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 ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. 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To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson: pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org