Re: [PSES] CE-EMC on Submersible Product

2016-05-19 Thread John Allen
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

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Re: [PSES] CE-EMC on Submersible Product

2016-05-19 Thread McCallum, Andy
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

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Re: [PSES] CE-EMC on Submersible Product

2016-05-18 Thread Grasso, Charles
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

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Re: [PSES] CE-EMC on Submersible Product

2016-05-18 Thread Regan Arndt
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

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Re: [PSES] CE-EMC on Submersible Product

2016-05-18 Thread T.Sato
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

-

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[PSES] CE-EMC on Submersible Product

2016-05-18 Thread John Allen
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

-

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