Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
Mark Harmonised Standards don't always contain all the requirements - Spectrum Requirements also apply and these are regulated by the various national radio interface regulations and not in the standards. The base for the use of the 2400-2483.5 MHz frequency band may be found in Annex 3 of ERC/REC 70-03. http://www.erodocdb.dk/Docs/doc98/official/pdf/REC7003e.pdf . This is the latest, October 2012 version, but the previous February 2011 version contained the following note: The equipment shall implement an adequate spectrum sharing mechanism in order to facilitate sharing between the various technologies and applications covered by this annex 3. In other words an adequate spectrum sharing requirement has been needed for some time. The wording in the OJ has changed (evolved) from, if you like, pointing to where ways for assessing this requirement could be found, to telling you where they can be found. It does not say that the Spectrum Sharing requirements of V1.8.1 must be followed, it says can be found. In my opinion, the note in the OJ referring to V1.8.1 is not mandatory. Demonstration with requirement could be made through consideration of sharing requirements already built in though conformity with relevant 802.11 requirements of WiFI or BT standards. But whatever you choose, you should be prepared to justify it to a Spectrum Authority if required. The manufacturer must fully apply the relevant Harmonised Standard if they want to apply the CE mark without the use of a Notified Body and the Spectrum Requirements must also be followed before the device is put into service. The requirement hasn't actually changed when applying V1.7.1 it's just that the guidance has been improved as it has been found to be not as clear as it might have been. Though whether it's completely clear now . . . . :) Regards Charlie From: Mark Gandler [mailto:markgand...@hotmail.com] Sent: 28 November 2012 19:51 To: Charlie Blackham; j...@jmwa.demon.co.uk; emc-pstc@listserv.ieee.org Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements Charlie, current mandatory version is 1.7.1. Future (2015) is 1.8.1. Both harmonized. There is an application note in question which describes additional requirements. Only as of last month this Note became mandatory. Note in OJ from 2009 was simply stating what actual tests been developed in draft 1.8.1. Should the note be treated as any other new version of the standard, allowing grace period? Better question: how does one challenge or ask for official clarification on the matter? Mark From: char...@sulisconsultants.commailto:char...@sulisconsultants.com To: j...@jmwa.demon.co.ukmailto:j...@jmwa.demon.co.uk; EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements Date: Wed, 28 Nov 2012 08:48:55 + I'll write that correctly this time :) UNLIKE many other Directives, the RTTE Directive REQUIRES the use of a Notified Body where Radio Spectrum Standards are NOT applied in full. Harmonised Standards are, in effect, mandatory unless you use a NB - and even then, you can't choose not to apply them because you don't like them From: Charlie Blackham Sent: 28 November 2012 08:47 To: 'John Woodgate'; EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements UNLIKE many other Directives, the RTTE Directive REQUIRES the use of a Notified Body where Radio Spectrum Standards are applied in full. Regards Charlie -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 28 November 2012 08:23 To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements In message snt108-w4738469ded84b4fb7df60ad...@phx.gblmailto:snt108-w4738469ded84b4fb7df60ad...@phx.gbl, dated Tue, 27 Nov 2012, Mark Gandler markgand...@hotmail.commailto:markgand...@hotmail.com writes: I'm not sure how anyone can justify this makes any sense and seems like going against the spirit of RTTE and any other EU Directives, allowing grace period for any requirement to take place. Simple mentioning of something been developed does not substitute a legal recruitment. Agreed; this seems like an erosion of the protection of manufacturers against instant changes. Like other Directives, the RTTE Directive contains no mandatory requirement to apply harmonized standards and carry out tests (except in the case of Full Quality Control). -- OOO - Own Opinions Only. See www.jmwa.demon.co.ukhttp://www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
I agree with Charlie that it is not saying you must test to V1.8.1. It is saying that you must have spectrum sharing mechanisms (we know that, it's in V1.7.1) but we don't necessarily know what that means. It gives examples, followed by an idea of where to find tests if you want them. Imagine the text from the OJ: This version of the standard gives presumption of conformity with the requirements of Article 3(2) of Directive 1999/5/EC under the following condition: The equipment shall implement an adequate spectrum sharing mechanism, e.g. LBT (Listen Before Talk), DAA (Detect And Avoid), etc., in order to comply with the requirement specified in clause 4.3.5 of this version. Such a mechanism shall facilitate sharing between the various technologies and applications which currently exist and in case of congestion, users will be ensured equal access (and as a consequence a graceful degradation of service to all users). The efficiency of the various sharing mechanisms can be assessed using the appropriate clauses of EN 300328 version 1.8.1. Now imagine a conversation between an industry person (let's call him IP) and the OJ itself. For the OJ, I shall use only the text above.. OJ: This version of the standard gives presumption of conformity with the requirements of Article 3(2) of Directive 1999/5/EC under the following condition: The equipment shall implement an adequate spectrum sharing mechanism, IP: What is a spectrum sharing mechanism? OJ:e.g. LBT (Listen Before Talk), DAA (Detect And Avoid), etc., in order to comply with the requirement specified in clause 4.3.5 of this version. IP: Oh, I see that, but what is it for? If you explain it, maybe I can use some other way to meet that requirement. OJ: Such a mechanism shall facilitate sharing between the various technologies and applications which currently exist and in case of congestion, users will be ensured equal access (and as a consequence a graceful degradation of service to all users). IP: I see. That would be really easy if I had a WLAN or Bluetooth device but I don't, I have this cool new technology I invented. Are there any tests I can follow? OJ: The efficiency of the various sharing mechanisms can be assessed using the appropriate clauses of EN 300328 version 1.8.1. IP: Thank you, you've been very helpful. Honestly, I don't actually hear these voices in my head. Michael. Michael Derby Regulatory Engineer ACB Europe From: Charlie Blackham [mailto:char...@sulisconsultants.com] Sent: 29 November 2012 08:31 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements Mark Harmonised Standards don't always contain all the requirements - Spectrum Requirements also apply and these are regulated by the various national radio interface regulations and not in the standards. The base for the use of the 2400-2483.5 MHz frequency band may be found in Annex 3 of ERC/REC 70-03. http://www.erodocdb.dk/Docs/doc98/official/pdf/REC7003e.pdf . This is the latest, October 2012 version, but the previous February 2011 version contained the following note: The equipment shall implement an adequate spectrum sharing mechanism in order to facilitate sharing between the various technologies and applications covered by this annex 3. In other words an adequate spectrum sharing requirement has been needed for some time. The wording in the OJ has changed (evolved) from, if you like, pointing to where ways for assessing this requirement could be found, to telling you where they can be found. It does not say that the Spectrum Sharing requirements of V1.8.1 must be followed, it says can be found. In my opinion, the note in the OJ referring to V1.8.1 is not mandatory. Demonstration with requirement could be made through consideration of sharing requirements already built in though conformity with relevant 802.11 requirements of WiFI or BT standards. But whatever you choose, you should be prepared to justify it to a Spectrum Authority if required. The manufacturer must fully apply the relevant Harmonised Standard if they want to apply the CE mark without the use of a Notified Body and the Spectrum Requirements must also be followed before the device is put into service. The requirement hasn't actually changed when applying V1.7.1 it's just that the guidance has been improved as it has been found to be not as clear as it might have been. Though whether it's completely clear now . . . . J Regards Charlie From: Mark Gandler [mailto:markgand...@hotmail.com] Sent: 28 November 2012 19:51 To: Charlie Blackham; j...@jmwa.demon.co.uk; emc-pstc@listserv.ieee.org Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements Charlie, current mandatory version is 1.7.1. Future (2015) is 1.8.1. Both harmonized. There is an application note in question which describes
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
I blame too much time between the helmholz coils!!! Michael Derby Regulatory Engineer ACB Europe From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: 29 November 2012 21:32 To: Michael Derby Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements You would not be alone if you did, Michael... On 29 Nov 2012, at 20:01, Michael Derby micha...@acbcert.com wrote: Honestly, I don't actually hear these voices in my head. - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
You would not be alone if you did, Michael... On 29 Nov 2012, at 20:01, Michael Derby micha...@acbcert.com wrote: Honestly, I don’t actually hear these voices in my head. - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
So do you hear the voice of Helmholtz? Donald Borowski EMC Compliance Engineer Schweitzer Engineering Labs Pullman, Washington, USA From: Michael Derby micha...@acbcert.com To: 'Nick Williams' nick.willi...@conformance.co.uk Cc: EMC-PSTC@LISTSERV.IEEE.ORG Date: 11/29/2012 01:56 PM Subject:RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements Sent by:emc-p...@ieee.org I blame too much time between the helmholz coils!!! Michael Derby Regulatory Engineer ACB Europe From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: 29 November 2012 21:32 To: Michael Derby Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements You would not be alone if you did, Michael... On 29 Nov 2012, at 20:01, Michael Derby micha...@acbcert.com wrote: Honestly, I don?t actually hear these voices in my head. - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
If he had a kind of high pitched, squeaky voice, yes. I do recall I did get a headache every time I put the surge generator through the coils but perhaps that's to be expected. Michael Derby Regulatory Engineer ACB Europe -Original Message- From: don_borow...@selinc.com [mailto:don_borow...@selinc.com] Sent: 29 November 2012 22:05 To: Michael Derby Cc: emc-p...@ieee.org; 'Nick Williams' Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements So do you hear the voice of Helmholtz? Donald Borowski EMC Compliance Engineer Schweitzer Engineering Labs Pullman, Washington, USA From: Michael Derby micha...@acbcert.com To: 'Nick Williams' nick.willi...@conformance.co.uk Cc: EMC-PSTC@LISTSERV.IEEE.ORG Date: 11/29/2012 01:56 PM Subject:RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements Sent by:emc-p...@ieee.org I blame too much time between the helmholz coils!!! Michael Derby Regulatory Engineer ACB Europe From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: 29 November 2012 21:32 To: Michael Derby Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements You would not be alone if you did, Michael... On 29 Nov 2012, at 20:01, Michael Derby micha...@acbcert.com wrote: Honestly, I don?t actually hear these voices in my head. - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
Now if you were meditating on it, then it would be the u holtz coils Dennis Ward Senior Certification Engineer PCTEST This communication and its attachments 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. From: Michael Derby [mailto:micha...@acbcert.com] Sent: Thursday, November 29, 2012 1:55 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements I blame too much time between the helmholz coils!!! Michael Derby Regulatory Engineer ACB Europe From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: 29 November 2012 21:32 To: Michael Derby Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements You would not be alone if you did, Michael... On 29 Nov 2012, at 20:01, Michael Derby micha...@acbcert.com wrote: Honestly, I don't actually hear these voices in my head. - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
In message snt108-w65b68ed3470c4710bf5c65ad...@phx.gbl, dated Thu, 29 Nov 2012, Mark Gandler markgand...@hotmail.com writes: All text coming after it is the condition, and that INCLUDES the testing. See last sentence: “The efficiency of the various sharing mechanisms can be assessed using the appropriate clauses of EN 300 328 version 1.8.1.” Mark Gandler: I still believe the word CAN is a key in this discussion, am trying to get final feedback from OJ on the word can Not only that, can a NOTE in an ETSI standard include a requirement? It cannot in IEC and CENELEC standards. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
In message snt108-w4738469ded84b4fb7df60ad...@phx.gbl, dated Tue, 27 Nov 2012, Mark Gandler markgand...@hotmail.com writes: I'm not sure how anyone can justify this makes any sense and seems like going against the spirit of RTTE and any other EU Directives, allowing grace period for any requirement to take place. Simple mentioning of something been developed does not substitute a legal recruitment. Agreed; this seems like an erosion of the protection of manufacturers against instant changes. Like other Directives, the RTTE Directive contains no mandatory requirement to apply harmonized standards and carry out tests (except in the case of Full Quality Control). -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
UNLIKE many other Directives, the RTTE Directive REQUIRES the use of a Notified Body where Radio Spectrum Standards are applied in full. Regards Charlie -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 28 November 2012 08:23 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements In message snt108-w4738469ded84b4fb7df60ad...@phx.gblmailto:snt108-w4738469ded84b4fb7df60ad...@phx.gbl, dated Tue, 27 Nov 2012, Mark Gandler markgand...@hotmail.commailto:markgand...@hotmail.com writes: I'm not sure how anyone can justify this makes any sense and seems like going against the spirit of RTTE and any other EU Directives, allowing grace period for any requirement to take place. Simple mentioning of something been developed does not substitute a legal recruitment. Agreed; this seems like an erosion of the protection of manufacturers against instant changes. Like other Directives, the RTTE Directive contains no mandatory requirement to apply harmonized standards and carry out tests (except in the case of Full Quality Control). -- OOO - Own Opinions Only. See www.jmwa.demon.co.ukhttp://www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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.orgmailto: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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald: dhe...@gmail.commailto: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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
I'll write that correctly this time :) UNLIKE many other Directives, the RTTE Directive REQUIRES the use of a Notified Body where Radio Spectrum Standards are NOT applied in full. Harmonised Standards are, in effect, mandatory unless you use a NB - and even then, you can't choose not to apply them because you don't like them From: Charlie Blackham Sent: 28 November 2012 08:47 To: 'John Woodgate'; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements UNLIKE many other Directives, the RTTE Directive REQUIRES the use of a Notified Body where Radio Spectrum Standards are applied in full. Regards Charlie -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 28 November 2012 08:23 To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements In message snt108-w4738469ded84b4fb7df60ad...@phx.gblmailto:snt108-w4738469ded84b4fb7df60ad...@phx.gbl, dated Tue, 27 Nov 2012, Mark Gandler markgand...@hotmail.commailto:markgand...@hotmail.com writes: I'm not sure how anyone can justify this makes any sense and seems like going against the spirit of RTTE and any other EU Directives, allowing grace period for any requirement to take place. Simple mentioning of something been developed does not substitute a legal recruitment. Agreed; this seems like an erosion of the protection of manufacturers against instant changes. Like other Directives, the RTTE Directive contains no mandatory requirement to apply harmonized standards and carry out tests (except in the case of Full Quality Control). -- OOO - Own Opinions Only. See www.jmwa.demon.co.ukhttp://www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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.orgmailto: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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald: dhe...@gmail.commailto: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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
Charlie,current mandatory version is 1.7.1. Future (2015) is 1.8.1. Both harmonized. There is an application note in question which describes additional requirements. Only as of last month this Note became mandatory. Note in OJ from 2009 was simply stating what actual tests been developed in draft 1.8.1. Should the note be treated as any other new version of the standard, allowing grace period? Better question: how does one challenge or ask for official clarification on the matter? Mark From: char...@sulisconsultants.com To: j...@jmwa.demon.co.uk; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements Date: Wed, 28 Nov 2012 08:48:55 + I’ll write that correctly this time J UNLIKE many other Directives, the RTTE Directive REQUIRES the use of a Notified Body where Radio Spectrum Standards are NOT applied in full. Harmonised Standards are, in effect, mandatory unless you use a NB – and even then, you can’t choose not to apply them because you don’t like them From: Charlie Blackham Sent: 28 November 2012 08:47 To: 'John Woodgate'; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements UNLIKE many other Directives, the RTTE Directive REQUIRES the use of a Notified Body where Radio Spectrum Standards are applied in full. Regards Charlie -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 28 November 2012 08:23 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements In message snt108-w4738469ded84b4fb7df60ad...@phx.gbl, dated Tue, 27 Nov 2012, Mark Gandler markgand...@hotmail.com writes: I'm not sure how anyone can justify this makes any sense and seems like going against the spirit of RTTE and any other EU Directives, allowing grace period for any requirement to take place. Simple mentioning of something been developed does not substitute a legal recruitment. Agreed; this seems like an erosion of the protection of manufacturers against instant changes. Like other Directives, the RTTE Directive contains no mandatory requirement to apply harmonized standards and carry out tests (except in the case of Full Quality Control). -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
In message snt108-w48a92b45f82f55a03910b9ad...@phx.gbl, dated Mon, 26 Nov 2012, Mark Gandler markgand...@hotmail.com writes: Bill,being struggling with the same question. 1.8.1 goes in effect only on 1.1.2015, but current 1.7.1 should be used with an adaptivity requirement from 1.8.1.It is very unusual circumstances where the requirement is pretty much dropped out of nowhere and looks like goes in effect immediately.Our test lab posted this question to an alleged author of the below note and his answer was yes, it applies and must be tested. not sure how it all makes sense to etsi authors and RTTE committee. what about currently shipping equipment which been evaluated to 1.7.1 version, but before adaptivity note been posted? It is indeed very unusual for a provision to come into effect without a transition period, and is normally not allowed. If it is allowed, there must be a safety or other over-riding issue to justify it and it must be explained publicly (at least according to many Directives). Were manufacturer experts on the relevant ETSI standards committee unaware of this unusual development? -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
There has been a comment in the OJ regarding requirement for spectrum sharing since December 2009: This version of the standard gives presumption of conformity with the requirements of Article 3(2) of Directive 1999/5/EC under the following condition: The equipment shall implement an adequate spectrum sharing mechanism, e.g. LBT (Listen Before Talk), DAA (Detect And Avoid), etc., in order to comply with the requirement specified in clause 4.3.5 of this version. Such a mechanism shall facilitate sharing between the various technologies and applications which currently exist and in case of congestion, users will be ensured equal access (and as a consequence a graceful degradation of service to all users). Harmonised ways for assessing the efficiency of various sharing mechanisms are currently been developed by ETSI in draft EN 300328 version 1.8.1. V1.8.1 has brought in some additional requirements, but the draft standard has been around for years and the published standard added to the OJ with a 26 month transition period. Regards Charlie -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 27 November 2012 08:42 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements In message snt108-w48a92b45f82f55a03910b9ad...@phx.gblmailto:snt108-w48a92b45f82f55a03910b9ad...@phx.gbl, dated Mon, 26 Nov 2012, Mark Gandler markgand...@hotmail.commailto:markgand...@hotmail.com writes: Bill,being struggling with the same question. 1.8.1 goes in effect only on 1.1.2015, but current 1.7.1 should be used with an adaptivity requirement from 1.8.1.It is very unusual circumstances where the requirement is pretty much dropped out of nowhere and looks like goes in effect immediately.Our test lab posted this question to an alleged author of the below note and his answer was yes, it applies and must be tested. not sure how it all makes sense to etsi authors and RTTE committee. what about currently shipping equipment which been evaluated to 1.7.1 version, but before adaptivity note been posted? It is indeed very unusual for a provision to come into effect without a transition period, and is normally not allowed. If it is allowed, there must be a safety or other over-riding issue to justify it and it must be explained publicly (at least according to many Directives). Were manufacturer experts on the relevant ETSI standards committee unaware of this unusual development? -- OOO - Own Opinions Only. See www.jmwa.demon.co.ukhttp://www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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.orgmailto: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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald: dhe...@gmail.commailto: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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
In message 3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.net, dated Tue, 27 Nov 2012, Charlie Blackham char...@sulisconsultants.com writes: V1.8.1 has brought in some additional requirements, but the draft standard has been around for years Not in the public domain, so that argument can't be used to hold that everyone should have known about it. and the published standard added to the OJ with a 26 month transition period. OK, so there IS a transition period, which the OP seemed to think was not so, but 26 months is odd - should it be 36, which is the normal 3 years? -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
Not in the public domain, so that argument can't be used to hold that everyone should have known about it. The reference has been in public domain for some years, and whilst the ETSI website is not always the easiest thing to navigate, draft standards are available, free of charge. Regards Charlie -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 27 November 2012 12:04 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements In message 3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.netmailto:3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.net, dated Tue, 27 Nov 2012, Charlie Blackham char...@sulisconsultants.commailto:char...@sulisconsultants.com writes: V1.8.1 has brought in some additional requirements, but the draft standard has been around for years Not in the public domain, so that argument can't be used to hold that everyone should have known about it. and the published standard added to the OJ with a 26 month transition period. OK, so there IS a transition period, which the OP seemed to think was not so, but 26 months is odd - should it be 36, which is the normal 3 years? -- OOO - Own Opinions Only. See www.jmwa.demon.co.ukhttp://www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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.orgmailto: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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald: dhe...@gmail.commailto: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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
In message 3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.net, dated Tue, 27 Nov 2012, Charlie Blackham char...@sulisconsultants.com writes: The reference has been in public domain for some years, and whilst the ETSI website is not always the easiest thing to navigate, draft standards are available, free of charge. Even to non-members? I tried to get a draft document and couldn't. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
Hello all, A mandatory requirement to have a Medium Access Protocol has existed in EN 300 328 since V1.7.1, which was published in 2006, first introduced onto the Official Journal sometime soon after that. (the oldest OJ I have on record is 2008 and it's on there). There were a lot of complaints that the section on Medium Access Protocol was not clear enough and people did not know what it meant. Or, they knew what it meant but didn't know how thorough it needed to be. We knew that IEEE 802.11 had it and we knew that Bluetooth hopped away from trouble. Zigbee was listed in the scope of the standard so we all felt happy about IEEE 802.15.4. But what about everything else? Industry called out for a better explanation and more clarification, which is summarised as the text we are discussing below. So, it is simply a clarification of an existing requirement. It's not some sudden new requirement. EN 300 328 V1.8.1 makes it even more clear and removes the requirement for clarifications in the OJ. As a final comment, yes, there are manufacturers involved in the ETSI group for EN 300 328. :-) Thanks, Michael. Michael Derby Regulatory Engineer ACB Europe -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 27 November 2012 13:25 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements In message 3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.net, dated Tue, 27 Nov 2012, Charlie Blackham char...@sulisconsultants.com writes: The reference has been in public domain for some years, and whilst the ETSI website is not always the easiest thing to navigate, draft standards are available, free of charge. Even to non-members? I tried to get a draft document and couldn't. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
In message 0fee01cdcca7$f69c8530$e3d58f90$@acbcert.com, dated Tue, 27 Nov 2012, Michael Derby micha...@acbcert.com writes: As a final comment, yes, there are manufacturers involved in the ETSI group for EN 300 328. :-) I asked when the thread context was that the new requirement (to apply a provision of s not-yet-published edition) had been introduced without a transition period of any sort. Manufacturers would normally object to that very strongly. It now appears that there is a transition period. But manufacturers' representatives on standards committees must *disregard* the advance knowledge that they get from participation when considering the impact of a change to a standard on the industry as a whole, unless they have taken positive steps to inform their industry associations of the new development. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
Please forgive my ignorance, but as am I wrong in assuming that a device designed to operate meeting IEEE 802.11 standards would already meet the requirements for adaptive equipment introduced in the ETSI standard? Bill -Original Message- From: Michael Derby [mailto:micha...@acbcert.com] Sent: Tuesday, November 27, 2012 8:03 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements Hello all, A mandatory requirement to have a Medium Access Protocol has existed in EN 300 328 since V1.7.1, which was published in 2006, first introduced onto the Official Journal sometime soon after that. (the oldest OJ I have on record is 2008 and it's on there). There were a lot of complaints that the section on Medium Access Protocol was not clear enough and people did not know what it meant. Or, they knew what it meant but didn't know how thorough it needed to be. We knew that IEEE 802.11 had it and we knew that Bluetooth hopped away from trouble. Zigbee was listed in the scope of the standard so we all felt happy about IEEE 802.15.4. But what about everything else? Industry called out for a better explanation and more clarification, which is summarised as the text we are discussing below. So, it is simply a clarification of an existing requirement. It's not some sudden new requirement. EN 300 328 V1.8.1 makes it even more clear and removes the requirement for clarifications in the OJ. As a final comment, yes, there are manufacturers involved in the ETSI group for EN 300 328. :-) Thanks, Michael. Michael Derby Regulatory Engineer ACB Europe -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 27 November 2012 13:25 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements In message 3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.net, dated Tue, 27 Nov 2012, Charlie Blackham char...@sulisconsultants.com writes: The reference has been in public domain for some years, and whilst the ETSI website is not always the easiest thing to navigate, draft standards are available, free of charge. Even to non-members? I tried to get a draft document and couldn't. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
Bill,if it would be only logical assessment, then yes, you are correct. But the writers of the aforementioned Note had a different idea and according to their interpretation in order to prove compliance with 1.8.1 you MUST test. Previous 1.7.1 did not address this and Medium Access Protocol was not the same requirement as Adaptivity with defined interference signals and test procedures. below is all what 1.7.1 had on MAP, no test requirements: 4.3.5 Medium access protocol4.3.5.1 DefinitionA medium access protocol is a mechanism designed to facilitate spectrum sharing with other devices in a wirelessnetwork.4.3.5.2 RequirementA medium access protocol shall be implemented by the equipmentMark From: bstu...@dlsemc.com To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements Date: Tue, 27 Nov 2012 19:36:49 + Please forgive my ignorance, but as am I wrong in assuming that a device designed to operate meeting IEEE 802.11 standards would already meet the requirements for adaptive equipment introduced in the ETSI standard? Bill -Original Message- From: Michael Derby [mailto:micha...@acbcert.com] Sent: Tuesday, November 27, 2012 8:03 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements Hello all, A mandatory requirement to have a Medium Access Protocol has existed in EN 300 328 since V1.7.1, which was published in 2006, first introduced onto the Official Journal sometime soon after that. (the oldest OJ I have on record is 2008 and it's on there). There were a lot of complaints that the section on Medium Access Protocol was not clear enough and people did not know what it meant. Or, they knew what it meant but didn't know how thorough it needed to be. We knew that IEEE 802.11 had it and we knew that Bluetooth hopped away from trouble. Zigbee was listed in the scope of the standard so we all felt happy about IEEE 802.15.4. But what about everything else? Industry called out for a better explanation and more clarification, which is summarised as the text we are discussing below. So, it is simply a clarification of an existing requirement. It's not some sudden new requirement. EN 300 328 V1.8.1 makes it even more clear and removes the requirement for clarifications in the OJ. As a final comment, yes, there are manufacturers involved in the ETSI group for EN 300 328. :-) Thanks, Michael. Michael Derby Regulatory Engineer ACB Europe -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 27 November 2012 13:25 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements In message 3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.net, dated Tue, 27 Nov 2012, Charlie Blackham char...@sulisconsultants.com writes: The reference has been in public domain for some years, and whilst the ETSI website is not always the easiest thing to navigate, draft standards are available, free of charge. Even to non-members? I tried to get a draft document and couldn't. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
Charlie,this comment is not the same note as published now under RTTE harmonized section and it did not require testing under 1.8.1 as current Note does. it merely mentioned harmonized ways are been developed in draft 1.8.1. 1.8.1 goes in effect in 2 years, requirement for testing according to 1.8.1 goes in effect immediately. I'm not sure how anyone can justify this makes any sense and seems like going against the spirit of RTTE and any other EU Directives, allowing grace period for any requirement to take place. Simple mentioning of something been developed does not substitute a legal recruitment.Mark From: char...@sulisconsultants.com To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements Date: Tue, 27 Nov 2012 11:36:26 + There has been a comment in the OJ regarding requirement for spectrum sharing since December 2009: This version of the standard gives presumption of conformity with the requirements of Article 3(2) of Directive 1999/5/EC under the following condition: The equipment shall implement an adequate spectrum sharing mechanism, e.g. LBT (Listen Before Talk), DAA (Detect And Avoid), etc., in order to comply with the requirement specified in clause 4.3.5 of this version. Such a mechanism shall facilitate sharing between the various technologies and applications which currently exist and in case of congestion, users will be ensured equal access (and as a consequence a graceful degradation of service to all users). Harmonised ways for assessing the efficiency of various sharing mechanisms are currently been developed by ETSI in draft EN 300328 version 1.8.1. V1.8.1 has brought in some additional requirements, but the draft standard has been around for years and the published standard added to the OJ with a 26 month transition period. Regards Charlie -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 27 November 2012 08:42 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements In message snt108-w48a92b45f82f55a03910b9ad...@phx.gbl, dated Mon, 26 Nov 2012, Mark Gandler markgand...@hotmail.com writes: Bill,being struggling with the same question. 1.8.1 goes in effect only on 1.1.2015, but current 1.7.1 should be used with an adaptivity requirement from 1.8.1.It is very unusual circumstances where the requirement is pretty much dropped out of nowhere and looks like goes in effect immediately.Our test lab posted this question to an alleged author of the below note and his answer was yes, it applies and must be tested. not sure how it all makes sense to etsi authors and RTTE committee. what about currently shipping equipment which been evaluated to 1.7.1 version, but before adaptivity note been posted? It is indeed very unusual for a provision to come into effect without a transition period, and is normally not allowed. If it is allowed, there must be a safety or other over-riding issue to justify it and it must be explained publicly (at least according to many Directives). Were manufacturer experts on the relevant ETSI standards committee unaware of this unusual development? -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org
Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
Bill,being struggling with the same question. 1.8.1 goes in effect only on 1.1.2015, but current 1.7.1 should be used with an adaptivity requirement from 1.8.1.It is very unusual circumstances where the requirement is pretty much dropped out of nowhere and looks like goes in effect immediately.Our test lab posted this question to an alleged author of the below note and his answer was yes, it applies and must be tested. not sure how it all makes sense to etsi authors and RTTE committee. what about currently shipping equipment which been evaluated to 1.7.1 version, but before adaptivity note been posted? Mark EN 300 328 V1.7.1Electromagnetic compatibility and Radio spectrum Matters (ERM); Wideband transmission systems; Data transmission equipment operating in the 2,4 GHz ISM band and using wide band modulation techniques; Harmonized EN covering essential requirements under article 3.2 of the RTTE DirectiveEN 300 328 V1.6.1 Note 2.1 Date expired (30/06/2008) Article 3(2) This version of the standard gives presumption of conformity with the requirements of Article 3(2) of Directive 1999/5/EC under the following condition: The equipment shall implement an adequate spectrum sharing mechanism, e.g. LBT (Listen Before Talk), DAA (Detect And Avoid), etc., in order to comply with the requirement specified in clause 4.3.5 of this version. Such a mechanism shall facilitate sharing between the various technologies and applications which currently exist and in case of congestion, users will be ensured equal access (and as a consequence a graceful degradation of service to all users). The efficiency of the various sharing mechanisms can be assessed using the appropriate clauses of EN 300 328 version 1.8.1.ETSIEN 300 328 V1.8.1 (new)Electromagnetic compatibility and Radio spectrum Matters (ERM); Wideband transmission systems; Data transmission equipment operating in the 2,4 GHz ISM band and using wide band modulation techniques; Harmonized EN covering the essential requirements of article 3.2 of the RTTE DirectiveEN 300 328 V1.7.1 Note 2.1 31/12/2014 Article 3(2) From: bstu...@dlsemc.com To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: EN 300 328 V1.8.1 new Adaptive equipment requirements Date: Mon, 26 Nov 2012 16:08:18 + Hello group, ETSI 300 328 V1.8.1 adds a new set of requirements for adaptive radio equipment. This will certainly put more of a burden on test labs, including additional test equipment needed to generate the “interference signal”. Has anyone reviewed these new requirements that wishes to offer their opinion or guidance? Bill Stumpf D.L.S. Electronic Systems, Inc. 166 South Carter Street Genoa City WI 53128 Ph: 262-279-0210 Email: bstu...@dlsemc.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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
