Re: [PSES] construction machinery in USA
On Wed, 27 Aug 2014 19:20:03 +0900, T.Sato vef00...@nifty.ne.jp wrote: Actually I guess so, but couldn't find the fact and the rationale. I also sent an inquiry about this to FCC, but had no response at this time. Now, I had response from FCC OET. QUOTE Inquiry: These days, internal-combustion engine driven heavy machines such as cranes, excavators, etc. may have several microprocessors and other electronic circuits, and such machines may be used also in residential areas. Will such machines be covered by the FCC Rules, especially the Part 15? If such machines can be exempted, what is the rationale? I know of 47 CFR 15.103(a), but I think such movable machines may not transportation vehicle, and even if such machinery can be categorized as transportation vehicle, I think KDB 892282 suggests that such machines will not be exempted. And if engine driven machines can be exempted, what about electric motor driven machines which may or may not powered from the mains? I am not thinking of the machines which have radio transmitters. FCC response You are correct, heavy machines, such as cranes, excavators are not designed for the purpose of transporting items or people,. The digital logic within the equipment, does not qualify as transportation vehicles for the 15.103 exemption. This equipment when transported is transported by other transport vehicles (trucks) between locations where they are temporally stationed for a period of time for their purpose to perform other specific task. In addition (in the case of cranes) could be connected to the power mains, which also disqualifies the equipment. In most cases the large Heavy machines would be used beyond 200 feet of a residential area and can be considered Class A. Manufactures should note that independent of exemptions or Class A or B, all Part 15 equipment is subject to the general conditions of operation in 15.5 and 15.29 which would require the equipment to be turned off in case of any interference issues. /QUOTE Regards, Tom -- Tomonori Sato vef00...@nifty.ne.jp URL: http://homepage3.nifty.com/tsato/ - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] construction machinery in USA
On Wed, 27 Aug 2014 00:26:23 +, Ted Eckert ted.eck...@microsoft.com wrote: The FCC is generally not concerned with unintentional emissions from construction machinery. The general assumption is that a susceptible receiver would not be operating in close proximity to the construction equipment. It may no longer be a correct assumption, but that is the basis. It will likely be true in some cases. I can't imagine a Caterpillar 797 operating in a residential area. However, smaller pieces of machinery might be used closer to susceptible receivers. The rules have not kept up with technology and they are based on a time when the most significant ignition source in a vehicle was the distributor and when digital electronics did not exist in construction equipment. Actually I guess so, but couldn't find the fact and the rationale. I also sent an inquiry about this to FCC, but had no response at this time. The general assumption is that a susceptible receiver would not be operating in close proximity to the construction equipment. It may no longer be a corre ct assumption, but that is the basis. It will likely be true in some cases. I can't imagine a Caterpillar 797 operating in a residential area. However, smal ler pieces of machinery might be used closer to susceptible receivers. The rul es have not kept up with technology and they are based on a time when the most significant ignition source in a vehicle was the distributor and when digital electronics did not exist in construction equipment. Well, in the good old days, heavy machines were driven by diesel engines with no ECU, those arms were driven by oil pressure through manual valves and they usually don't have any electronic circuit, so I risk of EMC problems should negligible. However, these days, heavy machines may be equipped with electric/ electronic circuit including microprocessors, control circuits, inverter driven electric motors, sensors, etc., which can cause electromagnetic emission/immunity problems. Also, such heavy machines (smaller ones, if not Caterpillar 797!) may be used also in/near residential areas. General vehicles are still explicitly exempted by 47 CFR 15.103(a) and industrial machines are usually exempted by 47 CFR 15.103(b), but I couldn't find any exemption applicable to heavy machines in general. This raise me the question. That being said, I'm not an expert in automotive EMC and I encourage anybody with better information to amend or correct what I have stated. (I would also like to know how you would run testing on a Caterpillar 797. I don't think it would fit in many chambers.) If international standards are accepted, I think we can measure those emissions with CISPR 12 test method. Regards, Tom -- Tomonori Sato vef00...@nifty.ne.jp URL: http://homepage3.nifty.com/tsato/ - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] construction machinery in USA
A sidebar here. FCC Rules also exempt A digital device utilized exclusively in an appliance, e.g., microwave oven, dishwasher, clothes dryer, air conditioner (central or window), etc.. These devices not only can be operated but are expected to be operated in residential areas. Rules don't always make sense. Jim Hulbert -Original Message- From: T.Sato [mailto:vef00...@nifty.ne.jp] Sent: Wednesday, August 27, 2014 6:20 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA On Wed, 27 Aug 2014 00:26:23 +, Ted Eckert ted.eck...@microsoft.com wrote: The FCC is generally not concerned with unintentional emissions from construction machinery. The general assumption is that a susceptible receiver would not be operating in close proximity to the construction equipment. It may no longer be a correct assumption, but that is the basis. It will likely be true in some cases. I can't imagine a Caterpillar 797 operating in a residential area. However, smaller pieces of machinery might be used closer to susceptible receivers. The rules have not kept up with technology and they are based on a time when the most significant ignition source in a vehicle was the distributor and when digital electronics did not exist in construction equipment. Actually I guess so, but couldn't find the fact and the rationale. I also sent an inquiry about this to FCC, but had no response at this time. The general assumption is that a susceptible receiver would not be operating in close proximity to the construction equipment. It may no longer be a corre ct assumption, but that is the basis. It will likely be true in some cases. I can't imagine a Caterpillar 797 operating in a residential area. However, smal ler pieces of machinery might be used closer to susceptible receivers. The rul es have not kept up with technology and they are based on a time when the most significant ignition source in a vehicle was the distributor and when digital electronics did not exist in construction equipment. Well, in the good old days, heavy machines were driven by diesel engines with no ECU, those arms were driven by oil pressure through manual valves and they usually don't have any electronic circuit, so I risk of EMC problems should negligible. However, these days, heavy machines may be equipped with electric/ electronic circuit including microprocessors, control circuits, inverter driven electric motors, sensors, etc., which can cause electromagnetic emission/immunity problems. Also, such heavy machines (smaller ones, if not Caterpillar 797!) may be used also in/near residential areas. General vehicles are still explicitly exempted by 47 CFR 15.103(a) and industrial machines are usually exempted by 47 CFR 15.103(b), but I couldn't find any exemption applicable to heavy machines in general. This raise me the question. That being said, I'm not an expert in automotive EMC and I encourage anybody with better information to amend or correct what I have stated. (I would also like to know how you would run testing on a Caterpillar 797. I don't think it would fit in many chambers.) If international standards are accepted, I think we can measure those emissions with CISPR 12 test method. Regards, Tom -- Tomonori Sato vef00...@nifty.ne.jp URL: http://homepage3.nifty.com/tsato/ - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org
Re: [PSES] construction machinery in USA
The rules made sense when they were drafted. Forty years ago, a dishwasher wouldn't have digital electronics and it would be unlikely to cause interference in receivers located more than a few meters away. The same dishwasher would be very loud during operation and you wouldn't be able to listen to the radio or TV in the kitchen where that dishwasher was operating. This was the rationale for many home appliances. The rules just haven't kept up with the changes. We now have appliances full of digital electronics and they make very little acoustic noise when operating. However, unless there are a lot of complaints to the FCC, the rules likely won't change. The United States has a history where people in denser residential environments, where you are more likely to be affected by a neighbor's appliance, are in larger cities where most commercial radio and television transmitters have stronger signals. In areas with fringe reception, people historically lived in single family housing that was spread out. The risk of being affected adversely by somebody else's appliance was lower. If my understanding of history is correct, we may even have the existence of the 2.4 GHz ISM band due to radiated emissions from microwave ovens. They operate at 2.4 GHz, and the early versions were a bit leaky. I've heard that this frequency was so polluted with noise in residential environments that it wasn't adopted by anybody for a specific purpose leaving it open to ISM applications. Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. -Original Message- From: Jim Hulbert [mailto:jim.hulb...@pb.com] Sent: Wednesday, August 27, 2014 4:59 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA A sidebar here. FCC Rules also exempt A digital device utilized exclusively in an appliance, e.g., microwave oven, dishwasher, clothes dryer, air conditioner (central or window), etc.. These devices not only can be operated but are expected to be operated in residential areas. Rules don't always make sense. Jim Hulbert -Original Message- From: T.Sato [mailto:vef00...@nifty.ne.jp] Sent: Wednesday, August 27, 2014 6:20 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA On Wed, 27 Aug 2014 00:26:23 +, Ted Eckert ted.eck...@microsoft.com wrote: The FCC is generally not concerned with unintentional emissions from construction machinery. The general assumption is that a susceptible receiver would not be operating in close proximity to the construction equipment. It may no longer be a correct assumption, but that is the basis. It will likely be true in some cases. I can't imagine a Caterpillar 797 operating in a residential area. However, smaller pieces of machinery might be used closer to susceptible receivers. The rules have not kept up with technology and they are based on a time when the most significant ignition source in a vehicle was the distributor and when digital electronics did not exist in construction equipment. Actually I guess so, but couldn't find the fact and the rationale. I also sent an inquiry about this to FCC, but had no response at this time. The general assumption is that a susceptible receiver would not be operating in close proximity to the construction equipment. It may no longer be a corre ct assumption, but that is the basis. It will likely be true in some cases. I can't imagine a Caterpillar 797 operating in a residential area. However, smal ler pieces of machinery might be used closer to susceptible receivers. The rul es have not kept up with technology and they are based on a time when the most significant ignition source in a vehicle was the distributor and when digital electronics did not exist in construction equipment. Well, in the good old days, heavy machines were driven by diesel engines with no ECU, those arms were driven by oil pressure through manual valves and they usually don't have any electronic circuit, so I risk of EMC problems should negligible. However, these days, heavy machines may be equipped with electric/ electronic circuit including microprocessors, control circuits, inverter driven electric motors, sensors, etc., which can cause electromagnetic emission/immunity problems. Also, such heavy machines (smaller ones, if not Caterpillar 797!) may be used also in/near residential areas. General vehicles are still explicitly exempted by 47 CFR 15.103(a) and industrial machines are usually exempted by 47 CFR 15.103(b), but I couldn't find any exemption applicable to heavy machines in general. This raise me the question. That being said, I'm not an expert in automotive EMC and I encourage anybody with better information to amend or correct what I have stated. (I would also like to know how you would run testing
Re: [PSES] construction machinery in USA
In message 90cb2e2117c14d10b8f8804eeb696...@bl2pr03mb372.namprd03.prod.outlook.com , dated Wed, 27 Aug 2014, Ted Eckert ted.eck...@microsoft.com writes: If my understanding of history is correct, we may even have the existence of the 2.4 GHz ISM band due to radiated emissions from microwave ovens. They operate at 2.4 GHz, and the early versions were a bit leaky. I've heard that this frequency was so polluted with noise in residential environments that it wasn't adopted by anybody for a specific purpose leaving it open to ISM applications. Microwave ovens are classified as ISM, because the definition of ISM really has nothing to do with 'industrial scientific and medical' but a great deal to do with 'the intentional use of radio-frequency energy'. Another case of failure to predict the future; when 'ISM' was invented, no-one thought that a 1 kW 2.4 GHz (potential) transmitter would be in nearly every home. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] construction machinery in USA
I'm guessing most people wouldn't even know to complain these days if theirs or their neighbors dishwasher started interfering with their TV or radio. And TV's with their cable/internet/satellite connections and FM/satellite radios are a lot more immune to that stuff as well than 40 years ago. So I wouldn't be surprised if the rules don't change either. Bigger fish to fry as they say. -Dave -Original Message- From: Ted Eckert [mailto:ted.eck...@microsoft.com] Sent: Wednesday, August 27, 2014 9:14 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA The rules made sense when they were drafted. Forty years ago, a dishwasher wouldn't have digital electronics and it would be unlikely to cause interference in receivers located more than a few meters away. The same dishwasher would be very loud during operation and you wouldn't be able to listen to the radio or TV in the kitchen where that dishwasher was operating. This was the rationale for many home appliances. The rules just haven't kept up with the changes. We now have appliances full of digital electronics and they make very little acoustic noise when operating. However, unless there are a lot of complaints to the FCC, the rules likely won't change. The United States has a history where people in denser residential environments, where you are more likely to be affected by a neighbor's appliance, are in larger cities where most commercial radio and television transmitters have stronger signals. In areas with fringe reception, people historically lived in single family housing that was spread out. The risk of being affected adversely by somebody else's appliance was lower. If my understanding of history is correct, we may even have the existence of the 2.4 GHz ISM band due to radiated emissions from microwave ovens. They operate at 2.4 GHz, and the early versions were a bit leaky. I've heard that this frequency was so polluted with noise in residential environments that it wasn't adopted by anybody for a specific purpose leaving it open to ISM applications. Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. -Original Message- From: Jim Hulbert [mailto:jim.hulb...@pb.com] Sent: Wednesday, August 27, 2014 4:59 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA A sidebar here. FCC Rules also exempt A digital device utilized exclusively in an appliance, e.g., microwave oven, dishwasher, clothes dryer, air conditioner (central or window), etc.. These devices not only can be operated but are expected to be operated in residential areas. Rules don't always make sense. Jim Hulbert -Original Message- From: T.Sato [mailto:vef00...@nifty.ne.jp] Sent: Wednesday, August 27, 2014 6:20 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA On Wed, 27 Aug 2014 00:26:23 +, Ted Eckert ted.eck...@microsoft.com wrote: The FCC is generally not concerned with unintentional emissions from construction machinery. The general assumption is that a susceptible receiver would not be operating in close proximity to the construction equipment. It may no longer be a correct assumption, but that is the basis. It will likely be true in some cases. I can't imagine a Caterpillar 797 operating in a residential area. However, smaller pieces of machinery might be used closer to susceptible receivers. The rules have not kept up with technology and they are based on a time when the most significant ignition source in a vehicle was the distributor and when digital electronics did not exist in construction equipment. Actually I guess so, but couldn't find the fact and the rationale. I also sent an inquiry about this to FCC, but had no response at this time. The general assumption is that a susceptible receiver would not be operating in close proximity to the construction equipment. It may no longer be a corre ct assumption, but that is the basis. It will likely be true in some cases. I can't imagine a Caterpillar 797 operating in a residential area. However, smal ler pieces of machinery might be used closer to susceptible receivers. The rul es have not kept up with technology and they are based on a time when the most significant ignition source in a vehicle was the distributor and when digital electronics did not exist in construction equipment. Well, in the good old days, heavy machines were driven by diesel engines with no ECU, those arms were driven by oil pressure through manual valves and they usually don't have any electronic circuit, so I risk of EMC problems should negligible. However, these days, heavy machines may be equipped with electric/ electronic circuit including microprocessors, control circuits, inverter driven electric motors, sensors, etc., which can
Re: [PSES] construction machinery in USA
Though the home appliance industry has had their issues in the past, I can testify this is no longer the case. I work within a few miles of the headquarters of one of the largest home appliance manufacturers in the world. I've worked with their EMC department in a cooperative effort for over thirty years and I must say they take EMC very seriously. This market is so competitive and their service and customer complaint records are often public knowledge, so any major EMC issue could be quite damaging. They have a very well equipped and well staffed EMC department. They'll even send products to our lab for conformation testing. Also consider, that their stoves and ovens are required to pass the immunity tests for safety approval by UL. Most such companies are designing for a worldwide market anyway so emissions and immunity testing is a common design requirement even in markets where is it not required. I don't know specifically the legal requirements for construction equipment but our EMC lab has tested such equipment in the past; for instance we performed class A emissions testing on an electronic laser level. A friend of mine used to work for Case Tractor in Joliet performing Immunity test on tractors and combines. Didn't want the variable speed AC blower motor to interfere with the 12 speaker surround sound stereo system. I believe there are safety reasons to perform emc testing as well. The Other Brian -Original Message- From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] Sent: Wednesday, August 27, 2014 10:05 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA I'm guessing most people wouldn't even know to complain these days if theirs or their neighbors dishwasher started interfering with their TV or radio. And TV's with their cable/internet/satellite connections and FM/satellite radios are a lot more immune to that stuff as well than 40 years ago. So I wouldn't be surprised if the rules don't change either. Bigger fish to fry as they say. -Dave -Original Message- From: Ted Eckert [mailto:ted.eck...@microsoft.com] Sent: Wednesday, August 27, 2014 9:14 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA The rules made sense when they were drafted. Forty years ago, a dishwasher wouldn't have digital electronics and it would be unlikely to cause interference in receivers located more than a few meters away. The same dishwasher would be very loud during operation and you wouldn't be able to listen to the radio or TV in the kitchen where that dishwasher was operating. This was the rationale for many home appliances. The rules just haven't kept up with the changes. We now have appliances full of digital electronics and they make very little acoustic noise when operating. However, unless there are a lot of complaints to the FCC, the rules likely won't change. The United States has a history where people in denser residential environments, where you are more likely to be affected by a neighbor's appliance, are in larger cities where most commercial radio and television transmitters have stronger signals. In areas with fringe reception, people historically lived in single family housing that was spread out. The risk of being affected adversely by somebody else's appliance was lower. If my understanding of history is correct, we may even have the existence of the 2.4 GHz ISM band due to radiated emissions from microwave ovens. They operate at 2.4 GHz, and the early versions were a bit leaky. I've heard that this frequency was so polluted with noise in residential environments that it wasn't adopted by anybody for a specific purpose leaving it open to ISM applications. Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. -Original Message- From: Jim Hulbert [mailto:jim.hulb...@pb.com] Sent: Wednesday, August 27, 2014 4:59 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA A sidebar here. FCC Rules also exempt A digital device utilized exclusively in an appliance, e.g., microwave oven, dishwasher, clothes dryer, air conditioner (central or window), etc.. These devices not only can be operated but are expected to be operated in residential areas. Rules don't always make sense. Jim Hulbert -Original Message- From: T.Sato [mailto:vef00...@nifty.ne.jp] Sent: Wednesday, August 27, 2014 6:20 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA On Wed, 27 Aug 2014 00:26:23 +, Ted Eckert ted.eck...@microsoft.com wrote: The FCC is generally not concerned with unintentional emissions from construction machinery. The general assumption is that a susceptible receiver would not be operating in close proximity to the construction equipment. It may no longer be a correct
Re: [PSES] construction machinery in USA
Brian brings up some good points and I would like to thank him for correcting and amending my original statements. I would like to think that industrial equipment wouldn't malfunction due to electromagnetic noise. I would hate to think what the Bagger 288 could do if its control systems went awry. Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. -Original Message- From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Wednesday, August 27, 2014 10:23 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA Though the home appliance industry has had their issues in the past, I can testify this is no longer the case. I work within a few miles of the headquarters of one of the largest home appliance manufacturers in the world. I've worked with their EMC department in a cooperative effort for over thirty years and I must say they take EMC very seriously. This market is so competitive and their service and customer complaint records are often public knowledge, so any major EMC issue could be quite damaging. They have a very well equipped and well staffed EMC department. They'll even send products to our lab for conformation testing. Also consider, that their stoves and ovens are required to pass the immunity tests for safety approval by UL. Most such companies are designing for a worldwide market anyway so emissions and immunity testing is a common design requirement even in markets where is it not required. I don't know specifically the legal requirements for construction equipment but our EMC lab has tested such equipment in the past; for instance we performed class A emissions testing on an electronic laser level. A friend of mine used to work for Case Tractor in Joliet performing Immunity test on tractors and combines. Didn't want the variable speed AC blower motor to interfere with the 12 speaker surround sound stereo system. I believe there are safety reasons to perform emc testing as well. The Other Brian -Original Message- From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] Sent: Wednesday, August 27, 2014 10:05 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA I'm guessing most people wouldn't even know to complain these days if theirs or their neighbors dishwasher started interfering with their TV or radio. And TV's with their cable/internet/satellite connections and FM/satellite radios are a lot more immune to that stuff as well than 40 years ago. So I wouldn't be surprised if the rules don't change either. Bigger fish to fry as they say. -Dave -Original Message- From: Ted Eckert [mailto:ted.eck...@microsoft.com] Sent: Wednesday, August 27, 2014 9:14 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA The rules made sense when they were drafted. Forty years ago, a dishwasher wouldn't have digital electronics and it would be unlikely to cause interference in receivers located more than a few meters away. The same dishwasher would be very loud during operation and you wouldn't be able to listen to the radio or TV in the kitchen where that dishwasher was operating. This was the rationale for many home appliances. The rules just haven't kept up with the changes. We now have appliances full of digital electronics and they make very little acoustic noise when operating. However, unless there are a lot of complaints to the FCC, the rules likely won't change. The United States has a history where people in denser residential environments, where you are more likely to be affected by a neighbor's appliance, are in larger cities where most commercial radio and television transmitters have stronger signals. In areas with fringe reception, people historically lived in single family housing that was spread out. The risk of being affected adversely by somebody else's appliance was lower. If my understanding of history is correct, we may even have the existence of the 2.4 GHz ISM band due to radiated emissions from microwave ovens. They operate at 2.4 GHz, and the early versions were a bit leaky. I've heard that this frequency was so polluted with noise in residential environments that it wasn't adopted by anybody for a specific purpose leaving it open to ISM applications. Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. -Original Message- From: Jim Hulbert [mailto:jim.hulb...@pb.com] Sent: Wednesday, August 27, 2014 4:59 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA A sidebar here. FCC Rules also exempt A digital device utilized exclusively in an appliance, e.g., microwave oven, dishwasher, clothes dryer, air conditioner (central or window), etc
Re: [PSES] construction machinery in USA
In message 00381d375d464f42b729f8999d3ff...@bl2pr03mb372.namprd03.prod.outlook.com , dated Wed, 27 Aug 2014, Ted Eckert ted.eck...@microsoft.com writes: Brian brings up some good points and I would like to thank him for correcting and amending my original statements. I would like to think that industrial equipment wouldn't malfunction due to electromagnetic noise. I would hate to think what the Bagger 288 could do if its control systems went awry. This is the real danger in not updating requirements until 'something happens'. If what happens is '50 dead', many other things will happen as a result. The FCC administration should ponder on that. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] construction machinery in USA
After reading this thread, am not certain why functional safety and EMC safety would not apply to heavy equipment for U.S. The FCC's scope exception is for transportation vehicles. The Bagger 288 is a magnificent machine, but 'transport' vehicle is certainly not among its incredible capabilities. EMC safety for both industrial and personal machinery in the U.S. has been overtly stated by adjudication, and is directly implied for the corporation by OHSA workplace safety requirements. Brian -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Wednesday, August 27, 2014 12:46 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA In message 00381d375d464f42b729f8999d3ff...@bl2pr03mb372.namprd03.prod.outlook.com , dated Wed, 27 Aug 2014, Ted Eckert ted.eck...@microsoft.com writes: Brian brings up some good points and I would like to thank him for correcting and amending my original statements. I would like to think that industrial equipment wouldn't malfunction due to electromagnetic noise. I would hate to think what the Bagger 288 could do if its control systems went awry. This is the real danger in not updating requirements until 'something happens'. If what happens is '50 dead', many other things will happen as a result. The FCC administration should ponder on that. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] construction machinery in USA
On 8/27/2014 7:58 AM, Jim Hulbert wrote: A sidebar here. FCC Rules also exempt A digital device utilized exclusively in an appliance, e.g., microwave oven, dishwasher, clothes dryer, air conditioner (central or window), etc.. These devices not only can be operated but are expected to be operated in residential areas. Rules don't always make sense. Jim Hulbert More accurately and completely, /§ 15.103 Exempted devices.// //The following devices are subject only to the general conditions of operation in §§ 15.5 and 15.29 and are exempt from the specific technical standards //and other requirements contained in this part. The operator of the exempted device shall be required to stop operating the device upon a finding by the //Commission or its representative that ... // § 15.5 General conditions of operation. (b) Operation of an intentional, unintentional, or incidental radiator is subject to the conditions that no harmful interference is caused and that interference must be accepted... / /§ 15.21 Information to user.// //... caution the user that changes or modifications not expressly approved by the party responsible for compliance could void the user's authority to operate the equipment./ The Commission or its representative may sometimes be less than easy to get to make the finding, however. http://www.arrl.org/arrlletter%3Fissue%3D2006-04-07 FWIW department: telco's exempt so long as equipment was inside central offices or on telephone company property found themselves having to scramble some years ago, when they moved it into residential-area cabinets and pedestals, or onto poles and messenger-wires. They did learn, eventually. I don't have a T-shirt, exactly, but I remember having to convince my then-employer that our gear had to meet FCC Class B even if WAS outside a dwelling. Lawyering loses to physics! Cortland - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] construction machinery in USA
The FCC is generally not concerned with unintentional emissions from construction machinery. The general assumption is that a susceptible receiver would not be operating in close proximity to the construction equipment. It may no longer be a correct assumption, but that is the basis. It will likely be true in some cases. I can't imagine a Caterpillar 797 operating in a residential area. However, smaller pieces of machinery might be used closer to susceptible receivers. The rules have not kept up with technology and they are based on a time when the most significant ignition source in a vehicle was the distributor and when digital electronics did not exist in construction equipment. That being said, I'm not an expert in automotive EMC and I encourage anybody with better information to amend or correct what I have stated. (I would also like to know how you would run testing on a Caterpillar 797. I don't think it would fit in many chambers.) Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.commailto:ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. -Original Message- From: T.Sato [mailto:vef00...@nifty.ne.jp] Sent: Tuesday, August 26, 2014 3:48 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] construction machinery in USA Dear experts, In USA, are there any regulatory EMC requirements for construction machinery (heavy machinery in general) such as crane, backhoe, etc.? For FCC, 47 CFR 15.103(a) says that digital devices utilized exclusively in transportation vehicle are exempted, but FCC OET says The exemption is only intended for digital devices which operate primarily when the vehicle is operating in a mobile environment such as on a road or highway where the potential for interference is low (KDB 892282) and I guessed that construction machinery would not covered by the exemption (i.e., may be covered by 47 CFR 15) even if the machinery can run on road. I also guessed that OSHA (or somebody else) may say something for electromagnetic immunity of such machinery as those malfunction can cause injury or death, but could find nothing about such requirements. Regards, Tom -- Tomonori Sato vef00...@nifty.ne.jpmailto:vef00...@nifty.ne.jp URL: http://homepage3.nifty.com/tsato/ - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald: dhe...@gmail.commailto:dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] construction machinery in USA
Our large mail and parcels processing equipment doesn't fit in any chamber either, and it doesn't have wheels. Just have to do it the old fashioned way and bring the portable equipment to the Cat. At least it can be driven to an open field for evaluation. -Dave From: Ted Eckert [mailto:ted.eck...@microsoft.com] Sent: Tuesday, August 26, 2014 8:26 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] construction machinery in USA The FCC is generally not concerned with unintentional emissions from construction machinery. The general assumption is that a susceptible receiver would not be operating in close proximity to the construction equipment. It may no longer be a correct assumption, but that is the basis. It will likely be true in some cases. I can't imagine a Caterpillar 797 operating in a residential area. However, smaller pieces of machinery might be used closer to susceptible receivers. The rules have not kept up with technology and they are based on a time when the most significant ignition source in a vehicle was the distributor and when digital electronics did not exist in construction equipment. That being said, I'm not an expert in automotive EMC and I encourage anybody with better information to amend or correct what I have stated. (I would also like to know how you would run testing on a Caterpillar 797. I don't think it would fit in many chambers.) Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.commailto:ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. -Original Message- From: T.Sato [mailto:vef00...@nifty.ne.jp] Sent: Tuesday, August 26, 2014 3:48 PM To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] construction machinery in USA Dear experts, In USA, are there any regulatory EMC requirements for construction machinery (heavy machinery in general) such as crane, backhoe, etc.? For FCC, 47 CFR 15.103(a) says that digital devices utilized exclusively in transportation vehicle are exempted, but FCC OET says The exemption is only intended for digital devices which operate primarily when the vehicle is operating in a mobile environment such as on a road or highway where the potential for interference is low (KDB 892282) and I guessed that construction machinery would not covered by the exemption (i.e., may be covered by 47 CFR 15) even if the machinery can run on road. I also guessed that OSHA (or somebody else) may say something for electromagnetic immunity of such machinery as those malfunction can cause injury or death, but could find nothing about such requirements. Regards, Tom -- Tomonori Sato vef00...@nifty.ne.jpmailto:vef00...@nifty.ne.jp URL: http://homepage3.nifty.com/tsato/ - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald: dhe...@gmail.commailto:dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://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 emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto:dhe...@gmail.com
Re: [PSES] construction machinery in USA
In message 510d85f1c3014e06aded907581717...@bl2pr03mb372.namprd03.prod.outlook.com , dated Wed, 27 Aug 2014, Ted Eckert ted.eck...@microsoft.com writes: (I would also like to know how you would run testing on a Caterpillar 797. I don?t think it would fit in many chambers.) Indeed, but there are a few which can accommodate objects like a main battle tank and some aircraft. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
