 
a hole in a powder coat painted metal plate with 7 ground lugs and one nut 
holding it all together.  With very little effort, the nut became loose and the 
ground became intermittent.  Yet, this unit has passed an NRTL inspection.


It is my understanding that PE Ground bonds made with a Screws cannot be 
stacked.  One Lug, One Screw.  Is this documented somewhere?

Thanks much for any input.

The Other Brian.
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Re: [PSES] Type F receptacle wiring

[Ted Eckert]

My information on the possibility of polarization comes from an old version of 
IEC 60083 that included the drawing below. This drawing was for Spain, covering 
what must have been a region that used the French plug. IEC 60083 also included 
the more familiar Schuko for Spain. The Wikipedia article linked previously 
states the following. "The French convention changed circa 2002 from nothing 
particular, to, if the earth pin was at the top then the line hole in the 
socket would be on the right looking at the socket." I think I misinterpreted 
the drawing. I originally thought the top part was the plug face. Now that I 
look at the context in the standard, the top drawing is the receptacle. This 
would confirm the Wikipedia statement.

[cid:image002.png@01D4CAC6.52FA2E90]

I always enjoy a discussion on this list server where my knowledge decreases as 
the discussion continues.

Ted Eckert
Microsoft Corporation

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

From: John Woodgate 
Sent: Friday, February 22, 2019 3:22 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Type F receptacle wiring


Look at the text in the Wikipedia link you gave us, under the heading:

CEE 7/5 socket and CEE 7/6 plug (French; Type E)

and the next :

CEE 7/7 plug (compatible with E and F)

Polarization rules!

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
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Rayleigh, Essex UK
On 2019-02-22 23:14, Richard Nute wrote:

Hi Doug:

The French, Belgian, and Schuko domestic connectors are non-polarized.

The British, North American, South Africa, some Japan domestic connectors are 
polarized.

Some domestic connectors in Norway and many in Japan have no PE.

Wikipedia discusses the various plugs and sockets, polarization, and earthing:

https://en.wikipedia.org/wiki/AC_power_plugs_and_sockets<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fen.wikipedia.org%2Fwiki%2FAC_power_plugs_and_sockets=02%7C01%7Cted.eckert%40microsoft.com%7Cfbf7b79a0d724a475b3b08d6991c90bf%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636864745308174012=M%2Bnb9lw65nwZvacXxt2Z8lJ%2Bmun8MNkxYnWWi4lWj%2Bo%3D=0>

See the table near the end for both polarization and earthing.

Appliance couplers are polarized in North America, but not elsewhere.

Best regards,
Rich


F
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Re: [PSES] Type F receptacle wiring

[Ted Eckert]

This is my understanding. If you are looking at the face of the plug, with the 
line and neutral pins pointing at you, and the hole for ground up, neutral 
should be on the left. As such, on the receptacle, with ground at the top, 
neutral should be on the right when looking at the front.

That being said, I would expect it to be highly likely that the receptacles are 
not wired consistently.

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer, LCIE or anybody who has actually wired a French outlet.

From: John Woodgate 
Sent: Friday, February 22, 2019 10:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Type F receptacle wiring


The plug is not reversible in France and Belgium.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7C2cb6a8aac91d445fada408d698f376b9%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636864568775180819=jQd4EPi00Gmlgflm6t6luApDsIDIcM4NKNK0D4nicb8%3D=0>

Rayleigh, Essex UK
On 2019-02-22 18:13, John Allen wrote:
Doug

As I am sure that many others will confirm, that CEE 7 socket does NOT have any 
defined polarity for the Live/Line and Neutral contact tubes, and thus the 
Line/Live and Neutral wires to those contact tubes can & are connected either 
way around according to the “wim” of the installer – unlike N.America and the 
UK (for example) which do have defined polarities for some sockets .

PS: researched this in detail about 20 yrs ago and I am quite sure that the 
situation has not changed since (as it had not changed in the decades before 
that).

John E Allen
W. London, UK

From: Doug Powell [mailto:doug...@gmail.com]
Sent: 22 February 2019 17:48
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Type F receptacle wiring

All,

I am searching for wiring information for the TYPE E CEE7/5, 250 Volt, 16 Amp 
receptacle for France and Belgium.  The earth pin is obvious and for some 
reason, I am unable to find information on the correct pins for Line and 
Neutral.  The receptacle has no makings to this effect.  One resource even says 
the left/right orientation is interchangeable since neutral is considered as 
live. The best I can find indicates neutral is on the left when viewing the 
reception from the front.  True?

Thanks!  -- Doug


Douglas E Powell

doug...@gmail.com<mailto:doug...@gmail.com>
http://www.linkedin.com/in/dougp01<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.linkedin.com%2Fin%2Fdougp01=02%7C01%7Cted.eckert%40microsoft.com%7C2cb6a8aac91d445fada408d698f376b9%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636864568775190832=0YT5fvInK%2Bg2Wb%2BXgbqOWYE9OUe9ePa6VB8o4KcwW9g%3D=0>
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Re: [PSES] New EU enforcement regulations touches on all? product regulations/directives.

[Ted Eckert]

My opinion is that the problem isn't companies that don't follow the current 
regulations. It's because some companies know how to use the current 
regulations all too well. Some companies operate as electronic storefronts for 
many of the products found through their site. The host company is not the 
seller and host company may not even carry the products in their fulfillment 
centers. The supplier ships directly to the customer. The host companies have 
structured their operations to make sure that they are not the manufacturer, 
importer or distributor.

The analogy may be a real estate company that leases out an empty store. If the 
company that leases the store sells noncompliant products, and then that 
retailer shuts down and disappears in the middle of the night, regulatory 
authorities aren't going to go after the property owner that just leased out 
the building.

The difference is that many of the electronic storefronts have their own name 
on the site. If you aren't paying attention, it can be very hard for you, as a 
consumer, to determine if you are purchasing through the company who's name you 
see or a third-party renting the electronic storefront space. A consumer who 
buys a product, and then has a problem, doesn't even know who to go to for 
support. We have a strange situation where the electronic real-estate company, 
the company hosting the electronic storefront, puts their name on that 
storefront. It is that name that consumers see as the seller.

The intent of the change is to place more responsibility on the company that 
display's their name on the electronic storefront. In my opinion, if you want 
to run an electronic storefront, and you want the sellers to be responsible, 
you need to make it clear to consumers that, when they purchase a product, they 
are leaving your site and going to a site for the third-party seller.

My opinion is that the change is an attempt to close loopholes that are 
commonly exploited. For many companies that follow the rules and follow best 
practices, there will be some extra work. For companies that exploit the 
loopholes, there will be a lot of new work. For consumers, there is the 
potential for a significantly improved situation.

This is only what I think is trying to be done. It is my opinion and not the 
opinion of the European Commission. I fully recognize that the EC cannot 
control the law of unintended consequences. By trying to close some loopholes, 
new issues may be created. Creative companies may still find ways around the 
new rules. I'm not arguing that the changes will make things better, and I know 
that there is a chance that it could make things worse. I'm only explaining 
what I think was the intent.

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer or the European Commission.

From: Kunde, Brian 
Sent: Thursday, February 14, 2019 12:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New EU enforcement regulations touches on all? product 
regulations/directives.

I've never understood why some people think that the solution to people not 
following the rules can be solved by creating more rules.  Studies have shown 
the the vast majority of non-compliances are lack of understanding low risk 
rules and not anything that would really hurt someone.  They put out 100 page 
Directives followed up by 1000 page Guides to explain the 100 page Directives 
and still people do not know what is required for Compliance.  Manufacturers 
have no direct interface with the rules makers. We cannot ask questions or ask 
for clarifications so we know how to do the little things correctly.  Then we 
and our products are judged by third party inspectors who wildly interpret the 
requirements to serve their interests and the manufacturer has no other action 
than to bow to their self proclaimed authority.

One of the documents uses the tirm "interlocutor", which was a new one on me, 
so I looked it up.  "a man in the middle of the line in a minstrel show who 
questions the end men and acts as leader."  Sounds like the Three-Stooges to 
me.  Yuck Yuck.

Last Friday I got an email from Amazon Web Services offering me a job as a 
"Senior Hardware Compliacne Manager".  Now it all makes sense.

Smile people.  Retirement is not that far off.

The Other Brian

From: Lauren Crane [mailto:lauren.cr...@us.tel.com]
Sent: Thursday, February 14, 2019 2:10 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] New EU enforcement regulations touches on all? product 
regulations/directives.

Yes, John, it looks like a new type of economic actor is defined to account for 
Amazon type companies, but it also constrains everyone else.

One of the interesting points is a requirement to indicated the REA 
(responsible economic actor) on the product (or in documents etc...). The REA 
has to be an EU person (real or legal)

Re: [PSES] A question about FDA language and interlocking devices

[Ted Eckert]

Hello Doug,

I have only a limited amount of knowledge in this area, and I hope another 
listserv member can either correct me or provide more detail. I also believe 
Mike Sherman may be correct on the knife edge/finger stock description.

The CDRH at the FDA is generally very conservative and they don't update 
requirements often as technology changes. (Their inspection 
guide<https://www.fda.gov/downloads/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/UCM135868.pdf>
 still dates from 1985.) I believe that the restrictions on interlock type is 
based on making it difficult to override the interlock. I do believe that your 
interpretation is correct. The interlocks you show should meet the CDRH 
requirements.

Ted Eckert
Microsoft Corporation

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

From: Doug Nix 
Sent: Tuesday, February 5, 2019 8:36 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] A question about FDA language and interlocking devices

Colleagues,

I had a question come my way yesterday that I need a little help with. Here's 
the question:

I have a customer that produces X-ray equipment. The FDA requires that the door 
that gives access to the X-ray source must have an interlock with a 'knife-edge 
and finger stock' type connection.  Also the FDA mentions that interlocks 
should be of conventional design. What is understood by "conventional design"?

My reading on this requirement is that any conventional electromechanical 
interlocking device like this:
[Image result for keyed interlock switch images]
will meet the basic requirements as described by the FDA as "knife-edge and 
finger stock" connection, but I am concerned that this may not be at all what 
is meant.

As always, any guidance you can offer will be welcomed and appreciated!

Best,

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

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Re: [PSES] Red phosphorus flame retartants

[Ted Eckert]

This is an anecdote and not data, but I can speak of the reliability issue from 
personal experience. I don’t remember exactly when this occurred, but it was 
around 2005. A supplier of power cords was using red phosphorus as the flame 
retardant in a plastic part for the IEC 60320-C13 connector on a power cord. 
The phosphorous was in the rigid plastic part that supported the contacts with 
the softer material molded over this material. The phosphorus was not well 
stabilized in the plastic. Moisture led to the chemical reaction described by 
Mr. Woodgate, resulting in phosphoric acid. The acid attached the contact 
material leading to a increase in the resistance of the contact. This occurred 
in products that used close to the full current rating of the connector, 
running close to 10 A. There was enough heating in the connector that the 
overmold material n the C13 swelled up to the point where the connector could 
no longer be removed from the mating C14 connector.

This did not cause a safety issue. Temperatures remained low enough that there 
was no ignition. This happened on industrial products in an environment where 
there were no flammable materials in the vicinity of the connectors. It only 
resulted in a reliability issue where there the electrical connection 
eventually was lost and the detachable cord was no longer detachable.

The final analysis determined that the supplier of the plastic part using the 
phosphorous didn’t have sufficient quality control to ensure that the 
phosphorous was properly encapsulated. Supply chains have become more 
complicated since then. Quality control and supply chain management are 
critical to avoid similar issues.

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
current employer, previous employer or the manufactures or power cords and 
connectors.

From: Adam Dixon 
Sent: Wednesday, January 2, 2019 7:12 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Red phosphorus flame retartants

I agree that it's an older paper, but the data are still relevant IMO.  Here 
are a few more recent ones from different US gov't organizations with a 
pyrology focus (so not solely focused on Scott's original question, but still 
informative):

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5445781/<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.ncbi.nlm.nih.gov%2Fpmc%2Farticles%2FPMC5445781%2F=02%7C01%7Cted.eckert%40microsoft.com%7C848549be33cc46a789f608d670c4cbd8%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C636820387889239646=khPIVM4MtaFuyvZVKByb%2FeS5bwkjXLf01HImUBIZNhE%3D=0>

https://www.epa.gov/sites/production/files/2015-08/documents/pcb_ch1.pdf<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.epa.gov%2Fsites%2Fproduction%2Ffiles%2F2015-08%2Fdocuments%2Fpcb_ch1.pdf=02%7C01%7Cted.eckert%40microsoft.com%7C848549be33cc46a789f608d670c4cbd8%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C636820387889249672=kgKdCKQyxu%2BseBaIajAgmrVdPglUneXVgnPb2lCv2y4%3D=0>
 (I think the EPA info has been shared on the list previously - just substitute 
2 through 7 at the end of the URL to get all chapters).

https://www.fire.tc.faa.gov/<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.fire.tc.faa.gov%2F=02%7C01%7Cted.eckert%40microsoft.com%7C848549be33cc46a789f608d670c4cbd8%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C636820387889259671=FJz%2BmtzOZBSnYcD%2FQH%2FeYQvHr5RTubCS3jrxTNkRMGM%3D=0>
https://www.fire.tc.faa.gov/pdf/05-14.pdf<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.fire.tc.faa.gov%2Fpdf%2F05-14.pdf=02%7C01%7Cted.eckert%40microsoft.com%7C848549be33cc46a789f608d670c4cbd8%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C636820387889259671=xBa%2BlI6uqxwD2Nr0pctLMeoNsYhmr19nnmnv%2BZxASzc%3D=0>
  (2005, so not quite as recent)



Cheers,
Adam in Atlanta
adam.di...@ieee.org<mailto:adam.di...@ieee.org>



On Wed, Jan 2, 2019 at 2:31 AM John Woodgate 
mailto:j...@woodjohn.uk>> wrote:

It is a good paper, but the sentence:

The European Union's risk assessment of TBBPA is currently ongoing and will not 
be completed until 2003 [9]

indicates that it is not exactly up-to-date.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7C848549be33cc46a789f608d670c4cbd8%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C636820387889269675=yH4l%2BM%2F2naEyMXS8XVztiCV4fXCRPmUXCEjPpBERvjE%3D=0>

Rayleigh, Essex UK
On 2019-01-02 00:16, Adam Dixon wrote:
Here's a good article focused on component reliability with some discussion of 
how red phosphorus is produced and comparison to several alternate fire 
retardant chemistries:

https://www.dfrsolutions.com/red-phosphorus-induced-failures-in-encapsulated-circuits<https://nam06.safelinks.protection.outloo

Re: [PSES] Japanese manis leads

[Ted Eckert]

Hello John,

The vast majority of single-phase electrical outlets in Japanese residential 
and commercial installations have no protective earth. Most products sold in 
Japan are Class II. Outlets with protective earth are typically only found in 
industrial applications in Japan.

Best regards,
Ted Eckert

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

From: John Woodgate 
Sent: Friday, December 7, 2018 2:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Japanese manis leads


In Japan, are 3-core (L, N, PE) mains leads widely used for single-phase 
products or are the majority of products safety Class II, with just L and N?

--

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7Cf031db8544524b5c8d5508d65c326e45%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636797769013214049=QRLcFfPrJhI%2BCzAHi6DY6mUlS6JiHPL3PzVF3Ho7XDA%3D=0>

Rayleigh, Essex UK
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Re: [PSES] Glow wire tests

[Ted Eckert]

Hello Scott,

I don’t know the exact basis for the determination of which test is run. I know 
the basics of the glow wire standard, but not the details.

Regards,
Ted Eckert
Microsoft Corporation

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

From: Scott Xe 
Sent: Tuesday, November 27, 2018 12:40 AM
To: Ted Eckert 
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Glow wire tests

Dear Ted,

Thanks for your useful guidance!  What is the definition of medium and higher 
energies?  I notice the safety standard determines the test voltage using the 
spacing between electrical conductors and plastic.  Is there any relationship 
in between?

Regards,

Scott

On Thu, 22 Nov 2018 at 02:01, Ted Eckert 
mailto:ted.eck...@microsoft.com>> wrote:
Hello Scott,

There are two different approaches to testing materials for flammability 
ratings. UL 94 determines what happens when plastics are ignited. It determines 
how material burn and whether they self- extinguish. These tests are based on 
the assumption that the material will ignite and then see how the material 
burns. The tests look at the rate of flame spread, dripping particles and other 
factors.

The glow wire test takes a different approach. It determines how easy or hard 
it is to ignite a material in the first place. A material may burn easily, but 
if it’s extremely hard to ignite, the rate at which it burns might not be an 
issue. Magnesium is used as a light-weight material for IT products, engine 
blocks and high-performance automobile wheels. Once it is ignited, it burns 
rapidly and releases a lot of energy. However, it’s very hard to ignite solid 
metallic magnesium in the first place.

In summary, some standards are concerned with whether or not a material ignites 
easily and then don’t test how well they burn after they are ignited. Materials 
that don’t ignite easily are accepted. Other standards only test how materials 
burn. If materials don’t burn quickly and resist flame spread, the standard 
doesn’t test how easily they ignite. They address the same problem through 
different approaches.

The different temperatures for glow wire tests represent different ignition 
sources. One is a medium energy source and the other a higher energy source. 
Materials that resist the higher temperature are considered harder to ignite.

Ted Eckert
Microsoft Corporation

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

From: Scott Xe mailto:scott...@gmail.com>>
Sent: Wednesday, November 21, 2018 8:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Glow wire tests

I notice in safety test standards that the plastic enclosure is required to 
pass glow wire test.  What does this test for?  There are commonly two 
conditions: 550 or 750 degC.  What are the differences and what does each 
represent its capabilities?  I am new to this requirement and appreciate your 
decent explanation.

Thanks and regards,

Scott
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Re: [PSES] Glow wire tests

[Ted Eckert]

Hello Scott,

There are two different approaches to testing materials for flammability 
ratings. UL 94 determines what happens when plastics are ignited. It determines 
how material burn and whether they self- extinguish. These tests are based on 
the assumption that the material will ignite and then see how the material 
burns. The tests look at the rate of flame spread, dripping particles and other 
factors.

The glow wire test takes a different approach. It determines how easy or hard 
it is to ignite a material in the first place. A material may burn easily, but 
if it’s extremely hard to ignite, the rate at which it burns might not be an 
issue. Magnesium is used as a light-weight material for IT products, engine 
blocks and high-performance automobile wheels. Once it is ignited, it burns 
rapidly and releases a lot of energy. However, it’s very hard to ignite solid 
metallic magnesium in the first place.

In summary, some standards are concerned with whether or not a material ignites 
easily and then don’t test how well they burn after they are ignited. Materials 
that don’t ignite easily are accepted. Other standards only test how materials 
burn. If materials don’t burn quickly and resist flame spread, the standard 
doesn’t test how easily they ignite. They address the same problem through 
different approaches.

The different temperatures for glow wire tests represent different ignition 
sources. One is a medium energy source and the other a higher energy source. 
Materials that resist the higher temperature are considered harder to ignite.

Ted Eckert
Microsoft Corporation

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

From: Scott Xe 
Sent: Wednesday, November 21, 2018 8:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Glow wire tests

I notice in safety test standards that the plastic enclosure is required to 
pass glow wire test.  What does this test for?  There are commonly two 
conditions: 550 or 750 degC.  What are the differences and what does each 
represent its capabilities?  I am new to this requirement and appreciate your 
decent explanation.

Thanks and regards,

Scott
-


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htt

Re: [PSES] NRTL approval

[Ted Eckert]

As far as I am aware, the lower voltage limit will not be removed from the Low 
Voltage 
Directive.<http://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/low-voltage/>
 That being said, a significant fraction of products include Bluetooth, Wi-Fi 
or other radios, thereby placing them under the Radio Equipment Directive 
(RED). The RED requires products to comply with the essential requirements of 
the Low Voltage Directive and the RED does so without the lower voltage limit. 
If Ian McBurney's product does not include any radios, I believe that he is 
entirely correct that the Low Voltage Directive does not apply and the General 
Product Safety Directive would apply for safety.

The OSHA question is a bit more complicated. OSHA's requirements are not 
mandatory for a product to be sold in the United States. They are mandatory for 
most businesses in the U.S. and the requirement apply to the products used by 
those businesses. Most electrical codes in the U.S. also require electrical 
products to either be Listed or they need to be deemed acceptable by the 
Authority Having Jurisdiction (AHJ).

For residential applications, the AHJ will typically only review products that 
are field wired and/or attached to building structure. Plug connected products 
are not likely to be reviewed by the AHJ because they are not likely to be 
present at the time of inspection. There is also the consideration that 
insurance companies may include requirements for NRTL 
Listing<https://www.osha.gov/dts/otpca/nrtl/> for plug-connected products, and 
these insurance companies may use this as justification for rejecting a claim 
if a non-certified product is determined to be the cause of an incident. 
However, I personally have never run into a case where either an AHJ or 
insurance company enforced this requirement for USB powered devices.

Although the OSHA mandate for businesses can be read broadly, I have also never 
heard of either an OSHA inspector or a corporate purchasing policy that 
required NRTL Listing on USB powered devices. I'm sure you could find a USB 
powered device that is NRTL Listed, but It has been a long time since I have 
seen NRTL certification for a thumb drive, USB dongle or other USB device. You 
may find NRTL Listing on USB mice and keyboards, but this may be for other 
reasons. If a manufacturer is selling a UL Listed computer, and the manufacture 
includes a USB mouse and keyboard in the retail package, UL would likely 
require that mouse and keyboard to be UL Listed Accessories. This, however, is 
UL's requirement that all accessories shipped with a UL Listed product must 
also meet UL requirements. It is not necessarily based on OSHA or electrical 
codes.

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer, the European Commission, OSHA, the Department of Labor or the 
International Association of Electrical Inspectors.

From: Joe Randolph 
Sent: Tuesday, November 13, 2018 5:12 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] NRTL approval

Hi Ian:
I have a vague recollection that the lower voltage limit either has been, or 
will be, withdrawn in the EU.  The change may be specifically related to the 
use of EN 62368-1, but I can't recall where I saw it.


Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848 (USA)
j...@randolph-telecom.com<mailto:j...@randolph-telecom.com>
http://www.randolph-telecom.com<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.randolph-telecom.com=02%7C01%7Cted.eckert%40microsoft.com%7C667c36d478844f995bee08d64969a352%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636777115401969796=evx1afapCfgq8Im5GwSyrIzvm%2Bc5%2BUBv9W%2BrNGjYGi0%3D=0>

From: McBurney, Ian [mailto:ian.mcbur...@allen-heath.com]
Sent: Tuesday, November 13, 2018 4:27 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] NRTL approval

Dear colleagues.

We are in the process of designing a USB bus powered audio product around 2.5W 
for professional/consumer use.
The product enclosure will be UL94 5VA flammability rated plastic.
Will this product have to be NRTL approved for sale in the USA/Canada?
The EU LVD doesn't apply because of the supply voltage is only 5V DC. The GPSD 
probably will!

Many thanks in advance.

Ian McBurney
Lead Compliance Engineer.

Allen & Heath Ltd.
Kernick Industrial Estate,
Penryn, Cornwall. TR10 9LU. UK
T: 01326 372070
E: ian.mcbur...@allen-heath.com<mailto:ian.mcbur...@allen-heath.com>


Allen & Heath Ltd is a registered business in England and Wales, Company 
number: 4163451. Any views expressed in this email are those of the individual 
and not necessarily those of the company.
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This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to

Re: [PSES] Does incorporated barcode scanner result in a new laser product?

[Ted Eckert]

I never said that the initial report would be easy. I only indicated that it 
would be simplified with proper test data from the manufacturer of the laser. 
If the laser manufacturer can provide a detailed report, the initial CDRH 
submittal shouldn't be too bad. I also didn't state that the annual report 
would be hard. I only indicated it would be a hassle. It is an unnecessary 
process in my opinion. The CDRH doesn't approve submittals and only sends out 
an acknowledgement that they received it. I have no evidence, but I suspect 
they spend even less time handling the annual reports. To me, sending in an 
annual report that will likely get filed away without any useful purpose makes 
the filing a hassle. It's quick and easy and doesn't take much time, but if 
it's useless to everybody, get rid of the requirement and save everybody the 
work. However, the FDA still hasn't finalized Laser Notice 56 and they are 
years behind on IEC 60825-1 3rd Edition. I wouldn't expect them to make 
progress on updating something more basic to the process of how they work.

Ted Eckert
Microsoft Corporation

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


From: Nyffenegger, Dave 
Sent: Monday, October 8, 2018 5:04 PM
To: Ted Eckert ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Does incorporated barcode scanner result in a new laser 
product?

The annual report is pretty basic, just requires some basic production record 
keeping along with any documented product issues.  The initial product report 
and any follow-up supplementary reports are a lot of work.

-Dave

From: Ted Eckert [mailto:07cf6ebeab9d-dmarc-requ...@ieee.org]
Sent: Monday, October 08, 2018 2:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Does incorporated barcode scanner result in a new laser 
product?

Hello Lauren,

As far as I am aware, the FDA only has reduced reporting and recordkeeping 
requirements if you incorporate a Class I laser into your product. Laser Notice 
54 gives some additional information, but the intention is that a computer 
manufacturer doesn't have to do extra work if they include a DVD drive made by 
another company. Your initial CDRH submittal may be simplified if the provider 
of your Class II laser can provide a test report or an existing Accession 
Number. The annual reporting requirements will likely still be a hassle.

Ted Eckert
Microsoft Corporation

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

From: Lauren Crane mailto:lauren.cr...@us.tel.com>>
Sent: Monday, October 8, 2018 9:51 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Does incorporated barcode scanner result in a new laser 
product?

John,

I tend to agree with you, but I've been fighting regulatory dragon's long 
enough to know there can sometimes be fine point details or 'special scenarios' 
I am not aware of. It never hurts only hurts a little to ask.

-L

From: John Woodgate mailto:j...@woodjohn.uk>>
Sent: Monday, October 08, 2018 11:15 AM
To: TEH EHS Crane, Lauren 
mailto:lauren.cr...@us.tel.com>>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Does incorporated barcode scanner result in a new laser 
product?


Little guidance, perhaps, because there is little reason to suppose 'no' is a 
possible answer.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7CTed.Eckert%40MICROSOFT.COM%7Cbea349c579b94474d12408d62d7abc5e%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636746402523036604=hJ2%2FAs7%2BfDwZbEfsmDPcXYwCvjf75VP0i4AOkoiwpPw%3D=0>

Rayleigh, Essex UK
On 2018-10-08 16:48, Lauren Crane wrote:
I'm not sure this is the correct forum for this question

Does incorporating a barcode scanner (that happens to be a class II laser 
product) into a piece of industrial machinery (e.g., for the purpose of reading 
identification tags on work pieces) that otherwise does not contain a laser 
result in a new, reportable laser product under US CDRH requirements?

I'm leaning towards 'yes', but I cannot find much guidance on the issue.

Regards,
Lauren Crane
Tokyo Electron

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

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Re: [PSES] Does incorporated barcode scanner result in a new laser product?

[Ted Eckert]

Hello Lauren,

As far as I am aware, the FDA only has reduced reporting and recordkeeping 
requirements if you incorporate a Class I laser into your product. Laser Notice 
54 gives some additional information, but the intention is that a computer 
manufacturer doesn't have to do extra work if they include a DVD drive made by 
another company. Your initial CDRH submittal may be simplified if the provider 
of your Class II laser can provide a test report or an existing Accession 
Number. The annual reporting requirements will likely still be a hassle.

Ted Eckert
Microsoft Corporation

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

From: Lauren Crane 
Sent: Monday, October 8, 2018 9:51 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Does incorporated barcode scanner result in a new laser 
product?

John,

I tend to agree with you, but I've been fighting regulatory dragon's long 
enough to know there can sometimes be fine point details or 'special scenarios' 
I am not aware of. It never hurts only hurts a little to ask.

-L

From: John Woodgate mailto:j...@woodjohn.uk>>
Sent: Monday, October 08, 2018 11:15 AM
To: TEH EHS Crane, Lauren 
mailto:lauren.cr...@us.tel.com>>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Does incorporated barcode scanner result in a new laser 
product?


Little guidance, perhaps, because there is little reason to suppose 'no' is a 
possible answer.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7C1c92841537674ec4ab7408d62d4079a0%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636746152287382780=vUiXYrOrayVHzr2fgCHMse6QXWTT2snLVNxphnJxnNI%3D=0>

Rayleigh, Essex UK
On 2018-10-08 16:48, Lauren Crane wrote:
I'm not sure this is the correct forum for this question

Does incorporating a barcode scanner (that happens to be a class II laser 
product) into a piece of industrial machinery (e.g., for the purpose of reading 
identification tags on work pieces) that otherwise does not contain a laser 
result in a new, reportable laser product under US CDRH requirements?

I'm leaning towards 'yes', but I cannot find much guidance on the issue.

Regards,
Lauren Crane
Tokyo Electron

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Re: [PSES] My update and tracking services

[Ted Eckert]

I would also recommend working with your industry trade association. Many of 
these trade groups are active at tacking regulatory changes on behalf of their 
members. If you are a member of one of these trade association, check with them 
to see what is available.

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer or IARPREL (International Association of Random People who Respond to 
Email Listservers).

From: Lauren Crane 
Sent: Thursday, October 4, 2018 2:34 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] My update and tracking services

Hello All,

This is great. Thanks for sharing.

Two extra points.

The EU’s WTO TBT portal is a much more user friendly service than NIST. Sign up 
at 
http://ec.europa.eu/growth/tools-databases/tbt/en/tbt-and-you/being-informed/mailing-list/subscribe-to-mailing-list/<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fec.europa.eu%2Fgrowth%2Ftools-databases%2Ftbt%2Fen%2Ftbt-and-you%2Fbeing-informed%2Fmailing-list%2Fsubscribe-to-mailing-list%2F=02%7C01%7Cted.eckert%40microsoft.com%7Cf2347aa299bb4ec5777908d62a45f1c3%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636742877254139462=M5TXN8Fg77oWaVHuIxCaP6DnRC2FmplUMFFX0Pnggy0%3D=0>
One of the nice things they do is create a separate web page for each 
notification where information is aggregated as it develops such as This 
One<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fec.europa.eu%2Fgrowth%2Ftools-databases%2Ftbt%2Fen%2Fsearch%2F%3Ftbtaction%3Dsearch.detail%26Country_ID%3DEU%26num%3D433%26dspLang%3Den%26basdatedeb%3D17%2F12%2F2016%26basdatefin%3D30%2F12%2F2016%26baspays%3D%26basnotifnum%3D%26basnotifnum2%3D%26bastypepays%3DANY%26baskeywords%3D=02%7C01%7Cted.eckert%40microsoft.com%7Cf2347aa299bb4ec5777908d62a45f1c3%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636742877254149470=1nv0Qk5TT4hw1xAlsZD8hmtsvVpa9R%2FD4kjqIC9%2FVYg%3D=0>
 for efficiency requirements of displays.  They do this for all WTO TBT 
notifications, not just the ones related to EU regulations, such as This 
One<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fec.europa.eu%2Fgrowth%2Ftools-databases%2Ftbt%2Fen%2Fsearch%2F%3Ftbtaction%3Dsearch.detail%26Country_id%3DUSA%26num%3D1269%26dspLang%3DEN%26basdatedeb%3D%26basdatefin%3D%26baspays%3DHUN%26basnotifnum%3D30%26basnotifnum2%3D%26bastypepays%3D%26baskeywords%3D%26CFID%3D843404%26CFTOKEN%3Dee15f8865d86df84-1EE43512-FD7B-4F4D-CFB78F1707E1FD00=02%7C01%7Cted.eckert%40microsoft.com%7Cf2347aa299bb4ec5777908d62a45f1c3%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636742877254159483=X%2Blgd9bKPO0b1wo1HZOkikZXyNWZhWx2Sjqfn9rhb4c%3D=0>
 related to FCC actions.

And NIST just informed me of a new service that also reports WTO TBT actions 
called ‘ePing’. You can sign up for ePing here:  
http://www.epingalert.org/en<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.epingalert.org%2Fen=02%7C01%7Cted.eckert%40microsoft.com%7Cf2347aa299bb4ec5777908d62a45f1c3%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636742877254169487=mDZQDleb7qChfDuIVIN97dzT5sS9VVGTKSN87queGgE%3D=0>


Regards,

Lauren Crane
Tokyo Electron

From: Grasso, Charles mailto:charles.gra...@dish.com>>
Sent: Thursday, October 04, 2018 4:00 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] My update and tracking services

Valuable stuff – Thanks guys!

From: Scott Aldous [mailto:0220f70c299a-dmarc-requ...@ieee.org]
Sent: Thursday, October 04, 2018 11:48 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] My update and tracking services


 This message originated outside of DISH and was sent by: 
owner-emc-p...@listserv.ieee.org<mailto:owner-emc-p...@listserv.ieee.org>
Thanks, Doug!

A few others related to recalls:

  *   Canada recalls: 
http://healthycanadians.gc.ca/recall-alert-rappel-avis/index-eng.php<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fhealthycanadians.gc.ca%2Frecall-alert-rappel-avis%2Findex-eng.php=02%7C01%7Cted.eckert%40microsoft.com%7Cf2347aa299bb4ec5777908d62a45f1c3%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636742877254169487=CEp82bPFZv2PN6lT9CnaiLIq8Qn52H1qzggn9pQDMzU%3D=0>
  *   EU RAPEX Alert Search: 
https://ec.europa.eu/consumers/consumers_safety/safety_products/rapex/alerts/?event=main.search<https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fec.europa.eu%2Fconsumers%2Fconsumers_safety%2Fsafety_products%2Frapex%2Falerts%2F%3Fevent%3Dmain.search=02%7C01%7Cted.eckert%40microsoft.com%7Cf2347aa299bb4ec5777908d62a45f1c3%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636742877254179500=%2Btjt5gVq53WIQnkVzgbBsjUXkBmQfxpv%2FBk4bMUfPiw%3D=0>
  *   METI (Japan) Product Safety Page, includes recall notifications: 
http://www.meti.go.jp/english/policy/economy/consumer/index.html<https://na01.safelinks.protection.outlook.co

Re: [PSES] Regulation 2017/1369 Energy Labelling

[Ted Eckert]

Hello Scott,

Have you looked at the European Commission’s EuP page?
https://ec.europa.eu/energy/en/topics/energy-efficiency/energy-efficient-products

In general, products that currently require labeling will continue to require 
labeling. Some products that may come into scope, such as computer monitors, 
may require labeling. Products that are outside of the scope of labeling, such 
as computers, are likely to remain outside of the scope of the labeling 
requirements.

My understanding is that each product type is being handled separately. While 
almost all of the product efficiency requirements are being updated, the 
progress on each will differ based on the work of the individual groups. As 
such, you would likely need to follow specific products types of concern to 
find out what the likely schedule will be. I am not aware of an overall 
schedule for all products.

Ted Eckert
Microsoft Corporation

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

From: Scott Xe 
Sent: Tuesday, September 18, 2018 10:04 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Regulation 2017/1369 Energy Labelling

In order to support this new energy labelling regulation, the corresponding 
delegated regulations and ecodesign regulation for each EuP will be published.  
The first 3 EuPs said to be refrigerating appliances, washing machines and 
dishwashers.  Where can we find the draft regulations and the road map of 
implementation for ref?

Thanks and regards,

Scott
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Re: [PSES] need some advice on cancellation policy for a seminar

[Ted Eckert]

Hello Doug,

I don’t know if this falls under the same business laws as retail transactions. 
If it does, it is still complicated because it depends on which state has 
jurisdiction. Most states, such as Nevada, give the purchaser no right to a 
refund. It is up to the retailer to set a refund policy and follow it. If the 
seller has no published policy, no refund is required. California allows a 
retailer to follow a clearly published refund policy. If they have no policy, 
they must refund customers within 30 days of purchase. Beyond 30 days, no 
refund is required.

I am not a lawyer and I am not offering legal advice. I can’t tell you if you 
follow the law where you live, where the seminar is held or where the customers 
were when they paid for the seminar. I don’t even know if your situation falls 
under the same laws as for a retail transaction at a store.

I wish you luck in resolving this issue and I hope the lawyers don’t need to 
get involved.

Regards,
Ted Eckert
The opinions expressed are my own and do not necessarily reflect those of my 
employer, the American Bar Association or RILA<https://www.rila.org/>.


From: Doug Smith 
Sent: Friday, September 14, 2018 3:17 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] need some advice on cancellation policy for a seminar

John,

If they were a customer I would just refund the amount. I would normally just 
let them come to the next or any event (even though it would cost me two of six 
registrations for the future event). But they do not want to do that.

I have classrooms available to me at no cost of 6, 20, and 100 people but I 
choose to do small seminars. Large ones are not nearly as useful to the 
attendees as small ones. If this were a group of 20, I would just refund.

So, I will just start marketing the next few weeks and see what happens. If two 
more sign up I will just refund. I will probably not allow the company that 
cancelled to come to my events in the future without special arrangements 
compared to others.

Doug
[https://hostingemail.xo.com/api/storage/d...@emcesd.com/signatures/images/2476c205-f457-4395-87cc-7aa199c734f2]


On Fri, 14 Sep 2018 22:50:03 +0100, John Woodgate wrote:

I guess you don't have a cancellation policy in your T No doubt you will 
fix that, as a result of this experience. If you don't want to lose the 
customer, and maybe get bad music on social media, let them come to a future 
event at no extra charge.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7Cad2c2b87192845c70a0908d61a8fe695%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636725602691262192=RUikJgNUyF99stdCYjwRm3rBwiyVZpE1xKhw%2BlO38Y4%3D=0>

Rayleigh, Essex UK
On 2018-09-14 21:51, Doug Smith wrote:
Hi Everyone,

I need some advice on a pair of cancelled registrations for a class I am 
holding next month. Two people from the same company registered and the company 
paid the registration fees. At that point the seminar was full (I limit it six 
people for a good experience) so I stopped marketing activities for the last 
week and a half. Then a manager higher up decided there will be no travel and 
now they want a refund. At this point, it is not likely, although possible, 
that two people additional people will register as time is short to get the 
required approvals. I have about an hour of work on each registration invested 
at this point for a total of two hours plus that much time to register and 
arrange for two different people if the register. Part of my time is making 
hotel reservations as the hotel and most meals are covered in the registration 
fee. Issuing a refund is a fair amount paperwork and record keeping, probably 
about an hour total for both. Basically, to save a few hundred dollars this 
company wants to cost me almost 10X that if I cannot fill the two seats (of 
six).

The problem is the no travel policy. I use Las Vegas McCarrann airport which 
must be the cheapest airport in the world because of being a vacation 
destination. I can fly to California for less than the cost of gas to drive 
there in a car ($49 ticket on SouthWest). The cost of their tickets should be 
about $300 or less per person round trip from their location compared to about 
$2000 per person already paid.

What do others do for a cancellation policy? In the past, I let someone come to 
a future delivery for no extra charge. In that case, the person had a personal 
reason for not being able to come. I try to be good to people as with the 
person just described plus I let unemployed engineers come at about to my cost 
if I have empty seats.

What would you do? I could use some advice.

Doug
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This message is f

Re: [PSES] Safety Test Templates Question

[Ted Eckert]

Does the testing involve Schroedinger’s cat?

Ted Eckert
Microsoft Corporation

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

From: Kevin J Harris 
Sent: Thursday, August 2, 2018 10:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Safety Test Templates Question

Hello

On test templates from several laboratories I have noticed where they indicate 
whether or not a particular test was successful or not, that there is an 
arrangement of text such as this

Conforms:Y □N  □
Non-Conforms:  Y □N  □

Is there a technical or legal reason behind this sort of double statement?


Thanks

Kevin

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

Website: 
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Re: [PSES] IET BS 7671:2018 vs USA National Electrical Codes (NEC)

[Ted Eckert]

Hello Vincent,

The following link is old, but it is still a reasonable comparison of the U.S. 
and European codes and installation requirements.
https://www.nema.org/Standards/ComplimentaryDocuments/nec-iec60364.pdf

Ted Eckert
Microsoft Corporation

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

From: Vincent Lee <08e6c8d35910-dmarc-requ...@ieee.org>
Sent: Monday, July 30, 2018 2:34 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] IET BS 7671:2018 vs USA National Electrical Codes (NEC)

Hi all,

Good evening,

1) With the publication of  IET BS 7671:2018, may I know what are the major 
differences between IET BS 7671:2018 and its 2008 version?


2) Apart from voltage rating of 120Vrms vs 230Vrms, how does USA National 
Electrical Codes (NEC) different from IET BS 7671?


3) Do USA NEC and IEC BS 7671 mutually accept each other ?


Hope to hear from you soon. Thank you.
Vincent


Regards, Vincent
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Re: [PSES] PS1 limit?

[Ted Eckert]

Hello Brad,

I recommend getting a copy of IEC TR 62368-2. It is the rationale document for 
IEC 62368-1 and it will provide history, rationale and additional information 
on this and other requirements of the standard. The short answer is that the 15 
W limit has been used as a limit in other IEC standards. The 3 second time was 
selected for ease of measurement. Times as short as 100 ms and as long a 5 
seconds were considered.

Best regards,
Ted Eckert
Microsoft

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

From: Willard, Bradley 
Sent: Thursday, July 26, 2018 2:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] PS1 limit?

Hello Everyone,

I'm looking for guidance on how the PS1 limit of 15 watts for 3 seconds in IEC 
62368-1 was determined.

Thanks in advance!

Best regards,
Brad



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Re: [PSES] Safety design of shutter opening

[Ted Eckert]

Would the standards committee come up with different shutter requirements for 
extension cables? Is placing the plug in the outlet upside down common on 
extension cables? I still content that this connection method is unlikely to 
happen as “accidental”. My contention is that standards committees do try to 
reduce the risk of hazards from misuse, but there are limits to what is 
practical.

I guess some of Rich Nute’s comments from years ago have stuck in my head. 
Where is the line between a fault condition and intentional misuse? Show me 
evidence that placing the plug in the outlet upside down happens accidentally 
and I may consider it a condition where additional safeguards might be 
warranted.

Ted Eckert
Microsoft

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

From: John Woodgate 
Sent: Tuesday, July 17, 2018 12:31 PM
To: Ted Eckert ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety design of shutter opening


You have misunderstood. The effect occurs with extension cables, usually fitted 
with four sockets in a line. It does not occur with wall sockets, even 
surface-mounted, because the sockets are large enough to prevent it.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7CTed.Eckert%40MICROSOFT.COM%7C3a87d68523484a53947908d5ec1bd3de%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C636674526626698531=KmKQVRNJ%2F95BRbunvrmk30SEOVJA3C9h3J%2FsAvvJ4GQ%3D=0>

Rayleigh, Essex UK
On 2018-07-17 18:53, Ted Eckert wrote:

I would go one step further than Mr. Woodgate.

Inserting a BS 1363 plug into an outlet backwards is a challenge. The ground 
pin is longer than the line and neutral pins, but not that much longer. You 
cannot fully insert the ground pin into the outlet “backwards” because the line 
and neutral pins will hold the plug away from the face of the outlet. If you 
can get the plug to stay in that position, it would be held in lightly at best. 
In many case, the weight of the plug and cord would likely pull it out of the 
outlet due to the limited engagement of the ground pin. Further, whatever 
device was plugged in won’t turn on because it won’t have power. It seems to me 
that it would be extremely unlikely that somebody would “accidentally” put the 
plug in backwards and leave it there for an extended period of time.

I agree that the shutter mechanism can be defeated. However, I see it as being 
very unlikely to happen accidentally. The standards committees are trying to 
prevent foreseeable misuse, but there is only so much you can do to prevent 
people who want to intentionally defeat a safeguard.

Ted Eckert
Microsoft

The opinions expressed are my own and do not necessarily reflect those of my 
employer or the Society of People Who Like to Put Metal Objects in Outlets 
(SPWLPMOO).

From: John Woodgate mailto:j...@woodjohn.uk>>
Sent: Tuesday, July 17, 2018 4:11 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Safety design of shutter opening


Well, strictly, an electric shock incident would be a 'two-fault' situation - 
plug reversed AND conducting object inserted into the live socket. In general, 
two-fault situations are almost impossible to avoid but luckily also occur very 
rarely.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7CTed.Eckert%40MICROSOFT.COM%7C3a87d68523484a53947908d5ec1bd3de%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636674526626698531=dMPefVH2%2FAXT6%2FBt2uTk%2BFUKx%2FUwa%2ByBOQnxyZGXaGE%3D=0>

Rayleigh, Essex UK
On 2018-07-17 10:58, Scott Xe wrote:
Hi Pete,

Thanks for your view!  Firstly I dare to say it is not a new issue since I have 
read some reviews with this concern in the past plus a quick search of products 
available on the market showing some models in exist.  I do believe the 
standard committee and manufacturers are well aware of it.  It must have a 
reason to be tolerated or in a lower priority.  This forum has lots of expert 
and senior and looking for their enlightenment or common alignment.

Regards,

Scott


On Tue, 17 Jul 2018 at 01:26, Pete Perkins 
mailto:peperkin...@cs.com>> wrote:
Scott,

In watching this thread it is clear that the technical 
assessment and the regulatory certification are two separate issues but linked 
by local law so we need to be cognizant of the regulatory environment.

The technical assessment (per the standard) is organized by an 
ongoing group of (fallible) folks who work very hard to cover all of the risks 
(usually) from the product manufacturers point of view (since they seem to 
dominate the technical committees).  Since the requirements are usually written 
in retrospect from experience and, usually, not organized 

Re: [PSES] Safety design of shutter opening

[Ted Eckert]

I would go one step further than Mr. Woodgate.

Inserting a BS 1363 plug into an outlet backwards is a challenge. The ground 
pin is longer than the line and neutral pins, but not that much longer. You 
cannot fully insert the ground pin into the outlet “backwards” because the line 
and neutral pins will hold the plug away from the face of the outlet. If you 
can get the plug to stay in that position, it would be held in lightly at best. 
In many case, the weight of the plug and cord would likely pull it out of the 
outlet due to the limited engagement of the ground pin. Further, whatever 
device was plugged in won’t turn on because it won’t have power. It seems to me 
that it would be extremely unlikely that somebody would “accidentally” put the 
plug in backwards and leave it there for an extended period of time.

I agree that the shutter mechanism can be defeated. However, I see it as being 
very unlikely to happen accidentally. The standards committees are trying to 
prevent foreseeable misuse, but there is only so much you can do to prevent 
people who want to intentionally defeat a safeguard.

Ted Eckert
Microsoft

The opinions expressed are my own and do not necessarily reflect those of my 
employer or the Society of People Who Like to Put Metal Objects in Outlets 
(SPWLPMOO).

From: John Woodgate mailto:j...@woodjohn.uk>>
Sent: Tuesday, July 17, 2018 4:11 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Safety design of shutter opening


Well, strictly, an electric shock incident would be a 'two-fault' situation - 
plug reversed AND conducting object inserted into the live socket. In general, 
two-fault situations are almost impossible to avoid but luckily also occur very 
rarely.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7C80438b42dacb42da1c4f08d5ebd62014%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C636674227263173356=Zxj4HPmpUMZQunCdde7BzuHeZyj%2BhVO%2BGAv4c1p7PIU%3D=0>

Rayleigh, Essex UK
On 2018-07-17 10:58, Scott Xe wrote:
Hi Pete,

Thanks for your view!  Firstly I dare to say it is not a new issue since I have 
read some reviews with this concern in the past plus a quick search of products 
available on the market showing some models in exist.  I do believe the 
standard committee and manufacturers are well aware of it.  It must have a 
reason to be tolerated or in a lower priority.  This forum has lots of expert 
and senior and looking for their enlightenment or common alignment.

Regards,

Scott


On Tue, 17 Jul 2018 at 01:26, Pete Perkins 
mailto:peperkin...@cs.com>> wrote:
Scott,

In watching this thread it is clear that the technical 
assessment and the regulatory certification are two separate issues but linked 
by local law so we need to be cognizant of the regulatory environment.

The technical assessment (per the standard) is organized by an 
ongoing group of (fallible) folks who work very hard to cover all of the risks 
(usually) from the product manufacturers point of view (since they seem to 
dominate the technical committees).  Since the requirements are usually written 
in retrospect from experience and, usually, not organized in a top down 
approach (using the usual risk assessment tools – FMEA, etc) it is incomplete 
is some (usually) unexpected ways – as you have discovered.  When exposed, the 
standards committee then scrambles to fill the hole identified.  This is a 
never ending process, approaching perfection asymptotically.
All this ignores the clever manufacturer who seeks out these holes and makes 
use of them to gain advantage in some way.

The regulatory certification reflects the level of development 
of the National bureaucracy responsible for setting requirements.  
Additionally, the lobbying of legislators and bureaucrats by special interest 
groups affects the final rules applied.  So it ends up being a patchwork of 
requirements that need to be applied by the manufacturer.
John Woodgate assures us that the world is happy with the UK approvals; check 
it out carefully.  Oh yes, a question – does Hong Kong or Singapore still use 
the British plug design?  What residual of this usage is still left in the 
world?

All of this is the reason that you and I (and most of the 
others on this net) have a meaningful job – once we get a little experience and 
are willing to put up with the uncertainty regarding the roles of requirements 
along with the varied level of enforcement by the legal jurisdictions.

You are uncomfortable with this hole in the requirements.  When 
we feel that the requirements or the application of requirements is either too 
strict or too slack our only recourse is to get (directly or indirectly) 
involved in fixing things (in which managers a

Re: [PSES] UL Listing of Computer Keyboard

[Ted Eckert]

NRTL approval is not a legal requirement to sell a product in the United 
States. There is no national legal requirement for many types of consumer 
products. Many jurisdictions have adopted NFPA 70, the National Electrical 
Code, which requires products either to be Listed by an NRTL or to be approved 
by the local inspector. This creates a de facto NRTL requirement for most 
permanently connected products. Inspections typically only occur during 
construction or renovation.

NRTL approval is expected for line-voltage products. Many large retailers won’t 
carry products unless they have NRTL approval. However, there are plenty of 
on-line and physical stores that don’t have NRTL requirements for the products 
they sell.

OSHA under the Department of Labor sets requirements for the workplace and OSHA 
does mandate NRTL approvals. OSHA actually manages the NRTL program as noted by 
one of the earlier commenters.

The standard for a keyboard depends on how it is used. I had a colleague that 
worked on 60601 approval for a keyboard used in medical applications. For the 
office, it would be UL 60950-1 or UL 62368-1, with the former standard being 
withdrawn in late 2020 if I recall correctly. The application in the U.S. is 
different than in Europe. Products certified to UL 60950-1 can continue to 
carry the certification mark after the date of withdrawal of the standard. 
Another date may be set further in the future when UL 60950-1 products would 
then need to be recertified to UL 62368-1.

Keyboards that are USB powered or use alkaline batteries technically fall under 
the OSHA requirements, but are generally considered low enough power that it is 
extremely unlikely that an inspector would require them to be NRTL approved.

If a keyboard is included in the retail package with an NRTL Listed computer, 
the NRTL may require the keyboard to be a Listed Accessory. Many NRTLs will 
require all included electrical accessories to be Listed if they are included 
in the same SKU with an NRTL Listed product.

Ted Eckert
Microsoft Corporation
The opinions expressed are my own and do not necessarily reflect those of my 
employer.



From: James Pawson (U3C) 
Sent: Tuesday, June 19, 2018 1:56 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UL Listing of Computer Keyboard

Hi all,

Thanks very much for the illuminating replies, it’s a great help. To summarise 
(and to make sure I’ve understood):


  *   NRTL approval legally required for selling in the USA? No.
  *   NRTL / UL approval expected? Highly likely.
  *   NRTL approval required for use in the workplace? Yes, not legally 
required but market expectation? Or is it a legal requirement?
  *   Standard used: UL 62368-1

@Pete Perkins: are you saying when the LVD was recast that they tried to remove 
the lower voltage limit? Presumably this didn’t happen because companies didn’t 
want the extra workload involved with extra testing / assessment?

Having looked at EN 62368-1, there’s not a great deal in there that applies to 
a low power device such as a USB powered keyboard so I think it’s fair to say 
that the type approval wouldn’t take a great deal of time / cost.

Reading 
http://www.productapprovals.co.uk/ul-approval.html<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.productapprovals.co.uk%2Ful-approval.html=02%7C01%7Cted.eckert%40microsoft.com%7C2e125d75d5f34301aba908d5d5c28d35%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636649953933516570=PsT2iw7EGYBVEVI9oyBGoMJRFyNzLXKp9%2BXwCswulrU%3D=0>
 there appear to be initial and regular factory inspections associated with a 
NRTL listing, with the figure of a few thousand dollars being quoted as a 
typical fee for maintaining an NRTL mark. Does this match people’s experience?

If the factory already has NRTL approval for manufacturing another product, 
could one piggyback onto this approval or is it on a per product basis?

Thanks again
James

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Re: [PSES] Automotive EMC question

[Ted Eckert]

Consider my thoughts as pure conjecture. Automotive electronics often use the 
chassis as the return for power. For high power devices, you run one wire and 
tie the device's ground terminal to the chassis nearby. If the shield was 
terminated at both ends, would there be a risk of higher return currents 
flowing on that shield from other devices?

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer or the Society of Automotive Engineers.

From: John Woodgate 
Sent: Tuesday, June 12, 2018 2:53 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Automotive EMC question


I hope it also at least recommends that the grounding is at the sending end, so 
that the cable capacitance is charged from the low-impedance source.  I guess 
that, e.g. in the auto environment, the risk of large shield currents is too 
great to allow routine grounding at both ends. But I suppose that grounding via 
a capacitor at the receiving end is not banned. If possible, this capacitor 
should be of the lowest possible inductance, which is not difficult with SMD, 
and if several capacitors are disposed radially around the end of the shield 
and grounded at their outer ends on a metal ring, the grounding should be good 
up to at least 1 GHz.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7C06dcf9fa28b84b06c1c008d5d0b00768%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C636644376846940054=L8vMop3oUcGnJh9%2F1NMRtATVBtChl2EP9Vs733ujVIw%3D=0>

Rayleigh, Essex UK
On 2018-06-12 22:41, Ken Javor wrote:
The CAN bus spec says that shield(s) are to be grounded at one end only. How 
does this work vs. meeting stringent rf RE and RS requirements at frequencies 
where cables are electrically long?

Thank you,

Ken Javor
Phone: (256) 650-5261


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Re: [PSES] Hello

[Ted Eckert]

Those aren’t zombies. That’s just like what the Disneyland employees look like 
after they get off work from their shift.

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer or the Walt Disney Corporation.

From: Brian O'Connell <oconne...@tamuracorp.com>
Sent: Friday, April 13, 2018 11:47 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Hello

Actually, most of us on the west coast have been busy fending off a zombie 
outbreak.

Members of the Orange County and San Diego PSES chapters were last seen getting 
their hi-pot machines ready as first line of defense, but believe them to have 
insufficient joules to be effective.

Brian


From: Richard Nute [mailto:ri...@ieee.org]
Sent: Friday, April 13, 2018 11:14 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Hello


Hi Josh:

I guess all of our problems are solved.    Or is it Spring Break?

Rich


From: Wiseman, Joshua 
<joshua.wise...@orthoclinicaldiagnostics.com<mailto:joshua.wise...@orthoclinicaldiagnostics.com>>
Sent: Friday, April 13, 2018 5:21 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Hello

I haven’t received any emails this week.  Just want to make sure I’m still 
getting them.

Josh

Joshua Wiseman
Staff Engineer, Product Safety/EMC
Ortho Clinical Diagnostics
100 Indigo Creek Dr
Rochester, NY 14626
T: +1 (585) 453-4231
joshua.wise...@orthoclinicaldiagnostics.com<mailto:joshua.wise...@orthoclinicaldiagnostics.com>
www.orthoclinicaldiagnostics.com<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.orthoclinicaldiagnostics.com=02%7C01%7Cted.eckert%40microsoft.com%7C0819ba4f8cb24887f07e08d5a173aae2%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C636592440518816032=j3SFU3TnIziGIxLxgYXRRhiBcVehN4i%2BarmYfx2Y678%3D=0>

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Re: [PSES] IEC 62368-1 3ed, Final Draft International Standard (FDIS)

[Ted Eckert]

I can only speak of my experience within the U.S. National Committee for TC 
108, and I am speaking about my personal experience and not in any official 
capacity as a representative of that committee.

One of the challenges on the committee is getting the members to actively 
participate. We occasionally have members submit comments to a draft standard 
and then they don’t show up to the meeting where the committee reviews and 
votes on the comments. It isn’t difficult to discuss a comment if it is written 
well and includes a clear justification. However, that is rarely the case. Most 
often, we need the submitter to provide more details at the meeting before the 
committee can make an informed decision about the proposed change. If the 
National Committee accepts the comment and proposed change, they must be 
willing to press their case at the international meetings. The further removed 
the original submitter is from the process, the harder it becomes.

My impression is that committee membership is open to those who are willing to 
actively participate. It does entail some expense and this can make it harder 
for individuals to participate. However, the multi-level national/international 
standards development create complexities greater than what NFPA faces. There 
needs to be a balance between openness and the ability to operate effectively. 
Currently, the vast majority of comments come from a small minority of 
committee members. It would not be unreasonable to interpret this as meaning 
that there isn’t a strong interest for greater participation and wider input on 
the standards development.

I do believe that the U.S. National Committee would like greater participation. 
New members would be welcome, particularly if they are willing to be active in 
the committee and to support the committee at the international level.

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer, TC 108, ANSI or the U.S. Technical Activities Group for TC 108.

From: John Woodgate <j...@woodjohn.uk>
Sent: Monday, March 19, 2018 8:20 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] IEC 62368-1 3ed, Final Draft International Standard (FDIS)

The secrecy is mostly justified as a protection of committee members from 
abusive reactions and even threats. However, the secrecy is often exaggerated, 
because we don't like being asked for documents we personally are not allowed 
to pass on. It's up to the National Committees of the IEC or ISO in each case 
to decide whether an enquirer has a justified reason for studying a 'work in 
progress' document, and their attitudes do differ; some are more liberal than 
others.

But committee members of National Committees  that mirror IEC or ISO committees 
are not just encouraged but required to consult their colleagues in their 
sponsoring organization about responses to circulated documents. The 
restrictions in this case are significant for those National Committees that 
charge for committee membership.

Both IEC and British Standards have relatively recently  introduced new ways 
that non-members of committees can see and comment on documents. See the web 
sites for details. This may require a lot of 'burrowing'.


John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=04%7C01%7Cted.eckert%40microsoft.com%7C46a8758f27264e39933c08d58dad014a%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C636570696651836433%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwifQ%3D%3D%7C-1=HQiQWNhMXLEwIIqrCdWjPic6qJ96CXUQwk3gyoo%2BxVA%3D=0>

Rayleigh, Essex UK
On 2018-03-19 14:51, Robert Johnson wrote:

I object to the secrecy and closed aspects of the IEC standards process. A 
better example is the NFPA where revision cycles are rigorously scheduled, 
public input and change requests are welcome, proposals are openly debated and 
published, and the standard is publicly available. They still seem to generate 
sufficient revenue from standards sales.

Bob Johnson

On 03/18/2018 03:54 PM, John Woodgate wrote:
1.  You can ask your National Committee, but that may not work. At some future 
date, maybe not far off, it may be available from the IEC as a 'PRV' 
(Pre-release version), which you pay for but then get the actual published 
version for no additional charge.

2. The differences are too extensive and to detailed to recount.  And 'major' 
is a dangerous word. A big change might not affect your product but a small 
change could put it off the market until it's fixed.

3. Yes, after a lot of  headless chicken, it is.


John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=04%7C01%7Cted.eckert%40microsoft.com%7C46a8758f27264e39933c08d58dad014a%7C72f988bf86f141af91ab2d7cd

Re: [PSES] insulation between SELV and protective earthed accessible part- IEC 62052-31

[Ted Eckert]

Part of the reason why two levels of protection are required is because of what 
happens if one level fails. If the protective earth bonding connection fails, 
and the exposed metal is no longer earthed, the product will typically continue 
to operate normally. There is no indication to the user that a failure has 
occurred. If a second failure occurs that bridges the insulation gap between 
hazardous voltage and that exposed metal, the chassis will become energized. 
The user may still have no obvious indication of a failure until they contact 
that energized chassis.

Different standards committees have different ways of addressing this issue. TC 
108 generally requires that the protective earth bonding be designed and tested 
in such a way to prove that it is robust enough. In many ITE products, the user 
accessible circuits are earth ground references, so providing basic insulation 
between SELV and earth ground is not possible. Other standards committees may 
have chosen other methods of protection based on the products they cover. TC 13 
may have decided that basic insulation between SELV and earthed parts may be 
the best way to provide protection in their products. In this case, if the 
earth bonding fails, the basic insulation may be need to reduce the risk or 
arcing between hazardous voltage and the exposed metal.


Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer, TC 13 or TC 108.

From: Scott Aldous 
<0220f70c299a-dmarc-requ...@ieee.org<mailto:0220f70c299a-dmarc-requ...@ieee.org>>
Sent: Tuesday, March 13, 2018 8:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] insulation between SELV and protective earthed accessible 
part- IEC 62052-31

Hi Vyas,

I'm not familiar with this standard, but the general principle is that 2 levels 
of protection are required to protect operators from hazards. In the case of 
the "protective earthed accessible part", I imagine the standard assumes that a 
single fault could compromise the protective earthing, so Basic or 
Supplementary Insulation is also required between such a circuit and SELV. In 
the same vein, the table requires Double or Reinforced Insulation between an 
"unearthed accessible part" and SELV.

On Tue, Mar 13, 2018 at 5:56 AM, Balmukund Vyas 
<balmukund.v...@ymllabs.com<mailto:balmukund.v...@ymllabs.com>> wrote:


Dear All,
IEC 62052-31 is standard for product safety requirements for electricity 
metering equipment. It has a table 20 (given below) which details out 
insulation requirements between various types of circuits.
My question is, why Basic insulation is required between SELV circuit and 
protective earthed accessible parts? Isn’t a functional insulation is 
sufficient for this?

Thanks

B M Vyas


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Re: [PSES] IEC60950-1 Limited Power Source via IC current limiter

[Ted Eckert]

I agree with Mr. Woodgate and I can add a little more information. UL 2367 is 
generally considered equivalent as Test Program 2 of Annex CC. Most NCBs will 
accept it as such and you should be able to place a statement in your report 
indicating the equivalency. Not all NCBs will necessarily accept the 
equivalence, but I have yet to run into an issue with integrated circuits 
approved under UL 2367.

Ted Eckert
Microsoft Corporation

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

From: John Woodgate <j...@woodjohn.uk>
Sent: Monday, March 5, 2018 1:07 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] IEC60950-1 Limited Power Source via IC current limiter


The standard says '...meets a suitable test program as given in Annex CC' [not 
Annex C].  It does not say 'shall meet the test program given in Annex CC'. As 
you know, the manufacturer is permitted  to decide (and document) that a part 
meeting UL2367 is acceptable, and it would be up to a regulatory authority to 
challenge that. It seems unlikely that UL 2367 would be deficient, since this 
is a precaution against fire, which is a major concern of UL, of course.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=04%7C01%7Cted.eckert%40microsoft.com%7C57ad0c33b883418c42a608d582dd12a3%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C636558808380524292%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwifQ%3D%3D%7C-2=Ul7TLxZq%2FHEl36YyaO1rCASJ4o%2B26Yn2z67Ld7rJ%2Fbo%3D=0>

Rayleigh, Essex UK
On 2018-03-05 20:11, Charlie Blackham wrote:
All

Client has designed a USB port with the DC power protected by a TI TPS2052B 
Current limiter:

  *   Component details: 
www.ti.com/product/TPS2052B/description<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.ti.com%2Fproduct%2FTPS2052B%2Fdescription=04%7C01%7Cted.eckert%40microsoft.com%7C57ad0c33b883418c42a608d582dd12a3%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C636558808380524292%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwifQ%3D%3D%7C-2=FUSXv3Bp93L9rC1gtGCcocla953sRv6etd8bPi9VVss%3D=0>
  *   Component is UL recognised component under QVGS2.E169910 which is based 
on UL 2367


2.5 Limited power sources
c) a regulating network, or an integrated circuit (IC) current limiter, limits 
the output in compliance with Table 2B, both with and without a simulated 
single fault (see 1.4.14) in the regulating network or the IC current limiter 
(open circuit or short circuit). A single fault between the input and output is 
not conducted if the IC current limiter meets a suitable test program as given 
in Annex CC;

Annex CC requires appears to require quite extensive testing of the component, 
and I can't tell whether a component recognised against UL2367 would meet this 
or not.

The issue, is that if they s/c the protection component, the output may no 
longer be LPS - we have provision to fit a suitable fuse on the board, but 
would prefer not to, so would be grateful for any advice

Thanks
Charlie


Charlie Blackham
Sulis Consultants Ltd
Mead House
Longwater Road
Eversley
RG27 0NW
UK
Tel: +44 (0)7946 624317
Email: char...@sulisconsultants.com<mailto:char...@sulisconsultants.com>
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Re: [PSES] light flicker

[Ted Eckert]

https://en.wikipedia.org/wiki/On_the_Internet,_nobody_knows_you%27re_a_dog#/media/File:Internet_dog.jpg


Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer or the American Kennel Club.

-Original Message-
From: Jim Hulbert <jim.hulb...@pb.com> 
Sent: Friday, March 2, 2018 11:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] light flicker

Did you get replies from other than humans?

Jim Hulbert

-Original Message-
From: Brian O'Connell [mailto:oconne...@tamuracorp.com]
Sent: Friday, March 02, 2018 2:31 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] light flicker

Good People,

Thanks to the humans that replied on and off-line. Much appreciated.

Have also noted that there has been some interesting discussions on the subject 
per the proposed Peoples Republic of California Energy Commission regulations 
for LED luminaires; for example, note this comment to the CEC:

https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fdocketpublic.energy.ca.gov%2FPublicDocuments%2F17-BSTD-02%2FTN222823_20180302T105129_Kelly_Seeger_Comments_Philips_Lighting_additional_comments_on_N.pdf=04%7C01%7Cted.eckert%40microsoft.com%7C6f29987962df4fbac58908d5807b64b1%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C636556189825131274%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwifQ%3D%3D%7C-1=ps5%2F%2Buvs0OKiU%2FS8uZJ%2BmJM%2BBsf5Q6eupMaDyTvl%2FBs%3D=0

Brian


-Original Message-
From: Brian O'Connell
Sent: Wednesday, February 21, 2018 2:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: light flicker

Does any 60601 collateral standard, address limits for light-source flicker; or 
have any other requirements for the light-flicker frequencies emitted by a 
luminaire? Have noted IEC60601-2-41 but do not have it; does it provide 
light-flicker frequency limits?

Am already aware of the TLA stuff in NEMA77 and IEEE1789, and the IEC61000-4-15 
'flickermeter' stuff. These standards are contradictory, and the IEEE standard 
fails to provide any reference to biophysical data that would provide a 
rationale. And 60601-1 clause 10 does not say much other than the generic 
response that references the RMF.

Thanks,
Brian

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This message is from the IEEE Product

Re: [PSES] GFCI vs GFPE

[Ted Eckert]

Hello Brian,

According to New South Wales, RCDs are required for many products in 
Australia.<http://www.safework.nsw.gov.au/health-and-safety/industry-safety/electrical-and-power/residual-current-devices>
 However, I checked a major supplier of Australian electrical devices, and they 
show RDCs that look more like the U.S. 
GFCI.<https://www.clipsal.com/Trade/Products/Electrical-Accessories/Safety-Protection/RCD-Protected-Portable-Accessories#.WnH940xFyeE>
 The cost for the type of RCD required in Australia may  not be as cost 
prohibitive as what you are finding. I will admit that these are single-phase 
devices. (Disclosure notice: Clipsal is a division of Schneider Electric, my 
previous employer. My reference to Clipsal products is just for reference 
purposes and is not necessarily intended to be an endorsement of their product 
line.)

As Mr. Woodgate noted, the differing wiring practices and regulations may make 
it more difficult come up with a common practice for RCDs in products, although 
Mr. Sherman’s suggestion may be a good starting place.

Does this list have a member of TC 23/SC 23E who may be more familiar with IEC 
standards in regards to RCDs?

Ted Eckert
Microsoft Corporation

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

From: Mike Sherman [mailto:msherma...@comcast.net]
Sent: Wednesday, January 31, 2018 9:29 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] GFCI vs GFPE

Brian --
I think I've seen a Part 2 standard for 60745-1, as I recall, that required a 
RCD if the tool used water and the water ended up in the wrong place 
electrically. If you'd like a screen shot of the section, I can probably find 
it for you.
Mike Sherman
Graco Inc.


From: "Brian Kunde" <brian_ku...@lecotc.com<mailto:brian_ku...@lecotc.com>>
To: "EMC-PSTC" <EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Sent: Wednesday, January 31, 2018 11:06:36 AM
Subject: Re: [PSES] GFCI vs GFPE

Where Pete stated, “The Euro systems use of RCDs require this protection in 
many installations (but I’m not familiar with the installation code details)”. 
This “Code” is probably what I am seeking.

Has anyone run across a Code rule that requires the Product to employ a RCCB 
within the product?  If the local electrical code requires a RCCB, cannot this 
protection be provided as part of the site protection?  Why burden the cost of 
a product where such a requirement may only be necessary in a small percentage 
of installations?

The main purpose of my question on this topic is cost.  Here in the USA, a GFCI 
receptacle is very inexpensive; costing around $10 at most home stores.  But a 
3-phase RCD Circuit Breaker can cost $300-$400.  On some products, such as a 
tile saw that uses water, this can more than double the cost of the entire 
product.  So knowing when and where they are required is very important.

Thanks again to everyone for your consideration.  From what I have read so far 
on this topic, it is a moving target as electric codes from different states 
and countries are always evolving and the code governing the requirements of 
RCDs and GFCIs are common to change.

Thanks,
Brian


From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Wednesday, January 31, 2018 11:13 AM
To: Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] GFCI vs GFPE


You can rely on the recent post in this thread by Pete Perkins.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7C1319dd0df87b4b9d8a9408d568d03b16%7Cee3303d7fb734b0c8589bcd847f1c277%7C1%7C0%7C636530165918821660=iS4KCuxeJ%2BQIgETijVZNOtup5usvE3MDNHIFAAarZlc%3D=0>

Rayleigh, Essex UK
On 2018-01-31 15:52, Kunde, Brian wrote:
Thanks for the input everyone.

I know that GFCI protectors in North America will trip between 4-6mA.  Do other 
countries, such as Europe, have the same requirements?
Or are 30mA protectors used in Europe? If so, does Europe use 30mA ground fault 
protectors because of nuisance tripping even though the studies have shown that 
30mA can be fatal?

These 3-phase cut-off saws that I’m evaluating comes with a power cord, but no 
plug. They can be field wired or a plug could be added and plugged it into a 
receptacle.  The choice is left up to the customer.

The saw uses water but the work environment would not normally be considered a 
“wet location”.  It would not be used in a construction location.

So again, I’m trying to figure out why the saw manufacturer used the expensive 
30mA ground fault breakers in their product.

Thanks,
The Other Brian






LECO Corporation Notice: This communication may contain confidential 
information intended for the named recipient(s) onl

Re: [PSES] GFCI vs GFPE

[Ted Eckert]

In North America, GFCIs are only used in wet environments; kitchens, bathrooms, 
garages, outdoor outlets and such. They are neither require nor used for other 
occupancies. There are exemptions to reduce the risk of nuisance tripping. If 
you want to keep a refrigerator or freezer in your garage, you can wire a 
dedicated circuit with only a single outlet. That outlet would not need a GFCI. 
The concern is more with temporary loads. Permanently connected products don’t 
require a GFCI. (The code requires these products to have a reliable ground 
connection when used in areas that would otherwise require a GFCI.)

The limited use, and the types of loads connected, tend to lead to little 
nuisance tripping.

I did have a case where a GFCI was used in a small data center. (It’s a long 
story as to why it was there and I won’t go into it here.) The GFCI trips at 5 
mA without regards to frequency. We may have a limit of 3.5 mA touch current 
for ITE in certain circumstances, but that is using the human body model. The 
circuit in question measured 1.5 mA touch current using a human body model 
meter. If you used a standard multimeter, the ground current was 9 mA due to 
the higher frequencies. In this case, there was constant nuisance tripping. The 
solution was to rewire the computer room the way it should have been done in 
the first place.

In summary, nuisance tripping of GFCIs has become relatively uncommon in the 
United States.

Ted Eckert
Microsoft Corporation

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

From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Tuesday, January 30, 2018 3:28 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] GFCI vs GFPE


We have an expert on electric shock here, so I won't go further than to say 
that the effect of 30 mA depends very much on how much contact area there is, 
where it is and for how long contact lasts. I am surprised that 6 mA doesn't 
result in nuisance tripping.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7C620a3e80f0b34e9c9d1808d568393584%7Cee3303d7fb734b0c8589bcd847f1c277%7C1%7C0%7C636529517282906600=ViZzB4GPKmnpkKAYIiV9H0xDOgn63brNjp%2BJbbLotx0%3D=0>

Rayleigh, Essex UK
On 2018-01-30 22:43, Ralph McDiarmid wrote:

Agreed, and current carry-carrying of PE and bonding of internal parts must 
meet stringent UL/CSA requirements. (not mA!)  It seems to me that 30mA is 
close to lethal, and the GFCI outlets Listed over here are 6mA trip.  (still a 
painful shock)



Ralph McDiarmid

Product Compliance Specialist

Solar Business

Schneider Electric





From: John Woodgate [mailto:j...@woodjohn.uk]

Sent: Tuesday, January 30, 2018 2:30 PM

To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>

Subject: Re: [PSES] GFCI vs GFPE



I don't think that is the reason recognized in Europe. The PE circuit has the 
same (or similar) current-carrying capacity as the line circuit(s), so its 
fault-current capacity for 30 s is very large even for a household supply. I 
think the protector is there to prevent fire and to give some protection 
against electric shock, although the latter is compromised so as to prevent 
nuisance-tripping, which would occur if the trip were set at say 5 mA to give 
much better protection.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
http://www.woodjohn.uk<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7C620a3e80f0b34e9c9d1808d568393584%7Cee3303d7fb734b0c8589bcd847f1c277%7C1%7C0%7C636529517282906600=ViZzB4GPKmnpkKAYIiV9H0xDOgn63brNjp%2BJbbLotx0%3D=0>

Rayleigh, Essex UK

On 2018-01-30 22:03, Kunde, Brian wrote:

I’ve recently come to understand that the 30mA Ground-Fault protectors, often 
built into a circuit breaker, is intended to protect the Protective Earth 
(Safety Ground) circuit in the case of a short circuit (opening the circuit 
before the safety ground could be damaged.  It this correct?



Here is my question. I’m evaluating a cut-off saw (5hp) which uses water to 
keep the blade and material cool.  The manufacturer uses a 3-phase 
supplementary circuit breaker which includes the 30mA GFPE option.  This is a 
very expensive part.  When I asked them why they use the GFPE part, they 
couldn’t give me a good answer.



Would such a part be required on a 3-phase motor driven cutoff saw in either 
North America or Europe?  What standard would dictate this?



If the only purpose of a GFPE is to protect the Ground Circuit, on products 
that can handle shorts without damaging the ground circuit, would a GFPE still 
be necessary?



Where are GFPE typically used? What industry?



Please educate me.  This is a new one on me.



Thanks,

Brian



From: Doug Nix [mailto:d...@ieee.org]

Sent: Friday, Januar

Re: [PSES] GFCI vs GFPE

[Ted Eckert]

My understanding isn’t as clear as I would like it to be, so the information I 
am providing is suspect.



I believe that the difference in trip points between North America and Europe 
is due to grounding, wiring and power distribution practices. The power 
distribution systems used in North America allow a trip point of nominally 5 mA 
(4 – 6 mA) without a significant risk of nuisance tripping. However, European 
wiring practices are such that nuisance tripping would be more likely at 5 mA 
and, as such, 30 mA is used as the limit.



Is the 3-phase saw plug connected or field wired? Is it used in a potentially 
wet environment? In North America, portable power distribution units, typically 
used at construction sites, must have protection because it is expected that 
the user will connect power tools that will be used in wet environments. 
However, for a field wired saw installed in a workshop would likely not require 
a GFCI. Much of this comes from the electrical code. Any standards that specify 
the additional protection do so because the code requires it.


Ted Eckert
Microsoft Corporation

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



-Original Message-
From: Ralph McDiarmid [mailto:ralph.mcdiar...@schneider-electric.com]
Sent: Tuesday, January 30, 2018 2:43 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] GFCI vs GFPE



Agreed, and current carry-carrying of PE and bonding of internal parts must 
meet stringent UL/CSA requirements. (not mA!)  It seems to me that 30mA is 
close to lethal, and the GFCI outlets Listed over here are 6mA trip.  (still a 
painful shock)



Ralph McDiarmid

Product Compliance Specialist

Solar Business

Schneider Electric





From: John Woodgate [mailto:j...@woodjohn.uk]

Sent: Tuesday, January 30, 2018 2:30 PM

To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>

Subject: Re: [PSES] GFCI vs GFPE



I don't think that is the reason recognized in Europe. The PE circuit has the 
same (or similar) current-carrying capacity as the line circuit(s), so its 
fault-current capacity for 30 s is very large even for a household supply. I 
think the protector is there to prevent fire and to give some protection 
against electric shock, although the latter is compromised so as to prevent 
nuisance-tripping, which would occur if the trip were set at say 5 mA to give 
much better protection.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7C332841906ad44ef66eaa08d5683526de%7Cee3303d7fb734b0c8589bcd847f1c277%7C1%7C0%7C636529499853637893=hM9ZJbor9gxzRIIwUYV0KkogbsHqlWIDv%2BCi2VRAr5I%3D=0

Rayleigh, Essex UK

On 2018-01-30 22:03, Kunde, Brian wrote:

I’ve recently come to understand that the 30mA Ground-Fault protectors, often 
built into a circuit breaker, is intended to protect the Protective Earth 
(Safety Ground) circuit in the case of a short circuit (opening the circuit 
before the safety ground could be damaged.  It this correct?



Here is my question. I’m evaluating a cut-off saw (5hp) which uses water to 
keep the blade and material cool.  The manufacturer uses a 3-phase 
supplementary circuit breaker which includes the 30mA GFPE option.  This is a 
very expensive part.  When I asked them why they use the GFPE part, they 
couldn’t give me a good answer.



Would such a part be required on a 3-phase motor driven cutoff saw in either 
North America or Europe?  What standard would dictate this?



If the only purpose of a GFPE is to protect the Ground Circuit, on products 
that can handle shorts without damaging the ground circuit, would a GFPE still 
be necessary?



Where are GFPE typically used? What industry?



Please educate me.  This is a new one on me.



Thanks,

Brian



From: Doug Nix [mailto:d...@ieee.org]

Sent: Friday, January 26, 2018 2:48 PM

To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG

Subject: [PSES] JOB POSTING - ONTARIO, CANADA



PLEASE CONTACT TED TYCZKA DIRECTLY



A very notable, “high-profile” client who is seeking a Safety & Services 
Sales/Business Development Professional - to join their Machine Services 
Division - the focus of the role is to spearhead/lead the sale of Engineering 
Services related to “functional safety.”



The company sells safety training (workshops), machine assessment/audits, 
engineering design per CSA and/or TUV Safety requirements (“Regulatory 
Compliance”).  The company also sells Remediation and Repair Services (of 
industrial machines) together with Service Contracts ... to customers in the 
aerospace, automotive, forestry, food & beverage, as well as, the packaging 
sectors.



The Safety & Services/Business Development Professional can work from a home 
office - anywhere in Ontario. A Bachelor of Science in Mechanical or Electrical 
Engineering, together with the sale of Machine Safeguard devices an

Re: [PSES] IATA/ICAO and U 83.3 rules

[Ted Eckert]

Hello Doug,

Go to the following website and download the “Shipping lithium batteries – 
documentation requirements” file.
http://www.fedex.com/id/tools/lithium.html

It has a flow chart showing the UN shipping requirements for batteries packaged 
within products. The batteries will need UN 38.3 testing, but shipping 
batteries in products is fairly simple after that.

Ted Eckert
Microsoft Corporation

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

From: Doug Powell [mailto:doug...@gmail.com]
Sent: Thursday, January 25, 2018 12:45 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] IATA/ICAO and U 83.3 rules

Hi all,

I am curious to know if anyone is familiar with IATA/ICAO and UN 83.3 rules as 
they apply to shipment of cell phones (and other products) with built in 
batteries.  Many manufacturers generally separate the battery from the product 
or insulate one of the terminals to prevent inadvertent activation during 
shipment. With built in batteries this is not always possible.  I don't believe 
the rules specifically say batteries must be removed or disconnected.  So how, 
exactly is this handled by most people?

Thanks all.  Doug

-- Hel

Douglas E Powell

doug...@gmail.com<mailto:doug...@gmail.com>
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Re: [PSES] Demo samples at stores

[Ted Eckert]

Hello Scott,

The exemptions for certain uses of prototypes are primarily exemptions from 
certification procedures. However, you still have some obligation to meet the 
essential requirements of the various Directives. You should monitor and 
control the use of these pre-certification prototypes to ensure that they do 
not present a risk of injury to users, interfere with radios and receivers or 
present some other hazard to the users or the public. If these devices are in a 
store, the employee safety and health at work regulations still apply and there 
may be issues of civil liability if the general public has access to the 
devices.
https://osha.europa.eu/en/safety-and-health-legislation

The immunity requirements of the EMC Directive and RED may be an area with 
lesser implications. For example, if the device is damaged by ESD, you won’t 
have an end-user who is affected by losing the use of a product they have 
purchased.

My recommendation is to work with your company’s legal staff or outside council 
familiar with this area of law before placing a product into a store for 
demonstration purposes if that product has not yet been tested and declared to 
the applicable Directives. Use for trade show or demonstration purposes should 
be reviewed carefully to ensure that you are complying with both the letter and 
the spirit of the law.

Ted Eckert
Microsoft Corporation

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

From: John Allen [mailto:09cc677f395b-dmarc-requ...@ieee.org]
Sent: Thursday, January 18, 2018 8:55 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Demo samples at stores

I don’t think the footnote was in the Blue Guide at the time (c2000) but that’s 
what I decided that we had to do, and to specify to trials teams (ours’ and the 
customers’), when we put prototype military equipment out for field trials – 
but sometimes it was difficult to persuade everyone (especially Project 
Manager’s “in a hurry”!) involved that such steps were “necessary”!

It was/is really only “common sense” from both the trials and the 
involved-personnel perspectives because you can’t really field-trial or 
demonstrate equipment except under “realistic” conditions and with suitable 
personnel – but everyone then has a “duty of care” to ensure that neither 
themselves or anyone-, or anything-, else is put at undue risk.

John E Allen
W. London, UK

From: Graevinghoff Andreas (ETAS/EHS2) [mailto:andreas.graevingh...@etas.com]
Sent: 18 January 2018 16:24
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Demo samples at stores

Hi Scott,

See footnote (57) in the Blue Guide regarding the controlled conditions:

“The prototype must be safe and under complete control and supervision. 
Controlled conditions would mean expert operators, restrictions to public 
contact with the product, avoiding inappropriate interaction with other 
neighbouring products, etc.”

Best regards,

Andreas Graevinghoff

From: Scott Xe [mailto:scott...@gmail.com]
Sent: Donnerstag, 18. Januar 2018 16:57
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Demo samples at stores

According to clause 2.3 of Blue guide, placing on the market is considered not 
to take place on demo samples.  The samples may be tested or tried by the store 
staff and the customers.  If the samples may not comply with relevant 
standards,  how to ensure the store staff and the customers to be protected 
from the health safety hazard?

Thanks and regards,

Scott Xe
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