Re: [PSES] **External**Re: [PSES] FCC Part 15 Testing in Situ

[John Woodgate]

Do a 'pre-test'. Run the machine and walk round it with a wide-band 
receiver in ever-increasing circles. Note what you pick up and where. 
That gives a guide as to what might need to be measured more accurately 
and/or suppressed.


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

On 2019-02-25 12:56, Jim Hulbert wrote:

Hi Tom,

The exemption in (b) is for electronic control or power system utilized by a 
public utility or in an industrial plant.  I don't believe the exemption 
extends to machinery operated in those environments.   And the exemption for 
(c) is for test equipment used in industrial, commercial or medical 
applications.

I agreein-situ testing can be very difficult.

Jim H.

-Original Message-
From: T.Sato [mailto:vef00...@nifty.com]
Sent: Friday, February 22, 2019 8:20 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] **External**Re: [PSES] FCC Part 15 Testing in Situ

CAUTION: THIS EMAIL IS FROM AN EXTERNAL SOURCE. Internet links, office 
documents or other attachments may contain viruses. Do not click on a link, 
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On Fri, 22 Feb 2019 14:39:46 +,
   Jim Hulbert  wrote:


Yes, FCC requirements for this type of equipment are not very practical.As 
a side note, such large equipment is industrial in nature, which may lead one 
to believe they would fall under FCC Part 18 for ISM instead of Part 15.   
However, Part 18 only covers industrial equipment that generates and locally 
uses RF energy for the production of physical, biological, or chemical effects. 
 An industrial machine that does not utilize RF energy for these purposes is 
not within scope of Part 18, and so Part 15 applies.

I guess large industrial machines which will not fall under Part 18 may often 
be exempted from Part 15 (except for general conditions of operation), 
especially due to 47 CFR 15.103 (b) or (c).

If the machine can't be exempted, although in-situ radiated emission 
measurement can be very difficult, I think we need to measure them in-situ 
individually at least for first three installations.

Regards,
Tom

--
Tomonori Sato  


From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Friday, February 22, 2019 3:05 AM
To: Jim Hulbert ;
EMC-PSTC@LISTSERV.IEEE.ORG
Subject: **External**Re: [PSES] FCC Part 15 Testing in Situ


Such very large equipment tends to be custom-designed, so three identical 
installations never exist. Even if there are three identical installations, 
they are unlikely to be completed simultaneously, so how can the first two be 
legally operated before the third is installed and tested?

I wonder if FCC needs to look again at this requirement.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates
https://na01.safelinks.protection.outlook.com/?url=www.woodjohn.uk&
;data=02%7C01%7CJim.Hulbert%40pb.com%7Ceaf18be7160c4e075aaa08d6992ddb1
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sdata=cJrnUUssyZT9dbdtTFnOWSMtsxyGA1B%2F3TyV5NxG9co%3D&reserved=0<
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odjohn.uk&data=02%7C01%7CJim.Hulbert%40pb.com%7Ceaf18be7160c4e075a
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amp;reserved=0>

Rayleigh, Essex UK
On 2019-02-21 20:48, Jim Hulbert wrote:
Equipment that is covered under FCC Rules Part 15, but which is too large to 
test on an open area test site, can alternatively been tested in situ.  
However, the rules state that the test should be performed at 3 different 
representative installations of the equipment.  Does anyone on this forum have 
experience doing this?  I would expect conducted emissions to be reasonably 
similar, but I can see how environmental influences could result in 3 different 
sets of radiated emissions data.  How do you make sense of the data?

Jim Hulbert



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Re: [PSES] **External**Re: [PSES] FCC Part 15 Testing in Situ

[Jim Hulbert]

Hi Tom,

The exemption in (b) is for electronic control or power system utilized by a 
public utility or in an industrial plant.  I don't believe the exemption 
extends to machinery operated in those environments.   And the exemption for 
(c) is for test equipment used in industrial, commercial or medical 
applications. 

I agreein-situ testing can be very difficult.

Jim H.

-Original Message-
From: T.Sato [mailto:vef00...@nifty.com] 
Sent: Friday, February 22, 2019 8:20 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] **External**Re: [PSES] FCC Part 15 Testing in Situ

CAUTION: THIS EMAIL IS FROM AN EXTERNAL SOURCE. Internet links, office 
documents or other attachments may contain viruses. Do not click on a link, 
open or enable any file unless you trust the sender.


On Fri, 22 Feb 2019 14:39:46 +,
  Jim Hulbert  wrote:

> Yes, FCC requirements for this type of equipment are not very practical.
> As a side note, such large equipment is industrial in nature, which may lead 
> one to believe they would fall under FCC Part 18 for ISM instead of Part 15.  
>  However, Part 18 only covers industrial equipment that generates and locally 
> uses RF energy for the production of physical, biological, or chemical 
> effects.  An industrial machine that does not utilize RF energy for these 
> purposes is not within scope of Part 18, and so Part 15 applies.

I guess large industrial machines which will not fall under Part 18 may often 
be exempted from Part 15 (except for general conditions of operation), 
especially due to 47 CFR 15.103 (b) or (c).

If the machine can't be exempted, although in-situ radiated emission 
measurement can be very difficult, I think we need to measure them in-situ 
individually at least for first three installations.

Regards,
Tom

--
Tomonori Sato  

> From: John Woodgate [mailto:j...@woodjohn.uk]
> Sent: Friday, February 22, 2019 3:05 AM
> To: Jim Hulbert ; 
> EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: **External**Re: [PSES] FCC Part 15 Testing in Situ
>
>
> Such very large equipment tends to be custom-designed, so three identical 
> installations never exist. Even if there are three identical installations, 
> they are unlikely to be completed simultaneously, so how can the first two be 
> legally operated before the third is installed and tested?
>
> I wonder if FCC needs to look again at this requirement.
>
> Best wishes
>
> John Woodgate OOO-Own Opinions Only
>
> J M Woodgate and Associates 
> https://na01.safelinks.protection.outlook.com/?url=www.woodjohn.uk&
> ;data=02%7C01%7CJim.Hulbert%40pb.com%7Ceaf18be7160c4e075aaa08d6992ddb1
> 7%7C8a4925a9fd8e4866b31cf719fb05dce6%7C1%7C0%7C636864819567427224&
> sdata=cJrnUUssyZT9dbdtTFnOWSMtsxyGA1B%2F3TyV5NxG9co%3D&reserved=0<
> https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.wo
> odjohn.uk&data=02%7C01%7CJim.Hulbert%40pb.com%7Ceaf18be7160c4e075a
> aa08d6992ddb17%7C8a4925a9fd8e4866b31cf719fb05dce6%7C1%7C0%7C6368648195
> 67427224&sdata=iMWfZ8B%2FpVrgg1C3AO3ViGDBvwSZJAapCx2XHpt8%2B60%3D&
> amp;reserved=0>
>
> Rayleigh, Essex UK
> On 2019-02-21 20:48, Jim Hulbert wrote:
> Equipment that is covered under FCC Rules Part 15, but which is too large to 
> test on an open area test site, can alternatively been tested in situ.  
> However, the rules state that the test should be performed at 3 different 
> representative installations of the equipment.  Does anyone on this forum 
> have experience doing this?  I would expect conducted emissions to be 
> reasonably similar, but I can see how environmental influences could result 
> in 3 different sets of radiated emissions data.  How do you make sense of the 
> data?
>
> Jim Hulbert
>
>
>
> This email message may contain confidential, proprietary and/or privileged 
> information. It is intended only for the use of the intended recipient(s). If 
> you have received it in error, please immediately advise the sender by reply 
> email and then delete this message. No one other than the intended recipient 
> may disclose, copy, distribute or use the information contained in this 
> message.
>
>
>
>
> -
> 
>
> 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>>
>
> All emc-pstc postings are archived and searchable on the web at: 
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> ee-pses.org%2Femc-pstc.html&data=02%7C01%7CJim.Hulbert%40pb.com%7C
> eaf18be7160c4e075aaa08d6992ddb17%7C8a4925a9fd8e4866b31cf719fb05dce6%7C
> 1%7C0%7C636864819567427224&sdata=HGmrf1mhW7bjo4QnZiGeOx7Gq5BazfENI
>

Re: [PSES] **External**Re: [PSES] FCC Part 15 Testing in Situ

[T.Sato]

On Fri, 22 Feb 2019 14:39:46 +,
  Jim Hulbert  wrote:

> Yes, FCC requirements for this type of equipment are not very practical.
> As a side note, such large equipment is industrial in nature, which may lead 
> one to believe they would fall under FCC Part 18 for ISM instead of Part 15.  
>  However, Part 18 only covers industrial equipment that generates and locally 
> uses RF energy for the production of physical, biological, or chemical 
> effects.  An industrial machine that does not utilize RF energy for these 
> purposes is not within scope of Part 18, and so Part 15 applies.

I guess large industrial machines which will not fall under Part 18
may often be exempted from Part 15 (except for general conditions of
operation), especially due to 47 CFR 15.103 (b) or (c).

If the machine can't be exempted, although in-situ radiated emission
measurement can be very difficult, I think we need to measure them
in-situ individually at least for first three installations.

Regards,
Tom

-- 
Tomonori Sato  

> From: John Woodgate [mailto:j...@woodjohn.uk]
> Sent: Friday, February 22, 2019 3:05 AM
> To: Jim Hulbert ; EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: **External**Re: [PSES] FCC Part 15 Testing in Situ
> 
> 
> Such very large equipment tends to be custom-designed, so three identical 
> installations never exist. Even if there are three identical installations, 
> they are unlikely to be completed simultaneously, so how can the first two be 
> legally operated before the third is installed and tested?
> 
> I wonder if FCC needs to look again at this requirement.
> 
> Best wishes
> 
> John Woodgate OOO-Own Opinions Only
> 
> J M Woodgate and Associates www.woodjohn.uk
> 
> Rayleigh, Essex UK
> On 2019-02-21 20:48, Jim Hulbert wrote:
> Equipment that is covered under FCC Rules Part 15, but which is too large to 
> test on an open area test site, can alternatively been tested in situ.  
> However, the rules state that the test should be performed at 3 different 
> representative installations of the equipment.  Does anyone on this forum 
> have experience doing this?  I would expect conducted emissions to be 
> reasonably similar, but I can see how environmental influences could result 
> in 3 different sets of radiated emissions data.  How do you make sense of the 
> data?
> 
> Jim Hulbert
> 
> 
> 
> This email message may contain confidential, proprietary and/or privileged 
> information. It is intended only for the use of the intended recipient(s). If 
> you have received it in error, please immediately advise the sender by reply 
> email and then delete this message. No one other than the intended recipient 
> may disclose, copy, distribute or use the information contained in this 
> message.
> 
> 
> 
> 
> -
> 
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc 
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> mailto:emc-p...@ieee.org>>
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> 
> Attachments are not permitted but the IEEE PSES Online Communities site at 
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Re: [PSES] **External**Re: [PSES] FCC Part 15 Testing in Situ

[Jim Hulbert]

“Best effort and engineering judgement”.   I like the sound of that.


From: Marko Radojicic [mailto:radojic...@yahoo.com]
Sent: Friday, February 22, 2019 12:39 AM
To: Jim Hulbert 
Cc: EMC-PSTC@listserv.ieee.org
Subject: **External**Re: [PSES] FCC Part 15 Testing in Situ

Hi

Tried this once and the ambients confounded the measurements and this was well 
before Wi-Fi, IOT, and widespread use of cellphones. The digital thermometer on 
the wall was significantly above the part 15 limit! Even desk phones and 
copiers dominated measurements in some frequency ranges and locations.

Also having 3-5m 360 degree access around the systems was not a reasonable 
expectation.

In the end, we used best effort and engineering judgement to create a 
certification report that met, in our opinion, the intent of the law. Good 
luck- Hope your systems are installed someplace nice like, say, Hawaii.
Sent from my mobile
Please excuse brevity & grammar

On Feb 21, 2019, at 12:48 PM, Jim Hulbert 
mailto:jim.hulb...@bluecrestinc.com>> wrote:
Equipment that is covered under FCC Rules Part 15, but which is too large to 
test on an open area test site, can alternatively been tested in situ.  
However, the rules state that the test should be performed at 3 different 
representative installations of the equipment.  Does anyone on this forum have 
experience doing this?  I would expect conducted emissions to be reasonably 
similar, but I can see how environmental influences could result in 3 different 
sets of radiated emissions data.  How do you make sense of the data?

Jim Hulbert



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information. It is intended only for the use of the intended recipient(s). If 
you have received it in error, please immediately advise the sender by reply 
email and then delete this message. No one other than the intended recipient 
may disclose, copy, distribute or use the information contained in this message.




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Re: [PSES] **External**Re: [PSES] FCC Part 15 Testing in Situ

[Jim Hulbert]

Yes, FCC requirements for this type of equipment are not very practical.As 
a side note, such large equipment is industrial in nature, which may lead one 
to believe they would fall under FCC Part 18 for ISM instead of Part 15.   
However, Part 18 only covers industrial equipment that generates and locally 
uses RF energy for the production of physical, biological, or chemical effects. 
 An industrial machine that does not utilize RF energy for these purposes is 
not within scope of Part 18, and so Part 15 applies.

I don't think there is any hope of FCC revisiting these rules any time soon, 
however.

Jim Hulbert

From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Friday, February 22, 2019 3:05 AM
To: Jim Hulbert ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: **External**Re: [PSES] FCC Part 15 Testing in Situ


Such very large equipment tends to be custom-designed, so three identical 
installations never exist. Even if there are three identical installations, 
they are unlikely to be completed simultaneously, so how can the first two be 
legally operated before the third is installed and tested?

I wonder if FCC needs to look again at this requirement.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk

Rayleigh, Essex UK
On 2019-02-21 20:48, Jim Hulbert wrote:
Equipment that is covered under FCC Rules Part 15, but which is too large to 
test on an open area test site, can alternatively been tested in situ.  
However, the rules state that the test should be performed at 3 different 
representative installations of the equipment.  Does anyone on this forum have 
experience doing this?  I would expect conducted emissions to be reasonably 
similar, but I can see how environmental influences could result in 3 different 
sets of radiated emissions data.  How do you make sense of the data?

Jim Hulbert



This email message may contain confidential, proprietary and/or privileged 
information. It is intended only for the use of the intended recipient(s). If 
you have received it in error, please immediately advise the sender by reply 
email and then delete this message. No one other than the intended recipient 
may disclose, copy, distribute or use the information contained in this message.




-


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David Heald mailto:dhe...@gmail.com>>

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formats), large files, etc.

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