Yup, but......
        I tired pointing out to one of the RBOC's that there reliance on
OSHA NRTL was horribly inadequate because most of them - maybe all of them
had nothing in the scope of accreditation that indicated the could do any of
the EMC tests. The key to any certification is what the scope of your
accreditation is. If you go out to the OSHA site and look at the NRTL scopes
you will see what I mean. Apparently, getting your name into the OSHA NRTL
site qualifies you to do anything and everything, no experience necessary.
Some of the OSHA NRTL's that I have seen probably can do a reasonable EMC
job, a couple I've seen were woefully adequate. (but doesn't matter because
they are NRTL's) As the ol' axiom goes "Garbage in Garbage out" The RBOC's
that ignore Nationally Recognized EMC Test labs, are doing themselves and us
a large disservice. They are not only nationally recognized by a US
govermental body but any country with a signed Mutual Recognition Agreement
(MRA), 
With EMC testing in the scope of accreditation they are internationally
recognized.
        But again, use the EMC lab you want and have your NRTL include the
data and wham-o - your done. (its Friday, I'm in a good mood, and no this
isn't quite as easy as I just made it sound)
Gary
        

                -----Original Message-----
                From:   Grant, Tania (Tania) [mailto:tgr...@lucent.com]
                Sent:   Friday, March 17, 2000 2:08 PM
                To:     'Naftali Shani'; 'Collins, Jeffrey'; 'Gary
McInturff'
                Cc:     'emc-p...@ieee.org'
                Subject:        RE: EMC, NEBS & NRTL's

                Gary and Company,

                You have a valid point, but incomplete historical data.
The reason OSHA
                "blesses" NRTLs is because the whole issue started because
the National
                Electrical Code used to state that the "appliances"
(everything is an
                appliance in the NEC!) placed into buildings be safety
approved by
                nationally recognized testing laboratories, such as
Underwriters
                Laboratories.    The NEC, as you well understand, does not
care about
                radiated emission limits.   Some time later an independent
east coast safety
                testing lab sued, or almost sued, OSHA/NEC that the specific
mention of the
                UL name was un-American, etc.   As a result, this offending
language was
                removed from the NEC, the National Recognized Testing
Laboratory achieved
                new status and, it seems, other (any) safety labs could now
"approve"
                appliances.    Well now, that did not sit too well with a
lot of labs or
                even OSHA.    The upshot was, safety labs were made to
submit their
                "expertise" to be blessed by OSHA as an NRTL.

                Now, if that same safety lab also happens to offer EMC
testing, it seems
                that this also falls into the NRTL umbrella.   I believe
that this is an
                incorrect premise.   Several UL offices also perform EMC
testing.   The east
                coast lab also performs safety (which is how they first got
NRTL listing)
                and EMC.   Thus, to my knowledge, there are at least two
labs that are NRTL
                and do both safety and EMC.    However, I am not aware that
any independent,
                EMC only test lab has gotten OSHA (which is only concerned
with safety) NRTL
                approval.

                The RBOCs, not realizing this fact, made a sweeping
statement that all
                testing had to be performed by an NRTL lab.   This
immediately cut out
                excellent independent EMC only testing labs.   This mess is
continuing
                because the RBOCs, very often, don't do their homework, but
assume many
                things.    Too bad.     

                To make a long story short, 
                Tania Grant,  tgr...@lucent.com <mailto:tgr...@lucent.com> 
                Lucent Technologies, Communications Applications Group


                ----------
                From:  Gary McInturff [SMTP:gmcintu...@telect.com]
                Sent:  Friday, March 17, 2000 8:57 AM
                To:  'Naftali Shani'; 'Collins, Jeffrey'
                Cc:  'emc-p...@ieee.org'
                Subject:  RE: EMC, NEBS & NRTL's


                    Still can be done at an independent site. The Lab I use,
ACME Testing,
                here in Washington has accreditation to at least the
radiated emissions
                portions of the GR-, I have to check on the susceptibility,
but I think so.
                Even if that were not true. I believe that if your "NRTL"
accepts the EMC
                data from the other lab they will include it in the overall
report. 
                    Now there is the dicey part. Many of the NRTL's have
their own EMC labs
                and may not want to loose the cash, and try reject the
independent lab's
                report. I would find that a really hard sell however,
because the NRTL labs
                undoubtedly carry accreditation through NIST for the EMC
portion, making any
                argument about competency of the "independent lab" a tough
sell.
                    At any rate I've never quite understood the
justification for not
                calling laboratories which are accredited through programs
set up by and
                through the FCC, as NRTLS'. The basic assumption I would
make is that the
                FCC knows a heck of a lot more about this aspect of testing
and
                accreditation than OSHA does. Heavy sigh!
                    Gary

                -----Original Message-----
                From: Naftali Shani [mailto:nsh...@nortelnetworks.com]
                Sent: Friday, March 17, 2000 6:05 AM
                To: 'Collins, Jeffrey'
                Cc: 'emc-p...@ieee.org'
                Subject: RE: EMC, NEBS & NRTL's



                        BM__MailDataJeffrey, the requirement that was for
NRTL lab (&
                Bellcore representative) for each section of GR-63 &
GR-1089, has been
                dropped. See section 3.1.2 in the BA-NEBS-R10.

                        However, FCC data/frequency range for radiated
emissions is
                insufficient: You should have data based on GR-1089
requirements &
                objectives (10 kHz to 10 GHz).

                        Regards,
                Naftali Shani, Nortel Networks, Dept. 0S45, MS 117/C1/M05 
                21 Richardson Side Road, Kanata, Ontario, Canada  K2K 2C1
                Voice +1.613.765.2505 (ESN 395) Fax +1.613.763.8091 (ESN
393) 
                E-mail:  <mailto:nsh...@nortelnetworks.com>
nsh...@nortelnetworks.com or
                <mailto:n...@ieee.org> n...@ieee.org 

                        -----Original Message----- 
                From:   Collins, Jeffrey [SMTP:jcoll...@ciena.com] 
                Sent:   Friday, March 17, 2000 4:57 AM 
                To:     'emc-p...@ieee.org' 
                Subject:        RE: EMC, NEBS & NRTL's 


                        Group, 


                        Can anyone confirm that the RBOC's, particularly
Bell Atlantic has
                agreed to 
                accept EMC FCC data from non NRTL's? 
                If this is true please provide any documentation to support
this. (You know 
                a customer is going to want to see it) 


                        Thanks in advance, 

                        Jeffrey Collins 
                MTS, Principal Compliance Engineer 
                Ciena Core Switching Division 
                jcoll...@ciena.com 
                www.ciena.com 


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