Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

As the discussion is about regulatory requirements in the US, what an 
individual may understand what a particular label does or does not mean and buy 
accordingly, that does not reflect what the requirement of the country are.

I for example, unless I am not familiar with a particular product or product 
manufacturer, do not look at label when buying a product as I expect reputable 
dealers with whom I deal to be aware of the requirements to put the product up 
for sale.  I pay much more attention to the store guarantee about the product.  
 Consequently, when buying TVs, computers, toasters, coffee maker, beds, 
furniture, or any other item, it is generally not an issue.  That has already 
been resolved.

Now, if I go out and buy a product of lesser value and of lesser reputation, 
then 'Caveat Emptor'.  Even then, if buying the product from a reputable 
dealer, their warranty generally resolves issues.

I am what might be called a gagitholic.  I buy a lot of electronic devices, 
etc.  And as a ham, I also buy amateur radio equipment now and then.  And, 
again, labels are of little interest to me as a buyer and the MTBF rates are of 
little concern.  Products in the US are every bit as good and reliable as any 
purchased anywhere else in the world.

But then there is the old adage - buy cheap, get cheap.

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
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confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
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-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: Tuesday, October 4, 2016 4:23 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 10/3/2016 12:08 PM, dward wrote:
> To repeat the obvious.  The fact that the CE marking is or is not on a 
> product in the US is really irrelevant to being able to be sold in the US.  
> The US market is not dependent upon other countries or Unions compliance 
> agendas or standards.  It is only the necessary push by manufacturers to 
> minimize the sizes of labels and yet have one label so as to sell in as many 
> areas of the world as possible, that has made it so irrelevant and/ or 
> unneeded markings, appear on products in The US; but they have absolutely no 
> legal meaning.


Some of us reading this thread will remember having received a bit of a shock 
when our employers decided to sell products in Europe and encountered VDE 0871, 
with an expanded conducted emissions  range and stricter requirements.

Those of us who own and use communications equipment for our employers, 
agencies, or Amateur Radio stations  will also remember looking for the VDE 
label; it was much less likely to cause interference to our own operations and 
more likely to function while we were transmitting.  


This is one reason why many of us in the United States now look for a CE mark. 
Equipment bearing it is at least as good as Part 15 in meeting our needs, and 
it seems more likely to be enforced in countries that DO require it.

Cortland Richmond
KA5S

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Attachments are not permitted but the IEEE PSES Online Communities site at 
htt

Re: [PSES] [RFI] Part 15 isn't enough..

[Nyffenegger, Dave]

Absolutely.  I tell this to folks all the time, in particular for the 
immunity/susceptibility.   Especially  all my Caribbean island friends who have 
 to live with daily surges from the grid coming from the local power plant and 
infrastructure where many electronic products have early failures.  Of course 
surge protectors help too.

-Dave

-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: Tuesday, October 04, 2016 7:23 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 10/3/2016 12:08 PM, dward wrote:
> To repeat the obvious.  The fact that the CE marking is or is not on a 
> product in the US is really irrelevant to being able to be sold in the US.  
> The US market is not dependent upon other countries or Unions compliance 
> agendas or standards.  It is only the necessary push by manufacturers to 
> minimize the sizes of labels and yet have one label so as to sell in as many 
> areas of the world as possible, that has made it so irrelevant and/ or 
> unneeded markings, appear on products in The US; but they have absolutely no 
> legal meaning.


Some of us reading this thread will remember having received a bit of a shock 
when our employers decided to sell products in Europe and encountered VDE 0871, 
with an expanded conducted emissions  range and stricter requirements.

Those of us who own and use communications equipment for our employers, 
agencies, or Amateur Radio stations  will also remember looking for the VDE 
label; it was much less likely to cause interference to our own operations and 
more likely to function while we were transmitting.  


This is one reason why many of us in the United States now look for a CE mark. 
Equipment bearing it is at least as good as Part 15 in meeting our needs, and 
it seems more likely to be enforced in countries that DO require it.

Cortland Richmond
KA5S

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
<emc-p...@ieee.org>

All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

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

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Jim Bacher:  <j.bac...@ieee.org>
David Heald: <dhe...@gmail.com>

Re: [PSES] [RFI] Part 15 isn't enough..

[Cortland Richmond]

On 10/3/2016 12:08 PM, dward wrote:

To repeat the obvious.  The fact that the CE marking is or is not on a product 
in the US is really irrelevant to being able to be sold in the US.  The US 
market is not dependent upon other countries or Unions compliance agendas or 
standards.  It is only the necessary push by manufacturers to minimize the 
sizes of labels and yet have one label so as to sell in as many areas of the 
world as possible, that has made it so irrelevant and/ or unneeded markings, 
appear on products in The US; but they have absolutely no legal meaning.



Some of us reading this thread will remember having received a bit of a 
shock when our employers decided to sell products in Europe and 
encountered VDE 0871, with an expanded conducted emissions  range and 
stricter requirements.


Those of us who own and use communications equipment for our employers, 
agencies, or Amateur Radio stations  will also remember looking for the 
VDE label; it was much less likely to cause interference to our own 
operations and more likely to function while we were transmitting.  
This is one reason why many of us in the United States now look for a 
CE mark. Equipment bearing it is at least as good as Part 15 in meeting 
our needs, and it seems more likely to be enforced in countries that DO 
require it.


Cortland Richmond
KA5S

-

This message is from the IEEE Product Safety Engineering Society emc-pstc discussion 
list. To post a message to the list, send your e-mail to 

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

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

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

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

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

Re: [PSES] [RFI] Part 15 isn't enough..

[Nyffenegger, Dave]

And of course the OSHA NRTL marks are required in the US on applicable products 
(which do not include EMC).

-Dave

-Original Message-
From: dward [mailto:dw...@pctestlab.com] 
Sent: Monday, October 03, 2016 12:09 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

To repeat the obvious.  The fact that the CE marking is or is not on a product 
in the US is really irrelevant to being able to be sold in the US.  The US 
market is not dependent upon other countries or Unions compliance agendas or 
standards.  It is only the necessary push by manufacturers to minimize the 
sizes of labels and yet have one label so as to sell in as many areas of the 
world as possible, that has made it so irrelevant and/ or unneeded markings, 
appear on products in The US; but they have absolutely no legal meaning.  

Many parts of the world accept CE marking as evidence of compliance, many 
accept FCC labeling as evidence of compliance.  The appearance of one over the 
other only matters for the specific country allowing or disallowing such label. 
 This we should all know. 

Consequently, in the US, no mark is acceptable as evidence of compliance, even 
while such markings may appear on products, unless that marking is specific to 
the US.  The FCC grant of authorization (FCC ID number),  FCC DoC, the required 
medical labels,  or the required FDA labels and such are the only valid labels 
for US products.   

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: Grasso, Charles [mailto:charles.gra...@echostar.com]
Sent: Monday, October 3, 2016 8:37 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Gert - That's a difficult question to answer. For high volume manufacturers 
(consumer type products) the presence of the CE mark in the US is a byproduct 
of the compliance marking (i.e. one label) and is common place.

-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl]
Sent: Saturday, October 01, 2016 3:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

John Allen wrote:
>That's probably why the products from some major multinationals (as mentioned 
>in the previously linked >website) could not be sold elsewhere in the major 
>World markets without suitable compliance and >verification, and yet can be 
>sold in the US.

I was wondering if that is really the case ?  Can our US collegues witness that 
product of reputable manufacturers are not wearing the CE marking in the US. ?? 
 




Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing Education

Web:www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information that is 
confidential and/or protected by intellectual property rights and are intended 
for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not limited to, 
total or partial reproduction, communication or distribution in any form) by 
persons other than the designated
recipient(s) is prohibited. If you have received this e-mail in error, please 
notify the sender either by telephone or by e-mail and delete the material from 
any computer. 
Thank you for your co-operation.

From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Friday 30 September 2016 15:31
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dieter

Yes, that's what the words state, and have done for years - but, with no clear 
requirements or guidelines as to the technical requirements (tests, limits, 
pass/fail conditions etc.) or the actual need to do verification, then 
many/most 

Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

To repeat the obvious.  The fact that the CE marking is or is not on a product 
in the US is really irrelevant to being able to be sold in the US.  The US 
market is not dependent upon other countries or Unions compliance agendas or 
standards.  It is only the necessary push by manufacturers to minimize the 
sizes of labels and yet have one label so as to sell in as many areas of the 
world as possible, that has made it so irrelevant and/ or unneeded markings, 
appear on products in The US; but they have absolutely no legal meaning.  

Many parts of the world accept CE marking as evidence of compliance, many 
accept FCC labeling as evidence of compliance.  The appearance of one over the 
other only matters for the specific country allowing or disallowing such label. 
 This we should all know. 

Consequently, in the US, no mark is acceptable as evidence of compliance, even 
while such markings may appear on products, unless that marking is specific to 
the US.  The FCC grant of authorization (FCC ID number),  FCC DoC, the required 
medical labels,  or the required FDA labels and such are the only valid labels 
for US products.   

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: Grasso, Charles [mailto:charles.gra...@echostar.com] 
Sent: Monday, October 3, 2016 8:37 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Gert - That's a difficult question to answer. For high volume manufacturers 
(consumer type products) the presence of the CE mark in the US is a byproduct 
of the compliance marking (i.e. one label) and is common place.

-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl]
Sent: Saturday, October 01, 2016 3:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

John Allen wrote:
>That's probably why the products from some major multinationals (as mentioned 
>in the previously linked >website) could not be sold elsewhere in the major 
>World markets without suitable compliance and >verification, and yet can be 
>sold in the US.

I was wondering if that is really the case ?  Can our US collegues witness that 
product of reputable manufacturers are not wearing the CE marking in the US. ?? 
 




Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing Education

Web:www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information that is 
confidential and/or protected by intellectual property rights and are intended 
for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not limited to, 
total or partial reproduction, communication or distribution in any form) by 
persons other than the designated
recipient(s) is prohibited. If you have received this e-mail in error, please 
notify the sender either by telephone or by e-mail and delete the material from 
any computer. 
Thank you for your co-operation.

From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Friday 30 September 2016 15:31
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dieter

Yes, that's what the words state, and have done for years - but, with no clear 
requirements or guidelines as to the technical requirements (tests, limits, 
pass/fail conditions etc.) or the actual need to do verification, then 
many/most suppliers appear to me to ignore those words! I think the same was 
true in Europe during the period after the original EMC Directive (76/889/EEC) 
was published but before the CE marking requirement version (89/336/EC) came 
out and required "proof" of compliance in the form of test reports, tech f

Re: [PSES] [RFI] Part 15 isn't enough..

[Grasso, Charles]

Gert - That's a difficult question to answer. For high volume manufacturers 
(consumer type products) the presence 
of the CE mark in the US is a byproduct of the compliance marking (i.e. one 
label) and is common place.

-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] 
Sent: Saturday, October 01, 2016 3:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

John Allen wrote:
>That's probably why the products from some major multinationals (as mentioned 
>in the previously linked >website) could not be sold elsewhere in the major 
>World markets without suitable compliance and >verification, and yet can be 
>sold in the US.

I was wondering if that is really the case ?  Can our US collegues witness that 
product of reputable manufacturers are not wearing the CE marking in the US. ?? 
 




Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking
 according to EC-directives:
    - Electro Magnetic Compatibility 2004/108/EC
    - Electrical Safety 2006/95/EC
    - Medical Devices 93/42/EC
    - Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing Education

Web:    www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information that is 
confidential and/or protected by intellectual property rights and are intended 
for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not limited to, 
total or partial reproduction, communication or distribution in any form) by 
persons other than the designated
recipient(s) is prohibited. If you have received this e-mail in error, please 
notify the sender either by telephone or by e-mail and delete the material from 
any computer. 
Thank you for your co-operation.

From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Friday 30 September 2016 15:31
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dieter

Yes, that's what the words state, and have done for years - but, with no clear 
requirements or guidelines as to the technical requirements (tests, limits, 
pass/fail conditions etc.) or the actual need to do verification, then 
many/most suppliers appear to me to ignore those words! I think the same was 
true in Europe during the period after the original EMC Directive (76/889/EEC) 
was published but before the CE marking requirement version (89/336/EC) came 
out and required "proof" of compliance in the form of test reports, tech files 
and the CE marking - after that, things gradually began to change! 

The big problem in 1989, and for some years after, was the almost total lack of 
standards against which to do the tests and assessments on non-military 
products. However, some 25+ years later, the same cannot be said as there are 
many international, and even US trade-body, standards which could almost 
immediately be used as the basis for realistic sets of requirements to be 
formulated.

Many multi-national and US companies already do that as normal development 
practice, but in the current US legislative environment they can then "cost 
cut" for the US market by either not doing that testing on US-market specific 
products, or "cost reducing" their internationally-sold products for sale in 
that market. That's probably why the products from some major multinationals 
(as mentioned in the previously linked website) could not be sold elsewhere in 
the major World markets without suitable compliance and verification, and yet 
can be sold in the US. 

John E Allen
W. London, UK

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com]
Sent: 30 September 2016 13:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately. 

 
Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.
 
And finally, isn't FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)
§15.5   General conditions of operation.
 (a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of any given 
frequency by virtue of prior registration or certification of equipmen

Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

Depends on the voltage.  If 120/240 then it is probably for world market and 
the CE mark is probably on it. If it is only 120, then it would not be 
acceptable for place a CE marking on the product.  But then the CE marking has 
no meaning in the US and is not acceptable for compliance issues. 

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] 
Sent: Saturday, October 1, 2016 2:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

John Allen wrote:
>That's probably why the products from some major multinationals (as mentioned 
>in the previously linked >website) could not be sold elsewhere in the major 
>World markets without suitable compliance and >verification, and yet can be 
>sold in the US.

I was wondering if that is really the case ?  Can our US collegues witness that 
product of reputable manufacturers are not wearing the CE marking in the US. ?? 
 




Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing Education

Web:www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information that is 
confidential and/or protected by intellectual property rights and are intended 
for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not limited to, 
total or partial reproduction, communication or distribution in any form) by 
persons other than the designated
recipient(s) is prohibited. If you have received this e-mail in error, please 
notify the sender either by telephone or by e-mail and delete the material from 
any computer. 
Thank you for your co-operation.

From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Friday 30 September 2016 15:31
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dieter

Yes, that's what the words state, and have done for years - but, with no clear 
requirements or guidelines as to the technical requirements (tests, limits, 
pass/fail conditions etc.) or the actual need to do verification, then 
many/most suppliers appear to me to ignore those words! I think the same was 
true in Europe during the period after the original EMC Directive (76/889/EEC) 
was published but before the CE marking requirement version (89/336/EC) came 
out and required "proof" of compliance in the form of test reports, tech files 
and the CE marking - after that, things gradually began to change! 

The big problem in 1989, and for some years after, was the almost total lack of 
standards against which to do the tests and assessments on non-military 
products. However, some 25+ years later, the same cannot be said as there are 
many international, and even US trade-body, standards which could almost 
immediately be used as the basis for realistic sets of requirements to be 
formulated.

Many multi-national and US companies already do that as normal development 
practice, but in the current US legislative environment they can then "cost 
cut" for the US market by either not doing that testing on US-market specific 
products, or "cost reducing" their internationally-sold products for sale in 
that market. That's probably why the products from some major multinationals 
(as mentioned in the previously linked website) could not be sold elsewhere in 
the major World markets without suitable compliance and verification, and yet 
can be sold in the US. 

John E Allen
W. London, UK

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com]
Sent: 30 September 2016 13:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I 

Re: [PSES] [RFI] Part 15 isn't enough..

[John Woodgate]

The problem with immunity cases is that it's really necessary to investigate 
each one. Sometimes it only needs a site inspection [1], but in other cases, 
it's necessary to DF the source and measure its field strength, which is costly.

[1] Site inspection: Why can't I unlock my car with the remote when it's parked 
in the car port? 
Because the wireless doorbell transmitter also works on 433 MHz. Transmitter is 
on in a pulsed handshake mode, but unmodulated until the button is pressed. 
Separation distance to nearest antenna in the car is about 2 m – too close.

With best wishes DESIGN IT IN! OOO – Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.


-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: Saturday, October 1, 2016 12:22 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 10/1/2016 6:26 AM, john Allen wrote:
> My comment about major manufacturers was partially based on the 
> appearance of a Sony TV on the apartmenttherapy website, as linked by 
> Cortland,

Right site, wrong appliance; it was an oven,

" was summertime and we weren’t using our oven much but we noticed that 
occasionally the oven would just turn itself /on/. It’s the type of 
wall-mounted oven wherein you must turn the oven “on” then set the temperature 
before it actually starts warming up. If you turn the oven “on” and don’t set 
the temperature the oven beeps as a reminder. That’s what was happening: very 
randomly our oven would start beeping as a reminder for us to set the 
temperature. But we hadn’t turned the oven on. Why was it doing this? 
Additionally, when I did turn the oven on and set the temperature, the oven 
would turn itself off after eight minutes. 
It did this over and over again so I couldn’t complete a baking cycle. 
Please bear with this saga…"


Cortland Richmond
KA5S

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Re: [PSES] [RFI] Part 15 isn't enough..

[john Allen]

John

 

That said, don’t forget the UK requirement for much construction site equipment 
to be 110V and it would have to be CE marked to the Machinery Directive (etc.) 
– maybe not “120V” but effectively very little different, although the 
standards would still be different to the US.

 

John E Allen

W. London, UK

 

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: 02 October 2016 07:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

I didn't say that 120 V operation is not allowed under the LVD.  I said that 
120 V-only products would not be sold in Europe, so EN safety standards 
wouldn't be applied, so the LVD wouldn't apply.

 

That CE-marked machinery must conform to all applicable Directives, otherwise 
the marking is illegal.

 

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

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

 

Sylvae in aeternum manent.

 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Sunday, October 2, 2016 5:09 AM
To: John Woodgate <jmw1...@btinternet.com>; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

 

I’ve not seen where conformity  to the LVD (or MD) disallows operation at 120V. 
 While it wouldn’t make sense or perhaps not allowed to sell 120V rated 
products for consumer use in the EU I’ve seen CE  marked commercial machinery 
designed primarily for the NA market and rated at 120V or 120/208 50/60Hz 
installed in the EU with the appropriate transformer (transformer not part of 
the product).  In much the same way European manufactured commercial products 
rated at European voltage are installed in the US with transformers.

 

-Dave

 

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Saturday, October 01, 2016 10:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Products that work only on 120 V obviously won't be CE marked, even if they 
meet the EMC Directive, because CE requires conformity to all applicable 
Directives and that includes the Low Voltage Directive.

 

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

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

 

Sylvae in aeternum manent.

 

From: Adam Dixon [mailto:lanterna.viri...@gmail.com] 
Sent: Saturday, October 1, 2016 2:39 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Reply to John's question about CE marking on products in US:  

Results from an early Saturday morning visit to local (Atlanta, GA) WalMart to 
look at product labels are:

Televisions:  no CE marking (FCC + UL was common to all six models from five 
manufacturers, majority of which would be considered reputable.)

Laptops:  CE marking (could only see markings on one unit the way they are 
displayed, as well as markings are typically covered by removeable battery 
pack).  Laptops @ home have CE marking.

LCD monitors:  LG monitor @ home w/CE marking

 

Power tools w/ or w/o lithium batteries:  no CE marking, first time seeing ANCE 
marking on one battery powered drill which also had NOM and CSA markings but no 
UL marking.

Toaster ovens:  no CE marking

Microwaves:  no CE marking

Childrens' electronic toys:  don't know - got in trouble w/store security 
unboxing before I could confirm.

Just kidding about the last one

Cheers,

Adam in Atlanta

 

 

On Sat, Oct 1, 2016 at 5:57 AM, ce-test, qualified testing bv - Gert Gremmen 
<g.grem...@cetest.nl> wrote:

John Allen wrote:
>That's probably why the products from some major multinationals (as mentioned 
>in the previously linked >website) could not be sold elsewhere in the major 
>World markets without suitable compliance and >verification, and yet can be 
>sold in the US.

I was wondering if that is really the case ?  Can our US collegues witness that 
product of reputable manufacturers are not wearing the CE marking in the US. ??




Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:www.cetest.nl (English)
Phone :  +31 10 415 24 26 <tel:%2B31%2010%20415%2024%2026> 
---
This e-mail and any attachments thereto may contain information
that is confidential and/or protected by intellectual property rights
and are intended for the sole use of the recipient(s) name

Re: [PSES] [RFI] Part 15 isn't enough..

[John Woodgate]

I didn't say that 120 V operation is not allowed under the LVD.  I said that 
120 V-only products would not be sold in Europe, so EN safety standards 
wouldn't be applied, so the LVD wouldn't apply.
 
That CE-marked machinery must conform to all applicable Directives, otherwise 
the marking is illegal.
 
With best wishes DESIGN IT IN! OOO – Own Opinions Only
 <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and 
Associates Rayleigh England
 
Sylvae in aeternum manent.
 
From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Sunday, October 2, 2016 5:09 AM
To: John Woodgate <jmw1...@btinternet.com>; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..
 
I’ve not seen where conformity  to the LVD (or MD) disallows operation at 120V. 
 While it wouldn’t make sense or perhaps not allowed to sell 120V rated 
products for consumer use in the EU I’ve seen CE  marked commercial machinery 
designed primarily for the NA market and rated at 120V or 120/208 50/60Hz 
installed in the EU with the appropriate transformer (transformer not part of 
the product).  In much the same way European manufactured commercial products 
rated at European voltage are installed in the US with transformers.
 
-Dave
 
From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Saturday, October 01, 2016 10:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Products that work only on 120 V obviously won't be CE marked, even if they 
meet the EMC Directive, because CE requires conformity to all applicable 
Directives and that includes the Low Voltage Directive.
 
With best wishes DESIGN IT IN! OOO – Own Opinions Only
 <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and 
Associates Rayleigh England
 
Sylvae in aeternum manent.
 
From: Adam Dixon [mailto:lanterna.viri...@gmail.com] 
Sent: Saturday, October 1, 2016 2:39 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Reply to John's question about CE marking on products in US:  

Results from an early Saturday morning visit to local (Atlanta, GA) WalMart to 
look at product labels are:
Televisions:  no CE marking (FCC + UL was common to all six models from five 
manufacturers, majority of which would be considered reputable.)
Laptops:  CE marking (could only see markings on one unit the way they are 
displayed, as well as markings are typically covered by removeable battery 
pack).  Laptops @ home have CE marking.
LCD monitors:  LG monitor @ home w/CE marking
 
Power tools w/ or w/o lithium batteries:  no CE marking, first time seeing ANCE 
marking on one battery powered drill which also had NOM and CSA markings but no 
UL marking.
Toaster ovens:  no CE marking
Microwaves:  no CE marking
Childrens' electronic toys:  don't know - got in trouble w/store security 
unboxing before I could confirm.
Just kidding about the last one
Cheers,
Adam in Atlanta
 
 
On Sat, Oct 1, 2016 at 5:57 AM, ce-test, qualified testing bv - Gert Gremmen 
<g.grem...@cetest.nl <mailto:g.grem...@cetest.nl> > wrote:
John Allen wrote:
>That's probably why the products from some major multinationals (as mentioned 
>in the previously linked >website) could not be sold elsewhere in the major 
>World markets without suitable compliance and >verification, and yet can be 
>sold in the US.

I was wondering if that is really the case ?  Can our US collegues witness that 
product of reputable manufacturers are not wearing the CE marking in the US. ??




Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:www.cetest.nl <http://www.cetest.nl>  (English)
Phone :  +31 10 415 24 26 <tel:%2B31%2010%20415%2024%2026> 
---
This e-mail and any attachments thereto may contain information
that is confidential and/or protected by intellectual property rights
and are intended for the sole use of the recipient(s) named above.
Any use of the information contained herein (including, but not
limited to, total or partial reproduction, communication or
distribution in any form) by persons other than the designated
recipient(s) is prohibited. If you have received this e-mail in error,
please notify the sender either by telephone or by e-mail and
delete the material from any co

Re: [PSES] [RFI] Part 15 isn't enough..

[Nyffenegger, Dave]

I’ve not seen where conformity  to the LVD (or MD) disallows operation at 120V. 
 While it wouldn’t make sense or perhaps not allowed to sell 120V rated 
products for consumer use in the EU I’ve seen CE  marked commercial machinery 
designed primarily for the NA market and rated at 120V or 120/208 50/60Hz 
installed in the EU with the appropriate transformer (transformer not part of 
the product).  In much the same way European manufactured commercial products 
rated at European voltage are installed in the US with transformers.

-Dave

From: John Woodgate [mailto:jmw1...@btinternet.com]
Sent: Saturday, October 01, 2016 10:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Products that work only on 120 V obviously won't be CE marked, even if they 
meet the EMC Directive, because CE requires conformity to all applicable 
Directives and that includes the Low Voltage Directive.

With best wishes DESIGN IT IN! OOO – Own Opinions Only
www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk/> J M Woodgate and Associates 
Rayleigh England

Sylvae in aeternum manent.

From: Adam Dixon [mailto:lanterna.viri...@gmail.com]
Sent: Saturday, October 1, 2016 2:39 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Reply to John's question about CE marking on products in US:

Results from an early Saturday morning visit to local (Atlanta, GA) WalMart to 
look at product labels are:
Televisions:  no CE marking (FCC + UL was common to all six models from five 
manufacturers, majority of which would be considered reputable.)
Laptops:  CE marking (could only see markings on one unit the way they are 
displayed, as well as markings are typically covered by removeable battery 
pack).  Laptops @ home have CE marking.
LCD monitors:  LG monitor @ home w/CE marking

Power tools w/ or w/o lithium batteries:  no CE marking, first time seeing ANCE 
marking on one battery powered drill which also had NOM and CSA markings but no 
UL marking.
Toaster ovens:  no CE marking
Microwaves:  no CE marking
Childrens' electronic toys:  don't know - got in trouble w/store security 
unboxing before I could confirm.

Just kidding about the last one

Cheers,
Adam in Atlanta


On Sat, Oct 1, 2016 at 5:57 AM, ce-test, qualified testing bv - Gert Gremmen 
<g.grem...@cetest.nl<mailto:g.grem...@cetest.nl>> wrote:
John Allen wrote:
>That's probably why the products from some major multinationals (as mentioned 
>in the previously linked >website) could not be sold elsewhere in the major 
>World markets without suitable compliance and >verification, and yet can be 
>sold in the US.

I was wondering if that is really the case ?  Can our US collegues witness that 
product of reputable manufacturers are not wearing the CE marking in the US. ??




Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:www.cetest.nl<http://www.cetest.nl> (English)
Phone :  +31 10 415 24 26<tel:%2B31%2010%20415%2024%2026>
---
This e-mail and any attachments thereto may contain information
that is confidential and/or protected by intellectual property rights
and are intended for the sole use of the recipient(s) named above.
Any use of the information contained herein (including, but not
limited to, total or partial reproduction, communication or
distribution in any form) by persons other than the designated
recipient(s) is prohibited. If you have received this e-mail in error,
please notify the sender either by telephone or by e-mail and
delete the material from any computer.
Thank you for your co-operation.

From: John Allen 
[mailto:john_e_al...@blueyonder.co.uk<mailto:john_e_al...@blueyonder.co.uk>]
Sent: Friday 30 September 2016 15:31
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dieter

Yes, that's what the words state, and have done for years - but, with no clear 
requirements or guidelines as to the technical requirements (tests, limits, 
pass/fail conditions etc.) or the actual need to do verification, then 
many/most suppliers appear to me to ignore those words! I think the same was 
true in Europe during the period after the original EMC Directive (76/889/EEC) 
was published but before the CE marking requirement version (89/336/EC) came 
out and required "proof" of compliance in the form of test re

Re: [PSES] [RFI] Part 15 isn't enough..

[John Allen]

Adam


W.r.t. worldwide sales, in some cases a company, and that includes many US 
ones, require the “agility” to quickly distribute and redirect products to many 
different markets, and that may mean minimising the numbers of varieties of 
those products – that’s quite common in market sectors like ITE and some AV 
products where the only difference between those going to the US, Japan and 
Europe will often  be the power cord because of the use of auto-ranging PSUs, 
and that also means that it will have to meet (or at least claim to meet!) all 
the regional EMC emission and immunity regs.

 

However domestic appliances and the like don’t generally sell so quickly and 
cost margins can be lower, and market preferences for the styles and features 
may differ more – that can often be the reason that such appliances tend to be 
market-specific and so the use of dedicated voltage PSUs and so on are more 
likely to be used. 

 

I think your ad hoc survey in Walmart generally illustrates the above points.

 

Re the TV market, don’t forget that digital terrestrial and satellite TV is now 
predominant in many developed regions of the world and the transmission 
characteristics of those systems have been pretty much standardised worldwide – 
so the references to the analogue (OUR spelling!) NTSC  & PAL systems are 
rather out of date! J. Also means that the relevant reception equipment is 
often designed to cope with many of the regional variations by firmware 
programming or plug-in modules and cards, and not by hardware changes – so such 
equipment is often multi-voltage/frequency and can be sold worldwide (subject 
to local technical import regs and approvals and so on), and so it will 
(should!) have to meet all the relevant EMC emissions and immunity requirements.

 

General “conclusion” (well, sort of) from the above – if you want to get 
equipment that has reasonably low emissions AND good immunity, then buy the 
same models that are intended to be sold in lots of other countries; if not 
then buy the US-market specific models and “good luck” on the immunity side of 
things.

 

John E Allen

W. London, UK

 

From: Adam Dixon [mailto:lanterna.viri...@gmail.com] 
Sent: 01 October 2016 17:15
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Well, it wasn't a totally wasted trip since I picked up treats for our dog.  ;-)

120VAC is within the 50-1000VAC LVD range, though I am not familiar with 120VAC 
or the minimum 50VAC applications in the UK.  I was thinking about product 
designs which apply to worldwide markets.  So it ends up being more a case of 
designing and certifying for country- or region-specific or worldwide markets.  
Attributes such as power supply cost, efficiency and universal vs non-universal 
input voltage, as well as scope and cost of regulatory compliance for one 
country vs worldwide, etc.  And for the television market, NTSC or PAL or both.


http://ec.europa.eu/growth/sectors/electrical-engineering/lvd-directive_en



Cheers,

Adam

 

 

On Sat, Oct 1, 2016 at 10:06 AM, John Woodgate <jmw1...@btinternet.com> wrote:

Products that work only on 120 V obviously won't be CE marked, even if they 
meet the EMC Directive, because CE requires conformity to all applicable 
Directives and that includes the Low Voltage Directive.

 

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

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

 

Sylvae in aeternum manent.

 

From: Adam Dixon [mailto:lanterna.viri...@gmail.com] 
Sent: Saturday, October 1, 2016 2:39 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Reply to John's question about CE marking on products in US:  

Results from an early Saturday morning visit to local (Atlanta, GA) WalMart to 
look at product labels are:

Televisions:  no CE marking (FCC + UL was common to all six models from five 
manufacturers, majority of which would be considered reputable.)

Laptops:  CE marking (could only see markings on one unit the way they are 
displayed, as well as markings are typically covered by removeable battery 
pack).  Laptops @ home have CE marking.

LCD monitors:  LG monitor @ home w/CE marking

 

Power tools w/ or w/o lithium batteries:  no CE marking, first time seeing ANCE 
marking on one battery powered drill which also had NOM and CSA markings but no 
UL marking.

Toaster ovens:  no CE marking

Microwaves:  no CE marking

Childrens' electronic toys:  don't know - got in trouble w/store security 
unboxing before I could confirm.

Just kidding about the last one

Cheers,

Adam in Atlanta

 

 

On Sat, Oct 1, 2016 at 5:57 AM, ce-test, qualified testing bv - Gert Gremmen 
<g.grem...@cetest.nl> wrote:

John Allen wrote:
>That's probably why the products from some major multinationals (as mentioned 
>in the previously linked >website) could not be sold elsewhere in th

Re: [PSES] [RFI] Part 15 isn't enough..

[John Woodgate]

Yes, 120 V is in the scope of the LVD, but for US-only sales you would not 
apply the relevant EN safety standard, as required (in practice but not de 
jure) by the LVD but the corresponding UL standard. 
 
Products that work on 120 V (or lower) and 230 V (or higher) are obviously 
intended for world-wide sales, so would conform to the EMCD and LVD for Europe, 
so can be CE marked, and to whatever other EMC and safety standards are 
required for market entry in the other countries.
 
With best wishes DESIGN IT IN! OOO – Own Opinions Only
 <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and 
Associates Rayleigh England
 
Sylvae in aeternum manent.
 
From: Adam Dixon [mailto:lanterna.viri...@gmail.com] 
Sent: Saturday, October 1, 2016 5:15 PM
To: John Woodgate <jmw1...@btinternet.com>
Cc: EMC-PSTC@listserv.ieee.org
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Well, it wasn't a totally wasted trip since I picked up treats for our dog.  ;-)

120VAC is within the 50-1000VAC LVD range, though I am not familiar with 120VAC 
or the minimum 50VAC applications in the UK.  I was thinking about product 
designs which apply to worldwide markets.  So it ends up being more a case of 
designing and certifying for country- or region-specific or worldwide markets.  
Attributes such as power supply cost, efficiency and universal vs non-universal 
input voltage, as well as scope and cost of regulatory compliance for one 
country vs worldwide, etc.  And for the television market, NTSC or PAL or both.

http://ec.europa.eu/growth/sectors/electrical-engineering/lvd-directive_en


Cheers,
Adam
 
 
On Sat, Oct 1, 2016 at 10:06 AM, John Woodgate <jmw1...@btinternet.com 
<mailto:jmw1...@btinternet.com> > wrote:
Products that work only on 120 V obviously won't be CE marked, even if they 
meet the EMC Directive, because CE requires conformity to all applicable 
Directives and that includes the Low Voltage Directive.
 
With best wishes DESIGN IT IN! OOO – Own Opinions Only
 <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and 
Associates Rayleigh England
 
Sylvae in aeternum manent.
 
From: Adam Dixon [mailto:lanterna.viri...@gmail.com 
<mailto:lanterna.viri...@gmail.com> ] 
Sent: Saturday, October 1, 2016 2:39 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Reply to John's question about CE marking on products in US:  

Results from an early Saturday morning visit to local (Atlanta, GA) WalMart to 
look at product labels are:
Televisions:  no CE marking (FCC + UL was common to all six models from five 
manufacturers, majority of which would be considered reputable.)
Laptops:  CE marking (could only see markings on one unit the way they are 
displayed, as well as markings are typically covered by removeable battery 
pack).  Laptops @ home have CE marking.
LCD monitors:  LG monitor @ home w/CE marking
 
Power tools w/ or w/o lithium batteries:  no CE marking, first time seeing ANCE 
marking on one battery powered drill which also had NOM and CSA markings but no 
UL marking.
Toaster ovens:  no CE marking
Microwaves:  no CE marking
Childrens' electronic toys:  don't know - got in trouble w/store security 
unboxing before I could confirm.
Just kidding about the last one
Cheers,
Adam in Atlanta
 
 
On Sat, Oct 1, 2016 at 5:57 AM, ce-test, qualified testing bv - Gert Gremmen 
<g.grem...@cetest.nl <mailto:g.grem...@cetest.nl> > wrote:
John Allen wrote:
>That's probably why the products from some major multinationals (as mentioned 
>in the previously linked >website) could not be sold elsewhere in the major 
>World markets without suitable compliance and >verification, and yet can be 
>sold in the US.

I was wondering if that is really the case ?  Can our US collegues witness that 
product of reputable manufacturers are not wearing the CE marking in the US. ??




Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:www.cetest.nl <http://www.cetest.nl>  (English)
Phone :  +31 10 415 24 26 <tel:%2B31%2010%20415%2024%2026> 
---
This e-mail and any attachments thereto may contain information
that is confidential and/or protected by intellectual property rights
and are intended for the sole use of the recipient(s) named above.
Any use of the information contained herein (including,

Re: [PSES] [RFI] Part 15 isn't enough..

[Adam Dixon]

Well, it wasn't a totally wasted trip since I picked up treats for our
dog.  ;-)

120VAC is within the 50-1000VAC LVD range, though I am not familiar with
120VAC or the minimum 50VAC applications in the UK.  I was thinking about
product designs which apply to worldwide markets.  So it ends up being more
a case of designing and certifying for country- or region-specific or
worldwide markets.  Attributes such as power supply cost, efficiency and
universal vs non-universal input voltage, as well as scope and cost of
regulatory compliance for one country vs worldwide, etc.  And for the
television market, NTSC or PAL or both.

http://ec.europa.eu/growth/sectors/electrical-engineering/lvd-directive_en


Cheers,
Adam



On Sat, Oct 1, 2016 at 10:06 AM, John Woodgate <jmw1...@btinternet.com>
wrote:

> Products that work only on 120 V obviously won't be CE marked, even if
> they meet the EMC Directive, because CE requires conformity to all
> applicable Directives and that includes the Low Voltage Directive.
>
>
>
> With best wishes DESIGN IT IN! OOO – Own Opinions Only
>
> www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England
>
>
>
> Sylvae in aeternum manent.
>
>
>
> *From:* Adam Dixon [mailto:lanterna.viri...@gmail.com]
> *Sent:* Saturday, October 1, 2016 2:39 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] [RFI] Part 15 isn't enough..
>
>
>
> Reply to John's question about CE marking on products in US:
>
> Results from an early Saturday morning visit to local (Atlanta, GA)
> WalMart to look at product labels are:
>
> Televisions:  no CE marking (FCC + UL was common to all six models from
> five manufacturers, majority of which would be considered reputable.)
>
> Laptops:  CE marking (could only see markings on one unit the way they are
> displayed, as well as markings are typically covered by removeable battery
> pack).  Laptops @ home have CE marking.
>
> LCD monitors:  LG monitor @ home w/CE marking
>
>
>
> Power tools w/ or w/o lithium batteries:  no CE marking, first time seeing
> ANCE marking on one battery powered drill which also had NOM and CSA
> markings but no UL marking.
>
> Toaster ovens:  no CE marking
>
> Microwaves:  no CE marking
>
> Childrens' electronic toys:  don't know - got in trouble w/store security
> unboxing before I could confirm.
>
> Just kidding about the last one
>
> Cheers,
>
> Adam in Atlanta
>
>
>
>
>
> On Sat, Oct 1, 2016 at 5:57 AM, ce-test, qualified testing bv - Gert
> Gremmen <g.grem...@cetest.nl> wrote:
>
> John Allen wrote:
> >That's probably why the products from some major multinationals (as
> mentioned in the previously linked >website) could not be sold elsewhere in
> the major World markets without suitable compliance and >verification, and
> yet can be sold in the US.
>
> I was wondering if that is really the case ?  Can our US collegues witness
> that product of reputable manufacturers are not wearing the CE marking in
> the US. ??
>
>
>
>
> Regards,
>
> Ing. Gert Gremmen
> Approvals manager
> 
> 
>
>
> + ce marking of electrical/electronic equipment
> + Independent Consultancy Services
> + Compliance Testing and Design for CE marking
>  according to EC-directives:
> - Electro Magnetic Compatibility 2004/108/EC
> - Electrical Safety 2006/95/EC
> - Medical Devices 93/42/EC
> - Radio & Telecommunication Terminal Equipment 99/5/EC
> + Improvement of Product Quality and Reliability testing
> + Education
>
> Web:www.cetest.nl (English)
> Phone :  +31 10 415 24 26
> ---
> This e-mail and any attachments thereto may contain information
> that is confidential and/or protected by intellectual property rights
> and are intended for the sole use of the recipient(s) named above.
> Any use of the information contained herein (including, but not
> limited to, total or partial reproduction, communication or
> distribution in any form) by persons other than the designated
> recipient(s) is prohibited. If you have received this e-mail in error,
> please notify the sender either by telephone or by e-mail and
> delete the material from any computer.
> Thank you for your co-operation.
>
> From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
> Sent: Friday 30 September 2016 15:31
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
>
> Dieter
>
> Yes, that's what the words state, and have done for years - but, with no
> clear requirements or guidelines as to t

Re: [PSES] [RFI] Part 15 isn't enough..

[John Allen]

Sorry, my error as I was posting from memory and did not check back on the site 
in question.

John E Allen
W. London, UK

-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: 01 October 2016 12:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 10/1/2016 6:26 AM, john Allen wrote:
> My comment about major manufacturers was partially based on the 
> appearance of a Sony TV on the apartmenttherapy website, as linked by 
> Cortland,

Right site, wrong appliance; it was an oven,

" was summertime and we weren’t using our oven much but we noticed that 
occasionally the oven would just turn itself /on/. It’s the type of 
wall-mounted oven wherein you must turn the oven “on” then set the temperature 
before it actually starts warming up. If you turn the oven “on” and don’t set 
the temperature the oven beeps as a reminder. That’s what was happening: very 
randomly our oven would start beeping as a reminder for us to set the 
temperature. But we hadn’t turned the oven on. Why was it doing this? 
Additionally, when I did turn the oven on and set the temperature, the oven 
would turn itself off after eight minutes. 
It did this over and over again so I couldn’t complete a baking cycle. 
Please bear with this saga…"


Cortland Richmond
KA5S

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
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<emc-p...@ieee.org>

All emc-pstc postings are archived and searchable on the web at:
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Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to 
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-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
<emc-p...@ieee.org>

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

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

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

For help, send mail to the list administrators:
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For policy questions, send mail to:
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David Heald: <dhe...@gmail.com>

Re: [PSES] [RFI] Part 15 isn't enough..

[John Woodgate]

Products that work only on 120 V obviously won't be CE marked, even if they 
meet the EMC Directive, because CE requires conformity to all applicable 
Directives and that includes the Low Voltage Directive.
 
With best wishes DESIGN IT IN! OOO – Own Opinions Only
 <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and 
Associates Rayleigh England
 
Sylvae in aeternum manent.
 
From: Adam Dixon [mailto:lanterna.viri...@gmail.com] 
Sent: Saturday, October 1, 2016 2:39 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Reply to John's question about CE marking on products in US:  

Results from an early Saturday morning visit to local (Atlanta, GA) WalMart to 
look at product labels are:
Televisions:  no CE marking (FCC + UL was common to all six models from five 
manufacturers, majority of which would be considered reputable.)
Laptops:  CE marking (could only see markings on one unit the way they are 
displayed, as well as markings are typically covered by removeable battery 
pack).  Laptops @ home have CE marking.
LCD monitors:  LG monitor @ home w/CE marking
 
Power tools w/ or w/o lithium batteries:  no CE marking, first time seeing ANCE 
marking on one battery powered drill which also had NOM and CSA markings but no 
UL marking.
Toaster ovens:  no CE marking
Microwaves:  no CE marking
Childrens' electronic toys:  don't know - got in trouble w/store security 
unboxing before I could confirm.


Just kidding about the last one


Cheers,
Adam in Atlanta
 
 
On Sat, Oct 1, 2016 at 5:57 AM, ce-test, qualified testing bv - Gert Gremmen 
<g.grem...@cetest.nl <mailto:g.grem...@cetest.nl> > wrote:
John Allen wrote:
>That's probably why the products from some major multinationals (as mentioned 
>in the previously linked >website) could not be sold elsewhere in the major 
>World markets without suitable compliance and >verification, and yet can be 
>sold in the US.

I was wondering if that is really the case ?  Can our US collegues witness that 
product of reputable manufacturers are not wearing the CE marking in the US. ??




Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:www.cetest.nl <http://www.cetest.nl>  (English)
Phone :  +31 10 415 24 26 <tel:%2B31%2010%20415%2024%2026> 
---
This e-mail and any attachments thereto may contain information
that is confidential and/or protected by intellectual property rights
and are intended for the sole use of the recipient(s) named above.
Any use of the information contained herein (including, but not
limited to, total or partial reproduction, communication or
distribution in any form) by persons other than the designated
recipient(s) is prohibited. If you have received this e-mail in error,
please notify the sender either by telephone or by e-mail and
delete the material from any computer.
Thank you for your co-operation.

From: John Allen [mailto:john_e_al...@blueyonder.co.uk 
<mailto:john_e_al...@blueyonder.co.uk> ]
Sent: Friday 30 September 2016 15:31
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dieter

Yes, that's what the words state, and have done for years - but, with no clear 
requirements or guidelines as to the technical requirements (tests, limits, 
pass/fail conditions etc.) or the actual need to do verification, then 
many/most suppliers appear to me to ignore those words! I think the same was 
true in Europe during the period after the original EMC Directive (76/889/EEC) 
was published but before the CE marking requirement version (89/336/EC) came 
out and required "proof" of compliance in the form of test reports, tech files 
and the CE marking - after that, things gradually began to change!

The big problem in 1989, and for some years after, was the almost total lack of 
standards against which to do the tests and assessments on non-military 
products. However, some 25+ years later, the same cannot be said as there are 
many international, and even US trade-body, standards which could almost 
immediately be used as the basis for realistic sets of requirements to be 
formulated.

Many multi-national and US companies already do that as normal development 
practice, but in the current US legislative environment they can then "cost 
cut" for the US market by either not doing that te

Re: [PSES] [RFI] Part 15 isn't enough..

[Adam Dixon]

Reply to John's question about CE marking on products in US:

Results from an early Saturday morning visit to local (Atlanta, GA) WalMart
to look at product labels are:

Televisions:  no CE marking (FCC + UL was common to all six models from
five manufacturers, majority of which would be considered reputable.)

Laptops:  CE marking (could only see markings on one unit the way they are
displayed, as well as markings are typically covered by removeable battery
pack).  Laptops @ home have CE marking.

LCD monitors:  LG monitor @ home w/CE marking

Power tools w/ or w/o lithium batteries:  no CE marking, first time seeing
ANCE marking on one battery powered drill which also had NOM and CSA
markings but no UL marking.

Toaster ovens:  no CE marking

Microwaves:  no CE marking

Childrens' electronic toys:  don't know - got in trouble w/store security
unboxing before I could confirm.


Just kidding about the last one


Cheers,
Adam in Atlanta


On Sat, Oct 1, 2016 at 5:57 AM, ce-test, qualified testing bv - Gert
Gremmen <g.grem...@cetest.nl> wrote:

> John Allen wrote:
> >That's probably why the products from some major multinationals (as
> mentioned in the previously linked >website) could not be sold elsewhere in
> the major World markets without suitable compliance and >verification, and
> yet can be sold in the US.
>
> I was wondering if that is really the case ?  Can our US collegues witness
> that product of reputable manufacturers are not wearing the CE marking in
> the US. ??
>
>
>
>
> Regards,
>
> Ing. Gert Gremmen
> Approvals manager
> 
> 
>
>
> + ce marking of electrical/electronic equipment
> + Independent Consultancy Services
> + Compliance Testing and Design for CE marking
>  according to EC-directives:
> - Electro Magnetic Compatibility 2004/108/EC
> - Electrical Safety 2006/95/EC
> - Medical Devices 93/42/EC
> - Radio & Telecommunication Terminal Equipment 99/5/EC
> + Improvement of Product Quality and Reliability testing
> + Education
>
> Web:www.cetest.nl (English)
> Phone :  +31 10 415 24 26
> ---
> This e-mail and any attachments thereto may contain information
> that is confidential and/or protected by intellectual property rights
> and are intended for the sole use of the recipient(s) named above.
> Any use of the information contained herein (including, but not
> limited to, total or partial reproduction, communication or
> distribution in any form) by persons other than the designated
> recipient(s) is prohibited. If you have received this e-mail in error,
> please notify the sender either by telephone or by e-mail and
> delete the material from any computer.
> Thank you for your co-operation.
>
> From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
> Sent: Friday 30 September 2016 15:31
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
>
> Dieter
>
> Yes, that's what the words state, and have done for years - but, with no
> clear requirements or guidelines as to the technical requirements (tests,
> limits, pass/fail conditions etc.) or the actual need to do verification,
> then many/most suppliers appear to me to ignore those words! I think the
> same was true in Europe during the period after the original EMC Directive
> (76/889/EEC) was published but before the CE marking requirement version
> (89/336/EC) came out and required "proof" of compliance in the form of test
> reports, tech files and the CE marking - after that, things gradually began
> to change!
>
> The big problem in 1989, and for some years after, was the almost total
> lack of standards against which to do the tests and assessments on
> non-military products. However, some 25+ years later, the same cannot be
> said as there are many international, and even US trade-body, standards
> which could almost immediately be used as the basis for realistic sets of
> requirements to be formulated.
>
> Many multi-national and US companies already do that as normal development
> practice, but in the current US legislative environment they can then "cost
> cut" for the US market by either not doing that testing on US-market
> specific products, or "cost reducing" their internationally-sold products
> for sale in that market. That's probably why the products from some major
> multinationals (as mentioned in the previously linked website) could not be
> sold elsewhere in the major World markets without suitable compliance and
> verification, and yet can be sold in the US.
>
> John E Allen
> W. London, UK
>
> From: P

Re: [PSES] [RFI] Part 15 isn't enough..

[Cortland Richmond]

On 10/1/2016 6:26 AM, john Allen wrote:

My comment about major manufacturers was partially based on the appearance
of a Sony TV on the apartmenttherapy website, as linked by Cortland,


Right site, wrong appliance; it was an oven,

" was summertime and we weren’t using our oven much but we noticed that 
occasionally the oven would just turn itself /on/. It’s the type of 
wall-mounted oven wherein you must turn the oven “on” then set the 
temperature before it actually starts warming up. If you turn the oven 
“on” and don’t set the temperature the oven beeps as a reminder. That’s 
what was happening: very randomly our oven would start beeping as a 
reminder for us to set the temperature. But we hadn’t turned the oven 
on. Why was it doing this? Additionally, when I did turn the oven on and 
set the temperature, the oven would turn itself off after eight minutes. 
It did this over and over again so I couldn’t complete a baking cycle. 
Please bear with this saga…"



Cortland RichmondKA5S

-

This message is from the IEEE Product Safety Engineering Society emc-pstc discussion 
list. To post a message to the list, send your e-mail to 

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

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

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

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

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

Re: [PSES] [RFI] Part 15 isn't enough..

[john Allen]

Gert

My comment about major manufacturers was partially based on the appearance
of a Sony TV on the apartmenttherapy website, as linked by Cortland, which
appeared to be unduly susceptible to external interference and you would not
expect that from a large manufacturer of that stature - and that made me
speculate as to which other such company's products have the same issues?

John E Allen
W. London, UK

-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: 01 October 2016 10:57
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

John Allen wrote:
>That's probably why the products from some major multinationals (as
mentioned in the previously linked >website) could not be sold elsewhere in
the major World markets without suitable compliance and >verification, and
yet can be sold in the US.

I was wondering if that is really the case ?  Can our US collegues witness
that product of reputable manufacturers are not wearing the CE marking in
the US. ??  




Regards,

Ing. Gert Gremmen
Approvals manager




+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking
 according to EC-directives:
    - Electro Magnetic Compatibility 2004/108/EC
    - Electrical Safety 2006/95/EC
    - Medical Devices 93/42/EC
    - Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing Education

Web:    www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information that is
confidential and/or protected by intellectual property rights and are
intended for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not limited to,
total or partial reproduction, communication or distribution in any form) by
persons other than the designated
recipient(s) is prohibited. If you have received this e-mail in error,
please notify the sender either by telephone or by e-mail and delete the
material from any computer. 
Thank you for your co-operation.

From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Friday 30 September 2016 15:31
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dieter

Yes, that's what the words state, and have done for years - but, with no
clear requirements or guidelines as to the technical requirements (tests,
limits, pass/fail conditions etc.) or the actual need to do verification,
then many/most suppliers appear to me to ignore those words! I think the
same was true in Europe during the period after the original EMC Directive
(76/889/EEC) was published but before the CE marking requirement version
(89/336/EC) came out and required "proof" of compliance in the form of test
reports, tech files and the CE marking - after that, things gradually began
to change! 

The big problem in 1989, and for some years after, was the almost total lack
of standards against which to do the tests and assessments on non-military
products. However, some 25+ years later, the same cannot be said as there
are many international, and even US trade-body, standards which could almost
immediately be used as the basis for realistic sets of requirements to be
formulated.

Many multi-national and US companies already do that as normal development
practice, but in the current US legislative environment they can then "cost
cut" for the US market by either not doing that testing on US-market
specific products, or "cost reducing" their internationally-sold products
for sale in that market. That's probably why the products from some major
multinationals (as mentioned in the previously linked website) could not be
sold elsewhere in the major World markets without suitable compliance and
verification, and yet can be sold in the US. 

John E Allen
W. London, UK

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com]
Sent: 30 September 2016 13:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I believe that changing part 15 will be very difficult since it
is a legal  (political) document and would need congress approval for
changes. Different that than in the EU where you have directives and
harmonized standards somehow separately. 

 
Also the US is part of international committees and heavily participates on
emissions and immunity standards. However implementation and enforcing is
always difficult.
 
And finally, isn't FCC indirectly stating that immunity has to be met as
well?  FCC Part 15.5 (b)
§15.5   General conditions of operation.
 (a) Persons operating intentional or unintentional radiators shall not
be deem

Re: [PSES] [RFI] Part 15 isn't enough..

[ce-test, qualified testing bv - Gert Gremmen]

John Allen wrote:
>That's probably why the products from some major multinationals (as mentioned 
>in the previously linked >website) could not be sold elsewhere in the major 
>World markets without suitable compliance and >verification, and yet can be 
>sold in the US.

I was wondering if that is really the case ?  Can our US collegues witness that 
product of reputable manufacturers are not wearing the CE marking in the US. ?? 
 




Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
    - Electro Magnetic Compatibility 2004/108/EC
    - Electrical Safety 2006/95/EC
    - Medical Devices 93/42/EC
    - Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:    www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
and are intended for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not 
limited to, total or partial reproduction, communication or 
distribution in any form) by persons other than the designated 
recipient(s) is prohibited. If you have received this e-mail in error, 
please notify the sender either by telephone or by e-mail and 
delete the material from any computer. 
Thank you for your co-operation.

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Friday 30 September 2016 15:31
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dieter

Yes, that's what the words state, and have done for years - but, with no clear 
requirements or guidelines as to the technical requirements (tests, limits, 
pass/fail conditions etc.) or the actual need to do verification, then 
many/most suppliers appear to me to ignore those words! I think the same was 
true in Europe during the period after the original EMC Directive (76/889/EEC) 
was published but before the CE marking requirement version (89/336/EC) came 
out and required "proof" of compliance in the form of test reports, tech files 
and the CE marking - after that, things gradually began to change! 

The big problem in 1989, and for some years after, was the almost total lack of 
standards against which to do the tests and assessments on non-military 
products. However, some 25+ years later, the same cannot be said as there are 
many international, and even US trade-body, standards which could almost 
immediately be used as the basis for realistic sets of requirements to be 
formulated.

Many multi-national and US companies already do that as normal development 
practice, but in the current US legislative environment they can then "cost 
cut" for the US market by either not doing that testing on US-market specific 
products, or "cost reducing" their internationally-sold products for sale in 
that market. That's probably why the products from some major multinationals 
(as mentioned in the previously linked website) could not be sold elsewhere in 
the major World markets without suitable compliance and verification, and yet 
can be sold in the US. 

John E Allen
W. London, UK

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com] 
Sent: 30 September 2016 13:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately. 

 
Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.
 
And finally, isn't FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)
§15.5   General conditions of operation.
 (a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of any given 
frequency by virtue of prior registration or certification of equipment, or, 
for power line carrier systems, on the basis of prior notification of use 
pursuant to §90.35(g) of this chapter.
 (b) Operation of an intentional, unintentional, or incidental radiator is 
subject to the conditions that no harmful interference is caused and that 
interference must be accepted that may be caused by the operation of an 
authorized radio station, by another intentional or unintentional radiator, by

Re: [PSES] [RFI] Part 15 isn't enough..

[John Woodgate]

IEC/CISPR classes all of those as immunity.

With best wishes DESIGN IT IN! OOO – Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.


-Original Message-
From: dward [mailto:dw...@pctestlab.com] 
Sent: Friday, September 30, 2016 7:26 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Do not confuse susceptibility of interference with immunity such as ESD, Fast 
Transient, etc.   The susceptibility spoken of is that of Spectrum Protection, 
and the protection of licensed users, not ESD, RF immunity, etc.

And, the actual law states "(2) establishing minimum performance standards 
for home electronic equipment and systems to reduce their susceptibility to 
interference from radio frequency energy."  
But then that is the 1982 version. The Telecommunications Act of 1934 amended 
1996 is the current law in force, not the 1982.  Also, while irrelevant, the 
1982 law only changed a few phrases to better describe specific instances.  
Such as adding "or home electronic equipment and systems" after "devices", and 
adding who can train and who can give amateur license testing.
​
The relevant law (i.e. Telecommunications Act of 1934 as amended in 1996) says 
" The Commission may, consistent with the public interest, convenience, and 
necessity, make reasonable regulations (1) governing the interference potential 
of devices which in their operation are capable of emitting radio frequency 
energy by radiation, conduction, or other means in sufficient degree to cause 
harmful interference to radio communications; and (2) establishing minimum 
performance standards for home electronic equipment and systems to reduce their 
susceptibility to interference from radio frequency energy. Such regulations 
shall be applicable to the manufacture, import, sale, offer for sale, or 
shipment of such devices and home electronic equipment and systems, and to the 
use of such devices.

Again, this is not immunity in the sense of radiated immunity, ESD, Fast 
Transient etc., but susceptibility only in regards to protection of the 
spectrum. 


Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
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or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net]
Sent: Friday, September 30, 2016 10:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 1:03 PM, dward wrote:
> Nor will there ever be anything in the FCC rules about immunity simply 
> because that, as Gherry state, has nothing to do with the protection 
> of the Spectrum.

The FCC already has the authority it needs to require *some* RF immunity, and 
has since 1982:

http://www.arrl.org/public-law-97-259

excerpt:


The FCC has opted for voluntary standards, rather than formal rules and 
regulations. The FCC and the ARRL are both active in an industry group (in 
cooperation with the American National Standards Institute, ANSI) that is 
studying "RF immunity issues." The Accredited Standards Committee C-63, has set 
an RFI-rejection standard for certain home electronic equipment. The voluntary 
standard provides for immunity of consumer equipment to some levels of RF field 
strength. This standard is not sufficient for full-power amateur stations under 
"worst case" 
conditions, but it covers the majority of cases. Starting in the second half of 
the 1990s, consumers started to see some built-in immunity in consumer 
products. The industry has a ways to go, but there is some light at the end of 
the tunnel.


Cortland
ka5s

-

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Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

Ed

Regulations are not law.  The communication act of 1934 instituted the FCC and 
gave it authority to make regulations based on the law. That law was amended in 
1996.  The FCC cannot implement Law, it can however, implement regulations 
based on the actual law as long as those regulations are in accord with that 
law, and it can, to a certain extent, enforce those regulations through fines 
etc.

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
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the sender immediately if you receive this communication in error, and delete 
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or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: Friday, September 30, 2016 3:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Dennis:

 

Not true. Congress passes a Communications Act, a law, and it directs the FCC 
to implement that law. These Acts may stand for years or may be superseded with 
a new Act whenever Congress wants to write a new one. The FCC proposes Rules 
which it thinks will implement the spirit and letter of that Communications 
Act, and then the maneuvering begins. The FCC currently has no basis of law to 
“protect the consumer,” but if Congress wishes to do so, the FCC will be 
mandated, funded and expanded to enforce Congressional wishes.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Friday, September 30, 2016 10:04 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Nor will there ever be anything in the FCC rules about immunity simply because 
that, as Gherry state, has nothing to do with the protection of the Spectrum.

 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Friday, September 30, 2016 9:03 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

The intent of the quoted statute is simply to protect licensed users of the 
spectrum from unlicensed unintentional “poachers.”  The licensed user paid for 
their use of the spectrum, and any unlicensed “poacher” must cease and desist 
his use when it interferes with the operation of a licensed user. 

It also says that one unlicensed user has no protection from another unlicensed 
user, and certainly not from a licensed user.

Basically just laying out a “pecking order” in terms of rights to use the 
spectrum.

Nothing here about immunity at all.

Ken Javor
Phone: (256) 650-5261

  _  

From: "Paasche, Dieter" <dieter.paas...@christiedigital.com 
<mailto:dieter.paas...@christiedigital.com> >
Reply-To: "Paasche, Dieter" <dieter.paas...@christiedigital.com 
<mailto:dieter.paas...@christiedigital.com> >
Date: Fri, 30 Sep 2016 12:59:04 +
To: <EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Conversation: [PSES] [RFI] Part 15 isn't enough..
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately. 
 
Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.
 
And finally, isn’t FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)
§15.5   General conditions of operation.
(a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of a

Re: [PSES] [RFI] Part 15 isn't enough..

[john Allen]

Cortland

Given the legal and philosophical  "issues" in the USA, that sounds as if it 
MIGHT work - my latest take on this subject, as "discussed" today from both 
sides, is that suppliers and users of intentional emitters should not be 
immune(!) from legal action if they continue to cause interference to 
non-intentional emitters and their use by entirely "innocent" people going 
about their legal daily business and activities at work and at home. Again, 
what is good for the goose (intentional emitter suppliers/users) is good for 
the gander (the rest of the public).

Not a particularly "good" solution IMHO - but maybe the best you collectively 
can hope for at present, given the apparently "entrenched" position of many 
people in the US who oppose any concept of immunity/susceptibility testing for 
general public-use products :-(.

Unfortunately that approach still does not address the, probably widespread, 
issue of one non-intentional product interfering with another one - which, I 
would suggest, is probably the more widespread problem for many of the public 
but they don't know what the issues are or how to fix them. 

For example, in my own case, my first digital sat receiver (around 1998) 
suffered interference from other components in my AV system (and this was a 
quite widely reported problem as I recall), until, with some relevant 
background knowledge to help, I replaced all the old single screened RF 
connections with decent double screened sat-spec cable - most people would not 
know why/how to do that. However, since then, I (and presumably many other 
consumers!) have never suffered the same issues  as the newer receivers are far 
more resilient to external interference because the manufacturers have been 
compelled to comply with the EU immunity requirements!

John E Allen
W. London, UK





-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: 30 September 2016 21:04
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 2:16 PM, Ken Javor wrote:
> I still don't understand what the applicability is, but if that 
> statement about MIL-STD-461 applies to products to be sold 
> commercially, it has serious issues and drawbacks that make it utterly 
> impractical.

I suspect the choice of MIL-Standards was made to reduce emissions more than 
FCC rules require and thus increase the margin available to prevent 
interference in the marketplace.

The problem with lower numerical limits is, however, that either they become 
prohibitively expensive to manufacture, or they will be adopted pro forma and 
ignored in practice – which is often what manufacturers do already facing FCC 
limits.  It does not help to require compliance with standards never meant to 
apply to consumer devices.



A reasonable default limitation – Part 15 – can put a ceiling on the number of 
interference complaints, and a predictably expensive penalty for actually 
causing interference could ensure that manufacturers actually complied with 
those limits, thus my suggestion to require a manufacturer warranty covering 
the costs of remediation should interference occur.  I think that might be 
enough; if coupled with a warranty against susceptibility to nearby 
transmitters, it could substantially reduce the number of complaints from that 
side as well.

Cortland Richmond
KA5S

-

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

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Instructions:  http://www.ieee-pse

Re: [PSES] [RFI] Part 15 isn't enough..

[Ed Price]

Dennis:

 

Not true. Congress passes a Communications Act, a law, and it directs the FCC 
to implement that law. These Acts may stand for years or may be superseded with 
a new Act whenever Congress wants to write a new one. The FCC proposes Rules 
which it thinks will implement the spirit and letter of that Communications 
Act, and then the maneuvering begins. The FCC currently has no basis of law to 
“protect the consumer,” but if Congress wishes to do so, the FCC will be 
mandated, funded and expanded to enforce Congressional wishes.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Friday, September 30, 2016 10:04 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Nor will there ever be anything in the FCC rules about immunity simply because 
that, as Gherry state, has nothing to do with the protection of the Spectrum.

 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Friday, September 30, 2016 9:03 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

The intent of the quoted statute is simply to protect licensed users of the 
spectrum from unlicensed unintentional “poachers.”  The licensed user paid for 
their use of the spectrum, and any unlicensed “poacher” must cease and desist 
his use when it interferes with the operation of a licensed user. 

It also says that one unlicensed user has no protection from another unlicensed 
user, and certainly not from a licensed user.

Basically just laying out a “pecking order” in terms of rights to use the 
spectrum.

Nothing here about immunity at all.

Ken Javor
Phone: (256) 650-5261

  _  

From: "Paasche, Dieter" <dieter.paas...@christiedigital.com>
Reply-To: "Paasche, Dieter" <dieter.paas...@christiedigital.com>
Date: Fri, 30 Sep 2016 12:59:04 +
To: <EMC-PSTC@LISTSERV.IEEE.ORG>
Conversation: [PSES] [RFI] Part 15 isn't enough..
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately. 
 
Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.
 
And finally, isn’t FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)
§15.5   General conditions of operation.
(a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of any given 
frequency by virtue of prior registration or certification of equipment, or, 
for power line carrier systems, on the basis of prior notification of use 
pursuant to §90.35(g) of this chapter.
(b) Operation of an intentional, unintentional, or incidental radiator is 
subject to the conditions that no harmful interference is caused and that 
interference must be accepted that may be caused by the operation of an 
authorized radio station, by another intentional or unintentional radiator, by 
industrial, scientific and medical (ISM) equipment, or by an incidental 
radiator.
(c) The operator of a radio frequency device shall be required to cease 
operating the device upon notification by a Commission representative that the 
device is causing harmful interference. Operation shall not resume until the 
condition causing the harmful interference has been corrected.
(d) Intentional radiators that produce Class B emissions (damped wave) are 
prohibited.


Sincerely, 
 
Dieter Paasche


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
<emc-p...@ieee.org>

All emc-pstc postings are archived and searchable on the web at: 
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large fi

Re: [PSES] [RFI] Part 15 isn't enough..

[Cortland Richmond]

On 9/30/2016 2:16 PM, Ken Javor wrote:

I still don't understand what the applicability is, but if that statement
about MIL-STD-461 applies to products to be sold commercially, it has
serious issues and drawbacks that make it utterly impractical.


I suspect the choice of MIL-Standards was made to reduce emissions more 
than FCC rules require and thus increase the margin available to prevent 
interference in the marketplace.


The problem with lower numerical limits is, however, that either they 
become prohibitively expensive to manufacture, or they will be adopted 
pro forma and ignored in practice – which is often what manufacturers do 
already facing FCC limits.  It does not help to require compliance with 
standards never meant to apply to consumer devices.


A reasonable default limitation – Part 15 – can put a ceiling on the 
number of interference complaints, and a predictably expensive penalty 
for actually causing interference could ensure that manufacturers 
actually complied with those limits, thus my suggestion to require a 
manufacturer warranty covering the costs of remediation should 
interference occur.  I think that might be enough; if coupled with a 
warranty against susceptibility to nearby transmitters, it could 
substantially reduce the number of complaints from that side as well.


Cortland Richmond
KA5S

-

This message is from the IEEE Product Safety Engineering Society emc-pstc discussion 
list. To post a message to the list, send your e-mail to 

All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
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List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

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

Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

Do not confuse susceptibility of interference with immunity such as ESD, Fast 
Transient, etc.   The susceptibility spoken of is that of Spectrum Protection, 
and the protection of licensed users, not ESD, RF immunity, etc.

And, the actual law states "(2) establishing minimum performance standards 
for home electronic equipment and systems to reduce their susceptibility to 
interference from radio frequency energy."  
But then that is the 1982 version. The Telecommunications Act of 1934 amended 
1996 is the current law in force, not the 1982.  Also, while irrelevant, the 
1982 law only changed a few phrases to better describe specific instances.  
Such as adding "or home electronic equipment and systems" after "devices", and 
adding who can train and who can give amateur license testing.
​
The relevant law (i.e. Telecommunications Act of 1934 as amended in 1996) says 
" The Commission may, consistent with the public interest, convenience, and 
necessity, make reasonable regulations (1) governing the interference potential 
of devices which in their operation are capable of emitting radio frequency 
energy by radiation, conduction, or other means in sufficient degree to cause 
harmful interference to radio communications; and (2) establishing minimum 
performance standards for home electronic equipment and systems to reduce their 
susceptibility to interference from radio frequency energy. Such regulations 
shall be applicable to the manufacture, import, sale, offer for sale, or 
shipment of such devices and home
electronic equipment and systems, and to the use of such devices.

Again, this is not immunity in the sense of radiated immunity, ESD, Fast 
Transient etc., but susceptibility only in regards to protection fo the 
spectrum. 


Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: Friday, September 30, 2016 10:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 1:03 PM, dward wrote:
> Nor will there ever be anything in the FCC rules about immunity simply 
> because that, as Gherry state, has nothing to do with the protection 
> of the Spectrum.

The FCC already has the authority it needs to require *some* RF immunity, and 
has since 1982:

http://www.arrl.org/public-law-97-259

excerpt:


The FCC has opted for voluntary standards, rather than formal rules and 
regulations. The FCC and the ARRL are both active in an industry group (in 
cooperation with the American National Standards Institute, ANSI) that is 
studying "RF immunity issues." The Accredited Standards Committee C-63, has set 
an RFI-rejection standard for certain home electronic equipment. The voluntary 
standard provides for immunity of consumer equipment to some levels of RF field 
strength. This standard is not sufficient for full-power amateur stations under 
"worst case" 
conditions, but it covers the majority of cases. Starting in the second half of 
the 1990s, consumers started to see some built-in immunity in consumer 
products. The industry has a ways to go, but there is some light at the end of 
the tunnel.


Cortland
ka5s

-

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

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

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

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

For help, send mail to the list administrators:
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David Heald: <dhe...@gmail.com>

-

This message is from the IEEE Product Safety Engineering Society emc

Re: [PSES] [RFI] Part 15 isn't enough..

[Ken Javor]

I still don't understand what the applicability is, but if that statement
about MIL-STD-461 applies to products to be sold commercially, it has
serious issues and drawbacks that make it utterly impractical.

In no particular order:

CS114, RE102, RS103 all have multiple limits based on Service applicability
and platform type. So the list is not specific enough to be applied.

RE102 and RS103 are nowhere near repeatable enough to even remotely qualify
as a barrier to market: any such requirement functioning as a barrier to
market (or gateway, depending on whether the glass is perceived half empty
or half full) must have the sort of repeatability claimed for test methods
such as CISPR 22. Note careful wording there.

CS116 and RS105 - EMP? Maybe for items that control the electrical grid, but
even there the limits would be all wrong because the -461 limits are
tailored for items the size of a vehicle of one sort or another, not cables
that interconnectedly stretch across a continent.

CE106 and the CS103/04/05 requirements were designed for transmit and
receive antennas co-located in close proximity to each other. That sort of
interaction outside an integrated vehicle will definitely occur with mobile
phones and wireless wi-fi router/hotspots, but aside from that isn't an
issue all across the spectrum as it is with a military vehicle with radios
operating across the spectrum.  For instance, imposing CS103/104 on say a
GPS receiver would require a front end filter for the L1/L2 band(s)
whichever is appropriate.  That adds cost and it isn't obvious there is a
need for the typical automotive application.

Ken Javor
Phone: (256) 650-5261


> From: Cortland Richmond <k...@earthlink.net>
> Reply-To: <k...@earthlink.net>
> Date: Fri, 30 Sep 2016 12:35:59 -0400
> To: <EMC-PSTC@LISTSERV.IEEE.ORG>
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> On 9/30/2016 12:04 PM, Ken Javor wrote:
>> Was the original post that started this long thread saying that Part 15
>> wasn't enough, we also needed immunity requirements, or as I understood it,
>> that Part 15 limits weren't low enough?
> 
> The latter, sort of,  but I added immunity (15.17) as a warranty item
> I'd like to see.
> 
> Here's the original:
> 
> Hey Gang,
> I know we have all discussed "part 15 isn't enough", particularly when we
> have talked about things like Solar systems
> 
> I was wondering - What if you were to say
> "System shall be compliant with MIL-STD-461F,
>   parts CE106,
>   CS103,104,105,114,115,116
> RE 102
> and
> RS 103, 105"
> 
> Think that should cover it?  Gives them an objective system of numbers to
> work with
> 
> 73 de KG2V
> Charlie
> 
> 
> 
> 
> Cortland
> KA5S
> 
> -
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to
> <emc-p...@ieee.org>
> 
> All emc-pstc postings are archived and searchable on the web at:
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> 
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Re: [PSES] [RFI] Part 15 isn't enough..

[John Woodgate]

To be logical, it is necessary to have emission limits, immunity requirements 
and specified measurement distances. Miss any one, let alone two, and the third 
is impossible to justify.

But the protection of radio services distorts this and leads to much 
misunderstanding. The radio receiver ipso facto doesn't have any immunity on 
the tuned frequency, so emission limits are set by considering what field 
strengths of wanted transmissions give adequate signal-to-noise ratios from the 
receivers, taking into account the undifferentiated levels of man-made and 
galactic EM noise. For example, an emission limit in field strength terms could 
be set to be equal, at a distance of 10 m from the source, to the 
undifferentiated level, thus reducing the S/N of a receiver at that distance by 
3 dB.

Interference with, for example, a microprocessor-controlled toaster is quite 
different. In this case, the toaster can reasonably be expected NOT to be an 
efficient radio receiver, so an immunity requirement can be set, such that the 
field strength of the source in the example above does not cause malfunction if 
the toaster is 10 m away. 

Of course, other measurement distances can be specified, taking into account 
the likely sources and victims in a given environment, and how far apart they 
are likely to be.

With best wishes DESIGN IT IN! OOO – Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.


-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: Friday, September 30, 2016 5:36 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 12:04 PM, Ken Javor wrote:
> Was the original post that started this long thread saying that Part 
> 15 wasn't enough, we also needed immunity requirements, or as I understood 
> it, that Part 15 limits weren't low enough?

The latter, sort of,  but I added immunity (15.17) as a warranty item I'd like 
to see.

Here's the original:

Hey Gang,
I know we have all discussed "part 15 isn't enough", particularly when we have 
talked about things like Solar systems

I was wondering - What if you were to say "System shall be compliant with 
MIL-STD-461F,
  parts CE106,
  CS103,104,105,114,115,116
RE 102
and
RS 103, 105"

Think that should cover it?  Gives them an objective system of numbers to work 
with

73 de KG2V
Charlie




Cortland
KA5S

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Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

Dieter

The simple answer to your question “isn’t FCC indirectly stating that immunity 
has to be met as well?  FCC Part 15.5 (b), is no.  While the FCC says that the 
manufacturer should consider methods to avoid interference, the impetus on 
15.5b only deals with interference to licensed users of the spectrum and not 
with any immunity issues not directly related to the protection of the 
spectrum. 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
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or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com] 
Sent: Friday, September 30, 2016 5:59 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately. 

 

Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.

 

And finally, isn’t FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)

§15.5   General conditions of operation.

(a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of any given 
frequency by virtue of prior registration or certification of equipment, or, 
for power line carrier systems, on the basis of prior notification of use 
pursuant to §90.35(g) of this chapter.

(b) Operation of an intentional, unintentional, or incidental radiator is 
subject to the conditions that no harmful interference is caused and that 
interference must be accepted that may be caused by the operation of an 
authorized radio station, by another intentional or unintentional radiator, by 
industrial, scientific and medical (ISM) equipment, or by an incidental 
radiator.

(c) The operator of a radio frequency device shall be required to cease 
operating the device upon notification by a Commission representative that the 
device is causing harmful interference. Operation shall not resume until the 
condition causing the harmful interference has been corrected.

(d) Intentional radiators that produce Class B emissions (damped wave) are 
prohibited.

 

Sincerely, 

 

Dieter Paasche

 



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-


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Re: [PSES] [RFI] Part 15 isn't enough..

[Cortland Richmond]

On 9/30/2016 1:03 PM, dward wrote:
Nor will there ever be anything in the FCC rules about immunity simply 
because that, as Gherry state, has nothing to do with the protection 
of the Spectrum.


The FCC already has the authority it needs to require *some* RF 
immunity, and has since 1982:


http://www.arrl.org/public-law-97-259

excerpt:


The FCC has opted for voluntary standards, rather than formal rules and 
regulations. The FCC and the ARRL are both active in an industry group 
(in cooperation with the American National Standards Institute, ANSI) 
that is studying "RF immunity issues." The Accredited Standards 
Committee C-63, has set an RFI-rejection standard for certain home 
electronic equipment. The voluntary standard provides for immunity of 
consumer equipment to some levels of RF field strength. This standard is 
not sufficient for full-power amateur stations under "worst case" 
conditions, but it covers the majority of cases. Starting in the second 
half of the 1990s, consumers started to see some built-in immunity in 
consumer products. The industry has a ways to go, but there is some 
light at the end of the tunnel.



Cortland
ka5s

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Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

Ops sorry Ghery, I put one to many r’s in your name.

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
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or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Friday, September 30, 2016 10:04 AM
To: 'Ken Javor' <ken.ja...@emccompliance.com>; 'EMC-PSTC@LISTSERV.IEEE.ORG' 
<EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

 

Nor will there ever be anything in the FCC rules about immunity simply because 
that, as Gherry state, has nothing to do with the protection of the Spectrum.

 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Friday, September 30, 2016 9:03 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

The intent of the quoted statute is simply to protect licensed users of the 
spectrum from unlicensed unintentional “poachers.”  The licensed user paid for 
their use of the spectrum, and any unlicensed “poacher” must cease and desist 
his use when it interferes with the operation of a licensed user. 

It also says that one unlicensed user has no protection from another unlicensed 
user, and certainly not from a licensed user.

Basically just laying out a “pecking order” in terms of rights to use the 
spectrum.

Nothing here about immunity at all.

Ken Javor
Phone: (256) 650-5261

  _  

From: "Paasche, Dieter" <dieter.paas...@christiedigital.com 
<mailto:dieter.paas...@christiedigital.com> >
Reply-To: "Paasche, Dieter" <dieter.paas...@christiedigital.com 
<mailto:dieter.paas...@christiedigital.com> >
Date: Fri, 30 Sep 2016 12:59:04 +
To: <EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Conversation: [PSES] [RFI] Part 15 isn't enough..
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately. 
 
Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.
 
And finally, isn’t FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)
§15.5   General conditions of operation.
(a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of any given 
frequency by virtue of prior registration or certification of equipment, or, 
for power line carrier systems, on the basis of prior notification of use 
pursuant to §90.35(g) of this chapter.
(b) Operation of an intentional, unintentional, or incidental radiator is 
subject to the conditions that no harmful interference is caused and that 
interference must be accepted that may be caused by the operation of an 
authorized radio station, by another intentional or unintentional radiator, by 
industrial, scientific and medical (ISM) equipment, or by an incidental 
radiator.
(c) The operator of a radio frequency device shall be required to cease 
operating the device upon notification by a Commission representative that the 
device is causing harmful interference. Operation shall not resume until the 
condition causing the harmful interference has been corrected.
(d) Intentional radiators that produce Class B emissions (damped wave) are 
prohibited.


Sincerely, 
 
Dieter Paasche

---

Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

Nor will there ever be anything in the FCC rules about immunity simply because 
that, as Gherry state, has nothing to do with the protection of the Spectrum.

 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Friday, September 30, 2016 9:03 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

The intent of the quoted statute is simply to protect licensed users of the 
spectrum from unlicensed unintentional “poachers.”  The licensed user paid for 
their use of the spectrum, and any unlicensed “poacher” must cease and desist 
his use when it interferes with the operation of a licensed user. 

It also says that one unlicensed user has no protection from another unlicensed 
user, and certainly not from a licensed user.

Basically just laying out a “pecking order” in terms of rights to use the 
spectrum.

Nothing here about immunity at all.

Ken Javor
Phone: (256) 650-5261



  _  

From: "Paasche, Dieter" <dieter.paas...@christiedigital.com 
<mailto:dieter.paas...@christiedigital.com> >
Reply-To: "Paasche, Dieter" <dieter.paas...@christiedigital.com 
<mailto:dieter.paas...@christiedigital.com> >
Date: Fri, 30 Sep 2016 12:59:04 +
To: <EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Conversation: [PSES] [RFI] Part 15 isn't enough..
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately. 
 
Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.
 
And finally, isn’t FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)
§15.5   General conditions of operation.
(a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of any given 
frequency by virtue of prior registration or certification of equipment, or, 
for power line carrier systems, on the basis of prior notification of use 
pursuant to §90.35(g) of this chapter.
(b) Operation of an intentional, unintentional, or incidental radiator is 
subject to the conditions that no harmful interference is caused and that 
interference must be accepted that may be caused by the operation of an 
authorized radio station, by another intentional or unintentional radiator, by 
industrial, scientific and medical (ISM) equipment, or by an incidental 
radiator.
(c) The operator of a radio frequency device shall be required to cease 
operating the device upon notification by a Commission representative that the 
device is causing harmful interference. Operation shall not resume until the 
condition causing the harmful interference has been corrected.
(d) Intentional radiators that produce Class B emissions (damped wave) are 
prohibited.


Sincerely, 
 
Dieter Paasche


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Jim Bache

Re: [PSES] [RFI] Part 15 isn't enough..

[John Allen]

Ghery

Does suing the relevant Federal authority happen (at least nowadays) with other 
aspects of Federal legislation, e.g. if the relevant Federal Motor Vehicle 
Safety Standards (FMVSS) for motor vehicle safety standard were thought to be 
inadequate would the NHTSA be sued - similarly with OSHA or the Consumer 
Product Safety Commission (CPSC) ?

If Yes, then you may have a good point, but if No/rarely then I think your 
point is not so well made, as, generally, EMC issues don't have quite the same 
potentially catastrophic effects (unless they cause aircraft crashes and so on) 
as inadequate motor vehicle safety, occupational safety or safety of consumer 
products, and so the likelihood of the FCC being hit by a major law suite would 
seem lower. 

John E Allen
W. London, UK

-Original Message-
From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: 30 September 2016 16:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

The FCC also is taking the route mandated by their charter - protect the radio 
users from interference.  Part 15 apparently does that adequately as 
interference complaints to the FCC have dropped to the noise level.  Not so 
before Part 15, Subpart J was published in the late 1970s.  Part 15 is doing 
its job.  Immunity testing isn't a "protection of the spectrum" issue.  
Besides, with the legal climate in the US, if the FCC mandated a certain level 
of immunity and someone was injured because that level wasn't high enough 
(allegedly or in actuality) the FCC would be sued.  Might not be successfully, 
but it is something to be avoided.  Keep in mind that the commissioners are 
political appointees.  Their job is to do their job while not making the 
President look bad.  Getting hauled into court doesn't do that so well.  Just 
another viewpoint...

Ghery S. Pettit

-Original Message-
From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Friday, September 30, 2016 8:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Cortland 

Sound like Congress being "ruled" by "big" and/or "small business" interests to 
make the FCC take the path of least resistance - I would have thought that 
their approach might have been deemed as being not in the general public 
interest, but I can now see where you are coming from on the warrantee front.

OTOH, from what I think you wrote earlier, some States would not permit that 
warrantee approach - sounds like more "vested interests" coming into play there.

Looks like rather a no-win situation on immunity improvements for products for 
the general public in the foreseeable future - unless, possibly, one or more 
important States were persuaded to pass appropriate legislation on the basis of 
the dangers from not doing so, as has been the cases related to environmental 
protection and energy conservation (and so on) that have affected the design 
and sale of electronic equipment 

Oh well, maybe someday EMC issues really will begin to "bite" a lot more people 
across the country and something will, most belatedly, be done at the Federal 
level.

John E Allen
W. London, UK

-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net]
Sent: 30 September 2016 14:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 8:59 AM, Dieter Paasche wrote:
> The operator of a radio frequency device shall be required to cease 
> operating the device *upon notification by a Commission
> representative* that the device is causing harmful interference.
[emphasis added]

The FCC has been reluctant to make that notification even after numerous 
complaints, as being too zealous in enforcing the Rules has historically 
resulted in Congress reducing the funds available to do so. You know the saying 
'Was nicht ausdrücklich erlaubt ist, ist verboten'; we have gone quite the 
opposite way to "Alles was nicht erlaubt ist, ist pflichtig" 
–  at least when there is profit to be had.

This is why I advocate placing a requirement the vendor warrant noninterference 
and RF immunity in the purchase contract.  What laws can't do, money can.

Cortland Richmond
KA5S

-

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F

Re: [PSES] [RFI] Part 15 isn't enough..

[John Allen]

Maybe my earlier comment about things coming to pass in the future might just 
have some very shallow roots even now?

 

John E Allen

W. London, UK

 

From: Ken Wyatt [mailto:k...@emc-seminars.com] 
Sent: 30 September 2016 16:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

I agree with Ghery that interference complaints from typical PC/ITE systems 
have dropped, but they’ve been getting numerous complaints lately, related to 
interference from lighting and in particular, out of compliance switching power 
supplies from offshore.

 

See: 
http://www.interferencetechnology.com/fcc-wants-help-understanding-spectral-noise-floor/

 

The overall noise floor below 200 MHz has increased to the point where the FCC 
is asking industry (and individuals) for historical noise floor data to assist 
with their analysis of the situation.

 

Cheers, Ken


___

 

I'm here to help you succeed! Feel free to call or email with any questions 
related to EMC or EMI troubleshooting - at no obligation. I'm always happy to 
help!


Kenneth Wyatt
Wyatt Technical Services LLC

56 Aspen Dr.
Woodland Park, CO 80863


Phone: (719) 310-5418


Email Me! <mailto:k...@emc-seminars.com>  | Web Site 
<http://www.emc-seminars.com>  | Blog <http://design-4-emc.com/> 

The EMC Blog (EDN) <http://www.edn.com/blog/The-EMC-Blog> 
Subscribe to Newsletter 
<http://www.emc-seminars.com/Newsletter/Newsletter.html> 
Connect with me on LinkedIn <http://www.linkedin.com/in/kennethwyatt> 

 

On Sep 30, 2016, at 9:26 AM, Ghery S. Pettit <n6...@comcast.net> wrote:

 

The FCC also is taking the route mandated by their charter - protect the radio 
users from interference.  Part 15 apparently does that adequately as 
interference complaints to the FCC have dropped to the noise level.  Not so 
before Part 15, Subpart J was published in the late 1970s.  Part 15 is doing 
its job.  Immunity testing isn't a "protection of the spectrum" issue.  
Besides, with the legal climate in the US, if the FCC mandated a certain level 
of immunity and someone was injured because that level wasn't high enough 
(allegedly or in actuality) the FCC would be sued.  Might not be successfully, 
but it is something to be avoided.  Keep in mind that the commissioners are 
political appointees.  Their job is to do their job while not making the 
President look bad.  Getting hauled into court doesn't do that so well.  Just 
another viewpoint...

Ghery S. Pettit

-Original Message-
From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Friday, September 30, 2016 8:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Cortland 

Sound like Congress being "ruled" by "big" and/or "small business" interests to 
make the FCC take the path of least resistance - I would have thought that 
their approach might have been deemed as being not in the general public 
interest, but I can now see where you are coming from on the warrantee front.

OTOH, from what I think you wrote earlier, some States would not permit that 
warrantee approach - sounds like more "vested interests" coming into play there.

Looks like rather a no-win situation on immunity improvements for products for 
the general public in the foreseeable future - unless, possibly, one or more 
important States were persuaded to pass appropriate legislation on the basis of 
the dangers from not doing so, as has been the cases related to environmental 
protection and energy conservation (and so on) that have affected the design 
and sale of electronic equipment 

Oh well, maybe someday EMC issues really will begin to "bite" a lot more people 
across the country and something will, most belatedly, be done at the Federal 
level.

John E Allen
W. London, UK

-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net]
Sent: 30 September 2016 14:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 8:59 AM, Dieter Paasche wrote:



The operator of a radio frequency device shall be required to cease 
operating the device *upon notification by a Commission
representative* that the device is causing harmful interference.

[emphasis added]

The FCC has been reluctant to make that notification even after numerous 
complaints, as being too zealous in enforcing the Rules has historically 
resulted in Congress reducing the funds available to do so. You know the saying 
'Was nicht ausdrücklich erlaubt ist, ist verboten'; we have gone quite the 
opposite way to "Alles was nicht erlaubt ist, ist pflichtig" 
–  at least when there is profit to be had.

This is why I advocate placing a requirement the vendor warrant noninterference 
and RF immunity in the purchase contract.  What laws can't do, money can.

Cortland Richmond
KA5S

-
--

Re: [PSES] [RFI] Part 15 isn't enough..

[Cortland Richmond]

On 9/30/2016 12:04 PM, Ken Javor wrote:

Was the original post that started this long thread saying that Part 15
wasn't enough, we also needed immunity requirements, or as I understood it, 
that Part 15 limits weren't low enough?


The latter, sort of,  but I added immunity (15.17) as a warranty item 
I'd like to see.


Here's the original:

Hey Gang,
I know we have all discussed "part 15 isn't enough", particularly when we
have talked about things like Solar systems

I was wondering - What if you were to say
"System shall be compliant with MIL-STD-461F,
 parts CE106,
 CS103,104,105,114,115,116
RE 102
and
RS 103, 105"

Think that should cover it?  Gives them an objective system of numbers to
work with

73 de KG2V
Charlie




Cortland
KA5S

-

This message is from the IEEE Product Safety Engineering Society emc-pstc discussion 
list. To post a message to the list, send your e-mail to 

All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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Mike Cantwell 

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

Re: [PSES] [RFI] Part 15 isn't enough..

[Ken Wyatt]

I agree with Ghery that interference complaints from typical PC/ITE systems 
have dropped, but they’ve been getting numerous complaints lately, related to 
interference from lighting and in particular, out of compliance switching power 
supplies from offshore.

See: 
http://www.interferencetechnology.com/fcc-wants-help-understanding-spectral-noise-floor/
 
<http://www.interferencetechnology.com/fcc-wants-help-understanding-spectral-noise-floor/>

The overall noise floor below 200 MHz has increased to the point where the FCC 
is asking industry (and individuals) for historical noise floor data to assist 
with their analysis of the situation.

Cheers, Ken

___

I'm here to help you succeed! Feel free to call or email with any questions 
related to EMC or EMI troubleshooting - at no obligation. I'm always happy to 
help!

Kenneth Wyatt
Wyatt Technical Services LLC
56 Aspen Dr.
Woodland Park, CO 80863

Phone: (719) 310-5418

Email Me! <mailto:k...@emc-seminars.com> | Web Site 
<http://www.emc-seminars.com/> | Blog <http://design-4-emc.com/>
The EMC Blog (EDN) <http://www.edn.com/blog/The-EMC-Blog>
Subscribe to Newsletter <http://www.emc-seminars.com/Newsletter/Newsletter.html>
Connect with me on LinkedIn <http://www.linkedin.com/in/kennethwyatt>
> On Sep 30, 2016, at 9:26 AM, Ghery S. Pettit <n6...@comcast.net> wrote:
> 
> The FCC also is taking the route mandated by their charter - protect the 
> radio users from interference.  Part 15 apparently does that adequately as 
> interference complaints to the FCC have dropped to the noise level.  Not so 
> before Part 15, Subpart J was published in the late 1970s.  Part 15 is doing 
> its job.  Immunity testing isn't a "protection of the spectrum" issue.  
> Besides, with the legal climate in the US, if the FCC mandated a certain 
> level of immunity and someone was injured because that level wasn't high 
> enough (allegedly or in actuality) the FCC would be sued.  Might not be 
> successfully, but it is something to be avoided.  Keep in mind that the 
> commissioners are political appointees.  Their job is to do their job while 
> not making the President look bad.  Getting hauled into court doesn't do that 
> so well.  Just another viewpoint...
> 
> Ghery S. Pettit
> 
> -Original Message-
> From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
> Sent: Friday, September 30, 2016 8:00 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> Cortland 
> 
> Sound like Congress being "ruled" by "big" and/or "small business" interests 
> to make the FCC take the path of least resistance - I would have thought that 
> their approach might have been deemed as being not in the general public 
> interest, but I can now see where you are coming from on the warrantee front.
> 
> OTOH, from what I think you wrote earlier, some States would not permit that 
> warrantee approach - sounds like more "vested interests" coming into play 
> there.
> 
> Looks like rather a no-win situation on immunity improvements for products 
> for the general public in the foreseeable future - unless, possibly, one or 
> more important States were persuaded to pass appropriate legislation on the 
> basis of the dangers from not doing so, as has been the cases related to 
> environmental protection and energy conservation (and so on) that have 
> affected the design and sale of electronic equipment 
> 
> Oh well, maybe someday EMC issues really will begin to "bite" a lot more 
> people across the country and something will, most belatedly, be done at the 
> Federal level.
> 
> John E Allen
> W. London, UK
> 
> -Original Message-
> From: Cortland Richmond [mailto:k...@earthlink.net]
> Sent: 30 September 2016 14:58
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> On 9/30/2016 8:59 AM, Dieter Paasche wrote:
>> The operator of a radio frequency device shall be required to cease 
>> operating the device *upon notification by a Commission
>> representative* that the device is causing harmful interference.
> [emphasis added]
> 
> The FCC has been reluctant to make that notification even after numerous 
> complaints, as being too zealous in enforcing the Rules has historically 
> resulted in Congress reducing the funds available to do so. You know the 
> saying 'Was nicht ausdrücklich erlaubt ist, ist verboten'; we have gone quite 
> the opposite way to "Alles was nicht erlaubt ist, ist pflichtig" 
> –  at least when there is profit to be had.
> 
> This is why I advocate placing a requirement the vendor warrant 
> noninterference and RF immunity in the purchase co

Re: [PSES] [RFI] Part 15 isn't enough..

[Ken Javor]

Was the original post that started this long thread saying that Part 15
wasn't enough, we also needed immunity requirements, or as I understood it,
that Part 15 limits weren't low enough?

Ken Javor
Phone: (256) 650-5261


> From: Joe Randolph <j...@randolph-telecom.com>
> Reply-To: Joe Randolph <j...@randolph-telecom.com>
> Date: Fri, 30 Sep 2016 11:43:55 -0400
> To: <EMC-PSTC@LISTSERV.IEEE.ORG>
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> There are other countries not mentioned that have immunity requirements, at
> least for the telecom product that I work with.
> 
> Mexico and Brazil immediately come to mind because their immunity requirements
> are in some cases more stringent than the EU requirements.
> 
> I believe there are others that do not immediately come to mind because they
> have harmonized their requirements with the EU and it's basically no
> additional work if the product already meets the EU requirements.
> 
> 
> Joe Randolph
> Telecom Design Consultant
> Randolph Telecom, Inc.
> 781-721-2848 (USA)
> j...@randolph-telecom.com
> http://www.randolph-telecom.com
> 
> -Original Message-
> From: ce-test, qualified testing bv - Gert Gremmen
> [mailto:g.grem...@cetest.nl]
> Sent: Friday, September 30, 2016 3:38 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> Hi  Ghery,
> 
> You need to get your numbers right Those tree entities outnumber your
> "real world" by 7.
> Economically by a factor 2...
>  
> 
> 
> Regards,
> 
> Ing. Gert Gremmen
> Approvals manager
> --
> --
> 
> 
> + ce marking of electrical/electronic equipment Independent Consultancy
> + Services Compliance Testing and Design for CE marking
>  according to EC-directives:
> - Electro Magnetic Compatibility 2004/108/EC
> - Electrical Safety 2006/95/EC
> - Medical Devices 93/42/EC
> - Radio & Telecommunication Terminal Equipment 99/5/EC
> + Improvement of Product Quality and Reliability testing Education
> 
> Web:www.cetest.nl (English)
> Phone :  +31 10 415 24 26
> ---
> This e-mail and any attachments thereto may contain information that is
> confidential and/or protected by intellectual property rights and are intended
> for the sole use of the recipient(s) named above.
> Any use of the information contained herein (including, but not limited to,
> total or partial reproduction, communication or distribution in any form) by
> persons other than the designated
> recipient(s) is prohibited. If you have received this e-mail in error, please
> notify the sender either by telephone or by e-mail and delete the material
> from any computer.
> Thank you for your co-operation.
> 
> From: Ghery S. Pettit [mailto:n6...@comcast.net]
> Sent: Friday 30 September 2016 00:20
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> Immunity testing is required in the EU, South Korea and China.  Nowhere else
> in the world is it required for commercial products.  I’d say that the US is
> in the “real world”.
> 
> Ghery S. Pettit
> 
> From: Ken Javor [mailto:ken.ja...@emccompliance.com]
> Sent: Thursday, September 29, 2016 3:01 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> Without getting into the specifics of this particular argument, the idea that
> the “rest of the world” has dome something doesn’t necessarily imply that
> North America is “behind.”  In the same sense that if a train has derailed and
> the locomotive is headed over a cliff, we don’t say the caboose is behind and
> needs to catch up.
> 
> Ken Javor
> Phone: (256) 650-5261
> 
> From: john Allen <john_e_al...@blueyonder.co.uk>
> Reply-To: john Allen <john_e_al...@blueyonder.co.uk>
> Date: Thu, 29 Sep 2016 22:44:48 +0100
> To: <EMC-PSTC@LISTSERV.IEEE.ORG>
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> Dennis
>  
> I really  do wonder what World you live in – but then, TBH, based on your
> previous comments of a similar nature, I did not expect anything else!
>  
> OK, Government “interference” is unwelcome in many cases but Brian O’Connell’s
> post is a  poignant “real world”  comment on what suppliers are facing, and
> what the Government should face up to and address – for the greater good of
> everyone in YOUR country.
>  
> Without getting trying to “personal”,  “get real”! - a lot of the rest of the
> “real world” has alrea

Re: [PSES] [RFI] Part 15 isn't enough..

[Ken Javor]

The intent of the quoted statute is simply to protect licensed users of the
spectrum from unlicensed unintentional ³poachers.²  The licensed user paid
for their use of the spectrum, and any unlicensed ³poacher² must cease and
desist his use when it interferes with the operation of a licensed user.

It also says that one unlicensed user has no protection from another
unlicensed user, and certainly not from a licensed user.

Basically just laying out a ³pecking order² in terms of rights to use the
spectrum.

Nothing here about immunity at all.

Ken Javor
Phone: (256) 650-5261



From: "Paasche, Dieter" <dieter.paas...@christiedigital.com>
Reply-To: "Paasche, Dieter" <dieter.paas...@christiedigital.com>
Date: Fri, 30 Sep 2016 12:59:04 +
To: <EMC-PSTC@LISTSERV.IEEE.ORG>
Conversation: [PSES] [RFI] Part 15 isn't enough..
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I believe that changing part 15 will be very difficult since it
is a legal  (political) document and would need congress approval for
changes. Different that than in the EU where you have directives and
harmonized standards somehow separately.
 
Also the US is part of international committees and heavily participates on
emissions and immunity standards. However implementation and enforcing is
always difficult.
 
And finally, isn¹t FCC indirectly stating that immunity has to be met as
well?  FCC Part 15.5 (b)
§15.5   General conditions of operation.
(a) Persons operating intentional or unintentional radiators shall not be
deemed to have any vested or recognizable right to continued use of any
given frequency by virtue of prior registration or certification of
equipment, or, for power line carrier systems, on the basis of prior
notification of use pursuant to §90.35(g) of this chapter.
(b) Operation of an intentional, unintentional, or incidental radiator is
subject to the conditions that no harmful interference is caused and that
interference must be accepted that may be caused by the operation of an
authorized radio station, by another intentional or unintentional radiator,
by industrial, scientific and medical (ISM) equipment, or by an incidental
radiator.
(c) The operator of a radio frequency device shall be required to cease
operating the device upon notification by a Commission representative that
the device is causing harmful interference. Operation shall not resume until
the condition causing the harmful interference has been corrected.
(d) Intentional radiators that produce Class B emissions (damped wave) are
prohibited.
 

Sincerely, 
 
Dieter Paasche
 

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
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-


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

All emc-pstc postings are archived and searchable on the web at:
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-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
<emc-p...@ieee.org>

All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communitie

Re: [PSES] [RFI] Part 15 isn't enough..

[Joe Randolph]

There are other countries not mentioned that have immunity requirements, at 
least for the telecom product that I work with.  

Mexico and Brazil immediately come to mind because their immunity requirements 
are in some cases more stringent than the EU requirements. 

I believe there are others that do not immediately come to mind because they 
have harmonized their requirements with the EU and it's basically no additional 
work if the product already meets the EU requirements.


Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848 (USA)
j...@randolph-telecom.com
http://www.randolph-telecom.com

-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] 
Sent: Friday, September 30, 2016 3:38 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Hi  Ghery,

You need to get your numbers right Those tree entities outnumber your "real 
world" by 7.
Economically by a factor 2...
 


Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing Education

Web:www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information that is 
confidential and/or protected by intellectual property rights and are intended 
for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not limited to, 
total or partial reproduction, communication or distribution in any form) by 
persons other than the designated
recipient(s) is prohibited. If you have received this e-mail in error, please 
notify the sender either by telephone or by e-mail and delete the material from 
any computer. 
Thank you for your co-operation.

From: Ghery S. Pettit [mailto:n6...@comcast.net]
Sent: Friday 30 September 2016 00:20
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Immunity testing is required in the EU, South Korea and China.  Nowhere else in 
the world is it required for commercial products.  I’d say that the US is in 
the “real world”.

Ghery S. Pettit

From: Ken Javor [mailto:ken.ja...@emccompliance.com]
Sent: Thursday, September 29, 2016 3:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Without getting into the specifics of this particular argument, the idea that 
the “rest of the world” has dome something doesn’t necessarily imply that North 
America is “behind.”  In the same sense that if a train has derailed and the 
locomotive is headed over a cliff, we don’t say the caboose is behind and needs 
to catch up.

Ken Javor
Phone: (256) 650-5261

From: john Allen <john_e_al...@blueyonder.co.uk>
Reply-To: john Allen <john_e_al...@blueyonder.co.uk>
Date: Thu, 29 Sep 2016 22:44:48 +0100
To: <EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dennis
 
I really  do wonder what World you live in – but then, TBH, based on your 
previous comments of a similar nature, I did not expect anything else!
 
OK, Government “interference” is unwelcome in many cases but Brian O’Connell’s 
post is a  poignant “real world”  comment on what suppliers are facing, and 
what the Government should face up to and address – for the greater good of 
everyone in YOUR country.
 
Without getting trying to “personal”,  “get real”! - a lot of the rest of the 
“real world” has already adopted appropriate requirements to try to prevent 
undue interference problems and so N. America is behind on this issue.
 
John E Allen.
W. London, UK
 

From: dward [mailto:dw...@pctestlab.com]
Sent: 29 September 2016 22:28
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

The federal government already interferes with US citizens far too much as it 
is – we do not need, nor do most of us want more federal intrusion.  The feds 
are there to keep the wolves at bay and keep out of our lives.  Besides, the 
open market in the US seems to take care of itself in the interference area.  
Does not take long for the consumer to know what is trash and what works.
The only regulations dealing with the spectrum that is needed is the regulation 
to help stop interference to licensed services. That was the intent of the FCC 
to start and there is no reason to change it.
 
 

​
Dennis Ward
This communication and its attachements contain info

Re: [PSES] [RFI] Part 15 isn't enough..

[Ghery S. Pettit]

The FCC also is taking the route mandated by their charter - protect the radio 
users from interference.  Part 15 apparently does that adequately as 
interference complaints to the FCC have dropped to the noise level.  Not so 
before Part 15, Subpart J was published in the late 1970s.  Part 15 is doing 
its job.  Immunity testing isn't a "protection of the spectrum" issue.  
Besides, with the legal climate in the US, if the FCC mandated a certain level 
of immunity and someone was injured because that level wasn't high enough 
(allegedly or in actuality) the FCC would be sued.  Might not be successfully, 
but it is something to be avoided.  Keep in mind that the commissioners are 
political appointees.  Their job is to do their job while not making the 
President look bad.  Getting hauled into court doesn't do that so well.  Just 
another viewpoint...

Ghery S. Pettit

-Original Message-
From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Friday, September 30, 2016 8:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Cortland 

Sound like Congress being "ruled" by "big" and/or "small business" interests to 
make the FCC take the path of least resistance - I would have thought that 
their approach might have been deemed as being not in the general public 
interest, but I can now see where you are coming from on the warrantee front.

OTOH, from what I think you wrote earlier, some States would not permit that 
warrantee approach - sounds like more "vested interests" coming into play there.

Looks like rather a no-win situation on immunity improvements for products for 
the general public in the foreseeable future - unless, possibly, one or more 
important States were persuaded to pass appropriate legislation on the basis of 
the dangers from not doing so, as has been the cases related to environmental 
protection and energy conservation (and so on) that have affected the design 
and sale of electronic equipment 

Oh well, maybe someday EMC issues really will begin to "bite" a lot more people 
across the country and something will, most belatedly, be done at the Federal 
level.

John E Allen
W. London, UK

-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net]
Sent: 30 September 2016 14:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 8:59 AM, Dieter Paasche wrote:
> The operator of a radio frequency device shall be required to cease 
> operating the device *upon notification by a Commission
> representative* that the device is causing harmful interference.
[emphasis added]

The FCC has been reluctant to make that notification even after numerous 
complaints, as being too zealous in enforcing the Rules has historically 
resulted in Congress reducing the funds available to do so. You know the saying 
'Was nicht ausdrücklich erlaubt ist, ist verboten'; we have gone quite the 
opposite way to "Alles was nicht erlaubt ist, ist pflichtig" 
–  at least when there is profit to be had.

This is why I advocate placing a requirement the vendor warrant noninterference 
and RF immunity in the purchase contract.  What laws can't do, money can.

Cortland Richmond
KA5S

-

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Re: [PSES] [RFI] Part 15 isn't enough..

[John Allen]

Cortland 

Sound like Congress being "ruled" by "big" and/or "small business" interests to 
make the FCC take the path of least resistance - I would have thought that 
their approach might have been deemed as being not in the general public 
interest, but I can now see where you are coming from on the warrantee front.

OTOH, from what I think you wrote earlier, some States would not permit that 
warrantee approach - sounds like more "vested interests" coming into play there.

Looks like rather a no-win situation on immunity improvements for products for 
the general public in the foreseeable future - unless, possibly, one or more 
important States were persuaded to pass appropriate legislation on the basis of 
the dangers from not doing so, as has been the cases related to environmental 
protection and energy conservation (and so on) that have affected the design 
and sale of electronic equipment 

Oh well, maybe someday EMC issues really will begin to "bite" a lot more people 
across the country and something will, most belatedly, be done at the Federal 
level.

John E Allen
W. London, UK

-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: 30 September 2016 14:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 8:59 AM, Dieter Paasche wrote:
> The operator of a radio frequency device shall be required to cease 
> operating the device *upon notification by a Commission
> representative* that the device is causing harmful interference.
[emphasis added]

The FCC has been reluctant to make that notification even after numerous 
complaints, as being too zealous in enforcing the Rules has historically 
resulted in Congress reducing the funds available to do so. You know the 
saying 'Was nicht ausdrücklich erlaubt ist, ist verboten'; we have gone 
quite the opposite way to "Alles was nicht erlaubt ist, ist pflichtig" 
–  at least when there is profit to be had.

This is why I advocate placing a requirement the vendor warrant 
noninterference and RF immunity in the purchase contract.  What laws 
can't do, money can.

Cortland Richmond
KA5S

-

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Re: [PSES] [RFI] Part 15 isn't enough..

[Cortland Richmond]

On 9/30/2016 8:59 AM, Dieter Paasche wrote:
The operator of a radio frequency device shall be required to cease 
operating the device *upon notification by a Commission 
representative* that the device is causing harmful interference.

[emphasis added]

The FCC has been reluctant to make that notification even after numerous 
complaints, as being too zealous in enforcing the Rules has historically 
resulted in Congress reducing the funds available to do so. You know the 
saying 'Was nicht ausdrücklich erlaubt ist, ist verboten'; we have gone 
quite the opposite way to "Alles was nicht erlaubt ist, ist pflichtig" 
–  at least when there is profit to be had.


This is why I advocate placing a requirement the vendor warrant 
noninterference and RF immunity in the purchase contract.  What laws 
can't do, money can.


Cortland Richmond
KA5S

-

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 

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Re: [PSES] [RFI] Part 15 isn't enough..

[John Allen]

Dieter

 

Yes, that’s what the words state, and have done for years – but, with no
clear requirements or guidelines as to the technical requirements (tests,
limits, pass/fail conditions etc.) or the actual need to do verification,
then many/most suppliers appear to me to ignore those words! I think the
same was true in Europe during the period after the original EMC Directive
(76/889/EEC) was published but before the CE marking requirement version
(89/336/EC) came out and required “proof” of compliance in the form of test
reports, tech files and the CE marking – after that, things gradually began
to change! 

 

The big problem in 1989, and for some years after, was the almost total lack
of standards against which to do the tests and assessments on non-military
products. However, some 25+ years later, the same cannot be said as there
are many international, and even US trade-body, standards which could almost
immediately be used as the basis for realistic sets of requirements to be
formulated.

 

Many multi-national and US companies already do that as normal development
practice, but in the current US legislative environment they can then “cost
cut” for the US market by either not doing that testing on US-market
specific products, or “cost reducing” their internationally-sold products
for sale in that market. That’s probably why the products from some major
multinationals (as mentioned in the previously linked website) could not be
sold elsewhere in the major World markets without suitable compliance and
verification, and yet can be sold in the US. 

 

John E Allen

W. London, UK

 

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com] 
Sent: 30 September 2016 13:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

In general I believe that changing part 15 will be very difficult since it
is a legal  (political) document and would need congress approval for
changes. Different that than in the EU where you have directives and
harmonized standards somehow separately. 

 

Also the US is part of international committees and heavily participates on
emissions and immunity standards. However implementation and enforcing is
always difficult.

 

And finally, isn’t FCC indirectly stating that immunity has to be met as
well?  FCC Part 15.5 (b)

§15.5   General conditions of operation.

(a) Persons operating intentional or unintentional radiators shall not be
deemed to have any vested or recognizable right to continued use of any
given frequency by virtue of prior registration or certification of
equipment, or, for power line carrier systems, on the basis of prior
notification of use pursuant to §90.35(g) of this chapter.

(b) Operation of an intentional, unintentional, or incidental radiator is
subject to the conditions that no harmful interference is caused and that
interference must be accepted that may be caused by the operation of an
authorized radio station, by another intentional or unintentional radiator,
by industrial, scientific and medical (ISM) equipment, or by an incidental
radiator.

(c) The operator of a radio frequency device shall be required to cease
operating the device upon notification by a Commission representative that
the device is causing harmful interference. Operation shall not resume until
the condition causing the harmful interference has been corrected.

(d) Intentional radiators that produce Class B emissions (damped wave) are
prohibited.

 

Sincerely, 

 

Dieter Paasche

 



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-


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

All emc-pstc postings are archived and searchable on the web at:
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http://product-compliance.oc.ieee.org/ can be used for graphics (in
well-used formats), l

Re: [PSES] [RFI] Part 15 isn't enough..

[Paasche, Dieter]

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately.

Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.

And finally, isn't FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)
§15.5   General conditions of operation.
(a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of any given 
frequency by virtue of prior registration or certification of equipment, or, 
for power line carrier systems, on the basis of prior notification of use 
pursuant to §90.35(g) of this chapter.
(b) Operation of an intentional, unintentional, or incidental radiator is 
subject to the conditions that no harmful interference is caused and that 
interference must be accepted that may be caused by the operation of an 
authorized radio station, by another intentional or unintentional radiator, by 
industrial, scientific and medical (ISM) equipment, or by an incidental 
radiator.
(c) The operator of a radio frequency device shall be required to cease 
operating the device upon notification by a Commission representative that the 
device is causing harmful interference. Operation shall not resume until the 
condition causing the harmful interference has been corrected.
(d) Intentional radiators that produce Class B emissions (damped wave) are 
prohibited.

Sincerely,

Dieter Paasche



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 
>

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-

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All emc-pstc postings are archived and searchable on the web at:
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Re: [PSES] [RFI] Part 15 isn't enough..

[john Allen]

Gert

I have to agree with you on both points ...

And, as more of a "consumer" nowadays (and knowing how much immunity testing 
costs for a single item of equipment!),  I know where I would stand if I lived 
in the US and my recently purchased and expensive equipment displayed the sort 
of behavior outlined on the apartmenttherapy website !

John E Allen
W. London, UK

-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] 
Sent: 30 September 2016 09:40
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Well  John,

The problem is not that immunity regulations are not reasonable (in the US), 
its mere the simple fact that they are regulations that  creates such a heavy 
opposition.
Even under EMC colleagues / members on this list. 

The opinion in the US is that bad products will weed themselves out by 
competition, and that  in the end only immune ovens survive. And everybody is 
happy, without regulations !

But for those early buyers of an oven, of course that actually do some  kind of 
immunity testing for the ovens manufacturer on their own cost.




Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing Education

Web:www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information that is 
confidential and/or protected by intellectual property rights and are intended 
for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not limited to, 
total or partial reproduction, communication or distribution in any form) by 
persons other than the designated
recipient(s) is prohibited. If you have received this e-mail in error, please 
notify the sender either by telephone or by e-mail and delete the material from 
any computer. 
Thank you for your co-operation.


-Original Message-
From: john Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Friday 30 September 2016 10:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Cortland

Morning

I have just read some of stories on the apartmenttherapy website you gave the 
link to - and the poor customers who had EMI-related problems have my sincere 
sympathy.

What seems clear to me (and presumably to most people viewing the current 
thread here!) is that relatively simple immunity fixes in the design and 
manufacture  of the products would have prevented most of these problems ever 
occurring - but that even some the most "reputable" manufacturers were cost 
cutting to the bone to avoid doing that for the US market.

However, where I disagree that about the warranty route being the one to go for 
because it put the onus of proof heavily on the poor customers, who will 
generally have no idea whatsoever what the problems with the products are. Most 
of us have had our own problems with products "under warranty" where it has 
been difficult or impossible to get the supplier to acknowledge that the 
product is at fault in some way when we know that it definitely is - and so why 
rely on a type of measure that often does not work and/or is easily deflected 
by the supplier (and especially by the local distributors and sales outlets, 
who generally know even less than the manufacturers about the EMC performance 
of the products that they sell!).

And, as one story clearly showed, manufacturers can and will deny  
responsibility when the warranty runs out - and if the source of a problem 
takes a lot of time to track down and the warranty has then expired, then the 
customer may well have no recourse other than to buy some sort of replacement, 
often at considerable cost.

These types of EMI problems can only get worse as more and more electronic 
devices are introduced and thus more EMI pollution occurs - and the ONLY people 
who can fix it are the manufacturers, not the poor and generally clueless 
customers, and so they should be made to do that before more, and potentially 
disasterous and life-threatening, incidents occur. 

Who can do that in the US: either the Federal Government or, in the current 
situation it appears, the individual States, and you might say that the problem 
is thus insoluable because of "differences" of opinion/attitude between the 
Federal and State bodies? 

However people in the US seem to forget that tha

Re: [PSES] [RFI] Part 15 isn't enough..

[ce-test, qualified testing bv - Gert Gremmen]

Well  John,

The problem is not that immunity regulations are not reasonable (in the US),
its mere the simple fact that they are regulations that  creates such a heavy 
opposition.
Even under EMC colleagues / members on this list. 

The opinion in the US is that bad products will weed themselves out by 
competition, and that
 in the end only immune ovens survive. And everybody is happy, without 
regulations !

But for those early buyers of an oven, of course that actually do some  kind of 
immunity testing
for the ovens manufacturer on their own cost.




Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
    - Electro Magnetic Compatibility 2004/108/EC
    - Electrical Safety 2006/95/EC
    - Medical Devices 93/42/EC
    - Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:    www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
and are intended for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not 
limited to, total or partial reproduction, communication or 
distribution in any form) by persons other than the designated 
recipient(s) is prohibited. If you have received this e-mail in error, 
please notify the sender either by telephone or by e-mail and 
delete the material from any computer. 
Thank you for your co-operation.


-Original Message-
From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Friday 30 September 2016 10:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Cortland

Morning

I have just read some of stories on the apartmenttherapy website you gave the 
link to - and the poor customers who had EMI-related problems have my sincere 
sympathy.

What seems clear to me (and presumably to most people viewing the current 
thread here!) is that relatively simple immunity fixes in the design and 
manufacture  of the products would have prevented most of these problems ever 
occurring - but that even some the most "reputable" manufacturers were cost 
cutting to the bone to avoid doing that for the US market.

However, where I disagree that about the warranty route being the one to go for 
because it put the onus of proof heavily on the poor customers, who will 
generally have no idea whatsoever what the problems with the products are. Most 
of us have had our own problems with products "under warranty" where it has 
been difficult or impossible to get the supplier to acknowledge that the 
product is at fault in some way when we know that it definitely is - and so why 
rely on a type of measure that often does not work and/or is easily deflected 
by the supplier (and especially by the local distributors and sales outlets, 
who generally know even less than the manufacturers about the EMC performance 
of the products that they sell!).

And, as one story clearly showed, manufacturers can and will deny  
responsibility when the warranty runs out - and if the source of a problem 
takes a lot of time to track down and the warranty has then expired, then the 
customer may well have no recourse other than to buy some sort of replacement, 
often at considerable cost.

These types of EMI problems can only get worse as more and more electronic 
devices are introduced and thus more EMI pollution occurs - and the ONLY people 
who can fix it are the manufacturers, not the poor and generally clueless 
customers, and so they should be made to do that before more, and potentially 
disasterous and life-threatening, incidents occur. 

Who can do that in the US: either the Federal Government or, in the current 
situation it appears, the individual States, and you might say that the problem 
is thus insoluable because of "differences" of opinion/attitude between the 
Federal and State bodies? 

However people in the US seem to forget that that is EXACTLY the situation we 
had in Europe in the late-middle of the 20th Century - every country had its 
own EMC legislation and that varied from very strictly enforced in Germany to 
quite lax, or at least "light-touch", as we had (and still do have!) in the UK 
and elsewhere. Nevertheless the emerging EMC problem was recognized by the 
national legislatures by the late 70's/early 80's and the EMC Directive (and 
later the R & RED) was born, and that is why we now have a reasonably 
effective and consistent legal and technical framework for EMC - both emissions 
AND im

Re: [PSES] [RFI] Part 15 isn't enough..

[john Allen]

Cortland

Morning

I have just read some of stories on the apartmenttherapy website you gave the 
link to - and the poor customers who had EMI-related problems have my sincere 
sympathy.

What seems clear to me (and presumably to most people viewing the current 
thread here!) is that relatively simple immunity fixes in the design and 
manufacture  of the products would have prevented most of these problems ever 
occurring - but that even some the most "reputable" manufacturers were cost 
cutting to the bone to avoid doing that for the US market.

However, where I disagree that about the warranty route being the one to go for 
because it put the onus of proof heavily on the poor customers, who will 
generally have no idea whatsoever what the problems with the products are. Most 
of us have had our own problems with products "under warranty" where it has 
been difficult or impossible to get the supplier to acknowledge that the 
product is at fault in some way when we know that it definitely is - and so why 
rely on a type of measure that often does not work and/or is easily deflected 
by the supplier (and especially by the local distributors and sales outlets, 
who generally know even less than the manufacturers about the EMC performance 
of the products that they sell!).

And, as one story clearly showed, manufacturers can and will deny  
responsibility when the warranty runs out - and if the source of a problem 
takes a lot of time to track down and the warranty has then expired, then the 
customer may well have no recourse other than to buy some sort of replacement, 
often at considerable cost.

These types of EMI problems can only get worse as more and more electronic 
devices are introduced and thus more EMI pollution occurs - and the ONLY people 
who can fix it are the manufacturers, not the poor and generally clueless 
customers, and so they should be made to do that before more, and potentially 
disasterous and life-threatening, incidents occur. 

Who can do that in the US: either the Federal Government or, in the current 
situation it appears, the individual States, and you might say that the problem 
is thus insoluable because of "differences" of opinion/attitude between the 
Federal and State bodies? 

However people in the US seem to forget that that is EXACTLY the situation we 
had in Europe in the late-middle of the 20th Century - every country had its 
own EMC legislation and that varied from very strictly enforced in Germany to 
quite lax, or at least "light-touch", as we had (and still do have!) in the UK 
and elsewhere. Nevertheless the emerging EMC problem was recognized by the 
national legislatures by the late 70's/early 80's and the EMC Directive (and 
later the R & RED) was born, and that is why we now have a reasonably 
effective and consistent legal and technical framework for EMC - both emissions 
AND immunity/susceptibility - control across the whole of the Continent, which 
is a marketplace of roughly the same size as the US! 

Therefore this sort of issue can "sorted" in the US when the relevant 
authorities at both Federal and State level are finally made to understand the 
size of the problem and that it can only get worse unless collective action is 
taken to address it.

John E Allen
W. London, UK



-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: 30 September 2016 04:56
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/29/2016 4:14 PM, Ghery S. Pettit wrote:
> Preventing harmful interference in all cases is a mighty tough call.  How low 
> do you need to limit emissions?  How high a signal must the product be immune 
> to?  The limits in Part 15 provide a reasonable level of protection, assuming 
> the potential victim is far enough away.  Co-located devices may need more 
> suppression.

That's why I think putting it in the form of a warranty is the best way to get 
manufacturers to pay attention to it.  They know if they do pay attention to 
suppressing interference, the warranty will very rarely be used. Another way is 
an implied warranty of fitness; I understand the UK and Europe enforce implied 
warranties of serviceability, which US merchants often refuse to recognize, but 
twelve states (and the District of Columbia) don't allow them to. See 
http://consumer.findlaw.com/consumer-transactions/what-is-an-implied-warranty-.html


Of course, this isn't legal advice, and I'm neither an attorney nor authorized 
to give legal advice.

I do suspect some manufacturers would refuse to submit bids if a customer firm 
tried to make them eat the cost of noncompliance, not with the limits, but by 
causing harmful interference, forbidden even if the victim is right next to the 
product.

Remember the gas oven that got turned on by a cell phone? Here's another one 
that took *months* to pin down – and had a simple fix th

Re: [PSES] [RFI] Part 15 isn't enough..

[ce-test, qualified testing bv - Gert Gremmen]

Hi  Ghery,

You need to get your numbers right Those tree entities outnumber your "real 
world" by 7.
Economically by a factor 2...
 


Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
    - Electro Magnetic Compatibility 2004/108/EC
    - Electrical Safety 2006/95/EC
    - Medical Devices 93/42/EC
    - Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:    www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
and are intended for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not 
limited to, total or partial reproduction, communication or 
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please notify the sender either by telephone or by e-mail and 
delete the material from any computer. 
Thank you for your co-operation.

From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: Friday 30 September 2016 00:20
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Immunity testing is required in the EU, South Korea and China.  Nowhere else in 
the world is it required for commercial products.  I’d say that the US is in 
the “real world”.

Ghery S. Pettit

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Thursday, September 29, 2016 3:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Without getting into the specifics of this particular argument, the idea that 
the “rest of the world” has dome something doesn’t necessarily imply that North 
America is “behind.”  In the same sense that if a train has derailed and the 
locomotive is headed over a cliff, we don’t say the caboose is behind and needs 
to catch up.

Ken Javor
Phone: (256) 650-5261

From: john Allen <john_e_al...@blueyonder.co.uk>
Reply-To: john Allen <john_e_al...@blueyonder.co.uk>
Date: Thu, 29 Sep 2016 22:44:48 +0100
To: <EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dennis
 
I really  do wonder what World you live in – but then, TBH, based on your 
previous comments of a similar nature, I did not expect anything else!
 
OK, Government “interference” is unwelcome in many cases but Brian O’Connell’s 
post is a  poignant “real world”  comment on what suppliers are facing, and 
what the Government should face up to and address – for the greater good of 
everyone in YOUR country.
 
Without getting trying to “personal”,  “get real”! - a lot of the rest of the 
“real world” has already adopted appropriate requirements to try to prevent 
undue interference problems and so N. America is behind on this issue.
 
John E Allen.
W. London, UK
 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 29 September 2016 22:28
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

The federal government already interferes with US citizens far too much as it 
is – we do not need, nor do most of us want more federal intrusion.  The feds 
are there to keep the wolves at bay and keep out of our lives.  Besides, the 
open market in the US seems to take care of itself in the interference area.  
Does not take long for the consumer to know what is trash and what works.
The only regulations dealing with the spectrum that is needed is the regulation 
to help stop interference to licensed services. That was the intent of the FCC 
to start and there is no reason to change it.
 
 

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.
 

From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 2:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Dennis
 
And why not

Re: [PSES] [RFI] Part 15 isn't enough..

[Ken Javor]

But this warranty business has nothing to do with Part 15!

Ken Javor
Phone: (256) 650-5261


> From: Cortland Richmond <k...@earthlink.net>
> Reply-To: <k...@earthlink.net>
> Date: Thu, 29 Sep 2016 23:55:52 -0400
> To: <EMC-PSTC@LISTSERV.IEEE.ORG>
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> On 9/29/2016 4:14 PM, Ghery S. Pettit wrote:
>> Preventing harmful interference in all cases is a mighty tough call.  How low
>> do you need to limit emissions?  How high a signal must the product be immune
>> to?  The limits in Part 15 provide a reasonable level of protection, assuming
>> the potential victim is far enough away.  Co-located devices may need more
>> suppression.
> 
> That's why I think putting it in the form of a warranty is the best way
> to get manufacturers to pay attention to it.  They know if they do pay
> attention to suppressing interference, the warranty will very rarely be
> used. Another way is an implied warranty of fitness; I understand the UK
> and Europe enforce implied warranties of serviceability, which US
> merchants often refuse to recognize, but twelve states (and the District
> of Columbia) don't allow them to. See
> http://consumer.findlaw.com/consumer-transactions/what-is-an-implied-warranty-
> .html
> 
> 
> Of course, this isn't legal advice, and I'm neither an attorney nor
> authorized to give legal advice.
> 
> I do suspect some manufacturers would refuse to submit bids if a
> customer firm tried to make them eat the cost of noncompliance, not with
> the limits, but by causing harmful interference, forbidden even if the
> victim is right next to the product.
> 
> Remember the gas oven that got turned on by a cell phone? Here's another
> one that took *months* to pin down ­ and had a simple fix the
> manufacturer might have applied for less than a dollar each:
> http://www.apartmenttherapy.com/help-my-kitchen-is-possessed-w-147015
> 
> 
> Cortland Richmond
> KA5S
> 
> -
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to
> <emc-p...@ieee.org>
> 
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
> 
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used
> formats), large files, etc.
> 
> Website:  http://www.ieee-pses.org/
> Instructions:  http://www.ieee-pses.org/list.html (including how to
> unsubscribe)
> List rules: http://www.ieee-pses.org/listrules.html
> 
> For help, send mail to the list administrators:
> Scott Douglas <sdoug...@ieee.org>
> Mike Cantwell <mcantw...@ieee.org>
> 
> For policy questions, send mail to:
> Jim Bacher:  <j.bac...@ieee.org>
> David Heald: <dhe...@gmail.com>

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
<emc-p...@ieee.org>

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

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

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

For help, send mail to the list administrators:
Scott Douglas <sdoug...@ieee.org>
Mike Cantwell <mcantw...@ieee.org>

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

Re: [PSES] [RFI] Part 15 isn't enough..

[Cortland Richmond]

On 9/29/2016 4:14 PM, Ghery S. Pettit wrote:

Preventing harmful interference in all cases is a mighty tough call.  How low 
do you need to limit emissions?  How high a signal must the product be immune 
to?  The limits in Part 15 provide a reasonable level of protection, assuming 
the potential victim is far enough away.  Co-located devices may need more 
suppression.


That's why I think putting it in the form of a warranty is the best way 
to get manufacturers to pay attention to it.  They know if they do pay 
attention to suppressing interference, the warranty will very rarely be 
used. Another way is an implied warranty of fitness; I understand the UK 
and Europe enforce implied warranties of serviceability, which US 
merchants often refuse to recognize, but twelve states (and the District 
of Columbia) don't allow them to. See

http://consumer.findlaw.com/consumer-transactions/what-is-an-implied-warranty-.html


Of course, this isn't legal advice, and I'm neither an attorney nor 
authorized to give legal advice.


I do suspect some manufacturers would refuse to submit bids if a 
customer firm tried to make them eat the cost of noncompliance, not with 
the limits, but by causing harmful interference, forbidden even if the 
victim is right next to the product.


Remember the gas oven that got turned on by a cell phone? Here's another 
one that took *months* to pin down – and had a simple fix the 
manufacturer might have applied for less than a dollar each:

http://www.apartmenttherapy.com/help-my-kitchen-is-possessed-w-147015


Cortland Richmond
KA5S

-

This message is from the IEEE Product Safety Engineering Society emc-pstc discussion 
list. To post a message to the list, send your e-mail to 

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

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

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

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

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

Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

The US government is not set up the way Europe or the EU is.  The feds only 
have say in things that are interstate or international.  The States hold all 
other legislative powers.  Thus each State deals with the safety of its 
citizens the way they see fit, not the way some group 2000 miles away in 
another State sees fit, nor how a group of politicians in DC see fit.  

 

California for example has some very strict safety laws, while other States 
have less strict safety laws.

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 2:45 PM
To: 'dward' <dw...@pctestlab.com>; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

 

Dennis

 

I really  do wonder what World you live in – but then, TBH, based on your 
previous comments of a similar nature, I did not expect anything else!

 

OK, Government “interference” is unwelcome in many cases but Brian O’Connell’s 
post is a  poignant “real world”  comment on what suppliers are facing, and 
what the Government should face up to and address – for the greater good of 
everyone in YOUR country.

 

Without getting trying to “personal”,  “get real”! - a lot of the rest of the 
“real world” has already adopted appropriate requirements to try to prevent 
undue interference problems and so N. America is behind on this issue.

 

John E Allen.

W. London, UK

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 29 September 2016 22:28
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG 
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

 

The federal government already interferes with US citizens far too much as it 
is – we do not need, nor do most of us want more federal intrusion.  The feds 
are there to keep the wolves at bay and keep out of our lives.  Besides, the 
open market in the US seems to take care of itself in the interference area.  
Does not take long for the consumer to know what is trash and what works.

The only regulations dealing with the spectrum that is needed is the regulation 
to help stop interference to licensed services. That was the intent of the FCC 
to start and there is no reason to change it.

 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 2:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Dennis

 

And why not – seriously?

 

As was said many years ago – and often repeated! - “what’s right for the goose 
is right for the gander”.

 

In this case (and many others) In simple terms, that means that implies that 
electronic devices need to be appropriately resilient to the generally 
“predictable” levels of external interference in the environments for which 
they are designed to operate – one of the basic essential requirements of the 
EMC Directive!

 

Otherwise you might need to specify that YOUR products need to have MIL-STD-461 
levels (highest!) of immunity to try to ensure they will work “anywhere” they 
are likely to be used!

 

John E Allen

W. London, UK

 

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 29 September 2016 21:53
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG 
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

 

Not a chance

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) name

Re: [PSES] [RFI] Part 15 isn't enough..

[Regan Arndt]

Check out this free download (google it): “Electronic Systems Failures & 
Anomalies Attributed to EMI” NASA Reference Publication 1374 issued in 1995.

You’d think we would have learned our lesson by now……

Regardless, it’s still all about the mighty dollar with no regard to human 
life. (unfortunately).

Check out section 2.3.3 – 6 deaths due to medical device EMI problems.



As for the New Jersey incident. It could have been prevented. It was just too 
costly…..until now.

http://www.cnn.com/2016/09/29/us/new-jersey-hoboken-train-safety/index.html



Regan Arndt

From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, September 29, 2016 4:15 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

As to John’s comment about the train wreck in the US, try looking at the so 
called safety record of train travel in the EU.  Wrecksin Spin killed 4 injured 
49, recent wrecks in Germany killed 30 injured many more.  Spain, France, UK, 
Germany, Italy, Netherlands on and on it goes.  So, John’s analogy of train 
wrecks and so called safety regulations simply does not hold water.


On Sep 29, 2016, at 3:19 PM, Ghery S. Pettit 
<n6...@comcast.net<mailto:n6...@comcast.net>> wrote:

Immunity testing is required in the EU, South Korea and China.  Nowhere else in 
the world is it required for commercial products.  I’d say that the US is in 
the “real world”.

Ghery S. Pettit

From: Ken Javor [mailto:ken.ja...@emccompliance.com]
Sent: Thursday, September 29, 2016 3:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@listserv.ieee.org>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Without getting into the specifics of this particular argument, the idea that 
the “rest of the world” has dome something doesn’t necessarily imply that North 
America is “behind.”  In the same sense that if a train has derailed and the 
locomotive is headed over a cliff, we don’t say the caboose is behind and needs 
to catch up.

Ken Javor
Phone: (256) 650-5261



From: john Allen 
<john_e_al...@blueyonder.co.uk<mailto:john_e_al...@blueyonder.co.uk>>
Reply-To: john Allen 
<john_e_al...@blueyonder.co.uk<mailto:john_e_al...@blueyonder.co.uk>>
Date: Thu, 29 Sep 2016 22:44:48 +0100
To: <EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dennis

I really  do wonder what World you live in – but then, TBH, based on your 
previous comments of a similar nature, I did not expect anything else!

OK, Government “interference” is unwelcome in many cases but Brian O’Connell’s 
post is a  poignant “real world”  comment on what suppliers are facing, and 
what the Government should face up to and address – for the greater good of 
everyone in YOUR country.

Without getting trying to “personal”,  “get real”! - a lot of the rest of the 
“real world” has already adopted appropriate requirements to try to prevent 
undue interference problems and so N. America is behind on this issue.

John E Allen.
W. London, UK


From: dward [mailto:dw...@pctestlab.com]
Sent: 29 September 2016 22:28
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

The federal government already interferes with US citizens far too much as it 
is – we do not need, nor do most of us want more federal intrusion.  The feds 
are there to keep the wolves at bay and keep out of our lives.  Besides, the 
open market in the US seems to take care of itself in the interference area.  
Does not take long for the consumer to know what is trash and what works.
The only regulations dealing with the spectrum that is needed is the regulation 
to help stop interference to licensed services. That was the intent of the FCC 
to start and there is no reason to change it.



​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.


From: john Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Thursday, September 29, 2016 2:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dennis

And why not – seriously?

As was said many years ago – and often repeated! - “what’s right for the goose 
is right for the gander”.

In this case (and 

Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

As to John’s comment about the train wreck in the US, try looking at the so 
called safety record of train travel in the EU.  Wrecksin Spin killed 4 injured 
49, recent wrecks in Germany killed 30 injured many more.  Spain, France, UK, 
Germany, Italy, Netherlands on and on it goes.  So, John’s analogy of train 
wrecks and so called safety regulations simply does not hold water.


> On Sep 29, 2016, at 3:19 PM, Ghery S. Pettit <n6...@comcast.net> wrote:
> 
> Immunity testing is required in the EU, South Korea and China.  Nowhere else 
> in the world is it required for commercial products.  I’d say that the US is 
> in the “real world”.
>  
> Ghery S. Pettit
>  
> From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
> Sent: Thursday, September 29, 2016 3:01 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
>  
> Without getting into the specifics of this particular argument, the idea that 
> the “rest of the world” has dome something doesn’t necessarily imply that 
> North America is “behind.”  In the same sense that if a train has derailed 
> and the locomotive is headed over a cliff, we don’t say the caboose is behind 
> and needs to catch up.
> 
> Ken Javor
> Phone: (256) 650-5261
> 
> 
> From: john Allen <john_e_al...@blueyonder.co.uk 
> <mailto:john_e_al...@blueyonder.co.uk>>
> Reply-To: john Allen <john_e_al...@blueyonder.co.uk 
> <mailto:john_e_al...@blueyonder.co.uk>>
> Date: Thu, 29 Sep 2016 22:44:48 +0100
> To: <EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> Dennis
>  
> I really  do wonder what World you live in – but then, TBH, based on your 
> previous comments of a similar nature, I did not expect anything else!
>  
> OK, Government “interference” is unwelcome in many cases but Brian 
> O’Connell’s post is a  poignant “real world”  comment on what suppliers are 
> facing, and what the Government should face up to and address – for the 
> greater good of everyone in YOUR country.
>  
> Without getting trying to “personal”,  “get real”! - a lot of the rest of the 
> “real world” has already adopted appropriate requirements to try to prevent 
> undue interference problems and so N. America is behind on this issue.
>  
> John E Allen.
> W. London, UK
>  
> 
> From: dward [mailto:dw...@pctestlab.com] <mailto:dw...@pctestlab.com]> 
> Sent: 29 September 2016 22:28
> To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG 
> <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
> Subject: RE: [PSES] [RFI] Part 15 isn't enough..
> 
> The federal government already interferes with US citizens far too much as it 
> is – we do not need, nor do most of us want more federal intrusion.  The feds 
> are there to keep the wolves at bay and keep out of our lives.  Besides, the 
> open market in the US seems to take care of itself in the interference area.  
> Does not take long for the consumer to know what is trash and what works.
> The only regulations dealing with the spectrum that is needed is the 
> regulation to help stop interference to licensed services. That was the 
> intent of the FCC to start and there is no reason to change it.
>  
>  
> 
> ​
> Dennis Ward
> This communication and its attachements contain information from PCTEST 
> Engineering Laboratory, Inc., and is intended for the exclusive use of the 
> recipient(s) named above.  It may contain information that is confidential 
> and/or legally privileged.  Any unauthorized use that may compromise that 
> confidentiality via distribution or disclosure is prohibited.  Please notify 
> the sender immediately if you receive this communication in error, and delete 
> it from your computer system.  Usage of PCTEST email addresses for 
> non-business related activities is strictly prohibited.  No warranty is made 
> that the e-mail or attachments(s) are free from computer virus or other 
> defect.  Thank you.
>  
> 
> From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
> <mailto:john_e_al...@blueyonder.co.uk]> 
> Sent: Thursday, September 29, 2016 2:11 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
>  
> Dennis
>  
> And why not – seriously?
>  
> As was said many years ago – and often repeated! - “what’s right for the 
> goose is right for the gander”.
>  
> In this case (and many others) In simple terms, that means that implies that 
> electronic devices need to be appropriately resilient to the generally 
> “predictable” levels of external interference in the environments for which 
> they are designed to operate – 

Re: [PSES] [RFI] Part 15 isn't enough..

[Ghery S. Pettit]

Immunity testing is required in the EU, South Korea and China.  Nowhere else in 
the world is it required for commercial products.  I’d say that the US is in 
the “real world”.

 

Ghery S. Pettit

 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Thursday, September 29, 2016 3:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Without getting into the specifics of this particular argument, the idea that 
the “rest of the world” has dome something doesn’t necessarily imply that North 
America is “behind.”  In the same sense that if a train has derailed and the 
locomotive is headed over a cliff, we don’t say the caboose is behind and needs 
to catch up.

Ken Javor
Phone: (256) 650-5261



  _  

From: john Allen <john_e_al...@blueyonder.co.uk>
Reply-To: john Allen <john_e_al...@blueyonder.co.uk>
Date: Thu, 29 Sep 2016 22:44:48 +0100
To: <EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dennis
 
I really  do wonder what World you live in – but then, TBH, based on your 
previous comments of a similar nature, I did not expect anything else!
 
OK, Government “interference” is unwelcome in many cases but Brian O’Connell’s 
post is a  poignant “real world”  comment on what suppliers are facing, and 
what the Government should face up to and address – for the greater good of 
everyone in YOUR country.
 
Without getting trying to “personal”,  “get real”! - a lot of the rest of the 
“real world” has already adopted appropriate requirements to try to prevent 
undue interference problems and so N. America is behind on this issue.
 
John E Allen.
W. London, UK
 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 29 September 2016 22:28
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

The federal government already interferes with US citizens far too much as it 
is – we do not need, nor do most of us want more federal intrusion.  The feds 
are there to keep the wolves at bay and keep out of our lives.  Besides, the 
open market in the US seems to take care of itself in the interference area.  
Does not take long for the consumer to know what is trash and what works.
The only regulations dealing with the spectrum that is needed is the regulation 
to help stop interference to licensed services. That was the intent of the FCC 
to start and there is no reason to change it.
 
 

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.
 

From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 2:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Dennis
 
And why not – seriously?
 
As was said many years ago – and often repeated! - “what’s right for the goose 
is right for the gander”.
 
In this case (and many others) In simple terms, that means that implies that 
electronic devices need to be appropriately resilient to the generally 
“predictable” levels of external interference in the environments for which 
they are designed to operate – one of the basic essential requirements of the 
EMC Directive!
 
Otherwise you might need to specify that YOUR products need to have MIL-STD-461 
levels (highest!) of immunity to try to ensure they will work “anywhere” they 
are likely to be used!
 
John E Allen
W. London, UK
 
 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 29 September 2016 21:53
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

Not a chance
 

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.
 

From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thur

Re: [PSES] [RFI] Part 15 isn't enough..

[john Allen]

Ken (and Dennis)

 

Well, apparently, the loco WAS behind the “caboose” (and everything else in the 
train) in the tragic  accident in NY today – don’t think that could happen in 
(most of) Europe today, and for very good safety reasons. A relevant, if very 
oblique, “lesson” on being “behind the curve”, maybe?

 

John E Allen

W. London, UK

 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: 29 September 2016 23:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Without getting into the specifics of this particular argument, the idea that 
the “rest of the world” has dome something doesn’t necessarily imply that North 
America is “behind.”  In the same sense that if a train has derailed and the 
locomotive is headed over a cliff, we don’t say the caboose is behind and needs 
to catch up.

Ken Javor
Phone: (256) 650-5261



  _  

From: john Allen <john_e_al...@blueyonder.co.uk>
Reply-To: john Allen <john_e_al...@blueyonder.co.uk>
Date: Thu, 29 Sep 2016 22:44:48 +0100
To: <EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dennis
 
I really  do wonder what World you live in – but then, TBH, based on your 
previous comments of a similar nature, I did not expect anything else!
 
OK, Government “interference” is unwelcome in many cases but Brian O’Connell’s 
post is a  poignant “real world”  comment on what suppliers are facing, and 
what the Government should face up to and address – for the greater good of 
everyone in YOUR country.
 
Without getting trying to “personal”,  “get real”! - a lot of the rest of the 
“real world” has already adopted appropriate requirements to try to prevent 
undue interference problems and so N. America is behind on this issue.
 
John E Allen.
W. London, UK
 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 29 September 2016 22:28
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

The federal government already interferes with US citizens far too much as it 
is – we do not need, nor do most of us want more federal intrusion.  The feds 
are there to keep the wolves at bay and keep out of our lives.  Besides, the 
open market in the US seems to take care of itself in the interference area.  
Does not take long for the consumer to know what is trash and what works.
The only regulations dealing with the spectrum that is needed is the regulation 
to help stop interference to licensed services. That was the intent of the FCC 
to start and there is no reason to change it.
 
 

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.
 

From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 2:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Dennis
 
And why not – seriously?
 
As was said many years ago – and often repeated! - “what’s right for the goose 
is right for the gander”.
 
In this case (and many others) In simple terms, that means that implies that 
electronic devices need to be appropriately resilient to the generally 
“predictable” levels of external interference in the environments for which 
they are designed to operate – one of the basic essential requirements of the 
EMC Directive!
 
Otherwise you might need to specify that YOUR products need to have MIL-STD-461 
levels (highest!) of immunity to try to ensure they will work “anywhere” they 
are likely to be used!
 
John E Allen
W. London, UK
 
 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 29 September 2016 21:53
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

Not a chance
 

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attac

Re: [PSES] [RFI] Part 15 isn't enough..

[john Allen]

Ken

 

Whilst I understand what you say, bear in mind that the majority of facility
owners (and ESPECIALLY consumers and most Small-to-Medium-Enterprises) have
no real (if ANY) understanding of any EMC “problems” with equipment which
they own -  let alone how to deal with them - and that costs them a lot of
hard cash in trying to find out what is happening and how to fix it (and IF
that is possible).

 

Far better to have basic legal emission AND immunity requirements  in-place
to at least reduce the likelihood of such situations occurring.

 

John E Allen

W. London, UK

 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: 29 September 2016 22:28
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Saying that Part 15 limits are not low enough has nothing to do with the
imposition of immunity requirements. Regardless of how high or low Part 15
limits might be, it has no impact on any suggested or imposed
susceptibility/immunity limits. Part 15 limits protect radio receivers, the
immunity requirements protect non-antenna connected equipment from
intentional transmissions (meaning 61000-4-3 and 61000–4-6, not the various
transient non-frequency domain requirements).

Ghery Pettit made the salient point: the Part 15 limits provide a degree of
protection such that if interference occurs, it is between two equipments
operated in the same area, under the same ownership, and therefore the
problem is controllable without causing problems between different entities,
one of which owns the culprit, and the other of which owns the victim. The
limits are not there to protect a culprit/victim pair jammed up
side-by-side. If that’s what you want, you are looking at MIL-STD-461, as
someone else pointed out. 

Ken Javor
Phone: (256) 650-5261



  _  

From: john Allen <john_e_al...@blueyonder.co.uk>
Reply-To: john Allen <john_e_al...@blueyonder.co.uk>
Date: Thu, 29 Sep 2016 21:27:14 +0100
To: <EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Almost sounds like a call for N. America to encompass our equivalent
immunity requirements  (often denigrated - even with Europe, but they
generally do seem to work!) J 
 
John E Allen
W. London, UK
 
-Original Message-
From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: 29 September 2016 21:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Preventing harmful interference in all cases is a mighty tough call.  How
low do you need to limit emissions?  How high a signal must the product be
immune to?  The limits in Part 15 provide a reasonable level of protection,
assuming the potential victim is far enough away.  Co-located devices may
need more suppression.
 
Ghery S. Pettit, NCE
 
-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net
<mailto:k...@earthlink.net> <mailto:k...@earthlink.net> ]
Sent: Thursday, September 29, 2016 12:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
On 9/29/2016 2:07 PM, Ken Javor wrote:
> I missed out on the prologue and am curious as why Part 15 limits 
> aren't low enough. Not low enough for what?
 
Actually preventing harmful interference.  Requiring a warranty in the
purchase contract would put manufacturers on notice that they're actually
expected to do that -- and eat the cost of fixing things if they don't.
 
§ 15.5 General conditions of operation.
(b) Operation of an intentional, unintentional, or incidental radiator is
subject to the conditions that no harmful interference is caused and that
interference must be accepted that may be caused by the operation of an
authorized radio station, by another intentional or unintentional radiator,
by industrial, scientific and medical
(ISM) equipment, or by an incidental radiator.
 
§ 15.15 General technical requirements.
(c) Parties responsible for equipment compliance should note that the limits
specified in this part will not prevent harmful interference under all
circumstances.  Since the operators of part 15 devices are required to cease
operation should harmful interference occur to authorized users of the radio
frequency spectrum, the parties responsible for equipment compliance are
encouraged to employ the minimum field strength necessary for
communications, to provide greater attenuation of unwanted emissions than
required by these regulations, and to advise the user as to how to resolve
harmful interference problems (for example, see §15.105(b)).
 
[and (maybe -- good luck)]
 
§ 15.17 Susceptibility to interference.
(a) Parties responsible for equipment compliance are advised to consider the
proximity and the high power of non-Government licensed radio stations, such
as broadcast, amateur, land mobile,and non-geostationary mobile satellite
feeder link earth stations, and of U.S. Government 

Re: [PSES] [RFI] Part 15 isn't enough..

[Ken Javor]

Without getting into the specifics of this particular argument, the idea
that the “rest of the world” has dome something doesn’t necessarily imply
that North America is “behind.”  In the same sense that if a train has
derailed and the locomotive is headed over a cliff, we don’t say the caboose
is behind and needs to catch up.

Ken Javor
Phone: (256) 650-5261



From: john Allen <john_e_al...@blueyonder.co.uk>
Reply-To: john Allen <john_e_al...@blueyonder.co.uk>
Date: Thu, 29 Sep 2016 22:44:48 +0100
To: <EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dennis
 
I really  do wonder what World you live in – but then, TBH, based on your
previous comments of a similar nature, I did not expect anything else!
 
OK, Government “interference” is unwelcome in many cases but Brian
O’Connell’s post is a  poignant “real world”  comment on what suppliers are
facing, and what the Government should face up to and address – for the
greater good of everyone in YOUR country.
 
Without getting trying to “personal”,  “get real”! - a lot of the rest of
the “real world” has already adopted appropriate requirements to try to
prevent undue interference problems and so N. America is behind on this
issue.
 
John E Allen.
W. London, UK
 

From: dward [mailto:dw...@pctestlab.com]
Sent: 29 September 2016 22:28
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..
 
The federal government already interferes with US citizens far too much as
it is – we do not need, nor do most of us want more federal intrusion.  The
feds are there to keep the wolves at bay and keep out of our lives.
Besides, the open market in the US seems to take care of itself in the
interference area.  Does not take long for the consumer to know what is
trash and what works.
The only regulations dealing with the spectrum that is needed is the
regulation to help stop interference to licensed services. That was the
intent of the FCC to start and there is no reason to change it.
 
 

​
Dennis Ward
This communication and its attachements contain information from PCTEST
Engineering Laboratory, Inc., and is intended for the exclusive use of the
recipient(s) named above.  It may contain information that is confidential
and/or legally privileged.  Any unauthorized use that may compromise that
confidentiality via distribution or disclosure is prohibited.  Please notify
the sender immediately if you receive this communication in error, and
delete it from your computer system.  Usage of PCTEST email addresses for
non-business related activities is strictly prohibited.  No warranty is made
that the e-mail or attachments(s) are free from computer virus or other
defect.  Thank you.
 

From: john Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Thursday, September 29, 2016 2:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Dennis
 
And why not – seriously?
 
As was said many years ago – and often repeated! - “what’s right for the
goose is right for the gander”.
 
In this case (and many others) In simple terms, that means that implies that
electronic devices need to be appropriately resilient to the generally
“predictable” levels of external interference in the environments for which
they are designed to operate – one of the basic essential requirements of
the EMC Directive!
 
Otherwise you might need to specify that YOUR products need to have
MIL-STD-461 levels (highest!) of immunity to try to ensure they will work
“anywhere” they are likely to be used!
 
John E Allen
W. London, UK
 
 

From: dward [mailto:dw...@pctestlab.com]
Sent: 29 September 2016 21:53
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..
 
Not a chance
 

​
Dennis Ward
This communication and its attachements contain information from PCTEST
Engineering Laboratory, Inc., and is intended for the exclusive use of the
recipient(s) named above.  It may contain information that is confidential
and/or legally privileged.  Any unauthorized use that may compromise that
confidentiality via distribution or disclosure is prohibited.  Please notify
the sender immediately if you receive this communication in error, and
delete it from your computer system.  Usage of PCTEST email addresses for
non-business related activities is strictly prohibited.  No warranty is made
that the e-mail or attachments(s) are free from computer virus or other
defect.  Thank you.
 

From: john Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Thursday, September 29, 2016 1:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Almost sounds like a call for N. America to encompass our equivalent
immunity requirements  (often denigrated - even with Europe, but they
generally do seem to work!) J
 
John E Allen
W. London, UK
 
-Original Message-
From: Ghery S. Pettit [mailto:n6...@comcast.net]
Sent: 29 September 2016 21:14
To: EMC-PSTC

Re: [PSES] [RFI] Part 15 isn't enough..

[john Allen]

Dennis

 

I really  do wonder what World you live in – but then, TBH, based on your 
previous comments of a similar nature, I did not expect anything else!

 

OK, Government “interference” is unwelcome in many cases but Brian O’Connell’s 
post is a  poignant “real world”  comment on what suppliers are facing, and 
what the Government should face up to and address – for the greater good of 
everyone in YOUR country.

 

Without getting trying to “personal”,  “get real”! - a lot of the rest of the 
“real world” has already adopted appropriate requirements to try to prevent 
undue interference problems and so N. America is behind on this issue.

 

John E Allen.

W. London, UK

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 29 September 2016 22:28
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

 

The federal government already interferes with US citizens far too much as it 
is – we do not need, nor do most of us want more federal intrusion.  The feds 
are there to keep the wolves at bay and keep out of our lives.  Besides, the 
open market in the US seems to take care of itself in the interference area.  
Does not take long for the consumer to know what is trash and what works.

The only regulations dealing with the spectrum that is needed is the regulation 
to help stop interference to licensed services. That was the intent of the FCC 
to start and there is no reason to change it.

 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 2:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Dennis

 

And why not – seriously?

 

As was said many years ago – and often repeated! - “what’s right for the goose 
is right for the gander”.

 

In this case (and many others) In simple terms, that means that implies that 
electronic devices need to be appropriately resilient to the generally 
“predictable” levels of external interference in the environments for which 
they are designed to operate – one of the basic essential requirements of the 
EMC Directive!

 

Otherwise you might need to specify that YOUR products need to have MIL-STD-461 
levels (highest!) of immunity to try to ensure they will work “anywhere” they 
are likely to be used!

 

John E Allen

W. London, UK

 

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 29 September 2016 21:53
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

 

Not a chance

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 1:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Almost sounds like a call for N. America to encompass our equivalent immunity 
requirements  (often denigrated - even with Europe, but they generally do seem 
to work!) J 

 

John E Allen

W. London, UK

 

-Original Message-
From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: 29 September 2016 21:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Preventing harmful interference in all cases is a mighty tough call.  How low 
do you need to limit emissions?  How high a signal must the product be immune 
to?  The limits in Part 15 provide a reasonable level of protection, assuming 
the potential victim is far enough away.  Co-located devices may need more 
suppression.

 

Ghery S. Pettit, NCE

 

-Original Message-

From: Cortland Richmond [ <mailto:k...@earthlink.net> ma

Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

The federal government already interferes with US citizens far too much as it 
is – we do not need, nor do most of us want more federal intrusion.  The feds 
are there to keep the wolves at bay and keep out of our lives.  Besides, the 
open market in the US seems to take care of itself in the interference area.  
Does not take long for the consumer to know what is trash and what works.

The only regulations dealing with the spectrum that is needed is the regulation 
to help stop interference to licensed services. That was the intent of the FCC 
to start and there is no reason to change it.

 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 2:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Dennis

 

And why not – seriously?

 

As was said many years ago – and often repeated! - “what’s right for the goose 
is right for the gander”.

 

In this case (and many others) In simple terms, that means that implies that 
electronic devices need to be appropriately resilient to the generally 
“predictable” levels of external interference in the environments for which 
they are designed to operate – one of the basic essential requirements of the 
EMC Directive!

 

Otherwise you might need to specify that YOUR products need to have MIL-STD-461 
levels (highest!) of immunity to try to ensure they will work “anywhere” they 
are likely to be used!

 

John E Allen

W. London, UK

 

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 29 September 2016 21:53
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG 
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

 

Not a chance

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 1:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Almost sounds like a call for N. America to encompass our equivalent immunity 
requirements  (often denigrated - even with Europe, but they generally do seem 
to work!) :) 

 

John E Allen

W. London, UK

 

-Original Message-
From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: 29 September 2016 21:14
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Preventing harmful interference in all cases is a mighty tough call.  How low 
do you need to limit emissions?  How high a signal must the product be immune 
to?  The limits in Part 15 provide a reasonable level of protection, assuming 
the potential victim is far enough away.  Co-located devices may need more 
suppression.

 

Ghery S. Pettit, NCE

 

-Original Message-

From: Cortland Richmond [ <mailto:k...@earthlink.net> mailto:k...@earthlink.net]

Sent: Thursday, September 29, 2016 12:29 PM

To:  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

On 9/29/2016 2:07 PM, Ken Javor wrote:

> I missed out on the prologue and am curious as why Part 15 limits 

> aren't low enough. Not low enough for what?

 

Actually preventing harmful interference.  Requiring a warranty in the purchase 
contract would put manufacturers on notice that they're actually expected to do 
that -- and eat the cost of fixing things if they don't.

 

§ 15.5 General conditions of operation.

(b) Operation of an intentional, unintentional, or incidental radiator is 
subject to the con

Re: [PSES] [RFI] Part 15 isn't enough..

[Ken Javor]

Saying that Part 15 limits are not low enough has nothing to do with the
imposition of immunity requirements. Regardless of how high or low Part 15
limits might be, it has no impact on any suggested or imposed
susceptibility/immunity limits. Part 15 limits protect radio receivers, the
immunity requirements protect non-antenna connected equipment from
intentional transmissions (meaning 61000-4-3 and 61000­4-6, not the various
transient non-frequency domain requirements).

Ghery Pettit made the salient point: the Part 15 limits provide a degree of
protection such that if interference occurs, it is between two equipments
operated in the same area, under the same ownership, and therefore the
problem is controllable without causing problems between different entities,
one of which owns the culprit, and the other of which owns the victim. The
limits are not there to protect a culprit/victim pair jammed up
side-by-side. If that¹s what you want, you are looking at MIL-STD-461, as
someone else pointed out.

Ken Javor
Phone: (256) 650-5261



From: john Allen <john_e_al...@blueyonder.co.uk>
Reply-To: john Allen <john_e_al...@blueyonder.co.uk>
Date: Thu, 29 Sep 2016 21:27:14 +0100
To: <EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Almost sounds like a call for N. America to encompass our equivalent
immunity requirements  (often denigrated - even with Europe, but they
generally do seem to work!) J
 
John E Allen
W. London, UK
 
-Original Message-
From: Ghery S. Pettit [mailto:n6...@comcast.net]
Sent: 29 September 2016 21:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Preventing harmful interference in all cases is a mighty tough call.  How
low do you need to limit emissions?  How high a signal must the product be
immune to?  The limits in Part 15 provide a reasonable level of protection,
assuming the potential victim is far enough away.  Co-located devices may
need more suppression.
 
Ghery S. Pettit, NCE
 
-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net
<mailto:k...@earthlink.net> ]
Sent: Thursday, September 29, 2016 12:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
On 9/29/2016 2:07 PM, Ken Javor wrote:
> I missed out on the prologue and am curious as why Part 15 limits
> aren't low enough. Not low enough for what?
 
Actually preventing harmful interference.  Requiring a warranty in the
purchase contract would put manufacturers on notice that they're actually
expected to do that -- and eat the cost of fixing things if they don't.
 
§ 15.5 General conditions of operation.
(b) Operation of an intentional, unintentional, or incidental radiator is
subject to the conditions that no harmful interference is caused and that
interference must be accepted that may be caused by the operation of an
authorized radio station, by another intentional or unintentional radiator,
by industrial, scientific and medical
(ISM) equipment, or by an incidental radiator.
 
§ 15.15 General technical requirements.
(c) Parties responsible for equipment compliance should note that the limits
specified in this part will not prevent harmful interference under all
circumstances.  Since the operators of part 15 devices are required to cease
operation should harmful interference occur to authorized users of the radio
frequency spectrum, the parties responsible for equipment compliance are
encouraged to employ the minimum field strength necessary for
communications, to provide greater attenuation of unwanted emissions than
required by these regulations, and to advise the user as to how to resolve
harmful interference problems (for example, see §15.105(b)).
 
[and (maybe -- good luck)]
 
§ 15.17 Susceptibility to interference.
(a) Parties responsible for equipment compliance are advised to consider the
proximity and the high power of non-Government licensed radio stations, such
as broadcast, amateur, land mobile,and non-geostationary mobile satellite
feeder link earth stations, and of U.S. Government radio stations, which
could include high-powered radar systems, when choosing operating
frequencies during the design of their equipment so as to reduce the
susceptibility for receiving harmful interference. ...
 
 
Cortland
 
-

This message is from the IEEE Product Safety Engineering Society emc-pstc
discussion list. To post a message to the list, send your e-mail to
<emc-p...@ieee.org <mailto:emc-p...@ieee.org> >
 
All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html
<http://www.ieee-pses.org/emc-pstc.html>
 
Attachments are not permitted but the IEEE PSES Online Communities site at
http://product-compliance.oc.ieee.org/
<http://product-compliance.oc.ieee.org/>  can be used for graphics (in
well-

Re: [PSES] [RFI] Part 15 isn't enough..

[Brian O'Connell]

Dunno, maybe you have something there. Increasing numbers of (non-mil) customer 
specs being shoved into my face for review are referencing RS and CS stuff.

Brian

From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 2:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dennis

And why not – seriously?

As was said many years ago – and often repeated! - “what’s right for the goose 
is right for the gander”.

In this case (and many others) In simple terms, that means that implies that 
electronic devices need to be appropriately resilient to the generally 
“predictable” levels of external interference in the environments for which 
they are designed to operate – one of the basic essential requirements of the 
EMC Directive!

Otherwise you might need to specify that YOUR products need to have MIL-STD-461 
levels (highest!) of immunity to try to ensure they will work “anywhere” they 
are likely to be used!

John E Allen
W. London, UK


From: dward [mailto:dw...@pctestlab.com] 
Sent: 29 September 2016 21:53
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

Not a chance

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 1:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Almost sounds like a call for N. America to encompass our equivalent immunity 
requirements  (often denigrated - even with Europe, but they generally do seem 
to work!) ☺ 

John E Allen
W. London, UK

-Original Message-
From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: 29 September 2016 21:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Preventing harmful interference in all cases is a mighty tough call.  How low 
do you need to limit emissions?  How high a signal must the product be immune 
to?  The limits in Part 15 provide a reasonable level of protection, assuming 
the potential victim is far enough away.  Co-located devices may need more 
suppression.

Ghery S. Pettit, NCE

-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net]
Sent: Thursday, September 29, 2016 12:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/29/2016 2:07 PM, Ken Javor wrote:
> I missed out on the prologue and am curious as why Part 15 limits 
> aren't low enough. Not low enough for what?

Actually preventing harmful interference.  Requiring a warranty in the purchase 
contract would put manufacturers on notice that they're actually expected to do 
that -- and eat the cost of fixing things if they don't.

§ 15.5 General conditions of operation.
(b) Operation of an intentional, unintentional, or incidental radiator is 
subject to the conditions that no harmful interference is caused and that 
interference must be accepted that may be caused by the operation of an 
authorized radio station, by another intentional or unintentional radiator, by 
industrial, scientific and medical
(ISM) equipment, or by an incidental radiator.

§ 15.15 General technical requirements.
(c) Parties responsible for equipment compliance should note that the limits 
specified in this part will not prevent harmful interference under all 
circumstances.  Since the operators of part 15 devices are required to cease 
operation should harmful interference occur to authorized users of the radio 
frequency spectrum, the parties responsible for equipment compliance are 
encouraged to employ the minimum field strength necessary for communications, 
to provide greater attenuation of unwanted emissions than required by these 
regulations, and to advise the user as to how to resolve harmful interference 
problems (for example, see §15.105(b)).

[and (maybe -- good luck)]

§ 15.17 Susceptibility to interference.
(a) Parties responsible for equipment compliance are advised to consider the 
proximity and the high power of non-Government licensed radio stations, such as 
broadcast, amateur, land mobile,and non-geostationary mobile satellite feeder 
link earth stations, and of U.S. Government radio stations, which could include 
high-powered radar systems, when choosing operating frequencies 

Re: [PSES] [RFI] Part 15 isn't enough..

[john Allen]

Dennis

 

And why not – seriously?

 

As was said many years ago – and often repeated! - “what’s right for the goose 
is right for the gander”.

 

In this case (and many others) In simple terms, that means that implies that 
electronic devices need to be appropriately resilient to the generally 
“predictable” levels of external interference in the environments for which 
they are designed to operate – one of the basic essential requirements of the 
EMC Directive!

 

Otherwise you might need to specify that YOUR products need to have MIL-STD-461 
levels (highest!) of immunity to try to ensure they will work “anywhere” they 
are likely to be used!

 

John E Allen

W. London, UK

 

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 29 September 2016 21:53
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

 

Not a chance

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 1:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Almost sounds like a call for N. America to encompass our equivalent immunity 
requirements  (often denigrated - even with Europe, but they generally do seem 
to work!) J 

 

John E Allen

W. London, UK

 

-Original Message-
From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: 29 September 2016 21:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Preventing harmful interference in all cases is a mighty tough call.  How low 
do you need to limit emissions?  How high a signal must the product be immune 
to?  The limits in Part 15 provide a reasonable level of protection, assuming 
the potential victim is far enough away.  Co-located devices may need more 
suppression.

 

Ghery S. Pettit, NCE

 

-Original Message-

From: Cortland Richmond [ <mailto:k...@earthlink.net> mailto:k...@earthlink.net]

Sent: Thursday, September 29, 2016 12:29 PM

To:  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

On 9/29/2016 2:07 PM, Ken Javor wrote:

> I missed out on the prologue and am curious as why Part 15 limits 

> aren't low enough. Not low enough for what?

 

Actually preventing harmful interference.  Requiring a warranty in the purchase 
contract would put manufacturers on notice that they're actually expected to do 
that -- and eat the cost of fixing things if they don't.

 

§ 15.5 General conditions of operation.

(b) Operation of an intentional, unintentional, or incidental radiator is 
subject to the conditions that no harmful interference is caused and that 
interference must be accepted that may be caused by the operation of an 
authorized radio station, by another intentional or unintentional radiator, by 
industrial, scientific and medical

(ISM) equipment, or by an incidental radiator.

 

§ 15.15 General technical requirements.

(c) Parties responsible for equipment compliance should note that the limits 
specified in this part will not prevent harmful interference under all 
circumstances.  Since the operators of part 15 devices are required to cease 
operation should harmful interference occur to authorized users of the radio 
frequency spectrum, the parties responsible for equipment compliance are 
encouraged to employ the minimum field strength necessary for communications, 
to provide greater attenuation of unwanted emissions than required by these 
regulations, and to advise the user as to how to resolve harmful interference 
problems (for example, see §15.105(b)).

 

[and (maybe -- good luck)]

 

§ 15.17 Susceptibility to interference.

(a) Parties responsible for equipment compliance are advised to consider the 
proximity and the high power of non-Government licensed radio stations, such as 
broadcast, amateur, land mobile,and non-geostationary mobile satellite feeder 
link earth stations, and of U.S. Government radio stations, which could include 
high-powered radar systems, when choosing operating frequencies during the 
design of their equipment so as to reduce the susceptibility for receiving 
harmful interference. .

Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

Not a chance

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 1:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Almost sounds like a call for N. America to encompass our equivalent immunity 
requirements  (often denigrated - even with Europe, but they generally do seem 
to work!) :) 

 

John E Allen

W. London, UK

 

-Original Message-
From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: 29 September 2016 21:14
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Preventing harmful interference in all cases is a mighty tough call.  How low 
do you need to limit emissions?  How high a signal must the product be immune 
to?  The limits in Part 15 provide a reasonable level of protection, assuming 
the potential victim is far enough away.  Co-located devices may need more 
suppression.

 

Ghery S. Pettit, NCE

 

-Original Message-

From: Cortland Richmond [ <mailto:k...@earthlink.net> mailto:k...@earthlink.net]

Sent: Thursday, September 29, 2016 12:29 PM

To:  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

On 9/29/2016 2:07 PM, Ken Javor wrote:

> I missed out on the prologue and am curious as why Part 15 limits 

> aren't low enough. Not low enough for what?

 

Actually preventing harmful interference.  Requiring a warranty in the purchase 
contract would put manufacturers on notice that they're actually expected to do 
that -- and eat the cost of fixing things if they don't.

 

§ 15.5 General conditions of operation.

(b) Operation of an intentional, unintentional, or incidental radiator is 
subject to the conditions that no harmful interference is caused and that 
interference must be accepted that may be caused by the operation of an 
authorized radio station, by another intentional or unintentional radiator, by 
industrial, scientific and medical

(ISM) equipment, or by an incidental radiator.

 

§ 15.15 General technical requirements.

(c) Parties responsible for equipment compliance should note that the limits 
specified in this part will not prevent harmful interference under all 
circumstances.  Since the operators of part 15 devices are required to cease 
operation should harmful interference occur to authorized users of the radio 
frequency spectrum, the parties responsible for equipment compliance are 
encouraged to employ the minimum field strength necessary for communications, 
to provide greater attenuation of unwanted emissions than required by these 
regulations, and to advise the user as to how to resolve harmful interference 
problems (for example, see §15.105(b)).

 

[and (maybe -- good luck)]

 

§ 15.17 Susceptibility to interference.

(a) Parties responsible for equipment compliance are advised to consider the 
proximity and the high power of non-Government licensed radio stations, such as 
broadcast, amateur, land mobile,and non-geostationary mobile satellite feeder 
link earth stations, and of U.S. Government radio stations, which could include 
high-powered radar systems, when choosing operating frequencies during the 
design of their equipment so as to reduce the susceptibility for receiving 
harmful interference. ...

 

 

Cortland

 

-



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

 

All emc-pstc postings are archived and searchable on the web at:

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

 

Attachments are not permitted but the IEEE PSES Online Communities site at  
<http://product-compliance.oc.ieee.org/> http://product-compliance.oc.ieee.org/ 
can be used for graphics (in well-used formats), large files, etc.

 

Website:   <http://www.ieee-pses.org/> http://www.ieee-pses.org/

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

Re: [PSES] [RFI] Part 15 isn't enough..

[john Allen]

Almost sounds like a call for N. America to encompass our equivalent immunity 
requirements  (often denigrated - even with Europe, but they generally do seem 
to work!) J 

 

John E Allen

W. London, UK

 

-Original Message-
From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: 29 September 2016 21:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Preventing harmful interference in all cases is a mighty tough call.  How low 
do you need to limit emissions?  How high a signal must the product be immune 
to?  The limits in Part 15 provide a reasonable level of protection, assuming 
the potential victim is far enough away.  Co-located devices may need more 
suppression.

 

Ghery S. Pettit, NCE

 

-Original Message-

From: Cortland Richmond [ <mailto:k...@earthlink.net> mailto:k...@earthlink.net]

Sent: Thursday, September 29, 2016 12:29 PM

To:  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

On 9/29/2016 2:07 PM, Ken Javor wrote:

> I missed out on the prologue and am curious as why Part 15 limits 

> aren't low enough. Not low enough for what?

 

Actually preventing harmful interference.  Requiring a warranty in the purchase 
contract would put manufacturers on notice that they're actually expected to do 
that -- and eat the cost of fixing things if they don't.

 

§ 15.5 General conditions of operation.

(b) Operation of an intentional, unintentional, or incidental radiator is 
subject to the conditions that no harmful interference is caused and that 
interference must be accepted that may be caused by the operation of an 
authorized radio station, by another intentional or unintentional radiator, by 
industrial, scientific and medical

(ISM) equipment, or by an incidental radiator.

 

§ 15.15 General technical requirements.

(c) Parties responsible for equipment compliance should note that the limits 
specified in this part will not prevent harmful interference under all 
circumstances.  Since the operators of part 15 devices are required to cease 
operation should harmful interference occur to authorized users of the radio 
frequency spectrum, the parties responsible for equipment compliance are 
encouraged to employ the minimum field strength necessary for communications, 
to provide greater attenuation of unwanted emissions than required by these 
regulations, and to advise the user as to how to resolve harmful interference 
problems (for example, see §15.105(b)).

 

[and (maybe -- good luck)]

 

§ 15.17 Susceptibility to interference.

(a) Parties responsible for equipment compliance are advised to consider the 
proximity and the high power of non-Government licensed radio stations, such as 
broadcast, amateur, land mobile,and non-geostationary mobile satellite feeder 
link earth stations, and of U.S. Government radio stations, which could include 
high-powered radar systems, when choosing operating frequencies during the 
design of their equipment so as to reduce the susceptibility for receiving 
harmful interference. ...

 

 

Cortland

 

-



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

 

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

 

Attachments are not permitted but the IEEE PSES Online Communities site at  
<http://product-compliance.oc.ieee.org/> http://product-compliance.oc.ieee.org/ 
can be used for graphics (in well-used formats), large files, etc.

 

Website:   <http://www.ieee-pses.org/> http://www.ieee-pses.org/

Instructions:   <http://www.ieee-pses.org/list.html> 
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This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to < 
<mailto:emc-p...@ieee.org> emc-p...@ieee.org>

 

All emc-pstc postings are archived and searchable on the web at:

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

 

Attachments are not permitted but the IEEE 

Re: [PSES] [RFI] Part 15 isn't enough..

[Ghery S. Pettit]

Preventing harmful interference in all cases is a mighty tough call.  How low 
do you need to limit emissions?  How high a signal must the product be immune 
to?  The limits in Part 15 provide a reasonable level of protection, assuming 
the potential victim is far enough away.  Co-located devices may need more 
suppression.

Ghery S. Pettit, NCE

-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: Thursday, September 29, 2016 12:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/29/2016 2:07 PM, Ken Javor wrote:
> I missed out on the prologue and am curious as why Part 15 limits 
> aren't low enough. Not low enough for what?

Actually preventing harmful interference.  Requiring a warranty in the purchase 
contract would put manufacturers on notice that they're actually expected to do 
that -- and eat the cost of fixing things if they don't.

§ 15.5 General conditions of operation.
(b) Operation of an intentional, unintentional, or incidental radiator is 
subject to the conditions that no harmful interference is caused and that 
interference must be accepted that may be caused by the operation of an 
authorized radio station, by another intentional or unintentional radiator, by 
industrial, scientific and medical
(ISM) equipment, or by an incidental radiator.

§ 15.15 General technical requirements.
(c) Parties responsible for equipment compliance should note that the limits 
specified in this part will not prevent harmful interference under all 
circumstances.  Since the operators of part 15 devices are required to cease 
operation should harmful interference occur to authorized users of the radio 
frequency spectrum, the parties responsible for equipment compliance are 
encouraged to employ the minimum field strength necessary for communications, 
to provide greater attenuation of unwanted emissions than required by these 
regulations, and to advise the user as to how to resolve harmful interference 
problems (for example, see §15.105(b)).

[and (maybe -- good luck)]

§ 15.17 Susceptibility to interference.
(a) Parties responsible for equipment compliance are advised to consider the 
proximity and the high power of non-Government licensed radio stations, such as 
broadcast, amateur, land mobile,and non-geostationary mobile satellite feeder 
link earth stations, and of U.S. Government radio stations, which could include 
high-powered radar systems, when choosing operating frequencies during the 
design of their equipment so as to reduce the susceptibility for receiving 
harmful interference. ...


Cortland

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Re: [PSES] [RFI] Part 15 isn't enough..

[Cortland Richmond]

On 9/29/2016 2:07 PM, Ken Javor wrote:

I missed out on the prologue and am curious as why Part 15 limits aren't low
enough. Not low enough for what?


Actually preventing harmful interference.  Requiring a warranty in the 
purchase contract would put
manufacturers on notice that they're actually expected to do that -- and 
eat the cost of fixing things

if they don't.

§ 15.5 General conditions of operation.
(b) Operation of an intentional, unintentional, or incidental radiator 
is subject to
the conditions that no harmful interference is caused and that 
interference must be
accepted that may be caused by the operation of an authorized radio 
station, by
another intentional or unintentional radiator, by industrial, scientific 
and medical

(ISM) equipment, or by an incidental radiator.

§ 15.15 General technical requirements.
(c) Parties responsible for equipment compliance should note that the limits
specified in this part will not prevent harmful interference under all
circumstances.  Since the operators of part 15 devices are required to 
cease

operation should harmful interference occur to authorized users of the radio
frequency spectrum, the parties responsible for equipment compliance are
encouraged to employ the minimum field strength necessary for 
communications,

to provide greater attenuation of unwanted emissions than required by these
regulations, and to advise the user as to how to resolve harmful
interference problems (for example, see §15.105(b)).

[and (maybe -- good luck)]

§ 15.17 Susceptibility to interference.
(a) Parties responsible for equipment compliance are advised to consider the
proximity and the high power of non-Government licensed radio stations,
such as broadcast, amateur, land mobile,and non-geostationary mobile 
satellite

feeder link earth stations, and of U.S. Government radio stations, which
could include high-powered radar systems, when choosing operating 
frequencies

during the design of their equipment so as to reduce the susceptibility
for receiving harmful interference. ...


Cortland

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Re: [PSES] [RFI] Part 15 isn't enough..

[Ken Javor]

I missed out on the prologue and am curious as why Part 15 limits aren't low
enough. Not low enough for what?

Ken Javor
Phone: (256) 650-5261


> From: Cortland Richmond <k...@earthlink.net>
> Reply-To: <k...@earthlink.net>
> Date: Thu, 29 Sep 2016 13:36:36 -0400
> To: <EMC-PSTC@LISTSERV.IEEE.ORG>
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> On 9/29/2016 6:53 AM, Charles Gallo wrote:
>> But part 15 limits are not low enough
> 
> That's why you'd want to require the manufacturer to warrant
> non-interference per the OTHER provisions of Part 15.
> 
> Cortland Richmond
> ka5s
> 
> -
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to
> <emc-p...@ieee.org>
> 
> All emc-pstc postings are archived and searchable on the web at:
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> 
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used
> formats), large files, etc.
> 
> Website:  http://www.ieee-pses.org/
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> 
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Re: [PSES] [RFI] Part 15 isn't enough..

[Cortland Richmond]

On 9/29/2016 6:53 AM, Charles Gallo wrote:

But part 15 limits are not low enough


That's why you'd want to require the manufacturer to warrant 
non-interference per the OTHER provisions of Part 15.


Cortland Richmond
ka5s

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