Re: FCC Part 15 and U.S. Safety dates?

2007-10-14 Thread emc-p...@ieee.org
Hi David,

Part 15, first known as the Low Power Rules in the 1930's, has been around
since 1949 or so.  Originally unlicensed transmitters were ok as long as their
field strength was 15 uV/m or less at a distance lamda/2pi, lambda being
wavelength.

As the electronics industry grew and radio interference sources proliferated,
FCC modified and added to the requirements, first with radiated and line
conducted emissions for receivers in the 30-890 Mc range (they hadn't
perfected the MHz yet), then with product based limits for garage door
openers, anti-pilferage devices, toys and walkie talkies, etc.  In 1976 a
Notice of Proposed Rule Making (NPRM) Docket 20780 was released, proposing 
additional categories of devices to be regulated , including data processing
equipment, and relaxing the  lamda/2pi limit.  By the time the docket was
placed into the Rules in 1979, references to other devices was eliminated and
the first version of the digital device rules went into effect.

best regards

Tom


On Oct 10, 2007, at 7:19 PM, David Lohbeck wrote:


hELLO,
 
Does anyone know when the FCC rules (part 15) went into effect (1982)?
 
Also, was there a date that a U.S. safety law WAS enacted and by who (OSHA)?
 
Thanks,,
Dave Lohbeck

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RE: FCC Part 15 and U.S. Safety dates?

2007-10-12 Thread emc-p...@ieee.org
While I am waiting for my test sample to (finally) die...

OSHA does NOT mandate any EMC requirements through the NRTL program. OSHA
has adopted the FDA guidelines for RF-emitting devices used in the work
place. OSHA bases these limits on FDA guidelines, which also establishes
the limits used by other federal agencies. Some limits are codified in
various CFR sections. I am not aware of any SAR-related material in the
NEC.

The American governmental bureaucracy is confusing, but here is my
synopsis of the part of this mess that could be considered related to
SAR-based stuff:

OSHA = Dept of Labor - concerned with work-place safety, implements the
NRTL program
FCC = independent federal agency - concerned with preserving the spectrum
CDRH = FDA =  Dept of Health and Human Services - the FDA in particular
is focused on 'technical' safety, while the HHS is concerned with direct
services and public welfare
CPSC - independent federal agency - legally authorized to regulate the
marketing of all consumer-related materials except guns, drugs, food, and
vehicles. The people that your lawyers will talk to if your device bakes a
human organ.
Department of Defense (DOD) - RF energy + biology research (Brooks AFB) -
data has been used by FDA
EPA - 'wannabe' in the RF safety field - not a 'full' cabinet-level
agency; ignore them.

incomplete chronology:
1968- Radiation Control for Health and Safety Act - mostly to limit
ionizing radiation
1969 - National Environmental Policy Act - an ambiguos and open-ended
text that allows the EPA to get involved in anything for any reason.
1971- OSHA issued 29 CFR 1910.97
1985 - FCC adopts 1982 ANSI standard - must now consider effects of RF on
enviroment
1992 - new standard for RF exposure ANSI/IEEE C95.1-1992
1995 - FCC updates CFR to include ANSI/IEEE C95.1-1992 exposure limits
1999 - formal filing for FCC to adopt CISPR 22 emissions limits
2001 - updated CFR formally released w/CISPR 22 harmonization

Other than the SAR-based stuff, it should be noted that, outside of
vehicle, medical, aviation, and military, there is no generic requirements
for EMC-related functional safety of consumer goods in American code. 

luck,
Brian 

  -Original Message-
  
   
  Also, was there a date that a U.S. safety law WAS enacted and by who
  (OSHA)?
   
  Thanks,,
  Dave Lohbeck
 

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RE: FCC Part 15 and U.S. Safety dates?

2007-10-12 Thread kazimier_gawrzy...@dell.com
Some brief history on OSHA and NRTL program.

http://www.osha.gov/dts/otpca/nrtl/nrtl/slide18.html

A bit more detail is at:  

http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo
.gov/2005/05-22630.htm (this link might wrap around in e-mail...go to
item B named B. Why Did OSHA Develop the NRTL Program?)

Thanks,
Kaz
kazimier_gawrzy...@dell.com


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Jim
Bacher
Sent: Friday, October 12, 2007 7:49 AM
To: David Lohbeck; emc-p...@ieee.org
Subject: RE: FCC Part 15 and U.S. Safety dates?

Dave, I am not sure when OSHA, NEC or others put it into place the
safety requirements, but I believe the NRTL program was started in the
area of late 1987 or early 1988. So the requirement for a product used
in the work place to have a safety certification would have had to been
in place by then. Below are a couple key items.


OSHA's rules say:
 
1910.155(c)(3)(iv)(B)

Equipment is labeled if there is attached to it a label, symbol, or
other identifying mark of a nationally recognized testing laboratory
which makes periodic inspections of the production of such equipment,
and whose labeling indicates compliance with nationally recognized
standards or tests to determine safe use in a specified manner;

1910.155(c)(3)(iv)(C)

Equipment is accepted if it has been inspected and found by a nationally
recognized testing laboratory to conform to specified plans or to
procedures of applicable codes; and

1910.155(c)(3)(iv)(D)

Equipment is certified if it has been tested and found by a nationally
recognized testing laboratory to meet nationally recognized standards or
to be safe for use in a specified manner or is of a kind whose
production is periodically inspected by a nationally recognized testing
laboratory, and if it bears a label, tag, or other record of
certification.

NEC says:

90-7.  Examination of Equipment for Safety.  For specific items of
equipment and materials referred to in this Code, examinations for
safety made under standard conditions will provide a basis for approval
where the record is made generally available through promulgation by
organizations properly equipped and qualified for experimental testing,
inspections of the run of goods at factories, and service-value
determination through field inspections.  This avoids the necessity for
repetition of examinations by different examiners, frequently with
inadequate facilities for such work, and the confusion that would result
from conflicting reports as to the suitability of devices and materials
examined for a given purpose.
 
 
Oregon says:
479.610 Sale or disposal of uncertified or unevaluated electrical
product prohibited. Except as provided under ORS 479.540, no person
shall sell or dispose of by gift or otherwise in connection with the
person's business an electrical product that is not certified or
evaluated under the requirements of ORS 479.510 to 479.945. [1959c.406
s.9; 1981 c.815 s.12; 1995 c.706 s.2]

URL for the State of Oregon:
http://landru.leg.state.or.us/ors/479.html 




 
Also, was there a date that a U.S. safety law WAS enacted and by who
(OSHA)?
 
Thanks,,
Dave Lohbeck

-

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 David Heald:emc-p...@daveheald.com

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RE: FCC Part 15 and U.S. Safety dates?

2007-10-12 Thread emc-p...@ieee.org
Dave, I am not sure when OSHA, NEC or others put it into place the
safety requirements, but I believe the NRTL program was started in the
area of late 1987 or early 1988. So the requirement for a product used
in the work place to have a safety certification would have had to been
in place by then. Below are a couple key items.


OSHA's rules say:
 
1910.155(c)(3)(iv)(B)

Equipment is labeled if there is attached to it a label, symbol, or
other identifying mark of a nationally recognized testing laboratory
which makes periodic inspections of the production of such equipment,
and whose labeling indicates compliance with nationally recognized
standards or tests to determine safe use in a specified manner;

1910.155(c)(3)(iv)(C)

Equipment is accepted if it has been inspected and found by a nationally
recognized testing laboratory to conform to specified plans or to
procedures of applicable codes; and

1910.155(c)(3)(iv)(D)

Equipment is certified if it has been tested and found by a nationally
recognized testing laboratory to meet nationally recognized standards or
to be safe for use in a specified manner or is of a kind whose
production is periodically inspected by a nationally recognized testing
laboratory, and if it bears a label, tag, or other record of
certification.

NEC says:

90-7.  Examination of Equipment for Safety.  For specific items of
equipment and materials referred to in this Code, examinations for
safety made under standard conditions will provide a basis for approval
where the record is made generally available through promulgation by
organizations properly equipped and qualified for experimental testing,
inspections of the run of goods at factories, and service-value
determination through field inspections.  This avoids the necessity for
repetition of examinations by different examiners, frequently with
inadequate facilities for such work, and the confusion that would result
from conflicting reports as to the suitability of devices and materials
examined for a given purpose.
 
 
Oregon says:
479.610 Sale or disposal of uncertified or unevaluated electrical
product prohibited. Except as provided under ORS 479.540, no person
shall sell or dispose of by gift or otherwise in connection with the
person's business an electrical product that is not certified or
evaluated under the requirements of ORS 479.510 to 479.945. [1959c.406
s.9; 1981 c.815 s.12; 1995 c.706 s.2]

URL for the State of Oregon:
http://landru.leg.state.or.us/ors/479.html 




 
Also, was there a date that a U.S. safety law WAS enacted and by who
(OSHA)?
 
Thanks,,
Dave Lohbeck

-

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 David Heald:emc-p...@daveheald.com

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Re: FCC Part 15 and U.S. Safety dates?

2007-10-11 Thread emc-p...@ieee.org
The FCC was receiving a growing number of complaints about interference
through the 1960's and 1970's.  The first version of rules for
unintentional radiators were proposed in 1976.  The Computer and Business
Equipment Manufacturers Association (CBEMA) did a study based on models and
real equipment in 1977.  The FCC used the CBEMA data and proposed the final
rules in 1979 which were enacted in 1980.

I am not as familiar with the history of specific safety regulation in the
United States.  However, safety regulation is dictated by the local
jurisdictions, not by the Federal government.  The history of safety
regulation is a lot more complicated than that for EMC.

Ted Eckert
American Power Conversion/MGE
http://www.apc.com/

The items contained in this e-mail reflect the personal opinions of the
writer and are only provided for the assistance of the reader. The writer
is not speaking in an official capacity for APC-MGE or Schneider Electric.
The speaker does not represent APC-MGE's or Schneider Electric's official
position on any matter.


   
 David Lohbeck 
 d_lohbeck@yahoo. 
 com   To 
 Sent by:  emc-p...@ieee.org   
 emc-p...@ieee.org  cc 
   
   Subject 
 10/10/2007 09:19  FCC Part 15 and U.S. Safety dates?  
 PM
   
   
   
   
   




hELLO,

Does anyone know when the FCC rules (part 15) went into effect (1982)?

Also, was there a date that a U.S. safety law WAS enacted and by who
(OSHA)?

Thanks,,
Dave Lohbeck


 Check out the hottest 2008 models today at Yahoo! Autos. -
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