From: "geoffrey (g.g.) skanes" <[email protected]>
Sender: "geoffrey (g.g.) skanes" <[email protected]>
Message-Id:  <"10075 Thu Oct 10 10:48:12 1996"@bnr.ca> 
To: [email protected]
Subject:  re:dBmargin 

Cynthia:

With the absence of a stated tolerance on your test results, you owe it to
yourself and your customer to include a margin on top of the limit.
At the risk of overdesigning a product, anything in excess of 10 dB margin
is too much--I've found 6 dB is more manageable for radiated EMI and 3 dB for
conducted.

The reasons for margins:
- there's as much as an 8 dB variation from site to site on RE - the FCC
  accepts this as part of the NSA filing you do on your site without having
  to correct your measurement data
- unless you have the luxury of sample testing a large volume / low cost
  item (unlike myself), you don't have an opportunity to determine the
  statistical variation characteristics from one sample to the next.
  (The 80/80 rule in EN 55022 is somewhat impractical for large, distributed 
  telecom systems.)
- Measurement uncertainty - this is receiving alot of debate within many
  standards fora and committees - an entire workshop was dedicated to this
  topic in the last EMC symposium and for a very good reason: as a customer
  or a test house, you need to know what level of confidence exists in the
  measurement results, especially in view of the former discussion.

The former notwithstanding, you have no legal (IMHO, I'm not a lawyer)
obligation to meet the Part 15 limits with margin.  So, how do you
insist your customers include a margin?   Start with the arguments
above--there are so many reasons why a 0 dB pass in one test could
be a 3 dB pass or a 3 dB fail somehwere else.  Is the customer willing
to accept the risk of failure on a subsequent test (stop shipment or
even worse, recall/retrofit in the field)?

To ensure there's no bickering over 0.2 dB, establish the test criteria
prior to testing in a written contract/agreement.  It is your
responsibility to convince the customer why you think the margin is
necessary before you switch on the spectrum analyser.  If they still
don't buy the arguments you have two options: refuse to test, or, test 
and make very specific recommendations for improvements to attain the
desired margin with a clear risk statement if the improvements are not
incorporated.

Clear as mud!

Regards,
Geoff Skanes 
Nortel Technology

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