[PSES] Red and Green lights on machinery

[Brian Kunde]

Greetings to all.

We are working on a motor driven machine that would be used in a
commercial, industrial, and light industrial environment.

The machine has a Green button to Start, and a Red button to Stop.  These
buttons are illuminated.  Other than the e-stop, these are the only
operator controls on the product.

When the machine is stopped, the Green button is lit. When you press the
green button, the motor starts, but then the green light in the button goes
out and the red light in the Stop button lights up (not flashing).Is
this OK?

The design team for this project thought it would help the Operator find
the buttons easier this way.

I must also state that this machine is not designed to follow the
construction rules for Control Panels. We call it a highbred design.  It
will be serviced and maintained by the manufacturer.

My only question is regarding the illuminated lights but feel free to
comment on any other aspect of this email.

Regards,
The Other Brian

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[PSES] High Touch Current in Industrial Machinery

[Brian Kunde]

I am working on an Industrial Machine with a 3-phase 5hp motor driven by a
VFD. To pass the EMC conducted emissions requirements, we had to add a RF
Line Filter that is recommended by the VFD manufacturer.  This filter has
large Y-Caps. I know these currents theoretically cancel out in a balanced
system, but when performing the traditional Touch Current test according to
IEC 60990 6.2.2.2, Fault Condition No. 1 (open Protective Conductor) we
measure a current about 50mA.

However, the standard says that "this subclause do not apply to reliably
earthed equipment. . . .". This Industrial Machine is either permanently
wired or it can use an industrial grade plug and socket, so this fault test
would not apply.

So even though the measured current is high if we perform this fault test,
because the machine is well grounded I do not have to do anything?

In contrast, the IEC 62368 would require a warning label, warning in the
manual, and a secondary PE terminal.

I have read comments online such as, "in the industrial environment, they
don't give a hoot about leakage current." Is this true?

On the other hand, an industrial machine could be the size of a building
and have dozens of VFD driven motors and line filters creating a huge
amounts of currents in an unbalance environment. So in my case, do I have
any concerns other than to insure the machine is well bonded to PE during
installation? But isn't this a normal installation consideration?

Thanks to all.
The Other Brian

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Re: [PSES] [EXTERNAL] Re: [PSES] Reduce Speed of Moving Part to Reduce Risk

[Brian Kunde]

I appreciate the replies on this topic.

My original question had less to do with how speed of motion affects the
injury and more to do with how speed affects the User/Operators ability to
Avoid the hazard in the first place. The IEC 61010-1 standard mentions how
velocity factors into the Risk Assessment for avoiding the hazard, but it
does not elaborate.

Thanks again to all.
The Other Brian

On Tue, Jan 30, 2024 at 9:01 AM Jim Hulbert 
wrote:

> ISO/TS 15066:2016 is a standard for Collaborative Robots (COBOTS).   While
> COBOT specific, it does contain a great deal of information on risk of harm
> based not only on the mass and velocity of the moving part of the COBOT,
> but also the duration of contact with the body, body part impacted, and
> surface area of contact.   Lots of interesting equations.
>
>
>
> Jim Hulbert
>
>
>
> *From:* Douglas Powell 
> *Sent:* Monday, January 29, 2024 7:04 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [EXTERNAL] Re: [PSES] Reduce Speed of Moving Part to Reduce
> Risk
>
>
>
> All valid points; however, I was taking my information from the
> established ISO/IEC standards for machinery, with which I am familiar. I do
> recall another standrd some years ago, mentioning contact surface area when
> I was looking into finger crush as well as sharp edges. And the
> original question was solely about speed, so that's how I responded.
>
>
>
> All the best,  ~ Doug
>
>
>
>
>
> Douglas E Powell
>
> Laporte, Colorado, USA
>
> doug...@gmail.com
>
> LinkedIn
> 
>
>
>
> (UTC-06:00, US-MDT)
>
>
>
>
>
> On Mon, Jan 29, 2024 at 4:41 PM Richard Nute  wrote:
>
>
>
> Hi Doug and Brian:
>
>
>
> I thought I would offer my (radical) point of view on the issue of “speed
> of moving parts.”
>
>
>
> Consider moving aluminum foil and moving aluminum block, both at the same
> speed.  The aluminum foil has very little mass, while the aluminum block
> has relatively high mass.  The foil is not likely to cause injury, while
> the block may cause injury.
>
>
>
> Consider an aluminum needle and an aluminum block, both having the same
> speed and mass.  The needle is likely to cause injury, while the block is
> not likely to cause injury.
>
>
>
> Consider the time of contact with a moving part.  If the time is long,
> then injury is not likely.  If the time is short, then injury is likely.
>
>
>
> So, in addition to speed, we must consider mass of the block, contact
> area, and duration of the contact in predicting injury.
>
>
>
> In other words, energy per area (mv2 per area in this case) whether
> mechanical, thermal, radiant, chemical, or electrical, transferred to a
> body part for a (usually short) period of time, causes injury.  The same
> energy magnitude transferred over a long period of time is not likely to
> cause injury.
>
>
>
> An injury occurs only when energy per contact area of sufficient magnitude
> and duration is imparted to a body part.  Both the safety science article
> and the IRSST paper discuss energy of moving parts and area, but do not
> address the other parameters.  Both introduce (to me) the concept of
> “force” on various body parts.  I’m not sure of how this fits into this
> safety discussion.
>
>
>
> Consideration of speed alone is over-simplification.
>
>
>
> Best regards,
>
> Rich
>
>
>
>
>
> *From:* Doug Nix 
> *Sent:* Monday, January 22, 2024 11:16 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Reduce Speed of Moving Part to Reduce Risk
>
>
>
> Hi Brian,
>
>
>
> In the machinery sector, 250 mm/s has long been used as the threshold for
> avoidability. This figure comes from the robot standards and has been used
> for about 30 years. Studies done at the Polytechnique de Montréal [1] and
> IRSST [2] have shown that a speed closer to 140 mm/s is more universally
> avoidable by people working in various environments, but the long use of
> 250 mm/s has entrenched that higher speed. Related to that is the IRSST’s
> Repoer R-956. I’ve attached copies of these documents for you.
>
>
>
> You can find the 250 mm/s number quoted in most machinery safety standards
> where reduced speed is considered for risk reduction. The origin is in
> ANSI/RIA R15.06 1992, which made its way into CSA Z434 and then eventually
> to ISO 10218.
>
>
>
> [1]  Y. Chinniah, B. Aucourt, and R. Bourbonnière, “Study of
> Machine Safety for Reduced-Speed or Reduced-Force Work R-956,” IRRST -
> Institut de recherche Robert-Sauvé en santé et en sécurité du travail,
> Montreal, 2017.
>
>
>
> [2]  Y. Chinniah, B. Aucourt, and R. Bourbonnière, “Safety of
> industrial machinery in reduced risk conditions,” Safety Science, vol. 93,
> pp. 152–161, Mar. 2017, doi: 10.1016/j.ssci.2016.12.002.
>
>
>
>
>
> Best regards,
>
>
>
> Doug Nix
>
> d...@ieee.org
>
> +1 (519) 729-5704
>
>
> 

[PSES] Reduce Speed of Moving Part to Reduce Risk

[Brian Kunde]

Greetings All.

The IEC/EN 61010-1 table 12, Risk assessment of mechanical hazards to body
parts, states that a hazard can be avoidable if the speed of the motion was
reduced.  Reduced to what speed?
It says, "The motion is visible and velocity is low enough for body parts
to be removed without being trapped".

This 2010 version of the standard is very helpful by including max forces
and max continuous contact pressures, but does not specify a speed or
velocity.

I assume the information I am after can be found in some other standard so
I have come to you for help.

For instance, the ISO 16089:2015 says in some conditions a speed of 0.5
meter per minute is allowed (only 0.33 inches per second) or 2 meters per
minute (1.3 inch per second) if you have a Hold-To-Run device.  Are these
values universal?  Are there other standards that do a better job at
specifying actual values to consider when evaluating mechanical hazards?

Are there "Rules of Thumb" that field inspectors use to make this
determination?  Do the occupational health and safety organizations provide
actual values to design and test to?

Thanks to all.
The Other Brian  (yeah, I am still around)

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Re: [PSES] ESD testing - Contact Mode to plated metal surfaces?

[Brian Kunde]

The standard I have says this in section 8.3.2:

*"In the case of painted surfaces covering a conducting substrate, the
following procedure shall be adopted: *

*If the coating is not declared to be an insulating coating by the
equipment manufacturer, then the pointed tip of the generator shall
penetrate the coating so as to make contact with the conducting substrate.
Coating declared as insulating by the manufacturer shall only be submitted
to the air discharge. The contact discharge test shall not be applied to
such surfaces. *

*In the case of air discharges, the ESD generator shall approach the EUT as
fast as possible until contact between the electrode and the EUT is made
(without causing mechanical damage). After each discharge, the ESD
generator (discharge electrode) shall be removed from the EUT. The
generator is then retriggered for a new single discharge. This procedure
shall be repeated until the discharges are completed. In the case of an air
discharge test, the discharge switch, which is used for contact discharge,
shall be closed."  *

The standard probably should not call out "painted" but worded in a way
that would include all types of coatings.  Maybe the newer versions of the
standard clarifies this.

The Other Brian

On Mon, Sep 18, 2023 at 9:13 PM Brent DeWitt  wrote:

> I believe the language said something like: "the contact discharge tip
> shall be applied to any coating not expressly declared as insulative"
>
> Could be wrong though.
>
> Brent DeWitt
> Milford, MA
>
> On 9/18/2023 7:39 PM, Ken Wyatt wrote:
>
> Always had the impression the sharp end of the CD tip was designed to
> punch through any coated metal.
>
> Kenneth Wyatt
> Woodland Park, CO
> Sent from my iPhone.
>
> On Sep 18, 2023, at 09:48, Sykes, Bob 
>  wrote:
>
> 
>
> Worldly Experts,
>
>
>
> I have a question regarding the suitability of contact mode ESD testing to
> plated metal surfaces.  I understand the wording in IEC 61000-4-2 regarding
> painted and bare metal.  Does the same logic used for painted metal
> surfaces also apply to other coatings (anodized, plated, passivated etc.)?
> These are not addressed in the Standard.
>
>
>
> adTHANKSvance,
>
> Bob Sykes
>
>
>
>
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[PSES] Directives that require the CE Marking

[Brian Kunde]

I have a non-electrical benchtop product that holds a piece of sandpaper
while slowly running water over the sandpaper. The only connection to this
product is a water supply at normal water supply pressure.  The User holds
the item they want to sand in their hand and rubs it back and forth on the
sandpaper.  It is as simple as that.

Is there an EU Directive that covers this type of product and if so, is the
Directive part of the CE Scheme?  I don't think there is but I am not
familiar with all of the EU Directives.


So why am I asking?  Believe it or not, some Sales and Marketing types like
to see the CE Marking on products. They feel it makes things sell better
and it avoids uneducated customers from asking why there is no CE marking
on the product.

Thanks for any advice, ideas, information, or suggestions.
The Other Brian

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Re: [PSES] Woodgate's reply on residential Immunity field strength

[Brian Kunde]

The exposure limits according to the ICNIRP depends on frequency, of course.

>From 1hz to 300hz the Occupational limits are like 20kV/m for E-Field and
40k to 200uT.

>From 3khz to 10Mhz the limit is 170V/m (100uT).  For the General Public (up
to 24 hours a day), the limit is 83V/m (27uT).

For example.

The Other Brian

On Thu, Jul 27, 2023 at 3:48 PM John Woodgate  wrote:

> The EM field exposure limits are not always in standards: in Europe they
> are in a European Council document based on Commission-funded research
> (ICNIRP). I don't recall any limits as low as 10 V/m.
> On 2023-07-27 19:07, Richard Nute wrote:
>
>
>
> I’m a product safety engineer.  This discussion is based upon a safety
> standard specifying a limit for the accessible electric field strength.
>
>
>
> Doug Smith said:
>
>
>
> “These days we think 10 V/m is dangerous.“
>
> See:
>
>
>
> https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3553569/
>
>
>
> This article (with scholarly research annotated) essentially says that we
> don’t know the effects of electric and magnetic fields on the body.  It
> cites 0.4 uT (>100 V/m) as a potential limit for children.  Doug goes on to
> cite his experience with exposure to 100 times 100 V/m with no ill
> effects.
>
>
>
> I wonder how the standards writers came up with limiting field strength
> when there is no definitive bodily injury?  Probably BOGSAT.
>
>
>
> Best regards,
>
> Rich
>
>
>
> ps:  Field strength conversion calculator:
>
>
>
> https://www.compeng.com.au/field-strength-calculator/
>
>
>
>
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[PSES] IEEE EMC + SIPS 2023 Symposium in Grand Rapids, Michigan

[Brian Kunde]

Who is planning to attend this event?

I will be there on Tuesday wandering around the vendor booths (autographs
are free☺ hee-hee).  Look for me and say "Howdy!!".  I will have my "The
Other Brian" name tag on.  It would be nice to put a face with the names.

I know many of you will be presenting.  Good luck to you all.  I am looking
forward to the live demonstrations as well.

I am more of a nerd than a geek so I don't get into all the social stuff.
But if there is a workshop or some event that is a Must See let me know.

See you there!!

The Other Brian

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[PSES] Current Probe for Surge Immunity Calibration Validation

[Brian Kunde]

Greetings Everyone.

To validate a Surge Immunity Generator and CDN, the IEC 61000-4-5 standard
refers to a "Current Probe" for measuring the Short-Circuit Current.   I
wish to buy one.

Can anyone recommend a model and supplier/manufacturer of a current probe
that they like and will do a good job for this application?

Thank you all very much.

The Other Brian

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Re: [PSES] FCC Part B questions

[Brian Kunde]

If I may pile on late, keep in mind that measurement uncertainty is Plus or
Minus (±). Years ago when I was with a previous company, we had a buy/sell
piece of junk product that we were selling with our company's brand/name on
it. It was audited in Sweden as part of their surveillance program and it
failed by 2dB.  The test lab said they could not say it FAILED because 2dB
was within their measurement uncertainty, so we could continue to ship and
sell this product in Sweden.

Has anyone else ever experienced this?

Thanks,
The Other Brian


On Sat, Jul 8, 2023 at 8:28 AM Brent DeWitt  wrote:

> Hi Brian.  It's not entirely clear which measurement range you are asking
> about, but I'll assume conducted emissions in the range of 150 kHz to 30
> MHz.
>
> Short answer: You can skip QP and Avg detection if the peak detection
> level is below the Avg detection limit.
>
> No margin is "required" to pass any emissions limit.  Zero dB margin is
> still passing.  That said, measurement uncertainty in that range is
> generally 3-4 dB, so having a passing margin greater than that gives you
> some confidence that a re-test at another time and lab will still pass.
>
> Hope that helps.
>
> respectfully,
>
> Brent DeWitt
> Milford, MA
>
> On 7/8/2023 12:38 AM, Brian Gregory wrote:
>
>
>  Hi there,
>
> A question came up that I can't answer w/o a copy of Part 47.
> Does the FCC report require Quasi-Peak (QP) data, or just Avg and Peak.
> When do peak readings trigger the need to report QP?  I'm pretty sure Part
> 15 has AVG and QP limits listed.
>
> Next was what sort of margin is expected in order to pass CE emissions
> requirements (CISPR 16 or 32)?  Memory serves that one wants 3dB of margin,
> but memories can be imperfect!
>
> "Colorado" Brian
> 720-450-4933
> -
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Re: [PSES] EU Machinery Regulation official version

[Brian Kunde]

Is there a good source of information on the application of this new
directive?  Are there any good articles or summaries comparing the new
directive to the old?  Are there implementation dates? Can we
declare compliance to the new directive now, or are their other hurdles
that need to be put into place?

Is there a source for good comments and discussion on this?  I have only
just started to dig into it.

Thanks to all.
The Other Brian



On Thu, Jun 29, 2023 at 2:12 PM Lauren Crane <
1afd08519f18-dmarc-requ...@listserv.ieee.org> wrote:

> FYI – now published in the OJ --
> https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R1230
>
>
>
> Best Regards,
>
> -Lauren
>
>
>
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[PSES] How to Measure Surface Conductivity?

[Brian Kunde]

I have been given two samples of metal plates; one plated in our current
material and the other with a new plating material we want to switch to in
production.  I have been tasked to compare the electrical surface
conductivity.

What is the best way to do this?  How is this done in the industry?

I have tried the following methods;
1. DMM (Ohm Meter) = inconclusive results
2. Used 5 volts from a current limited power supply and measured the
current = inconclusive results
3. Used our Ground Bond Tester set to 60 amps. One plate measured 3-4mΩ,
the other 1-3mΩ

I measured 1 inch apart and from corner to corner. Test #3 above is the
only test that showed any difference.

BTW, I use 3/4" squares of soft braid material between the probes and
surface. The probes are zeroed out between tests.

So far, I can conclude that the new material is as good as, or slightly
better than our current production plating material.

What more can I do, within reason?

Thanks to all.
The Other Brian

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[PSES] X-Caps after Diode Bridge

[Brian Kunde]

We use X2 caps in RF filters prior to the Diode Bridge.  Do filter caps
after the Diode Bridge (DC), but before the isolation transformer,  have to
be X2?  How about filter caps to Chassis/PE after the Bridge? Do they have
to be Y-caps?

Thanks,
The Other Brian

PS: We typically buy power supplies, so I am not familiar with the
downstream requirements.

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[PSES] Egypt Customs Requirements for Electronic Equipment

[Brian Kunde]

I have a piece of Electronic Equipment (laboratory equipment declared under
the Machinery Directive) being held up in Egypt Customs. They say they
accept the CE marking and EU-DoC but the DoC has to be signed by some
authority other than the Manufacturer.  What does that mean?

Does anyone know what I have to do?

Thanks,
The Other Brian

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Re: [PSES] Secondary creepage/clearance

[Brian Kunde]

The simple answer is that you need to provide creepage and clearance
distances in secondary circuits to avoid arcing when the circuit is
subjected to the absolute worst case surges and transients that the circuit
might see.  Since this can be difficult to determine, most people just use
the tables found in the standard. These tables are also found in the IP
Standards used by PCB CAD programs.

Notice that Table 6 says, "circuits derived from Mains", which means
circuits that are or can be affected by commonly known surges and
transients on the AC Mains.  These tables are created as a guide to take
some of the guess work and testing out of the equation.  Circuits that are
highly isolated or independently generated may not be subject to junk that
gets onto the AC Mains.  But keep in mind that there are some transients,
such as from relays, solenoids, switch contacts, etc. that can be quite
strong in a local circuit, so you must be careful not to underdesign.

I think the old version of the 61010-1 standard had an equation that took
into account the maximum transient overvoltage, but I think that has now
been integrated into Table 6 in Ed. 3 of the standard.

If you can run tests on your secondary circuits and can determine the worst
case surges and transients, you can design to those distances.  Also keep
in mind the use of PCB coatings, potting, pollution degree, etc..  Inner
layers of a PCB can have closer trace distances in most cases.

Good luck and have fun with it.

The Other Brian

On Thu, Dec 1, 2022 at 3:51 PM Steve Brody  wrote:

> I have a client who has a secondary pwb that has traces and vias that may
> have 100 vdc on them adjacent to ground.
>
> Per 61010-1 there is a requirement for spacing and/or dielectric test,
> both depending on what the mains voltage is.
>
> The question is why is the mains voltage a consideration or concern if the
> 100vdc secondary voltage is several layers of impedance and circuitry from
> the mains?
>
> Is it a concern that a surge on the mains would trickle down to the
> secondary circuit, or is there another reason/rationale?
>
> I suggested that a dielectric test per Table 6 [in A1] would suffice and
> put the issue to rest for this product, but the question from the designers
> remains as to why is it a concern in the standard of what the mains voltage
> is.
>
> Is there anything in the standard, that I haven't found, that does not
> require Table 6 to be followed if there is no way for a mains surge to
> impact the secondary voltage?
>
> I look to the experts for an explanation.
>
> Thanks,
>
> Steve Brody
> sgbr...@comcast.net
> C - 603 617 9116
> -
> 
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Re: [PSES] Surge Protection Device required by NEC

[Brian Kunde]

Exactly!!! The IEC 62326-1 calls out Immunity Test Requirements for
Industrial Electromagnetic Environment on the AC Mains, such as ±2kV Fast
Transients/Burst, Surges, and Voltage dips and interruptions.

If an Industrial Machine is tested and passes these tests, then is
additional SPDs required?  Or does the NFPA 70 & 79 make SPDs required
regardless?
Thanks,
Brian

On Wed, Nov 2, 2022 at 3:28 PM MIKE SHERMAN  wrote:

> If you are declaring conformance with the EU’s EMC Directive, there are
> standard surge tests to run. There are generic “light industrial” and
> “heavy industrial” levels of surge immunity. As shorthand, “heavy” can be
> interpreted as a facility with its own pad transformer, and “light” as one
> that shares a utility transformer with others (think strip mall).
> There’s also a “fast transient” test, as I recall. That might be related
> to lighting strikes, but there are others on this forum who know this
> better than I.
>
> Mike Sherman
> Sherman PSC LLC
>
> On 11/02/2022 1:59 PM Brian Kunde  wrote:
>
>
> Very good information, all.
>
> So how do I know if my product is "*effectively protected from
> voltage surges on the incoming supply circuit"??*
> Can I test my product to the Surge Immunity Test IEC 61000-4-5 at some
> voltage??? 2kV?, 3kV? 4kV? higher? to make that determination?
>
> How is a Field Inspector going to determine if a product is efficiently
> protected or not?
>
> The manufacturers of Surge Protection Devices are saying their "listed"
> devices are now "Required", and there's no way around it. The hair on the
> back of my head sticks up when I hear such things.
>
> Manufacturers of Industrial Machines will not know if their customer
> already has Surge Protection, so why should the both parties be burdened
> with the cost of double protection. Can the machine manufacturer specify
> that the facility must provide the SPD?
>
> Instead of just requiring a SPD, why not require the Machine Manufacturer
> to insure their products pass a Surge Immunity Test of some kind? Isn't
> Surge Immunity already a requirement in the electrical safety standards
> that Machines have to meet anyway?
>
> You got me thinking, now. Thanks again.
> Brian
>
>
> On Tue, Nov 1, 2022 at 5:26 PM Don Gies <
> 0e5e843b011c-dmarc-requ...@listserv.ieee.org> wrote:
>
> Group,
>
>
>
> The requirement for surge protection in NFPA 70 (2023): 670.6 goes back to
> NFPA 79, “Electrical Standard for Industrial Machinery.”
>
>
>
>
>
> The scope NEC 70 (2023): 670  refers to NFPA 79, as follows:
>
>
>
> *Article 670 Industrial Machinery*
>
> 670.1 Scope.
>
> This article covers the nameplate data for, overvoltage protection for,
> and the size and overcurrent protection of supply conductors to industrial
> machinery.
>
> Informational Note No. 1:
> See NFPA 79, *Electrical Standard for Industrial Machinery*, for further
> information.
>
> Informational Note No. 2:
> See 110.26
> <https://link.nfpa.org/publications/70/2023/chapters/1/articles/110#ID00070283>
> for information on the workspace requirements for equipment containing
> supply conductor terminals.
>
> Informational Note No. 3:
> See NFPA 79, *Electrical Standard for Industrial Machinery*, for
> information on the workspace requirements for machine power and control
> equipment.
>
> 670.6 reads as follows (2023 NEC):
>
> 670.6 Overvoltage Protection.
> Industrial machinery with safety circuits shall have overvoltage
> protection.
>
>
>
> Under NFPA 79:  7.8.1, the requirement for surge protection is as follows:
>
>
>
> 7.8.1*
> <https://link.nfpa.org/publications/79/2021/annexes/A/groups/7#ID000790001728>
>  Surge-Protective
> Devices (SPDs).
>
> Industrial machinery with safety circuits not effectively protected from
> the effects of overvoltages due to lightning or switching surges shall have
> surge protection installed.
>
> Exception:
> SPDs shall not be required where the risks associated with the effects of
> overvoltages are mitigated such that the safety performance determined by a
> risk assessment is met.
>
> Enhanced Content
>
> The term *surge-protective devices (SPDs*) has replaced the previously
> used terms * overvoltage protection device, lightning overvoltage
> suppression*, and *surge switching overvoltage suppression* in 7.8.1,
> 7.8.2
> <https://link.nfpa.org/publications/79/2021/chapters/7#ID00079458>,
> and 7.8.3
> <https://link.nfpa.org/publications/79/2021/chapters/7#ID000790001613>.
> See the definition of *surge-protective device (SPD)* in 3.3.104
> <https://link.nfpa.org/publicatio

Re: [PSES] Surge Protection Device required by NEC

[Brian Kunde]

gt;
>
> Does “effectively protected” mean passing the dielectric (hi-pot) test?
>
>
>
> Richard Nute
>
> Bend, Oregon, USA
>
> (Several inches accumulation of snow this morning, but above freezing.)
>
>
>
>
>
> *From:* Doug Powell 
> *Sent:* Tuesday, November 1, 2022 11:28 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Surge Protection Device required by NEC
>
>
>
> From the 2020 Edition, emphasis is mine.
>
>
>
> "670.6 Surge Protection. Industrial machinery with safety interlock
> control devices *not effectively protected from voltage surges on the
> incoming supply circuit* shall have surge protection installed."
>
>
>
> It does not say where this protection needs to be applied, so I assume it
> can be within the machine or somewhere in machine supply. Also, does the
> product you are inquiring about fall under the definition of *Industrial
> Machinery*, NFPA 79?
>
>
>
> -Doug
>
>
>
> Douglas E Powell
>
> Laporte, Colorado USA
>
> doug...@gmail.com
>
> LinkedIn
> <https://eur02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.linkedin.com%2Fin%2Fcoloradocomplianceguy%2F=05%7C01%7Cdonald.gies%40se.com%7C2941b6fae766483a408508dabc4414aa%7C6e51e1adc54b4b39b5980ffe9ae68fef%7C0%7C0%7C638029297833795988%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=aTsjPeQTYkClbU2fXAmeM4UidLwnyb9v3wEYHCSB7WI%3D=0>
>
>
>
> (UTC -06:00) Mountain Time (US-MDT)
>
>
>
>
>
>
>
> On Tue, Nov 1, 2022 at 11:55 AM Brian Kunde  wrote:
>
> It just came to my attention that section 670.6 of the US National
> Electric Code 2017 requires a listed Surge Protection Device (SPD) to be on
> any Industrial Machine that has an Interlock, or I assume any kind of
> safety function.  Is this true? The only information I can find on the
> internet is from the companies that make and sell the SPDs which can often
> be very one sided.  Is there more to this story that I am missing?
>
>
>
> Does the Surge Protection have to be listed? Are there specifications for
> the SPD? Is there a Surge Immunity Test that be used to validate and
> verify whether an additional SPD is required or not?
>
>
>
> Thanks,
>
> The Other Brian
>
> -
> 
>
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Re: [PSES] Surge Protection Device required by NEC

[Brian Kunde]

I understand that this is also stated in NFPA 79:2020.

Our product would fall under the definition of an industrial machine, but
it does not have an Industrial Control Panel.  It does have interlocked
guards and safety functions to prevent the unexpected starting of the motor
when the guard is removed. The machine is housed in a custom enclosure that
includes internal surge protection components. But it does not have a
"listed" Surge Protection device as some such manufacturers and test labs
say is now required.

Thanks,
Brian

On Tue, Nov 1, 2022 at 2:28 PM Doug Powell  wrote:

> From the 2020 Edition, emphasis is mine.
>
> "670.6 Surge Protection. Industrial machinery with safety interlock
> control devices *not effectively protected from voltage surges on the
> incoming supply circuit* shall have surge protection installed."
>
>
> It does not say where this protection needs to be applied, so I assume it
> can be within the machine or somewhere in machine supply. Also, does the
> product you are inquiring about fall under the definition of *Industrial
> Machinery*, NFPA 79?
>
> -Doug
>
> Douglas E Powell
> Laporte, Colorado USA
> doug...@gmail.com
> LinkedIn <https://www.linkedin.com/in/coloradocomplianceguy/>
>
> (UTC -06:00) Mountain Time (US-MDT)
>
>
>
> On Tue, Nov 1, 2022 at 11:55 AM Brian Kunde  wrote:
>
>> It just came to my attention that section 670.6 of the US National
>> Electric Code 2017 requires a listed Surge Protection Device (SPD) to be on
>> any Industrial Machine that has an Interlock, or I assume any kind of
>> safety function.  Is this true? The only information I can find on the
>> internet is from the companies that make and sell the SPDs which can often
>> be very one sided.  Is there more to this story that I am missing?
>>
>> Does the Surge Protection have to be listed? Are there specifications for
>> the SPD? Is there a Surge Immunity Test that be used to validate and
>> verify whether an additional SPD is required or not?
>>
>> Thanks,
>> The Other Brian
>> -
>> 
>>
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[PSES] Surge Protection Device required by NEC

[Brian Kunde]

It just came to my attention that section 670.6 of the US National Electric
Code 2017 requires a listed Surge Protection Device (SPD) to be on any
Industrial Machine that has an Interlock, or I assume any kind of safety
function.  Is this true? The only information I can find on the internet is
from the companies that make and sell the SPDs which can often be very one
sided.  Is there more to this story that I am missing?

Does the Surge Protection have to be listed? Are there specifications for
the SPD? Is there a Surge Immunity Test that be used to validate and
verify whether an additional SPD is required or not?

Thanks,
The Other Brian

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[PSES] Hazard-Based safety Engineering (HBSE) Principles

[Brian Kunde]

I see the new IEC 62368-1 standard is described as a HBSE standard.  In
your own words, in just a few sentences, and maybe with an example or two,
can you explain how this HBSE standard differs from a non-HBSE standard?
How does this change the way a conformity assessment is performed and
documented?
Thanks,
The Other Brian

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Re: [PSES] Assess risk of electric shock from charged capacitors

[Brian Kunde]

Another way to go is to buy a Capacitor Discharge Tester that is made to
perform the test you want.  Just plug it in and press a couple buttons.
There may be more on the market but the only one I know of is made by
Compliance West USA, model CDT-240.  We have the 15 amp version.  The nice
thing about this is you just plug it in, select the standard and test you
want to test to, then start.  Simple and safe.

On our products, we find that the load of the product itself discharges the
"X" caps very quickly. Worst case is when the power switch is OFF and the
RF Line Filter is still connected to the AC Mains. Most line filters have
adequate bleeder resistors to discharge the caps to a safe level within the
5 seconds (or whatever standard you are using).  But some of the larger
line filters used in industrial equipment (typically permanently mounted)
do not discharge their caps fast enough.  So this is always a good test to
run.

Hope this was helpful.
The Other Brian

On Mon, Oct 17, 2022 at 11:18 AM Scott Xe  wrote:

> In order to judge if there is no risk of electric shock from charged
> capacitors, it is required to measure the voltage across L and N of mains
> plug after the removal of power input.  To avoid grounding loop between
> test equipment and the unit under test, an isolating transformer is
> strongly recommended.  I have learnt another way by using Add Function and
> two hot probes of a dual channel DSO.  Can someone advise which way is more
> common in safety conformity test.  Especially the latter one, I have not
> tried it yet before and appreciate any notes I must take in the measurement.
>
> Thanks and regards,
>
> Scott
>
>> -
> 
>
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Re: [PSES] List of Common Misuses

[Brian Kunde]

Exactly.  Exactly.  Exactly.

We work hard to make sure our products are safe in a normal and fault
condition and in every possible way.  The only MisUse we can list is if the
User doesn't keep the instrument clean or remember to clean/change the air
filters, but even then, we do tests to make sure these misuses will not
cause a hazardous condition.  So I am lost when we are asked to provide
more possible MisUses.

I guess I was hoping to find a generic list of misuses that could apply to
most any complex electrical device.

How can you list unforeseen misuses when they are unforeseen? As soon as
you realize it is unforeseen, it becomes foreseen, so it is no longer
unforeseen. yuck yuck.

Thanks for all the good responses. Very interesting.  Enjoy your week.

The Other Brian

On Wed, Oct 5, 2022 at 5:58 PM Richard Nute  wrote:

>
>
> Misuse is using a product for a use which is not a normal use.  An example
> is using a chair (which is for sitting) as a stool.  Or, using a
> screwdriver for prying.  Or using a hammer for breaking concrete.  Each of
> these misuses can lead to injury.
>
>
>
> Identifying misuse for a TV, a laptop, or a printer is much harder, if not
> impractical.
>
>
>
> Rich
>
>
>
>
>
> *From:* Charlie Blackham 
> *Sent:* Wednesday, October 5, 2022 1:18 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] List of Common Misuses
>
>
>
> I’m not a lawyer, or from the USA, but in Europe the term “misuse” has
> been discussed in various REDCA (Radio Equipment Directive Compliance
> Association) Meetings with Notified Bodies and The EU Commission, and their
> view is that there’s no such thing as “misuse”, it’s just “use”.
>
>
>
> Drawing up a list of possible “misuses” is ultimately futile, as where do
> you draw the line – user manuals instructions telling you not to use a
> telephone in the bath morph into statements telling you not to use a PBX in
> the bath.
>
>
>
> My suspicion as an Engineer, is that some companies want great long lists
> of “do not do X” in the manual as some form of defence against mitigation
> by Darwin Awards nominees – but then you finish up with a manual so big
> that no one reads it anyway
>
>
>
> Just my 2p / 2c
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/> *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* MIKE SHERMAN 
> *Sent:* 05 October 2022 19:09
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] List of Common Misuses
>
>
>
> Brian --
>
>
>
> Good to hear from you!
>
>
>
> Re your question, it is not clear who the "they" is who is requesting a
> list of misuses.
>
>
>
> From my working experience, we (on advice of Legal) usually did not try to
> compile a list of misuses in the operating manual, on the theory that if a
> creative user found another (dangerous) misuse that was not on our list,
> they might conclude that it must be safe because it wasn't on our misuse
> list. We emphasized how to use our equipment correctly, and what the scope
> of its applications were.
>
>
>
> However, we would clearly identify in some warnings what not to do where
> we perceived that to be a foreseeable misuse.
>
>
>
> Hope this helps!
>
> Mike Sherman
>
> Sherman PSC LLC
>
> On 10/05/2022 1:01 PM Brian Kunde  wrote:
>
>
>
>
>
> My company manufactures Laboratory Equipment such as analyzers and
> determinators. They are highly specialized equipment, yet have an infinite
> range of uses.
>
>
>
> Even though all known residual risks are documented in the Safety Warning
> section of the manual, they will commonly request a list of Misuses.  There
> are no buttons, or settings that can be changed by the User that can cause
> a hazard.  The operational environment is clearly defined. So in most all
> cases, I am not aware of any "Misuse" that can cause a hazard. For some
> reason, this answer is not acceptable.  We are expected to come up with
> something.
>
>
>
> Is there a standard or common list of MisUses that seem to satisfy this
> requirement?
>
>
>
> How crazy are we to get with this?, e.g., don't use the 400lb analyzer
> while taking a bath?  Don't use it to mow your lawn?  Common
>
>
>
> I used to work for a computer company and I couldn't believe the stupid
> warnings we had to put in the manual.
>
>
>
> Thanks to all.
>
>
>
> The Other Brian
>
> -
> 

[PSES] List of Common Misuses

[Brian Kunde]

My company manufactures Laboratory Equipment such as analyzers and
determinators. They are highly specialized equipment, yet have an infinite
range of uses.

Even though all known residual risks are documented in the Safety Warning
section of the manual, they will commonly request a list of Misuses.  There
are no buttons, or settings that can be changed by the User that can cause
a hazard.  The operational environment is clearly defined. So in most all
cases, I am not aware of any "Misuse" that can cause a hazard. For some
reason, this answer is not acceptable.  We are expected to come up with
something.

Is there a standard or common list of MisUses that seem to satisfy this
requirement?

How crazy are we to get with this?, e.g., don't use the 400lb analyzer
while taking a bath?  Don't use it to mow your lawn?  Common

I used to work for a computer company and I couldn't believe the stupid
warnings we had to put in the manual.

Thanks to all.

The Other Brian

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Re: [PSES] High Touch Current and GFCIs

[Brian Kunde]

ral
>conductors, not current in the protective conductor.  It nominally operates
>at 5 mA.  We assume (with a reasonable degree of accuracy) that leakage
>(touch) current is 100% of the differential current measured by the GFCI.
>It is possible, although unlikely, for some of the GFCI differential
>current to find another return path than the protective grounding 
> conductor.
>
> Best regards,
>
> Rich
>
>
>
>
>
> *From:* Lfresearch Jose <00734758d943-dmarc-requ...@listserv.ieee.org>
> <00734758d943-dmarc-requ...@listserv.ieee.org>
> *Sent:* Wednesday, August 24, 2022 1:44 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] High Touch Current and GFCIs
>
>
>
> I have wondered about something similar.
>
>
>
> If I use a 6 way power strip, I’m assuming all the leakage currents for
> anything plugged in sum. Is that correct? I recall getting a few trips when
> I used a power strip and It’s only just twigged that might be why.
>
>
>
> Cheers,
>
>
>
> Derek.
>
> Sent from my iPad
>
>
>
>
> On Aug 24, 2022, at 3:27 PM, Brian Kunde  wrote:
>
> 
>
> If I have a rake of electrical equipment with a single power cord and a
> combined touch current exceeding 6mA, and I plug the rake into a circuit
> with a GFCI, will it trip?
>
>
>
> Thanks.
>
>
>
> The Other Brian
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
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> emc-p...@ieee.org>
>
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> emc-p...@ieee.org>
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>
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> For h

Re: [PSES] High Touch Current and GFCIs

[Brian Kunde]

>
>
>
>1. A GFCI measures the current difference between line and neutral
>conductors, not current in the protective conductor.  It nominally operates
>at 5 mA.  We assume (with a reasonable degree of accuracy) that leakage
>(touch) current is 100% of the differential current measured by the GFCI.
>It is possible, although unlikely, for some of the GFCI differential
>current to find another return path than the protective grounding 
> conductor.
>
> Best regards,
>
> Rich
>
>
>
>
>
> *From:* Lfresearch Jose <00734758d943-dmarc-requ...@listserv.ieee.org>
> <00734758d943-dmarc-requ...@listserv.ieee.org>
> *Sent:* Wednesday, August 24, 2022 1:44 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] High Touch Current and GFCIs
>
>
>
> I have wondered about something similar.
>
>
>
> If I use a 6 way power strip, I’m assuming all the leakage currents for
> anything plugged in sum. Is that correct? I recall getting a few trips when
> I used a power strip and It’s only just twigged that might be why.
>
>
>
> Cheers,
>
>
>
> Derek.
>
> Sent from my iPad
>
>
>
>
> On Aug 24, 2022, at 3:27 PM, Brian Kunde  wrote:
>
> 
>
> If I have a rake of electrical equipment with a single power cord and a
> combined touch current exceeding 6mA, and I plug the rake into a circuit
> with a GFCI, will it trip?
>
>
>
> Thanks.
>
>
>
> The Other Brian
>
> -
> 
>
> 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
>
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>
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[PSES] High Touch Current and GFCIs

[Brian Kunde]

If I have a rake of electrical equipment with a single power cord and a
combined touch current exceeding 6mA, and I plug the rake into a circuit
with a GFCI, will it trip?

Thanks.

The Other Brian

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Re: [PSES] Harmonised standards

[Brian Kunde]

This topic goes a little deeper, I think.  Question being, how are the
harmonized standards to be listed on your DoC?

It appears to me that the Commission lists standards a couple different
ways, which adds to the confusion. For example, on the EMCD Harmonized
Standards list, it shows it one way as:

Method #1
EN 16361:2013+A1:2016

but then for another standard shows it this way:

Method #2
EN 50065-2-1:2003, EN 50065-2-1:2003/A1:2005, EN 50065-2-1:2003/AC:2003

Using the first method, the above could be listed as

Method #1
EN 50065-2-1:2003+AC:2033+A1:2005

I thought we had a discussion a year or so ago where the plus sign "+" was
to be replaced by the slash "/".  If that is true, then the above could be
listed as:

Method #3
EN 50065-2-1:2003/AC:2033/A1:2005

But this method could be technically confusing thinking you are using only
the amendment to show compliance. Yet, we all know what
this really means, right?.

So, which is correct?  Does it really matter?  Using method #2 above is
probably the most correct, but it is very long.  I prefer method #1 or #3
because it is shorter and gets the point across.

Comments?

The Other Brian






On Wed, Aug 24, 2022 at 11:59 AM Scott Xe  wrote:

> Hi Gert,
>
> Thanks for your useful reply!  The EN 55032 : 2017/A11 : 2020 contains the
> corrigendum only, no any technical changes.  Does AC have another condition
> to qualify for?
>
> Will arrange some time for visiting the CENELEC site.
>
> Best regards,
>
> Scott
>
> On Wed, 24 Aug 2022 at 21:38, Gert Gremmen  wrote:
>
>> Hi Scott,
>>
>> No only the :
>>
>> EN 55032 : 2017  is the Harmonised Standard (1 documnet)
>> EN 55032 : 2017/A11 : 2020  is the (Harmonised) amendment only (1
>> dcoument)
>>
>> Both documents are needed. (did not check the OJ for you)
>>
>> EN 55032 : 2017+A11 : 2020  is both documents together.
>>
>> AC stands for Corrigendum, most used for plain error, typos ,wrong
>> references etc.
>>
>> There is lots of info on the site of CENELEC on these subjects. Worth so
>> spent an afternoon.
>>
>> Gert Gremmen
>>
>> On 24-8-2022 15:06, Scott Xe wrote:
>> > EN 55032 : 2017/A11 : 2020
>> >
>> --
>> Independent Expert on CE marking
>> EMC Consultant
>> Electrical Safety Consultant
>>
>> -
>> 
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[PSES] Touch Current - More Questions

[Brian Kunde]

I lost all my emails from before on Leakage Current/Touch Current, but your
replies were very helpful. Thanks.

I am trying to understand what affects the result of the Touch Current test
according to IEC 60990. In our example, we are testing 230V single phase
products with a grounded PE third pin on the power cord that connects to
the chassis of the EUT. The 230V could be derived from split-phase, though
we do not connect to the center tapped neutral, or one side of the 230V can
be referenced to Earth (neutral), or the 230V could be isolated (not
referenced to Earth) but still have the safety ground PE connected to
chassis.

When we test for Touch Current, the PE is opened (which isolates the EUT
from Earth) and the Human Body Model circuit is inserted and metered.  We
take a measurement, reverse polarity on the AC Mains, then test again.  We
usually get similar results regardless of whether the AC is isolated or
referenced to ground in some way.

Now here is my question. We took a power cord, connected it to a line
filter, then to a 150 watt 24Vdc power supply (which also has a live
filter) that is loaded down with resistor loads, all mounted to a piece of
sheet metal representing our chassis.  We get a Touch Current of about
0.8mA, which seems typical.

Then we added two 2000 watt dc power supplies (with internal line filters)
driving heating elements and some ac powered heating elements and AC
cooling fans. Our Touch Current test results went down to 0.2mA.  How can
this be? What phenomenon is lowering the test results driving more AC
components in the EUT?  Or are we doing something wrong?

Thanks,
The Other Brian

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[PSES] RoHS Exempt Industrial Machinery

[Brian Kunde]

Greetings.

Would a stand-alone industrial cut-off saw (stationary grinding machine),
5hp to 30hp, intended to cut through metal material, 3-phase 380V, about
the size of a large refrigerator and weighing about 400kg (880 lbs) or
more, be exempt from RoHS?

Wading through all the RoHS documents and guides, it would appear as if
such machinery by definition of its function would be exempt from RoHS.  Is
this true or does it also have to be of a certain size and weight?

Thanks,
The Other Brian

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[PSES] Leakage Current Testing (Touch Current) Reference

[Brian Kunde]

This has always confused me.  Consider the EUT as ITE or Laboratory
Equipment (61010-1).

I can see where the PE conductor is opened and you place the Human Body
Impedance Circuit (Measuring Device or MD) between the accessible metal
chassis of the EUT and PE to measure the leakage current that a person
might be exposed to.

However, when Leakage Current is tested and recorded in the lab, the PE
conductor is opened, but the MD is placed between L1 and chassis, and then
to Neutral (L2) and chassis. These values are measured and recorded with
the power switch  ON and OFF.But in real life, the USER does not have
access to L1 or N. So why is the test done that way?

Or am I totally mistaken about how the MD is referenced during the test?

Thanks to all in advance.

The Other Brian

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Re: [PSES] NRTL Marks on Industrial Pump Assemblies

[Brian Kunde]

To all. Thanks for the many comments and advice. They were most helpful.

Our NRTL inspector is focusing on the AC Mains driving the motor as a
potential hazardous circuit. They want the Pump Assembly, or just the
motor, to have UL and CSA for sales in North America. Our NRTL inspector
says that evaluating motors in the field (Field Evaluation) is difficult
for it would require a locked rotor test which would be impossible to do in
the field and be potentially destructive to the motor. So these markings on
the motor are required.

We are in the process of disassembling the pump to see if the motor has
these markings, but it is being difficult to disassemble. Still working on
it.  The Pump Manufacturers are being unresponsive or very slow to respond
to our requests.

With the current part shortage problems, we are having a difficult time
finding a supplier that has a product to sell us. And amongst those, we are
having this compliance issue.  R is frustrated, rightfully so, and is
seeking help from our Compliance Engineering Department.

Is there a test or tests that can be done in the field that would make this
pump assembly acceptable to the AHJ? Ultimately, we will want a pump
assembly with the Safety Marking clearly visible from the outside so there
are no issues in the field with AHJs, but for now we will take whatever
will get the product shipping.

 Thanks.
The Other Brian

On Thu, Jul 7, 2022 at 9:53 AM  wrote:

> Brian,
>
>
>
> I’m curious if your NRTL has made it clear for what topic the pump needs
> certification? There are many energy efficiency criteria being applied to
> industrial components of various kinds these days. I cannot bring them all
> to mind quickly, but water circulators are certainly a possibility, as well
> as 3 phase induction motors. Energy efficiency compliance generally cannot
> be judged at the incorporated level.
>
>
>
> Best Regards,
>
> -Lauren
>
>
>
> *From:* Brian Kunde 
> *Sent:* Thursday, June 30, 2022 2:01 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] NRTL Marks on Industrial Pump Assemblies
>
>
>
>
>
> *External Email:* Do NOT reply, click on links, or open attachments
> *unless* you recognize the sender and know the content is safe. If you
> believe this email may be unsafe, please click on the “Report Phishing”
> button on the top right of Outlook.
>
>
>
> I am confused and frustrated.  We have an industrial product that includes
> a small water recirculation tank which includes a motor/pump assembly that
> is powered by 230V/360V/460Vac 3-phase.  Our NRTL inspectors says this pump
> assembly must have UL, CSA, or equivalent. Here is a website that shows the
> type of assembly we are looking for:
>
>
>
> https://www.graymills.com/fm-series.html
> <https://nam02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.graymills.com%2Ffm-series.html=05%7C01%7Clauren.crane%40lamresearch.com%7Cd9bf71274ca44a02bbb008da5acae122%7C918079dbc9024e29b22c9764410d0375%7C0%7C0%7C637927978970075867%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C=dbrKCO2k%2BDnZlrxRp%2FkMTz%2FR5CxV0gEFs2AYKchw86U%3D=0>
>
>
>
> The trouble is, Graymills, Granger, Dayton, etc. doesn't provide NRTL
> markings on the pumps that meet our functional requirements.  They all say
> that most of their customers do not require these marks so they only offer
> a few models that do.
>
>
>
> How can this be? Am I missing something?  Some say that manufacturers can
> get the pumps approved as part of a certification of the entire machine,
> but how can the pump be evaluated by a system integrator who doesn't
> manufacture the pump, nor has any constructional information?  Wouldn't it
> HAVE to be done by the motor manufacturer?
>
>
>
> I keep asking our NRTL Field Inspector if he would accept such a product
> and the answer is no.  Our CSA inspector also says no; it must have CSA or
> equivalent on the motor and/or motor/pump assembly.
>
>
>
> Any suggestions?
>
>
>
> Thanks,
>
> The Other Brian
>
> -
> 
>
> 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>
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[PSES] NRTL Marks on Industrial Pump Assemblies

[Brian Kunde]

I am confused and frustrated.  We have an industrial product that includes
a small water recirculation tank which includes a motor/pump assembly that
is powered by 230V/360V/460Vac 3-phase.  Our NRTL inspectors says this pump
assembly must have UL, CSA, or equivalent. Here is a website that shows the
type of assembly we are looking for:

https://www.graymills.com/fm-series.html

The trouble is, Graymills, Granger, Dayton, etc. doesn't provide NRTL
markings on the pumps that meet our functional requirements.  They all say
that most of their customers do not require these marks so they only offer
a few models that do.

How can this be? Am I missing something?  Some say that manufacturers can
get the pumps approved as part of a certification of the entire machine,
but how can the pump be evaluated by a system integrator who doesn't
manufacture the pump, nor has any constructional information?  Wouldn't it
HAVE to be done by the motor manufacturer?

I keep asking our NRTL Field Inspector if he would accept such a product
and the answer is no.  Our CSA inspector also says no; it must have CSA or
equivalent on the motor and/or motor/pump assembly.

Any suggestions?

Thanks,
The Other Brian

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[PSES] Using E-Stop in a Non-Emergency Task

[Brian Kunde]

Greetings  to All!!

I have an industrial machine with blades that has to be changed out by the
User/Operator.  The blade is behind a door with a positive mechanical
action switch that when opened puts the motor's VFD into a Safe Stop
Function Mode (this is a certified Safety Function).  In addition, power is
removed from the Start Button circuit so the motor cannot unexpectedly
start.

When the E-Stop button is pressed, it does the same as the Door Switch
above, but in addition, it also opens the Motor Enable Relay which removes
the 3-phase power from the VFD.  Now the motor really really cannot
unexpectedly start.  I think this circuit arrangement is typical.

We noticed that many of our Customers instruct their Employees (Operators)
to PRESS the E-STOP Button before changing out the Blade taking advantage
of the extra layers of protection.

So here is my question.  Is it OK to instruct the Operator in OUR MANUALS
to Press the E-Stop when changing the blades?  We have always been told
that the E-Stop function should ONLY be used for Emergency and not for
routine tasks.  Is there any additional liability on  our company if we
give these instructions? In doing so, are we admitting that our product is
unsafe or not as safe and may unexpectedly start unless you press the
E-Stop?

What is your opinion of this topic?

Thanks to all.
The Other Brian

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[PSES] Fwd: [PSES] UKCA importer/ representative

[Brian Kunde]

This has always been confusing because they choose poor words and
terminology and then keep changing the meaning which only makes it more
confusing.

It shouldn't matter who manufacturers the product, ships it, imports it,
sells it, stocks it, markets it, or repairs it.  What is important is to
know who is responsible for the Compliance of the product regardless of
where in the world they are located.  If the Responsible Party cannot
fulfill the duties themselves, then they have the option to Assign an
Authorised Representative (AR) to perform the required duties on their
behalf, IF THEY CHOOSE.  The contact information for the Responsible Party
should always be on the product whoever they are, where ever they are
located. Done. Case Closed.

Importers change. Authorized Representatives change. Sales offices move.
Phone numbers and addresses change. Personnel change. Names Change (just
ask my bank).  What good is it if you put contact information on a product
for the AR or Importer if this information changes within a few years?
Worthless.  In a global economy as such is today, you are better off to
know the contact information of the Responsible Party wherever in the world
they are.  This could be the manufacturer, the importer, an AR, of some guy
on his computer living in his mom's basement.  Someone has to be
responsible and whoever that is, their contact information must be made
available.

Just my opinion.
The Other Brian

On Tue, Apr 5, 2022 at 6:29 PM Gary Tornquist <05big...@gmail.com> wrote:

> Hi Kim,
>
> Not quite official, but take a look at this article equivalent for UK
> 
>  post-Brexit.
> At the end it addresses your question.
>
>
>
> Cheers,
>
> Gary Tornquist
>
>
>
> *From:* Kim Boll Jensen <199f0011b1e3-dmarc-requ...@listserv.ieee.org>
>
> *Sent:* Tuesday, April 5, 2022 5:49 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] UKCA importer/ representative
>
>
>
> Hi all
>
>
>
> When we started understanding the new/coming UKCA rules, we got the
> impression that all companies selling products to the UK should not only
> mark the products and make a UKCA declaration of conformity BUT they shall
> have en importer/authorized representative in the UK (or North Ireland).
>
>
>
> But now when we read some new official information, we see that they use
> the wording: if you need to have a representative/importer he shall have
> address in the UK.
>
>
>
> Does that mean that not all imported products will require an importer/
> representative company with address in the UK?
>
>
>
> Can some one point me to some official web pages that makes it clear when
> we need an importer/ representative company with address in the UK?
>
>
>
>
>
> Med venlig hilsen / Best regards,
>
> Kim Boll Jensen
> Bolls Aps
> 22 99 69 91
>
> -
> 
>
> 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>
>
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>
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>
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All 

[PSES] Job Posting - Product Safety Technician - LECO Corp - S.W. Michigan

[Brian Kunde]

If interested, please inquire through the following website:

https://workforcenow.adp.com/mascsr/default/mdf/recruitment/recruitment.html?cid=263cbf9c-eec3-4f43-a005-51e8815d8a23

Hiring or promoting to a Product Safety Engineer position is possible to
the right person with the right qualifications and experience, but not
guaranteed.

LECO Corporation is located in Southwest Michigan along the shores of Lake
Michigan in St. Joseph, Berrien County, MI (known as Harbor Country to the
locals). It is a great area to live; laid back, no traffic, nice schools,
affordable housing, and in the heart of the Fruit Belt.  There are a lot of
wineries (yes, this is wine country) and breweries. A 90 minute drive to
Chicago, 40 minute to South Bend, IN, 50 minutes to Kalamazoo, and 80
minutes to Grand Rapids, MI.  Our beaches are fantastic during the summer
so this area does get weekend tourists.

LECO manufactures almost everything right here in St. Joseph, MI.  We
engineer our own PCBs, our own CAD and mechanical CAD work, electrical
design, analytical and mechanical design right here. We build/solder our
own PC cards, punch out, bend, and mill our own metal parts; we do our own
plating, painting, masking, silkscreening, etc., we make many of our own
cable assemblies.  Look at our website to get an idea of the products we
manufacture.

LECO Corporation designs, manufactures, and sells world-wide state of the
art Laboratory Equipment (analytical test equipment); mostly under the
IEC/EN/UL/CSA 61010-1 Safety Standard.  We have a few other products that
would fall under light industrial, due to their mechanical nature. For
Europe, we test and declare compliance to the LVD and Machinery Directives,
and products going to Canada are 100% field evaluated.  Because we
build-to-order in small quantities, we do not currently qualify for a
Safety Agency Certification, but that is a future goal if it becomes
financially advantageous. By request from some customers, we do obtain an
NRTL Field Evaluation on a few products every year.

The above is my personal opinion, statement, and comments. LECO Corporation
cannot be held responsible for any content in this email.  I know that when
I look at a job posting, it would be nice to know a little bit about the
area where you would be working and the type of products you would be
working on.

Good luck.

The Other Brian

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Re: [PSES] Fuse designations

[Brian Kunde]

I do not know where the information I have originally came from, but I got
this and have been using this for over 30 years:

FF = Very Fast Acting
F = Fast Acting (Common)
M = Medium Time Lag
T = Time Lag (Common)
TT = Long Time Lag

I got this from Bud Lang who was our Safety Guru at Heath Kit many years
ago.

The Other Brian

On Tue, Mar 1, 2022 at 5:33 PM Douglas E Powell  wrote:

> All,
>
> Over the years, I've seen various ways people include a caution or warning,
> in their user documents or product labels, for replacement fuses. Similar
> to: "replace only with same type and rating of fuse";  followed by a code: 
> T1.6AH250V.
> And for those who may not understand the code, they may sometimes add in
> parentheses some variant of "(1.6 Amp time-lag, ~250V, high breaking
> capacity)".
>
> So now to my question, US manufacturers sometimes use the phrase "SLO-BLO"
> or "Slow Blow" instead of Time-Lag or Time-Delay.  Are these terms commonly
> used internationally and if so, are they clearly understood?
>
> I took some time to look up SLO-BLO and found it's a registered trademark
> for Littelfuse going back to 1957, and it has been continuously renewed
> since that time.
>
> Incidentally, a German Engineer once told me the way he would designate a
> fuse type for a variety of tripping characteristics was in this order from
> very slow to very fast: TT1.0A250V, T1.0A250V, 1.0A250V, F1.0A250V,
> FF1.0A250V.
>
> Thanks, -Doug
>
>
> Douglas E Powell
> Laporte, Colorado USA
>
> (UTC -07:00) Mountain Time (US-MST)
>
>
>
>
> -
> 
>
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[PSES] RFID Reader Integration

[Brian Kunde]

I know nothing about the regulatory requirements of an RFID Reader but I
assume it has a transceiver so it is considered an Intentional Radiator.

If I buy a reader over-the-counter in one country, can I use it in another
country? Or, like WiFi and Bluetooth, do I have to have a Reader that is
Certified for every country/market?

If I want to integrate an RFID reader into an electronic device or machine,
can I buy pre-certified modules for a worldwide market?  Or will I have to
have the entire electronic device certified?

What are my options?  Any insight would be helpful and appreciated.

Thanks,
The Other Brian

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[PSES] IP Code Question

[Brian Kunde]

An IP code of IPx2 implies the enclosure protects against the ingress of
water drops at 15° tilt.  Now, most PC enclosures protect the electronics
from occasional exposure to water drops, but it is not designed to be
exposed to water drops continuously.  So can you rate an electronic device
IP22, for instance, but not intend it to be used outside or in an
environment where it is exposed to water on a regular basis?

Thanks for your input.
The Other Brian

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Re: [PSES] BREXIT - UK Designated Standards

[Brian Kunde]

This begs the question, what is the difference between the BS version and
the EN version?  Is it likely that a product that meets the requirements of
the EN version won't meet the requirements of the BS version?  I think
the risk of that would be quite low.  Would putting the BS version on your
UK-DoC cause any issues?

The Other Brian

On Sun, Aug 8, 2021 at 5:52 PM Carl Newton  wrote:

> I'm seeing conflicting information as to whether the UK Declaration of
> Conformity "Designated Standards" should  be the "BS" versions or the "EN"
> versions.  Every source that I've seen (including very reputable sources)
> has stated that the BS version should be cited.  However, I'm seeing that
> the "EN" versions are being listed as the Designated Standards at the
> GOV.UK web site.  The following link references the EMC standards for
> this example:
>
> https://www.gov.uk/government/publications/designated-standards-emc
>
> It seems pretty clear to me that for now and the foreseeable future that
> the European Norm "EN" versions are also the UK Designated Standards.  But
> I'm looking for safety in numbers here.
>
> Thanks,
>
> Carl
>
>
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
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>
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Re: [PSES] Friday question

[Brian Kunde]

I'll add a little more to my post.

Our Compliance Department works with many different "Design Teams", so how
involved we get during the development of any project depends a lot on the
Team Members. Those who have been burned in the past know to get us
involved early and often.  Those projects usually go very smoothly.  But
some of our less experienced engineers/project leaders try to shy away from
our involvement until it is too late.  Those projects can be a disaster;
usually causing redesign and unwanted delays. It is learning the hard way.
We try to be as proactive as possible, but some projects are so
confidential that they do not get us involved until it is too late. Then we
have to rain on their parade if you know what I mean.  Fortunately, this
doesn't happen very often.

It used to be more common.  My old boss used to call me "The Seagull"
because when I did get involved in a new project, I tented to "Swoop in,
crap all over everything, then fly away".  That's the job.

The Other Brian

On Mon, Jun 28, 2021 at 2:57 PM Douglas E Powell  wrote:

> Thanks Brian, I appreciate it.
>
> It was a team effort, and I provided regulatory guidance.  The team was
> very receptive to my recommendations, and it shows. BTW - I forgot to
> mention, it went from an prototype to certification in 4 months time.  In a
> few of my past lives this would have taken six months to two years.
>
> -Doug
>
>
> Douglas E Powell
> Laporte, Colorado USA
> doug...@gmail.com
> http://www.linkedin.com/in/dougp01
>
>
> On Mon, Jun 28, 2021 at 11:28 AM Brian Kunde  wrote:
>
>> Doug,
>>
>> This is a huge accomplishment and you and your entire design team should
>> be very proud. A celebration of some kind would be expected.  For companies
>> like ours who have been making the same type of products for many years, we
>> usually pass safety inspections in the first pass because we know what we
>> are doing and have lots of experience, and have taken our lumps over many
>> years.  But for a start-up or any company making a new type of product, to
>> pass out of the gate is fantastic and almost unheard of.  Good Job!!! all
>> around.
>>
>> The Other Brian
>>
>> On Sat, Jun 26, 2021 at 1:14 AM Douglas E Powell 
>> wrote:
>>
>>> The reason I asked this question is because a company I have been
>>> consulting with for the last 4 months, has this week successfully had their
>>> 80 kWh energy storage system reviewed and tested for a UL 9540 listing.
>>> This a startup company and they achieved first pass certification of their
>>> product. A limited production certificate was issued and now they are at
>>> the point where they will want to ramp up for factory certification. I was
>>> duly impressed and felt priveledged to be a part of the team. I also felt
>>> this was a very rare achievement and wanted to know the experience of
>>> others in this regard.
>>>
>>> Doug
>>>
>>> On Fri, Jun 25, 2021, 8:12 PM Scott Xe  wrote:
>>>
>>>> Dear Doug,
>>>>
>>>> Very interesting question and I would like to know it as well.  Suggest
>>>> to go to the testing lab for the answer.  They should have the statistics
>>>> in their business.
>>>>
>>>> Would you mind sharing why you want to know it, what for?  Although I
>>>> do not have the figures I am aware of the answers why the product cannot
>>>> pass the test in the first attempt.  Below is my experience in dealing with
>>>> Asian suppliers in the past many years.
>>>>
>>>>- No safety engineer to go thru the design against the applicable
>>>>standards before submitted for testing.
>>>>- No proper facilities to conduct the pre-tests.
>>>>- The employer does not recognise the importance of this position
>>>>and results in no safety engineer in the manufacturer.  The design 
>>>> engineer
>>>>is also not brave enough to tell the employer that they do not have
>>>>knowledge, experience and test facilities in doing the relevant test 
>>>> work
>>>>so the employer believes he/she looks after this as well.
>>>>- The design engineer does not have relevant knowledge and training
>>>>for the test work.  There is little education system in current
>>>>universities/vocational institutes to help the society.  Most test
>>>>engineers in public test labs are trained by the employers, not from the
>>>>current educational system.  Some small association

Re: [PSES] Friday question

[Brian Kunde]

Doug,

This is a huge accomplishment and you and your entire design team should be
very proud. A celebration of some kind would be expected.  For companies
like ours who have been making the same type of products for many years, we
usually pass safety inspections in the first pass because we know what we
are doing and have lots of experience, and have taken our lumps over many
years.  But for a start-up or any company making a new type of product, to
pass out of the gate is fantastic and almost unheard of.  Good Job!!! all
around.

The Other Brian

On Sat, Jun 26, 2021 at 1:14 AM Douglas E Powell  wrote:

> The reason I asked this question is because a company I have been
> consulting with for the last 4 months, has this week successfully had their
> 80 kWh energy storage system reviewed and tested for a UL 9540 listing.
> This a startup company and they achieved first pass certification of their
> product. A limited production certificate was issued and now they are at
> the point where they will want to ramp up for factory certification. I was
> duly impressed and felt priveledged to be a part of the team. I also felt
> this was a very rare achievement and wanted to know the experience of
> others in this regard.
>
> Doug
>
> On Fri, Jun 25, 2021, 8:12 PM Scott Xe  wrote:
>
>> Dear Doug,
>>
>> Very interesting question and I would like to know it as well.  Suggest
>> to go to the testing lab for the answer.  They should have the statistics
>> in their business.
>>
>> Would you mind sharing why you want to know it, what for?  Although I do
>> not have the figures I am aware of the answers why the product cannot pass
>> the test in the first attempt.  Below is my experience in dealing with
>> Asian suppliers in the past many years.
>>
>>- No safety engineer to go thru the design against the applicable
>>standards before submitted for testing.
>>- No proper facilities to conduct the pre-tests.
>>- The employer does not recognise the importance of this position and
>>results in no safety engineer in the manufacturer.  The design engineer is
>>also not brave enough to tell the employer that they do not have 
>> knowledge,
>>experience and test facilities in doing the relevant test work so the
>>employer believes he/she looks after this as well.
>>- The design engineer does not have relevant knowledge and training
>>for the test work.  There is little education system in current
>>universities/vocational institutes to help the society.  Most test
>>engineers in public test labs are trained by the employers, not from the
>>current educational system.  Some small associations (TIC - Testing,
>>Inspection & Certification) from the industry are setting up routes to be
>>certified testing professionals in the current educational system with the
>>help from the Government Industry Department.  Just some improvement but
>>not sufficient IMO!
>>
>> Based on the above facts, it leads to other potential issues in the
>> finished products.  Even if the product has passed the conformity test, the
>> manufacturer may not know why their design meets the requirements.  How can
>> they maintain the compliance in production?  If the manufacturer does not
>> have this knowledge, how can they plan their assurance protocol for mass
>> production in order to validate the finished products in compliance with
>> the original design limits before leaving the factory?
>>
>> Best regards, ☺
>>
>> Scott
>>
>> On Sat, 26 Jun 2021 at 01:56, Douglas E Powell  wrote:
>>
>>> Out of curiosity,
>>>
>>> I would like to know (especially from those who have been in the
>>> business for a while) what is your "first pass success rate" for safety
>>> certifications on new product introductions? That is, to achieve a product
>>> safety certification from an accredited laboratory with no action items
>>> required coming out of the preliminary design review.  It's helpful if you
>>> can indicate how complex the projects are.
>>>
>>> In my 26 years as a compliance engineer, I've observed possibly three in
>>> total for products with a reasonably high complexity.
>>>
>>> Thanks! Doug
>>> --
>>>
>>> Douglas E Powell
>>> doug...@gmail.com
>>> http://www.linkedin.com/in/dougp01
>>>
>>> -
>>> 
>>>
>>> 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) 

Re: [PSES] Friday question

[Brian Kunde]

https://www.linkedin.com/pulse/ship-repair-man-story-why-experts-get-paid-more-faiz-noor/

A giant ship engine failed. The ship’s owners tried one expert after
another, but none of them could figure but how to fix the engine.

Then they brought in an old man who had been fixing ships since he was
young. He carried a large bag of tools with him, and when he arrived, he
immediately went to work. He inspected the engine very carefully, top to
bottom.

Two of the ship’s owners were there, watching this man, hoping he would
know what to do. After looking things over, the old man reached into his
bag and pulled out a small hammer. He gently tapped something. Instantly,
the engine lurched into life. He carefully put his hammer away. The engine
was fixed!

A week later, the owners received a bill from the old man for ten thousand
dollars.

“What?!” the owners exclaimed. “He hardly did anything!”

So they wrote the old man a note saying, “Please send us an itemized bill.

The man sent a bill that read:

Tapping with a hammer……….. $ 2.00

Knowing where to tap.. $ 9,998.00

Effort is important, but knowing where to make an effort makes all the
difference!

On Fri, Jun 25, 2021 at 2:59 PM Dennis Ward <
0dbeaa892a40-dmarc-requ...@listserv.ieee.org> wrote:

> A company once made glassware. They could not figure out why it did not
> hold water.  They hired an engineer who told them to put a bottom on the
> glass.  It held water.  The manager that hired the engineer left the
> company and a new manager was hired.  He asked why this engineer was hired
> and did not see the reason for him.  So he left and the company went back
> to making glass ware the old way.  To this day, their glasses don’t hold
> water and they can’t figure out why.
>
>
>
>
>
>
>
> *Dennis Ward *Senior Reviewing Engineer
> PCTEST Engineering Laboratory, LLC.
> 7185 Oakland Mills Road
> Columbia, MD  21045
> 1 410 290 6652)
>
> dennis.w...@pctest.com | www.pctest.com | www.element.com
>
> This communication and any attachment contain information from PCTEST
> Engineering Laboratory, LLC. and is intended for the exclusive use of the
> recipient(s) named above.
>
>
>
> *From:* Ken Javor 
> *Sent:* Friday, June 25, 2021 11:19 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Friday question
>
>
>
> *CAUTION:*This email originated from outside of Element Materials
> Technology. *DO NOT* click links or open attachments unless you recognize
> the sender and know the content is safe. Please contact IT Service Desk if
> you are in any doubt about this email.
>
> Second hand info.
>
> A colleague of mine, Mark Nave, was hired as an EMC engineer by Network
> Appliance in the early 2000s.  He took them to regularly passing the first
> time through.
>
> After awhile, the VP who hired him retired or moved on, and the new VP
> didn’t have the history of not passing changing to passing.  He questioned
> why they had even hired Mark – what did he do for them?
>
> Mark got angry, and left.
>
> End of story.
>
> Ken Javor
> Phone: (256) 650-5261
>
> --
>
> *From: *"doug...@gmail.com
> "
>  
> >
> *Reply-To: *"doug...@gmail.com
> "
>  
> >
> *Date: *Fri, 25 Jun 2021 11:55:26 -0600
> *To: * 

Re: [PSES] EN 61010-1 under LVD and Functional safety

[Brian Kunde]

IEC/EN/UL 61010-1 standard in section 17 states that if there is a hazard
not addressed by the standard that you must perform a risk assessment.  In
a note, it lists some Risk Assessment standards, but the most used and
current standard is the ISO 12100 which calls out many other standards
including the ISO 13849-1.

Hope this is helpful.

The Other Brian

On Tue, Jun 15, 2021 at 9:48 AM Rodriguez, Daniel (ESP) <
123de38bd494-dmarc-requ...@listserv.ieee.org> wrote:

> Good morning all
>
> We have a system that generates a chemical but without pumps and only
> electro valves as moving part. The system has been checked for EN 61010-1
>
> There is a risk that an hazardous gas release can happen and we have a gas
> detector for that.
>
> The question is that as it is not a Machinery (no moving part) , don’t we
> need to apply functional safety under EN 13849-1 and confirm the
> Performance Level of the Safety Control?
>
>
>
> EN 61010-1 doesn’t refer to functional safety and only list IEC 61508 in
> bibliography...
>
>
>
> Thank you for your answers!
>
>
>
> Kind Regards / Saludos cordiales / Mit freundlichen Grüßen
>
>
>
> *Daniel Rodríguez*
>
> Sr. Equipment Compliance Specialist EMEA
>
> *T* +34 673556249
>
> *E *drodrig...@ecolab.com
>
> *ecolab.com *
>
>
> CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may
> contain proprietary and privileged information for the use of the
> designated recipients named above. Any unauthorized review, use, disclosure
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> please contact the sender by reply e-mail and destroy all copies of the
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Re: [PSES] Hot surface sign

[Brian Kunde]

Usually, high-temperature surface warning symbols are only required if the
hazard is not obvious.  So in ovens, stovetops, griddles, toasters,
heat-sinks, etc. do not require them.

However, if such appliances or device have areas that are hot but it is not
obvious it is hot, a warning symbol might be required.

At home, I have a 2-slice toaster. It is a "Cool Touch" toaster that has
no hot exposed surfaces, except from the small surface between the two
slots on the top.  So the manufacturer engraved the symbol on the metal
surface.  Not a bad idea.  But back in the day, the sides of a toaster got
really hot; hot enough to melt the Wonder Bread bag.  As a kid, I think
every toaster I ever saw had a Wonder Bread bag melted on the side.

The Other Brian

On Wed, May 26, 2021 at 10:04 AM Scott Xe  wrote:

> In some cooking appliances, there are some hot surfaces that may cause
> burn injury and safety standards suggest putting a hot surface sign to
> alert the users.
>
>- Is there any specific colour requirement?  Common practice is black
>colour on yellow background or white colour on black background.
>- Is an embossed sign black on black considered as a legible sign in
>EU criteria perspective?
>- In case of ink-printed label, is it put on the top of the hot
>surface or next to the hot surface?  If on the top of surface, the colours
>are protected from heat degradation and specialized adhesives should be
>used to withstand higher temperatures.  Is there any test criteria for
>verification?
>
> Thanks and regards,
>
> Scott
> -
> 
>
> 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
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Re: [PSES] Basic Schematic Creation Software

[Brian Kunde]

Wow, I really like Dia.  It has some nice features. Looks to be a handy
program for a lot of different applications. I'll have to play around with
this a bit.

Thanks.
The Other Brian

On Thu, May 20, 2021 at 3:15 PM Patrick Lawler  wrote:

> Hi Brian,
>
> I wasn't aware of the 'Dia' software until Brent mentioned it.  While
> looking through the developers site, I saw there are additional symbol
> packs already designed that may meet your needs:
> http://dia-installer.de/shapes/index.html.en
>
> Regards,
> Patrick Lawler
>
> On Thu, May 20, 2021 at 8:53 AM Brian Kunde  wrote:
> >
> >
> > I am in need of a simple program for creating simple schematics of
> Safety Circuits in a variety of States.  I envision something that I can
> easily insert door switches, relays, button switches, e-stops, fuses,
> circuit breakers, etc..  It would be nice if once laid out, I can simply
> click to change the state of a switch or relay to represent different
> states of a Safety Function.  And then save it off in .pdf format.
> >
> > Does anyone know of some software that will do this for a low cost or
> maybe Free?  This is something we will use only a few times a year.
> >
> > Thanks to all in advance for any information.
> >
> > Regards,
> > The Other Brian
> >
> >
> > -
> > 
> >
> > 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.
> >
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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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> >
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>

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Re: [PSES] [EXTERNAL] Re: [PSES] What percentage of products pass first time?

[Brian Kunde]

I also concur with what has been posted by others.  But I would like to
inject one short commentary if I might.

Traditionally, we have found that a large percentage of emissions failures
are due to the over-the-counter peripherals and/or cables; a required part
of the overall test system but somewhat outside the control of the
customer.  I know this is not new information, but the customer is not
happy when they are paying good money troubleshooting a failure caused by
the peripherals or cables they chose.  And then they will ask the questions
I so dread, "How can they sell peripherals that do not meet the
requirements?".  I wish I had an answer.

So for our EMC lab, if we do not count the failures caused by
over-the-counter peripherals, the percentage of failures goes way down.

Piece out.  Stay safe.

The Other Brian

On Wed, May 26, 2021 at 7:59 AM Jim Hulbert 
wrote:

> I first started in the EMC, Product Safety, and standards compliance
> aspect of engineering about 35 years ago.  At that time they were saying
> all the same things we are saying today:  Must be considered up front in
> designs.  Must be included in engineering education at the
> college/university level.  Management needs to commit to compliance.  I
> would also add that EMC was “black magic” (do people still say that?).
>  Apparently we still have a long way to go.  I wonder if they will still be
> saying these things 35 years from now.
>
>
>
> Jim Hulbert
>
>
>
> *From:* John E Allen <09cc677f395b-dmarc-requ...@listserv.ieee.org>
> *Sent:* Tuesday, May 25, 2021 5:59 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [EXTERNAL] Re: [PSES] What percentage of products pass first
> time?
>
>
>
> Like a “lot” of people here, I never had any formal education in either
> safety or EMC compliance – I just had to learn “on the job” about “what
> worked and what didn’t”, and often in very challenging situations*. *
>
> *(OTOH, I was never the “sharpest tool in the toolbox” in engineering
>  parlance – which was a “problem”  when engaging with local management
> which, frankly, mainly “didn’t to know” **☹**, ) *
>
>
>
> Therefore safety, standards compliance and EMC standards compliance REALLY
> MUST be an integral component of engineering education –* and ALSO for
> company management *- forward from where we are “now”.
>
>
>
> John E Allen
>
> W. London, UK.
>
>
>
>
>
> *From:* Dennis Ward <0dbeaa892a40-dmarc-requ...@listserv.ieee.org>
> *Sent:* 25 May 2021 21:09
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] What percentage of products pass first time?
>
>
>
> Having been in the EMC business now for going on 40+years, I concur with
> what Pete is saying.  The truth of the matter is, this field of study is
> sadly under taught and is still more hands on and learning by trial and
> error for the most part.  Yes, there are a lot of good ‘classes’ you can
> take, but the fact remains, this is more than not an OJT field.
>
>
>
> As to manufacturers designing at the limit.  This is also true, and also
> problematic as it means far too many products still fail first time out.
>
>
>
> I don’t know if I would necessarily agree with the percentages reported,
> but it is getting a better.
>
>
>
> My last 20+ years has been working in the regulatory approvals end and I
> can say that failure to comply with rules and standards is still a big
> issue with manufacturers.
>
>
>
> Thanks
>
>
>
>
>
> *Dennis Ward *Senior Reviewing Engineer
> PCTEST Engineering Laboratory, LLC.
> 7185 Oakland Mills Road
> Columbia, MD  21045
> 1 410 290 6652)
>
> dennis.w...@pctest.com | www.pctest.com
> 
> | www.element.com
> 
>
> This communication and any attachment contain information from PCTEST
> Engineering Laboratory, LLC. and is intended for the exclusive use of the
> recipient(s) named above.
>
>
>
> *From:* Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org>
> *Sent:* Tuesday, May 25, 2021 12:39 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> 

Re: [PSES] Basic Schematic Creation Software

[Brian Kunde]

Thanks. I'll check them out.  If I find one that does what I want I'll let
everyone know.
The Other Brian

On Thu, May 20, 2021 at 2:05 PM Brent DeWitt  wrote:

> Manny brings up a great option.  Even if you have no need for actual
> circuit simulation.  I can recommend SiMterix, LTSpice and MicroSim as
> totally free programs that will allow you to create schematics, however,
> I'm not so sure that any of those offer open/closed switch symbols.
>
> From a purely graphic approach,"DIA" is a free alternative to Visio and
> allows structured drawings with some pre-defined electrical elements:
>
>
>
> Fare well,
> Brent DeWitt, AB1LF
>
> On 5/20/2021 1:42 PM, Manny Barron wrote:
>
> Hi Brian,
>
> I have found Spice to be useful for scenarios as you describe, in my case
> for EMC/EMI analysis. The program is relatively easy to use and changing
> circuit elements and re-running an analysis is simple in my opinion.
>
> There are several variations of Spice on the market today, but I'm not
> sure if you'll find a free version. Ten years ago I purchased T-Spice (I
> think that's the name) for about $500 and it worked great for current
> in-rush analysis I had to do.
>
> Recommend doing some web searches on Spice to see what turns up, maybe
> you'll find what you're looking for, and who knows, maybe even freeware.
>
> Regards,
>
> Manny Barron
>
>
>
>
> On Thu, May 20, 2021 at 8:53 AM Brian Kunde  wrote:
>
>>
>> I am in need of a simple program for creating simple schematics of Safety
>> Circuits in a variety of States.  I envision something that I can easily
>> insert door switches, relays, button switches, e-stops, fuses, circuit
>> breakers, etc..  It would be nice if once laid out, I can simply click to
>> change the state of a switch or relay to represent different states of a
>> Safety Function.  And then save it off in .pdf format.
>>
>> Does anyone know of some software that will do this for a low cost or
>> maybe Free?  This is something we will use only a few times a year.
>>
>> Thanks to all in advance for any information.
>>
>> Regards,
>> The Other Brian
>>
>>
>> -
>> 
>>
>> 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) <http://www.ieee-pses.org/list.html>
>> List rules: http://www.ieee-pses.org/listrules.html
>>
>> For help, send mail to the list administrators:
>> Scott Douglas sdoug...@ieee.org
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>>
>> For policy questions, send mail to:
>> Jim Bacher j.bac...@ieee.org
>> David Heald dhe...@gmail.com
>>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
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>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
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>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-com

[PSES] Basic Schematic Creation Software

[Brian Kunde]

I am in need of a simple program for creating simple schematics of Safety
Circuits in a variety of States.  I envision something that I can easily
insert door switches, relays, button switches, e-stops, fuses, circuit
breakers, etc..  It would be nice if once laid out, I can simply click to
change the state of a switch or relay to represent different states of a
Safety Function.  And then save it off in .pdf format.

Does anyone know of some software that will do this for a low cost or maybe
Free?  This is something we will use only a few times a year.

Thanks to all in advance for any information.

Regards,
The Other Brian

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Re: [PSES] Ground Bond Tests

[Brian Kunde]

John,

I think you are getting your tests mixed up.  The Ohm Meter is a Ground
Bond Test but at a very low current. As I said in my earlier email, Annex F
doesn't specify a current value for this test so technically an ohm meter
will do the job and meet the requirement of the 61010-1.

The HiPot test puts a high voltage potential between Line (or neutral) to
chassis ground to test the Dielectric Strength of your insulation. This
test is typically performed at 1500Vac and/or 2100Vdc for electrical
equipment operating up to the 230-volt range, but I have seen lower voltage
levels used also.   This is a different test than the Ground Bond test and
is also required for 100% of production.

I hope this was helpful.

The Other Brian

On Wed, May 12, 2021 at 2:09 PM John Cochran  wrote:

> I’m interested in these answers, but UL and Intertek do not require us to
> do more than Ground Continuity testing on 100% of the products.  The UL/cUL
> certified product is an Industrial LCD Monitor (NWGQ, NWGQ7) evaluated to
> the ITE standard IEC 60950-1 & CAN/CSA C22.2 No. 60950-1-07, with a
> detachable power cord.  The Intertek certified product is a mobile cart
> with a permanently attached 3/c cord with plug.  It is evaluated to UL
> 61010-1 & CSA C22.2#61010-1-12.  Both have an input range of 100-240VAC @
> 15A.  We use a Hi-Pot tester with a Ground Continuity, Open/Short and
> Dielectric tests.  Neither NRTL requires more than a buzzer/ohm-meter test
> of all exposed metal surfaces, which the Hi-Pot tester does.  The responses
> to this email challenge these requirements, but if not required, it is hard
> to convince management that we need to invest in more test equipment.  I
> feel more assured of the grounding on a system when we use our 25A Ground
> Bond Tester, but we only have one for engineering purposes.  We have never
> been required to do Ground Bond testing, only Ground Continuity.
>
>
>
> *John Cochran*
>
> *jcoch...@strongarm.com *
>
> 215-443-3400 x219
>
>
>
> *From:* MIKE SHERMAN 
> *Sent:* Wednesday, May 12, 2021 11:08 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Ground Bond Tests
>
>
>
> Rich Nute has 3 Technically Speaking columns on this that can be found at
> the In Compliance magazine website. The first is here
>
> https://incompliancemag.com/article/derivation-of-ground-impedance/
>
> and I find it quite informative.
>
> Mike Sherman
>
> Graco Inc.
>
>
>
> On 05/12/2021 8:01 AM Wiseman, Joshua <
> joshua.wise...@orthoclinicaldiagnostics.com> wrote:
>
>
>
>
>
> I agree with Brian. I’ve been involved with product safety over 20 yrs and
> worked for an NRTL for about 6 of those.
>
>
>
> The 40 A requirement came from the Canadian electrical code and all the
> NRTLs.
>
>
>
> The only exemptions I’ve seen to the 100 % ground bond requirement has
> been for Class II and Class III devices or devices using an external power
> supply (brick or wall-wart styles.)
>
>
>
> Josh
>
>
>
> *From:* Brian Kunde 
> *Sent:* Wednesday, May 12, 2021 8:42 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Ground Bond Tests
>
>
>
> *EXTERNAL SENDER: Verify links, attachments and sender before taking
> action*
>
>
>
> 61010-1 § 4.1 says,  "Tests in this standard are TYPE TESTS to be carried
> out on samples of equipment or parts. Their only purpose is to check that
> the design and construction ensure conformity with this standard. In
> addition, *manufacturers shall perform the ROUTINE TESTS of Annex F on
> 100 % of equipment produced* which has both HAZARDOUS LIVE parts and
> ACCESSIBLE conductive parts."
>
>
>
> 61010-1 Annex F, § F2 calls out the "Protective earth" test, also known as
> the Ground Bond Test, as a required test to be performed on 100% of
> production.  Note the "NOTE" that says, "No value is specified for the test
> current.".   So some NRTL inspectors allow the ground bond test in
> production to be performed at any reasonable current value, but most will
> follow the requirements of 6.5.2.
>
>
>
>
>
> I have been doing Product Safety for over 30 years and have worked with
> UL, CSA, TUV, NEMKO, EOLAS, etc., and all of them require 100% testing of
> production units to both the Highpot test and the Ground Bond test.
>
>
>
> Regarding the 100mΩ verses 200mΩ question, all the NRTL inspectors I have
> worked with require the measured impedance of the Power Cord to be no more
> than 100mΩ.  Note the UL/ANSI/CSA Deviation to 6.5.2.4 that instead of the
> 100mΩ requirement has a "shall not cause a potential drop of more than 4
> V".  At a minimum 40 A ground bond test, 

Re: [PSES] Ground Bond Tests

[Brian Kunde]

61010-1 § 4.1 says,  "Tests in this standard are TYPE TESTS to be carried
out on samples of equipment or parts. Their only purpose is to check that
the design and construction ensure conformity with this standard. In
addition, *manufacturers shall perform the ROUTINE TESTS of Annex F on 100
% of equipment produced *which has both HAZARDOUS LIVE parts and ACCESSIBLE
conductive parts."

61010-1 Annex F, § F2 calls out the "Protective earth" test, also known as
the Ground Bond Test, as a required test to be performed on 100% of
production.  Note the "NOTE" that says, "No value is specified for the test
current.".   So some NRTL inspectors allow the ground bond test in
production to be performed at any reasonable current value, but most will
follow the requirements of 6.5.2.


I have been doing Product Safety for over 30 years and have worked with UL,
CSA, TUV, NEMKO, EOLAS, etc., and all of them require 100% testing of
production units to both the Highpot test and the Ground Bond test.

Regarding the 100mΩ verses 200mΩ question, all the NRTL inspectors I have
worked with require the measured impedance of the Power Cord to be no more
than 100mΩ.  Note the UL/ANSI/CSA Deviation to 6.5.2.4 that instead of the
100mΩ requirement has a "shall not cause a potential drop of more than 4
V".  At a minimum 40 A ground bond test, a 100mΩ impedance would give you a
4V drop.  It doesn't say anything about an 8V drop for non-detachable power
cords.  So NRTLs are going to stick with the 100mΩ across the board, I
believe (this is opinion).

Hope this information is helpful.

The Other Brian


On Tue, May 11, 2021 at 11:27 PM Steve Brody  wrote:

> So here is my question, or actually two of them:
>
> First, one of my clients has been told by their 3rd party NRTL that a
> ground bond test is required as part of factory/production routine tests,
> even though it is not required by 61010-1.  I have never run into this
> requirement in my work history and I would be interested in hearing if any
> of you have.
>
> Second, just to be sure my interpretation is correct, 61010-1, section
> 6.5.2.4, Impedance of protective bonding of plug-connected equipment, in
> the fist sentence, it has a limit of 100 mOhms impedance and my read is
> that this is for equipment with a power cord that has a plug on one end and
> a receptacle on the other.
>
> Then, in the same section, still under the title of plug-connected
> equipment, it says for equipment that has a non-detachable power cord  the
> limit is 200 mOhms.  My interpretation is that plug-connected equipment
> with a non-detachable power cord is when the power cord is hard wired to
> the unit under test, but still has a plug for mains connection.
>
> Thoughts?
>
> Thanks in advance and you can reply here or privately to
> stev...@productehsconsulting.com
>
>
> Steve Brody
> sgbr...@comcast.net
> C - 603 617 9116
> -
> 
>
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[PSES] UKCA Questions

[Brian Kunde]

I have a few questions regarding UKCA.

1. Machinery Regulation 2008-1597 pretty much says the same thing and the
EU Machinery Directive.  Section 1.7.4.2c) requires the DoC to be included
in the Manual (Instructions), OR "a document setting out the contents of
the EC declaration of conformity, showing the particulars of the machinery,
not necessarily including the serial number and the signature".

Our company has always struggled with this requirement for if we put the
DoC in the manual, it takes forever to change it when the information on
the DoC changes.  SO, currently we publish information that satisfies the
"document setting out the contents of the " part of the requirement.

Are we going to have to do the same thing for the UKCA?   I was really
hoping that the EU would drop this as a requirement in future versions of
the Machinery Directive.


2.  North Ireland:   So, if we have a low risk product that does not
require validation from a Notified Body, then we can continue to sell and
ship into North Ireland using the CE Marking and EU-DoC?  Is this correct?
 We do not have to apply the North Ireland UKNI marking. Correct?


Thanks to all for your help.

The Other Brian

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[PSES] FCC Emissions on Industrial Equipment

[Brian Kunde]

I am working on the first Industrial Machine of my career so I could use
some advice and clarification regarding the requirements for FCC emissions.

I have been told by many that in North America, Industrial Equipment does
not have to be tested, verified, or anything for FCC by the manufacturer of
the equipment.  Is this true?  I was told that interference is unlikely,
even if the equipment exceeds the FCC emissions limits.   Meeting the FCC
limits is recommended, and voluntary, but not required.  True?


On the other hand,  Europe is not so.  If EE equipment goes to Europe, it
has to pass the EN 55011 emissions test as well as the immunity tests.   Is
that correct?


Any additional information that would be helpful to me would be appreciated.

The Other Brian

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Re: [PSES] ROHS and DoC

[Brian Kunde]

Our motivation for including information on our EU DoCs that may not be
technically required is two-fold; 1. to better inform our customers, and 2.
to reduce the number of questions/complaints from the field.  We could
drastically reduce the number of requests from the field if we provide the
information on the DoC; in this case, the 2015/863 amendment.  I agree that
technically it should not be necessary, but there are benefits here to
consider.  And as far as I know, there is no rule against it.  So why not?

BTW, thanks to everyone who participated in this thread.  It has been very
informative and I appreciate it.

Have a great Thanksgiving if you celebrate such a thing.  We have the next
few days off which I'm looking forward to.

Brian

On Sun, Nov 22, 2020 at 4:47 AM Charlie Blackham <
char...@sulisconsultants.com> wrote:

> A lot of articles were published when 2015/863 was published, so people
> are more aware of it that the other amendments, but RoHS compliance is very
> much a moving target due to a wide variety of exemptions and exemption
> expiration dates – such as this example:
>
>
>
>
>
> 6(c) Copper alloy containing up to 4 % lead by weight
>
> Expires on:
>
> — 21 July 2021 for categories 1-7 and 10,
>
> — 21 July 2021 for categories 8 and 9 other than *in vitro* diagnostic
> medical devices and industrial monitoring and control instruments,
>
> — 21 July 2023 for category 8 *in vitro* diagnostic medical devices,
>
> — 21 July 2024 for category 9 industrial monitoring and control
> instruments, and for category 11.
>
>
>
> By declaring compliance to RoHS you are automatically declaring compliance
> with all applicable amending Delegated Directives – none of these,
> including 2015/863, amended Annex VI which tells you how to declare
> compliance with RoHS:
>
>
>
> *The object of the declaration described above is in conformity with
> Directive 2011/65/EU of the European Parliament and of the Council of 8
> June 2011 on the restriction of the use of certain hazardous substances in
> electrical and electronic equipment*
>
>
>
> *@Scott Douglas *
>
> I presume the complaints were from customers and not market enforcement?
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/> *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Brian Kunde 
> *Sent:* 22 November 2020 05:26
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] ROHS and DoC
>
>
>
> Because we provide DoCs translated into over 30 languages, we try to avoid
> text that has to be translated. Our type of products do not have to comply
> with these new regulations until next year, but when we do, we plan to use
> the same nomenclature that is used for the amendments of Standards by using
> the Plus Sign (+). So under the RoHS Directive, we plan to list it like
> this:
>
>
>
> 2011/65/EU + 2015/863
>
>
>
> Does anyone see any issue with this?
>
>
>
> Regards,
>
> The Other Brian
>
>
>
>
>
>
>
> On Sat, Nov 21, 2020 at 4:26 PM Scott Douglas 
> wrote:
>
> I used to get complaints I was not up to date when I said 2011/65/EU as
> amended. Now I say 2011/65/EU as amended by 2015/863. No more complaints.
>
>
>
>
>
> On Sat, Nov 21, 2020, 12:57 PM Charlie Blackham <
> char...@sulisconsultants.com> wrote:
>
> Amund
>
> Whilst 2015/863 updates 2011/65/EU, you do not CE mark to it.
> The DoC must be to 2011/65/EU
>
> Some people concentrate a lot on 2015/863 but there have been far more
> Delegated Directives dealing with exemptions than just this one dealing
> with substances  (
> https://ec.europa.eu/environment/waste/rohs_eee/legis_en.htm)
>
> Best regards
> Charlie
>
> Charlie Blackham
> Sulis Consultants Ltd
> Tel: +44 (0)7946 624317
> Web: https://sulisconsultants.com/
> Registered in England and Wales, number 05466247
>
> -Original Message-
> From: Amund Westin 
> Sent: 21 November 2020 10:01
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: [PSES] ROHS and DoC
>
> For EU compliance, I assume Directive 2011/65/EU is still the correct
> reference to use?
> I see several parties who is referring to 2015/863 in their DoC, but isn't
> that reference just a replacement for Annex II in 2011/65/EU?
>
> Best regards
> Amund
>
> -
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-

Re: [PSES] ROHS and DoC

[Brian Kunde]

Because we provide DoCs translated into over 30 languages, we try to avoid
text that has to be translated. Our type of products do not have to comply
with these new regulations until next year, but when we do, we plan to use
the same nomenclature that is used for the amendments of Standards by using
the Plus Sign (+). So under the RoHS Directive, we plan to list it like
this:

2011/65/EU + 2015/863

Does anyone see any issue with this?

Regards,
The Other Brian



On Sat, Nov 21, 2020 at 4:26 PM Scott Douglas  wrote:

> I used to get complaints I was not up to date when I said 2011/65/EU as
> amended. Now I say 2011/65/EU as amended by 2015/863. No more complaints.
>
>
>
> On Sat, Nov 21, 2020, 12:57 PM Charlie Blackham <
> char...@sulisconsultants.com> wrote:
>
>> Amund
>>
>> Whilst 2015/863 updates 2011/65/EU, you do not CE mark to it.
>> The DoC must be to 2011/65/EU
>>
>> Some people concentrate a lot on 2015/863 but there have been far more
>> Delegated Directives dealing with exemptions than just this one dealing
>> with substances  (
>> https://ec.europa.eu/environment/waste/rohs_eee/legis_en.htm)
>>
>> Best regards
>> Charlie
>>
>> Charlie Blackham
>> Sulis Consultants Ltd
>> Tel: +44 (0)7946 624317
>> Web: https://sulisconsultants.com/
>> Registered in England and Wales, number 05466247
>>
>> -Original Message-
>> From: Amund Westin 
>> Sent: 21 November 2020 10:01
>> To: EMC-PSTC@LISTSERV.IEEE.ORG
>> Subject: [PSES] ROHS and DoC
>>
>> For EU compliance, I assume Directive 2011/65/EU is still the correct
>> reference to use?
>> I see several parties who is referring to 2015/863 in their DoC, but
>> isn't that reference just a replacement for Annex II in 2011/65/EU?
>>
>> Best regards
>> Amund
>>
>> -
>> 
>> 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>
>>
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>> 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.
>>
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>>
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>> emc-p...@ieee.org>
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>> well-used formats), large files, etc.
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[PSES] Short Circuit Current Rating (SCCR)

[Brian Kunde]

Greetings to all. I hope this finds you well.

Once again the subject of SCCR has come up.  I have struggled for years to
find a document or someone who can explain this to me.  The bottom line is
I need to know how I would determine the SCCR for my product.  In one case
in particular I am currently working on, it is a 3 phase motor-driven
industrial device. It draws less than 8 amps at 230V. Internal to the
device, we have three "CC" type fuses with a SCCR of 200KA.  However, ahead
of that we have a lockout/tagout disconnect device that is only rated 10KA
SCCR.

How exactly can I determine the SCCR of my device?

Thank you all.

The Other Brian

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Re: [PSES] EMF harmonised standards

[Brian Kunde]

When do you know if a product needs to be tested to these standards or
not?  What requires this testing?  Is there a criteria that can be used?
Does the SCOPE of these standards make it clear if and when the standards
need to be applied to a product?   We have had customers request it
but most electronic equipment doesn't put out enough magnetic or
electromagnetic fields to even make it onto the graph?  Seems like a waste
of time for most electronics unless they incorporate high current or high
power RF transmitters.

Brian

On Thu, Oct 1, 2020 at 2:18 AM Charlie Blackham <
char...@sulisconsultants.com> wrote:

> Scott
>
>
>
> There no “solid guidance”
>
>
>
> EN 50663:2017 is a much more recent standard and makes reference to both
> EN 62311:2008 and EN 62479:2010 for assessment, but does not allow use of
> EN 62479 table B.1 for using higher transmit powers for values of Pmax
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/  *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Scott Xe 
> *Sent:* 30 September 2020 14:53
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] EMF harmonised standards
>
>
>
> I notice EN 62311 is commonly used for electrical appliances.  For AV/ITE
> products, there are 3 standards: EN 50633, EN 62311 and EN 62479 to be
> used.  Is there any solid guidance to select the correct standard for the
> product category?
>
>
>
> Thanks and regards,
>
>
>
> Scott
>
> -
> 
>
> 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>
>
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>
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Re: [PSES] AW: [PSES] AW: [PSES] Selling into the Ukraine

[Brian Kunde]

Thanks to all for the information.  From our perspective, it would appear
to be a huge step in the wrong direction.  I am not sure of the
motivation but I have a few ideas.  We are moving forward by working with a
representative in Ukraine who is working with a local test laboratory that
wants us to send them EMC and Safety test reports.  These documents plus a
fist full of money will hopefully get the product into the hands of the
customer eventually.  Time will tell.

I have received many emails from people on this topic and I must pass on to
the group that given a choice many companies would rather stop doing
business in Ukraine than send detailed technical information about their
products to an unknown test lab.  Something real to consider.

Thanks to everyone for the information.

Brian

On Mon, Sep 28, 2020 at 2:20 AM Dürrer Bernd  wrote:

> Hello Brian,
>
>
>
> It depends on your product, the applicable regulation (electrical safety,
> EMC, energy efficiency, RoHS-like environmental compliance), the applicable
> standards, and the applicable national certification scheme. If you already
> have CB reports for your product that are based on standards that have been
> adopted as national standards in the Ukraine, then, from our experience,
> local re-testing will not be necessary, and the existing CB report can be
> provided as technical documentation. I do not know all the details of the
> process and different certification schemes, as local certification is
> handled by our Ukrainian subsidiary, and we only provide our technical
> documentation to them. If you have a local subsidiary, importer or service
> company in Ukraine, I propose to check with them what specifically is
> required for your product.
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* Brian Kunde 
> *Gesendet:* Freitag, 25. September 2020 17:23
> *An:* Dürrer Bernd 
> *Cc:* EMC-PSTC@listserv.ieee.org
> *Betreff:* Re: [PSES] AW: [PSES] Selling into the Ukraine
>
>
>
> Thanks for the information.
>
>
>
> I know you mentioned "Local" certification body, is there any MRAs with
> international test labs that we could get this done in the states before
> shipping the product to the Ukraine?  If not, is there likely to some in
> the Future?  I brought up this topic to the Lab we use and they know
> nothing to very little about the Ukraine situation.
>
>
>
> Thanks.
>
> Brian
>
>
>
> On Wed, Sep 23, 2020 at 2:26 AM Dürrer Bernd 
> wrote:
>
> Hi Brian,
>
>
>
> The EAC marking scheme is the conformity assessment procedure for the
> Eurasian Economic Union (http://www.eaeunion.org/?lang=en
> <https://eur01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.eaeunion.org%2F%3Flang%3Den=02%7C01%7C%7C9f46cc81cf90432eaf5d08d86166fe15%7C39288a38ff19432c80111cd9d0dff445%7C0%7C0%7C637366442270356708=BZKgGepnmNL60eWD6dPz5fgler5BUvkGnboafUl3zvY%3D=0>),
> but not for Ukraine. The Member-States of the Eurasian Economic Union are
> the Republic of Armenia, the Republic of Belarus, the Republic of
> Kazakhstan, the Kyrgyz Republic and the Russian Federation, but not
> Ukraine. Ukraine has its own conformity assessment procedure with
> regulations that are aligned with those of the European Union for CE
> marking, but Ukraine requires a Declaration of Conformity according to its
> own scheme that depending on the type of product involves a local
> certification body, a local representative, marking of the product with the
> Ukraine TR conformity mark (
> https://www.gma.trade/single-post/2017/11/24/Requirements-for-UA-TR-mark-application-in-Ukraine
> <https://eur01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.gma.trade%2Fsingle-post%2F2017%2F11%2F24%2FRequirements-for-UA-TR-mark-application-in-Ukraine=02%7C01%7C%7C9f46cc81cf90432eaf5d08d86166fe15%7C39288a38ff19432c80111cd9d0dff445%7C0%7C0%7C637366442270356708=ibfgZk4iO3B5CrLXDbpG4NdZjgZJbEWnjGXys0koQj0%3D=0>),
> and labels and instructions in Ukrainian language. As many of the national
> standards are adopted from international IEC or EN standards, existing CB
> reports may be used as evidence of conformity in the required technical
> documentation.
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
>
>
> *Von:* MIKE SHERMAN 
> *Gesendet:* Dienstag, 22. September 2020 20:17
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* Re: [PSES] Selling into the Ukraine
>
>
>
> We've been EAC marking for a while, but I was not aware that the Ukraine
> was part of the EAC marking scheme.
>
>
>
> For EAC marking:
>
> -There are a few additional pieces of information required in the manual
> related to expected life, including when stored.
>
> -We are careful about w

Re: [PSES] AW: [PSES] Selling into the Ukraine

[Brian Kunde]

Thanks for the information.

I know you mentioned "Local" certification body, is there any MRAs with
international test labs that we could get this done in the states before
shipping the product to the Ukraine?  If not, is there likely to some in
the Future?  I brought up this topic to the Lab we use and they know
nothing to very little about the Ukraine situation.

Thanks.
Brian

On Wed, Sep 23, 2020 at 2:26 AM Dürrer Bernd  wrote:

> Hi Brian,
>
>
>
> The EAC marking scheme is the conformity assessment procedure for the
> Eurasian Economic Union (http://www.eaeunion.org/?lang=en), but not for
> Ukraine. The Member-States of the Eurasian Economic Union are the Republic
> of Armenia, the Republic of Belarus, the Republic of Kazakhstan, the Kyrgyz
> Republic and the Russian Federation, but not Ukraine. Ukraine has its own
> conformity assessment procedure with regulations that are aligned with
> those of the European Union for CE marking, but Ukraine requires a
> Declaration of Conformity according to its own scheme that depending on the
> type of product involves a local certification body, a local
> representative, marking of the product with the Ukraine TR conformity mark (
> https://www.gma.trade/single-post/2017/11/24/Requirements-for-UA-TR-mark-application-in-Ukraine),
> and labels and instructions in Ukrainian language. As many of the national
> standards are adopted from international IEC or EN standards, existing CB
> reports may be used as evidence of conformity in the required technical
> documentation.
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
>
>
> *Von:* MIKE SHERMAN 
> *Gesendet:* Dienstag, 22. September 2020 20:17
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* Re: [PSES] Selling into the Ukraine
>
>
>
> We've been EAC marking for a while, but I was not aware that the Ukraine
> was part of the EAC marking scheme.
>
>
>
> For EAC marking:
>
> -There are a few additional pieces of information required in the manual
> related to expected life, including when stored.
>
> -We are careful about what technical information we share.
>
> -We submit a Russian manual, plus Russian translations of the parts of our
> CE technical file that we share.
>
>
>
> Contact me separately if you have questions about EAC marking.
>
>
>
> Mike Sherman
>
> Graco Inc.
>
> On 09/22/2020 12:40 PM Steve Brody  wrote:
>
>
>
>
>
> Brian,
>
>
>
> One of my client's was going to sell into the Ukraine and was told they
> needed an EAC mark on the product and that the CE was not valid in the
> EAC.  They did not proceed beyond that so I can not give you any further
> guidance.
>
>
>
> You can check EAC 3rd parties on line, I think.  I had this discussion
> with UL as to why Ukraine, and the EAC, would not accept the CB Scheme
> report, which is why the client went that route, but the answer was that it
> still needed to go through an EAC 3rd party before they would issue a
> mark.  And that included a physical product review and factory inspection.
> The unanswered question then was what does the CB report buy me - no
> response.
>
>
>
> Client opted not  to sell into the EAC.
>
> On 09/22/2020 12:53 PM Brian Kunde  wrote:
>
>
>
>
>
> Greetings All.
>
>
>
> All of a sudden we are having trouble with Ukraine.  Before we even ship
> our product to the customer, we are being contacted by unknown companies
> who claim to be responsible to overlook the installation and perform
> "complex protocols" on our product.  They are asking for EMC and Safety
> test reports among other R type of test data.  Is this for real?
>
>
>
> Doing a Google search on this topic, it appears as though Ukraine should
> accept our CE Marking and Declaration from Europe. However, they are
> telling us that their laws changed and they no longer accept the CE
> marking.
>
>
>
> What is going on?  Is there a simple way to satisfy whatever the new
> requirements are?
>
>
>
> I appreciate any help you can provide.
>
>
>
> Best Regards,
>
>
>
> The Other Brian
>
>
>
>
>
> -
> 
>
> 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
> <https://eur01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.ieee-pses.org%2Femc-pstc.html=02%7C01%7C%7C723bcad160384c749c0208d85f23c815%7C39288a38ff19432c80111cd9d0dff44

[PSES] Selling into the Ukraine

[Brian Kunde]

Greetings All.

All of a sudden we are having trouble with Ukraine.  Before we even ship
our product to the customer, we are being contacted by unknown companies
who claim to be responsible to overlook the installation and perform
"complex protocols" on our product.  They are asking for EMC and Safety
test reports among other R type of test data.  Is this for real?

Doing a Google search on this topic, it appears as though Ukraine should
accept our CE Marking and Declaration from Europe. However, they are
telling us that their laws changed and they no longer accept the CE
marking.

What is going on?  Is there a simple way to satisfy whatever the new
requirements are?

I appreciate any help you can provide.

Best Regards,

The Other Brian

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[PSES] ICNIRP 2020 Guidelines

[Brian Kunde]

Even though our products do not have intentional radiators, on occasion,
one of our customers will ask us to provide data so they can do a Risk
Assessment to the ICNIRP guidelines and/or EU Directive 2013/35/EU.  The
ICNIRP just released two new guidelines; one that covers up to 100khz and
the other starting at 100khz up to 300Ghz.

We do perform low frequency magnetic and electromagnetic radiated
measurements at the "Operator Position" from 1hz to 100khz using a
probe/spectrum analyzer.  And we perform emi tests from 150khz to 1Ghz to
the EN55011 and FCC.  However, above 100khz we are not really testings
according to the intent of the guidelines.

So here are my questions to the group.  How do you handle such requests?
Do you perform tests to support the physical agent guidelines?  What tests
and/or test equipment do you use to make such measurements?  How high in
frequency do you go?  Any advice or warnings you can share?

Since we have the test equipment to test up to 100khz, we are mainly
interested in testing the higher frequencies.

We have started looking at test equipment to make measurements above
100khz.  We are looking for something reasonable in price yet quick and
simple.

Thank you all in advance for any input.

The Other Brian

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Re: [PSES] marking of rated voltages

[Brian Kunde]

Did you get the replies you wanted?  Have you ever looked at the standard
EN IEC 61293:2020?  This new version just came out. This new version is
loaded with typos and to many I think they are going to find it more
confusing than what we are currently doing.

One major change this standard is trying to make is the fact that the
literary world is trying to do away with the dash "-" to mean a range
between two values, such as 200-240V.  The new way is something like this,
" 200 V, ..., 240 V ".  I find this very confusing. I know our Manual
writers always change dashes into the word " to ".

Oh, and they really really like spaces. Spaces between everything!!

But here are some examples this standard gives:

2 ~ 230 V
1/N/PE ~ 230 V 50 Hz
2/N ~ 110/220 V 60 Hz  (this would be for 2 phase or split phase in North
America)
3 ~ 400 V
3/N ~ 277/480 V 60 Hz(North America does use "PE" to show safety ground)
3/N/PE ~ 230/400 V 50 Hz


So if you have a product that has a universal input, it would be rated
something like this:

100 V, ..., 240 V 50/60 Hz(this looks strange to me)

So I have a question. Since the EN IEC 61293:2020 standard is trying to
standardize on the way we rate electronic devices, what mussel does it have
to force the world to follow it?  How we "rate" equipment seems to be more
of an Industry Standard (do what everyone else is doing) and not set in
stone by some IEC standard.  I really don't get it.

Thanks.
The Other Brian

On Fri, May 22, 2020 at 12:54 PM Brian Kunde  wrote:

> Did you get the replies you wanted?  Have you ever looked at the standard
> EN IEC 61293:2020?  This new version just came out. This new version is
> loaded with typos and to many I think they are going to find it more
> confusing than what we are currently doing.
>
> One major change this standard is trying to make is the fact that the
> literary world is trying to do away with the dash "-" to mean a range
> between two values, such as 200-240V.  The new way is something like this,
> " 200 V, ..., 240 V ".  I find this very confusing. I know our Manual
> writers always change dashes into the word " to ".
>
> Oh, and they really really like spaces. Spaces between everything!!
>
> But here are some examples this standard gives:
>
> 2 ~ 230 V
> 1/N/PE ~ 230 V 50 Hz
> 2/N ~ 110/220 V 60 Hz  (this would be for 2 phase or split phase in North
> America)
> 3 ~ 400 V
> 3/N ~ 277/480 V 60 Hz(North America does use "PE" to show safety
> ground)
> 3/N/PE ~ 230/400 V 50 Hz
>
>
> So if you have a product that has a universal input, it would be rated
> something like this:
>
> 100 V, ..., 240 V 50/60 Hz(this looks strange to me)
>
> So I have a question. Since the EN IEC 61293:2020 standard is trying to
> standardize on the way we rate electronic devices, what mussel does it have
> to force the world to follow it?  How we "rate" equipment seems to be more
> of an Industry Standard (do what everyone else is doing) and not set in
> stone by some IEC standard.  I really don't get it.
>
> Thanks.
> The Other Brian
>
>
> On Fri, May 8, 2020 at 7:24 AM Boštjan Glavič 
> wrote:
>
>> Dear colleagues,
>>
>> I am struggling with correct marking of rating on the product.
>>
>> How would you mark your product when connected to :
>>
>> 3 phase star system (with Neutral) and/or
>>
>> 3 phase delta system and/or
>>
>> 1 phase system
>>
>> Standard is IEC 62368-1 – table F.2
>>
>>
>>
>> Some examples that I have in mind:
>>
>> 400 Y/230 V 3~; 50/60Hz, 3A, (This is for star system but with this
>> marking not identified that Netral is required)
>>
>> 208 V 3~, 50/60Hz, 3A (This is for connection to Delta system)
>>
>> 208-230V, 50/60Hz, 6A (This is for 1 phase L to N or 2 phase L1 to L2
>> connection)
>>
>> What do you think?
>>
>>
>>
>> I remeber that in the past connection to STAR system was identified like
>> 400/230V, 50/60Hz, 3A, 3W + N + PE, however it looks that this was
>> changed.
>>
>> Thank you for your support.
>>
>> Best regards,
>>
>> Boštjan
>> -
>> 
>>
>> 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://pro

[PSES] Fwd: Emergency Stop Function

[Brian Kunde]

If any of you have a Case of Corrona, I hope it is the type that comes in
bottles or cans.

First, there is a guy in this group who I chatted with in the past who is
like an expert in the E-Stop function.  He has a Blog or Website dedicated
to this topic which I cannot currently find.  Can anyone help me get in
contact with him?

My area of need is with integrating the E-Stop function with a Variable
Frequency Drive (inverter).  I have to meet the international requirements
as well as the USA and Canadian requirements.

What I have is 3-phase AC power, through a Contactor, to a VFD, which
powers a 3-phase motor.  The VFD has the motor brake feature built in.
Under a normal STOP command, the VFD engages the motor brake.  All is
fine.

The VFD manufacturer's documentation shows to connect the E-STOP to the
motor Contactor which OPENs power to the VFD.  When the E-Stop is engaged,
power to the VFD is shut down; the motor continues to spin for up to 30
seconds or more before coming to a stop.  The motor Brake does not engage
because it is a feature of the VFD which is powered down.  This makes no
sense to me.

The E-STOP is supposed to stop motion as quickly as possible without
causing additional Risk (according to the MD and NFPA 79 cat.2).  So how is
the E-Stop function supposed to work with a VFD?  How is this typically
done?  Are we buying the wrong VFD?

Thanks to all.

The Other Brian

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Re: [PSES] Mandatory certification

[Brian Kunde]

Not all companies manufacturers high volume consumer goods. Our company
designs and builds analytical test equipment (laboratory equipment) which
is very expensive (relatively speaking) and built one at a time per our
customer requirements.  We have about 50 Families of products; each with
dozens of variations. Even our best selling product family might only sell
less than 50 units per year, and many models may not see a single sale in a
year.  Yet when someone needs one, we build it.

Some of our customers require NRTL certification.

We have approached several NRTLs requesting Certification for our
production units.  Nope.  Their 'certification programs' do not
accommodate low volume production, such as ours.  The ONLY option we have
is NRTL Field Evaluations.

NOTE: If anyone out there in cyberland knows of an NRTL or other local
authority who can provide an alternate but acceptable service, please let
me know!!

We started paying for NRTL FES (Field Evaluation Services) more than 20
years ago.  It started out maybe one per year at a cost of only a few
hundred dollars (US).  Now we get 12-15 requests a year and the cost has
sky-rocketed to nearly $4000.  We beg and plead to our NRTLs to do
everything possible to keep down the costs without success.  AGAIN, if
anyone knows of an acceptable alternative, please let me know.

Ok, let's talk about the 3 definitions the Federal Register 29 section
1910-399 gives for Acceptable by OSHA.  I will paraphrase below:

Number 1:  Products must be tested and labeled by an NRTL.  This can be
done through a Certification Program with an NRTL or by a Field
Evaluation.  Does anyone know another way to get an NRTL sticker on your
products?  Please share.

Number 2:  For products that no NRTL accepts, certifies, lists, labels, or
determines to be safe.  What does this mean?  In our case, if NRTLs will
not Certify our products because of how we manufacturer them in low volume,
does this section apply?  And if so, who is the "federal agency, state,
municipal, or other local authority that will test my product and stick a
label on it that will be acceptable to our customers?  Local to the
manufacturer or local to the customer purchasing the equipment?  Can anyone
provide me with a name, company name, phone or email of such a person?
 Practically speaking, I don't think this option will work.  If anyone has
a real-life example of how this works, please fill me in. I would really
appreciate it.

Number 3: Custom-made equipment is SUPPOSED to be "ACCEPTABLE" if it is
"determined to be safe for its intended use *by its manufacturer*".  Is
this crazy or what?  Can I be so bold as to say that THIS IS LAW???  Ok, so
how is this accomplished?  The manufacturer has a top-notch safety
compliance lab that generates a test report with "test data" showing the
product to be SAFE.  Then what?  The manufacturer has no marking.  How do I
convince a Customer that this method is or should be acceptable by OSHA?
NOTE: In the last 25 years, I have successfully used this approach. I sent
a detailed safety test report in CB (like) format to an OSHA inspector at
our customer site and it was accepted. But don't get your hopes up.

BOTTOM LINE:  If you do business with customers who are associated with
federal or state organization, schools, universities, military
subcontractors, customers in California or Washington, etc., chances are
you ONLY have Option ONE above which can be accomplished by an NRTL
Certification Program or by a Field Evaluation.  However, as I mentioned,
either choice is getting crazy expensive.  Something has to be done and
soon. Many test labs are struggling to keep their doors open including
NRTLs.  Many have closed down in the last 10 years.

Final Comment:  Last year we had a small supporting product that we sold to
a customer who wanted an NRTL Label on it. The retail price of the device
was only $2000 (US) but the NRTL charged us $4000 for the Field
Evaluation.  As a federal subcontractor, the customer paid for it because
they had no choice.  Something needs to be done.  An alternative must be
found.  Like Europe, for low-risk devices, OSHA should allow manufacturers
to test their own products and do a Manufacturer's Declaration of
Compliance with some kind of recognized marking.

This issue comes up about every year and I really really hope that someday
North American authorities will come up with a solution.  It is a crazy and
very expensive mess for may manufacturers.  Is there someone in the US
Government we can talk to, complain to, plead to?

I now return you to your regularly scheduled program.

The Other Brian





On Thu, Feb 20, 2020 at 10:09 PM Kevin Robinson 
wrote:

> Clause 2 under the definition for “acceptable” can only be used under
> specific conditions, specifically if no NRTL has the capability to test and
> certify the equipment.  In such cases, the equipment/installation would be
> acceptable to OSHA if a state/federal agency determined it was safe.  

[PSES] Test Standards Copyright

[Brian Kunde]

When we develop a new test report in the CB Format for a test standard, we
usually summarize with test requirements for each clause to reduce the size
of the overall report.

Can the Test Report be a Word-for-Word copy of the test standard, so does
it have to be different to avoid copyright issues?

Thanks,
The Other Brian

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[PSES] Conformity Assessment Procedure

[Brian Kunde]

Greetings.

I know this email is similar to Ragan's recent email, but I just had a
similar encounter. I could really use your help and wisdom.

Our company self declares to the CE requirements in Europe.  We also sell
products in the United States without NRLT certification but will obtain an
NRLT field evaluation upon request of our customer.  I manage a top-notch
corporate EMC and Product Safety Test laboratory where we perform all the
required examinations for CE.

We perform annual production audits.  The products received are nearly
completely assembled but lacking some components that may get broken during
shipment. These parts and some external components are shipped in separate
boxes called Component Packs.  We use some, but not all of the parts in
these packs to complete the assembly of the Product Under Test, and then
perform all of the required examination tests as part of the over-all
Conformity Assessment. The remaining parts we examine if necessary.  When
we are done with the product, we unassemble it to the state in which we
receive it and ship it back to where the product goes through re-testing
prior to shipping to the customer. The Component Packs have to be gone
through to ensure all the parts are still there and not broken.

Here is the problem.

Our shipping department does not want to have to re-count and re-pack the
Component Packs.  They have endlessly tried to convince management that we
do not need the packs or need every part in the packs. They want us to
either store the parts necessary to assemble the product for testing so
they don't have to send us any packs or we have to give them a list on only
the parts we need, which is a huge waste of our time.

So I'm looking for a clear or precise Examination or Conformity Assessment
Procedure that calls out that I have to get the Entire or Complete Product.

The closest thing I can find is in the 768/2008 document under Module B,
EC-Type Examination, section 2 where it states "examination of a
specimen, representative of the production envisaged, of the *complete
product.*  Unfortunately, this refers to the testing performed by a
Notified Body.

Is there any document that specified the requirements in detail of a
Conformity Assessment and Examination performed by the Manufacturer Test
Lab?

Thanks for any help.

The OTher Brian

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Re: [PSES] Fire enclosure IEC/EN61010 - flammability classification

[Brian Kunde]

The actual requirement is "2) The ENCLOSURE, and any baffle or flame
barrier, shall be made of metal (except magnesium)
or of non-metallic materials having a flammability classification of *V-1
or better*, of IEC 60695-
11-10."

Keep in mind the "or better".  Most enclosures I have ever seen are rated
V-0 or 5V which is better than V-1.  The flammability rating of plastic is
based on its thickness. Molded plastic parts can vary in thickness so using
a better material gives you some margin.

Good luck,
The Other Brian

On Mon, Dec 9, 2019 at 6:46 AM Amund Westin 
wrote:

>
>- Moveable equipment (4 pcs castor wheels).
>-
>- Contains various electronics (230VAC, EN60950 power supplies, low
>power PCBs, etc)
>- Bottom plate of metal.
>
>
>
> Enclosure: sides and top of plastic material, *type V-1*, correct?
>
>
>
>
>
> Best regards
>
> Amund
>
>
> -
> 
>
> 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:
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>
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>
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[PSES] Branding Products and EU Decision 768 NLF

[Brian Kunde]

I'm not a Marketing person, so I do not know the official term for it, but
there is a method of doing business where one company buy/sells a product
made by another company marked with the brand name and trademark of the
marketing company.  I've always called this "Branding", but like I said it
may officially be called something else.  Here is the situation in more
detail:

Company-A designs and manufactures a great Electronic Widget and will
produce the Widget in your company's color (Company-B), your company's name
on the manual,  and with your company's name and trademark on the front of
the Widget.  Company-A's name and address is on the Nameplate Label on the
back of the Widget. Company-A handles everything including the Conformity
Assessment, Generating the EU-DoC, Applying the CE marking, audits,
inspections, etc.. All you have to do is market and sell it.

Here is the Problem:  According to the EU Decision 768 document also known
as the New Legislative Format, paragraph 26,

"Any economic operator that either places a product on the
market under his own name or trademark  should be considered to be
the *manufacturer *and should assume the obligations of the manufacturer."

Company-B accepts the responsibility and liability of the Widget but there
are many tasks called out that the "Manufacturer" must do that Company-B
cannot do, such as the conformity assessment.

Paragraph 21 states,

"The manufacturer, having detailed knowledge of the design
and production process, is best placed to carry out the
complete conformity assessment procedure. Conformity
assessment should therefore remain the obligation of the
manufacturer alone."

Company-B can be responsible for the conformity assessment, but they cannot
carry out the procedure because they do not possess the required detailed
knowledge of the design or production process.

A customer purchasing the Widget from Company-B asked for a copy of the
EU-DoC. The customer would not accept the EU-DoC because it was generated
by Company-A.  The customer insisted that Company-B generates the EU-DoC
because per the NLF, Company-B is the "Manufacturer" and so all
documentation should be in the letterhead of Company-B.  Does Company-B
have the credentials necessary to generate the DoC?

Must the DoC be in the letterhead of Company-B or should the customer
accept the DoC generated by Company-A?

Thanks to all.

The Other Brian

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[PSES] CE Marking and DoC for Multi Device Product

[Brian Kunde]

If I have an electronic product that I want to place on the market in
Europe, and the product is made up of several individual electronic devices
each powered by AC mains (packaged and sold together), do I place the CE
marking on only one of the devices or all devices?

And if the answer is "all devices", then do I need a DoC for each device or
will one DoC be ok? If each device has its own identifier, can I just list
all identifiers on the DoC?  OR can I simply list what the devices are
instead of their specific part numbers?

In the same train of thought, If my product is called "E-box One", for
example, AND the product is made up of many individual electronic devices
each with their own identifying part number, does the marketing name "E-box
One" have to be on at least one of the devices that make it up OR does it
have to be on every one of the devices?

How do we handle the case were say two years down the road a customer with
a 4-device system wants to expand to a 5-device system?  Individually these
devices are nothing and could be viewed as an upgrade kit. Does this "kit"
have to have its own CE Marking and DoC?   What if the "kit" is not
officially marketed; just the customer ordered a kit similar to ordering a
replacement part?

How should these be handled?

Thanks,
The Other Brian

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[PSES] Observation Period during Flicker Emissions Test

[Brian Kunde]

Reference IEC/EN 61000-3-3:2013 section 6.5 regarding Observation Period.
The Electrical Equipment (EE) under test is NOT listed in Annex A.

We are trying to make sure we are testing a product correctly. Your help
would be greatly appreciated.

The EE has a cycle time of about 15 to 20 minutes.  Since the cycle time is
greater than 10 minutes, it is my understanding that the cycle is NOT
repeated to determine the Plt.  So would it be correct to start up a 2-hour
test, run the EE through a single cycle and then just let the EE run in
standby mode for the remainder of the 2-hour test?



Here is our situation.  We have an EE under test that passes the 10 minute
Pst limit with a value around 0.8 (1 is the limit).  If we repeat the
operational cycle over and over again during the 2-hour test, we again will
get a Plt value of about 0.8 (limit is 0.65) and Fail.  But if we run the
cycle only once and then let the EE sit in standby mode for the remainder
of the 2-hour test, the Plt will creep down below 0.65 and pass the test.

Again, we want to make sure we are performing the test correctly according
to the standard.

Thanks to all for help on this.

The Other Brian

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Re: [PSES] Stacking Grounds on a Stud

[Brian Kunde]

Thanks to every one. I received some very good information.

The Other Brian

On Fri, Jun 7, 2019 at 7:58 PM Ted Eckert <
07cf6ebeab9d-dmarc-requ...@ieee.org> wrote:

> Hello Brian,
>
>
>
> Let’s start with the easy question first, the order of stacking lugs on a
> single stud. The equipment’s protective earthing conductor should go on the
> bottom and have a lock washer and nut on top of it before any other bonding
> conductors are added. The rationale is that you don’t want service
> personnel to have to remove the main earthing lug to remove any other
> parts. If the main earthing lug is bolted below other lugs, there is a
> lower risk of it being disturbed in any servicing procedure. There is one
> advantage of placing a lock washer and nut over each additional lug added.
> If two lugs are under the same nut, there is a chance that they could
> rotate against each other loosening the nut above them and compromising the
> connection. I recommend a separate bonding stud for each lug if the
> equipment is expected to require servicing that removes bonding conductors
> to remove parts.
>
>
>
> If you have a welded, press fit or similarly fixed stud, you likely do not
> need to mask of the paint or coating around the stud. The flat faces of the
> nuts will make good electrical contact with the grounding lugs and the
> threads of the nut will have good electrical contact with the stud.
> However, I have had at least one NRTL tell me that they wanted the paint
> masked off in a ring around the stud. That NRTL was in the minority. I’ve
> had differing opinions on whether split or star-tooth lock washers are
> better at cutting through paint, coatings or oxidation. I take no position
> on that, and it shouldn’t matter based on a connection through the threads.
>
>
>
> Bolts and screws pose a different problem. These may not make as good of
> electrical connection to the chassis. Lock washers that cut through
> coatings and oxidation will likely be required. That being said, I have a
> personal aversion to bolts and screws for bonding. The exception is where
> there is a threaded insert or otherwise set of well formed threads in the
> chassis where the bolt will make a good connection through the threads.
> Screws are too easy to strip out if overtightened, thereby compromising the
> bonding.
>
>
>
> I’m sure these rules are written down somewhere, but I don’t know where
> that would be. I would be interested in knowing, because I assume there are
> written rules somewhere that would tell me that everything I just wrote is
> wrong.
>
>
>
> Ted Eckert
>
> Microsoft
>
> The opinions expressed are my own and do not necessarily reflect those of
> my employer.
>
>
>
> *From:* Brian Kunde 
> *Sent:* Friday, June 7, 2019 6:10 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] Stacking Grounds on a Stud
>
>
>
>
>
> My question(s) is about stacking ground lugs on a single stud for the
> Protective Earth Terminal inside of a piece of electrical equipment (IT or
> Lab Equipment).
>
>
>
> Where is it documented how to properly stack ground lungs?
>
>
>
>
>
> I have seen this done several ways:
>
>
>
> 1. A welded stud or just a bolt (#6 or #8 machine screw) pushed through a
> hole,  with the Power Cord Ground Conductor lug stacked FIRST, followed by
> additional lugs. I have seen this with and without locking washers between
> the lugs.
>
> 2. I have seen the above with Nuts or Locking Nuts between each Lug.  This
> method seems much more reliable to me but the nuts take up a lot more space
> limiting the number of lugs that can be stacked.
>
>
>
> 3. I have seen the above on black oxide, anodized aluminum, or powder
> coated painted metal with not attempt to scrape off the non-conductive
> material to ensure a good bond.
>
>
>
>
>
>
>
> I just evaluated a 3rd party product that had a #6 machine screw pushed
> through a hole in a powder coat painted metal plate with 7 ground lugs and
> one nut holding it all together.  With very little effort, the nut became
> loose and the ground became intermittent.  Yet, this unit has passed an
> NRTL inspection.
>
>
>
>
>
> It is my understanding that PE Ground bonds made with a *Screws *cannot
> be stacked.  One Lug, One Screw.  Is this documented somewhere?
>
>
>
> Thanks much for any input.
>
>
>
> The Other Brian.
>
> -
> 
>
> 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>
>
>

[PSES] Stacking Grounds on a Stud

[Brian Kunde]

My question(s) is about stacking ground lugs on a single stud for the
Protective Earth Terminal inside of a piece of electrical equipment (IT or
Lab Equipment).

Where is it documented how to properly stack ground lungs?


I have seen this done several ways:

1. A welded stud or just a bolt (#6 or #8 machine screw) pushed through a
hole,  with the Power Cord Ground Conductor lug stacked FIRST, followed by
additional lugs. I have seen this with and without locking washers between
the lugs.

2. I have seen the above with Nuts or Locking Nuts between each Lug.  This
method seems much more reliable to me but the nuts take up a lot more space
limiting the number of lugs that can be stacked.

3. I have seen the above on black oxide, anodized aluminum, or powder
coated painted metal with not attempt to scrape off the non-conductive
material to ensure a good bond.



I just evaluated a 3rd party product that had a #6 machine screw pushed
through a hole in a powder coat painted metal plate with 7 ground lugs and
one nut holding it all together.  With very little effort, the nut became
loose and the ground became intermittent.  Yet, this unit has passed an
NRTL inspection.


It is my understanding that PE Ground bonds made with a *Screws *cannot be
stacked.  One Lug, One Screw.  Is this documented somewhere?

Thanks much for any input.

The Other Brian.

>

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Re: [PSES] E-Stop Questions

[Brian Kunde]

Thanks. Very Helpful.

The Other Brian

On Wed, Apr 24, 2019 at 1:16 PM Doug Nix, C.E.T.  wrote:

> Hi Brian,
>
> I’ve dealt with many related questions on my blog, machinerysafety101.com
> https://machinerysafety101.com/series/emergency-stop/, but not these
> specific questions, so I’ll answer them now. Then I’ll add them to the blog
> (thanks for the inspiration!).
>
> 1) How mushroom-shaped is enough?
>
> There’s no hard answer to this, but I can say this: there are three
> fundamental shapes for push button operators, flush, extended, and
> mushroom. The intent is that neither flush nor extended head operators be
> used for e-stop functions. More info in IEC 60947 on that.
>
> 2) Yellow background. Yellow backgrounds have to be big enough to provide
> clear contrast with the red button operator. A tiny ring, or just a yellow
> stripe around the base of the button is not enough in my opinion. Typical
> rings are 2x the operator nominal size, i.e., 30 mm buttons get a 60 mm
> ring, 22 mm buttons get a 44 mm ring. These are common practice
> recommendations.
>
> 3) Printing “emergency stop” on the yellow ring is not required in any
> jurisdiction anymore, and has been removed from NFPA 79, as well as IEC
> 60204-1. Just leave it off, as the red/yellow combination is
> internationally recognized as the sign for e-stop and emergency switching
> off devices.
>
> Best,
> Doug Nix
>
> d...@ieee.org
> Mobile: (519) 729-5704
> Office:(519) 650-4753
>
> On Apr 24, 2019, at 12:49, John Woodgate  wrote:
>
> Mushrooms come in all sorts of shape, so the description is not very
> scientific.  It's only a concern if the AHJ thinks it is!
>
> Whether the English is acceptable is a matter for national legislation, so
> there are probably several incompatible answers.
>
> Best wishes
> John Woodgate OOO-Own Opinions Only
> J M Woodgate and Associates www.woodjohn.uk
> Rayleigh, Essex UK
>
> On 2019-04-24 17:43, Brian Kunde wrote:
>
> I am constantly being asked three questions about E-Stops which I cannot
> find the answers to.
>
> 1. "Mushroom Shape" is specifically called out in some standards but the
> newer style e-stop switches are becoming less and less Mushroom Shaped.  If
> this a concern?
>
> 2. "Yellow Background" is getting smaller and smaller. Some small e-stop
> switches has no yellow background but has a small area on the shaft of the
> switch that is yellow. This is not technically the "background".  Is this
> acceptable or is a yellow background required in addition?  The size of the
> yellow area is not specified as far as I have found.
>
> 3. English text "Emergency Stop" printed on the button or on the yellow
> background ring:  Is this a problem in non-english speaking countries?  Do
> I have to translate (like in French for France and Canada) or are these
> words "globally acceptable"?  I have been telling our engineers to choose
> e-stop switches and yellow rings without text but some manufacturers only
> provide it with the text.
>
> Thanks to all.
>
> The Other Brian
> -
> 
>
> 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) <http://www.ieee-pses.org/list.html>
> List rules: http://www.ieee-pses.org/listrules.html
>
> For help, send mail to the list administrators:
> Scott Douglas 
> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bacher 
> David Heald 
>
> -
> 
>
> 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 

[PSES] E-Stop Questions

[Brian Kunde]

I am constantly being asked three questions about E-Stops which I cannot
find the answers to.

1. "Mushroom Shape" is specifically called out in some standards but the
newer style e-stop switches are becoming less and less Mushroom Shaped.  If
this a concern?

2. "Yellow Background" is getting smaller and smaller. Some small e-stop
switches has no yellow background but has a small area on the shaft of the
switch that is yellow. This is not technically the "background".  Is this
acceptable or is a yellow background required in addition?  The size of the
yellow area is not specified as far as I have found.

3. English text "Emergency Stop" printed on the button or on the yellow
background ring:  Is this a problem in non-english speaking countries?  Do
I have to translate (like in French for France and Canada) or are these
words "globally acceptable"?  I have been telling our engineers to choose
e-stop switches and yellow rings without text but some manufacturers only
provide it with the text.

Thanks to all.

The Other Brian

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Re: [PSES] Big Boot from List Server

[Brian Kunde]

So hopefully it is no big deal and just a glitch the List Server
administrators will resolve.  From my perspective, since this was the third
time since January, it seemed like a bigger deal than it really was.  Sorry
if I over-reacted.

Piece Out.

The Other Brian

On Wed, Apr 24, 2019 at 12:18 PM Sundstrom, Mike 
wrote:

> I got this email for the first time last night. It says I’m unsubscribed
> now?
>
> So my main question is, have I actually been unsubscribed or is this a
> bogus email?
>
>
>
> Enquiring minds want to know.
>
>
>
> Thanks,
>
>
>
> Michael Sundstrom
>
> Garmin Compliance Engineer
>
> 2-2605
>
> (913) 440 1540
>
> KB5UKT
>
>
>
>
> *"We call it theory when we know much about something but nothing works,
> and practice when everything works but nobody knows why."  *-- Albert
> Einstein
>
>
>
> *From:* Nyffenegger, Dave 
> *Sent:* Wednesday, April 24, 2019 10:16 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Big Boot from List Server
>
>
>
> *CAUTION - EXTERNAL EMAIL:* Do not click any links or open any
> attachments unless you trust the sender and know the content is safe.
>
>
>
>
>
> I received the same systematic notification last night as everyone else
> and have not done anything with it.  I am receiving email today but I don’t
> think my post from earlier this morning went through.  So we’ll see if this
> reply goes through or not.
>
>
>
> -Dave
>
>
>
> *From:* Brian Kunde [mailto:bkundew...@gmail.com ]
> *Sent:* Wednesday, April 24, 2019 11:05 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] Big Boot from List Server
>
>
>
> Since the first of the year, I have been having trouble maintaining my
> subscription to this List Server. According to those who administrate this,
> the problems are all at our end but our eMail Administrator looked into it
> and said the problem that is being reported is outside our control
> (Phishing).
>
>
>
> So in early April, I switched to my Gmail account thinking that this move
> should resolve all the issues. Nope. Today I was booted again for 2
> undeliverable emails.
>
>
>
> The problem is not my posts because I haven't posted since my last
> re-subscription.  I don't know what else to try.
>
>
>
> Is anyone else having similar troubles? Any suggestions other than just
> re-subscribing every few weeks?
>
>
>
> I appreciate your input.
>
>
>
> The Other Brian
>
> -
> 
>
> 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) <http://www.ieee-pses.org/list.html>
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>
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>
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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 <
> 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) <http://www.ieee-pses.org/list.html>
> List rules: http://www.ieee-pses.org/listrules.html
>
> For help, send mail to the list administrators:
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> Mike Cantwell 
>
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> Jim Bacher 
> David Heald 
>
> --
>
> CONFIDENTIALITY NOTICE: This email and any attachments are for the sole
> use of the intended recipient(s) and contain information that may be Garmin
> confidential and/or Garmin legally privileged. If you have received this
> email in

Re: [PSES] Postal address on product labelling...

[Brian Kunde]

The companies I have worked for over the last 40 years have relied heavily
on international sales, so having your company's name and address on the
product is just part of doing business.  I'm not sure what the argument is
with having your address on the product.  My questions to those who
complain would be, "Why Not?".

As far as the requirements of EU Directives go, keep in mind that what they
are asking for is the name and address of the responsible party for the
compliance of the instrument. The Directive refers to this legal person or
entity as the "Manufacturer", but that does not mean it is the company who
actually builds the product, thou in most cases they are one and the same.


Personally, I'm surprised that the writers of the EU Directives, the
Commission, Legal Authorities in all Countries, etc.  don't require some
type of information on ALL PRODUCT, be it an address, phone number, fax
number, email address, website, etc. that provides IMMEDIATE RESPONSE from
the responsible party or at least within 48 hours.  AND the system,
whatever it is, must always be active, and only used by authorities and/or
anyone regarding a Compliance Issue or Question.  Kind of like a reverse
911 (emergency number in the States).

For those of you who deal in Product Safety and RoHS where you need to
contact component manufacturers for supporting documentation knows what I'm
talking about.  I hate it when you go to a company's website, fill out a
three-page on-form requesting compliance information, and then never EVER
getting a reply.  OR, you call the "corporate office" for the address that
is labeled on the Nameplate of the product and IF you can get through to a
Real Live Person, you asked for the Compliance Department and the person
has no idea who to transfer you to.  After being transferred to 5 potential
people you finally get ahold of something who says their products are built
in another country somewhere and they "THINK" compliance is handled by
them.   Does this sound at all familiar to anyone?

Once again, I'm glad I'm over the hill and gaining speed for a head-first
collision into the wall call retirement.  Let you young pups figure out how
to resolve all the problems of the world.

The Other Brian



On Wed, Mar 20, 2019 at 9:41 AM Charlie Blackham <
char...@sulisconsultants.com> wrote:

> Matthew
>
>
>
> “But Sir, they’re not doing it” isn’t a defence in court or when you’re
> equipment is stuck in customs, or a competitor has pointed market
> enforcement authorities in your direction
>
>
>
> The key phrase is “…or, *where that is not possible,* on its packaging or
> in a document accompanying the apparatus…..”
>
>
>
> To my knowledge there’s no guidance anywhere as to “what is possible”, so
> it’s probably up to you and your lawyers 
>
>
>
> Regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: **www.sulisconsultants.com*
> 
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Matthew Wilson 
> *Sent:* 20 March 2019 13:06
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] Postal address on product labelling...
>
>
>
> Does anyone else have endless arguments about the need to put a postal
> address on products as per the EMC and LVD requirements?  The EMC directive
> obliges the following (article 7.6 of 2014/30/EU).  The LVD also had the
> exact same obligation (article 6.6 of 2014/35/EU);
>
> ?Manufacturers shall indicate, on the apparatus, their name, registered
> trade name or registered trade mark and the postal address at which they
> can be contacted or, where that is not possible, on its packaging or in a
> document accompanying the apparatus. The address shall indicate a single
> point at which the manufacturer can be contacted. The contact details shall
> be in a language easily understood by end-users and market surveillance
> authorities.?
>
> Manufacturer is, of course, meaning the entity responsible for the product
> denoted by the brand name present on the apparatus.
>
> And every time I encounter this advice being questioned someone always
> says 'But [some large entities/corporations supplying consumer products -
> you can pick your own example] don't put their address on their products.'
>  Well they should!  Maybe those devices with screens allow you to look up
> the address somewhere in the operating system?
>
> Humph!
>
> Sorry just letting off steam :-)
>
>
> --
>
> *Matthew* *Wilson*
> Technical Director
>
> [image: GBE] 
> https://gbelectronics.uk
>
> T:
>
> +44 (0)1903 244500
>
> F:
>
> +44 (0)1903 700715
>
> Ascot House // Mulberry Close // Woods Way
> Goring-by-Sea // West Sussex // BN12 4QY // UK
>
> *Electronics Design // Manufacturing // Component Distribution*
>
> [image: ISO 9001 | ISO 14001] 

[PSES] CCC on Cooling Fans?

[Brian Kunde]

We received a strange request today from Hong Kong
supposedly initiated from Customs.

We were asked to provide CCC supporting documents for about a dozen cooling
fans used in some of our instruments (laboratory equipment).  I knew CCC is
required on household electrical fans but not small internal cooling fans.
The list of fans is a mixture of 230Vac fans and 24Vdc fans.

Some of these fans were used in products that went obsolete 10 years ago or
longer.  We may still ship them as repair replacement parts, but I thought
service parts were exempt.

Is this a new requirement or do you think there is some kind of confusion
going on?

Regards,

The Other Brian

PS: How many active EMC-PSTC members do you think there are?

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RE: Mains Color Codes

[Brian Kunde]

RE: Mains Color CodesRobert,

The only sections I could find in the NEC allowing light blue wire for
neutral was in Chapter 4 Equipment for General Use, article 400 Flexible
Cords and Cables.  This would apply to flexible power cords for computers
and such. I'm not sure what your product is or if this would apply. Hope
this is helpful.

Brian


402-8. Grounded Conductor Identification
One conductor of fixture wires that is intended to be used as a grounded
conductor shall be identified by means of stripes or by the means described
in Sections 400-22(a) through (e).

400-22. Grounded-Conductor Identification
One conductor of flexible cords that is intended to be used as a grounded
circuit conductor shall have a continuous marker that readily distinguishes
it from the other conductor or conductors. The identification shall consist
of one of the methods indicated in (a) through (f).
(a) Colored Braid. A braid finished to show a white or natural gray color
and the braid on the other conductor or conductors finished to show a
readily distinguishable solid color or colors.
(b) Tracer in Braid. A tracer in a braid of any color contrasting with that
of the braid and no tracer in the braid of the other conductor or
conductors. No tracer shall be used in the braid of any conductor of a
flexible cord that contains a conductor having a braid finished to show
white or natural gray.
Exception: In the case of Types C and PD and cords having the braids on the
individual conductors finished to show white or natural gray. In such cords,
the identifying marker shall be permitted to consist of the solid white or
natural gray finish on one conductor provided there is a colored tracer in
the braid of each other conductor.
(c) Colored Insulation. A white or natural gray insulation on one conductor
and insulation of a readily distinguishable color or colors on the other
conductor or conductors for cords having no braids on the individual
conductors.
For jacketed cords furnished with appliances, one conductor having its
insulation colored light blue, with the other conductors having their
insulation of a readily distinguishable color other than white or natural
gray.
Exception: Cords that have insulation on the individual conductors integral
with the jacket.
The insulation shall be permitted to be covered with an outer finish to
provide the desired color.
  -Original Message-
  From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf Of
Mavis, Robert
  Sent: Wednesday, April 05, 2000 1:28 PM
  To: Lacey,Scott
  Cc: emc-p...@ieee.org
  Subject: RE: Mains Color Codes


  I am running into a problem with UL not accepting the Brown/Blue color
code due to UL 2044 and The NEC stating that the Neutral must be white or
Natural grey.

  Has there been any updates to the NEC that allows the Euro Color code?

  -Original Message-
  From: Lacey,Scott [mailto:sla...@foxboro.com]
  Sent: Wednesday, April 05, 2000 4:48 AM
  To: Mavis, Robert
  Cc: 'emc-p...@ieee.org'
  Subject: RE: Mains Color Codes



  Robert,
  I have always found the European color codes (brown/light blue/green
  w/yellow) to be best for dual market use. UL and CSA seem to have no
problem
  with the use of these. You will need to provide some kind of legend plate
or
  tag explaining the color codes, as many U.S. electricians are still not
  familiar with these.

  Scott Lacey

  -Original Message-
  From:   Mavis, Robert [SMTP:rma...@pelco.com]
  Sent:   Tuesday, April 04, 2000 5:33 PM
  To: emc-p...@ieee.org
  Subject:Mains Color Codes

  I know this was kicked around a while back but here we go again.

  What are the allowable color codes for pigtails that come from a
  permanently connected apparatus to be connected to mains for US and
Europe?
  Is there a color code that is allowable for both?

  Thanks in advance for any help..

  
  Robert L. Mavis
  Agency Compliance Coordinator
  Engineering Department,
  Compliance Engineering Group
  Pelco
  300 W. Pontiac Way
  Clovis, CA 93612

  Phone:  (559) 292-1981 x2309
  Toll Free:  (800) 292-1981 x2309
  Fax:(559) 291-3775
  email:  rma...@pelco.com
  URL:http://www.pelco.com http://www.pelco.com
  -



  Note: If you are not the intended recipient of this e-mail,
contact
  administra...@pelco.com or call (559) 292-1981.  Information contained may
  be confidential.  Dissemination, distribution or copying of this e-mail is
  prohibited if you are not the intended recipient.

  Note: If you are not the intended recipient of this e-mail, contact
administra...@pelco.com or call (559) 292-1981.  Information contained may
be confidential.  Dissemination, 

RE: ACA contact..

[Brian Kunde]

ACA contact..George,

Goto the following web page:

http://www.aca.gov.au/standards/emc.htm

The bottom of that web page has phone, fax and email addresses. I have
contacted them by email in the past and they are very quick to respond as
well as being very helpful.

Brian Kunde
  -Original Message-
  From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf Of
George Sparacino
  Sent: Wednesday, April 05, 2000 1:09 PM
  To: 'emc-pstc'
  Subject: ACA contact..


  Hello All..

  I am trying to find out if my product falls within the Australian EMC
framework for the C-Tick marking. Does anyone have a contact name / phone#
of someone at ACA that may be able to provide some answers ?



  Thanks in Advance,
  George

RE: Lifting restrictions

[Brian Kunde]

Brian,

Most of the information you find will be regarding lifting restrictions for
production workers where to lift heavy objects is part of their everyday
job. The limits are based on weight, size, lift start point, lift
destination point, lift angle, how often,  etc...

I have not found a good source for labeling or warning information for
individual products (as a manufacturer). We make an analyzer which is a
table top (Lab bench) instrument which weighs over 400lbs (180kg). We tossed
around the idea of stating in the installation manual about suggesting 4 men
lift from the corners, but was told that we could become liable if an injury
occurred.

What we ended up doing was to clearly state the weight of the instrument in
the manual and state, Use proper lifting equipment.  The burden is then on
the customer to find a way to safety lift the unit.

The safety standards (such as EN 61010) states that the product must have a
way of lifting it. So if it is not designed so this can be done you must
provide handles or some way of lifting it either by man or machine.


As far as warning labels go, you only have to use labels if it is not
apparent that the unit is heavy. If it looks heavy it probably is. No
unknown hazard there so don't worry about labels. If it is heaver than it
looks, then you would need a label. If it is questionable, use a label. This
is why most packaging (or boxes) have weight warning on boxes that you can't
see what's inside but might be the size some one might try and pick up.

Well anyway, you can't go wrong with the old triangle with the exclamation
point in the center. Under it state the weight or something like 18kg. I
have seen this method used.  You can get creative and make your own
graphics. UPS uses a picture of a scale with 31.5+ in the middle.  On a
monitor box we have here in the lab there is a graphic of two stick men with
legs bent lifting a box from either side. I have also seen the graphic that
looks like a big weight (like the 1 ton weight that would always fall on the
coyote in the Roadrunner cartoons) with the weight stated in the center.

As a manufacturer you are responsible to do one of two things: eliminate the
hazard (2 levels of protection) or inform of the hazard. If lifting your
product can cause a hazard (or injury) all you can do is inform. In
addition, the safety standards say you have to provide the means to safely
lift. That's basically it.

I'm sorry I could not give you exactly what you asked for.  I asked the same
question last year and spent weeks pouring through factory worker standards
that didn't apply to products. I hope this helps.
Brian Kunde

-Original Message-
From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf
Of bharl...@vgscientific.com
Sent: Thursday, March 30, 2000 4:11 AM
To: emc-p...@ieee.org
Subject: Lifting restrictions



Hi group
Is anyone aware of a standard UL or EN which details the
Weights that are acceptable as one and two person lifts.

I have come across a number of industry and company related
information but cannot find a standard.

Also is there an accepted international  warning label to cover this.

Regards

Brian Harlowe

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RE: Questions about EN61000-4-6

[Brian Kunde]

Hi Barry,

I commend you on the in-dept study you do when looking at standards, but as
Abraham Lincoln said, If you look for the bad ... you will surely find it.

Standards are written for the majority of products, not for every product in
every environment. That's why there is the TCF rout to compliance.  Remember
that we are ultimately not striving for compliance to standards, but to the
EU Directives which does not give boundaries.

It is impossible to write a standard that some what if wouldn't kill. So
don't expect it to. But, don't think that because a test standard sets some
boundaries that that's all there is to it. If you (your company) designs a
product that 'by design' would be susceptible at some condition or frequency
or in some likely environment that is not covered in a test standard you are
still reasonable for its immunity performance per the Directive. Trying to
determine what to test for is why us EMC engineers make the 'big bucks'. If
you miss a problem area don't worry. It will show up at the customer site
and then you can fix it.

We had a product that passed all our immunity tests (even more strict than
what the EU requires) but at one customer site the product would fail every
day at the same time. What we found out was that they had a clock system
that sent a pulse emission on the AC power line for the entire building to
tell the clocks to advance to the hour and stop. Then a second pulse would
tell all the clocks to start back up synchronizing them throughout the
building.  This pulse was unique enough to get past our Immunity tests. Are
we legally required to make our products immune to this and all known
emissions? Does the Directive give us an alternative?  I believe we are
obligated to design our products to be immune to any emission that it would
'Likely' see in the environments it will be used in which is always a moving
target. But, would we burden the entire industry to be immune to a 'Clock
Pluse' emisision that was only found at a few customer sites? Only YOU can
answer that question, not the standards writter.  As technology advances the
environment our products much work in will be different than today. We as
EMC engineers must be ready to do our jobs even when it requires us to go
beyond the published standards.

The people who are involved in writing standards have a difficult task. My
hat goes off to them for their hard work.  My hope is that I didn't offend
anyone with my comments.

Brian



-Original Message-
From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf
Of Barry Ma
Sent: Monday, March 27, 2000 6:33 PM
To: EMC-PSTC
Subject: Questions about EN61000-4-6



Hi Group,

Here are some of my questions and thoughts about EN61000-4-6. Any
corrections and comments are greatly appreciated. In discussion of Wisdom
behind all these standards, Richard Nute summarized three points raised by
Martin Rowe. One of them is reasonableness or appropriateness of the
standard. Please allow me to have better understanding of reasonableness
or appropriateness of the EN61000-4-6.

Both EN61000-4-3 (4-3 in short below) and EN61000-4-6 (4-6) verify the
immunity of EUT against induced disturbances caused by incident
electromagnetic fields from 150 KHz to 1 GHz. The chamber test approach used
in 4-3 is not suitable at lower frequencies (150 KHz to 80 MHz), - not in
principle only technically.  That's why we need to perform 4-6 differently
from 4-3. The methodology of 4-6 is to inject conducted disturbance to
cables connected to the EUT by using direct injection or clamp coupling. The
injected cable currents are supposed to be the same as induced by incident
electromagnetic fields in real world.

The methodology of 4-6 also implies that at low frequencies the possible
disturbance directly coupled into the EUT from incident electromagnetic
fields can be ignored in comparison with the disturbance indirectly coupled
to the EUT via attached cables. For many well-shielded EUT that assumption
works because it is difficult for low frequency electromagnetic fields to
directly get into the EUT through apertures (such as slots, seams, and
holes), whose dimensions are small compared to wavelength.  But what if the
EUT has larger openings or only plastic enclosure?

Let's see an extreme example. A component cannot work properly under the
illumination of 2.5 V/m incident field at 50 MHz The component would feel
2.5 V/m field when installed if the EUT is illuminated by 3 V/m incident
field. But the component could work OK if injecting cable current of 3V into
the EUT.

The boundary 80 MHz between 4-3 (80 to 1000 MHz) and 4-6 (0.15 to 80 MHz) is
not always fixed. It may be adjusted depending on different scenario. That
principle is mentioned only in principle. I would like to see a real example
to adjust the boundary between 4-3 and 4-6. Does it make more sense to setup
a transition region, say 50 to 100 MHz, for both 4-3 and 4-6 to overlap?

For the same EUT the test level 

RE: EMC - Declaration of Incorporation?

[Brian Kunde]

If the product you are selling is a component or sub assembly that will be
installed as part of a finished product, then yes you can do what you
purpose. Make sure you document what needs to be done and why.  Most DOCs
have a section labeled Supplementary Information:. I would place a note in
that section stating that there are conditions for compliance.

If your product is the final product or a consumer product than no. How is
your customer going to install a cap across the AC line in your product?
External assemblies such as shielded I/O cables and such are allowed as long
as they are well documented.  I have seen special line cords with filters
built into the plug, but it had to be made captive to the unit (or part of
the unit) per the VDE (this was many years ago). I don't see how this can be
done though there are many more clever than I. I will be curious to see
others reply.

Brian Kunde
LECO Corp.

-Original Message-
From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf
Of Russell, Ray
Sent: Friday, March 24, 2000 10:14 AM
To: 'IEEE PSTC'
Subject: EMC - Declaration of Incorporation?



Greetings,

We sell an air compressor with a DC motor. This motor requires a capacitor
across the DC supply lines to meet the EMC requirements. Of course
management does not want to supply the capacitor, they want to describe it
in the documentation, and add a note on the Declaration of Conformity that a
capacitor is required. Is this acceptable for European customers?

In that scenario, I would like to issue a Declaration of Incorporation, but
after reviewing the directives, I can only find a reference to the
Declaration of Incorporation in the Machinery Directive. Can this be used
for the other directives?

Thank you once again for your assistance,


Ray Russell
Regulatory Compliance Engineer


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Wire Colors for different Motor Voltages

[Brian Kunde at LECO]

Hello group,

I apologize for this question but I'm in a pickle and looking for help and 
advise.

We make and sell a Cut-off Saw that is used to cut steal rods. We sold a unit 
to a customer in the United States. The unit was shipped with the motor wired 
for 220VAC. The customer wants it configured for 480VAC which is no problem 
because we provide written instructions on how to do it. It is simply changing 
a few wires on a terminal block. The instructions are simple and the wires are 
clearly labeled.

Here is the problem.

The Local Union Electricians hired to re-wire the unit for 480VAC says they 
can't do it because the wires don't meet the color codes in the NEC.  The wires 
are all black.

Is this really a problem or are these Electricians just giving us a hard time?  
I thought internal wire colors are not important (except for the green/yellow 
protective ground).  Any 10 year old could follow the instructions and make the 
wiring change. 

Has anyone else had this problem?  Are we unknowingly violating some NEC rule? 
We are looking through the NEC but haven't found anything to support the 
Electrician's statement. Help!

Thanks again for any replies.

Brian

Re: Servicing and repairs

[Brian Kunde at LECO]

Hi Brian Harlowe,

I'm not aware of a EU Legislation that says a company can't service or
maintain purchased equipment. Our company is in the same situation as you
are: we manufacture laboratory equipment and sell it world wide. We also
test our products to EN61010 which is not as strict in these areas as
consumer products would be if tested to EN60950. It is assumed that the
operator has the proper training to perform the necessary tasks of their
job.

Many of our customers demand to service and maintain our products
themselves, so we have to provide procedures, schematics, part lists,
assembly diagrams, etc...   This request is so common that we provide all
this information with every unit now.

The manufacturer of a product is not responsible for the technical level of
the operator or the person who maintains or services the instrument at the
customer location.  The customer has the burden to make sure his people are
properly trained for the tasks under their job description.  As a
manufacturer, you have to provide a safe product and provide instructions
for safe operation,  maintenance, and service. As for maintenance and
service, provide the proper warnings in the documentation and on the product
such as Warning: High Voltage. Remove Mains Cord prior to removing panel.
Your job is to identify all hazards whether it is the operator or a service
person who will be performing the task.

You don't have to provide Maintenance and Service information for your
customers. You can make a stand and say that these tasks can only be
performed by your own people. BUT, you will still have to generate
maintenance and service documentation for in-house use. This is a
requirement especially if documentation is required to insure the safety of
the person performing the maintenance or service.

So the question is, what's wrong with providing your customer with
Maintenance and Service information on your product?  Nothing that I am
aware of as long as you do a good job in identifying the hazards.

Our company takes a similar view as our customers. We will not purchase a
piece of equipment, whether a computer, a lift truck, or digital scope
unless we can obtain the schematics, drawings, and service documentation.  I
think in this industry it is for the most part a requirement of doing
business.

Brian Kunde





- Original Message -
From: Brian Harlowe bharl...@vgscientific.com
To: emc-p...@ieee.org
Sent: Tuesday, December 21, 1999 12:04 PM
Subject: Servicing and repairs



Traditionally my company has encouraged it's users to carry out a
limited amount of servicing and repair on our Electronic units.

Under the EU Safety legislation I know this is now a No No.

I am a little bit of a lone voice crying in the wilderness as far as
our management is concerned.

Can any one out there quote me any instances or cases that I can use
to drive home the point with our management

A happy Christmas to you fellow compliance people and if we survive
the Y2K business.  Good luck in the new century and may this
newsgroup continue to prosper

Best Regards

Brian Harlowe
* opinions expressed here are personal and in no way reflect the position of
VG Scientific

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Measuring Capacitance in HV circuits

[Brian Kunde at LECO]

Hello Group,

In EN61010,  section 6.3 says, If the voltage exceeds the value listed in 
6.3.1 or 6.3.2, the current and capacitance shall be measured.

I understand how to measure current (6.3.1.2) with the circuit in Annex A, but 
how do I measure Capacitance for section 6.3.1.3?   It doesn't seem right to 
try and measure a complex circuit while powered off with a conventional 
capacitance meter.  How else can this be done?

Any help would be appreciated.

Brian Kunde

MORE INFORMATION

I have an instrument that places 2500 volts in an area that the operator has to 
have access to. We are attempting to verify that this circuit meets the 
requirements of a limited current circuit by applying the requirements of 
section 6.3.. When applying the loading circuit described in Annex A the 
voltage is loaded down to a point where the HV circuit shuts down. To my 
understanding, doing so meets the requirements of 6.3.1.2..  But, when you 
first apply the loading circuit to the HV circuit you see a small arc or spark, 
so I'm assuming there is some discharged energy that exists before the HV 
Circuit shuts off.  

I assume this issue would be covered under the Capacitance measurement in 
section 6.3.1.3 but I have no idea how to make this measurement.

Re: D of C - Who Signs?

[Brian Kunde at LECO]

Tony,

Very good question.  The person that signs the DOC is doing so as a
representative of the company he/she works for.  If he/she ends their
employment the replacement person does not have to re-issue the DOCs.  It is
the company that is making the declaration, not the individual.  The company
gives the signatory the authority to sign on their behalf.  If the authority
is given to a different person, for what ever reason, it doesn't effect the
validity of previously signed DOCs.

Think of it this way. If a company signed a contract with another company,
neither company can break the contract simply by firing the person who
signed it. Right?  It is the same concept.

Brian Kunde






- Original Message -
From: Tony Reynolds reyno...@pb.com
To: emc-p...@ieee.org
Sent: Thursday, November 11, 1999 10:15 AM
Subject: D of C - Who Signs?



 Hello!

 Forgive me for asking a possibly dumb question but here goes:

 If the EU Declaration of Conformity is signed by a
 responsible/technically competent person who has been nominated on
 behalf of the company's Directors and then that person leaves the
 company,  does his/her replacement who assumes the same level of
 responsibility need to go back and re-issue all of the old D of C's
 with their signature on the document.

 In other words is it acceptable to issue D of C's to
 suppliers/customers which have been signed by someone who has left the
 company.

 Thankyou in advance.

 Tony Reynolds
 Pitney Bowes (UK) Ltd
 Tel +44 (0) 1279 449479
 Fax +44 (0) 1279 449118
 e-mail: reyno...@pb.com




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Penalty for Non-Compliance

[Brian Kunde]

 I hear a very disturbing subject being openly discussed among several 
 of my European contacts.  Distributors in Europe are saying that the 
 CE marking is a joke. That many companies (European Companies are 
 mentioned most often) are simply applying the CE marking to their 
 products without testing.  Some say that many companies were initially 
 forced to do this because of the time and cost of testing and 
 redesign, but since there is very little checking going on the risk is 
 Cost Effective.
 
 IS THIS TRUE?  
 
 Has anyone heard of specific situations where a company or person has 
 been fined or jailed for fraudulently placing the CE marking on 
 non-compliant equipment?  What is the penalty for non-compliance? What 
 is the penalty for fraud?  Is anyone checking?  Is anyone getting in 
 trouble? 
 
 I have been asked to obtain strong evidence to counter this opinion. 
 More or less to put the fear of God into distributors and reassure 
 our marketing and sales force that delaying product to market for the 
 CE mark is the right thing to do.
 
 Can you help?  Please post or email me anything you can.
 
 Thanks,
 
 Brian Kunde
 brian_ku...@leco.com

EMI Window for LCD needed.

[Brian Kunde]

 
 I am in need of an EMI solution for an old mono EL Panel that radiates 
 right through the front of the panel. A fine mesh screen works great 
 but difficult to manufacture because it is so flimsy.  To have a 
 custom frame made to hold the screen taught is to costly.
 
 Does anyone know of a manufacture that has fine mesh screen that is 
 laminated onto a thin mylar sheet (or something like that)?  
 
 I have tried several conductive mylar materials (sputtered with some 
 kind of conductive material) but I can not seem to get enough 
 attenuation through it.  Any recommendations or alternate solutions 
 will be most appreciated.
 
 Please email me at:
 
 brian_ku...@leco.com
 
 Thanks
 Brian Kunde
 Compliance Testing Center
 Leco Corp.

EU Guidelines Document on EMC Directive

[Brian Kunde]

 
 I just received my Sept-Oct issue of CE Magazine that highlight the 
 new Guideline Document on the EMC Directive (everything you ever 
 wanted to know about the EMC Directive).
 
 I have one question.  How do I get this document?
 
 Thanks in advance for your replies.
 
 Brian Kunde
 LECO Corporation
 Compliance Testing Center

Please Help! Need EMI Shield for LCD Panel!

[Brian Kunde]

Now that I need one I can't find one.

I am in need of a transparent shield that will go over a 9 inch diag. 
LCD Panel.  Years ago I had vendors knocking down my doors with these 
cheep shields that where made from a fine conductive screen material 
with a small frame and a drain (ground) wire.  Does anyone know a 
company that still makes these things?  How about the raw material (I 
can make them myself)?

Thanks in advance,
Brian Kunde
bku...@qtm.net
LECO Corp.

Automated Software Needed.

[Brian Kunde]

I am looking for recommendations for software to run an automated 
emissions scan in an anechoic chamber being able to control an HP8546A 
Receiver, Sunol turntable, and Sunol mast.  

I am also looking for software that will perform the radiated immunity 
test controlling a Marconi signal generator, an AR field probe/monitor, 
and an HP power meter.

Would appreciate any and all recommendations on software you have seen 
or used, good or bad.


Brian Kunde
LECO Corp.

Re: Australian Requirements

[Brian Kunde]

An additional method to obtain safety approval in Australia (if it is still 
allowed) and 
other countries that we did when I worked for Zenith Data Systems was to obtain 
a “CB” 
Test Report and Certificate based on the appropriate IEC version of the 
standard (for IT 
equipment it is IEC950).  We obtained this from NEMKO, but now I understand you 
can get 
CB RC in North America from UL, ETL, CSA, etc.  

The purpose of the “CB” scheme is so testing can be done at one lab and the 
test results 
would have to be excepted by other labs, though a review of the product may be 
requested.

For Australia,  we would send our CB RC to a company representative in 
Australia.  He 
would take it with any additional information to the proper authorities.  At 
this point 
I understand it is a paperwork thing and only takes a few weeks to obtain an 
approval.  

I believe this method is still used.  Maybe others could comment on their 
experience 
with using the CB scheme.

Brian Kunde
LECO Corp.