Re: [PSES] [SPAM?] Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-06 Thread John Woodgate
It may also be significant that the Council of Europe disbanded the 
committee that produced that resolution. Post hoc is not necessarily 
propter hoc, but on the other hand, it often is.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-04-06 16:29, Pete Perkins wrote:


It’s easy to raise questions regarding results derived from data 
without providing the technical detail and the arguments refuting the 
original results.  This technique needs to be rejected outright and 
only pay attention to substantive arguments backed by data; the 
complainer should start the argument with the folks who have published 
their data and work to change their mind; then we will accept the new 
limits announced by INCIRP.


:>) br,  Pete

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

503/452-1201

IEEE Life Fellow

p.perk...@ieee.org <mailto:p.perk...@ieee.org>

*From:*John Woodgate <j...@woodjohn.uk>
*Sent:* Thursday, April 5, 2018 1:25 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] [SPAM?] Re: [PSES] EU Harmonized RF Exposure 
Standards per RED for 13.56 MHz RFID


The Wikipedia page repeats part of the Buss document, which cites no 
figures, not even any verifiable evidence. The resulting Council 
resolution, while recommending ALARA, is overall typically alarmist 
and even anti-science in its approach.  Let us all now don our tinfoil 
hats.


The probity of ICNIRP can be investigated at: 
https://www.icnirp.org/en/about-icnirp/funding-governance/index.html 
It should be noted that IEEE concluded that recommended limits higher 
than those of ICNIRP are acceptable.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK

On 2018-04-05 20:35, gdstuyvenb...@yahoo.com 
<mailto:gdstuyvenb...@yahoo.com> wrote:


Respectfully acknowledged.  However, the following needs to be taken into 
consideration.  With the advent of 5G, this becomes an increasingly urgent 
issue that demands sorting out.  (Alarm klaxons sounding)  SPAM.really?

***

Despite or because of the wide use of ICNIRP guidance, it also encounters criticism. 
The Council of Europe says: "it is most curious, to say the least, that the 
applicable official threshold values for limiting the health impact of extremely low 
frequency electromagnetic fields and high frequency waves were drawn up and proposed to 
international political institutions (WHO, European Commission, governments) by the 
ICNIRP, an NGO whose origin and structure are none too clear and which is furthermore 
suspected of having rather close links with the industries whose expansion is shaped by 
recommendations for maximum threshold values for the different frequencies of 
electromagnetic fields".[3]

See also

     Mobile phone radiation and health

     International Radiation Protection Association - IRPA

References

[1]"Framework for Developing Health-Based EMF Standards" (pdf). World 
Health Organization. Retrieved 7 January 2011.

[2]"WHO - International Organizations". Retrieved 27 October 2012.

[3]Huss, Jean (2011-05-06). "B. Explanatory memorandum by Mr Huss, rapporteur - 
Section 7. Technological progress and economic growth at the expense of environment and 
health protection - Subsection 29". The potential dangers of electromagnetic fields 
and their effect on the environment - Report - Doc. 12608. Council of Europe - 
Parliamentary Assembly - Committee on the Environment, Agriculture and Local and Regional 
Affairs. Retrieved 2013-04-10.


https://en.wikipedia.org/wiki/International_Commission_on_Non-Ionizing_Radiation_Protection

***

Gary Stuyvenberg

Sr. EMC Engineer

Thompson Consulting



On Wed, 4/4/18, John Woodgate<j...@woodjohn.uk> <mailto:j...@woodjohn.uk>  
wrote:

      Subject: Re: [PSES] [SPAM] Re: [PSES] EU Harmonized RF Exposure Standards 
per RED for 13.56 MHz RFID

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

  Date: Wednesday, April 4, 2018, 3:59 PM

  

  


   As is usual with these things, about 20% of the words are justified, the 
rest are not, or vice versa.

   For example, in the first citation, the first 7 words are not justified 
by any peer-reviewed

   research reports, the rest are largely true. In the second citation, the 
first 14 words are

   asserted without proof. In the third citation, the words 'produced by 
EMF exposures'

   and 'of EMFs' are asserted without proof. The sentence without these 
words is claimed

   to be true. In the fourth statement, the words 'reduce the harmful 
effects of EMFs'

   are superfluous; eve

Re: [PSES] [SPAM?] Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-05 Thread John Woodgate
The Wikipedia page repeats part of the Buss document, which cites no 
figures, not even any verifiable evidence. The resulting Council 
resolution, while recommending ALARA, is overalltypically alarmist and 
even anti-science in its approach.  Let us all now don our tinfoil hats.


The probity of ICNIRP can be investigated at: 
https://www.icnirp.org/en/about-icnirp/funding-governance/index.html It 
should be noted that IEEE concluded that recommended limits higher than 
those of ICNIRP are acceptable.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-04-05 20:35, gdstuyvenb...@yahoo.com wrote:

Respectfully acknowledged.  However, the following needs to be taken into 
consideration.  With the advent of 5G, this becomes an increasingly urgent 
issue that demands sorting out.  (Alarm klaxons sounding)  SPAM.really?

***
Despite or because of the wide use of ICNIRP guidance, it also encounters criticism. The 
Council of Europe says: "it is most curious, to say the least, that the applicable 
official threshold values for limiting the health impact of extremely low frequency 
electromagnetic fields and high frequency waves were drawn up and proposed to 
international political institutions (WHO, European Commission, governments) by the 
ICNIRP, an NGO whose origin and structure are none too clear and which is furthermore 
suspected of having rather close links with the industries whose expansion is shaped by 
recommendations for maximum threshold values for the different frequencies of 
electromagnetic fields".[3]

See also
 Mobile phone radiation and health
 International Radiation Protection Association - IRPA

References

[1]"Framework for Developing Health-Based EMF Standards" (pdf). World Health 
Organization. Retrieved 7 January 2011.

[2]"WHO - International Organizations". Retrieved 27 October 2012.

[3]Huss, Jean (2011-05-06). "B. Explanatory memorandum by Mr Huss, rapporteur - 
Section 7. Technological progress and economic growth at the expense of environment and 
health protection - Subsection 29". The potential dangers of electromagnetic fields 
and their effect on the environment - Report - Doc. 12608. Council of Europe - 
Parliamentary Assembly - Committee on the Environment, Agriculture and Local and Regional 
Affairs. Retrieved 2013-04-10.

https://en.wikipedia.org/wiki/International_Commission_on_Non-Ionizing_Radiation_Protection
***

Gary Stuyvenberg
Sr. EMC Engineer
Thompson Consulting



On Wed, 4/4/18, John Woodgate <j...@woodjohn.uk> wrote:

  Subject: Re: [PSES] [SPAM] Re: [PSES] EU Harmonized RF Exposure Standards per 
RED for 13.56 MHz RFID
  To: EMC-PSTC@LISTSERV.IEEE.ORG
  Date: Wednesday, April 4, 2018, 3:59 PM
  
  
   As is usual with these things, about 20% of the words are justified, the rest are not, or vice versa.

   For example, in the first citation, the first 7 words are not justified by 
any peer-reviewed
   research reports, the rest are largely true. In the second citation, the 
first 14 words are
   asserted without proof. In the third citation, the words 'produced by EMF 
exposures'
   and 'of EMFs' are asserted without proof. The sentence without these words 
is claimed
   to be true. In the fourth statement, the words 'reduce the harmful effects 
of EMFs'
   are superfluous; everyone knows that the rest of the sentence is true, 
whether one is
   exposed to EMF or not.
  
   Alternatively, you can believe that the relevant IEEE and ICNIRP research reports are all falsehoods.
  
  John Woodgate

  OOO-Own Opinions Only
  J M Woodgate and Associates www.woodjohn.uk
  Rayleigh, Essex UK



On 2018-04-04 20:41, gdstuyvenb...@yahoo.com wrote:
   
  Re: Exposure Limits
  
  Thought I would post this to the group as it has been the

  subject of debate for many years.  I found it Interesting as
  it gets into the mechanisms at work and symptoms while
  underscoring the importance of our work.
  
  Gary Stuyvenberg

  Sr. EMC Engineer
  Thompson Consulting
  
  
  THE HARMFUL EFFECTS OF ELECTROMAGNETIC FIELDS EXPLAINED
  
  http://articles.mercola.com/sites/articles/archive/2017/09/03/electromagnetic-fields-harmful-effects.aspx
  
  September 03, 2017 • 148,493 views
  
  Story at-a-glance
 
  - Exposure to microwave EMFs, like cellphones, causes massive mitochondrial dysfunction due to

  damage done by free radicals from peroxynitrite that also cause single and 
double stranded breaks in
  your DNA
  
  - Excessive free radicals triggered by low-frequency microwave exposure from cellphones and Wi-Fi

  networks have been linked to chronic diseases such as cardiac arrhythmias, 
anxiety, depression,
  autism, Alzheimer’s and infertility
  
  - Excessive calcium signaling produced by EMF exposures also has important roles in producing

  pat

Re: [PSES] [SPAM?] Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-05 Thread gdstuyvenb...@yahoo.com
Respectfully acknowledged.  However, the following needs to be taken into 
consideration.  With the advent of 5G, this becomes an increasingly urgent 
issue that demands sorting out.  (Alarm klaxons sounding)  SPAM.really? 
 

***
Despite or because of the wide use of ICNIRP guidance, it also encounters 
criticism. The Council of Europe says: "it is most curious, to say the least, 
that the applicable official threshold values for limiting the health impact of 
extremely low frequency electromagnetic fields and high frequency waves were 
drawn up and proposed to international political institutions (WHO, European 
Commission, governments) by the ICNIRP, an NGO whose origin and structure are 
none too clear and which is furthermore suspected of having rather close links 
with the industries whose expansion is shaped by recommendations for maximum 
threshold values for the different frequencies of electromagnetic fields".[3]

See also
Mobile phone radiation and health
International Radiation Protection Association - IRPA

References

[1]"Framework for Developing Health-Based EMF Standards" (pdf). World Health 
Organization. Retrieved 7 January 2011.

[2]"WHO - International Organizations". Retrieved 27 October 2012.

[3]Huss, Jean (2011-05-06). "B. Explanatory memorandum by Mr Huss, rapporteur - 
Section 7. Technological progress and economic growth at the expense of 
environment and health protection - Subsection 29". The potential dangers of 
electromagnetic fields and their effect on the environment - Report - Doc. 
12608. Council of Europe - Parliamentary Assembly - Committee on the 
Environment, Agriculture and Local and Regional Affairs. Retrieved 2013-04-10.

https://en.wikipedia.org/wiki/International_Commission_on_Non-Ionizing_Radiation_Protection
***

Gary Stuyvenberg
Sr. EMC Engineer
Thompson Consulting



On Wed, 4/4/18, John Woodgate <j...@woodjohn.uk> wrote:

 Subject: Re: [PSES] [SPAM] Re: [PSES] EU Harmonized RF Exposure Standards per 
RED for 13.56 MHz RFID
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Date: Wednesday, April 4, 2018, 3:59 PM
 
 
  As is usual with these things, about 20% of the words are justified, the rest 
are not, or vice versa.
  For example, in the first citation, the first 7 words are not justified by 
any peer-reviewed
  research reports, the rest are largely true. In the second citation, the 
first 14 words are
  asserted without proof. In the third citation, the words 'produced by EMF 
exposures' 
  and 'of EMFs' are asserted without proof. The sentence without these words is 
claimed
  to be true. In the fourth statement, the words 'reduce the harmful effects of 
EMFs' 
  are superfluous; everyone knows that the rest of the sentence is true, 
whether one is 
  exposed to EMF or not.
 
  Alternatively, you can believe that the relevant IEEE and ICNIRP research 
reports are all falsehoods.
 
 John Woodgate
 OOO-Own Opinions Only
 J M Woodgate and Associates www.woodjohn.uk
 Rayleigh, Essex UK



On 2018-04-04 20:41, gdstuyvenb...@yahoo.com wrote:
  
 Re: Exposure Limits
 
 Thought I would post this to the group as it has been the
 subject of debate for many years.  I found it Interesting as
 it gets into the mechanisms at work and symptoms while
 underscoring the importance of our work. 
 
 Gary Stuyvenberg
 Sr. EMC Engineer
 Thompson Consulting
 
 
 THE HARMFUL EFFECTS OF ELECTROMAGNETIC FIELDS EXPLAINED
 
 
http://articles.mercola.com/sites/articles/archive/2017/09/03/electromagnetic-fields-harmful-effects.aspx
 
 September 03, 2017 • 148,493 views
 
 Story at-a-glance

 - Exposure to microwave EMFs, like cellphones, causes massive mitochondrial 
dysfunction due to
 damage done by free radicals from peroxynitrite that also cause single and 
double stranded breaks in
 your DNA
 
 - Excessive free radicals triggered by low-frequency microwave exposure from 
cellphones and Wi-Fi
 networks have been linked to chronic diseases such as cardiac arrhythmias, 
anxiety, depression,
 autism, Alzheimer’s and infertility
 
 - Excessive calcium signaling produced by EMF exposures also has important 
roles in producing
 pathophysiological effects of EMFs including each of the effects listed above
 
 - Strategies that may help reduce the harmful effects of EMFs include 
optimizing your magnesium level,
 certain Nrf2-boosting foods, exercise, calorie restriction and strategies that 
boost nitric oxide signaling
 (which acts, in turn, by raising Nrf2)

 -
 
 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 permitte

Re: [PSES] [SPAM] Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-04 Thread John Woodgate
As is usual with these things, about 20% of the words are justified, the 
rest are not, or vice versa. For example, in the first citation, the 
first 7 words are not justified by any peer-reviewed research reports, 
the rest are largely true. In the second citation, the first 14 words 
are asserted without proof. In the third citation, the words 'produced 
by EMF exposures' and 'of EMFs' are asserted without proof. The sentence 
without these words is claimed to be true. In the fourth statement, the 
words 'reduce the harmful effects of EMFs' are superfluous; everyone 
knows that the rest of the sentence is true, whether one is exposed to 
EMF or not.


Alternatively, you can believe that the relevant IEEE and ICNIRP 
research reports are all falsehoods.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-04-04 20:41, gdstuyvenb...@yahoo.com wrote:

Re: Exposure Limits

Thought I would post this to the group as it has been the subject of debate for 
many years.  I found it Interesting as it gets into the mechanisms at work and 
symptoms while underscoring the importance of our work.

Gary Stuyvenberg
Sr. EMC Engineer
Thompson Consulting


THE HARMFUL EFFECTS OF ELECTROMAGNETIC FIELDS EXPLAINED

http://articles.mercola.com/sites/articles/archive/2017/09/03/electromagnetic-fields-harmful-effects.aspx

September 03, 2017 • 148,493 views

Story at-a-glance


Exposure to microwave EMFs, like cellphones, causes massive mitochondrial 
dysfunction due to damage done by free radicals from peroxynitrite that also 
cause single and double stranded breaks in your DNA
Excessive free radicals triggered by low-frequency microwave exposure from 
cellphones and Wi-Fi networks have been linked to chronic diseases such as 
cardiac arrhythmias, anxiety, depression, autism, Alzheimer’s and infertility
Excessive calcium signaling produced by EMF exposures also has important roles 
in producing pathophysiological effects of EMFs including each of the effects 
listed above
Strategies that may help reduce the harmful effects of EMFs include optimizing 
your magnesium level, certain Nrf2-boosting foods, exercise, calorie 
restriction and strategies that boost nitric oxide signaling (which acts, in 
turn, by raising Nrf2)

-

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

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

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
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For help, send mail to the list administrators:
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For policy questions, send mail to:
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-

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

All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
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Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
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Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-04 Thread gdstuyvenb...@yahoo.com
Re: Exposure Limits

Thought I would post this to the group as it has been the subject of debate for 
many years.  I found it Interesting as it gets into the mechanisms at work and 
symptoms while underscoring the importance of our work. 

Gary Stuyvenberg
Sr. EMC Engineer
Thompson Consulting


THE HARMFUL EFFECTS OF ELECTROMAGNETIC FIELDS EXPLAINED

http://articles.mercola.com/sites/articles/archive/2017/09/03/electromagnetic-fields-harmful-effects.aspx

September 03, 2017 • 148,493 views

Story at-a-glance

>Exposure to microwave EMFs, like cellphones, causes massive mitochondrial 
>dysfunction due to damage done by free radicals from peroxynitrite that also 
>cause single and double stranded breaks in your DNA

>Excessive free radicals triggered by low-frequency microwave exposure from 
>cellphones and Wi-Fi networks have been linked to chronic diseases such as 
>cardiac arrhythmias, anxiety, depression, autism, Alzheimer’s and infertility

>Excessive calcium signaling produced by EMF exposures also has important roles 
>in producing pathophysiological effects of EMFs including each of the effects 
>listed above

>Strategies that may help reduce the harmful effects of EMFs include optimizing 
>your magnesium level, certain Nrf2-boosting foods, exercise, calorie 
>restriction and strategies that boost nitric oxide signaling (which acts, in 
>turn, by raising Nrf2)

-

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


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

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

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

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

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


Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-04 Thread Nyffenegger, Dave
So it sounds similar to the MD with respect to the LVD requirements and you 
don’t declare to the LVD.

From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Wednesday, April 04, 2018 12:09 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz 
RFID

OK, the LVD does not apply, but all its provisions apply. Is that pernickety 
enough?



John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-04-04 16:57, Gert Gremmen; ce-test wrote:

The LVD does NOT apply.

For elektrical safety and EMC the RED will use it's proper list of harmonised 
standards.

As says:

Art 1.4

Radio equipment falling within the scope of this Directive shall not be subject 
to Directive 2014/35/EU, except as set out in point (a) of Article 3(1) of this 
Directive.

Art 3.1(a) says :

the protection of health and safety of persons and of domestic animals and the 
protection of property, including the objectives with respect to safety 
requirements set out in Directive 2014/35/EU, but with no voltage limit 
applying;
One cannot legally apply a directive and say at the same time that some part of 
it is not applicable. It's the objectives as set-out in the LV-directive, that 
are an essential requirement to the RED, not the directive itself. I agree that 
such IS somewhat obscurantist wording.

The fact that no standards for electrical safety have been published yet does 
NOT help in good understanding the directives wording, of course.

Gert Gremmen
On 4-4-2018 17:44, John Woodgate wrote:
Yes, well, it's typical obscurantist wording. The LVD DOES apply, but without 
its low-voltage limit. That is what Article 3 1 (a) says, quite explicitly.



John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-04-04 16:33, Charlie Blackham wrote:
The LVD is cited, but the RED is the applicable Directive, as per article Art. 
1.4 of the RED which states



“Radio equipment falling within the scope of this Directive shall not be 
subject to Directive 2014/35/EU (LVD), except as set out in point (a) of 
Article 3(1) of this Directive.”

In due course, all product EMF standards will be harmonised under RED

Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>
Registered in England and Wales, number 05466247

From: John Woodgate <j...@woodjohn.uk><mailto:j...@woodjohn.uk>
Sent: 04 April 2018 16:05
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz 
RFID


Yes, I cited the wrong Directive. Wrong citations are quite common, due to the 
Commission and the SMBs citing the largely meaningless '/nn' numbers 
instead of the titles of the Directives.

. The actual situation is that the Directive concerned is the Low Voltage 
Directive. The involvement of the RED is ONLY Article 3 1 (a), which applies 
the LVD without its  low-voltage limit. Nothing else of the RED is relevant.



John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-04-04 14:51, Michael Derby wrote:
John,

I think the physical agents Directive is concerned with the workplace, not with 
products.

For assessment of RF Exposure risk/safety from products, the RED is indeed the 
correct Directive and it would be covered in Article 3.1a.


Thanks,

Michael.


Michael Derby
Senior Regulatory Engineer
Director
ACB Europe

Certification Resource for the Wireless Industry
Web:   www.acbcert.com<http://www.acbcert.com/>

e-mail:micha...@acbcert.com<mailto:micha...@acbcert.com>
Mobile phone:   (+44) 7939 880829   (UK area code)
Corporate office phone: USA:   (+1) 703 847 4700






From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: 04 April 2018 14:38
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz 
RFID

SECOND RESPONSE

I should have mentioned that exposure standards have nothing to do with RED but 
are relevant to a different Directive:

DIRECTIVE 2013/35/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 26 June 2013
on the minimum health and safety requirements regarding the exposure of workers 
to the risks
arising from physical agents (electromagnetic fields) (20th individual 
Directive within the meaning
of Article 16(1) of Directive 89/391/EEC) and repealing Directive 2004/40/EC




John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-04-04 13:38, Grace Lin wrote:
Dear Members,

Is t

Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-04 Thread Michael Derby
Hello,

 

Actually a safety assessment equivalent to the LVD (but without the lower 
voltage limit) does apply to RED devices, but the LV Directive (LVD) itself 
does not apply to RED equipment.

 

Thanks,

 

Michael.

 

 

From: John Woodgate [mailto:j...@woodjohn.uk] 
Sent: 04 April 2018 16:44
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz 
RFID

 

Yes, well, it's typical obscurantist wording. The LVD DOES apply, but without 
its low-voltage limit. That is what Article 3 1 (a) says, quite explicitly. 




John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2018-04-04 16:33, Charlie Blackham wrote:

The LVD is cited, but the RED is the applicable Directive, as per article Art. 
1.4 of the RED which states

 

“Radio equipment falling within the scope of this Directive shall not be 
subject to Directive 2014/35/EU (LVD), except as set out in point (a) of 
Article 3(1) of this Directive.” 

 

In due course, all product EMF standards will be harmonised under RED

 

Regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:  
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>
 www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: John Woodgate  <mailto:j...@woodjohn.uk> <j...@woodjohn.uk> 
Sent: 04 April 2018 16:05
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz 
RFID

 


Yes, I cited the wrong Directive. Wrong citations are quite common, due to the 
Commission and the SMBs citing the largely meaningless '/nn' numbers 
instead of the titles of the Directives.  

. The actual situation is that the Directive concerned is the Low Voltage 
Directive. The involvement of the RED is ONLY Article 3 1 (a), which applies 
the LVD without its  low-voltage limit. Nothing else of the RED is relevant.




John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2018-04-04 14:51, Michael Derby wrote:

John,

 

I think the physical agents Directive is concerned with the workplace, not with 
products.

 

For assessment of RF Exposure risk/safety from products, the RED is indeed the 
correct Directive and it would be covered in Article 3.1a.

 

 

Thanks,

 

Michael.

 

 

Michael Derby 

Senior Regulatory Engineer 

Director 

ACB Europe 

 

Certification Resource for the Wireless Industry 

Web:   www.acbcert.com <http://www.acbcert.com/>  

  

e-mail: <mailto:micha...@acbcert.com> micha...@acbcert.com 

Mobile phone:   (+44) 7939 880829   (UK area code) 

Corporate office phone: USA:   (+1) 703 847 4700 

 

 

 

 

 

 

From: John Woodgate [mailto:j...@woodjohn.uk] 
Sent: 04 April 2018 14:38
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz 
RFID

 

SECOND RESPONSE

I should have mentioned that exposure standards have nothing to do with RED but 
are relevant to a different Directive:

DIRECTIVE 2013/35/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 26 June 2013 
on the minimum health and safety requirements regarding the exposure of workers 
to the risks
arising from physical agents (electromagnetic fields) (20th individual 
Directive within the meaning
of Article 16(1) of Directive 89/391/EEC) and repealing Directive 2004/40/EC 





John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2018-04-04 13:38, Grace Lin wrote:

Dear Members,

 

Is there any harmonized standards applicable to 13.56 MHz RFID devices?

 

The following four standards are listed in the latest published list standards 
(March 9, 2018).  It seems there is no one applicable to a 13.56 MHz RFID 
device.

 

 

EN 50360:2017 Product standard to demonstrate the compliance of wireless 
communication devices, with the basic restrictions and exposure limit values 
related to human exposure to electromagnetic fields in the frequency range from 
300 MHz to 6 GHz: devices used next to the ear

 

EN 50385:2017 Product standard to demonstrate the compliance of base station 
equipment with radiofrequency electromagnetic field exposure limits (110 MHz — 
100 GHz), when placed on the market

 

EN 50401:2017 Product standard to demonstrate the compliance of base station 
equipment with radiofrequency electromagnetic field exposure limits (110 MHz — 
100 GHz), when put into service

 

EN 50566:2017 Product standard to demonstrate the compliance of wireless 
communication devices with the basic restrictions and exposure limit values 
related to human exposure t

Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-04 Thread John Woodgate
OK, the LVD does not apply, but all its provisions apply. Is that 
pernickety enough?


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-04-04 16:57, Gert Gremmen; ce-test wrote:


The LVD does NOT apply.

For elektrical safety and EMC the RED will use it's proper list of 
harmonised standards.


As says:

Art 1.4

/Radio equipment//falling within//the scope of this Directive//shall 
_*not*_ be subject//to Directive//2014/35/EU,//except as//set out in 
point (a) of Article 3(1) of this Directive. /


Art 3.1(a) says :

/the protection of health//and safety of persons//and of 
domestic//animals//and the protection//of proper//ty, 
including//the//objectives//with respect//to safety requirements//set 
out in Directive//2014/35/EU,//but with no voltage limit applying; /


One cannot legally apply a directive and say at the same time that 
some part of it is not applicable. It's the _objectives as set-out in 
the LV-directive_, that are an essential requirement to the RED, not 
the directive itself. I agree that such IS somewhat obscurantist wording.


The fact that no standards for electrical safety have been published 
yet does NOT help in good understanding the directives wording, of course.


Gert Gremmen
On 4-4-2018 17:44, John Woodgate wrote:
Yes, well, it's typical obscurantist wording. The LVD DOES apply, but 
without its low-voltage limit. That is what Article 3 1 (a) says, 
quite explicitly.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2018-04-04 16:33, Charlie Blackham wrote:


The LVD is cited, but the RED is the applicable Directive, as per 
article Art. 1.4 of the RED which states


“Radio equipment falling within the scope of this Directive shall 
not be subject to Directive 2014/35/EU (LVD), except as set out in 
point (a) of Article 3(1) of this Directive.”


In due course, all product EMF standards will be harmonised under RED

Regards

Charlie

*Charlie Blackham*

*Sulis Consultants Ltd*

*Tel: +44 (0)7946 624317*

*Web: **www.sulisconsultants.com* 
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>


Registered in England and Wales, number 05466247

*From:*John Woodgate <j...@woodjohn.uk>
*Sent:* 04 April 2018 16:05
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] EU Harmonized RF Exposure Standards per RED 
for 13.56 MHz RFID



Yes, I cited the wrong Directive. Wrong citations are quite common, 
due to the Commission and the SMBs citing the largely meaningless 
'/nn' numbers instead of the titles of the Directives.


. The actual situation is that the Directive concerned is the Low 
Voltage Directive. The involvement of the RED is ONLY Article 3 1 
(a), which applies the LVD without its  low-voltage limit. Nothing 
else of the RED is relevant.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK

On 2018-04-04 14:51, Michael Derby wrote:

John,

I think the physical agents Directive is concerned with the
workplace, not with products.

For assessment of RF Exposure risk/safety from products, the RED
is indeed the correct Directive and it would be covered in
Article 3.1a.

Thanks,

Michael.

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

Certification Resource for the Wireless Industry

Web: www.acbcert.com <http://www.acbcert.com/>

e-mail: micha...@acbcert.com <mailto:micha...@acbcert.com>

Mobile phone:   (+44) 7939 880829   (UK area code)

Corporate office phone: USA:   (+1) 703 847 4700

*From:*John Woodgate [mailto:j...@woodjohn.uk]
*Sent:* 04 April 2018 14:38
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
    *Subject:* Re: [PSES] EU Harmonized RF Exposure Standards per
RED for 13.56 MHz RFID

SECOND RESPONSE

I should have mentioned that exposure standards have nothing to
do with RED but are relevant to a different Directive:

DIRECTIVE 2013/35/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 26 June 2013
on the minimum health and safety requirements regarding the
exposure of workers to the risks
arising from physical agents (electromagnetic fields) (20th
individual Directive within the meaning
of Article 16(1) of Directive 89/391/EEC) and repealing
Directive 2004/40/EC


John Woodgate OOO-Own Opinions Only

J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>

Rayleigh, Essex UK

On 2018-04-04 13:38, Grace Lin wrote:

Dear Members,

Is there any harmonized standards applicable to 13.56 MHz
RFID devices?

The following four standards are listed in the latest
published list standards (March 9, 2018).  It seems there is
no

Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-04 Thread Charlie Blackham
From the RED guide, http://ec.europa.eu/docsroom/documents/23321

Relationship between the RED and LVD/EMCD
Radio equipment falling under the scope of the RED are excluded from both the 
Low Voltage Directive (LVD) and Electromagnetic Compatibility Directive (EMCD) 
33:

  *   Art. 1.4 RED: “Radio equipment falling within the scope of this Directive 
shall not be subject to Directive 2014/35/EU (LVD), except as set out in point 
(a) of Article 3(1) of this Directive.”
  *   Art. 2.2(a) EMCD: “This Directive shall not apply to equipment covered by 
Directive 1999/5/EC.”34

Therefore, where RED is applicable to radio equipment, the LVD and EMCD do not 
apply, however the RED refers to the essential requirements of the LVD and EMCD 
(on the essential requirements, see Chapter 3).

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>
Registered in England and Wales, number 05466247

From: John Woodgate <j...@woodjohn.uk>
Sent: 04 April 2018 16:44
To: Charlie Blackham <char...@sulisconsultants.com>; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz 
RFID

Yes, well, it's typical obscurantist wording. The LVD DOES apply, but without 
its low-voltage limit. That is what Article 3 1 (a) says, quite explicitly.



John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-04-04 16:33, Charlie Blackham wrote:
The LVD is cited, but the RED is the applicable Directive, as per article Art. 
1.4 of the RED which states



“Radio equipment falling within the scope of this Directive shall not be 
subject to Directive 2014/35/EU (LVD), except as set out in point (a) of 
Article 3(1) of this Directive.”

In due course, all product EMF standards will be harmonised under RED

Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>
Registered in England and Wales, number 05466247

From: John Woodgate <j...@woodjohn.uk><mailto:j...@woodjohn.uk>
Sent: 04 April 2018 16:05
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz 
RFID


Yes, I cited the wrong Directive. Wrong citations are quite common, due to the 
Commission and the SMBs citing the largely meaningless '/nn' numbers 
instead of the titles of the Directives.

. The actual situation is that the Directive concerned is the Low Voltage 
Directive. The involvement of the RED is ONLY Article 3 1 (a), which applies 
the LVD without its  low-voltage limit. Nothing else of the RED is relevant.



John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-04-04 14:51, Michael Derby wrote:
John,

I think the physical agents Directive is concerned with the workplace, not with 
products.

For assessment of RF Exposure risk/safety from products, the RED is indeed the 
correct Directive and it would be covered in Article 3.1a.


Thanks,

Michael.


Michael Derby
Senior Regulatory Engineer
Director
ACB Europe

Certification Resource for the Wireless Industry
Web:   www.acbcert.com<http://www.acbcert.com/>

e-mail:micha...@acbcert.com<mailto:micha...@acbcert.com>
Mobile phone:   (+44) 7939 880829   (UK area code)
Corporate office phone: USA:   (+1) 703 847 4700






From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: 04 April 2018 14:38
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz 
RFID

SECOND RESPONSE

I should have mentioned that exposure standards have nothing to do with RED but 
are relevant to a different Directive:

DIRECTIVE 2013/35/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 26 June 2013
on the minimum health and safety requirements regarding the exposure of workers 
to the risks
arising from physical agents (electromagnetic fields) (20th individual 
Directive within the meaning
of Article 16(1) of Directive 89/391/EEC) and repealing Directive 2004/40/EC




John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-04-04 13:38, Grace Lin wrote:
Dear Members,

Is there any harmonized standards applicable to 13.56 MHz RFID devices?

The following four standards are listed in the latest published list standards 
(March 9, 2018).  It seems there is no one applicable to a 13.56 MHz RFID 
device.


EN 50360:2017 Product standard to demonstrate the compliance of wireless 
communication de

Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-04 Thread Gert Gremmen; ce-test

The LVD does NOT apply.

For elektrical safety and EMC the RED will use it's proper list of 
harmonised standards.


As says:

Art 1.4

/Radio equipment//falling within//the scope of this Directive//shall 
_*not*_ be subject//to Directive//2014/35/EU,//except as//set out in 
point (a) of Article 3(1) of this Directive. /


Art 3.1(a) says :

/the protection of health//and safety of persons//and of 
domestic//animals//and the protection//of proper//ty, 
including//the//objectives//with respect//to safety requirements//set 
out in Directive//2014/35/EU,//but with no voltage limit applying; /


One cannot legally apply a directive and say at the same time that some 
part of it is not applicable. It's the _objectives as set-out in the 
LV-directive_, that are an essential requirement to the RED, not the 
directive itself. I agree that such IS somewhat obscurantist wording.


The fact that no standards for electrical safety have been published yet 
does NOT help in good understanding the directives wording, of course.


Gert Gremmen
On 4-4-2018 17:44, John Woodgate wrote:
Yes, well, it's typical obscurantist wording. The LVD DOES apply, but 
without its low-voltage limit. That is what Article 3 1 (a) says, 
quite explicitly.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2018-04-04 16:33, Charlie Blackham wrote:


The LVD is cited, but the RED is the applicable Directive, as per 
article Art. 1.4 of the RED which states


“Radio equipment falling within the scope of this Directive shall not 
be subject to Directive 2014/35/EU (LVD), except as set out in point 
(a) of Article 3(1) of this Directive.”


In due course, all product EMF standards will be harmonised under RED

Regards

Charlie

*Charlie Blackham*

*Sulis Consultants Ltd*

*Tel: +44 (0)7946 624317*

*Web: **www.sulisconsultants.com* 
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>


Registered in England and Wales, number 05466247

*From:*John Woodgate <j...@woodjohn.uk>
*Sent:* 04 April 2018 16:05
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] EU Harmonized RF Exposure Standards per RED for 
13.56 MHz RFID



Yes, I cited the wrong Directive. Wrong citations are quite common, 
due to the Commission and the SMBs citing the largely meaningless 
'/nn' numbers instead of the titles of the Directives.


. The actual situation is that the Directive concerned is the Low 
Voltage Directive. The involvement of the RED is ONLY Article 3 1 
(a), which applies the LVD without its low-voltage limit. Nothing 
else of the RED is relevant.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK

On 2018-04-04 14:51, Michael Derby wrote:

John,

I think the physical agents Directive is concerned with the
workplace, not with products.

For assessment of RF Exposure risk/safety from products, the RED
is indeed the correct Directive and it would be covered in
Article 3.1a.

Thanks,

Michael.

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

Certification Resource for the Wireless Industry

Web: www.acbcert.com <http://www.acbcert.com/>

e-mail: micha...@acbcert.com <mailto:micha...@acbcert.com>

Mobile phone:   (+44) 7939 880829   (UK area code)

Corporate office phone: USA:   (+1) 703 847 4700

*From:*John Woodgate [mailto:j...@woodjohn.uk]
*Sent:* 04 April 2018 14:38
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
    *Subject:* Re: [PSES] EU Harmonized RF Exposure Standards per RED
for 13.56 MHz RFID

SECOND RESPONSE

I should have mentioned that exposure standards have nothing to
do with RED but are relevant to a different Directive:

DIRECTIVE 2013/35/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 26 June 2013
on the minimum health and safety requirements regarding the
exposure of workers to the risks
arising from physical agents (electromagnetic fields) (20th
individual Directive within the meaning
of Article 16(1) of Directive 89/391/EEC) and repealing Directive
2004/40/EC


John Woodgate OOO-Own Opinions Only

J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>

Rayleigh, Essex UK

On 2018-04-04 13:38, Grace Lin wrote:

Dear Members,

Is there any harmonized standards applicable to 13.56 MHz
RFID devices?

The following four standards are listed in the latest
published list standards (March 9, 2018).  It seems there is
no one applicable to a 13.56 MHz RFID device.

EN 50360:2017 Product standard to demonstrate the compliance
of wireless communication devices, with the basic
restrictions and exposure limit values related to human

Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-04 Thread John Woodgate
Yes, well, it's typical obscurantist wording. The LVD DOES apply, but 
without its low-voltage limit. That is what Article 3 1 (a) says, quite 
explicitly.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-04-04 16:33, Charlie Blackham wrote:


The LVD is cited, but the RED is the applicable Directive, as per 
article Art. 1.4 of the RED which states


“Radio equipment falling within the scope of this Directive shall not 
be subject to Directive 2014/35/EU (LVD), except as set out in point 
(a) of Article 3(1) of this Directive.”


In due course, all product EMF standards will be harmonised under RED

Regards

Charlie

*Charlie Blackham*

*Sulis Consultants Ltd*

*Tel: +44 (0)7946 624317*

*Web: **www.sulisconsultants.com* 
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>


Registered in England and Wales, number 05466247

*From:*John Woodgate <j...@woodjohn.uk>
*Sent:* 04 April 2018 16:05
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] EU Harmonized RF Exposure Standards per RED for 
13.56 MHz RFID



Yes, I cited the wrong Directive. Wrong citations are quite common, 
due to the Commission and the SMBs citing the largely meaningless 
'/nn' numbers instead of the titles of the Directives.


. The actual situation is that the Directive concerned is the Low 
Voltage Directive. The involvement of the RED is ONLY Article 3 1 (a), 
which applies the LVD without its low-voltage limit. Nothing else of 
the RED is relevant.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK

On 2018-04-04 14:51, Michael Derby wrote:

John,

I think the physical agents Directive is concerned with the
workplace, not with products.

For assessment of RF Exposure risk/safety from products, the RED
is indeed the correct Directive and it would be covered in Article
3.1a.

Thanks,

Michael.

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

Certification Resource for the Wireless Industry

Web: www.acbcert.com <http://www.acbcert.com/>

e-mail: micha...@acbcert.com <mailto:micha...@acbcert.com>

Mobile phone:   (+44) 7939 880829   (UK area code)

Corporate office phone: USA:   (+1) 703 847 4700

*From:*John Woodgate [mailto:j...@woodjohn.uk]
*Sent:* 04 April 2018 14:38
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
    *Subject:* Re: [PSES] EU Harmonized RF Exposure Standards per RED
for 13.56 MHz RFID

SECOND RESPONSE

I should have mentioned that exposure standards have nothing to do
with RED but are relevant to a different Directive:

DIRECTIVE 2013/35/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 26 June 2013
on the minimum health and safety requirements regarding the
exposure of workers to the risks
arising from physical agents (electromagnetic fields) (20th
individual Directive within the meaning
of Article 16(1) of Directive 89/391/EEC) and repealing Directive
2004/40/EC


John Woodgate OOO-Own Opinions Only

J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>

Rayleigh, Essex UK

On 2018-04-04 13:38, Grace Lin wrote:

Dear Members,

Is there any harmonized standards applicable to 13.56 MHz RFID
devices?

The following four standards are listed in the latest
published list standards (March 9, 2018).  It seems there is
no one applicable to a 13.56 MHz RFID device.

EN 50360:2017 Product standard to demonstrate the compliance
of wireless communication devices, with the basic restrictions
and exposure limit values related to human exposure to
electromagnetic fields in the frequency range from 300 MHz to
6 GHz: devices used next to the ear

EN 50385:2017 Product standard to demonstrate the compliance
of base station equipment with radiofrequency electromagnetic
field exposure limits (110 MHz — 100 GHz), when placed on the
market

EN 50401:2017 Product standard to demonstrate the compliance
of base station equipment with radiofrequency electromagnetic
field exposure limits (110 MHz — 100 GHz), when put into service

EN 50566:2017 Product standard to demonstrate the compliance
of wireless communication devices with the basic restrictions
and exposure limit values related to human exposure to
electromagnetic fields in the frequency range from 30 MHz to 6
GHz: hand-held and body mounted devices in close proximity to
the human body

Thank you very much and I look forward to hearing from you.

Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-04 Thread Charlie Blackham
The LVD is cited, but the RED is the applicable Directive, as per article Art. 
1.4 of the RED which states



“Radio equipment falling within the scope of this Directive shall not be 
subject to Directive 2014/35/EU (LVD), except as set out in point (a) of 
Article 3(1) of this Directive.”

In due course, all product EMF standards will be harmonised under RED

Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>
Registered in England and Wales, number 05466247

From: John Woodgate <j...@woodjohn.uk>
Sent: 04 April 2018 16:05
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz 
RFID


Yes, I cited the wrong Directive. Wrong citations are quite common, due to the 
Commission and the SMBs citing the largely meaningless '/nn' numbers 
instead of the titles of the Directives.

. The actual situation is that the Directive concerned is the Low Voltage 
Directive. The involvement of the RED is ONLY Article 3 1 (a), which applies 
the LVD without its  low-voltage limit. Nothing else of the RED is relevant.


John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-04-04 14:51, Michael Derby wrote:
John,

I think the physical agents Directive is concerned with the workplace, not with 
products.

For assessment of RF Exposure risk/safety from products, the RED is indeed the 
correct Directive and it would be covered in Article 3.1a.


Thanks,

Michael.


Michael Derby
Senior Regulatory Engineer
Director
ACB Europe

Certification Resource for the Wireless Industry
Web:   www.acbcert.com<http://www.acbcert.com/>

e-mail:micha...@acbcert.com<mailto:micha...@acbcert.com>
Mobile phone:   (+44) 7939 880829   (UK area code)
Corporate office phone: USA:   (+1) 703 847 4700






From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: 04 April 2018 14:38
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz 
RFID

SECOND RESPONSE

I should have mentioned that exposure standards have nothing to do with RED but 
are relevant to a different Directive:

DIRECTIVE 2013/35/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 26 June 2013
on the minimum health and safety requirements regarding the exposure of workers 
to the risks
arising from physical agents (electromagnetic fields) (20th individual 
Directive within the meaning
of Article 16(1) of Directive 89/391/EEC) and repealing Directive 2004/40/EC



John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-04-04 13:38, Grace Lin wrote:
Dear Members,

Is there any harmonized standards applicable to 13.56 MHz RFID devices?

The following four standards are listed in the latest published list standards 
(March 9, 2018).  It seems there is no one applicable to a 13.56 MHz RFID 
device.


EN 50360:2017 Product standard to demonstrate the compliance of wireless 
communication devices, with the basic restrictions and exposure limit values 
related to human exposure to electromagnetic fields in the frequency range from 
300 MHz to 6 GHz: devices used next to the ear

EN 50385:2017 Product standard to demonstrate the compliance of base station 
equipment with radiofrequency electromagnetic field exposure limits (110 MHz — 
100 GHz), when placed on the market

EN 50401:2017 Product standard to demonstrate the compliance of base station 
equipment with radiofrequency electromagnetic field exposure limits (110 MHz — 
100 GHz), when put into service

EN 50566:2017 Product standard to demonstrate the compliance of wireless 
communication devices with the basic restrictions and exposure limit values 
related to human exposure to electromagnetic fields in the frequency range from 
30 MHz to 6 GHz: hand-held and body mounted devices in close proximity to the 
human body

Thank you very much and I look forward to hearing from you.

Best regards,
Grace Lin
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List ru

Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-04 Thread Gert Gremmen; ce-test
As LVD (2014/35) is not applicable for Radio devices and so RFID, this 
standard is set up to be harmonized


under the RED. Be it as an Electrical Safety Standard under the RED. 
Look at the provided link.



Gert Gremmen


On 4-4-2018 15:37, John Woodgate wrote:

SECOND RESPONSE

I should have mentioned that exposure standards have nothing to do 
with RED but are relevant to a different Directive:


DIRECTIVE 2013/35/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 26 June 2013
on the minimum health and safety requirements regarding the exposure 
of workers to the risks
arising from physical agents (electromagnetic fields) (20th individual 
Directive within the meaning
of Article 16(1) of Directive 89/391/EEC) and repealing Directive 
2004/40/EC

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2018-04-04 13:38, Grace Lin wrote:

Dear Members,

Is there any harmonized standards applicable to 13.56 MHz RFID devices?

The following four standards are listed in the latest published list 
standards (March 9, 2018).  It seems there is no one applicable to a 
13.56 MHz RFID device.



EN 50360:2017 Product standard to demonstrate the compliance of 
wireless communication devices, with the basic restrictions and 
exposure limit values related to human exposure to electromagnetic 
fields in the frequency range from 300 MHz to 6 GHz: devices used 
next to the ear


EN 50385:2017 Product standard to demonstrate the compliance of base 
station equipment with radiofrequency electromagnetic field exposure 
limits (110 MHz — 100 GHz), when placed on the market


EN 50401:2017 Product standard to demonstrate the compliance of base 
station equipment with radiofrequency electromagnetic field exposure 
limits (110 MHz — 100 GHz), when put into service


EN 50566:2017 Product standard to demonstrate the compliance of 
wireless communication devices with the basic restrictions and 
exposure limit values related to human exposure to electromagnetic 
fields in the frequency range from 30 MHz to 6 GHz: hand-held and 
body mounted devices in close proximity to the human body



Thank you very much and I look forward to hearing from you.

Best regards,
Grace Lin
-


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Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-04 Thread John Woodgate


Yes, I cited the wrong Directive. Wrong citations are quite common, due 
to the Commission and the SMBs citing the largely meaningless '/nn' 
numbers instead of the titles of the Directives.


. The actual situation is that the Directive concerned is the Low 
Voltage Directive. The involvement of the RED is ONLY Article 3 1 (a), 
which applies the LVD without its  low-voltage limit. Nothing else of 
the RED is relevant.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-04-04 14:51, Michael Derby wrote:


John,

I think the physical agents Directive is concerned with the workplace, 
not with products.


For assessment of RF Exposure risk/safety from products, the RED is 
indeed the correct Directive and it would be covered in Article 3.1a.


Thanks,

Michael.

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

Certification Resource for the Wireless Industry

Web: www.acbcert.com <http://www.acbcert.com/>

e-mail: micha...@acbcert.com <mailto:micha...@acbcert.com>

Mobile phone:   (+44) 7939 880829   (UK area code)

Corporate office phone: USA:   (+1) 703 847 4700

*From:*John Woodgate [mailto:j...@woodjohn.uk]
*Sent:* 04 April 2018 14:38
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] EU Harmonized RF Exposure Standards per RED for 
13.56 MHz RFID


SECOND RESPONSE

I should have mentioned that exposure standards have nothing to do 
with RED but are relevant to a different Directive:


DIRECTIVE 2013/35/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 26 June 2013
on the minimum health and safety requirements regarding the exposure 
of workers to the risks
arising from physical agents (electromagnetic fields) (20th individual 
Directive within the meaning
of Article 16(1) of Directive 89/391/EEC) and repealing Directive 
2004/40/EC


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK

On 2018-04-04 13:38, Grace Lin wrote:

Dear Members,

Is there any harmonized standards applicable to 13.56 MHz RFID
devices?

The following four standards are listed in the latest published
list standards (March 9, 2018).  It seems there is no one
applicable to a 13.56 MHz RFID device.

EN 50360:2017 Product standard to demonstrate the compliance of
wireless communication devices, with the basic restrictions and
exposure limit values related to human exposure to electromagnetic
fields in the frequency range from 300 MHz to 6 GHz: devices used
next to the ear

EN 50385:2017 Product standard to demonstrate the compliance of
base station equipment with radiofrequency electromagnetic field
exposure limits (110 MHz — 100 GHz), when placed on the market

EN 50401:2017 Product standard to demonstrate the compliance of
base station equipment with radiofrequency electromagnetic field
exposure limits (110 MHz — 100 GHz), when put into service

EN 50566:2017 Product standard to demonstrate the compliance of
wireless communication devices with the basic restrictions and
exposure limit values related to human exposure to electromagnetic
fields in the frequency range from 30 MHz to 6 GHz: hand-held and
body mounted devices in close proximity to the human body

Thank you very much and I look forward to hearing from you.

Best regards,

Grace Lin

-


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Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-04 Thread T.Sato
On Wed, 4 Apr 2018 05:38:41 -0700,
  Grace Lin  wrote:

> Is there any harmonized standards applicable to 13.56 MHz RFID devices?
> 
> The following four standards are listed in the latest published list
> standards (March 9, 2018).  It seems there is no one applicable to a 13.56
> MHz RFID device.

Will EN 50364 applicable to the device?

Although it is not listed under 2014/53/EU yet, EN 50364:2010 is
listed under 2014/35/EU, and it appears EN 50364:2018 is intended
to be harmonized under 2014/35/EU and 2014/53/EU.

EN 50364:2018
Product standard for human exposure to electromagnetic fields from
devices operating in the frequency range 0 Hz to 300 GHz, used in
Electronic Article Surveillance (EAS), Radio Frequency Identification
(RFID) and similar applications

https://www.cenelec.eu/dyn/www/f?p=104:110:1541743784364801FSP_ORG_ID,FSP_PROJECT,FSP_LANG_ID:1258483,62212,25

Regards,
Tom

-- 
Tomonori Sato  
URL: http://t-sato.in.coocan.jp

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Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-04 Thread Michael Derby
John,

 

I think the physical agents Directive is concerned with the workplace, not with 
products.

 

For assessment of RF Exposure risk/safety from products, the RED is indeed the 
correct Directive and it would be covered in Article 3.1a.

 

 

Thanks,

 

Michael.

 

 

Michael Derby 

Senior Regulatory Engineer 

Director 

ACB Europe 

 

Certification Resource for the Wireless Industry 

Web:   www.acbcert.com <http://www.acbcert.com/>  

  

e-mail: <mailto:micha...@acbcert.com> micha...@acbcert.com 

Mobile phone:   (+44) 7939 880829   (UK area code) 

Corporate office phone: USA:   (+1) 703 847 4700 

 

 

 

 

 

 

From: John Woodgate [mailto:j...@woodjohn.uk] 
Sent: 04 April 2018 14:38
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz 
RFID

 

SECOND RESPONSE

I should have mentioned that exposure standards have nothing to do with RED but 
are relevant to a different Directive:

DIRECTIVE 2013/35/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 26 June 2013 
on the minimum health and safety requirements regarding the exposure of workers 
to the risks
arising from physical agents (electromagnetic fields) (20th individual 
Directive within the meaning
of Article 16(1) of Directive 89/391/EEC) and repealing Directive 2004/40/EC 



John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2018-04-04 13:38, Grace Lin wrote:

Dear Members,

 

Is there any harmonized standards applicable to 13.56 MHz RFID devices?

 

The following four standards are listed in the latest published list standards 
(March 9, 2018).  It seems there is no one applicable to a 13.56 MHz RFID 
device.

 

 

EN 50360:2017 Product standard to demonstrate the compliance of wireless 
communication devices, with the basic restrictions and exposure limit values 
related to human exposure to electromagnetic fields in the frequency range from 
300 MHz to 6 GHz: devices used next to the ear

 

EN 50385:2017 Product standard to demonstrate the compliance of base station 
equipment with radiofrequency electromagnetic field exposure limits (110 MHz — 
100 GHz), when placed on the market

 

EN 50401:2017 Product standard to demonstrate the compliance of base station 
equipment with radiofrequency electromagnetic field exposure limits (110 MHz — 
100 GHz), when put into service

 

EN 50566:2017 Product standard to demonstrate the compliance of wireless 
communication devices with the basic restrictions and exposure limit values 
related to human exposure to electromagnetic fields in the frequency range from 
30 MHz to 6 GHz: hand-held and body mounted devices in close proximity to the 
human body

 

Thank you very much and I look forward to hearing from you.

 

Best regards,

Grace Lin

-


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Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-04 Thread John Woodgate

SECOND RESPONSE

I should have mentioned that exposure standards have nothing to do with 
RED but are relevant to a different Directive:


DIRECTIVE 2013/35/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 26 June 2013
on the minimum health and safety requirements regarding the exposure of 
workers to the risks
arising from physical agents (electromagnetic fields) (20th individual 
Directive within the meaning
of Article 16(1) of Directive 89/391/EEC) and repealing Directive 
2004/40/EC


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-04-04 13:38, Grace Lin wrote:

Dear Members,

Is there any harmonized standards applicable to 13.56 MHz RFID devices?

The following four standards are listed in the latest published list 
standards (March 9, 2018).  It seems there is no one applicable to a 
13.56 MHz RFID device.



EN 50360:2017 Product standard to demonstrate the compliance of 
wireless communication devices, with the basic restrictions and 
exposure limit values related to human exposure to electromagnetic 
fields in the frequency range from 300 MHz to 6 GHz: devices used next 
to the ear


EN 50385:2017 Product standard to demonstrate the compliance of base 
station equipment with radiofrequency electromagnetic field exposure 
limits (110 MHz — 100 GHz), when placed on the market


EN 50401:2017 Product standard to demonstrate the compliance of base 
station equipment with radiofrequency electromagnetic field exposure 
limits (110 MHz — 100 GHz), when put into service


EN 50566:2017 Product standard to demonstrate the compliance of 
wireless communication devices with the basic restrictions and 
exposure limit values related to human exposure to electromagnetic 
fields in the frequency range from 30 MHz to 6 GHz: hand-held and body 
mounted devices in close proximity to the human body



Thank you very much and I look forward to hearing from you.

Best regards,
Grace Lin
-


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emc-pstc discussion list. To post a message to the list, send your 
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Re: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

2018-04-04 Thread Charlie Blackham
Grace

Assuming the device is not transmitting with 100% duty cycle, it is very likely 
to meet requirements for low power devices, so the appropriate standard would 
be EN 50663:2017

This is not yet harmonised under the RED, but Harmonised Standards are not 
mandatory for article 3.1a

Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com
Registered in England and Wales, number 05466247

From: Grace Lin 
Sent: 04 April 2018 13:39
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU Harmonized RF Exposure Standards per RED for 13.56 MHz RFID

Dear Members,

Is there any harmonized standards applicable to 13.56 MHz RFID devices?

The following four standards are listed in the latest published list standards 
(March 9, 2018).  It seems there is no one applicable to a 13.56 MHz RFID 
device.


EN 50360:2017 Product standard to demonstrate the compliance of wireless 
communication devices, with the basic restrictions and exposure limit values 
related to human exposure to electromagnetic fields in the frequency range from 
300 MHz to 6 GHz: devices used next to the ear

EN 50385:2017 Product standard to demonstrate the compliance of base station 
equipment with radiofrequency electromagnetic field exposure limits (110 MHz — 
100 GHz), when placed on the market

EN 50401:2017 Product standard to demonstrate the compliance of base station 
equipment with radiofrequency electromagnetic field exposure limits (110 MHz — 
100 GHz), when put into service

EN 50566:2017 Product standard to demonstrate the compliance of wireless 
communication devices with the basic restrictions and exposure limit values 
related to human exposure to electromagnetic fields in the frequency range from 
30 MHz to 6 GHz: hand-held and body mounted devices in close proximity to the 
human body

Thank you very much and I look forward to hearing from you.

Best regards,
Grace Lin
-


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discussion list. To post a message to the list, send your e-mail to 
>

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