Gert, thanks for your reply.  I appreciate your reasoning on this matter as
I have just been thought similar reasoning on a standard I am working on,
IEC 60601-1-2, EMC for Medical electrical equipment.  The group responsible
for writing IEC 61000-3-2, IEC SC 77A WG 1, has agreed with our
interpretation of  "public low voltage distribution systems", that is, it is
the same as CISPR 11 Class A environment, "Class A equipment is equipment
suitable for use in all establishments other than domestic and those
directly connected to a low voltage power supply network which supplies
buildings used for domestic purposes."  However, as you mentioned, these
standard are subject to change and my understanding is that both harmonics
and flicker requirements will apply to all environments in the future.  I
hope this helps.

Jim


Jim Conrad
P.O. Box 25
Hamilton, MA 01936-0025
USA

[email protected]
Phone #:  978-468-3909
FAX #:     978-468-3909


-----Original Message-----
From:   CE-test - Ing. Gert Gremmen - ce-marking and more...
[mailto:[email protected]]
Sent:   Monday, December 04, 2000 1:18 PM
To:     Jim Conrad; [email protected]; [email protected]
Subject:        RE: EN 61000-3-3 Flicker Tests

 << File: Gert Gremmen.vcf >>
be careful Jim,

In Europe one harmonic standard has no power to exclude
the requirements of another harmonic standard that is applicable to the
apparatus.
Especially those of EN 61000-3-2 and 61000-3-3  !!
The target of the EMC-directive is covering all essential EMC requirements:

-Low frequency
-High frequency
-Radiated
-Conducted
for
-Emission
-Immunity
and the permutations of the above.
This does not mean that testing is required; you just sign for
compliance. Any proof of compliance, even reasoning may be sufficient.
In some cases you will need the opinion of a third party (CB).

As some harmonized standards (55011) are older than these requirements, some
incompatible statements may occur. These will be ruled out slowly when newer
versions
of the standard appear. Normally every standard will be updated once every 4
years.

Be especially careful with all exceptions and notes in standards that
for some (not) obvious reason try to exclude certain categories of
equipment from some difficult to meet requirements IF a such-and-so-note
is printed on the equipment. These have no value in Europe for ce marking.

Basically most Class A (EN 55022 and 55011) are not easy to be sold in
Europe due to the very strict definition of heavy industrial environment.

In fact, if there is no very stringent (functional) reason why an equipment
cannot meet
Class B emissions, it should. No clauses allowed !!!!

Regards,

Gert Gremmen, (Ing)

ce-test, qualified testing

===============================================
Web presence  http://www.cetest.nl
CE-shop http://www.cetest.nl/ce_shop.htm
/-/ Compliance testing is our core business /-/
===============================================


>>-----Original Message-----
>>From: [email protected] [mailto:[email protected]]On Behalf
>>Of Jim Conrad
>>Sent: Monday, December 04, 2000 3:17 PM
>>To: [email protected]; [email protected]
>>Subject: RE: EN 61000-3-3 Flicker Tests
>>
>>
>>
>>Hi Bruce,
>>
>>Your customer is correct.  If the device is classified as a Class A
>>(according to CISPR 11), you do not need to comply with flicker
>>requirements.
>>
>>Jim
>>
>>
>>Jim Conrad
>>P.O. Box 25
>>Hamilton, MA 01936-0025
>>USA
>>
>>[email protected]
>>Phone #:  978-468-3909
>>FAX #:     978-468-3909
>>
>>
>>-----Original Message-----
>>From: [email protected] [mailto:[email protected]] On
>>Behalf Of
>>[email protected]
>>Sent: Sunday, December 03, 2000 6:04 PM
>>To:   [email protected]
>>Subject:      EN 61000-3-3 Flicker Tests
>>
>>
>>Hello group!
>>
>>I've got a customer in our EMC lab that makes a laboratory instrument
>>incorporating heaters with a typical 3-4 amp input current at 230vac.  He
>>is failing the flicker test due to the design of the heater control.  They
>>are undertaking a redesign but would like to keep selling product in the
>>interim.
>>
>>They have come up with an interesting interpretation of the scope of EN
>>61000-3-3:  the standard specifies that the tests are applicable to
>>products connected to the "public low voltage distribution
>>systems"  but if
>>you take a typical industrial location or even a typical commercial
>>location, isn't it true that these locations are fed by a dedicated
>>transformer at the building that isolates them from the public network?  I
>>guess the question becomes - what is considered the public network?  What
>>if the marketing of the product was restricted to "industrial" locations?
>>
>>My initial reaction to the question was that anyplace you can plug or wire
>>into at typical 230vac is considered the "public network", especially
>>considering the mixed residential / commercial buildings common in Europe.
>>
>>Anyone care to comment?
>>
>>Bruce Fagley
>>Sr. Specialist, EMC
>>Industrial Products
>>TUV Rheinland
>>12 Commerce Rd.
>>Newtown CT. 06470
>>203-426-0888 ext 119
>>203-426-4009 fax
>>
>>
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>>
>>-------------------------------------------
>>This message is from the IEEE EMC Society Product Safety
>>Technical Committee emc-pstc discussion list.
>>
>>To cancel your subscription, send mail to:
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>>with the single line:
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>>
>>For policy questions, send mail to:
>>     Richard Nute:           [email protected]
>>
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