Re: [PSES] CE Marking Provoqium

[Dward]

Let's not confuse a CFR with law. While a Code of Federal Regulations may be
backed up by a law, they are in themselves not law.
It is like CFR 47 for telecom.  The only teeth it has is contained in the
telecommuncations act of 1934 updated in 1999. Outside this law, the CFR has
no teeth whatsoever.
Also, let's remember that OSHA is the OCCUPATIONAL Safety and Health
Administration formed by the OSHA act of 1970 and as such ONLY has
regulatory power as it pertains to the work environment. And while the OSHA
act of 1970 is law, CFR29 is not.  It has no authority to do more.

Thanks 

-Original Message-
From: Brian Oconnell [mailto:oconne...@tamuracorp.com] 
Sent: Friday, August 17, 2012 4:39 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE Marking Provoqium

The assertions were In the USA, I think there is no law requiring safety
approval.
But local AHJ's, authorities having jurisdiction, and insurance providers,
etc. can require as a business item, that devices are 'approved'
That 'requirement' won't change because it is not regulated by the
government.

My reply was simply 29 CFR 1910. While local AHJs may or may not require
certification for equipment and materials in both residential and
commercial, the federal code is a statute; it is not policy. There is are
federal 'laws' that require safety certification for equipment used on
commercial sites. And the federal laws indicate that while local authorities
can pass policy or code to regulate safety of equipment, the requirements of
local code for the workplace must at least meet federal law.

I have had this problem with each new manager or executive - There is no
law requiring any of this.

Ok, we will just sell this 500kVA, 477V transformer for use in private homes
only...

Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Peter Tarver
Sent: Friday, August 17, 2012 4:17 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] CE Marking Provoqium

which only applies to the work place.

 From: Brian Oconnell [mailto:oconne...@tamuracorp.com]
 Sent: Friday, August 17, 2012 16:09

 29 CFR 1910


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Re: [PSES] ANSI C63.4:2009 1GHz Testing

[Dward]

Under ANSI C63.4 2009 you are to test with the absorbers above 1GHz, but if
the lab uses ANSI C63.4 2003 you CANNOT use the absorbers.  Under ANSI
C63.4:2009 the minimum attenuation for the absorbers must be 20dB and cover
a  2.4 m by 2.4 m square.

 

Thanks 

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: emcp...@aol.com [mailto:emcp...@aol.com] 
Sent: Friday, September 07, 2012 3:21 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] ANSI C63.4:2009 1GHz Testing

 

Hello,

 

I have a question regarding ANSI C63.4 1GHz testing setup with absorbers
compliant to CISPR 16-1-4:2007.

 

The test lab I use has absorbers on the ground plane meeting the CISPR
16-1-4:2007 VSWR requirement up to 6GHz. ANSI says absorbers are acceptable
above 1GHz as long as the setup is meeting the CISPR 16-1-4 requirements.
Does this mean I can run an FCC test from 1-40GHz with these absorbers in
place?

 

Thanks,

Tim

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Re: [PSES] ANSI C63.4:2009 1GHz Testing

[Dward]

Hi Tim

Correct, ANSI C63.4:2009 uses the absorbers from 1 to 40 GHz per section 5.5
of C63.4:2009

Thanks 

 

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
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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: emcp...@aol.com [mailto:emcp...@aol.com] 
Sent: Friday, September 07, 2012 4:00 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] ANSI C63.4:2009 1GHz Testing

 

Hi Dennis,

 

Does this mean I can use absorbers up to 40GHz following ANSI C63.4:2009?

 

Thanks,

Tim

 

In a message dated 9/7/2012 3:46:16 P.M. Pacific Daylight Time,
dw...@pctestlab.com writes:

Under ANSI C63.4 2009 you are to test with the absorbers above 1GHz, but if
the lab uses ANSI C63.4 2003 you CANNOT use the absorbers.  Under ANSI
C63.4:2009 the minimum attenuation for the absorbers must be 20dB and cover
a  2.4 m by 2.4 m square.

 

Thanks 

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: emcp...@aol.com [mailto:emcp...@aol.com] 
Sent: Friday, September 07, 2012 3:21 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] ANSI C63.4:2009 1GHz Testing

 

Hello,

 

I have a question regarding ANSI C63.4 1GHz testing setup with absorbers
compliant to CISPR 16-1-4:2007.

 

The test lab I use has absorbers on the ground plane meeting the CISPR
16-1-4:2007 VSWR requirement up to 6GHz. ANSI says absorbers are acceptable
above 1GHz as long as the setup is meeting the CISPR 16-1-4 requirements.
Does this mean I can run an FCC test from 1-40GHz with these absorbers in
place?

 

Thanks,

Tim

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For 

Re: [PSES] OATS vs FAR Radiated Emissions Limits

[Dward]

Yes TASO is correct.

TASO 3 is a picture that has noise (snow) that is present but not
objectionable.

 

Dennis Ward

Senior Certification Engineer

PCTEST

This communication and its attachments contain information from PCTEST
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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: Thomas Cokenias [mailto:t...@tncokenias.org] 
Sent: Wednesday, October 17, 2012 10:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] OATS vs FAR Radiated Emissions Limits

 

When I worked at FCC I remember being told the interference limits were such
that a TASO Grade 3 quality picture would be maintained as a minimum.  Not
sure if TASO is the right acronym but it's correct phonetically...

 

On Oct 17, 2012, at 9:45 AM, Ken Javor wrote:





What is arbitrary and capricious about setting EMI limits just below a level
that provides a minimum quality standard?
  
Ken Javor
Phone: (256) 650-5261



  _  

From: Bill Owsley wdows...@yahoo.com
Reply-To: Bill Owsley wdows...@yahoo.com
Date: Wed, 17 Oct 2012 09:39:13 -0700 (PDT)
To: John Woodgate j...@jmwa.demon.co.uk, EMC-PSTC@LISTSERV.IEEE.ORG
EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] OATS vs FAR Radiated Emissions Limits

Way back in the old days, so goes the tale as it was told to me, for the
FCC,broadcast receivers were determined to have a certain level of
sensitivity for reliable reception of the intended broadcast.  So Limits
were set capriciously and arbitrarily just below that sensitivity level.
Measuring distance was determined in a similar fashion, 3 meters being the
home environment, and 10 meters being the work or non-home environment.  I
vaguely recall a 30 meter distance.  All this are tales of the dark side
when there were only OATS and testing was all day long in the blistering
summer sun, or all night while feeding mosquito's.

The automotive industry declined to play along and took care of themselves,
as did the military, and the airlines, 
And they do have some near field testing and get to use comfortable test
environments like indoors for a large portion.

We got so envious of those comfortable conditions, we ginned up a fine story
about ambients interfering with our tests, and weather interfering with test
time, etc.  that we got to build a 3 meter chamber, the first one recognized
by the FCC as an alternative to the OATS.



  
 
 
  

  _  

 From: John Woodgate j...@jmwa.demon.co.uk
 To: EMC-PSTC@LISTSERV.IEEE.ORG 
 Sent: Wednesday, October 17, 2012 8:45 AM
 Subject: Re: [PSES] OATS vs FAR Radiated Emissions Limits
  
 
In message
of583e7385.c0c56cf9-on86257a9a.0040152b-86257a9a.00418...@mmm.com, dated
Wed, 17 Oct 2012, rehel...@mmm.com writes:

 And has any of this OATS, SAR, FAR, and TEM cell data differences been
correlated to actual interference problems? Is the EMC industry crying
wolf?

The only practicable way to check is to look at the number of complaints of
interference, but many countries now don't collect them, and the number of
interference cases probably exceeds the number of complaints by a large
factor.

It is certain that if any manufacturer or industry association heard any
alarmist cries, representations would be made for speedy changes.
 
 Limits and test methods should be based in reality. They should not be
academic exercises. For example, much of the world's products are in the
near-field of each other (cockpits, OR, control rooms, etc.). Why aren't
there near field test procedures? Yes, I know the problems but those are
just excuses. Methods need to be developed (and alas, I'm not smart enough).

The problems are not excuses, any more than an inability to develop
anti-gravity is an excuse. Ye canna change the laws o'physics, Cap'n!
Near-field measurements are horribly non-repeatable and, in almost all
cases, cannot be relied on in a regulatory context.
-- OOO - Own Opinions Only. See www.jmwa.demon.co.uk
http://www.jmwa.demon.co.uk/ http://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

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Instructions:  

Re: [PSES] OATS vs FAR Radiated Emissions Limits

[Dward]

Today we have computers, transmitters and receivers that do not interfere to
much with other devices.  But none of that would be possible if it weren't
for the work of what far too many today see as 'capricious and arbitrary'.
So soon the makers of things forget why things were done, why limits were
made and why regulations were needed to be enforced.  The work of many
'great minds' in the early days of EMC are too easily brushed off, not
because they were arbitrary or capricious, but because the work they founded
allowed industry to make products that actually could comply with
interference requirements, could be made cheaper and less power hungry so I
could work on my computer or talk on my Ham while my neighbor watched his
TV.

 

A lot is owed to these men of science and we all too often dis their work
and forget their contributions calling it capricious and arbitrary.

 

OK off my soap box.

 

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: Pettit, Ghery [mailto:ghery.pet...@intel.com] 
Sent: Wednesday, October 17, 2012 9:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] OATS vs FAR Radiated Emissions Limits

 

The 30 meter limits existed in a German standard and Edition 1 of CISPR 22.
Edition 2 made Class A and Class B limits at the same distance, 10 meters.

 

The limits were not capricious nor arbitrary, they were set based on a
fairly large amount of work by industry participants.   CBEMA ESC-5 (now ITI
TC5) published a large document detailing the studies.  The FCC used this
document.  And, why did we have the limits?  Because early home computers
were LOUD and interfered with everything.  The limits we have today fixed
the problem.

 

Ghery S. Pettit

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ken Javor
Sent: Wednesday, October 17, 2012 9:45 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] OATS vs FAR Radiated Emissions Limits

 

What is arbitrary and capricious about setting EMI limits just below a level
that provides a minimum quality standard?
  
Ken Javor
Phone: (256) 650-5261

  _  

From: Bill Owsley wdows...@yahoo.com
Reply-To: Bill Owsley wdows...@yahoo.com
Date: Wed, 17 Oct 2012 09:39:13 -0700 (PDT)
To: John Woodgate j...@jmwa.demon.co.uk, EMC-PSTC@LISTSERV.IEEE.ORG
EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] OATS vs FAR Radiated Emissions Limits

Way back in the old days, so goes the tale as it was told to me, for the
FCC,broadcast receivers were determined to have a certain level of
sensitivity for reliable reception of the intended broadcast.  So Limits
were set capriciously and arbitrarily just below that sensitivity level.
Measuring distance was determined in a similar fashion, 3 meters being the
home environment, and 10 meters being the work or non-home environment.  I
vaguely recall a 30 meter distance.  All this are tales of the dark side
when there were only OATS and testing was all day long in the blistering
summer sun, or all night while feeding mosquito's.

The automotive industry declined to play along and took care of themselves,
as did the military, and the airlines, 
And they do have some near field testing and get to use comfortable test
environments like indoors for a large portion.

We got so envious of those comfortable conditions, we ginned up a fine story
about ambients interfering with our tests, and weather interfering with test
time, etc.  that we got to build a 3 meter chamber, the first one recognized
by the FCC as an alternative to the OATS.



  
 
 
  

  _  

 From: John Woodgate j...@jmwa.demon.co.uk
 To: EMC-PSTC@LISTSERV.IEEE.ORG 
 Sent: Wednesday, October 17, 2012 8:45 AM
 Subject: Re: [PSES] OATS vs FAR Radiated Emissions Limits
  
 
In message
of583e7385.c0c56cf9-on86257a9a.0040152b-86257a9a.00418...@mmm.com, dated
Wed, 17 Oct 2012, rehel...@mmm.com writes:

 And has any of this OATS, SAR, FAR, and TEM cell data differences been
correlated to actual interference problems? Is the EMC industry crying
wolf?

The only practicable way to check is to look at the number of complaints of
interference, but many countries now don't collect them, and the number of
interference cases probably exceeds the number of complaints by a large
factor.

It is certain that if any manufacturer or industry association heard any
alarmist cries, representations would be made for speedy changes.
 
 Limits and test methods should be based in reality. They should not be
academic exercises. For example, much of the world's products are in the

Re: [PSES] Possible Counterfeit EMC Components?

[Dward]

Sounds like you have found 'yellow paint in butter'.  Just the note that the
component came the 'far east' send shivers up the spine.

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.  

-Original Message-
From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: Tuesday, October 30, 2012 1:42 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Possible Counterfeit EMC Components?

I recently preformed a safety evaluation of a product made in the far east
which contained a suspicious looking rf line filter. Instead of the nice
silkscreened markings showing the company name, numbers and a schematic of
the filter components, it just had a basic printed label. When I removed the
filter and turned it over I found that the case was not soldered but just
spot welded in four spots.

Are line filter companies cutting corners to save money or might this filter
be a counterfeit?

The filter manufacturer's website doesn't show this model filter (anymore?)
but you can buy them from several online electronic component companies.

Has anyone run across counterfeit components and is this something we need
to keep an eye out for? My biggest concern is with safety certified
components which smaller companies like ours have to purchase through
distributors who get them from who knows where.

Is this a real concern or am I just being paranoid?

Thanks,
The Other Brian




LECO Corporation Notice: This communication may contain confidential
information intended for the named recipient(s) only. If you received this
by mistake, please destroy it and notify us of the error. Thank you.

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Re: [PSES] Testing EUT

[Dward]

You mean to them there those ones what aint got no gud englitch

 

 

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: Robert Heller [mailto:rehel...@mmm.com] 
Sent: Thursday, November 15, 2012 3:42 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Testing EUT

 

Actually that helps a lot of native speakers too.:) 

Bob Heller
3M EMC Laboratory, 76-1-01
St. Paul, MN 55107-1208
Tel: 651-778-6336
Fax: 651-778-6252
=




From:Monrad Monsen monrad.mon...@oracle.com 
To:g.grem...@cetest.nl, EMC-PSTC@LISTSERV.IEEE.ORG 
Date:11/14/2012 08:04 PM 
Subject:Re: [PSES] Testing EUT 
Sent by:emc-p...@ieee.org 

  _  




For non-native speakers, please note that the Anthony Thomson statement 
about exorcise and John Woodgate's subsequent comment is purely a joke 
and not to be considered a real answer.

Please do not use Exercision / Exercition at all in your writing for 
English.  It won't be understood.  The words Exercise / Exercising / 
Exercised should be used based on the tense in which the sentence is 
written.

Examples include the below:
We used a PC running DataDriver software (Revision 4.0) to exercise the EUT.
We exercised the EUT using a PC running DataDriver software (Revision 4.0).
DataDriver software (Revision 4.0) running on a support PC exercised all 
modes of the EUT throughout the testing.

Alternate forms using synonyms would be:
The support PC running DataDriver software (Revision 4.0) ran the EUT 
through continuous write/read/compare routines throughout testing.

Please note that I give a lot of leeway for English grammar and spelling 
errors when reviewing reports.  Some mistakes are made by native English 
speakers.  We know what you are trying to express in your reports, so a 
grammar mistake is ignored as long as you do provide the critical 
information (margin from the emissions limits, how was the product setup 
and run during testing, date of test, etc.).

Hope this helps.

Monrad



On 11/1/2012 4:00 AM, John Woodgate wrote:
 In message 20121101090042.6...@gmx.com, dated Thu, 1 Nov 2012, 
 Anthony Thomson ton...@europe.com writes:

 If it is passing, or the test result is yet unknown, you will 
 exercise the EUT. If it is not passing, then you will need to 
 exorcise the EUT.

 By cutting out any EXOR gates?

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discussion list. To post a message to the 

Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Dward]

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.

 

 

 

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Re: [PSES] Boeing engineers use spuds to improve in-air Wi-Fi

[Dward]

Maybe they can substitute potatoes for SAR solutions. If the potato bakes,
then the power is too high and the device fails:)

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.  

-Original Message-
From: Pat Lawler [mailto:plawl...@gmail.com] 
Sent: Tuesday, December 25, 2012 10:17 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Boeing engineers use spuds to improve in-air Wi-Fi

In case you missed this article:
Sacks of potatoes stand in for passengers as Boeing engineers work to
improve on-board wireless
http://news.yahoo.com/boeing-engineers-spuds-improve-air-220847344.html

The article said Boeing has been doing 'potato substitution testing'
since 2006.  I'm surprised I hadn't heard about it until now.

Gives the kid's toy 'Mr. Potato Head' a whole new meaning!

Pat Lawler
Engineer
Century Electronics

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Re: [PSES] FCC IC and Product Information

[Dward]

Sorry Ron but your information is quite outdated.

It should not be assumed that Canada is a slam dunk for confidentiality or
that all documents can be held confidential.  While it is true that Canada
(IC) does not go out of its way to make documents available, Canada does
have a right to access law, and Canadians can request documents that do not
have confidentiality requested by the manufacturer.

Also, due to this Right to know law, Canada, at least recently, has
refused to accept confidentiality to test reports, user manuals, internal
and external photos. They allow confidentiality for block diagrams,
schematics, operational descriptions, parts lists and tune up procedures.
Canada also does NOT have a temporary confidentiality system.

 

A Canadian confidentiality request can contain items such as manuals and
internal photos, but before this is granted, IC must be contacted directly
on a case by case basis.  The days of everything confidential in Canada is
over. 

Thanks 

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: Ron Pickard RPQ [mailto:rpick...@rpqconsulting.com] 
Sent: Friday, February 01, 2013 9:13 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC  IC and Product Information

 

Previous contributors have given good information and I've had no experience
in which a TCB or the FCC have charged extra for a confidentiality request.

 

Here in the USA, details of what can/cannot be held confidential and under
what conditions are generally found in FCC Part 0 (0.457-0.459 I believe).
Also refer to Public Notice DA 04-1705 and the FCC's marketing regulations
found in FCC Part 2.803 for further guidance.

 

In Canada, requests for 100% confidentiality are usually granted by Industry
Canada (mostly because they don't make any documents available on their REL
listings page anyway).

 

IHTH.

 

I look forward to your reply.

 

Best regards,

 

Ron Pickard

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Michael
Derby
Sent: Thursday, January 31, 2013 7:43 AM
To: 'itl-emc user group'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] FCC  IC and Product Information

 

Hello,

 

You cannot get confidentiality or even short term confidentiality on a test
report.   You can't keep the results private, sorry.

 

David is correct in his summary below.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: itl-emc user group [mailto:itl...@itl.co.il] 
Sent: 30 January 2013 05:15
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC  IC and Product Information

 

In my experience, TCB's don't charge extra for confidentiality unlike the
FCC.

I have not heard of short term confidentiality for a test report.

Internal photos can be kept confidential only under certain circumstances
such as the device being filled and sealed with epoxy. Permanent
confidentiality request for schematics, block diagram and parts list is
given without any problem. 

 

Regards,

David Shidlowsky | Technical Writer

Address 1 Bat-Sheva St. POB 87, LOD 71100 Israel

Tel 972-8-9186113 Fax 972-8-9153101

Mail e...@itl.co.il/dav...@itl.co.il  Web  http://www.itl.co.il/
www.itl.co.il

 

 http://app.sqm.co.il/SitePages/Questionnaire.aspx Fill out Customer
Satisfaction Survey

Global Certifications You Can Trust 

 

 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Mark Gandler
Sent: Tuesday, January 29, 2013 9:50 PM
To: emc-pstc@listserv.ieee.org
Subject: RE: [PSES] FCC  IC and Product Information

 

You can submit 180 days Short term request for confidentiality pretty much
on most of the  information (phots, manuals, test setup) and later on ask
for 90 days extension.

The longer the request higher the fee

 

There is also an option for permanent confidentiality request on some of the
more critical info: block diagram, schematics. There is also a fee for that.


 

Mark

  _  

From: edpr...@cox.net
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] FCC  IC and Product Information
Date: Mon, 28 Jan 2013 21:27:46 -0800

Bill:

 

Wow, I never knew about this source. This will keep me up all night!

 

Ed Price

WB6WSN

Chula Vista, CA  USA

 

From: Bill Owsley [mailto:wdows...@yahoo.com] 
Sent: Monday, January 28, 2013 8:40 PM
To: Ed Price
Subject: Re: [PSES] FCC  IC and Product Information

 

http://transition.fcc.gov/oet/ea/fccid/
and explore from there...

 


  _  


From: Ed Price edpr...@cox.net
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Sent: Monday, January 28, 2013 

Re: [PSES] EU Group

[Dward]

Oh wait, wasn't that the moon that blew up - I think they still had to move

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.  Usage of PCTEST email addresses for
non-business related activities is strictly prohibited. No warranty is made
that the e-mail or attachment(s) are free from computer virus or other
defect.  Thank you.


-Original Message-
From: Dward [mailto:dw...@pctestlab.com] 
Sent: Friday, March 08, 2013 1:02 PM
To: 'Tom Smith'; 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: RE: [PSES] EU Group

Kronos blew up, they had to move

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.  Usage of PCTEST email addresses for
non-business related activities is strictly prohibited. No warranty is made
that the e-mail or attachment(s) are free from computer virus or other
defect.  Thank you.

-Original Message-
From: Tom Smith [mailto:tsm...@tjstechnical.com]
Sent: Friday, March 08, 2013 11:36 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU Group

Maybe Klingon should have been KR for Kronos, their home planet.

Regards,
Tom Smith, P.Eng 

Principal Engineer
TJS Technical Services Inc.
Tel: +1 403-612-6664
Email: tsm...@tjstechnical.com
http://tjstechnical.com
Follow us on Twitter: TJS_Technical

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Brian
Oconnell
Sent: March-08-13 12:19 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: EU Group

My 'typical' CBTR, for the most recent ITE TRF, uses the term EU Group
Differences and EU Special National Conditions and/or National
Differences, followed by country codes, and code explanations.

I once had a report rejected because it used 'KL' for Klingon national
difference. One would think that CABs would be more open to additional test
conditions...

Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of John Woodgate
Sent: Friday, March 08, 2013 10:12 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: EU Group

In message
cajq2vagqy+a3r7qmjczs0qoe6+ywevna6hx6hucqipp2mt7...@mail.gmail.com,
dated Fri, 8 Mar 2013, Grace Lin graceli...@gmail.com writes:

Is EU Group an international recognized term?

No.
 I reviewed a CB report with EU Group listed.

Ask for a definition of 'EU group' to be added to the report.

 I requested to have each individual country listed.  The reply was 
additional USD400 charge.  I cannot be convinced for the charge.
 
It sounds totally unsupportable. Can anybody ask IECEE (which runs the CB
Scheme) about it?
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR!
Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M
Woodgate and Associates, Rayleigh, Essex UK

-

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-

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Re: [PSES] EU Group

[Dward]

Kronos blew up, they had to move

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.  Usage of PCTEST email addresses for
non-business related activities is strictly prohibited. No warranty is made
that the e-mail or attachment(s) are free from computer virus or other
defect.  Thank you.

-Original Message-
From: Tom Smith [mailto:tsm...@tjstechnical.com] 
Sent: Friday, March 08, 2013 11:36 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU Group

Maybe Klingon should have been KR for Kronos, their home planet.

Regards,
Tom Smith, P.Eng 

Principal Engineer
TJS Technical Services Inc.
Tel: +1 403-612-6664
Email: tsm...@tjstechnical.com
http://tjstechnical.com
Follow us on Twitter: TJS_Technical

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Brian
Oconnell
Sent: March-08-13 12:19 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: EU Group

My 'typical' CBTR, for the most recent ITE TRF, uses the term EU Group
Differences and EU Special National Conditions and/or National
Differences, followed by country codes, and code explanations.

I once had a report rejected because it used 'KL' for Klingon national
difference. One would think that CABs would be more open to additional test
conditions...

Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of John Woodgate
Sent: Friday, March 08, 2013 10:12 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: EU Group

In message
cajq2vagqy+a3r7qmjczs0qoe6+ywevna6hx6hucqipp2mt7...@mail.gmail.com,
dated Fri, 8 Mar 2013, Grace Lin graceli...@gmail.com writes:

Is EU Group an international recognized term?

No.
 I reviewed a CB report with EU Group listed.

Ask for a definition of 'EU group' to be added to the report.

 I requested to have each individual country listed.  The reply was 
additional USD400 charge.  I cannot be convinced for the charge.
 
It sounds totally unsupportable. Can anybody ask IECEE (which runs the CB
Scheme) about it?
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR!
Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M
Woodgate and Associates, Rayleigh, Essex UK

-

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discussion list. To post a message to the list, send your e-mail to
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Attachments are not permitted but the IEEE PSES Online Communities site at
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Instructions:  http://listserv.ieee.org/request/user-guide.html
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For help, send mail to the list administrators:
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-

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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
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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:
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David Heald: dhe...@gmail.com

-

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formats), large files, etc.

Website:  http://www.ieee-pses.org/

Re: [PSES] FCC and very low-power wireless devices

[Dward]

Be careful with the idea that you can do anything on any frequency under
15.209. This simply is not true.  While under 15.209 a perimeter protection
device can operate in the 54-72 MHz and 76-88 MHz bands, no other type
intentional radiator is allowed to have its fundamental in the 54-72 MHz,
76-88 MHz, 174-216 MHz or 470-806 MHz.
Thanks 

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.  Usage of PCTEST email addresses for
non-business related activities is strictly prohibited. No warranty is made
that the e-mail or attachment(s) are free from computer virus or other
defect.  Thank you.


-Original Message-
From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com] 
Sent: Thursday, March 14, 2013 7:27 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC and very low-power wireless devices

Can I use any frequency if my transmission level is below the class B limit?


Sincerely, 

Dieter Paasche x7211


-Original Message-
From: Thomas Cokenias [mailto:t...@tncokenias.org]
Sent: March 12, 2013 5:30 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC and very low-power wireless devices

Hi John

Section 15.209 has general requirements for radiated emissions for
intentional radiators (transmitters).  At these frequencies you would be
allowed 200 uV/m at 3m, not much but you aren't allowed higher power until
you get to 902-928 MHz band.

best regards

Tom

On Mar 12, 2013, at 12:28 PM, John Woodgate wrote:

 Does the FCC allow very low power wireless devices (transmitting speech
for assisted hearing for disabled people) to operate on 863 MHz or nearby?
 --
 OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! 
 Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M 
 Woodgate and Associates, Rayleigh, Essex UK
 
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Re: [PSES] Critical component in EMC report

[Dward]

From: Dward [mailto:dw...@pctestlab.com] 
Sent: Wednesday, March 20, 2013 12:53 PM
To: 'Derek Walton'; 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: RE: [PSES] Critical component in EMC report

 

I would have to disagree with you.  I do not know what version you are 
reciting, but 17025 does not contain the statement that the lab cannot give an 
opinion.  Laboratories are accredited to ISO 17025 and 17025 allows opinions.  
And the applicant is in fact looking for an opinion from the lab.  Even the 
statement that the device complies with a particular standard is an opinion.  
An opinion based on the accuracies of a test labs equipment, setup, and any 
objective evidence resulting in testing etc, but still only an opinion.  And, 
while they may be based on objective evidence, opinions are always subjective 
as the originate from a person’s mind and how he/she thinks.

 

From 17025:

Section 4.7 “Service to the customer” - NOTE 2 Customers value the maintenance 
of good communication, advice and guidance in technical matters, and opinions 
and interpretations based on results.

 

Section 5.2.1 – “Personnel”

NOTE 2 The personnel responsible for the opinions and interpretation included 
in test reports should, in addition to the

appropriate qualifications, training, experience and satisfactory knowledge of 
the testing carried out, also have:

 

Section 5.2.4 – 

the responsibilities for reporting opinions and interpretations.

 

Section 5.2.5 

The management shall authorize specific personnel to perform particular types 
of sampling, test

and/or calibration, to issue test reports and calibration certificates, to give 
opinions and interpretations and to

operate particular types of equipment.

 

Section 5.10.3 Test reports  - 

where appropriate and needed, opinions and interpretations (see 5.10.5);

 

Section 5.10.5 “Opinions and interpretations”

When opinions and interpretations are included, the laboratory shall document 
the basis upon which the

opinions and interpretations have been made. 

NOTE 1 Opinions and interpretations should not be confused with inspections and 
product certifications as intended in

ISO/IEC 17020 and ISO/IEC Guide 65

NOTE 2 Opinions and interpretations included in a test report may comprise, but 
not be limited to, the following:

 

In fact, a good report would have to contain an opinion on the pass or fail of 
testing, otherwise, it is not a compliance report, it is just a document 
providing test results.  So, as you see, reports can and do contain opinions.  

 

Thanks 

Dennis Ward

Senior Certification Engineer

PCTEST

This communication and its attachments contain information from PCTEST 
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or attachment(s) are free from computer virus or other defect.  Thank you.

 

From: Derek Walton [mailto:lfresea...@aol.com] 
Sent: Wednesday, March 20, 2013 12:28 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Critical component in EMC report

 

Hi Dennis, 

 

the excerpts are verbatim words from the standard. Nothing inaccurate about it.

 

These were the words stated in the thread:

 

SNIP

Test Reports from independent test laboratories should NEVER, NEVER EVER, 
incorporate subjective opinions. It is your duty to identify the EUT by means 
of serial numbers, h/w  s/w revisions, photographs, objective descriptions, 
declarations of the build from the client etc., and describe the test 
configuration and set-up by means of diagrams, photographs, operating 
instructions etc.

 

In fact, accreditation bodies expressly prohibit independent laboratories from 
expressing opinions.

SNIP

 

I refuted both these and gave the grounds for why both were not true.

 

What the standard and assessing bodies allow has no bearing on the professional 
relationship between lab and client. It can't be interpreted as follow the 
standard unless the lab or client gets upset...

 

Up to $1:50 now ;-)

 

Derek.

-Original Message-
From: Dward  mailto:dw...@pctestlab.com dw...@pctestlab.com
To: 'Anthony Thomson'  mailto:ton...@europe.com ton...@europe.com; EMC-PSTC 
 mailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG
Sent: Wed, Mar 20, 2013 1:32 pm
Subject: RE: [PSES] Critical component in EMC report

Actually, that is not accurate.  While it may be dangerous to the test lab and 
client relationships, depending on the ‘opinion’, test labs can put their 
opinions in their reports.

Section 5.10.5 of ISO17025 states that opinions

Re: [PSES] 3rd party labs due-diligence

[Dward]

Well, unfortunately it is too often that some labs just know how to pass an
audit, but when it comes to testing, they fall very short.

Far too many 'so called' good labs rely on instrumentation and simply do not
question results.  This leads to bad measurements, even though the lab is
supposedly accredited.

 

 

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
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delete it from your computer system.  Usage of PCTEST email addresses for
non-business related activities is strictly prohibited. No warranty is made
that the e-mail or attachment(s) are free from computer virus or other
defect.  Thank you.

 

From: Kevin Robinson [mailto:kevinrobinso...@gmail.com] 
Sent: Friday, August 30, 2013 6:19 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 3rd party labs due-diligence

 

Full disclosure, I used to work at a test lab, and I now work for a
government regulator that audits test labs.

 

In most cases, as Richard said, test labs, except for possibly your small
local labs have accreditations from multiple accreditation bodies, all
auditing to some variant of 17025/17065/Guide 65.  This means that the labs
are subject to audits 12 or more times a year.  Now each audit may not cover
the full scope that the laboratory has, but their core QA systems are
generally being reviewed at each audit, and individual sectors (EMC, Safety,
Performance etc.) are typically audited several times a year .  Their
systems are generally pretty tight, and staff have been trained and audited
enough to make sure that they are following their own top level procedures
for the most part.  If you do audit, you might find a deficiency in
corporate level procedures, but most will be relatively minor, and are
attributed to human error/laziness.

 

I tell people that ask me to visit your lab(s), talk to the engineers and
your account reps.  Ask them about the standards, perhaps pick a few
sections that are confusing to you and ask them to explain them to you.  It
will become very obvious very quickly how knowledgeable they are in the
standards, and if you are new to the world of testing, how well they are
able to take a complex standard and break it down into something that you
can understand.  Take a tour of their facilities.  Try to look past all of
the glitz and focus on the condition of their storage areas and equipment.
If things are neat and orderly, chances are, they will put the same effort
into clearly and properly recording your test results.  Also consider their
corporate culture.  Is the lab focused on customer service, clearly
explaining things to you every step of the way, or are they extremely
efficient and would prefer to just give you a report with little
communication throughout the testing process.  Find a lab that is a good fit
for your personality and your corporate culture.  As far as conducting an
audit, when you have most labs being audited by ANSI, A2LA, IAS, NIST/NVLAP,
FCC, FDA, OSHA/NRTL, Standards Council of Canada, Industry Canada, Verizon,
ATT, EPA, IECEE/CB Scheme and many others, chances are, you will not find
any significant issues, especially if the lab has been with the same
accreditors for many years.

 

Kevin Robinson

 

On Fri, Aug 30, 2013 at 4:39 PM, John Woodgate j...@jmwa.demon.co.uk wrote:

In message
63e38a5b081437478c77651f3d56c64f57f4f...@orsmsx102.amr.corp.intel.com,
dated Fri, 30 Aug 2013, Pettit, Ghery ghery.pet...@intel.com writes:

I've found cases where the documentation was in good shape, indicating that
the assessor understood ISO/IEC 17025, but the test setups were wrong,
indicating that either the assessor didn't understand the EMC standards

 

Quite often, I believe. In some cases, they defy understanding!

 

or the lab went back to the way they were used to doing the test after the
assessor left.

 

Also quite often. In some cases, they may be right (as well as wrong).

But I suppose the OP has enough experience to know about those issues. What
I meant by my apparently facetious response is: 'Unless you have full
confidence, don't go there'.


-- 
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Why is the stapler always empty just when you want it?

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Retest because of supersded standard?

[Dward]

Testing and meeting essential requirements. – indeed an interesting 
combination.  

 

A man goes to a doctor and asks how he can meet his bodies directive that it 
receives essential nourishment without using his stomach because his stomach 
‘changes’, gives him gas and gets upset too often.  The doctor says, well, the 
body never said you had to eat in order to meet its requirement of essential 
nourishment.  You can choose another method if you want it is just simpler to 
eat than to take another route.

 

It is true that the EMC directive does not require testing.  But then one does 
not test to the directive, one tests to show compliance to a standard which is 
used to show a device meets the essential requirements of the directive.  So, 
because a mfg used standards to show they meet essential requirements, when 
those standards that are not mandatory change, does one need to retest?

 

There are two issues really, the first is how a party responsible shows they 
continue to meet the essential requirements of the directive. Second, if the 
path used to show meeting the essential requirements has changed (i.e. use of a 
standard), what are the requirements to show continued compliance to those 
changes?  Remember, it is no longer simply the essential requirements of the 
directive that needs to be met, but showing how the path chosen is still 
sufficient to meet those essential requriements.

 

The first is always a requirement and meeting essential requirements is not 
optional.

The second, how that is done, is optional and can and does change.  While 
testing is not required to be used to show meeting essential requirements of 
the directive, if the party responsible chose and is still using the standards 
methods to show how they meet the essential requirements, then it is the 
standard that dictates if testing is or is not (dare I use the word) required.  
If you do not want to test, then don’t use a test standard. But the options are 
far more complicated.

 

Generally one of the statements in any standard is something akin to “THE 
EQUIPMENT SHALL BE TESTED…….”  So, if the party responsible is going to 
continue to use the standards route to show how their device meets the 
directive, then when a standard changes they must do as the standard says and 
test in order show how the results in accordance with the most recent standards 
still meets the essential requirements.  If nothing in the standard changed the 
way a previous test was or was not applied, then no new testing would be 
required.  If however the standard did change in an area that affected test or 
test limits, then in order to still show how it meets the essential 
requirements of the directive, retesting would be required.  Again, remember 
that it is not a requirement of the directive, but it is a requirement of the 
path chosen to use to meet the essential requirements of that directive; and, 
if you do not test, then you are no longer using the standard as the method to 
show meeting essential requirements and you must choose another path in order 
to do that.

 

More simply put, if the party responsible wishes to continue to use a standard 
to show meeting essential requirements, then when testing or retesting is 
required, that is what they must do.  If they no longer wish to test to a 
standard to show meeting the directive requirements, they will still  be 
required to show, aside from testing, how the device continues to meet the 
essential requirements. 

 

thanks

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 
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or attachment(s) are free from computer virus or other defect.  Thank you.

 

From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] 
Sent: Saturday, August 31, 2013 4:31 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Retest because of supersded standard?

 

John Wrote:

 

The EMC Directive doesn't demand ANY testing.

 

Maybe, but it demands EVIDENCE of compliance. Annex IV - 1

 

Two Definitons of Evidence

Law: The documentary or oral statements and the material objects admissible as 
testimony in a court of law.

Law: information drawn from personal testimony, a document, or a material 
object, used to establish facts in a legal investigation or admissible as 
testimony in a law court.

 

 

The rest of your email witnesses daily practices in factories, but 

Re: [PSES] USA Canada rf emission test standards

[Dward]

Well, first, ANSI C63.4 is not a UL document, it is an ANSI standard
published by IEEE.  So there is no ANSI UL C63.4.  That aside, the FCC KDB
data base and DA-09-2478 confirm that either the 2003 or 2009 version can be
used.  

 

There are differences, so a test lab cannot or should not assume that to
test to one is to test to the other.  If the 2009 version is used, then all
testing is to be done to the 2009 version - you cannot mix and match between
test methods and standards.

Thanks 

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
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delete it from your computer system.  Usage of PCTEST email addresses for
non-business related activities is strictly prohibited. No warranty is made
that the e-mail or attachment(s) are free from computer virus or other
defect.  Thank you.

 

From: Ian McBurney [mailto:ian.mcbur...@allen-heath.com] 
Sent: Tuesday, September 17, 2013 8:35 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] USA  Canada rf emission test standards

 

Dear Colleagues;

 

I am trying to combine FCC 47 CFR part 15 and Canadian ICES-003:2012
radiated rf emission testing for a digital device that is an unintentional
radiator.

However; looking into the test standards for each country I am getting
perplexed.

 

It appears that for 47 CFR part 15 sub part B, the test standard for
compliance is ANSI UL C63.4 2003 whereas for Canada it is the latest edition
that is acceptable which I believe is the ANSI UL C63.4 2009.

Similarly; if I was to apply the CISPR 22 method then CFR47 part 15
recognises the third edition of CISPR 22 and Canada applies the 6 edition
2008.

 

Is there a common set of standards that can be applied for radiated 
conducted rf emission measurements that is acceptable in both the USA 
Canada?

 

I am carrying out measurements from 30MHz to 2GHz to class B limits.

 

Many thanks in advance.

 

Ian McBurney

Design  Compliance Engineer.

 

Allen  Heath Ltd.

Kernick Industrial Estate,

Penryn, Cornwall. TR10 9LU. UK

T: 01326 372070

E: ian.mcbur...@allen-heath.com

 

 

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Re: [PSES] USA Canada rf emission test standards

[Dward]

On the second part of the question about FCC and IC having the same test
standards.  Canada allows the use of ANSI C63.4 however, ICES-003 does say
that is must be the latest addition.  This only means that if both FCC and
IC are being done, then the 2009 version would be the one used. 

As with the FCC defaulting to the rules in case of differences, IC has a
caveat that any discrepancies between the requirements in ICES-003 or CISPR
22 or ANSI C63.4:2009, then the ICES wins.

One common error in testing for both FCC and IC is the assumption that
because the restricted bands for the US have been considered and measured
that it covers Canada as well. This is not true as Canada does have several
restricted bands that are different than the US.  

 

Thanks 

 

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.  Usage of PCTEST email addresses for
non-business related activities is strictly prohibited. No warranty is made
that the e-mail or attachment(s) are free from computer virus or other
defect.  Thank you.

 

From: Ian McBurney [mailto:ian.mcbur...@allen-heath.com] 
Sent: Tuesday, September 17, 2013 8:35 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] USA  Canada rf emission test standards

 

Dear Colleagues;

 

I am trying to combine FCC 47 CFR part 15 and Canadian ICES-003:2012
radiated rf emission testing for a digital device that is an unintentional
radiator.

However; looking into the test standards for each country I am getting
perplexed.

 

It appears that for 47 CFR part 15 sub part B, the test standard for
compliance is ANSI UL C63.4 2003 whereas for Canada it is the latest edition
that is acceptable which I believe is the ANSI UL C63.4 2009.

Similarly; if I was to apply the CISPR 22 method then CFR47 part 15
recognises the third edition of CISPR 22 and Canada applies the 6 edition
2008.

 

Is there a common set of standards that can be applied for radiated 
conducted rf emission measurements that is acceptable in both the USA 
Canada?

 

I am carrying out measurements from 30MHz to 2GHz to class B limits.

 

Many thanks in advance.

 

Ian McBurney

Design  Compliance Engineer.

 

Allen  Heath Ltd.

Kernick Industrial Estate,

Penryn, Cornwall. TR10 9LU. UK

T: 01326 372070

E: ian.mcbur...@allen-heath.com

 

 

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RE: mobile phone safety

[dward]

Here is the relationship of cell phones to popping corn.

1 Place the popcorn in a bowl with butter and salt.

2 Place one two or three cellphones in a plastic bag and
place in the same bowl. The plastic bag is to protect the cell phone from the
butter.

3 Place the bowl into a microwave oven.

4 Turn microwave oven on high.

5 Run for the hills because you do not want to be anywhere
around when the corn start to pop – that should happen just shortly after
one or all of the cellphones explode and come flying through the clear glass
of the micro wave door.

6 Do not eat the pop corn, even if you can clean it off
the walls, as it will probably be contaminated by the hazardous material from
the 2002/95/EC non compliant cellphones.

 

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com 
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 

NOTICE: This E-Mail message and any attachment may contain privileged or
company proprietary information. If you received this message in error, please
return to the sender. 

 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of James, Chris
Sent: 06/17/2008 11:06 PM
To: emc-p...@ieee.org
Subject: mobile phone safety

 

Anyone care to comment on whether popping pop-corn with mobile (cell) phones
is a reality?

 

A number of video clips are appearing on the internet demonstrating it but it
could of course be contrived:

 

http://www.koreus.com/video/telephone-portable-mais-popcorn.html
BLOCKED::http://www.koreus.com/video/telephone-portable-mais-popcorn.html 

 

 

Chris

 

 



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RE: like your eggs raw /// mobile phone safety

[dward]

To paraphrase an old adage dealing with those who may actually believe this
video has any credibility what so ever - You can lead a horse to water but
you cannot make him THINK.



Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com 
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 

NOTICE: This E-Mail message and any attachment may contain privileged or
company proprietary information. If you received this message in error,
please return to the sender. 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John
Woodgate
Sent: 06/18/2008 11:11 PM
To: emc-p...@ieee.org
Subject: Re: like your eggs raw /// mobile phone safety

In message 
9d04b979323dcd428297dda95108893e0120c...@bb-corp-ex2.corp.cubic.cub, 
dated Wed, 18 Jun 2008, Price, Edward ed.pr...@cubic.com writes:



I hate to guess the ratio of viewers of that video who analyzed the 
conditions (antenna direction, underlying physics) to those who now 
know they have proof that cell phones are more dangerous than ever.

 
It doesn't stop there. This was passed on to me. It may come from:

http://www.telecompaper.com/news/article.aspx?cid=623982

but that's a subscription-only site. There is also some information in 
French at:

http://www.denisbaupin.fr/?s=Wifi

Paris, France

The elected municipal officials have called, Monday, June 16, to launch 
a thorough comparative study of the mechanisms put in place in other 
countries, cities or institutions in order to reduce the health risks 
related to exposure of Wi-Fi.

Denis Baupin, Green elected deputy mayor of Paris, had expressed his 
concerns against the program Paris Wi-Fi which provides high-speed 
access for 80% of Parisian buildings by 2010.

The facts about Wi-Fi waves raise new concerns

Six Parisian libraries have already been the subject of a campaign of 
measurements of electromagnetic waves, showing that electric fields were 
80 to 400 times below the regulatory limit. The city is aware of 
concerns and wants to remain vigilant, said Anne Hidalgo, the first 
deputy mayor of Paris.

In November 2007 a moratorium on Wi-Fi in libraries in Paris had been 
voted by the committee hygiene and safety, and the direction of Cultural 
Affairs of the City of Paris. The same month, the ministry of ecology 
and health had ordered a report on radiation, therefore including waves 
Wi-Fi, report whose publication is scheduled to appear at the end of the 
year.
-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
Either we are causing global warming, in which case we may be able to stop
it,
or natural variation is causing it, and we probably can't stop it. You
choose!
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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RE: Radio module integration (Part 22/24)

[dward]

Hi Adam

While the FCC does have a policy statement about licensed modular transmitters
using “Contains FCC ID: xxxyyyzzz” on the outside of a host device, it
does not have a policy about full transmitters (i.e. non-modular).   If the
licensed transmitter is not a modular transmitter but has an FCC ID then the
FCC has no requirements about placing the ID number on the system and it is
sufficient that the FCC ID is on the outside of the licensed transmitter.  

Thanks 

 

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com 
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Rudd, Adam
Sent: Friday, September 05, 2008 6:11 AM
To: emc-p...@ieee.org
Subject: Radio module integration (Part 22/24)

 

Gentlemen,

Does the FCC have any regulations or guidance for integrating a radio device
into a larger system, specifically for a part 22/24 radio where the device
will be concealed from view?  Per 15.212, there is a lot of criteria involving
the device having a Grant with Modular Approval and then if the integrator
conceals the radio module’s FCC ID from view we must put a label on the
outside that says “Contains FCC ID:xx”.  I’m quite familiar with
these requirements for 802.11 and RFID radio devices.  But that code section
is strictly for unlicensed part 15 transmitters.  What about licensed Part 22
and 24 transmitters such as cellular radio devices such as:

 

FCC ID N7NAC875

https://fjallfoss.fcc.gov/oetcf/eas/rep
rts/ViewExhibitReport.cfm?mode=Exhibits
RequestTimeout=500calledFromFrame=Nap
lication_id=184431fcc_id=%27N7NAC875%27

 

Note: Does not have “modular approval”, but that was a requirement under
part 15.212… which may or may not be applicable here.

 

I have submitted an inquiry with the FCC OET.  But that usually take a couple
weeks to get a responce.  I am hoping someone here might be able to point me
toward the rule section of Part 22 and 24 that would provide guidance.

 

Thank you!

Adam Rudd

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RE: Radio module integration (Part 22/24)

[dward]

The FCC has two different approaches to part 15 and to licensed modules, but
many of the same issues apply to both.  The FCC for example only has ONE
modular approval docket DA001407 and that deals ONLY with part 15 modules. 
However, the FCC also recognizes that licensed devices may also be of a
modular nature and so, while there really is no modular approval docket for
licensed devices like there is for unlicensed part 15 devices, modular
transmitters are allowed in the licensed world.  There are a few issues
dealing with modular transmitters in the licensed rule parts.  

 

Licensed transmitters may be approved as modules for installation into the
final devices provided the following criteria are met:

1  The final device is designed for mobile or fixed operation
(Portable is not permitted – this is in reference to rf exposure more than
anything)

2  The maximum antenna gain to allow compliance with RF exposure
requirements is listed on the Grant of Certification for the modular
transmitter

3  The licensed module must have a FCC ID label on the module
itself. That FCC ID label must be visible through a window on the final device
or it must be visible when an access panel, door or cover is easily removed.
If not, a second label must be placed on the outside of the final device that
contains the following text: Contains FCC ID: xxxyyyzzz.”

4  The Grant should include the following words in the device
description or grant notes: “modular transmitter” or “transmitter
module”

 

You should notice that unlike the unlicensed DA001407 modular approval docket,
since this is a licensed device, you do not have to limit the antenna except
to the max gain.  Any type antenna, any type connector etc can be used.  In
fact, removable antenna device do not even have to have an antenna connected
for any of the testing.  Power can be conducted antenna terminal power and
radiated spurious emissions, even though erp/eirp done to TIA603C, only have
to have the antenna port connected to a ‘dummy load’.  The gain of the
antenna can be ‘calculated’ to yield the appropriate MPE etc.  

 

You should also notice that there is no such thing as a licensed portable
modular transmitter.

 

Thanks 

 

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com
http://www.atcb.com  
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Bill Owsley
Sent: Friday, September 05, 2008 10:34 AM
To: 'Rudd, Adam'; emc-p...@ieee.org; dw...@atcb.com
Subject: RE: Radio module integration (Part 22/24)

 

In looking at the reference example, the transmitter appears to fit into the
PCI port of a laptop, much the same as wireless network card fits into one.  

 

So does modular have more to do with being unlicensed, or would it have more
to do with how it is used?  

- Bill
You can say what you want about the South, but you never hear of anyone
retiring and moving North!!!

--- On Fri, 9/5/08, dward dw...@atcb.com wrote:

From: dward dw...@atcb.com
Subject: RE: Radio module integration (Part 22/24)
To: 'Rudd, Adam' ar185...@ncr.com, emc-p...@ieee.org
Date: Friday, September 5, 2008, 11:42 AM

Hi Adam

While the FCC does have a policy statement about licensed modular
transmitters using “Contains FCC ID: xxxyyyzzz” on the outside of a host
device, it does not have a policy about full transmitters (i.e. non-modular). 
 If the licensed transmitter is not a modular transmitter but has an FCC ID
then the FCC has no requirements about placing the ID number on the system and
it is sufficient that the FCC ID is on the outside of the licensed
transmitter.  

Thanks 

 

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com
http://www.atcb.com/  
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Rudd, Adam
Sent: Friday, September 05, 2008 6:11 AM
To: emc-p...@ieee.org
Subject: Radio module integration (Part 22/24)

 

Gentlemen,

Does the FCC have any regulations or guidance for integrating a radio device
into a larger system, specifically for a part 22/24 radio where the device
will be concealed from view?  Per 15.212, there is a lot of criteria involving
the device having a Grant with Modular Approval and then if the integrator
conceals the radio module’s FCC ID from view we must put a label on the
outside that says “Contains FCC ID:xx”.  I’m quite familiar with
these requirements for 802.11 and RFID radio devices.  But that code section
is strictly for unlicensed part 15 transmitters.  What about licensed Part 22
and 24 transmitters such as cellular radio devices such as:

 

FCC ID N7NAC875

https://fjallfoss.fcc.gov/oetcf/eas/rep
rts/ViewExhibitReport.cfm?mode=Exhibits
RequestTimeout

RE: Radio module integration (Part 22/24)

[dward]

) or 2.1033(c).

 

Best Regards, 

Adam Rudd 
Engineer (EMC) 
NCR Corporation - RHSS 
Duluth, GA 
(770) 495-2825 



From: dward [mailto:dw...@atcb.com] 
Sent: Friday, September 05, 2008 2:35 PM
To: wdows...@yahoo.com; Rudd, Adam; emc-p...@ieee.org
Subject: RE: Radio module integration (Part 22/24)

 

The FCC has two different approaches to part 15 and to licensed modules, but
many of the same issues apply to both.  The FCC for example only has ONE
modular approval docket DA001407 and that deals ONLY with part 15 modules. 
However, the FCC also recognizes that licensed devices may also be of a
modular nature and so, while there really is no modular approval docket for
licensed devices like there is for unlicensed part 15 devices, modular
transmitters are allowed in the licensed world.  There are a few issues
dealing with modular transmitters in the licensed rule parts.  

 

Licensed transmitters may be approved as modules for installation into the
final devices provided the following criteria are met:

1  The final device is designed for mobile or fixed operation
(Portable is not permitted – this is in reference to rf exposure more than
anything)

2  The maximum antenna gain to allow compliance with RF exposure
requirements is listed on the Grant of Certification for the modular
transmitter

3  The licensed module must have a FCC ID label on the module
itself. That FCC ID label must be visible through a window on the final device
or it must be visible when an access panel, door or cover is easily removed.
If not, a second label must be placed on the outside of the final device that
contains the following text: Contains FCC ID: xxxyyyzzz.”

4  The Grant should include the following words in the device
description or grant notes: “modular transmitter” or “transmitter
module”

 

You should notice that unlike the unlicensed DA001407 modular approval docket,
since this is a licensed device, you do not have to limit the antenna except
to the max gain.  Any type antenna, any type connector etc can be used.  In
fact, removable antenna device do not even have to have an antenna connected
for any of the testing.  Power can be conducted antenna terminal power and
radiated spurious emissions, even though erp/eirp done to TIA603C, only have
to have the antenna port connected to a ‘dummy load’.  The gain of the
antenna can be ‘calculated’ to yield the appropriate MPE etc.  

 

You should also notice that there is no such thing as a licensed portable
modular transmitter.

 

Thanks 

 

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com
http://www.atcb.com  
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Bill Owsley
Sent: Friday, September 05, 2008 10:34 AM
To: 'Rudd, Adam'; emc-p...@ieee.org; dw...@atcb.com
Subject: RE: Radio module integration (Part 22/24)

 

In looking at the reference example, the transmitter appears to fit into the 
PCI port of a laptop,
much the same as wireless network card fits into one.  

 

So does modular have more to do with being unlicensed, or would it have more
to do with how it is used?  

- Bill
You can say what you want about the South, but you never hear of anyone
retiring and moving North!!!

--- On Fri, 9/5/08, dward dw...@atcb.com wrote:

From: dward dw...@atcb.com
Subject: RE: Radio module integration (Part 22/24)
To: 'Rudd, Adam' ar185...@ncr.com, emc-p...@ieee.org
Date: Friday, September 5, 2008, 11:42 AM

Hi Adam

While the FCC does have a policy statement about licensed modular
transmitters using “Contains FCC ID: xxxyyyzzz” on the outside of a host
device, it does not have a policy about full transmitters (i.e. non-modular). 
 If the licensed transmitter is not a modular transmitter but has an FCC ID
then the FCC has no requirements about placing the ID number on the system and
it is sufficient that the FCC ID is on the outside of the licensed
transmitter.  

Thanks 

 

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com
http://www.atcb.com/  
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Rudd, Adam
Sent: Friday, September 05, 2008 6:11 AM
To: emc-p...@ieee.org
Subject: Radio module integration (Part 22/24)

 

Gentlemen,

Does the FCC have any regulations or guidance for integrating a radio device
into a larger system, specifically for a part 22/24 radio where the device
will be concealed from view?  Per 15.212, there is a lot of criteria involving
the device having a Grant with Modular Approval and then if the integrator
conceals the radio module’s FCC ID from view we must put a label on the
outside that says “Contains FCC ID:xx”.  I’m quite familiar

RE: Labeling Requirements per Industry Canada

[dward]

HI Grace

While it may be a desire of a marketing company to use their name, they are
not the certificate holder and thus putting only the marketing companies name
on the device would be incorrect.  The standard is pretty clear on this issue.
 The “the applicant's name (i.e. manufacturer's name, trade name or brand
name), model number and certification number” are to be on the device label.
This however, does not mean that in addition to these the marketing companies
name cannot be on the device.  

 

It should be remembered that the intent of the IC requirements is to identify
the device and link it to the manufacturer/applicant and the model number and
IC number. 

 

If a more specific interpretation from the IC is desired you may also contact
certification.bur...@ic.gc.ca. 

 

Thanks  

 

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com
http://www.atcb.com  
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Grace Lin
Sent: Tuesday, September 09, 2008 11:17 AM
To: emc-p...@ieee.org
Subject: Labeling Requirements per Industry Canada

 

Dear Members,

 

Could someone please advise if a marketing company is able to mark an Industry
Canada certified OEM product by using the manufacturer's (applicant's) IC
number and the marketing company's name and model number?

 

I excerpt Section 5.2 of RSS-Gen below for your convenience.

 

If yes for the above question, is there any procedure we or our OEM supplier
has to follow (permissive change, etc.) ?

 

Thank you and look forward to hear from you.

 

Best regards,

Grace Lin

 



All Category I radio equipment intended for use in Canada shall permanently
display on each transmitter, receiver, or inseparable combination thereof, the
applicant's name (i.e. manufacturer's name, trade name or brand name), model
number and certification number. This information shall be affixed in such a
manner as not to be removable except by destruction or defacement. The size of
the lettering shall be legible without the aid of magnification but is not
required to be larger than 8-point font size. If the device is too small to
meet this condition, the information can be included in the user manual upon
agreement with Industry Canada. 

The label for medical implants which are designed to be used within the human
body, can be placed on the package and user manual.

The certification number is made up of a Company Number (CN) assigned by the
Bureau followed by the Unique Product Number (UPN), assigned by the applicant.

The certification number shall appear as follows: 

IC: XX-YYY 

Where: 

*   XX-YYY is the certification number; 
*   XX is the Company Number (CN) assigned by Industry Canada, made 
of at
most 6 alphanumeric characters (A-Z, 0-9), including a letter at the end of
the CN to distinguish between different company addresses; 
*   YYY is the Unique Product Number (UPN) assigned by the 
applicant,
made of at most 11 alphanumeric characters (A-Z, 0-9); and 
*   the letters IC have no other meaning or purpose than to identify the
Industry Canada certification number. 

Permitted alphanumerical characters used in the CN and UPN are limited to
capital letters (A-Z) and digits (0-9). An example of the new format for a
company having a CN of 21A and wishing to use a UPN of WILAN3 would thus
be: IC: 21A-WILAN3. Each equipment model shall be explicitly identified. The
use of characters, such as #, / or -, in the certification number is not
allowed. The use of wild card characters in the model number (for the
purpose of identifying multiple models with one name) is not allowed.

Equipment that has received certification but is not labelled with the
applicant's name, model number and the certification number as outlined above
is not considered certified.

Category II equipment shall be labelled in accordance with the requirements of
RSS-310. 



-  This
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For help, send mail to the list administrators: 

Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org 

For policy questions, send mail to: 

Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com 

All emc-pstc postings are archived and searchable on the web at: 

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-  This
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To post a message to the list, send your 

RE: FCC Requirement Note

[dward]

Hi Andrew

Grant notes, while some being generic, are always applicable to the particular
grant on which they occur.  In this case the source of the note is the device
itself.  The limit to gain is most likely due to the MPE caused by the gains
listed being able to meet the separation distance specified in the MPE report.
 The grant for this particular device is only effective under those
conditions.  They deal with the device being used in a mobile rf configuration
as well as the instances when they are fixed.  The grant note is basically
saying that you cannot use a higher gain antenna than listed unless MPE has
been accounted for in either a PC2 or new ID application.

 

Thanks 

 

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com 
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Mark Briggs
Sent: Friday, September 12, 2008 8:11 PM
To: Andrew McCallum
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: FCC Requirement Note

 

Andy

The source for the note is probably the FCC grant for the device.  

After a quick look on the FCC's search page at
https://fjallfoss.fcc.gov/oetcf/eas/reports/GenericSearch.cfm  I am guessing
that the module you are looking at is from Multi-Tech Systems, FCC ID
AU792U07G30822.


I think others have replied with explanations as to the reasoning behind the
requirement.

Regards

Mark


At 02:00 AM 9/12/2008, Andrew McCallum wrote:



Been given the note below but need to find the original source for reference
can anyone help please?
 
FCC Requirements Note:
The antenna gain, including cable loss, must not exceed 3.0 dBi at 1900 MHz /
1.6 dBi at
850 M0Hz for mobile operating configurations and 7.0 dBi at 1900 MHz / 2.3 dBi
at 850 MHz for
fixed mounted operations, as defined in 2.1091 and 1.1307 of the rules for
satisfying RF exposure
compliance.
 
Thanks very much
 
Andy






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RE: FCC

[dward]

In the situation you mention, as long as the antenna is of the same or lesser
gain and also of the same type as approved, then the device can be used based
on its approval and would not mandate any further testing when placed in a
system.  However, approval status only shows an assumption of compliance, they
do not show each situation is compliant.   We should never confuse a
‘claim’ of compliance with actual compliance of each device to the rules. 
Part 15 devices, regardless of approval status, always are subject to the
condition that they do not cause interference.   This basically means that the
part 15C device could be fully compliant to the limits in the rules yet, if it
causes interference and a complaint is received, it would have to be either
turned off or fixed to stop interfering.  Failure to do so could lead to fines
or other punitive actions imposed by the FCC – again, regardless of approval
status

For this reason alone, regardless of no mandated test requirements, it is
always a good idea to test the system to make sure that all devices work
together in a compliant fashion.

That way, if complaints do arise, you will at least have evidence of due
diligence. 

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com
http://www.atcb.com  
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Andrew McCallum
Sent: Friday, September 19, 2008 7:35 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: FCC

 

If you connect an FCC approved modem and antenna (gain within the grant of the
modem) to a system which is fully compliant to the standards required in its
intended environment would you have to carry out further testing on the whole
system to claim FCC compliance for the system or would it be satisfactory to
say that as the modem is FCC compliant the system (which is passive)is
therefore compliant.

 

Any thoughts much appreciated. 

 

regards

 

Andy  

 




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RE: EU/OJ Blacklist

[dward]

Hi Gail
I would think that you should look into the Anti-dumping laws in the EU for
this sort of thing.

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com 
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Birdsall,
Gail
Sent: Friday, October 17, 2008 9:38 AM
To: emc-p...@ieee.org
Subject: EU/OJ Blacklist

Dear Colleagues,

I have long heard (unofficially) that the EU has a blacklist of
companies/products that have been identified as unsafe (nonconforming)
to EU directives/standards.  Also, a means of notifying member countries
of these companies and products.

Does such a list and notification system really exist, or is a just
something someone invented to worry companies that ignore the EU
requirements.

Any informed information would be appreciated.

Best Regards,

Gail Birdsall
Mgr. Compliance Dept.
Hach Co.
ph: (970) 669-3050 x 2682
gbird...@hach.com 


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RE: rod antenna measurement not allowed below 30 MHz for FCC

[dward]

Hi Mario 

This has been a very long standing position from the FCC. It goes way back to
the 80’s when I first started dealing with the FCC.  This very old policy
has been reiterated in the Knowledge Data Base (KDB).  For example when
specifically asked the FCC responded in KDB460108 which states “Question:
May a monopole (rod) antenna be used for making radiated emission measurements
below 30 MHz? 

Answer:   The procedures for measuring intentional and unintentional radiators
is contained in Section 15.31(a)(3), which incorporates into the Rules by
reference ANSI Standard C63.4–2003: “Methods of Measurement of Radio-Noise
Emissions from Low-Voltage Electrical and Electronic Equipment in the Range of
9 kHz to 40 GHz”.   Excluded, however, are Sections 4.1.5.2, 5.7, 9 and 14
of ANSI C63.4-2003, which, among other things, excludes the use of the rod
antenna.  For radiated emission measurements below 30 MHz, the FCC requires
the use of a loop antenna.”

 

As to the rules and measurement procedures; what you need to remember is that
the rules are not really test methods and so you would not necessarily find
this in the rules themselves, but in the established and/or approved test
procedures accepted by the FCC.  Also, the FCC has accepted some industry
standardized test methods as well as producing several FCC documents and
procedures.  For the industry standards they are purchased from the standards
organization and will not be found as downloadable from any FCC site.  Here is
a short list:

1  ANSI C63.4 2003 (with exclusions from FCC where appropriate)
– covers many low power devices other that 15.247, 15.407 etc. Purchased
from ANSI or other publishing firms such as Global etc

2  DA00705 -  this is a docket from the FCC itself and can be
downloaded from OET. This deals with FHSS devices under 15.247

3  Guidance on Measurements for Digital Transmission Systems
Section 15.247 – issued in 2002 downloadable from OET. This deals with DTS
systems and UNII systems under 15.247 and 15.407 etc.

4  TIA603C – this is the generic test procedure for all licensed
rule parts (i.e. other than parts 15 and 18).  Purchased from TIA or other
orgs such as Global etc.

5  MP-5 – this is part 18 methods and is downloadable from OET.

You should also consult the FCC Knowledge Data Base for specific methods
acceptable by FCC as well.

Thanks

 

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com 
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of
mlehm...@herberg-sp.de
Sent: Tuesday, October 21, 2008 1:12 AM
To: emc-p...@ieee.org
Cc: Grace Lin
Subject: rod antenna measurement not allowed below 30 MHz for FCC

 


Dear Members, 

I´ve heard that FCC will not accept rod antenna measurements below 30 MHz.
This was´nt  puplished anywhere in the rules. 
May I ask you to help finding a source on the FCC web site to get such
important informations in the future? 

Kind regards 

Mario Lehmann 

  

Geschäftsbereich European Compliance Laboratory (ECL) 

__ 

HERBERG. 


Service Plus GmbH 

Tel: 

+49 911 59835-923 

Nordostpark 51 

Fax: 

+49 911 59835-90 

90411 Nürnberg 

mailto: 

mlehm...@herberg-sp.de mailto:mlehm...@herberg-sp.de  

  

http://www.herberg-sp.de http://www.herberg-sp.de/  

 

Amtsgericht Nürnberg 

Geschäftsführer 

  

HRB 19587 

Peter Birkmann 

 

 

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RE: EMI Receiver

[dward]

I would ALWAYS caution anyone making measurements not to rely solely on what
an analyzer is supposed to do or not do and to always use his/her own noodle
to judge any measurement made.  Measuring instruments make errors, don't
report error, or sometimes are just setup wrong.  Never never rely solely on
what the device reports.  There is nothing out there that is infallible and
which does not require constant monitoring of the human brain.
Thanks 

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com 
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Clif Brick
Sent: Thursday, December 04, 2008 11:14 AM
To: Gert Gremmen; Ralph McDiarmid
Cc: emc-p...@ieee.org
Subject: RE: EMI Receiver

I guess the crux of your argument lies in the definition of decent
receiver.  While true that a CISPR compliant receiver would warn you,
it also has preselection.  Less expensive pre-compliance instruments
require careful attention to this issue.

I have certainly seen this occur in real life, it's by no means merely
theoretical. Often it occurs in measuring transmitters, where the filter
that is attenuatiing the fundamental is not adequately large.  It can
however occur from a strong ambient and an inexperienced operator not
recognizing the significance of that large ambient signal could readily
make an erroneous conclusion.  Now of course if it's all carried out in
a chamber.




From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Gert
Gremmen
Sent: Thursday, December 04, 2008 1:50 PM
To: Ralph McDiarmid
Cc: emc-p...@ieee.org
Subject: RE: EMI Receiver

I think this is more a theoretic exercise, and as true as unlikely to
fool you.

Any decent receiver in overload
does not show a measurement value
but blinks, reports an error condition (IEEE-bus) or has a bright red
blinking error led or beeper.

I have never been able to reproduce this phenomenon with a spectrum
analyzer without reported error condition. (and certainly not with all
signals -spurious included- meeting limit lines, and make me conclude a
compliant result.)




Gert


Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens Ralph McDiarmid
Verzonden: donderdag 4 december 2008 17:57
Aan: emc-p...@ieee.org
Onderwerp: RE: EMI Receiver

That's my understanding too.


Ralph McDiarmid, AScT
Compliance Engineering Group
Xantrex Technology Inc


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Clif
Brick
Sent: Thursday, December 04, 2008 8:50 AM
To: Gert Gremmen; emc-p...@ieee.org
Subject: RE: EMI Receiver

I could be wrong as it's been a few years, but it seems to me that a
spectrum analyzer receiver in overload will show a signal to be a lower
amplitude than it really is (in addition to ghosts, spurs and intermod
products).  The issue is one of compression, and in fact an overlaoded
analyzer will show comply when in fact the device is non-compliant just
as readily as the opposite.

If an overlaod condition exists, you may get a reading of a real (from
the EUT) signal that is say 0dBm, you add 10 dB of attenuation and get
-3dBm.  This means that in fact your signal is at least 7dB larger than
your display.  If you add 10 dB more and get say -7, you're still in
overload.  You would need to continue until you get linear response.
Important to understand is that it may be well outside of the band of
interest that the overlaoding signal is comin in on.  This is why
preselection helps

Best regards,
Clif


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Gert
Gremmen
Sent: Wednesday, December 03, 2008 2:27 AM
To: emc-p...@ieee.org
Subject: RE: EMI Receiver

From EUT cost to compliance point of view I fully agree with  this
discussion about preselectors.
The only error one makes without preselector is that one may (not will)
need much more effort and cost to make your product compliant, as ghost
emissions may appear due to overload effects in any receiver
amplifier/mixer part, transient  limiter or elsewhere.
However, if your receiver/spectrumanlyser without preselector indicates
compliance the result is valid (other non-compliance aspects neglected).

Without preselector:

A non compliance result is NOT reliable
A compliance result IS reliable.


Another remark:

Most transient limiters contain an attenuator (20dB) in front of the
limiter. As a transient limiter will clip somewhere between 1 and 3
volts pk, the spikes that triggered the transient limiter were generated
by that immature design were of an amplitude very likely to have
destroyed the input of the analyser without the transient device (20V)
!!

I have no relations with this company!!!
I stick to the (older?) RS receivers, as they have shown to produce
consistent results over time, and have sufficient head room in their
amplifiers to never create overload problems, and do have decent
pre-selectors. In addition, they have no problems 

RE: Mobile Phones in EMC Labs

[dward]

Whatever happened to the time when a good engineer could repair his own
dipole, fix minor front end analyzer problems, be able to tell the
difference between 20dBm and 20dBuV, know what dBm and dBuV meant,
understand you can't put the output of a 100W transmitter directly into the
front end of the measuring instrument without proper attenuation,
understanding what attenuation was, understand what was actually happening
during a test automated or otherwise.  

In the rush for speed, we lost a lot.  Automation, under control, can be a
good thing.  Automation, without proper control, only gives a lot of paper
with meaningless unsubstantiated number.

Of course that is just my opinion.  

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com 
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Pettit,
Ghery
Sent: Tuesday, December 09, 2008 10:47 AM
To: Kunde, Brian; Derek Walton
Cc: Luke Turnbull; emc-p...@ieee.org
Subject: RE: Mobile Phones in EMC Labs

At least your tech was there.  We'd have him doing something else while the
chamber took care of itself.  :-)  Multitasking, that's the name of the
game.



From: Kunde, Brian [mailto:brian_ku...@lecotc.com]
Sent: Tuesday, December 09, 2008 10:45 AM
To: Pettit, Ghery; Derek Walton
Cc: Luke Turnbull; emc-p...@ieee.org
Subject: RE: Mobile Phones in EMC Labs

Today, I walk by the test station; the EUT has fallen off the table and
is on fire, the sprinklers have shot down through the ceiling spraying
950 gallons of water per minute in to the chamber, the mast rope got
twisted on the pulley and broke, the BiConLog antenna is smashed on the
floor in a hundred pieces, all while the technician is playing a fishing
game on his IPHONE.

Oh, what I wouldn't give for the good ol' days. I'm not asking for much,
just to pay attention to what is going on even during an automated scan.




From: Pettit, Ghery [mailto:ghery.pet...@intel.com]
Sent: Tuesday, December 09, 2008 12:50 PM
To: Kunde, Brian; Derek Walton
Cc: Luke Turnbull; emc-p...@ieee.org
Subject: RE: Mobile Phones in EMC Labs

Ah, for the good old days when the receiver was tuned by hand, one hand
on the tuning knob, the other on the IF gain / slide back / RF
attenuator.  Note the level on the scope, disconnect the antenna and
connect the IG, adjust the IG to match the level noted on the scope and
write that number down.  Apply antenna factor by hand and move to the
next signal.

Naw!  I like automated tests.  At least in an ambient free environment
like a chamber.  But, you should have your techs do it by hand a few
times so they'll really appreciate the automation.  And, did I mention
that sometimes you did the old way in really interesting places?
Like, Adak?  :-)

Ghery



From: Kunde, Brian [mailto:brian_ku...@lecotc.com]
Sent: Tuesday, December 09, 2008 9:45 AM
To: Derek Walton; Pettit, Ghery
Cc: Luke Turnbull; emc-p...@ieee.org
Subject: RE: Mobile Phones in EMC Labs

You bring up a good point. You must control your environment if there is
any possible way changes in that environment can affect or even put into
doubt your test results.

We have done hours of testing then realize a customer had been playing a
PSP game system in the area. Now whether it affected our test results or
not, it had put our test results into doubt.  So we had to perform more
testing to verify our results.

So, I would make it clear to customers, engineers, and even your own
testers that no additional electronic devices are to be introduced into
your testing environment unless it has been verified not to affect the
test results.

I also agree that a good and well trained test technician should be able
to notice and track down any new emission source within a reasonable
amount of time, but within an automated test system like ours, they tend
to get a little lazy. Push a button, get a cup of coffee.  Man I hate
that.

The Other Brian



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Derek
Walton
Sent: Tuesday, December 09, 2008 11:21 AM
To: Pettit, Ghery
Cc: Luke Turnbull; emc-p...@ieee.org
Subject: Re: Mobile Phones in EMC Labs

Hi all,

just a thought If you're an accredited lab you are supposed to
evaluate your working environment: I'd include Cell phones in this.

Now, I hate banning things, so my first thought is that whoever is
running testing should know about mobile Transmitters, from Door openers

to cell phones. This is a topic I always discuss when Assessing.

Just because things are banned doesn't mean they will not be present.

In my lab I use the 4 module HP system, and Sucoflex cables. I do not
see signals related to the cell phone in this system. I did when I used
low cost cables. I am not advocating the used of a particular brand,
just good cables.

The power to the four modules is passed through a Xantrex super
isolation transformer also: just cos'.

Seasons greetings,

RE: Mobile Phones in EMC Labs

[dward]

Sorry but I would have to disagree with you on that.  In the surveillance
end, we find that if a device submitted for certification has been properly
tested by qualified engineers under proper control, even on automated
systems, the numbers can be reproduced within a reasonable expectations,
whereas uncontrolled testing by inexperienced engineers using automated
systems alone tend to produce a very wide difference in what is measured.

If you remember back to the days of yesteryear, some of the biggest problems
were uncontrolled setups, uncontrolled testing procedures, uncontrolled
engineering practice etc.  What we seem to be reintroducing in the automated
test systems is the uncontrolled factor once again.  Turn the system on go
get coffee and let it do whatever it does and come back to some set of
numbers to which we have no idea if they are right wrong or within
reasonable variations.

Thanks 

 

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com 
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John
Woodgate
Sent: Tuesday, December 09, 2008 11:58 AM
To: emc-p...@ieee.org
Subject: Re: Mobile Phones in EMC Labs

In message 00b201c95a35$f528d430$df7a7c90$@com, dated Tue, 9 Dec 2008, 
dward dw...@atcb.com writes:


Automation, without proper control, only gives a lot of paper with 
meaningless unsubstantiated number.

Doesn't matter, because most of the test methods are either artificial 
or unrepeatable, so even manual measurements give meaningless 
unsubstantiated numbers.

Pardon my cynicism. The only justification for what we do is that it 
works in practice.
-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
Either we are causing global warming, in which case we may be able to stop
it,
or natural variation is causing it, and we probably can't stop it. You
choose!
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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RE: FCC question RF exposure question

[dward]

There are two rf exposure conditions provided in the FCC rules that must be
addressed at the time of certification. One is for portable configurations for
devices that are used within 20cm of the body, and the other is mobile
configurations for devices that are used more than 20cm from the body.  SAR is
to be considered for portable configurations.  IN some cases like cell phones,
SAR evaluation is required, for some it depends on the power level or low
threshold to determine if SAR evaluation is required.  MPE is considered for
mobile configurations.

 

The last group for consideration of rf exposure are those devices that must be
licensed at the time of installation.  

 

thanks

 

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com 
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Anders
Svensson B
Sent: Monday, December 15, 2008 11:50 PM
To: emc-p...@ieee.org
Subject: FCC question RF exposure question

 

Hi group, 

 

What means with the expression in a FCC grant: mobile-only exposure
conditions? 

Regards 
Anders 

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RE: EMC Eduction and Training

[dward]

In keeping with the season and to insure beginning EMC engineers I recite,
with editorial license, Church’s response to Virginia O’Hanlon.

Virginia- I am 8 years old. Some of my little friends say there is no EMC and
that it is Black Magic.  Papa says, “If you see it on the emc-pstc, it’s
so.” Please tell me the truth, is EMC Black Magic? - Virginia O’Hanlon

 

Virginia, your little friends are wrong. They have been affected by the
skepticism of a skeptical age. They do not believe except they see. They think
that nothing can be which is not comprehensible by their little minds. All
minds, Virginia, whether they be men’s or children’s, are little. In this
great universe of ours, man is a mere insect, an ant, in his intellect as
compared with the boundless world about him, as measured by the intelligence
capable of grasping the whole of truth and knowledge. Yes, Virginia, there is
EMC and it is no Black Magic. It exists as certainly as love and generosity
and devotion exist, and you know that they abound and give to your life its
highest beauty and joy. Alas! how dreary would be the world if there were no
EMC and if it were Black Magic! It would be as dreary as if there were no
Virginias. There would be no childlike faith then, no poetry, no romance to
make tolerable this existence. We should have no enjoyment, except in sense
and sight. The eternal light with which childhood fills the world would be
extinguished.

Not believe in EMC! You might as well not believe in ferrites, or absorbers.
You might get your papa to hire men to watch in all the stores to catch EMC,
but even if you did not see EMC coming down and interfering, what would that
prove? Nobody sees EMC, but that is no sign that there is no EMC. The most
real things in the world are those that neither children nor men can see. Did
you ever see EMC fairies dancing on the lawn? Of course not, but that’s no
proof that they are not there. Nobody can conceive or imagine all the wonders
there are unseen and unseeable in the world.

 

You tear apart the baby monitor and see what makes the noise inside, but there
is a veil covering the unseen world which not the strongest man, nor

even the united strength of all the strongest men that ever lived could tear
apart. Only faith, experience, love of the field, testing, can push aside that
curtain and view and picture the supernal beauty and glory beyond. Is it all
real? Ah, Virginia, in all this world there is nothing else real and abiding.

No EMC! Thank God! It exists and will forever. A thousand years from now,
Virginia, nay 10 times 10,000 years from now, EMC will continue to

make glad the heart of inquisitive engineers.

 

Merry Christmas

 

Dennis Ward 
Director of Engineering 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com 
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Price, Edward
Sent: Tuesday, December 16, 2008 7:49 AM
To: EMC-PSTC
Subject: RE: EMC Eduction and Training

 

 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Kunde, 
Brian
Sent: Tuesday, December 16, 2008 6:52 AM
To: EMC-PSTC
Subject: RE: EMC Eduction and Training

Hey, lets think about this for a minute.  Do we really want this “black
magic” stuff we do for a living to be better taught in universities?  Lets
face it, we have a good thing going here and we don’t need some greenhorn
engineer thinking he knows more about it than we do.  As mentioned earlier,
this job is more experience and technique than science.

  

The best EMC engineers and technicians I know where not taught in 
school, but
had been mentored by an older experienced EMC engineer.  Like a magician
passing on his secretes to his apprentice. This is how it has been done and
the way it has to be done.  

 

 

The Other Brian 

 

 

The Other Brian touches on an interesting and salient feature of the happy EMC
Engineer. EMC demands a more hands on approach than most of the other
disciplines. Those students who are not already building their own circuits
and frying their own power supplies will not do well in EMC, or at minimum,
will try to stay toward the academic / computational edge of EMC. To the
rigidly academic, it must be terrifying to discover that EMC problems have so
many unknowns and (usually) more than one solution.

 

I'm not so sure that a mentoring / apprentice system HAS to be the only way to
assure continuity, but, from my observation, it has been an effective and
efficient method. Certainly, we could get into an endless discussion of
whether our educational system rationally assigns talent to appropriate needs
(after all, they told me I could be anything I wanted; what they didn't tell
me was that what I wanted also had to be needed). Remember Pachinko and
Pinball machines? There's 

Re: [PSES] TCBs FCC Shut Down

[Dward]

To be more specific – a TCB does not actually issue a grant, even though it has 
their name on it as the TCB.  Only the FCC can issue a legal grant of equipment 
authorization and no device, except under the special conditions of marketing 
in part 2, can be sold or offered for sale, used or turned on without a grant 
in place.

 

All TCBs should know and understand this and should inform an inquirer of the 
same thing.  If a TCB says otherwise, then they either do not understand their 
role and the rules, or there is another reason for misleading the questioner.

 

Thanks 

Dennis Ward

Senior Certification Engineer

PCTEST

This communication and its attachments contain information from PCTEST 
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or attachment(s) are free from computer virus or other defect.  Thank you.

 

From: Dwardpctest [mailto:dw...@pctestlab.com] 
Sent: Wednesday, October 02, 2013 12:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] TCBs  FCC Shut Down

 

A device is not considered certified (granted) until a grant is issued by the 
FCC website.  If there is no issued grant then there is no certification period.

Sent from my iPad


On Oct 2, 2013, at 11:31 AM, FW Miller f_w_mil...@yahoo.com wrote:

I need some advice and information, please.  

What constitutes a grant of certification from a TCB? 

1. Posting on the FCC web site, which is now shut down, until it isn't..

2. Technical evaluation review completed, with something in writing indicating 
it's OK to ship.

3. Any other method? Chapter  verse of the source would be appreciated.

4. Following the certification, there's a C2PC for co-location that's required. 

 

We, as with many many others have been affected by the shut down  are looking 
for solutions. Are the TCBs acting in unison on this one, or should we be 
shopping around?

 

Many thanks in advance for your support.

 

 

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Re: [PSES] Standards copyright lawsuit

[Dward]

Probably more accurate is that we see laws we do not like and then try to find 
ways around them or to find loopholes that apply to us.  Sometimes it is simply 
better for all if we just read and understand the intent of laws and not try to 
sway them in one way or the other.   H not gonna happen.

 

Dennis Ward

Senior Certification Engineer

PCTEST

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or attachment(s) are free from computer virus or other defect.  Thank you.

 

From: John Shinn [mailto:jmsh...@pacbell.net] 
Sent: Tuesday, October 08, 2013 1:15 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Standards copyright lawsuit

 

and the number of lawyers.

 

From: Derek Walton mailto:lfresea...@aol.com  

Sent: Tuesday, October 08, 2013 4:32 AM

To: EMC-PSTC@LISTSERV.IEEE.ORG 

Subject: Re: [PSES] Standards copyright lawsuit

 

Doug has a point, the laws are available, and we can get access for free. The 
problem is we spend our lives trying to find which laws we have to comply with, 
then more than likely have lawyers try to agree what they really meant when it 
was written!  Time we reduced the number of laws

 

Derek.

Sent from my iPad


On Oct 7, 2013, at 16:41, Doug Powell doug...@gmail.com wrote:

Cortland 

I am not certain you speed limit example explains the point you are trying to 
make. 

Here in Colorado we have the Colorado Revised Statutes, or CRS. In these laws 
are all the requirements for citizens to follow so they are in compliance with 
the law.  In practice posted speed limits are akin to the warning labels we put 
on products like: Danger High Voltage or Speed Limit 65.  

In my state we can go to the government website and read any portion of the CRS 
for free. Same with the US Code of Federal Regulations.  Now, if this were 
available only by paid subscription, then your point would be made. Of course, 
how many citizens actually read the law in its entirety? I suspect it is less 
than even 1%. Hence the need for posted cautionary and warning statements. 

Doug

 


From: Cortland Richmond

Sent: Monday, October 7, 2013 12:32 PM

To: EMC-PSTC@LISTSERV.IEEE.ORG

Reply To: k...@earthlink.net

Subject: Re: [PSES] Standards copyright lawsuit

 

The problem is, of course, that by incorporating copyrighted documents into the 
Code of Federal Regulations by reference, various agencies render invisible 
laws we are all required to obey -- unless we go to their reading rooms (I 
think) to find out. 

In practice?  We on this list work or have worked for firms who could afford to 
buy copies of their own.  But imagine one day finding that one has been 
convicted in absentia of speeding through a town without speed limit signs,  
limits available only by subscription.


Cortland Richmond  

On 10/7/2013 1135, Peter Tarver wrote:

There is occasionally much haranguing regarding how standards should be free.

 

The NFPA has joined ASHRAE and ASTM 
http://www.nfpa.org/newsandpublications/nfpa-journal/2013/september-october-2013/pov/first-word?order_src=C247
  to claim otherwise.

 

 

Regards,

 

Peter L. Tarver

 


 


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Re: [PSES] Job Opening for EMC Engineer

[Dward]

I tend to agree with Brian's statements.  

I would also add that even if experience is gained in another field, it is
probably not enough in the EMC field to meet the  they want several years
of experience criteria.  After all, it is not just engineering experience
they are looking for, it is specific EMC/EMI experience.

If you do want to make this field your career and are still working as an
intern, try getting the company to 'promote' you to a test engineer.  That
is one obvious way you can get more experience.  

While I am not a great one for the iNARTE thing (been there, done that,
dropped them all), it can help entry level engineers test themselves to see
how much they do or do not know and where they need to improve; and it seems
to influence some labs/companies in their hiring process.

In the end however, in this field, it is experience that counts and well,
you do not get experience except by experiencing. :) 


Dennis Ward
Senior Certification Engineer
PCTEST
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-Original Message-
From: Brian Oconnell [mailto:oconne...@tamuracorp.com] 
Sent: Monday, November 18, 2013 12:20 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Job Opening for EMC Engineer

There are some people that started out at one of the test labs or a CAB then
went into industry, but have yet to personally meet an industry compliance
person that had not started in another engineering job.

Many companies consider compliance an 'ancillary' position designated for
one of the designers; and some large corporations have a separate department
full of compliance people. Most of my colleagues seem to have reached a
compliance position through the back door, and very few do just EMC or just
safety.

If I were to retire (hah!) tomorrow, the person that I recommend to fill my
position would have done significant time as an engineer and tester that had
to fix a broken design. And this person must also understood basics of
mechanics and chemistry, as well as a being a bit of a code monkey.

Brian

From: Murisa, Egide [mailto:egide.mur...@molex.com]
Sent: Monday, November 18, 2013 11:32 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Job Opening for EMC Engineer

Hello EMC Experts,

Now that Don listed the job announcement, it got me thinking to ask you guys
who have been in this industry for a long time.
EMC Engineering is not something that is being taught in colleges; at least
not at the University I just graduated from.
After a few months working as an EMC/EMI Testing Intern, I became fascinated
by this engineering field, I feel like I want to do this my entire life.

However, companies do not want to hire entry level engineers as EMC
Engineers, they want several years of experience.
As experts, would you advise an entry level engineer like me to pursue this
career right away, or first find another Electrical Engineering position
first to gain an experience in the industry?  Your responses will be highly
appreciated.

Regards,

Egide

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Re: [PSES] Job Opening for EMC Engineer

[Dward]

Old EMC engineers never 'retire', they just attenuate their activities. J

 

Dennis Ward

Senior Certification Engineer

PCTEST

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that the e-mail or attachment(s) are free from computer virus or other
defect.  Thank you.

 

From: Ken Wyatt [mailto:k...@emc-seminars.com] 
Sent: Monday, November 18, 2013 1:40 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Job Opening for EMC Engineer

 

I also hired my replacement from MST after I retired.

 

Ken


___

Ken Wyatt

Wyatt Technical Services LLC

k...@emc-seminars.com

www.emc-seminars.com

Phone: (719) 310-5418

 

On Nov 18, 2013, at 2:36 PM, Richard Nute ri...@ieee.org wrote:








EMC Engineering is not something that is being taught in colleges

Electromagnetic Compatibility Laboratory

The Missouri ST Electromagnetic Compatibility (EMC) Laboratory supports EMC
research and education projects with a goal of developing the knowledge
base, tools and people necessary to solve today's EMC problems and address
the EMC problems of the future.

We hired at least one EMC engineer from UM.


Rich

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Re: [PSES] FCC draft comments on WiFi operation in channels 12 and 13

[Dward]

Michael gives a good over view of the situation.  The bottom line is that a
device CANNOT transmit on any frequency that it has not been shown to
comply.  So, even if the device passive scans, it still cannot transmit on
channels 12 and 13 unless those channels have been shown to comply in the
application for certification.  If channels 12 and 13 were part of the
initial filing, and they passive scan, then they can transmit.  Even if they
do not passive scan, but have been shown to comply with the rules they can
transmit.  If they have not been shown to comly then they cannot transmit -
period passive scan or not.

 

But here is the real issue.  If a device has been shown to comply and has
channels 12 and 13 on the grant, then there would be no need to passive scan
any more than on any of the other channels 1-11.  The question then is why
passive scan on these channels in the first place. The answer, other
countries use these channels and at the same or similar power as the other
channels; so using the incorrect concept that the US does not have these
channels, so it should be OK to passive scan because it won't transmit in
the US  is simply NOT true.  The US does have and allows these channels,
when properly tested and shown to comply and the channel frequency is
included on the grant.  Since the beginning of the WLAN craze, it has always
been this way.

 

While the FCC, also in the beginning of the TCB program, tried to 'mandate'
that only channels 1-11 could be used, that ended very quickly when a
certain manufacturer basically said, uh NO, nothing in the rules stops me
from using channels 12 and 13 as long as I comply to the rules.  Needless to
say, that manufacturer was and is correct and these channels have been
certifiable all along.  It is difficult, but it is doable. I can remember as
far back as very early in the TCB program when I certified my first channel
12 and 13 WLAN device.  So, they are out there and the concept that ' I
should be able to simply passive scan channel 12 and 13 for when the device
is in a country that uses these channels, and not worry about them in the US
because the US does not have these channels simply does not fly and never
has.  

 

In essence, the FCC has always allowed properly tested and properly powered
channels 12 and 13 passive scanning when the device has been shown to comply
to the rules in the channels it scans.  It is only when no evidence of
compliance for those channels exists that the FCC, rightfully so, says NO.  

 

Thanks 

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
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that the e-mail or attachment(s) are free from computer virus or other
defect.  Thank you.

 

From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Friday, January 31, 2014 1:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC draft comments on WiFi operation in channels 12 and
13

 

Hello Curt,

 

It has always been possible to use channels 12 and 13 in the USA because
they are perfectly in band channels.   However, it is very difficult for a
WLAN device to pass the FCC tests on those channels, so most manufacturers
simply choose to disable them.   Some manufacturers choose to reduce the
power on those channels.   Of course, if the whole device has sufficiently
low power, then it might pass channels 12 and 13 (or just 12) without
additional power reduction.

 

This means that most WLAN devices use only channels 1 to 11 but some do use
1 to 12 or 1 to 13.   (12 is easier to get passing than 13, since the tricky
test is a band edge issue)

 

It has always been the case that if you only test and certify your device up
to channel 11, then you cannot sell a device which could transmit on
channels 12 or 13.

 

In the past, manufacturers have asked the FCC if their devices can passive
scan on 12 and 13, even if their device is only certified up to channel 11.

Of course the answer was yes, you can passive scan because passive
scanning does not include transmission.

Of course, the assumption then should be that if the client device sees a
working access point on channel 12 or 13, it must not actually form a link
and transmit!

 

You can imagine that as a TCB, if we see an application which states that a
device transmits on channels 1 to 11 and can also passive scan on channels
12 and 13; it looks perfectly reasonable.   Many did not realise the need to
ask:  Please confirm that it 

Re: [PSES] Concerning FCC classification of digital devices

[Dward]

HI Neils

Your client should understand that it is not his point of view that matters,
it is what the FCC says about the device and what they say needs to be done
in order for the device to be authorized.   The simple fact that it can, at
any time, connect to a PC and download software makes this a Computer
Peripheral.  It does not matter how often it can be done, nor how many times
it is actually done, the fact that it can be done and that it is a consumer
device makes this device a Class B Computing Device Peripheral subject to
DoC or Certification, depending on how the grantee wants to address the
authorization.

Thanks 

 

 

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
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delete it from your computer system.  Usage of PCTEST email addresses for
non-business related activities is strictly prohibited. No warranty is made
that the e-mail or attachment(s) are free from computer virus or other
defect.  Thank you.

 

From: Niels Hougaard [mailto:n...@bolls.dk] 
Sent: Friday, March 14, 2014 7:05 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Concerning FCC classification of digital devices

 

Dear list members,

 

Being an independent testing facility, we have received a question from a
costumer regarding FCC classification. 

The consumer’s product is a small portable device for use with a musical
instrument. When the product is used normally, it is attached to the
instrument by audio Jack cables. The product is battery powered, but can be
powered by a general purpose adaptor. The product has a build-in
microprocessor and therefore clock frequencies that requires a
classification with regards to FCC (47 cfr part 15, §15.101).

For software update, programming purpose , and under these circumstances
also sometimes powering, the product has a MINI-B USB connector – depending
on variant, the product can either be supplied with or without the USB cable
in the shipping box.

 

Question is

– Is this product considered a “Class B Computer Peripheral” – which require
a DoC, and an accredited test report from an NVLAP accredited test lab and
appropriate FCC logo markings (DoC or certification procedure) ?

or 

– is the product considered  “Other Class B digital device - - “ – which
require only a verification and no FCC logo marking (Verification procedure)
?

 

Our costumer states that in their point of view the users only operates the
device with a computer connected, when they are putting the device into
operation initially or for reconfiguration, software upgrade or similar.
Therefore they claims it should not be considered Computer Peripheral since
the use of the product is very different from the use of typical computer
Peripherals like keyboard, mouse or printer.

 

Is having a USB connector enough to classify the product as a “Class B
Computer Peripheral”? Or is the use of the USB connector of importance+

 

Does anyone in here have experience from similar cases?

 

Regards,

Niels

Niels Hougaard

Bolls ApS

Ved Gadekæret 11F

DK-3660 Stenløse

Denmark

 

T: +45 48 18 35 66

F: +45 48 18 35 30

 mailto:n...@bolls.dk n...@bolls.dk

 http://www.bolls.dk/ www.bolls.dk

 

 

 

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Re: [PSES] Foam Table Documentation

[Dward]

Hi Michael

The FCC is not going to state any specific table material requirement.  While 
they recommend material like XPS (Styrofoam - an extruded polystyrene foam) 
above 1GHz, the only requirement is that the table be non-conductive at 
whatever frequency you are measuring. 

 

ANSI C63.4 says similar in that the table or other support surface used to 
raise the EUT to the designated height is to be nonconductive.  ANSI recommends 
“A method for evaluating the effects of the table on EUT radiated emissions is 
given in subclause 5.9 of CISPR 16-1-4:2007 for frequencies up to 1 GHz.”   It 
is up to the test lab to justify the material used and show its non-conductive 
nature if other than generally accepted materials such a Styrofoam are used 
above 1GHz.

 

Thanks 

 

 

​

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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited. No warranty is made that the e-mail 
or attachment(s) are free from computer virus or other defect.  Thank you.

 

From: Sundstrom, Mike [mailto:mike.sundst...@garmin.com] 
Sent: Friday, April 25, 2014 9:47 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Foam Table Documentation

 

Hello,

I have been asked to find where in the FCC/EU specifications it documents the 
use / requirement for the foam table on the test site. ANSI maybe?

I know it is a best engineering practice, but I’m having a hard time finding it 
in writing. I have been audited several times and even had notices when it 
wasn’t in use on an OATS.

 

 

Michael Sundstrom

Garmin Compliance Engineer

USA

(913) 440-1540

 

 

  _  


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Re: [PSES] radiated emissions testing may understate actual emissions, an example using a class D stereo amp

[Dward]

I do not want to speak for Mike Violette, but what I think he is referring
to by interference is the fact that, while the FCC could care less if two
part 15 devices interfered with each other, they do care if part 15 devices
interfere with licensed services. And it is in this area that the 'issue has
been solved' by the 'amazingly conservative' class B limits.  

Dennis Ward
Senior Certification Engineer
PCTEST
This communication and its attachments contain information from PCTEST
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-Original Message-
From: Richard Nute [mailto:ri...@ieee.org] 
Sent: Wednesday, June 04, 2014 10:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] radiated emissions testing may understate actual
emissions, an example using a class D stereo amp

On 6/4/2014 9:47 AM, Mike Violette wrote:

Class B limits are amazingly conservative, to which large populations of
devices ascribe.


Try using an ordinary AM radio beside a compact fluorescent lamp
as on a beside table.

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Re: [PSES] radiated emissions testing may understate actual emissions, an example using a class D stereo amp

[Dward]

While there is a distance difference between Class A and Class B, it is not
the distance that defines the Class, it is the Class that defines the
distance.  The definition of a Class B is similar, but not exactly the same
as for EN. Class B part 15 digital devices are defined as  A digital device
that is marketed for use in a residential environment notwithstanding use in
commercial, business and industrial environments.  A Class A digital device
is A digital device that is marketed for use in a commercial, industrial or
business environment, exclusive of a device which is marketed for use by the
general public or is intended to be used in the home.  This only means that
a Class B can be approved for both residential and commercial environments,
but a Class A is only approved for a commercial, industrial or business
environment but not approved for residential.

Currently the rules are very specific about the year of CISPR 22 that can be
used.  15.38 specifically states that the reference to CISPR pub 22 only
applies to the 1997 third edition version.  Also, CFR47 does not recognize
nor allow use of EN55022 in any year. While differences can be minute, it is
only the legally referenced document that can be used to show compliance.

Dennis Ward
Senior Certification Engineer
PCTEST
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-Original Message-
From: Sykes, Bob [mailto:bob.sy...@gilbarco.com] 
Sent: Wednesday, June 04, 2014 10:58 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] radiated emissions testing may understate actual
emissions, an example using a class D stereo amp

Charlie,

FCC Class B protection distance is 3m,  where Class A is 10m.  This
establishes their relationship.  Class B = X dBuV measured at 3m, and Class
A = X dBuV @ 10m. (where X = X)

EN 55022 Class B is for domestic environment which is an environment where
the use of broadcast radio and television receivers may be expected within a
distance of 10m or the apparatus concerned.

---
Rick,

AM is older than the FCC, but they are making noise (pun intended) about
revitalizing it.
https://apps.fcc.gov/edocs_public/attachmatch/DOC-323370A1.pdf

While LEDs are quiet, any mains powered LED lamp involves some form of
pulsed current and EMI.  LED lamps are regulated under FCC Part 15.  I tried
to use them (LED floods) in my shielded enclosure with dismal results.

For those interested; This article is mainly about visual flicker, but the
same principles apply to noise generation.
http://www.digikey.com/en-US/articles/techzone/2012/jul/characterizing-and-m
inimizing-led-flicker-in-lighting-applications

Here's a discussion of the RFI problem more from a regulatory perspective. 
http://www.emcrules.com/2011/07/radio-interference-from-led-lighting.html

-Bob Sykes



-Original Message-
From: Rick Busche [mailto:rick.bus...@qnergy.com]
Sent: Wednesday, June 04, 2014 1:26 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] radiated emissions testing may understate actual
emissions, an example using a class D stereo amp

Do we still have AM? Someone once called that was Ancient Modulation. :) I
suspect that in a few years fluorescent lamps will give way to LED
technology. As a side note, do LED lamps create EMI concerns?

-Original Message-
From: Richard Nute [mailto:ri...@ieee.org]
Sent: Wednesday, June 04, 2014 11:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] radiated emissions testing may understate actual
emissions, an example using a class D stereo amp

On 6/4/2014 9:47 AM, Mike Violette wrote:

Class B limits are amazingly conservative, to which large populations of
devices ascribe.


Try using an ordinary AM radio beside a compact fluorescent lamp as on a
beside table.

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Re: [PSES] radiated emissions testing may understate actual emissions, an example using a class D stereo amp

[Dward]

I have a paper copy somewhere in my standards dead file.  

Dennis Ward
Senior Certification Engineer
PCTEST
This communication and its attachments contain information from PCTEST
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-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Wednesday, June 04, 2014 12:40 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] radiated emissions testing may understate actual
emissions, an example using a class D stereo amp

In message 000a01cf8024$494154b0$dbc3fe10$@pctestlab.com, dated Wed, 4 Jun
2014, Dward dw...@pctestlab.com writes:

Currently the rules are very specific about the year of CISPR 22 that 
can be used.  15.38 specifically states that the reference to CISPR pub
22 only applies to the 1997 third edition version.

Only available as engraved stone tablets.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid
faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] FCC EMI Test and Ferrites on Cables

[dward]

The designer is flat wrong.
15.27 makes it clear that if such a 'special accessory' is required for
compliance of a device the they either must be provided with the device or
they must ensure a method such that the special accessory is provided to the
user of the device without additional charge and at the time of purchase.
And, while these special accessories must either be provided or made
available at the time of purchase at no additional charge, the manual must
give adequate instructions on how to install and use the special accessory.
A statement that ferrites is needed does not meet this requirement as it
would incur additional expense on the part of the user as ferrited cables
cost more.

The actual wording from 15.27 is as follows: 
(a) Equipment marketed to a consumer must be capable of complying with the
necessary regulations in the configuration in which the equipment is
marketed. Where special accessories, such as shielded cables and/or special
connectors, are required to enable an unintentional or intentional radiator
to comply with the emission limits in this part, the equipment must be
marketed with, i.e., shipped and sold with, those special accessories.
However, in lieu of shipping or packaging the special accessories with the
unintentional or intentional radiator, the responsible party may employ
other methods of ensuring that the special accessories are provided to the
consumer, without additional charge, at the time of purchase. Information
detailing any alternative method used to supply the special accessories
shall be included in the application for a grant of equipment authorization
or retained in the verification records, as appropriate. The party
responsible for the equipment, as detailed in §2.909 of this chapter, shall
ensure that these special accessories are provided with the equipment. The
instruction manual for such devices shall include appropriate instructions
on the first page of the text concerned with the installation of the device
that these special accessories must be used with the device. It is the
responsibility of the user to use the needed special accessories supplied
with the equipment. In cases where the manual is provided only in a form
other than paper, such as on a computer disk or over the Internet, the
information required by this section may be included in the manual in that
alternative form, provided the user can reasonably be expected to have the
capability to access information in that form.

Thanks 

Dennis Ward
This communication and its attachements contain information from PCTEST
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-Original Message-
From: Rudd, Adam [mailto:adam.r...@ncr.com] 
Sent: Thursday, September 4, 2014 5:03 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC EMI Test and Ferrites on Cables

It's all in Part 15, spread about.

47CFR15.27

47CFR15.31(j)


-Original Message-
From: Scott Douglas [mailto:sdouglas...@gmail.com]
Sent: Thursday, September 04, 2014 2:31 AM
To: EMC-PSTC@listserv.ieee.org
Subject: [PSES] FCC EMI Test and Ferrites on Cables

Fellow List persons...

Please help refresh a tired brain. A designer of a product tells us that he
passes FCC emissions testing if he puts ferrite sleeves (beads?) on the four
HDMI cables connected at the rear panel of the product.

He tells us that all he needs to do is add a statement in the user manual to
the effect that the HDMI output cables must have ferrite sleeves (beads?) on
them.

He says he does not need to specify manufacturer name and part number of the
ferrites.

He says he does not need to provide the ferrites with the product.

He also does not plan to include the HDMI output cables with the product
because every installation will have different length HDMI cables needed.

Now, my old brain thinks the above is not acceptable and that the FCC says
that anything special needed to pass FCC testing must be provided with the
product. And I am thinking that ferrites are special as you can't get them
at Walmart or Radio Shack or Ace Hardware. And not all ferrites are the
same.

Can anyone confirm my memory and maybe give a pointer to the part of the FCC
Rules that clarify this? Or have the rules changed over the years and I just
missed that part?

Thank you in advance for any and all comments, on list or off.

Best regards,
Scott

-

Re: [PSES] Battery certification issue

[dward]

Europe is dealing with separate and sovereign countries, so MRA and the like
between certifiers in all countries are needed.  But, if you go to one test
house in one country and another test house in that same country, even in
Europe, I am sure you will find that they do not all 'accept' each others
data.
The US in one country, not many.  So, while most if not all NRTLs in the US
have their own test labs, there is no need for any MRA between NRTLs within
the US.  And, as they are their own test house and as they also use
registered trademarks and registered certification marks, they also do not
need to accept test data from other test houses.  

It is extremely unlikely that this will change any time in the foreseeable
future.

Thanks 

Dennis Ward
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-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Thursday, September 4, 2014 9:40 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Battery certification issue

In message
2CF77CABFB3BC045B2724A8EF4182E7310324D46E0@P3PW5EX1MB13.EX1.SECURESERVER
.NET, dated Thu, 4 Sep 2014, jral...@productsafetyinc.com 
jral...@productsafetyinc.com writes:

Don't forget we are dealing with Registered Trademarks.  The NRTLs have 
complete discretion over who is allowed to use their mark.  They also, 
of course, have complete discretion over what test data they accept.

This is what we had in Europe with each country having its government agency
with trademark. It was decided long ago that it is not the best solution.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid
faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] RF shielding in clothing.

[dward]

Probably from the same people that brought you snake oil and the like.

 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
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or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: Thursday, September 4, 2014 6:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RF shielding in clothing.

 

‎All,

 

This is probably a curiosity. I ran across this article that claims to shield 
cell phones from hackers at specific operating frequencies. 

 

‎http://www.engadget.com/2014/09/04/1984-anti-surveillance-fashion/?utm_medium=feedutm_source=Feed_Classicutm_campaign=Engadgetncid=rss_semi

 

Has anyone here ‎had experience with this fabric and does it actually work?

 

Thanks, - doug

Douglas Powell
http://www.linkedin.com/in/dougp01   

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Re: [PSES] Failure of Radiated emission

[dward]

One of the reasons, many years ago, that a 'standard' setup was determined in 
both CISPR and ANSI standards was to relieve the never ending always present 
constant manipulation of cables and equipment.  While the EUT is to be 
operating in a typical use scenario, the setup should be as depicted in the 
standard.  This includes cables being bundled correctly, draped correctly and 
arranged on the test table correctly.  Variation of this setup goes back to the 
1980s when the constant equipment variations.  Let's not go back there.


Dennis Ward
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-Original Message-
From: Carpentier Kristiaan [mailto:kristiaan.carpent...@technicolor.com] 
Sent: Friday, September 5, 2014 7:36 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Failure of Radiated emission

Hi group,

A ITE product is tested to EN55022 Radiated emission with a well defined setup 
(cables, traffic, etc...) trying to find the worst case emissions and it passes.
I think finding the real worst case emission for all frequencies with one and 
the same set-up is in practice not possible in practice.

That same product is retested by a customer or in case of market surveillance 
campaigns, then it is most likely not tested with the same set-up and results 
may fail.
Would this be an issue or is it acceptable that it is retested with the same 
set-up as the initial testing? I refer to CISPR22, clause 8.4 that states that 
the operational conditions of the EUT shall be determined acc. to typical 
use.The operat mode and rationale shall be stated in the report.

So to me it looks sufficient to test a typical set-up, do your best to not make 
it best case and describe everything in the report.

Any other thoughts?

Best regards,
Kris Carpentier

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Re: [PSES] RF shielding in clothing.

[dward]

unlikely

Dennis Ward
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-Original Message-
From: Doug Powell [mailto:doug...@gmail.com] 
Sent: Friday, September 5, 2014 6:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF shielding in clothing.

Ah yes,

But can ‎coax cable with a double layer shield claim that much attenuation at 
all frequencies? 


Thanks, - doug

Douglas Powell
http://www.linkedin.com/in/dougp01
  Original Message
From: John Woodgate
Sent: Friday, September 5, 2014 7:51 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Reply To: John Woodgate
Subject: Re: [PSES] RF shielding in clothing.

In message 20140905132845.6037649.80805.13...@gmail.com, dated Fri, 5 Sep 
2014, Doug Powell doug...@gmail.com writes:

100 dB is pretty impressive.

It's a matter of a very fine, interlocked weave.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid 
faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] FCC EMI Test and Ferrites on Cables - a conundrum

[dward]

Since it is the ferrite that  is the ‘special accessory’, the company would not 
necessarily need to provide the cable, they would only have to provide the 
special accessory ferrite that would fit on the cable.  Or they would provide a 
means of obtaining the ferrite at the time of purchase for the cable.  Since 
ferrites are not typically over the counter easily accessible accessories that 
would also mean that most likely the actual ferrites would have to be provided 
along with instructions on how to install them on any cable the user purchases. 
 It does not matter if the customer purchased the cable at a later date, that 
is up to them, but what does matter is that the ferrites are dealt with AT THE 
TIME OF PURCHASE.

Thanks 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
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or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Pat Lawler [mailto:plawl...@gmail.com] 
Sent: Sunday, September 7, 2014 6:58 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC EMI Test and Ferrites on Cables - a conundrum

 

All,

 

I was looking through sales ads for electronics equipment, and saw a Blu-Ray 
disc player from a major company that came with an HDMI cable.

 

In the past, I would have just considered this a convenience to the buyer, like 
including batteries for remote controls.  Now, I'm wondering if the HDMI cable 
had ferrites, or came from a qualified vendor list of known-good cable 
manufacturers.

 

If a company has to supply a cable to control emissions, does that fact need to 
be reinforced in the user's manual?  For example, 'Use only supplied HDMI cable 
or equivalent', or 'Use only company brand products for best performance.'

 

Pat Lawler

plawl...@gmail.com mailto:plawl...@gmail.com 

 

On Thu, Sep 4, 2014 at 9:31 AM, Gary McInturff gary.mcintu...@esterline.com 
mailto:gary.mcintu...@esterline.com  wrote:

Playing the devil advocate here only because I find this interesting and I'm 
not advocating anything. Heck I'm probably just arguing for argument sake.

 If all cables are not equal as Ghery and note and the designer/manufacturer 
has knowledge of that don't the cables then become special accessories in their 
own right? Under 15.27 c) They would not normally be considered special 
accessory items  under the definition because they can be easily purchased at a 
multitude of locations.
15.27 c) Accessory items that can be readily obtained from multiple 
retail outlets are NOT (my emphasis)  considered to be special accessories ...
But given the knowledge of the designer/manufacturer that cables vary in 
performance and not all cables were tested the only assurance they have that 
the system will perform as intended is buy telling the consumer exactly which 
cable they must use buy name and brand. But if they do that then the cable 
isn't readily obtained from multiple outlets and is now by definition a 
special accessory. Paragraph 15.27 says that The party responsible for the 
equipment, as detailed in §2.909 of this chapter, shall ensure that these 
special accessories are provided with the equipment So now must the cable be 
provided?


Gmac

-Original Message-
From: Pettit, Ghery [mailto:ghery.pet...@intel.com 
mailto:ghery.pet...@intel.com ]
Sent: Thursday, September 04, 2014 12:46 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] FCC EMI Test and Ferrites on Cables

You are highly unlikely to find the ferrite prayer beads at Best Buy.  If you 
don't specify which ones to get you have no idea what the result will be.  I 
think you are correct, the beads must be shipped with the product.  The right 
ones, to boot.

Now, how does the designer know that he needs ferrite beads?  My experience has 
been that many (most?) HDMI cables do not have their shields terminated 
properly, if at all.  Once the shields are terminated correctly problems go 
away.  Could this be a better solution?

Ghery S. Pettit

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Re: [PSES] California Prop 65

[dward]

It must be tattooed on your forehead or right hand in permanent ink and the
letters must be of a size that can be easily read without the use of
magnification. :) 

Dennis Ward
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-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Thursday, October 2, 2014 8:48 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] California Prop 65

In message 86089981.284126.1412263641329.javamail.r...@comcast.net,
dated Thu, 2 Oct 2014, Mike Sherman - Original Message -
msherma...@comcast.net writes:

The basis of the law is that one should not expose citizens of 
California to any of these chemicals known to the State of... without 
first warning them.

People contain carcinogens, and I am going to LA next week. Will I have to
carry a sign?
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid
faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] California Prop 65

[dward]

Actually, since the US has no legal National Language, it needs to be in
English, Spanish, Vietnamese, Chinese (common character), Portuguese,
Italian, Gaelic, French, Lithuanian, Russian and German.  Hope you have a
big forehead. :)

Dennis Ward
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-Original Message-
From: Brian Oconnell [mailto:oconne...@tamuracorp.com] 
Sent: Thursday, October 2, 2014 9:20 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] California Prop 65

Yes, but must be in American and Spanglish.

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: Thursday, October 02, 2014 8:48 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] California Prop 65

In message 86089981.284126.1412263641329.javamail.r...@comcast.net,
dated Thu, 2 Oct 2014, Mike Sherman - Original Message -
msherma...@comcast.net writes:

The basis of the law is that one should not expose citizens of 
California to any of these chemicals known to the State of... without 
first warning them.

People contain carcinogens, and I am going to LA next week. Will I have to
carry a sign?
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid
faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Misuse mains cordset

[dward]

If the normal stated operating temperatures of a laptop is 30 degrees to 100
degrees F then leaving a laptop in a hot car in for example AZ would be
misuse as it is not being used within the parameters of its design.  And
there are ladders that are designed for use across small open crevasses so
it would not be misuse.  Misuse then is a very nebulous concept.


Dennis Ward
This communication and its attachements contain information from PCTEST
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defect.  Thank you.

-Original Message-
From: Richard Nute [mailto:ri...@ieee.org] 
Sent: Friday, October 17, 2014 5:16 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Misuse mains cordset

Misuse is just that:  Using a product for some use other than intended use.

Using a CD tray as a coffee cup holder is misuse.

Cleaning a keyboard with a wet rag is not misuse.

Chewing a pencil is misuse.  

Leaving a laptop in a hot car is not misuse.  

Using a chain saw to trim a hedge is misuse.

Standing on the top rung of a ladder is not misuse.

Using a ladder to cross a crevasse is misuse.

Not all misuse has the potential to cause an injury.  

Misuse is not usually foreseeable.  Misuse depends on what the user wants to
accomplish by using the product for other than its intended use.  Think
MacGyver.  I watched a TV program last night in which the heroes used a
sheet metal strap to carve away some wood so they could open the door of the
room in which they were locked.  They worked for
12 hours, and were unsuccessful.  The metal strap was being misused, as its
original purpose was to hold a shelf.


Best regards,
Rich

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Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe

[dward]

Also, if an NB did such a thing, I would think (hope) their AB would not
only slap their hands, but either suspend them or remove their accreditation
as an NB.

Dennis Ward
This communication and its attachements contain information from PCTEST
Engineering Laboratory, Inc., and I sintended for the exclusive use of the
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that the e-mail or attachments(s) are free from computer virus or other
defect.  Thank you.

-Original Message-
From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: Thursday, October 30, 2014 4:43 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you
sell wireless devices into Europe

I think Nick was being diplomatic - they can do no such thing, any more than
they could give a certificate to the ATEX or MDD directives unless suitably
appointed.

Charlie

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 30 October 2014 11:26
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you
sell wireless devices into Europe

In message
2655b21dc209421abdc4eeb95de1a...@bn1pr04mb309.namprd04.prod.outlook.com
, dated Thu, 30 Oct 2014, Hooper, Nick nick.hoo...@ul.com writes:

So a RTTE NB has no appointment (NANDO database listing) to issue a NB 
EU type examination Certificate for the RED, they are, at best, 
misleading their customers, they cannot give such a certificate.

True, of course, but they can issue a certificate with a suitable
disclaimer, so as not to mislead.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid
faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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-

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Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe

[dward]

Competent and reliable = interesting concept.

Until the RED is actually usable existing means of NB appointments do not do a 
lot in the area of competence.  For example, a TCB has to show competence in 
the area they certify.  They must prove that reviewers can actually do the 
testing and they need to show more than just average knowledge.  The same 
cannot really be said about NBs.  While it may be assumed all NBs have the same 
level of competence, that simply is not the case.  

The RED, to its credit, does try to address this situation by requiring 
significantly more expertise to be shown by both the Notifying Authorities and 
Notified Bodies.  By putting more stringent requirements and more uniform 
requirements on all Notifying Authorities this at least levels the playing 
field and will prevent or slow down the approval of less competent NBs.  

 

Thanks 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and I sintended for the exclusive use of the 
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related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Anthony Thomson [mailto:ton...@europe.com] 
Sent: Thursday, October 30, 2014 2:16 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

 

But the thread started with Nick Hooper saying that Notified Body's were 
already, and have issued opinions against the RED. This is where my interest 
lies, in finding a NB to issue an opinion against the RED in the coming weeks, 
when I stumbled across Nicks post questioning the validity of these NB opinions.

 

I though NB's were supposed to be competent and reliable. I often rely on them 
to ratify and confirm our regulatory position. Sounds pretty serious to me and 
I find my confidence in the whole NB system waning!

 

T

 

 

Sent: Thursday, October 30, 2014 at 8:52 AM
From: Michael Derby micha...@acbcert.com mailto:micha...@acbcert.com 
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

Just to add to the conversation, I will throw in a little practicality…….

 

There are two primary compliance routes for manufacturers to use the RE 
Directive, as with the RTTE Directive.

A manufacturer can fully apply the harmonised standards.

Or, a manufacturer can consult a Notified Body to obtain an opinion when 
harmonised standards are not fully applied.

(I guess you could also add that there is the option for a quality assessment 
(Annex V of RTTE), using a Notified Body).

 

For the RE Directive:

There are no harmonised standards.

There are no Notified Bodies.

 

So, from a practical point of view, it is also impossible.

 

 

Michael.

 

 

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

 

From: Anthony Thomson [mailto:ton...@europe.com]
Sent: 29 October 2014 15:00
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

 

Hi Charlie,

 

Thanks for your assistance, but I still can't see anything preventing one 
claiming compliance to the RED. It's an EU directive which does appear to be 
currently 'in force' across Europe, though not yet 'enforceable' by law.

 

So why can't you claim compliance to the RED (assuming you do)? To coin a 
phrase... there's no law against it. Or is there?

 

See my ongoing questions below.

 

Regards,

Tony

Sent: Wednesday, October 29, 2014 at 12:59 PM
From: Charlie Blackham char...@sulisconsultants.com
To: Anthony Thomson ton...@europe.com, EMC-PSTC@LISTSERV.IEEE.ORG 
EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

Tony

Article 48 says that the existing legislation (RTTE or EMC+LVD) may be used 
for equipment within scope of RED until 13 June 2017, provided it was on the 
market before 16 June 2016.

T: Yes, I can see that Article 48 permits optionally applying the RTTED (et. 
al.), to new products, for 1 year after the RED becomes enforceable under law 
on 13 June 2016. However, I can't see how this sets the earliest date that 
compliance against the RED can be claimed, and this is what I'm trying to get 
to.

Article 49 says that RED shall be applied from 13 June 2016 (in other words, it 
is won’t 

Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe

[dward]

In a perfect world, all Authorizing Bodies, NBs, TCBs and test labs would do 
everything right.  Alas, they world is far less than perfect and errors abound. 
 Accreditation helps, but it is only paper and does not monitor the actual work 
involved. It relies on the integrity and reliability of the entity accredited.  
However, as long as the push is cheaper, faster and less testing, many will 
feed at the bottom of the barrel where these traits seem to fester.

There are many good NBs, many good TCBs and many good CBs in the world and it 
only takes one or two ‘bottom feeder’ to spoil the entire taste of the pie.

 

Thanks  

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and I sintended 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Thursday, October 30, 2014 2:26 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

 

It’s a valid concern Tony.   I imagine that ADCO in Europe are probably 
(hopefully) looking closely at any Notified Body who would issue a certificate 
for a Directive if they are not authorised to.   There are no Notified Bodies 
designated to the RE Directive.

 

I would like to think your waning confidence is in questionable Notified 
Bodies, rather than in the whole NB system.

In the same way as you might be happy with the idea of FCC TCBs, despite the 
fact that some TCBs get it wrong.

In the same way as you might be happy with the idea of test labs, despite the 
fact that some of them don’t seem to know how to test.

 

 

Michael.

 

 

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

 

From: Anthony Thomson [mailto:ton...@europe.com] 
Sent: 30 October 2014 09:16
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

 

But the thread started with Nick Hooper saying that Notified Body's were 
already, and have issued opinions against the RED. This is where my interest 
lies, in finding a NB to issue an opinion against the RED in the coming weeks, 
when I stumbled across Nicks post questioning the validity of these NB opinions.

 

I though NB's were supposed to be competent and reliable. I often rely on them 
to ratify and confirm our regulatory position. Sounds pretty serious to me and 
I find my confidence in the whole NB system waning!

 

T

 

 

Sent: Thursday, October 30, 2014 at 8:52 AM
From: Michael Derby micha...@acbcert.com mailto:micha...@acbcert.com 
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

Just to add to the conversation, I will throw in a little practicality…….

 

There are two primary compliance routes for manufacturers to use the RE 
Directive, as with the RTTE Directive.

A manufacturer can fully apply the harmonised standards.

Or, a manufacturer can consult a Notified Body to obtain an opinion when 
harmonised standards are not fully applied.

(I guess you could also add that there is the option for a quality assessment 
(Annex V of RTTE), using a Notified Body).

 

For the RE Directive:

There are no harmonised standards.

There are no Notified Bodies.

 

So, from a practical point of view, it is also impossible.

 

 

Michael.

 

 

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

 

From: Anthony Thomson [mailto:ton...@europe.com]
Sent: 29 October 2014 15:00
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

 

Hi Charlie,

 

Thanks for your assistance, but I still can't see anything preventing one 
claiming compliance to the RED. It's an EU directive which does appear to be 
currently 'in force' across Europe, though not yet 'enforceable' by law.

 

So why can't you claim compliance to the RED (assuming you do)? To coin a 
phrase... there's no law against it. Or is there?

 

See my ongoing questions below.

 

Regards,

Tony

Sent: Wednesday, October 29, 2014 at 12:59 PM
From: Charlie Blackham char...@sulisconsultants.com
To: Anthony Thomson ton...@europe.com, 

Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe

[dward]

I love mixed metaphors

 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and I sintended 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Friday, October 31, 2014 10:30 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

 

In a perfect world, all Authorizing Bodies, NBs, TCBs and test labs would do 
everything right.  Alas, they world is far less than perfect and errors abound. 
 Accreditation helps, but it is only paper and does not monitor the actual work 
involved. It relies on the integrity and reliability of the entity accredited.  
However, as long as the push is cheaper, faster and less testing, many will 
feed at the bottom of the barrel where these traits seem to fester.

There are many good NBs, many good TCBs and many good CBs in the world and it 
only takes one or two ‘bottom feeder’ to spoil the entire taste of the pie.

 

Thanks  

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and I sintended 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Thursday, October 30, 2014 2:26 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

 

It’s a valid concern Tony.   I imagine that ADCO in Europe are probably 
(hopefully) looking closely at any Notified Body who would issue a certificate 
for a Directive if they are not authorised to.   There are no Notified Bodies 
designated to the RE Directive.

 

I would like to think your waning confidence is in questionable Notified 
Bodies, rather than in the whole NB system.

In the same way as you might be happy with the idea of FCC TCBs, despite the 
fact that some TCBs get it wrong.

In the same way as you might be happy with the idea of test labs, despite the 
fact that some of them don’t seem to know how to test.

 

 

Michael.

 

 

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

 

From: Anthony Thomson [mailto:ton...@europe.com] 
Sent: 30 October 2014 09:16
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

 

But the thread started with Nick Hooper saying that Notified Body's were 
already, and have issued opinions against the RED. This is where my interest 
lies, in finding a NB to issue an opinion against the RED in the coming weeks, 
when I stumbled across Nicks post questioning the validity of these NB opinions.

 

I though NB's were supposed to be competent and reliable. I often rely on them 
to ratify and confirm our regulatory position. Sounds pretty serious to me and 
I find my confidence in the whole NB system waning!

 

T

 

 

Sent: Thursday, October 30, 2014 at 8:52 AM
From: Michael Derby micha...@acbcert.com mailto:micha...@acbcert.com 
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

Just to add to the conversation, I will throw in a little practicality…….

 

There are two primary compliance routes for manufacturers to use the RE 
Directive, as with the RTTE Directive.

A manufacturer can fully apply the harmonised standards.

Or, a manufacturer can consult a Notified Body to obtain an opinion when 
harmonised standards are not fully applied.

(I guess you could also add that there is the option for a quality assessment 
(Annex V of RTTE), using a Notified Body).

 

For the RE Directive:

There are no harmonised standards

Re: [PSES] Brick power supplies and test errors (two topics)

[dward]

Surprise surprise:)

As long as assessment of labs is being done by people not even in the proper 
field of expertise, should we really expect more??

 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and I sintended 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Grasso, Charles [mailto:charles.gra...@echostar.com] 
Sent: Wednesday, December 17, 2014 9:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brick power supplies and test errors (two topics)

 

It would appear that the best efforts of lab accreditations are not living up 
to expectations?

Or am I expecting too much? 

 

Best Regards

Charles Grasso

Compliance Engineer

Echostar Communications

(w) 303-706-5467

(c) 303-204-2974

(t) 3032042...@vtext.com mailto:3032042...@vtext.com 

(e) charles.gra...@echostar.com mailto:charles.gra...@echostar.com 

(e2) chasgra...@gmail.com mailto:chasgra...@gmail.com 

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: Monday, December 15, 2014 4:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] Brick power supplies and test errors (two topics)

 

Doug:

 

Did you create a write-up on what those errors specifically were, and how it 
happened that you noticed them in time to control them?

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

From: Doug Smith [mailto:d...@emcesd.com] 
Sent: Sunday, December 14, 2014 3:49 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: [PSES] Brick power supplies and test errors (two topics)

 

Hi All,


When I was at Auspex Systems (1996-2001) we had 8 EMC radiated emissions tests 
performed on our equipment (three 1500 lb cabinets full of disk drives). Of 
these, 4 tests had significant test errors, two major and two minor errors, but 
all had a large impact to our company! The tests were done at three different 
labs over time, all made at least one error. Trust but verify.

Doug

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Re: [PSES] Brick power supplies and test errors (two topics)

[dward]

Exactly.  While assessors may look over paperwork, that does not actually mean 
those involved in testing know what the standard to which they are testing 
actually says or if they do that they actually test to them.  Cannot tell you 
how many times I review reports from supposedly accredited labs and see that 
the test results make no sense or are just flat wrong.

It is not just from one economic area either, it seems almost pandemic 
sometimes.  

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and I sintended for the exclusive use of the 
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and/or legally privileged.  Any unauthorized use that may compromise that 
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the sender immediately if you receive this communication in error, and delete 
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or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Pettit, Ghery [mailto:ghery.pet...@intel.com] 
Sent: Wednesday, December 17, 2014 2:36 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brick power supplies and test errors (two topics)

 

Yes, but the standards I’m thinking of are core to the computer industry.  
CISPR 22, CISPR 32, CISPR 24, ANSI C63.4.  Really disturbing when you see key 
things that aren’t set up properly.  It makes you wonder what the 
qualifications are of the on-site assessors.  Paperwork is usually fine, the 
assessors understand ISO/IEC 17025.

 

Ghery S. Pettit

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: Wednesday, December 17, 2014 1:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] Brick power supplies and test errors (two topics)

 

Ghery:

 

I found that business conditions have created large labs which strive to 
provide one-stop compliance services, and that this concept is subject to 
corruption by enthusiasm. By that, I mean that the labs often have a little 
subsection which is tasked with doing nothing but expanding the range of 
accreditations; these are the chaps who paper entire hallways with certificates 
of accreditation, allowing you to take comfort that if you ever needed a 
machine safety certificate for Kleptostan, you were already in the right place. 
A certain disconnect exists between these certificate harvesters (think 
marketing) and the other part of the lab (think engineering) which actually has 
to do that rare and idiosyncratic test.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

From: Pettit, Ghery [mailto:ghery.pet...@intel.com] 
Sent: Wednesday, December 17, 2014 10:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] Brick power supplies and test errors (two topics)

 

I brought up some serious problems with accredited labs at the ASC C63 meetings 
in Mesa last month.  One accrediting body seems interested in dealing with the 
issue, the others not so much.  It’s so much fun to go into a lab that isn’t 
properly equipped to perform tests listed on its Scope of Accreditation.

 

Ghery S. Pettit

 

From: Grasso, Charles [mailto:charles.gra...@echostar.com] 
Sent: Wednesday, December 17, 2014 9:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] Brick power supplies and test errors (two topics)

 

It would appear that the best efforts of lab accreditations are not living up 
to expectations?

Or am I expecting too much? 

 

Best Regards

Charles Grasso

Compliance Engineer

Echostar Communications

(w) 303-706-5467

(c) 303-204-2974

(t) 3032042...@vtext.com mailto:3032042...@vtext.com 

(e) charles.gra...@echostar.com mailto:charles.gra...@echostar.com 

(e2) chasgra...@gmail.com mailto:chasgra...@gmail.com 

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: Monday, December 15, 2014 4:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] Brick power supplies and test errors (two topics)

 

Doug:

 

Did you create a write-up on what those errors specifically were, and how it 
happened that you noticed them in time to control them?

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

From: Doug Smith [mailto:d...@emcesd.com] 
Sent: Sunday, December 14, 2014 3:49 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: [PSES] Brick power supplies and test errors (two topics)

 

Hi All,


When I was at Auspex Systems (1996-2001) we had 8 EMC radiated emissions tests 
performed on our equipment (three 1500 lb cabinets full of disk drives). Of 
these, 4 tests had significant test errors, two major and two minor errors, but 
all had a large impact to our company! The tests were done at three different 
labs over time, all made at least one error. Trust but 

Re: [PSES] test errors

[dward]

I don’t think the original discussion is or was centered on testing ‘black 
boxes’ or even the fact that a manufacturer should know his product and what it 
takes to get it in the market. The original discussion was that labs which are 
supposed to know what they are doing, because they have a standards listed on 
their scope of accreditation, may not actually know what they are doing.  It 
does not deal with off the wall testing specific to a particular manufacturer, 
it deals with common everyday expertise.

Any lab can test anything or anyway they want, but if they are saying the 
testing is to a specific standard and is in accordance with their scope, then 
they need to make sure it is.  If it is not, then the accreditations generally 
only say (paraphrased) ‘if you didn’t test it correctly to the std on the 
scope, then don’t say you did.  If you did test it according to your scope, 
then the results should clearly show you did.’

Thanks 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and I sintended 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Grasso, Charles [mailto:charles.gra...@echostar.com] 
Sent: Thursday, December 18, 2014 1:06 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] test errors

 

Hello Brian – with regards to the “Top Secret” box. It is my understanding that 
the customer it responsible
for assuring that their product is tested to the correct standard and the test 
lab is responsible for testing
the delivered product  according to that standard. So I would say that yes – 
you did what the customer asked
so you tested the product correctly.

 

Best Regards

Charles Grasso

Compliance Engineer

Echostar Communications

(w) 303-706-5467

(c) 303-204-2974

(t) 3032042...@vtext.com mailto:3032042...@vtext.com 

(e) charles.gra...@echostar.com mailto:charles.gra...@echostar.com 

(e2) chasgra...@gmail.com mailto:chasgra...@gmail.com 

 

From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: Thursday, December 18, 2014 8:26 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] test errors

 

Well said. I’m really enjoying this topic.

 

Expecting customers to be Compliance Test experts would be nice, but a little 
like expecting people to have to be auto mechanics to be able to take their 
cars to the repair shop. But like auto repair shops, EMC and Safety test labs 
are all in it for the money. They have payroll to meet just like any business 
and they are not likely to turn away work because it is something they are not 
100% sure they know how to properly test until the customer arrives with it. 
And in those cases I’m sure they do the best they can.

 

We also expect test labs to be experts in hundreds of standards and how they 
apply to an infinite number of products, configurations, and supporting 
equipment; many of which they may know absolutely nothing about how it even 
works.  Such expectations are unrealistic. 

 

I once tested a metal box with something moving inside. “Top Secret” according 
to the customer. Did we test it correctly? How would I know? We did what the 
customer wanted.  

 

Yup, errors and mistakes are going to happen. That is part of life. Though I am 
not a fan of accreditation, one cannot expect anything more than an attempt to 
minimize the errors. I don’t think a stack of procedures in a file or book in 
the manager’s office is very affective at eliminating error, but it is better 
than nothing. And as test labs become more competitive, a long list of 
accreditations is like money in the bank.  

 

Personally, I like the “Accountability Method” or as mentioned early the 
“looking over the shoulder” method. This is where the test setup and testing is 
overseen by a second person in the lab who can most often see problems the main 
tester cannot see right in front of his face. It is like having someone proof 
read your memos (I cannot believe I make so many typos).  

 

Many of our customers hire Consultants to babysit or oversee their EMC testing. 
Some of them drill me all day long about how we do things. It can be 
exhausting. But, I prefer such customers over those who come in and don’t know 
anything about anything. 

 

I once tested a Sand Blast Cabinet which comprised of a metal box with a 
brushless AC blower motor and incandescent light bulb. I tried to explain that 
this product did 

Re: [PSES] EMC on Industrial Cut-Off Saws

[dward]

Nah – they just had a bigger lobby when the FCC rules were put in place:)

So, that is why no one invites me to dinner

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and I sintended 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Wednesday, February 4, 2015 1:45 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC on Industrial Cut-Off Saws

 

It would be disappointing if emissions from household items were ever fully 
eliminated because it’s the only way I can explain to people what I do for a 
living.

 

“What do you do…..”

 

“Well, you know that crackling noise you get from the radio when someone is 
using a hair dryer…..”

 

If they fix that, I’ll have to start talking about SAR levels and then I won’t 
get invited to dinner any more.

 

 

Michael.

 

 

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

 

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: 03 February 2015 15:22
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] EMC on Industrial Cut-Off Saws

 

Same is true of other power tools, drills, vacuum cleaners, etc.  I believe 
‎the thinking is these are only intermittent use.  

 

 

 - doug

Douglas Powell
http://www.linkedin.com/in/dougp01   


From: Bill Stumpf

Sent: Tuesday, February 3, 2015 8:14 AM

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

Reply To: Bill Stumpf

Subject: Re: [PSES] EMC on Industrial Cut-Off Saws

 

Based on inquiries I've made to the FCC  IC regarding digitally controlled 
power tools, the FCC currently exempts these devices from Part 15 technical 
regulations.  Industry Canada compliance testing should be done to ICES-001 
requirements.

 

 

Bill

 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Monday, February 02, 2015 10:51 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] EMC on Industrial Cut-Off Saws

 

Code of Federal Regulations (CFR) Title 47 Telecommunication Chapter 1 
Subchapter A Part 15

15.103 Exempted devices. 

(c) A digital device used exclusively as industrial, commercial, or medical 
test equipment.

 

Sounds like it would be FCC part 15 exempt providing the user stops operating 
the device upon a finding by the Commission or its representative that the 
device is causing harmful interference.

 

Don’t know about Canada yet but they usually follow the US.

 

-Dave

 

 

From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: Monday, February 02, 2015 5:12 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: [PSES] EMC on Industrial Cut-Off Saws

 

I am not at all familiar with this category of products so please excuse my 
ignorance which is an industrial cut-off saw with a 5hp electric motor for 
cutting steel rods, and such.  

 

Most of these basic model saws have no high frequency devices and brushless AC 
motors so they do not generate EMI. However, the more expensive models have 
Inverters (Frequency Drives) to slow start/stop the motor and act as a break.

 

We evaluated a saw from a company who says they do not require EMC testing on 
their saws even when they use the Inverter, as long as they follow the 
installation instructions from the inverter manufacturer (yea, I just about 
fell out of my chair). We tested one of these saws and failed CISPR 11 Class A 
Conducted Emissions by 50db (if was a prototype saw not on the market).  How do 
these people sleep at night?

 

So here is my question. Does the US and Canada require Emissions testing on 
Industrial Saws?  Same question for Europe. I assume EN 55011 Class A is 
mandatory in Europe on such a devices. 

 

Please confirm (sanity check). 

 

Thanks,

The Other Brian

 

 

  _  


LECO Corporation Notice: This communication may contain confidential 
information intended for the named recipient(s) only. If you received this by 
mistake, please destroy it and notify us of the error. Thank you. 


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Re: [PSES] RS FSP Spectrum Analyzer

[dward]

In the field of certification or compliance testing the workings of analyzers 
can be a daunting task to understand.  However, understanding the analyzer and 
what it does is a must - especially with the newer analyzers.  These devices do 
things that are amazing and that reduce test time. However, they also have 
issues that, if the engineer does not understand, can lead to a false security 
of compliance, regardless if the device is or is not CISPR 16 compliant.   For 
example, how many engineers can tell why the newer analyzers can sometimes show 
occupied bandwidths smaller than a 6dB bandwidth?  And how many would go to the 
trouble to remeasure to get reliable numbers or even care if the numbers make 
sense or even read the analyzer manual to find out why this happens?

Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and I sintended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
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or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: Alexandru Guidea [mailto:alexandru.gui...@cae.com] 
Sent: Tuesday, February 17, 2015 10:48 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RS FSP Spectrum Analyzer

Hello Grace,

Purchasing a new compliance spectrum analyzer is a big expenditure and the 
decision to select one particular type or brand can have long term impact.
Such an instrument will usually need technical support on SW, HW, and firmware 
upgrades for optimal operation and keeping up with evolving standards. We've 
recently bought an RS SA and are very disappointed with their after sales 
service. I won't go into the details of our issue, but being a new customer of 
RS, we did not expect their technical support to be lacking in resolution. 
We've been a long-time customer of their main competitor and always had 
excellent support.

Alexandru Guidea
CAE Inc.

Alexandru G.


-Original Message-
From: Grace Lin [mailto:graceli...@gmail.com]
Sent: February-16-15 4:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RS FSP Spectrum Analyzer

Dear Members,

Is anyone familiar with the RS FSP spectrum analyzer
(http://www.rohde-schwarz.com/en/product/fsp-products_63492-8043.html)
and would like to share comments/experience?

A friend advises me that this is not good for my purpose (taking data for 
regulatory compliance of wireless devices).  I am looking/searching for 
justifications to request a new one.

Thank you very much.

Best regards,
Grace Lin

-


-

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Re: [PSES] RS FSP Spectrum Analyzer

[Dward]

HI Grace
If it meets CISPR 16 and/or ANSI requirements, then it is OK to use for this 
type measurement.  You just have to be careful and make sure the engineer pays 
attention to the values and understands how the device works.

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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited. No warranty is made that the e-mail 
or attachment(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: Grace Lin [mailto:graceli...@gmail.com] 
Sent: Monday, February 16, 2015 1:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RS FSP Spectrum Analyzer

Dear Members,

Is anyone familiar with the RS FSP spectrum analyzer
(http://www.rohde-schwarz.com/en/product/fsp-products_63492-8043.html)
and would like to share comments/experience?

A friend advises me that this is not good for my purpose (taking data for 
regulatory compliance of wireless devices).  I am looking/searching for 
justifications to request a new one.

Thank you very much.

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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formats), large files, etc.

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Re: [PSES] RS FSP Spectrum Analyzer

[dward]

Since even radiated spurious emissions for FCC licensed radios is ERP/EIRP 
measurements, currently it would not matter a whole lot.  Currently the only 
requirement to use CISPR 16 for analyzers for licensed devices is in TIA603 
when TEM cells are used.  

However, for part 15 devices, where radiated emissions, especially restricted 
band, is not ERP/EIRP it is a requirement for the analyzer to meet ANSI or 
CISPR.  When the new ANSI C83.26 is voted in and then accepted by the FCC, even 
for licensed devices analyzers making certain type measurements will be 
required to meet CISPR or ANSI requirements.  It is already a requirements in 
C63.10.  

Dennis Ward
This communication and its attachements contain information from PCTEST 
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-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] 
Sent: Wednesday, February 18, 2015 12:55 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RS FSP Spectrum Analyzer

I believe CISPR16 is for EMC only. 
If it is for radio aspects not being spurious emissions, CISPR16 is not 
applicable.
I do own a FSP and the test results obtained are very suitable for radio, and 
the EMC  test results (with a pre-amp) do match our TEST receivers result very 
good and accuracy is generally better. 
Note that for radio measurements additional attenuators and filters are really 
necessary to attenuate/ suppress the carrier frequency and power RS advertised 
this as a pre-compliance EMC receiver, and I suppose it is not a CISPR16 
compliant device. However, within limits , compliant results can be obtained.


Gert Gremmen



-Original Message-
From: Grace Lin [mailto:graceli...@gmail.com]
Sent: Monday 16 February 2015 22:02
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RS FSP Spectrum Analyzer

Dear Members,

Is anyone familiar with the RS FSP spectrum analyzer
(http://www.rohde-schwarz.com/en/product/fsp-products_63492-8043.html)
and would like to share comments/experience?

A friend advises me that this is not good for my purpose (taking data for 
regulatory compliance of wireless devices).  I am looking/searching for 
justifications to request a new one.

Thank you very much.

Best regards,
Grace Lin

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Attachments 

Re: [PSES] Safety standards versus safety engineering

[dward]

“Risk Assessment” or in plain English – How many people have to get injured or 
killed before anything is done that should have been done in the beginning 
anyway.

 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and I sintended for the exclusive use of the 
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or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Douglas Powell [mailto:doug...@gmail.com] 
Sent: Friday, March 6, 2015 10:03 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

 

Mike,

 

...dismissal of identifiable risks...





Isn't this the main problem with Risk Assessment in general.   The people 
assigned to identify risks and catalog their risk values are almost always the 
same ones who design and built the product. The same goes for FMEA, and PFMEA.  
The assignment of risk values is very subjective, allowing those involved to 
say the chances of that happening are .  And the team agrees to set the  
likelihood of occurrence very low.





I watched exactly this scenario occur in real life when through a chain of 
events a 7,000 CFM cooling fan was activated while a worker had his hands in 
the exhaust duct.   1) He should not have been working in there with power 
applied, 2) Communications to the Xylinx fan controller had been established 
through the company ethernet, 3) The default IP address of the controller had 
not been changed, 4) The digital engineer was working on a similar proto board, 
in another office building, with the same default IP address configured on his 
board, 5) The proto board was connected to the same network, as is their usual 
practice,  6) The digital engineer enabled the fan on his proto board and 
simultaneously enabled the fan in the unit on the manufacturing floor to full 
speed. 





Risk Assessment said this was very unlikely event and the technician nearly 
paid for it.   The mitigation was to simply reassign the IP address for every 
circuit board on receipt at incoming inspection and to reinforce LOTO safety 
procedures on the shop floor.  





Oh, and by the way, this product was already fully certified to applicable 
standards.





Thanks, - doug





Douglas Powell

Skype: doug.powell52

http://www.linkedin.com/in/dougp01   














From: Mike Sherman - Original Message -

Sent: Friday, March 6, 2015 10:17 AM

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

Reply To: msherma...@comcast.net mailto:msherma...@comcast.net 

Subject: Re: [PSES] Safety standards versus safety engineering

 

Re ...and dismissal of identifiable risks deemed conveniently unlikely to 
occur.

 

This is a real issue in organizations, and was a key contributor to the 
Columbia space shuttle disaster.

 

NASA's Columbia Accident Investigation Board's final report explores this 
contributor a lot. The report is easy to find on the web.

 

As safety professionals, we are more effective if we understand the psychology 
that makes such dismissal attractive and learn to counteract it.

 

Mike Sherman

Graco Inc.

 

  _  

From: CR k...@earthlink.net mailto:k...@earthlink.net 
To: EMC-PSTC EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Sent: Friday, March 6, 2015 6:46:33 AM
Subject: Re: [PSES] Safety standards versus safety engineering

 

On 3/6/2015 2:56 AM, John Woodgate wrote:
 Making the designers responsible for the safety of the design (as 
 opposed to the safety of what is shipped, over which they have no 
 control) immediately eliminates any claim that it's not their problem 
 and/or cramps their style. 
I'm not a Safety Engineer; my work is in EMC but...

 

Some years ago, after the EU tripled the immunity requirement for 
medical equipment, I had occasion to speak with a management type 
complaining that a test plan I'd written required them to do tests no 
other firm did, and would place them at a competitive disadvantage. 
Asked why, I said: Because I don't want you to kill people whose lives 
you're trying to save. *

 

End of discussion.

 

* For an example of what I was thinking about, see number 3 Banana Skin  
at /http://www.compliance-club.com/archive/old_archive/Bananaskins.htm/ 
.  In any event no one had HAD to test to those levels before, and he 
didn't want to start.

 

It seems to me that many firms waste and disparage the pride its own 
engineering staff takes in work they do, binding it in a web of Six 

Re: [PSES] Safety standards versus safety engineering

[dward]

“Obvious things” – you mean like “Duh, this is a knife, if you run the narrow 
side over your hand you will probably bleed and need stitches or at minimum a 
band aide”, or “Duh, this is a hot cup of coffee, don’t place in your lap, it 
might burn you.”

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
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or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Friday, March 6, 2015 11:14 AM
To: 'dward'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Safety standards versus safety engineering

 

Good evening

 

My “ three pennyth” / “few cents worth” – for what they are worth :):

 

Regardless of what product or system is under discussion, there is rarely (if 
ever?) a rationale for not doing relevant risk assessments  - what may put some 
people off doing it, or doing it properly, could be (in no particular order, 
and there are probably many more!) any or all of the following:

-   They don’t know which risk assessment standard/methodology to apply

-   They don’t believe it is necessary or would help

-   They don’t actually know what it involves in respect of their product

-   They believe the product already complies with a “standard” and that is 
“good enough” – even if that standard has no overt risk assessment requirements

-   They think they already know what the risks are, and what they have 
already done to mitigate them is “good enough”, and so any chance of a real 
accident is remote to “impossible”

-   They don’t think wider than their own “box” in terms of the effects it 
could have on other “boxes” with which it might be, or conceivably be used, 
and/or by whom

-   They think risk assessment only applies to basic occupational safety 
(health  hygiene, climbing ladders, manual handling, etc.) within their 
premises or domain – and that’s someone else’s responsibility

-   They don’t want to risk finding out something that they really won’t 
like

-   The “guy at the top” believes one or more of the above will cause him 
more harm than good, and cost him a lot of time and money in the process, and 
won’t sanction it even when his employees state clearly that it is necessary

-   The “guy at the top” is working to tight time/cost targets and means to 
“get the job done” regardless of anything else – and then deal with any 
“consequences” later

-   The “guy at the top” has no concept of risk assessment, and what can 
result if you don’t do (and properly)

-   The “guy at the top” believes that “the insurance will cover any 
consequences”

-   The “guy at the top” has no understanding failure to take the right 
actions could result in criminal prosecutions – including of himself

-   The “guy at the top” is a “cowboy”, pure and simple (and I’ve met a few 
of those in my time!)

 

Why have I said all these “obvious” things that I think we have all encountered 
some time / somewhere?

 

Because I think they encompass many of the reasons given in the earlier posts 
as to why risk assessments are not done, or are not done appropriately (and I 
have avoided the word “correctly” because I don’t think there could ever be a 
“correct” risk assessment in absolute terms!).

 

Therefore if you made up a checklist something like the above, then maybe you 
could begin to identify why some companies do, or don’t do, the appropriate 
risk assessments, see where the drop-offs could be fixed, and try to overcome 
any opposition to doing them as/where/how appropriate.

 

John Allen

W.London, UK

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 06 March 2015 18:15
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] Safety standards versus safety engineering

 

“Risk Assessment” or in plain English – How many people have to get injured or 
killed before anything is done that should have been done in the beginning 
anyway.

 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and I sintended 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

Re: [PSES] Quasi Peak - Length of Measurement Time for Final Spot Measurement?

[dward]

Yes, worst case means worst case.

 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
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or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Rob Oglesbee [mailto:rogles...@radianresearch.com] 
Sent: Thursday, March 26, 2015 8:30 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Quasi Peak - Length of Measurement Time for Final Spot 
Measurement?

 

James,

 

Since you are aware of it, you need to make sure you capture the max reading.

 

Rob Oglesbee

Radian Research

(765) 449-5505

 

This message, and any attachments to it, may contain information that is 
privileged, confidential, and exempt from disclosure under applicable law. If 
the reader of this message is not the intended recipient, you are notified that 
any use, dissemination, distribution, copying, or communication of this message 
is strictly prohibited. If you have received this message in error, please 
notify the sender immediately by return e-mail or call 765-449-5500 and delete 
the message and any attachments. Thank you.

 

From: Pawson, James [mailto:james.paw...@echostar.com] 
Sent: Thursday, March 26, 2015 11:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: [PSES] Quasi Peak - Length of Measurement Time for Final Spot 
Measurement?

 

Dear group,

 

When measuring emissions using a Quasi Peak detector are there any regulations 
or guidance concerning the amount of time one should dwell on a single 
frequency for a measurement?

 

I know it depends on the nature of the signal. In this case, the signal of 
interest results in a burst of emissions of a high duty cycle followed by a 
long period (i.e. several minutes) of low duty cycle activity. If I use a QP 
detector and measure for 1 second just as the burst happens then I would get a 
high QP reading. If I measure in the steady state period I would get a lower QP 
reading.

 

In this case, knowing the signals involves, would the intention to be to measure

 

1.   one full representative cycle of emissions i.e. the initial burst and 
the low duty period after

2.   during the maximum duty cycle only

3.   during the steady state only

 

I can imagine that the measurement difference between 1) and 3) in this case 
would be small as the level measured during the high duty period would have had 
time to decay down to the same level as the steady state due to the QP time 
constant.

 

I’m asking this question in the context of both EN 55022 and FCC 15.

 

Googling for “quasi peak measurement time” and similar phrases is not proving 
helpful

 

Many thanks

James Pawson

 

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List 

Re: [PSES] Preamplifiers

[dward]

HI Grace
Pre-amp gain compression occurs when the input is too high and it causes 
non-linearity in the amp.  The issue then is to make sure that the input stays 
within the stated linearity range of the amp otherwise, too much input will 
cause readings that are not accurate.  

This is a very important factor in accurate measurements.  You should run input 
output comparison tests over the operating range of the device to see just 
where gain begins to be affected.  Don't rely on tech specs for this as they 
are generic and not necessarily specific to your device.

Issues to look out for in any amp are:
Gain compression, noise floor, non-linearity, and intermodulation issues.  All 
of these could affect measurements and the accuracy of results.
Thanks 

Dennis Ward
This communication and its attachements contain information from PCTEST 
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-Original Message-
From: Grace Lin [mailto:graceli...@gmail.com] 
Sent: Wednesday, February 25, 2015 8:07 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Preamplifiers

Dear Group Members,

I try to figure out the differences (from performance point of view) between an 
old preamplifier and a new preamplifier. Your comments and help are highly 
appreciated.

An HP 8449B preamplifier was very popular 20 years ago. Its replacement is 
83017A according to the Keysight webpage.  Website information for these two 
models was copied and pastes to the bottom of this email for convenience.

Page 11 of Agilent AN 1315 states: ... There are two important factors to 
consider when choosing a preamplifier: gain and noise figure.  The noise figure 
(NF) of the preamplifier must be lower than the NF of the spectrum analyzer...

It seems there are not much differences for the gain and noise figure between 
8449B and 83017A.  It seems there is a big difference for the gain compression.

My questions are:
1) How does the role of gain compression play in the measurement?
2) Are there any other parameters to be consider when choosing a preamplifier? 
I did note a lot of spectrum analyzers and EMI receivers have a built in 
preamplifier.

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

Best regards,
Grace Lin




8449B Microwave Preamplifier, 26.5 GHz

http://www.keysight.com/en/pd-101909%3Aepsg%3Apro-pn-8449B/microwave-preamplifier-1-ghz-to-265-ghz?cc=USlc=eng

Key Features  Specifications
•   Sensitivity for MIL-STD radiated measurements
•   Noise Figure: 1.0-12.5 GHz - 8.5dB; 12.5-22.0 GHz - 12.5dB;
22.0-26.5 GHz - 14.5dB
•   Minimum Gain: 23.5dB
•   Gain Flatness: 1.0-26.5 GHz - ±4.5dB; 2.0-22.0 GHZ ±3.5dB
•   Gain compression: 1 dB for output signal of ≤ +7 dBm
•   Connector Type: ACP - 3.5 male

Description
The Keysight 8449B microwave preamplifier is a high-gain, low-noise 
preamplifier that provides additional sensitivity for any RF/microwave spectrum 
analyzer for detection and analysis of very low signals. The improved 
sensitivity can dramatically reduce measurement time.


83017A Microwave System Amplifier, 0.5 to 26.5 GHz

http://www.keysight.com/en/pd-101780%3Aepsg%3Apro-pn-83017A/microwave-system-amplifier-05-to-265-ghz?nid=-32708.536880733.00cc=USlc=eng

Key Features  Specifications

Superior RF performance
•   Gain of more than 25dB
•   P1dB of more than 18dBm to 20GHz
•   Noise figure of less than 8dB to 18GHz,13dB to 26.5GHz (typ)

Connectors Type
•   Rf connectors: 3.5mm(f)
•   DC Detector output connector: BNC (f)

Description
The Keysight 83017A microwave system amplifier is a compact, off-the-shelf 
amplifier designed for systems designers and integrators. This amplifier 
provides power where you need it to recover system losses and to boost 
available power in RF and microwave ATE systems. The ultrabroad bandwidth from 
500 MHz to 26.5 GHz allows the designer to replace several narrow bandwidth 
amplifiers with a single Keysight amplifier, eliminating the need for crossover 
networks or multiple bias supplies.

-

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Re: [PSES] Interference Caused by Microwave Oven

[dward]

The solution to that is simple - get a new microwave but don't buy the same 
brand. :)

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
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-Original Message-
From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Friday, May 15, 2015 12:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Interference Caused by Microwave Oven

This isn't a particularly helpful contribution, but when I use my microwave 
(used correctly, with the door closed), my Bluetooth speaker completely stops 
working and any WiFi activity grinds to a halt.

I try to keep the kids away from the microwave when it's in use, as much as I 
can.


Michael.


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 14 May 2015 23:42
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Interference Caused by Microwave Oven

In message 1f28.6030...@gmail.com, dated Thu, 14 May 2015, Doug Powell 
doug...@gmail.com writes:

My question is this.  If the RF generated inside the oven does not stop 
prior to the opening of the RF seal on the door, which testing is 
responsible to identify this problem, EMC or the Safety testing

Not 'either/or': emission with the door open violates CISPR 11/EN 55011, it's 
also a violation of the Section of IEC/EN 60335-2 (too late here to look it up) 
and potentially a violation of the regulatory EMF exposure limits as measured 
according to IEC 62233.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

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Re: [PSES] Interference Caused by Microwave Oven

[dward]

Sinicism - a word made up from Latin for Chinese (sinicus) and Greek for 
belief, ideology or style (ism).  Meaning - a Chinese method or style
extended meaning - a certain negative belief about products made in China - of 
which may result in missing the good things.
​
Dennis Ward
This communication and its attachements 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 
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or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Friday, May 15, 2015 12:16 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Interference Caused by Microwave Oven

And I'm not disappointed.

Ken Javor
Phone: (256) 650-5261


 From: John Woodgate j...@jmwa.demon.co.uk
 Reply-To: John Woodgate j...@jmwa.demon.co.uk
 Date: Fri, 15 May 2015 19:50:26 +0100
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] Interference Caused by Microwave Oven
 
 In message 002e01d08f35$4068c0f0$c13a42d0$@pctestlab.com, dated Fri,
 15 May 2015, dward dw...@pctestlab.com writes:
 
 May your Sinicism not cause you to miss the good things in life.
 
 I'm not Chinese! And I'm not of the canine persuasion, which is what 
 the word you aimed at originally alluded to.
 --
 OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk 
 When I turn my back on the sun, it's to look for a rainbow John 
 Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
 
 -
 
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 emc-pstc discussion list. To post a message to the list, send your 
 e-mail to emc-p...@ieee.org
 
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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 
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 Instructions:  http://www.ieee-pses.org/list.html (including how to
 unsubscribe)
 List rules: http://www.ieee-pses.org/listrules.html
 
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Re: [PSES] Interference Caused by Microwave Oven

[dward]

The fact that this seems an anomaly says the Bayesian probability is satisfied 
by reason and uniformity -  that being, there are more satisfactorily operating 
devices than lemons.

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
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or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Friday, May 15, 2015 9:04 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Interference Caused by Microwave Oven

In message 001001d08f24$621e6c60$265b4520$@pctestlab.com, dated Fri,
15 May 2015, dward dw...@pctestlab.com writes:

The solution to that is simple - get a new microwave but don't buy the 
same brand. :)

What is the Bayesian probability that the new brand will be worse? (;-)
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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Re: [PSES] Interference Caused by Microwave Oven

[dward]

May your Sinicism not cause you to miss the good things in life. 

​
Dennis Ward
This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
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or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Friday, May 15, 2015 9:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Interference Caused by Microwave Oven

In message 002701d08f2c$fbcc7d40$f36577c0$@pctestlab.com, dated Fri,
15 May 2015, dward dw...@pctestlab.com writes:

The fact that this seems an anomaly says the Bayesian probability is 
satisfied by reason and uniformity -  that being, there are more 
satisfactorily operating devices than lemons.

May you never be disillusioned.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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Re: [PSES] Integrating radio COSTs into other equipment

[dward]

First, there is no such thing as an RTTE certified device.  Second, a module is 
an apparatus and any apparatus, regardless of where used, is to comply with the 
associated directives. Third. all device using CE marking, must still comply.  
If it does not comply in a final configuration, then it does not comply and 
cannot really be considered properly using CE marking.
Thanks 

​
Dennis Ward
This communication and its attachements 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 
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or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] 
Sent: Monday, May 11, 2015 4:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Integrating radio COSTs into other equipment

Michael, 

Do you think this applies to the case for installing a finished product? For 
example if I make and industrial machine and install a wireless keyboard that 
is already RTTE certified, have I created a new item (i.e. the machine) that 
must be assessed for RTTE conformance? 

I think the common sense answer is 'no', but Commission and ETSI guidance does 
not seem to address this scenario.  

Regards,
Lauren Crane
KLA-Tencor

-Original Message-
From: Michael Derby [mailto:micha...@acbcert.com]
Sent: Monday, May 11, 2015 6:10 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Integrating radio COSTs into other equipment

Hello Amund,

This is a general reply about installing CE Marked radio modules into host 
products..

The important thing to remember is that there no certification process under 
the RTTE Directive and also no modular approvals.

Anyone installing the module into a product becomes responsible for the 
compliance of the overall product, with the RTTE Directive.
Radio, EMC, Safety.

It's possible to imagine cases where the test results for the radio performance 
(made by the module manufacturer, on the module) could be used
to show compliance of the overall final product.   For example, if the
module is installed ok in accordance with manufacturer's instructions, you
could imagine that the power, frequency, etc., should not be changed.   Many
module installers rely on most of the tests in the radio test report of the 
module for their compliance to Article 3.2 of the RTTE Directive.

For radiated emissions of the transmitter module (also Article 3.2) in the 
final product, I know that most module manufacturers recommend that the final 
host product should be re-tested and I certainly think this is a good
recommendation.   Anyone who has tested emissions of final products with
modules installed will know that the emissions from the module can sometimes 
fail when installed in a host.

For EMC and Safety, it is very difficult (impossible?) to imagine that any 
tests of the module might be representative of the radio's performance inside a 
host; so the host should really be treated as a new product for testing to 
standards like EN 301 489-7, EN 301 489-24, product safety, etc.

Finally; I see an incredibly wide variation in testing approach from module
manufacturers for CE Marking a module.   Just because it is CE Marked, does
not mean they have fully tested it for every possible installation!

This link is very useful..
http://www.rtteca.com/TGN01%20-%20May%202013.pdf



Michael.



-Original Message-
From: Amund Westin [mailto:am...@westin-emission.no]
Sent: 11 May 2015 07:55
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Integrating radio COSTs into other equipment

RTTE approved 3G GSM module (EN 301 511) is integrated into an EN 61326-1 
measurement product. 
Maybe this call for new radio tests such as radiated spurious emission.

Anyone have experience about the consequences integrating such radio COTS? 

Regards
Amund

-

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Re: [PSES] Interference Caused by Microwave Oven

[dward]

It's there, keep looking. :)

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
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-Original Message-
From: Grasso, Charles [mailto:charles.gra...@echostar.com] 
Sent: Friday, May 15, 2015 12:43 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Interference Caused by Microwave Oven

Hmm -odd - It's not in my dictionary - or online!

Best Regards
Charles Grasso
Compliance Engineer
Echostar Communications
(w) 303-706-5467
(c) 303-204-2974
(t) 3032042...@vtext.com
(e) charles.gra...@echostar.com
(e2) chasgra...@gmail.com


-Original Message-
From: dward [mailto:dw...@pctestlab.com]
Sent: Friday, May 15, 2015 1:34 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Interference Caused by Microwave Oven

Sinicism - a word made up from Latin for Chinese (sinicus) and Greek for 
belief, ideology or style (ism).  Meaning - a Chinese method or style extended 
meaning - a certain negative belief about products made in China - of which may 
result in missing the good things.
​
Dennis Ward
This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: Ken Javor [mailto:ken.ja...@emccompliance.com]
Sent: Friday, May 15, 2015 12:16 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Interference Caused by Microwave Oven

And I'm not disappointed.

Ken Javor
Phone: (256) 650-5261


 From: John Woodgate j...@jmwa.demon.co.uk
 Reply-To: John Woodgate j...@jmwa.demon.co.uk
 Date: Fri, 15 May 2015 19:50:26 +0100
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] Interference Caused by Microwave Oven
 
 In message 002e01d08f35$4068c0f0$c13a42d0$@pctestlab.com, dated Fri,
 15 May 2015, dward dw...@pctestlab.com writes:
 
 May your Sinicism not cause you to miss the good things in life.
 
 I'm not Chinese! And I'm not of the canine persuasion, which is what 
 the word you aimed at originally alluded to.
 --
 OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk 
 When I turn my back on the sun, it's to look for a rainbow 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://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 sdoug...@ieee.org
 Mike Cantwell mcantw...@ieee.org
 
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 Jim Bacher:  j.bac...@ieee.org
 David Heald: dhe...@gmail.com

-

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For help

Re: [PSES] Interference Caused by Microwave Oven

[dward]

Apologies to John for inferring a problem with certain areas of the 
manufacturing world.

​
Dennis Ward
This communication and its attachements 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 
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the sender immediately if you receive this communication in error, and delete 
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or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: dward [mailto:dw...@pctestlab.com] 
Sent: Friday, May 15, 2015 12:34 PM
To: 'Ken Javor'; 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: RE: [PSES] Interference Caused by Microwave Oven

Sinicism - a word made up from Latin for Chinese (sinicus) and Greek for 
belief, ideology or style (ism).  Meaning - a Chinese method or style extended 
meaning - a certain negative belief about products made in China - of which may 
result in missing the good things.
​
Dennis Ward
This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: Ken Javor [mailto:ken.ja...@emccompliance.com]
Sent: Friday, May 15, 2015 12:16 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Interference Caused by Microwave Oven

And I'm not disappointed.

Ken Javor
Phone: (256) 650-5261


 From: John Woodgate j...@jmwa.demon.co.uk
 Reply-To: John Woodgate j...@jmwa.demon.co.uk
 Date: Fri, 15 May 2015 19:50:26 +0100
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] Interference Caused by Microwave Oven
 
 In message 002e01d08f35$4068c0f0$c13a42d0$@pctestlab.com, dated Fri,
 15 May 2015, dward dw...@pctestlab.com writes:
 
 May your Sinicism not cause you to miss the good things in life.
 
 I'm not Chinese! And I'm not of the canine persuasion, which is what 
 the word you aimed at originally alluded to.
 --
 OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk 
 When I turn my back on the sun, it's to look for a rainbow 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://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 sdoug...@ieee.org
 Mike Cantwell mcantw...@ieee.org
 
 For policy questions, send mail to:
 Jim Bacher:  j.bac...@ieee.org
 David Heald: dhe...@gmail.com

-

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Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) Where?

[dward]

Actually, that is not exactly correct.  While many standards are written as 
'voluntary' the FCC does in fact incorporate by reference some ANSI standards.  
To incorporate by reference means that the full content of the referenced 
document is part and parcel of the document to which it is referenced - except 
when specific disallowance of particular parts of the referenced std are 
mentioned.  So, if the standard says there is a needed uncertainty, then it 
could very well also, in legal terms, mean that the CFRs in fact incorporate 
these uncertainties by reference to that stated standard.  While it may not be 
enforced as yet, there is the possibility that, in a court of law, since some 
ANSI stds, except where specifically disallowed, are included by reference to 
the rules, uncertainties may also be included by that same reference.


​
Dennis Ward
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-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] 
Sent: Tuesday, October 13, 2015 10:49 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) 
Where?

They are not. No public standard enforces any margin.
Even measurement uncertainty is not taken into account, unless (in some 
standards) your uncertainty is larger than an assumed (calculated) value 
(depending on test set up and test type).

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
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+ Improvement of Product Quality and Reliability testing Education

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-Original Message-
From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com]
Sent: Tuesday 13 October 2015 18:44
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) 
Where?

All the issues being raised regarding possible variability must be known to the 
members of various standards committees. Does anyone know that the issues are 
*not* taken into account when the committees set test levels? If standards are 
followed, including any instructions regarding EUT sampling and measurement 
uncertainty, why assume additional margins must be applied?


Regards,
Lauren Crane
KLA-Tencor

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This 

Re: [PSES] RF Common Mode Immunity Test Question

[dward]

Yes, that is the point isn’t it – it was not an amateur radio operator.  First, 
wrong frequency, second not the way amateurs identify themselves.

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
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or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Saturday, September 12, 2015 12:37 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

FWIW, 27MHz sounds more like a CB station rather than an “real” Amateur station 
which (IIRC) would be using the 28MHz band – and CB operators (especially in 
some countries! ) may use illegal amps (“boosters”) to raise the transmit power 
beyond the legal limits!


John Allen

W.London, UK

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 12 September 2015 20:00
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

I agree -an amateur could not and would not use a call sign other than his or 
her designated licensed call sign. No blue leader, no quacking duck, nothing 
but respective number licensed to him or her.

 

 

 

 

 

Sent from my Verizon Wireless 4G LTE smartphone

 Original message 

From: "ce-test, qualified testing bv - Gert Gremmen" <g.grem...@cetest.nl 
<mailto:g.grem...@cetest.nl> > 

Date: 9/12/2015 11:25 AM (GMT-08:00) 

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

Subject: Re: [PSES] RF Common Mode Immunity Test Question 

 

A Ham never can be a source of interference, by definition (if they
respect their limits- in more than one way).

To me an amateur is not a HAM, but that is a matter of language I
suppose.



My example showed a (spiced up) example of lack of immunity in a
professional audio installation , that due pragmatic testing, too cables
with average screening properties

and a substantial power output in a "room" with  may-i-say very specific
acoustic properties, lead to an extremely interfering situation.



Gert Gremmen



Van: Ed Price [mailto:edpr...@cox.net] 
Verzonden: zaterdag 12 september 2015 20:09
Aan: ce-test, qualified testing bv - Gert Gremmen
Onderwerp: RE: [PSES] RF Common Mode Immunity Test Question



Gert:



Allow me to fine tune your story for accuracy. In the late 1950's, the
USA FCC re-allocated the 27 MHz region (called 11 meter band) from
amateur use to a new "citizens" band. (I don't know how many other
countries followed that example.) This was created from the existing
amateur 10-meter band, making amateurs rather unhappy. This 11-meter
Citizens Band eventually degenerated into unregulated technical and
operational chaos. If you had a device exhibiting a susceptible response
of a "blue angel calling a red devil" and not something like "WB6WSN
calling..." then the source was not an amateur but an unregulated CB'er.
Please, hams are sensitive about being the assumed source of
interference.



Ed Price
WB6WSN
Chula Vista, CA USA



-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: Saturday, September 12, 2015 10:18 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] RF Common Mode Immunity Test Question



This is a typical standards clause included in a standard by non-emc
"experts".



What  is a metal enclosure, and when is it not enclosure ?

Metalized plastic:  is not metal but might be as good Painted metal:
complies but may have substantial potential difference between parts



If heavy interference exists, 4 braid connection points are not enough,
and inferior braided coax and signal cables is all over the market.



This is an example of economic drive  "fast  cheap & pragmatic testing"

and this  exemption clause

is a recipe for problems in the field.



I remember a customer of mine building PA systems for a church
application ( = 55103-2) Final testing was ok, and the system worked
like a charm.

The first Sunday in real use, the vicar got an unexpected reply on its
questions to the mighty when a local 27 MHz radio amateur switched on
its transmitter and "preached"  : "blue angel calling red devil "







Gert Gremmen

ce-test qualified testing 

Re: [PSES] RF Common Mode Immunity Test Question

[dward]

I agree -an amateur could not and would not use a call sign other than his or 
her designated licensed call sign. No blue leader, no quacking duck, nothing 
but respective number licensed to him or her.




Sent from my Verizon Wireless 4G LTE smartphone Original message 
From: "ce-test, qualified testing bv - Gert Gremmen" 
 Date: 9/12/2015  11:25 AM  (GMT-08:00) To: 
EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RF Common Mode Immunity Test 
Question 
A Ham never can be a source of interference, by definition (if they
respect their limits- in more than one way).

To me an amateur is not a HAM, but that is a matter of language I
suppose.

 

My example showed a (spiced up) example of lack of immunity in a
professional audio installation , that due pragmatic testing, too cables
with average screening properties

and a substantial power output in a "room" with  may-i-say very specific
acoustic properties, lead to an extremely interfering situation.

 

Gert Gremmen

 

Van: Ed Price [mailto:edpr...@cox.net] 
Verzonden: zaterdag 12 september 2015 20:09
Aan: ce-test, qualified testing bv - Gert Gremmen
Onderwerp: RE: [PSES] RF Common Mode Immunity Test Question

 

Gert:

 

Allow me to fine tune your story for accuracy. In the late 1950's, the
USA FCC re-allocated the 27 MHz region (called 11 meter band) from
amateur use to a new "citizens" band. (I don't know how many other
countries followed that example.) This was created from the existing
amateur 10-meter band, making amateurs rather unhappy. This 11-meter
Citizens Band eventually degenerated into unregulated technical and
operational chaos. If you had a device exhibiting a susceptible response
of a "blue angel calling a red devil" and not something like "WB6WSN
calling..." then the source was not an amateur but an unregulated CB'er.
Please, hams are sensitive about being the assumed source of
interference.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: Saturday, September 12, 2015 10:18 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

This is a typical standards clause included in a standard by non-emc
"experts".

 

What  is a metal enclosure, and when is it not enclosure ?

Metalized plastic:  is not metal but might be as good Painted metal:
complies but may have substantial potential difference between parts

 

If heavy interference exists, 4 braid connection points are not enough,
and inferior braided coax and signal cables is all over the market.

 

This is an example of economic drive  "fast  cheap & pragmatic testing"

and this  exemption clause

is a recipe for problems in the field.

 

I remember a customer of mine building PA systems for a church
application ( = 55103-2) Final testing was ok, and the system worked
like a charm.

The first Sunday in real use, the vicar got an unexpected reply on its
questions to the mighty when a local 27 MHz radio amateur switched on
its transmitter and "preached"  : "blue angel calling red devil "

 

 

 

Gert Gremmen

ce-test qualified testing bv

 

 

-Oorspronkelijk bericht-

Van: John Woodgate [mailto:j...@jmwa.demon.co.uk
 ]

Verzonden: vrijdag 11 september 2015 16:48

Aan: EMC-PSTC@LISTSERV.IEEE.ORG  

Onderwerp: Re: [PSES] RF Common Mode Immunity Test Question

 

In message

<6165069ea399fe46b1a5148bcb1a75ebd...@ex-ukha-01.ad.s-a-m.com
 >,
dated Fri, 11 Sep 2015, Robert Dunkerley  > writes:

 

>Would this not imply that nearly all types of signal cables (most are 

>screened this way?) would be exempt from this test, or is my 

>understanding totally wrong? (probably the case!)

 

Not all products have a metal case. Not all ports meet the definition of
'screened port'. Not all cables have braided screens/shields.

--

OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
  When I turn my back on the sun, it's to
look for a rainbow John Woodgate, J M Woodgate and Associates, Rayleigh,
Essex UK

 

-



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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:  

Re: [PSES] RF Common Mode Immunity Test Question

[dward]

I for one would never want the US to get into this arena.  Too much regulation 
in the US as it is.  Don’t need more and don’t want more.  I’ll decide what is 
best for me, not the government.

 

 

​

Dennis Ward

This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: Saturday, September 12, 2015 1:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

John:

 

Unfortunately, American consumer electronics has no E-field immunity 
requirement. The only help a consumer gets is that little paragraph of legalese 
that advises you to re-orient your device and move further away from emitters. 
OTOH, most consumer equipment design which takes emission compliance into 
account will also yield reasonable immunity levels. My personal experience 
indicates that most immunity problems with consumer electronics is not a design 
problem but a reliability problem. As an example, last year a friend asked me 
to repair his semi-pro mixer board (used in a church environment); he had 
problems “everywhere” with distortion, low gain and external RF susceptibility. 
However, the mixer board was fine; it was his patch cords that were horribly 
abused and leaky.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Saturday, September 12, 2015 11:47 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

In message <  
FCA549BE3ECF9D4CB8CB8576837EA48920AF42@ZEUS.cetest.local>,

dated Sat, 12 Sep 2015, "ce-test, qualified testing bv - Gert Gremmen" 

<  g.grem...@cetest.nl> writes:

 

>A Ham never can be a source of interference, by definition (if they 

>respect their limits- in more than one way).

 

It is clearly not true, given the unlimited lack of immunity exhibited by some 
products. Immunity isn't even controlled in the Americas.

> 

>To me an amateur is not a HAM, but that is a matter of language I 

>suppose.

 

Yes. 'Amateur' is the larval form. (;-)

> 

>My example showed a (spiced up) example of lack of immunity in a 

>professional audio installation , that due pragmatic testing, too 

>cables with average screening properties

 

Was it definitely due to cables? Much professional PA equipment is none too 
good on immunity. And there are far too many installations that don't 
exclusively use balanced lines.

> 

 

--

OOO - Own Opinions Only. With best wishes. See   
www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow 
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

 

-



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 emc-p...@ieee.org>

 

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 http://product-compliance.oc.ieee.org/ 
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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 
 >

Re: [PSES] RF Common Mode Immunity Test Question

[dward]

There always will be 'accidents' caused by bad products, even those that pass 
all the tests. From Ford Pintos to toaster ovens to toys, you cannot regulate 
them out of existence.  A percentage will always slip through.  

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
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or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Monday, September 14, 2015 9:04 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

In message <002801d0ef00$de0b37e0$9a21a7a0$@pctestlab.com>, dated Mon,
14 Sep 2015, dward <dw...@pctestlab.com> writes:

>I for one would never want the US to get into this arena.  Too much 
>regulation in the US as it is.  Don’t need more and don’t want more. 
>I’ll decide what is best for me, not the government.

But if you were a manufacture of a product that caused a bad accident due to 
lack of immunity It already happened twice, one in a Danish hospital and 
once in a fire due to a malfunctioning toast oven.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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Re: [PSES] RF Common Mode Immunity Test Question

[dward]

The old adage “buyer beware” fits.

That said, the price of freedom is that everyone takes responsibility for 
themselves, they take responsibility on what they purchase and what they use.  
They reject government intrusion.  They set up things like the consumer 
protection organizations in the US; which do protect against many of what 
others think is required to be legislated.  It does not take laws and 
standards; it does not take government watch dogs, it takes personal 
responsibility.  The return policies and lemon policies of most if not all 
manufactured products in the US speak to that savvy.  If you buy a product that 
does not do what it claims, it can be and generally is returned.  

 

I also believe that the US buyer is far more savvy than many give them credit.  
Yes, there are those who would rather have some agency think for them; there 
always will be. But for the most part, using BBB and other consumer groups 
there is absolutely no reason to introduce an overly cumbersome, inane and 
self-serving government intrusion in private affairs of US citizens.

 

 

​

Dennis Ward

This communication and its attachements 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 
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related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: Monday, September 14, 2015 9:10 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

Dennis:

 

The rationale that you don’t need consumer electronics with a modicum of 
immunity works only for you, because you are what I would call an expert 
customer. You have the knowledge to ameliorate immunity problems, but most of 
the population does not have this capability.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Monday, September 14, 2015 8:20 AM
To: 'Ed Price'; EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: RE: [PSES] RF Common Mode Immunity Test Question

 

I for one would never want the US to get into this arena.  Too much regulation 
in the US as it is.  Don’t need more and don’t want more.  I’ll decide what is 
best for me, not the government.

 

 

​

Dennis Ward

This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: Saturday, September 12, 2015 1:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

John:

 

Unfortunately, American consumer electronics has no E-field immunity 
requirement. The only help a consumer gets is that little paragraph of legalese 
that advises you to re-orient your device and move further away from emitters. 
OTOH, most consumer equipment design which takes emission compliance into 
account will also yield reasonable immunity levels. My personal experience 
indicates that most immunity problems with consumer electronics is not a design 
problem but a reliability problem. As an example, last year a friend asked me 
to repair his semi-pro mixer board (used in a church environment); he had 
problems “everywhere” with distortion, low gain and external RF susceptibility. 
However, the mixer board was fine; it was his patch cords that were horribly 
abused and leaky.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Saturday, September 12, 2015 11:47 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

In message < <mailto:FCA549BE3ECF9D4CB8CB8576837EA48920AF42@ZEUS.cetest.local> 
FCA549BE3ECF9D4CB8CB8576837EA48920AF42@ZEUS.cetest.local>,

dated Sat, 12 Sep 2015, "ce-test, 

Re: [PSES] RF Common Mode Immunity Test Question

[dward]

Rocks have been thrown from lawnmower blades and have killed or injured people. 
Do we now outlaw rocks because in some obscure instance they might get caught 
in a mower blade.  Is there really a need to put “do not light, may explode” on 
stick of dynamite? Or ‘contents may be hot’ on a cup of hot coffee?   

 

Not wanting to require immunity is not the same as not having immune products.  
Consumer awareness and consumer groups, and yes, law suits if needed; not 
government intervention.  If you want guaranteed failure, get the government 
involved.

 

 

​

Dennis Ward

This communication and its attachements 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 
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the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
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or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Monday, September 14, 2015 10:05 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

Seconded!

 

Anyway, what would one of  your “average” US customers say if, for example, one 
of their sophisticated modern consumer appliances (e.g. a robotic lawnmower/ 
vacuum cleaner/ “internet of things” kitchen appliance / “domestic robot” 
[already almost here!)  – need I go on?) went haywire and ran them/their kids 
over in the garden/house or set fire to the house whilst everyone was in bed 
because their neighbour switched on their perfectly legally EM 
emissions-compliant CB set, TV, washing machine (etc.),  but their own 
equipment was very susceptible to those EM emissions?

 

Sue the perfectly innocent neighbour or else the manufacturer, the distributor 
etc? Maybe, if the first person (people) ever got out of hospital!  Some may 
think I’m exaggerating but the same sort of thing has happened in the past in 
the US and elsewhere. 

 

The responsible approach is like many countries to legally require a reasonable 
level of EM immunity for consumer and industrial products (and the medical and 
some other sectors are even more stringent) – and since so many such countries 
already have the requirements in place, then why does the US government not 
take the “easy path” and introduce similar requirements? (same reasons, I 
suppose, as the opposition to gun-control and so on :().

 

The bean counters might want to rely on their product liability insurance – but 
that only works once or twice and then a company will find it difficult to get 
that anymore, and the resulting publicity can be horrendous.

 

Prevention is better than punishment!

 

Not politics on my part, just what I consider to be ethical common sense.

 

John Allen

W.London, UK

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: 14 September 2015 17:10
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

Dennis:

 

The rationale that you don’t need consumer electronics with a modicum of 
immunity works only for you, because you are what I would call an expert 
customer. You have the knowledge to ameliorate immunity problems, but most of 
the population does not have this capability.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Monday, September 14, 2015 8:20 AM
To: 'Ed Price'; EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: RE: [PSES] RF Common Mode Immunity Test Question

 

I for one would never want the US to get into this arena.  Too much regulation 
in the US as it is.  Don’t need more and don’t want more.  I’ll decide what is 
best for me, not the government.

 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
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confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
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or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: Saturday, September 12, 2015 1:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LI

Re: [PSES] RF Common Mode Immunity Test Question

[dward]

Exactly – and thank you for pointing that out Rodney.  In the US, if you make a 
product you are responsible for that product.  You are responsible for it 
meeting the frequency spectrum rules, you are responsible for it to meet safety 
needs so that it is safe to use and you are responsible for it to be immune to 
affects in the environment in which it will be used - period.  No immunity laws 
needed, no immunity laws desired.

 

​

Dennis Ward

This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Rodney Davis [mailto:rodney.da...@mitel.com] 
Sent: Monday, September 14, 2015 10:27 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

Hi guys, in simple English.. the  FCC does state in section 15.17 
Susceptibility to interference..., you are responsible for reducing the 
susceptibility for receiving harmful interference.

 

This clause is enough to make you responsible for any immunity complaint 
regardless of the levels!

 

Rodney Davis

 

  _  

From: Ed Price <edpr...@cox.net <mailto:edpr...@cox.net> >
Sent: Monday, September 14, 2015 12:09 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] RF Common Mode Immunity Test Question 

 

Dennis:

 

The rationale that you don’t need consumer electronics with a modicum of 
immunity works only for you, because you are what I would call an expert 
customer. You have the knowledge to ameliorate immunity problems, but most of 
the population does not have this capability.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Monday, September 14, 2015 8:20 AM
To: 'Ed Price'; EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: RE: [PSES] RF Common Mode Immunity Test Question

 

I for one would never want the US to get into this arena.  Too much regulation 
in the US as it is.  Don’t need more and don’t want more.  I’ll decide what is 
best for me, not the government.

 

 

Dennis Ward

This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: Saturday, September 12, 2015 1:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

John:

 

Unfortunately, American consumer electronics has no E-field immunity 
requirement. The only help a consumer gets is that little paragraph of legalese 
that advises you to re-orient your device and move further away from emitters. 
OTOH, most consumer equipment design which takes emission compliance into 
account will also yield reasonable immunity levels. My personal experience 
indicates that most immunity problems with consumer electronics is not a design 
problem but a reliability problem. As an example, last year a friend asked me 
to repair his semi-pro mixer board (used in a church environment); he had 
problems “everywhere” with distortion, low gain and external RF susceptibility. 
However, the mixer board was fine; it was his patch cords that were horribly 
abused and leaky.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Saturday, September 12, 2015 11:47 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

In message < <mailto:FCA549BE3ECF9D4CB8CB8576837EA48920AF42@ZEUS.cetest.local> 
FCA549BE3ECF9D4CB8CB8576837EA48920AF42@ZEUS.cetest.local>,

dated Sat, 12 Sep 2015, "ce-test, qualified testing bv - Gert Gremmen" 

< <mailto:g.grem...@cetest.n

Re: [PSES] RF Common Mode Immunity Test Question

[dward]

As a US citizen my premise on any government involvement is to make it as 
impossible or as hard for them to regulate anything as can be.  This includes 
EMC, immunity or any other thing.  Too many fall under the idea that personal 
safety outweighs personal freedom.  That may work in a socialist type 
environment, but not in here.  

 

 

​

Dennis Ward

This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Tuesday, September 15, 2015 11:01 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

Ravinder

 

W.r.t. your 2nd para, the 1st  sentence is roughly what I said in an earlier 
post - but the 2nd sentence could be a misleading assumption because of what 
you said in the 1st para (and what I also said in my earlier post about bean 
counting for the US market!) :(

 

John Allen

W.London, UK

 

-Original Message-
From: Ravinder Ajmani [mailto:ravinder.ajm...@hgst.com] 
Sent: 15 September 2015 18:51
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

Pardon my skepticism, but I have very little faith on the US industries 
self-enforcing any kind of regulations.  When Wall Street analysts expect 
public companies to show higher profits quarter after quarter, lowering the 
cost becomes the key driver.

 

However most US companies ship their products overseas, and almost all of these 
countries have some form of immunity requirements, similar to the EU 
regulations.  Hence one can assume that the products built in US are designed 
to meet these requirements. 

 

The sad thing is that in until the eighties US was leading the world on EMC 
requirements, but now has fallen behind.

 

My personal view.

 

Regards

 

Ravinder Ajmani

HGST, a Western Digital company

  ravinder.ajm...@hgst.com

 

 

5601 Great Oaks Parkway

San Jose, CA 95119

  www.hgst.com

 

-Original Message-

From: Gary McInturff [  
mailto:gary.mcintu...@esterline.com]

Sent: Tuesday, September 15, 2015 9:16 AM

To:   EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

Well not really John - ANSI has no regulatory authority but money does. A 
business isn't likely to simply add either NRE cost or cost per unit without 
justification - poor product performance, competitive advantage, regulation. 
Poor performance isn't even a clean definition - if I have one failure out of 
10,000 because of ESD for example - just ship them another one etc.

 

My personal opinion is that proper operation in the field is as important as 
any other functional specification but whether it's done through 
self-enforcement or governmental regulation is a thorny question.

 

-Original Message-

From: John Woodgate [  
mailto:j...@jmwa.demon.co.uk]

Sent: Monday, September 14, 2015 11:38 PM

To:   EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

In message <  
009601d0ef5d$3dc51eb0$b94f5c10$@cox.net>, dated Mon, 14 Sep 2015, Ed Price < 
 edpr...@cox.net> writes:

 

>True, the FCC is essentially still following the Communications Act of

>1934 in its scope. However, telegraph rates aren?t so important 

>anymore, while the issue of consumer electronics immunity certainly is.

>We expect our laws and regulations to evolve to address the important 

>issues of the day, junking the obsolete and helping with new conflicts.

 

It is interesting that the US (ANSI) participates fully in the IEC committees 
on immunity, having four experts on each and holding the Convenership of one.

 

Immunity is for other people, right?just

--

OOO - Own Opinions Only. With best wishes. See   
www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow 
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

 

-



This message is from the IEEE Product Safety Engineering 

Re: [PSES] EN55032 definition of residential environment

[dward]

Ain't no such thing.  


Sent from my Verizon Wireless 4G LTE smartphone Original message 
From: Richard Nute  Date: 12/8/2015  12:23 PM  
(GMT-08:00) To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EN55032 
definition of residential environment 
 

 

Hmm.

 

“The Class B requirements are intended to offer
adequate protection to broadcast services within
the residential environment.”

 

I live about ¼ mile from 8 transmitter TV, FM,
etc., towers.  Only the best of radios, e.g.,
Grundig Yachtboy, can properly tune both AM and
FM, but the digital TVs are unaffected (as near as
I can tell).

 

What about protection of my radios from the
broadcast services?  :)  

 

 

Rich

 

 

 

 

From: Ronald Pickard
[mailto:ronald.pick...@compoundphotonics.com] 
Sent: Tuesday, December 08, 2015 11:32 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN55032 definition of
residential environment

 

Hi Ian,

The “residential” environment is generally
understood to be the household/domestic
environments where humans typically “reside”. With
that said and further into EN 55032 clause 4,
there is a subtle and a bit of a loose Class B
definition: “The Class B requirements are intended
to offer adequate protection to broadcast services
within the residential environment.” Such
residential broadcast services would typically
include radio and television for personal
consumption, and possibly including Wi-Fi now-a
days. And, I’m not sure what “adequate protection”
actually means in this case, but given Ghery’s
statement below, I doubt that it will get any more
definitive.

 

Best regards,

 

Ron Pickard
Regulatory Compliance Engineer
Compound Photonics 
D | +1 (602) 883-8039

 

From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: Tuesday, December 08, 2015 12:00 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
 
Subject: Re: [PSES] EN55032 definition of
residential environment

 

Disclaimer – While I am the Vice Chairman of CISPR
I, the following is my personal opinion and does
not necessarily reflect the opinions of the
Chairman or other members of CISPR I, its working
groups, national committees or IEC HQ.

 

That said…

 

I don’t recall seeing Gert at CISPR I meetings,
nor CISPR I WG2 (emissions) or CISPR I WG4
(immunity) meetings (he isn’t a member of either
WG).  If he were present, he would know that the
reason such regulatory statements are not in CISPR
standards such as CISPR 22, 24 or 32 is that CISPR
standards may not contain regulatory statements.
Defining which products must meet Class A or Class
B limits is up to regulators.  There as even been
discussion about the “legality” of the Class A
warning label in CISPR 22 and 32.  CISPR 32 does
have language that gives guidance to help the user
of the standard properly apply it, but a regulator
is free to ignore or change this at their
discretion.  So, to say that CISPR I has been
“notorious” is a bit of a stretch, in my opinion.

 

There has been no serious work done to have two
different immunity levels in CISPR 24 or 35 as it
has not been felt to be needed.  Join your
national committee (or contact it) and make a
proposal if you feel that such additional test
levels would be warranted.  A persuasive argument
would be given a fair hearing.  Be aware that any
new requirements will take years to incorporate
into a standard.  Remember, CISPR I has been
trying to get CISPR 35 published for nearly 15
years as it is, but feel free to make a proposal
for an amendment to add different test levels for
Class A products.  Just remember, we’ve gotten
along well with single limits in CISPR 24 since it
was originally published in 1997, so a convincing
argument will be needed.

 

Ghery S. Pettit

Vice Chairman, CISPR SC I

 

From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: Tuesday, December 08, 2015 9:55 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
 
Subject: Re: [PSES] EN55032 definition of
residential environment

 

1.

Independent of the standards, the EMC directive
requires marking on typeplate and/or documentation
if an equipment is non-residential.

 

2.

Unwilling standards committees have been
“reluctant” in including  the definitions in
written in their standards. 

CISPR I has been notorious in these for years, by
not even defining Class A for immunity (CISPR 24).

There are ample standards and EC documents giving
an appropriate definitions, in general something

like:

 

If it is predominantly used for households or is
connected to a residentially used power newtwork

the equipment will be residential or often said
“Class B”. 

If connected to a private power network then it
should be Industrial or “Class A”.

 

One standard that comes to mind that gives a good
description including examples is EN 61326-1:2013.

An EC document TC210/Sec0515/INF from 2007
addresses the topic in full and includes the
recommendation to

include a 

Re: [PSES] Bluetooth audio product

[dward]

Careful with the idea that the US and Canada are ‘fully harmonized’. That 
simply aint the case.  There are a number of things that must be considered for 
transmitters that are different between the US and Canada.  What can be said is 
that most likely, if you do testing per the Canadian requirements, then the FCC 
is probably met as well, but not necessarily the other way around.

Thanks 

​

Dennis Ward

This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: S Drysdale [mailto:sdd...@gmail.com] 
Sent: Friday, February 12, 2016 10:46 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Bluetooth audio product

 

I could fully agree about IC (now calling themselves ISED)  As IC/ISED 
typically only accepts data for RF certification up 1 year past measurement 
date, it is well worth filing for IC/ISED for Canada at the same time as FCC 
certification.  Even if you are not planning on marketing in Canada now, the 
'couple bucks for filing purposes' can save having to re-test down the road.  

Best Regards,

Scott Drysdale

Global EMC Labs (Montreal, Canada)

OOO - Own Opinion Only

 

 

On Tue, Feb 9, 2016 at 2:57 PM, Rodney Davis  > wrote:

And what about Industry Canada, may as well get IC as it is fully harmonized, 
just another couple bucks for filing purposes and you can expand your market 
region...

 

Rodney Davis

 

 


  _  


From: Paasche, Dieter  >
Sent: Tuesday, February 9, 2016 1:54 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] Bluetooth audio product 

 

Just to add some information to Michaels very good comments. 

 

The R Directive will be replaced by the new RED directive soon. European 
member states must apply the Directive requirements from 13 June 2016.

 

For FCC and if you use an approved module (highly recommended) here is a link 
to the FCC ID search. 

 

  
https://www.fcc.gov/general/fcc-id-search-page


  

  FCC ID Search | Federal 
Communications Commission

www.fcc.gov  

FCC ID numbers consists of two elements, a grantee code and an equipment 
product code. The FCC ID is assigned to all devices subject to certification.

 

 

If you use an approved module,  make sure you use it as it was certified. Any 
critical change (Like changing to an antenna with an higher gain) might need 
re-certification. 

 

 

Sincerely, 

 

Dieter Paasche

Advanced Product Developer, Electrical

CHRISTIE

809 Wellington Street North

Kitchener, Ontario  N2G 4Y7

Phone: +1 519-744-8005 Ext 7211  

  www.christiedigital.com

 

This e-mail message (including attachments, if any), is confidential. Any 
unauthorized use, distribution or disclosure is prohibited.  If you have 
received this e-mail message in error, please notify the sender by reply e-mail 
or telephone and delete it and any attachments from your computer system and 
records.

 

From: Michael Derby [mailto:micha...@acbcert.com  
] 
Sent: Tuesday, February 09, 2016 10:04 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] Bluetooth audio product

 

Hello Ian,

 

Your product will now need to meet the R Directive.   No longer will it be 
the EMCD and LVD.

 

You’ll still need to consider your audio operation during your EMC testing 
(does my audio still work when I apply EMC tests?), just as you have always 
done.

But now, in addition, you will need to test that the Bluetooth link also 
continues to work during the EMC tests.   The standard to look at there is EN 
301 489-17 and it calls up EN 301 489-1.

 

You will need to test the Bluetooth radio performance to an appropriate 
standard too, such as EN 300 328.

 

EN 300 328, EN 301 489-17 and EN 301 489-1 all come in versions which are 
harmonised standards, assuming you use the correct version numbers (Vx.x.x, 
etc.) and you test correctly.   (Accredited test lab is not needed, but it 
might give you confidence)

When you have fully applied 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[dward]

Several issues.  First, 15.123 is not the clause exempting devices it is a 
clause referring to labeling of digital ready devices.  

 

Clause 15.103 is for exemption of devices.  So, while it may say exempt, 
unintentional radiator devices are still subject to 15.5 and 15.29 with 
‘strong’ recommendation to comply to part 15.  (NOTE: 15.5b states “Operation 
of an intentional, unintentional, or incidental radiator is subject to the 
conditions that no harmful interference is caused and that interference must be 
accepted that may be caused by the operation of an authorized radio station, by 
another intentional or unintentional radiator, by industrial, scientific and 
medical (ISM) equipment, or by an incidental radiator.”   15.103 main paragraph 
states, “Although not mandatory, it is strongly recommended that the 
manufacturer of an exempted device endeavor to have the device meet the 
specific technical standards in this part.”  So to say there are no mandatory 
EMC requirements is not accurate, as, while being exempt from any specific 
technical requirement, they are required NOT to interfere etc.  

 

It should also be noted that this exemption is ONLY for test equipment, not all 
digital equipment.  NOTE: 15.103c says “​A digital device used exclusively 
as industrial, commercial, or medical test equipment.”   It is not saying a 
piece of medical test equipment and all other industrial or commercial 
equipment.  It is saying industrial test equipment, commercial test equipment 
or medical test equipment.

 

Also, be careful with the concept of fixed in regards exclusive use in these 
areas to exemption under 15.103.  Exclusive does not mean fixed, it simply 
means that it is the ONLY area in which it is used, it means it cannot be taken 
out of the industrial, commercial or medical environment.  I would think that 
test equipment would not be fixed and since the exemption for digital devices 
in these areas is for test equipment, I doubt if it means fixed.

 

Thanks 

Dennis Ward

This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ted Eckert [mailto:ted.eck...@microsoft.com] 
Sent: Thursday, February 18, 2016 6:37 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

Hello Michael,

 

Whether or not EMC requirement apply in North America may depend on whether the 
industrial computer is in a fixed location. Digital devices that are part of 
industrial equipment are generally exempted. Incorporated devices are fixed in 
location and there is a general assumption that the environment is such that 
residential radio receivers, such as televisions, will not be within 3 meters 
of the equipment.

 

A personal computer that has been ruggedized for use in industrial environments 
may still be subject to EMC requirements if it is movable. An industrial 
laptop, for example, may be used in a factory part of the time and in an office 
environment the rest of the time. 

 

I believe the key word is “exclusively” in the regulation you quoted. For a 
device to be exempted, it must be designed and marketed such that it is 
reasonably expected it will only be used in industrial environments.

 

Best regards,

Ted Eckert

Microsoft Corporation

 

The opinions expressed are my own and do not necessarily reflect those of my 
employer.

 

 

From: loerzer_mob...@globalnorm.de   
[mailto:loerzer_mob...@globalnorm.de] 
Sent: Thursday, February 18, 2016 2:09 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an 
industrial personal computer?

 

Hi,

 

I am sorry if my question was answered anytime before. Nevertheless here my 
question:

 

An European manufacturer has applied EN 61326-1 and EN 61010-1 for an 
industrial personal computer in an industrial plant for measurement purposes.

 

What are the mandatory requirements regarding EMC in US/Canada?

 

Is ICES-003 mandatory for Canada? If not in my understanding ICES-001 is also 
not applicable.

Is § 15.123 "exempted devices" (A digital device used exclusively as 
industrial, commercial, or medical test equipment.) for US applicable?  If yes, 
47 CFR Part 18 is in my opion also 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[dward]

In addition to the previous comment I made, it is noted that the FCC defines 
ISM equipment as “Equipment or appliances designed to generate and use locally 
RF energy for industrial, scientific, medical, domestic or similar purposes, 
excluding applications in the field of telecommunication.”  So, unless a 
digital device meets the exemption requirements 15.103 and if it is not a piece 
of test equipment, it is subject to Part 15.  Now then you must look to see if 
it is Class A or Class B.  

 

​

Dennis Ward

This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Thursday, February 18, 2016 8:46 AM
To: 'Ted Eckert' <ted.eck...@microsoft.com>; 'EMC-PSTC@LISTSERV.IEEE.ORG' 
<EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

Several issues.  First, 15.123 is not the clause exempting devices it is a 
clause referring to labeling of digital ready devices.  

 

Clause 15.103 is for exemption of devices.  So, while it may say exempt, 
unintentional radiator devices are still subject to 15.5 and 15.29 with 
‘strong’ recommendation to comply to part 15.  (NOTE: 15.5b states “Operation 
of an intentional, unintentional, or incidental radiator is subject to the 
conditions that no harmful interference is caused and that interference must be 
accepted that may be caused by the operation of an authorized radio station, by 
another intentional or unintentional radiator, by industrial, scientific and 
medical (ISM) equipment, or by an incidental radiator.”   15.103 main paragraph 
states, “Although not mandatory, it is strongly recommended that the 
manufacturer of an exempted device endeavor to have the device meet the 
specific technical standards in this part.”  So to say there are no mandatory 
EMC requirements is not accurate, as, while being exempt from any specific 
technical requirement, they are required NOT to interfere etc.  

 

It should also be noted that this exemption is ONLY for test equipment, not all 
digital equipment.  NOTE: 15.103c says “​A digital device used exclusively 
as industrial, commercial, or medical test equipment.”   It is not saying a 
piece of medical test equipment and all other industrial or commercial 
equipment.  It is saying industrial test equipment, commercial test equipment 
or medical test equipment.

 

Also, be careful with the concept of fixed in regards exclusive use in these 
areas to exemption under 15.103.  Exclusive does not mean fixed, it simply 
means that it is the ONLY area in which it is used, it means it cannot be taken 
out of the industrial, commercial or medical environment.  I would think that 
test equipment would not be fixed and since the exemption for digital devices 
in these areas is for test equipment, I doubt if it means fixed.

 

Thanks 

Dennis Ward

This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ted Eckert [mailto:ted.eck...@microsoft.com] 
Sent: Thursday, February 18, 2016 6:37 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

Hello Michael,

 

Whether or not EMC requirement apply in North America may depend on whether the 
industrial computer is in a fixed location. Digital devices that are part of 
industrial equipment are generally exempted. Incorporated devices are fixed in 
location and there is a general assumption that the environment is such that 
residential radio receivers, such as televisions, will not be within 3 meters 
of the equipment.

 

A

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[dward]

 does not resolve the ambiguity – “Test 
equipment” is “equipment that is intended primarily for purposes of performing 
measurements or scientific investigations [and] includes, but is not limited 
to, field strength meters, spectrum analyzers, and modulation monitors.”

 

It also seems important that the language of FCC is in terms of ‘devices’ more 
often than ‘products’ or ‘equipment’, thus a product or equipment might contain 
several devices each of which must have their particular FCC concerns 
addressed. 

 

Regards, 

Lauren Crane

 

KLA-Tencor

Public | Unrestricted

 

From: Bill Stumpf [mailto:bstu...@dlsemc.com] 
Sent: Thursday, February 18, 2016 11:13 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

Dennis is 100% right. The exemption applies exclusively to products which are 
industrial, commercial, or medical test equipment.  The "test equipment" 
classification applies to all of these categories, not only medical devices - 
at least this is my interpretation.  So if the digital device is not test 
equipment, the exemption does not apply.  If the exemption applies, it only 
pertains to the technical requirements of Part 15.  The general operation 
requirements of 15.5 always apply. As to the Class A/B application, you have to 
look at how the device is marketed. If it is not marketed to the consumer and 
is not intended to be used in the home, then Class A applies.  

 

Bill Stumpf

 

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Thursday, February 18, 2016 11:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

In addition to the previous comment I made, it is noted that the FCC defines 
ISM equipment as “Equipment or appliances designed to generate and use locally 
RF energy for industrial, scientific, medical, domestic or similar purposes, 
excluding applications in the field of telecommunication.”  So, unless a 
digital device meets the exemption requirements 15.103 and if it is not a piece 
of test equipment, it is subject to Part 15.  Now then you must look to see if 
it is Class A or Class B.  

 

​

Dennis Ward

This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Thursday, February 18, 2016 8:46 AM
To: 'Ted Eckert' <ted.eck...@microsoft.com <mailto:ted.eck...@microsoft.com> >; 
'EMC-PSTC@LISTSERV.IEEE.ORG' <EMC-PSTC@LISTSERV.IEEE.ORG 
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Subject: RE: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

Several issues.  First, 15.123 is not the clause exempting devices it is a 
clause referring to labeling of digital ready devices.  

 

Clause 15.103 is for exemption of devices.  So, while it may say exempt, 
unintentional radiator devices are still subject to 15.5 and 15.29 with 
‘strong’ recommendation to comply to part 15.  (NOTE: 15.5b states “Operation 
of an intentional, unintentional, or incidental radiator is subject to the 
conditions that no harmful interference is caused and that interference must be 
accepted that may be caused by the operation of an authorized radio station, by 
another intentional or unintentional radiator, by industrial, scientific and 
medical (ISM) equipment, or by an incidental radiator.”   15.103 main paragraph 
states, “Although not mandatory, it is strongly recommended that the 
manufacturer of an exempted device endeavor to have the device meet the 
specific technical standards in this part.”  So to say there are no mandatory 
EMC requirements is not accurate, as, while being exempt from any specific 
technical requirement, they are required NOT to interfere etc.  

 

It should also be noted that this exemption is ONLY for test equipment, not all 
digital equipment.  NOTE: 15.103c says “​A digital device used exclusively 
as industrial, commercial, or medical test equipment.”   It is not saying a 
piece of medical test equipment and all other industrial or commercial 
equipment.  It is saying industrial test equipment, commercial test 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[dward]

The answer is - look at what is not required to be tested and what is exempt 
from Part 15.  For example, when was the last time a spectrum analyzer was 
required to meet Part 15 digital device requirements? Or when was the last time 
that Scientific test equipment was required to meet Part 15 Digital Device 
requirements?  Never.  The reason is that the concept of test equipment is for 
all three types listed and not only Medical Test Equipment.   One would not 
want the FCC to list test equipment as ONLY Medical test equipment, that would 
be unrealistic.

 

 

​

Dennis Ward

This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Thursday, February 18, 2016 11:58 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

This is an interesting point.   My interpretation has always been that “test” 
only applies to “medical” and that the exemption applied to all industrial and 
commercial equipment.  Oh the joys of the English language.  If we wrote 
software like this we’d likely end up with planes crashing into the ocean:)

 

So what is the correct interpretation?

 

-Dave

 

From: Bill Stumpf [mailto:bstu...@dlsemc.com] 
Sent: Thursday, February 18, 2016 12:13 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

Dennis is 100% right. The exemption applies exclusively to products which are 
industrial, commercial, or medical test equipment.  The "test equipment" 
classification applies to all of these categories, not only medical devices - 
at least this is my interpretation.  So if the digital device is not test 
equipment, the exemption does not apply.  If the exemption applies, it only 
pertains to the technical requirements of Part 15.  The general operation 
requirements of 15.5 always apply. As to the Class A/B application, you have to 
look at how the device is marketed. If it is not marketed to the consumer and 
is not intended to be used in the home, then Class A applies.  

 

Bill Stumpf

 

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Thursday, February 18, 2016 11:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

In addition to the previous comment I made, it is noted that the FCC defines 
ISM equipment as “Equipment or appliances designed to generate and use locally 
RF energy for industrial, scientific, medical, domestic or similar purposes, 
excluding applications in the field of telecommunication.”  So, unless a 
digital device meets the exemption requirements 15.103 and if it is not a piece 
of test equipment, it is subject to Part 15.  Now then you must look to see if 
it is Class A or Class B.  

 

​

Dennis Ward

This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Thursday, February 18, 2016 8:46 AM
To: 'Ted Eckert' <ted.eck...@microsoft.com <mailto:ted.eck...@microsoft.com> >; 
'EMC-PSTC@LISTSERV.IEEE.ORG' <EMC-PSTC@LISTSERV.IEEE.ORG 
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Subject: RE: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

Several issues.  First, 15.123 is not the clause exempting devices it is a 
clause referring to labeling of digital ready devices.  

 

Clause 15.103 is for exemption of devices

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[dward]

Correct.  By definition a PC CANNOT be a piece of test equipment.   PC means 
Personal Computer, which is clearly defined by the FCC as a Class B digital 
device, not a piece of test equipment.  And, if the device is designed so it 
could only be used for one specific control purpose, then, while it may be a 
digital device or even a computing device, it is not a PC.

A PC is a very specific device in the FCC rules.  One problem in our industry 
is that we lump most all computing devices into the term PC and it causes a lot 
of problems if one is not careful.  

As someone once said “Words mean things”.

​

Dennis Ward

This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Thursday, February 18, 2016 12:24 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

But how is a PC test equipment in any sense of the word?  The most a PC can be 
is an automated controller of test equipment. Since it can be used for any 
number of other applications, it is not test equipment, right?  Unless the PC 
manufacturer designed that PC so that it could only be used for one specific 
control purpose.

Ken Javor
Phone: (256) 650-5261



  _  

From: dward <dw...@pctestlab.com <mailto:dw...@pctestlab.com> >
Reply-To: dward <dw...@pctestlab.com <mailto:dw...@pctestlab.com> >
Date: Thu, 18 Feb 2016 12:13:32 -0800
To: <EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

The answer is - look at what is not required to be tested and what is exempt 
from Part 15.  For example, when was the last time a spectrum analyzer was 
required to meet Part 15 digital device requirements? Or when was the last time 
that Scientific test equipment was required to meet Part 15 Digital Device 
requirements?  Never.  The reason is that the concept of test equipment is for 
all three types listed and not only Medical Test Equipment.   One would not 
want the FCC to list test equipment as ONLY Medical test equipment, that would 
be unrealistic.
 
 

​
Dennis Ward
This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.
 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Thursday, February 18, 2016 11:58 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

This is an interesting point.   My interpretation has always been that “test” 
only applies to “medical” and that the exemption applied to all industrial and 
commercial equipment.  Oh the joys of the English language.  If we wrote 
software like this we’d likely end up with planes crashing into the ocean:)

So what is the correct interpretation?
 
-Dave
 

From: Bill Stumpf [mailto:bstu...@dlsemc.com] 
Sent: Thursday, February 18, 2016 12:13 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Dennis is 100% right. The exemption applies exclusively to products which are 
industrial, commercial, or medical test equipment.  The "test equipment" 
classification applies to all of these categories, not only medical devices - 
at least this is my interpretation.  So if the digital device is not test 
equipment, the exemption does not apply.  If the exemption applies, it only 
pertains to the technical req

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[dward]

l personal computer?

Dennis is 100% right. The exemption applies exclusively to products which are 
industrial, commercial, or medical test equipment.  The "test equipment" 
classification applies to all of these categories, not only medical devices - 
at least this is my interpretation.  So if the digital device is not test 
equipment, the exemption does not apply.  If the exemption applies, it only 
pertains to the technical requirements of Part 15.  The general operation 
requirements of 15.5 always apply. As to the Class A/B application, you have to 
look at how the device is marketed. If it is not marketed to the consumer and 
is not intended to be used in the home, then Class A applies. 
 
Bill Stumpf
 
 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Thursday, February 18, 2016 11:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

In addition to the previous comment I made, it is noted that the FCC defines 
ISM equipment as “Equipment or appliances designed to generate and use locally 
RF energy for industrial, scientific, medical, domestic or similar purposes, 
excluding applications in the field of telecommunication.”  So, unless a 
digital device meets the exemption requirements 15.103 and if it is not a piece 
of test equipment, it is subject to Part 15.  Now then you must look to see if 
it is Class A or Class B. 


​
Dennis Ward
This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.


From: dward [mailto:dw...@pctestlab.com] 
Sent: Thursday, February 18, 2016 8:46 AM
To: 'Ted Eckert' <ted.eck...@microsoft.com <mailto:ted.eck...@microsoft.com> >; 
'EMC-PSTC@LISTSERV.IEEE.ORG' <EMC-PSTC@LISTSERV.IEEE.ORG 
<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Subject: RE: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Several issues.  First, 15.123 is not the clause exempting devices it is a 
clause referring to labeling of digital ready devices. 
 
Clause 15.103 is for exemption of devices. So, while it may say exempt, 
unintentional radiator devices are still subject to 15.5 and 15.29 with 
‘strong’ recommendation to comply to part 15.  (NOTE: 15.5b states “Operation 
of an intentional, unintentional, or incidental radiator is subject to the 
conditions that no harmful interference is caused and that interference must be 
accepted that may be caused by the operation of an authorized radio station, by 
another intentional or unintentional radiator, by industrial, scientific and 
medical (ISM) equipment, or by an incidental radiator.”   15.103 main paragraph 
states, “Although not mandatory, it is strongly recommended that the 
manufacturer of an exempted device endeavor to have the device meet the 
specific technical standards in this part.”  So to say there are no mandatory 
EMC requirements is not accurate, as, while being exempt from any specific 
technical requirement, they are required NOT to interfere etc.  
 
It should also be noted that this exemption is ONLY for test equipment, not all 
digital equipment.  NOTE: 15.103c says “​A digital device used exclusively 
as industrial, commercial, or medical test equipment.”   It is not saying a 
piece of medical test equipment and all other industrial or commercial 
equipment.  It is saying industrial test equipment, commercial test equipment 
or medical test equipment.
 

Also, be careful with the concept of fixed in regards exclusive use in these 
areas to exemption under 15.103.  Exclusive does not mean fixed, it simply 
means that it is the ONLY area in which it is used, it means it cannot be taken 
out of the industrial, commercial or medical environment.  I would think that 
test equipment would not be fixed and since the exemption for digital devices 
in these areas is for test equipment, I doubt if it means fixed.
 
Thanks 
Dennis Ward
This communication and its attachements 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.

Re: [PSES] [EXTERNAL] Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[dward]

Actually I believe it was if it was exempt from compliance issues because of 
ISM under 15.103 (mistakenly referred to as 15.123.  From there it went to the 
issue of it being a piece of test equipment that met the exemption, etc etc 
etc.  The Class A or B came about after that discussion. But you are correct, 
either Class A or Class B must meet the associated technical standards.  

​
Dennis Ward
This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Thursday, February 18, 2016 8:26 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 
applicable/mandatory for an industrial personal computer?

The original post was not class A vs. Class B, but whether any FCC requirement 
applied.  I can't see how they could not be required to qualify to class A.

Ken Javor
Phone: (256) 650-5261


> From: Brian O'Connell 
> Reply-To: Brian O'Connell 
> Date: Thu, 18 Feb 2016 20:21:52 +
> To: 
> Conversation: [PSES] [EXTERNAL]  Re: [PSES] 47 CFR Part 15 Subpart B /
> ICES-003 applicable/mandatory for an industrial personal computer?
> Subject: Re: [PSES] [EXTERNAL]  Re: [PSES] 47 CFR Part 15 Subpart B / 
> ICES-003 applicable/mandatory for an industrial personal computer?
> 
> Generally agree, but government people can be capricious. For several 
> years, have loaned a 'measurement device' to customers having issues 
> with interfacing our stuff to their stuff. The device is marked 
> "Property of the Empire. For Test and Evaluation Only". The device is 
> a small plastic box with an USB port and a terminal block for analog 
> and digital inputs that is embedded inside the customer's equipment; 
> and the box has no display/keyboard/etc. Inside this little box is an ARM 4 
> processor and other stuff to measure and record.
> 
> There was one site where the box was supposedly interfering with a 
> zigbee mesh, which resulted in another supplier making complaint. The 
> brilliant and charming government people said that my little box was 
> essentially a computer so should be Class B.
> 
> The customer's laptop computer, while connected to the 'device' USB 
> port, caused the interference. The customer had defeated 
> electromechanical interlocks to run his equipment with their computer 
> connected to my USB port.
> 
> There are several mundane morals to this silly story, but will not 
> restate the obvious.
> 
> Brian
> 
> 
> From: Gary McInturff [mailto:gary.mcintu...@esterline.com]
> Sent: Thursday, February 18, 2016 11:49 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] [EXTERNAL] Re: [PSES] 47 CFR Part 15 Subpart B / 
> ICES-003 applicable/mandatory for an industrial personal computer?
> 
> I interpreted the original post correctly this was a system that was 
> developed by the original posters company expressly to be used in the 
> industrial market.
> It might look like a personal computer but there is another factor to 
> be considered.
> The OEC document provides an escape clause, if you will, in a couple 
> of places if you read it carefully enough. The term ³marketed² is 
> important in this context.  Since I don¹t know who can see snippets of 
> a PDF file and I don¹t want type out the paragraphs I¹m going to just 
> refer you to section 15.3 (h),
> 15.3 (i) and 15.3(s)
> Section (s) defines a personal computer stating ³computers that are 
> ³marketed² through retail outlets, mail order, and advertised to the general 
> public.
> If the original poster is building a computer that isn¹t 
> marketed to the average consumer, advertises in trade magazines rather 
> that Best Buy type circulars, and/or is too big or bulky or even 
> lacking consumer esthetics then it¹s not a personal computer is 
> industrial equipment. The marketing can also include price and 
> supported software functions. 3X the price of an average computer, 
> optimized to support only a CNC machine etc. takes it out of the personnel 
> computer definition.
> 
> Section h and I essentially do the same thing: Class A digital devices 
> are ones that are are ³marketed Exclusively² for use in Business, 
> industrial and commercial environments.
> 
> I had this discussion 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[dward]

I believe the references are 15.3(k) and 15.3(s).  

As to “confused yet”, I have been in that state ever since I started EMC work 
30+ years ago. :(

 

 

​

Dennis Ward

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From: Sykes, Bob [mailto:bob.sy...@gilbarco.com] 
Sent: Friday, February 19, 2016 8:56 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

 

In addition to Mr. Ward's words of wisdom below, it is probably worth 
mentioning that a Class A digital device [as defined in Part 15.1(k)] aka 
"industrial computer" (which may be based on "PC" architecture) cannot take 
advantage of the "Declaration of Conformity" FCC Approval process(es).  These 
are specific FCC approval routes that offers some flexibility, but only apply 
to Class B "Personal Computers" [PC as defined in Part 15.1(s)].

 

See Part 2 for the DoC administrative requirements [2.906 is good starting 
point].  There are also DoC specific labeling and test requirements found in 
Part 15.  This DoC process has nothing to do with the CE Marking "Declaration 
of Conformity"

 

To the original question poster:  It may be worthwhile to take a look at the 
FCC Rules Part 15.31(3)(k) relating to Composite Systems.

 

Confused yet?  Glad it's Friday?

 

-Bob Sykes

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Thursday, February 18, 2016 3:38 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

Probably one of the beneficial aspects of the FCC is that they tend to take the 
manufacturers word for how and where their devices are to be used.  Thus, 
unless the documentation or other information clearly indicates one of those 
purposes is for use in the residential environments, the FCC accepts the 
manufacturers premises if it states ‘commercial use only’ or otherwise 
indicates how they control where the devices are used.  That does not mean 
however that a company can go out to Best Buy and purchase a batch of laptops 
clearly intended for personal use and say they are ‘business computers’.  They 
are still PCs but used in a commercial environment.  

 

So the idea that “Our company uses PCs with our products which are considered 
“Laboratory Equipment”. Our products only have to meet the Class A 
requirements…” may not be totally correct unless the computers the company 
actually buys is a Class A computer and not PC (Personal Computers).  

 

As 15.3s states, “…notwithstanding business applications. Such computers are 
considered Class B digital devices.” 

 

The guiding factor in a computer, computing device or digital device being 
Class B is in the following conditions:

(1)   Marketed through a retail outlet or direct mail order catalog.  (2) 
Notices of sale or advertisements are distributed or directed to the general 
public or hobbyist users rather than restricted to commercial users.  (3) 
Operates on a battery or 120 volt electrical supply.

As the FCC rules state, the proof for classifying a digital device as other 
than Class B lies with the responsible party to demonstrate.

 

​Thanks 

Dennis Ward

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From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: Thursday, February 18, 2016 11:29 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

I don’t thin

Re: [PSES] Maximum Allowed Duty Cycle Correction Factor per FCC 15.35

[dward]

Remember, these are in regards to the limit, NOT the measured values.

 

​

Dennis Ward

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From: Grasso, Charles [mailto:charles.gra...@echostar.com] 
Sent: Monday, April 4, 2016 8:13 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Maximum Allowed Duty Cycle Correction Factor per FCC 15.35

 

Hello Grace – If memory serves me this is buried in 15.35(b) as the peak 
emission maximum allowed over the average value when using DCCF.

 

Best Regards

Charles Grasso

Compliance Engineer

Echostar Communications

(w) 303-706-5467

(c) 303-204-2974

(t) 3032042...@vtext.com  

(e) charles.gra...@echostar.com  

(e2) chasgra...@gmail.com  

 

From: Grace Lin [mailto:graceli...@gmail.com] 
Sent: Friday, April 01, 2016 2:32 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Maximum Allowed Duty Cycle Correction Factor per FCC 15.35

 

Dear Members,

 

Could  you please advise the standard which specified the maximum allowed duty 
cycle correction factor of 20 dB?

 

I remember seeing the requirement from a standard.  With a quick look at the 
FCC 15.35, ANSI C63.4-2014, and ANSI C63.10-2013, I couldn't locate the 20 dB 
maximum requirement.

 

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

 

Best regards,

Grace Lin 

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Re: [PSES] NFC Near Field Communication Devices

[dward]

For FCC NFC transmitters are a certified device.  And starting very soon, 
testing can only be done at an accredited lab either in the US or in an MRA 
partner.  NOTE that the accredited lab in an MRA partner country must be listed 
as a CAB under the MRA and not simply accredited.  Evidently there are a number 
of labs that, while accredited, are not CABs under the MRAs.

 

 

 

​

Dennis Ward

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From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: Wednesday, May 4, 2016 1:37 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] NFC Near Field Communication Devices

 

What can you tell a newb like me about NFC?  It operates in the ISM frequency 
of 13.56Mhz. If we incorporate it into a product, does it require testing by a 
certified or accredited lab?  It is globally accepted without licenses and 
certifications?  

 

Thanks,

The Other Brian 

  _  


LECO Corporation Notice: This communication may contain confidential 
information intended for the named recipient(s) only. If you received this by 
mistake, please destroy it and notify us of the error. Thank you. 


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Re: [PSES] iNARTE EMC accreditation - thoughts?

[dward]

Had several of them; dropped them; don’t need them; don’t want them; never 
helped me get work, never stopped me from getting work.

So, while the certs look pretty, they have little meaning and unless a company 
pays for them, they simply are not worth the expense.  But that is just my view.

 

​

Dennis Ward

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From: Ken Wyatt [mailto:k...@emc-seminars.com] 
Sent: Friday, August 12, 2016 10:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] iNARTE EMC accreditation - thoughts?

 

Hi James,

 

May I offer an alternative viewpoint to my esteemed colleagues (I guess there’s 
one in every crowd)? I believe the answer to gaining iNARTE certification is 
“it depends”, like so many other questions in EMC.

 

When NAVLAP initially proposed and promoted the idea of a NARTE certification 
for EMC engineers and technicians, the only method for gaining a 
"certification” was to provide 10 Q to help develop a question pool. At that 
time, I thought, “well, that’s not going to be too meaningful to anyone who 
really understands how the initial batch of 'certified' engineers obtained 
their badges”, and while I thought about contributing, never did. Through the 
years, though, I do believe those going through the program certainly come away 
with a meaningful certification they can use to help self-promote themselves.

 

Back to my answer of “it depends”. If you’re an unknown quantity approaching a 
potential client, then yes, I believe iNARTE certification would be at least 
something you could dangle in front of them - even though they probably have 
never heard of it.

 

On the other hand, if you’re a “known quantity”, that is, have an established 
internet presence, and have published many articles and books on the subject, 
then I believe that fact would be much more meaningful to a potential client. 
You can now approach them with, “in fact I’ve written a book on the subject”, 
and that alone will hold much more weight than any (usually unknown to them) 
certification.

 

Cheers, Ken


___

 

I'm here to help you succeed! Feel free to call or email with any questions 
related to EMC or EMI troubleshooting - at no obligation. I'm always happy to 
help!


Kenneth Wyatt
Wyatt Technical Services LLC

56 Aspen Dr.
Woodland Park, CO 80863


Phone: (719) 310-5418


Email Me!   | Web Site 
  | Blog  

The EMC Blog (EDN)  
Subscribe to Newsletter 
 
Connect with me on LinkedIn  

 

On Aug 10, 2016, at 10:01 AM, Pawson, James  > wrote:

 

Hello fellow engineers,

 

With an eye on the future, I am considering taking an iNARTE EMC qualification. 
Specifically, I’m considering one (or possibly both) of these accreditations.

 

* iNARTE EMC Design Engineer Certification

* iNARTE Electromagnetic Compatibility (EMC/EMI) Certification

 

I’m looking for your advice and experience of

 

* Gaining these qualifications

* Views of the engineering community on the worth of these 
qualifications

* Suggestions as to which one of these would be most beneficial for a 
career in EMC either working as a company employee or as a 
contractor/consultant in EMC testing and design

 

I appreciate these are open questions and I would appreciate any and all 
opinions. If you feel more comfortable replying off list then please do.

 

Thanks and regards,

James Pawson

 

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Re: [PSES] Co-located modules

[dward]

The other issue is that, just because the FCC may consider collocated as being 
antennas in the same unit, does not affect the 20 cm rf exposure requirement 
for rf exposure in a mobile configuration.  I am not, however, that the FCC 
only considers collocation as stated.  For example, transmitter, other than 
part 15, that have multiple antenna placement using external antennas are still 
referred to this as collocation of antenna.  So, while the FCC may consider 
part 15 device antenna collocation as antennas in the same device, it may not 
hold true for other rule parts.

Thanks 

 

​

Dennis Ward

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From: Bill Stumpf [mailto:bstu...@dlsemc.com] 
Sent: Wednesday, February 15, 2017 5:34 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Co-located modules

 

The latest chatter I gathered on this topic is that the FCC considers 
collocated as "in the same enclosure".  Indications are that any reference to 
<20cm being considered collocated has been set aside. 

 

Bill

 

From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Wednesday, February 15, 2017 2:18 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] Co-located modules

 

Hi Stephen,

 

One thing to remember is that “must not be co-located” really just means “must 
not be co-located without some additional effort”

 

For example, co-locating two modules and then calculating the new combined RF 
Exposure MPE value to verify that the product still meets the requirements, 
would be acceptable.   It does not necessarily mean a C2PC is needed, for 
example.

 

I think you’re right that 20 cm is ‘good guidance’ with regard to RF Exposure.  
 But if your modules are 20.5cm apart, you might still want to consider the 
overall compliance of that final product… and a co-located MPE calculation is 
not too hard.

 

 

Thanks,

 

Michael.

 

 

 

From: Stephen Whalen [mailto:scwha...@bellsouth.net] 
Sent: 14 February 2017 23:34
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Co-located modules

 

All,

For a module that has "must not be co-located" restriction on FCC grant.  

What is the minimum separation distance allowed for another transmitter?  I 
recall 20cm but can't find where it is documented.

 

Regards,

Stephen

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Re: [PSES] Cell phone power output, legal limits in USA

[dward]

Part 22H, 24E, 27 and 90S. Part 90S however, has some bands that are not ERP 
but antenna conducted.

​
Dennis Ward
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-Original Message-
From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Monday, August 22, 2016 8:08 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Cell phone power output, legal limits in USA

Can someone point me to an authoritative source on legal limits on cell phone 
ERP for all the various bands used in the USA?

Thank you,

Ken Javor
Phone: (256) 650-5261

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Re: [PSES] Cell phone power output, legal limits in USA

[dward]

The question was what are the FCC limits, not the 3G or 4G limits and specs. 
Those are quite different.

​
Dennis Ward
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-Original Message-
From: Deniz Demirci [mailto:deniz.demi...@nts.com] 
Sent: Monday, August 22, 2016 11:52 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Cell phone power output, legal limits in USA

Yes, generally the SAR is a limiting factor for regulatory compliance, but the 
cell carriers in North America also assumes the mobile stations are compliant 
with the technical conformance specifications, such as 3GPP... The RF power 
levels for PCS/GSM bands are quite high based on power classes but not for 
LTE...
The min./max. RF power levels and the power classes are very well defined the 
technical specification standards which can be found in the ETSI web site for 
free.

Regards,

Deniz

-Original Message-
From: dward [mailto:dw...@pctestlab.com]
Sent: Monday, August 22, 2016 10:32 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Cell phone power output, legal limits in USA

Yes they are CFR 47.
Part 22H has a limit of 7W ERP for mobile phones, but no manufacturer would 
ever do that high simply because the device would never pass SAR requirements.
Part 24E is limited to 2W EIRP.
Part 27 varies depending on the frequency of operation. For example, the eirp 
for the 2300MHz band is 50mW/MHz; portable stations in the 746-757 MHz, 776-788 
MHz are allowed 3W eirp; eirp in the 1915-1920 MH band is 300mW; Mobile 
stations transmitting in the 1390-1392 MHz and 1432-1435 MHz bands are limited 
to 4 watts EIRP peak power. Mobile stations transmitting in the1392-1395 MHz 
band are limited to 1 watt EIRP peak power; BRS and EBS Mobile stations are 
limited to 2.0 watts EIRP; and in the 1700MHz band 1 W eirp.
Part 90, except where the band overlaps part 22 bands, it is a maximum antenna 
conducted power limit of 100W in the 800MHz bands.  But then again, regardless 
of the allowed power, SAR is still a limiting requirement.
Thanks 

​
Dennis Ward
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-Original Message-
From: Ken Javor [mailto:ken.ja...@emccompliance.com]
Sent: Monday, August 22, 2016 8:35 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Cell phone power output, legal limits in USA

Are these parts in Title 47?

Thank you,

Ken Javor
Phone: (256) 650-5261


> From: dward <dw...@pctestlab.com>
> Date: Mon, 22 Aug 2016 08:25:07 -0700
> To: 'Ken Javor' <ken.ja...@emccompliance.com>, 
> <EMC-PSTC@LISTSERV.IEEE.ORG>
> Subject: RE: [PSES] Cell phone power output, legal limits in USA
> 
> Part 22H, 24E, 27 and 90S. Part 90S however, has some bands that are 
> not ERP but antenna conducted.
> 
> ​
> Dennis Ward
> This communication and its attachements 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.
> Usage of PCTEST email addresses for non-business related activities is 
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> 
> -Original Message-
> From: Ken Javor [mailto:ken.ja...@emccompliance.com]
> Sent: Monday, August 22, 2016 

Re: [PSES] Cell phone power output, legal limits in USA

[dward]

While the legal limits available may do as you mentioned, the legal limit for 
some rule parts is not appropriate, so calculating the highest field intensity 
available has no real meaning other than for information.
It has been years (actually before the TCB program) when a part 22 phone may 
have been greater than 2W.  Now, however, the 2W limit, again due to SAR 
issues, may be the easiest way to approach a calculation on the highest 
available field intensity for phones. That of course with the caveat that, 
while power may be higher in the rules, the SAR would most likely be exceeded, 
so the phone could not comply with Parts 1 and 2 of CFR 47.

​
Dennis Ward
This communication and its attachements 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.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

-Original Message-
From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Monday, August 22, 2016 12:26 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Cell phone power output, legal limits in USA

I asked for legal limits in USA, which I expected meant FCC, but I did not 
explain why.  I have a customer trying to ascertain the highest field intensity 
available from cell phones (as a function of distance cm to
meters) in use in the USA, and I expected a legal limit on transmit power would 
upper-side bound that.

Ken Javor
Phone: (256) 650-5261


> From: dward <dw...@pctestlab.com>
> Reply-To: dward <dw...@pctestlab.com>
> Date: Mon, 22 Aug 2016 12:04:11 -0700
> To: <EMC-PSTC@LISTSERV.IEEE.ORG>
> Subject: Re: [PSES] Cell phone power output, legal limits in USA
> 
> The question was what are the FCC limits, not the 3G or 4G limits and specs.
> Those are quite different.
> 
> ​
> Dennis Ward
> This communication and its attachements 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.  
> Usage of PCTEST email addresses for non-business related activities is 
> strictly prohibited.  No warranty is made that the e-mail or 
> attachments(s) are free from computer virus or other defect.  Thank you.
> 
> -Original Message-
> From: Deniz Demirci [mailto:deniz.demi...@nts.com]
> Sent: Monday, August 22, 2016 11:52 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] Cell phone power output, legal limits in USA
> 
> Yes, generally the SAR is a limiting factor for regulatory compliance, 
> but the cell carriers in North America also assumes the mobile 
> stations are compliant with the technical conformance specifications, 
> such as 3GPP... The RF power levels for PCS/GSM bands are quite high 
> based on power classes but not for LTE...
> The min./max. RF power levels and the power classes are very well 
> defined the technical specification standards which can be found in 
> the ETSI web site for free.
> 
> Regards,
> 
> Deniz
> 
> -Original Message-
> From: dward [mailto:dw...@pctestlab.com]
> Sent: Monday, August 22, 2016 10:32 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] Cell phone power output, legal limits in USA
> 
> Yes they are CFR 47.
> Part 22H has a limit of 7W ERP for mobile phones, but no manufacturer 
> would ever do that high simply because the device would never pass SAR 
> requirements.
> Part 24E is limited to 2W EIRP.
> Part 27 varies depending on the frequency of operation. For example, 
> the eirp for the 2300MHz band is 50mW/MHz; portable stations in the 
> 746-757 MHz,
> 776-788 MHz are allowed 3W eirp; eirp in the 1915-1920 MH band is 
> 300mW; Mobile stations transmitting in the 1390-1392 MHz and 1432-1435 
> MHz bands are limited to 4 watts EIRP peak power. Mobile stations 
> transmitting in
> the1392-1395 MHz band are limited to 1 watt EIRP peak power; BRS and 
> EBS Mobile stations are limited to 2.0 watts EIRP; and in the 1700MHz 
> band 1 W eirp.
> Part 90, except where