Re: [PSES] CE-EMC on Submersible Product
My last company made equipment for monitoring the condition of oil/gas well drill holes (both Closed Hole metal drill pipes and Open Holes where it was part of exploratory drilling equipment in the surrounding rocks, etc), but it did not make submersibles. However we tested the equipment on the surface as if it were "normal devices" because it had to be operated there for preparation and test purposes. We did not attempt to test it as it would be when it was in the drill pipes or holes because it would then be surrounded by either a metal Faraday cage or vast areas of solid rock and so on - where there was little or no chance of it interfering with, or being interfered by, anything else. Also, AFAIK, there had never been any reports of interference to, or from, other equipment, and that would also have been part of a defence against any accusations that it did need to be tested in the down-hole configurations. John E Allen W.London, UK -Original Message- From: McCallum, Andy [mailto:andy.mccal...@mottmac.com] Sent: 19 May 2016 10:38 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE-EMC on Submersible Product John Is there anything stopping the device producing noise when it is out of the water? If not I would look to test it as for any normal device. Regards Andy -Original Message- From: John Allen [mailto:jral...@productsafetyinc.com] Sent: 18 May 2016 22:19 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] CE-EMC on Submersible Product Hi, I would like to get thoughts on if EMC testing is required for CE on a product that does generate noise, but is installed 30 feet below the surface of water. I'm guessing conducted radiation is still a concern, but what about radiated and immunity?? Does it matter if it's 30 feet below or 3 feet?? Best Regards, John John Allen Product Safety Consulting, Inc www.productsafetyinc.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 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: - 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: - 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] CE-EMC on Submersible Product
John Is there anything stopping the device producing noise when it is out of the water? If not I would look to test it as for any normal device. Regards Andy -Original Message- From: John Allen [mailto:jral...@productsafetyinc.com] Sent: 18 May 2016 22:19 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] CE-EMC on Submersible Product Hi, I would like to get thoughts on if EMC testing is required for CE on a product that does generate noise, but is installed 30 feet below the surface of water. I'm guessing conducted radiation is still a concern, but what about radiated and immunity?? Does it matter if it's 30 feet below or 3 feet?? Best Regards, John John Allen Product Safety Consulting, Inc www.productsafetyinc.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 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: - 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] CE-EMC on Submersible Product
Your best bet is to work through a notified body. Best Regards Charles Grasso Compliance Engineer Echostar Communications (w) 303-706-5467 (c) 303-204-2974 (t) 3032042...@vtext.com (e) charles.gra...@echostar.com (e2) chasgra...@gmail.com -Original Message- From: T.Sato [mailto:vef00...@nifty.com] Sent: Wednesday, May 18, 2016 4:47 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE-EMC on Submersible Product On Wed, 18 May 2016 21:19:00 +, John Allen wrote: > I would like to get thoughts on if EMC testing is required for CE on a > product that does generate noise, but is installed 30 feet below the surface > of water. > > I'm guessing conducted radiation is still a concern, but what about radiated > and immunity?? Does it matter if it's 30 feet below or 3 feet?? If the attenuation data in http://file.scirp.org/pdf/JEMAA2011071_18390291.pdf Electromagnetic Wave Propagation into Fresh Water is appicable, for 30 MHz, about -10 dB attenuation may be expected at 10 m, which may not enough to ignore radiated emissions and immunities. In addition, some RF may propagate up/down through the cable. I guess radiated emissions/immunities can still a matter. Regards, Tom -- Tomonori Sato URL: http://t-sato.in.coocan.jp - 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: - 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] CE-EMC on Submersible Product
Excerpt from Marine directive: COMMISSION DECISION of 1 September 2010 on criteria and methodological standards on good environmental status of marine waters (notified under document C(2010) 5956) (Text with EEA relevance) (2010/477/EU) Descriptor 11: Introduction of energy, including underwater noise, is at levels that do not adversely affect the marine environment. Together with underwater noise, which is highlighted throughout Directive 2008/56/EC, other forms of energy input have the potential to impact on components of marine ecosystems, such as thermal energy, electromagnetic fields and light. Additional scientific and technical progress is still required to support the further development of criteria related to this descriptor (22), including in relation to impacts of introduction of energy on marine life, relevant noise and frequency levels (which may need to be adapted, where appropriate, subject to the requirement of regional cooperation). At the current stage, the main orientations for the measurement of underwater noise have been identified as a first priority in relation to assessment and monitoring (23), subject to further development, including in relation to mapping. Anthropogenic sounds may be of short duration (e.g. impulsive such as from seismic surveys and piling for wind farms and platforms, as well as explosions) or be long lasting (e.g. continuous such as dredging, shipping and energy installations) affecting organisms in different ways. Most commercial activities entailing high level noise levels affecting relatively broad areas are executed under regulated conditions subject to a license. This creates the opportunity for coordinating coherent requirements for measuring such loud impulsive sounds. 11.1. Distribution in time and place of loud, low and mid frequency impulsive sounds - Proportion of days and their distribution within a calendar year over areas of a determined surface, as well as their spatial distribution, in which anthropogenic sound sources exceed levels that are likely to entail significant impact on marine animals measured as Sound Exposure Level (in dB re 1μPa2.s) or as peak sound pressure level (in dB re 1μPapeak) at one metre, measured over the frequency band 10 Hz to 10 kHz (11.1.1) 11.2. Continuous low frequency sound - Trends in the ambient noise level within the 1/3 octave bands 63 and 125 Hz (centre frequency) (re 1μΡa RMS; average noise level in these octave bands over a year) measured by observation stations and/or with the use of models if appropriate (11.2.1). Hope this helps somewhat. Regan Arndt -Original Message- From: T.Sato [mailto:vef00...@nifty.com] Sent: Wednesday, May 18, 2016 3:47 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE-EMC on Submersible Product On Wed, 18 May 2016 21:19:00 +, John Allen mailto:jral...@productsafetyinc.com>> wrote: > I would like to get thoughts on if EMC testing is required for CE on a > product that does generate noise, but is installed 30 feet below the surface > of water. > > I'm guessing conducted radiation is still a concern, but what about radiated > and immunity?? Does it matter if it's 30 feet below or 3 feet?? If the attenuation data in http://file.scirp.org/pdf/JEMAA2011071_18390291.pdf Electromagnetic Wave Propagation into Fresh Water is appicable, for 30 MHz, about -10 dB attenuation may be expected at 10 m, which may not enough to ignore radiated emissions and immunities. In addition, some RF may propagate up/down through the cable. I guess radiated emissions/immunities can still a matter. Regards, Tom -- Tomonori Sato mailto:vef00...@nifty.com>> URL: http://t-sato.in.coocan.jp - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to mailto:emc-p...@ieee.org>> All emc-pstc postings are archived and searchable on the web at: 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 mailto:sdoug...@ieee.org>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher: mailto:j.bac...@ieee.org>> David Heald: mailto: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 All emc-pstc postings are archived and searcha
Re: [PSES] CE-EMC on Submersible Product
On Wed, 18 May 2016 21:19:00 +, John Allen wrote: > I would like to get thoughts on if EMC testing is required for CE on a > product that does generate noise, but is installed 30 feet below the surface > of water. > > I'm guessing conducted radiation is still a concern, but what about radiated > and immunity?? Does it matter if it's 30 feet below or 3 feet?? If the attenuation data in http://file.scirp.org/pdf/JEMAA2011071_18390291.pdf Electromagnetic Wave Propagation into Fresh Water is appicable, for 30 MHz, about -10 dB attenuation may be expected at 10 m, which may not enough to ignore radiated emissions and immunities. In addition, some RF may propagate up/down through the cable. I guess radiated emissions/immunities can still a matter. Regards, Tom -- Tomonori Sato URL: http://t-sato.in.coocan.jp - 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:
[PSES] CE-EMC on Submersible Product
Hi, I would like to get thoughts on if EMC testing is required for CE on a product that does generate noise, but is installed 30 feet below the surface of water. I'm guessing conducted radiation is still a concern, but what about radiated and immunity?? Does it matter if it's 30 feet below or 3 feet?? Best Regards, John John Allen Product Safety Consulting, Inc www.productsafetyinc.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 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: