I have a copy of a CBEMA (Computer and Business Equipment Manufacturers' 
Association) report from 1977 that includes the complete development of the
CE and RE limits imposed by the FCC.  The limits are based purely on the
effect on a radio receiver.  I have myself verified that the limits are
well-placed in the conducted case.  I think any concern about measurement
accuracy should NOT be built into the limits.  The limits themselves contain
a lot of slop.  The limits are based on maintaining a particular
signal-to-noise ratio which in turn means a particular level of signal from
the broadcast station.  Also, different radios have different sensitivity
when receiving the same rf input, that is for the same rf input to the front
end, differing amounts of rfi cause the same amount of interference.  I have
myself verified this across a sample of over 30 radios with large variations
from sample to sample but the mean was exactly 48 dBuV, which is the
CBEMA-recommended and FCC mandated CE limit.  With  significant variation in
the response of individual protected victims, an excessive focus on minor
variations in the repeatability of measurements is unproductive and
misplaced emphasis.  Incidentally, several years ago I determined that the
response of these radios to common mode rfi was 20 dB more sensitive than to
differential mode rfi, because the storage capacitor in the radio's power
supply acts as a filter to dm conducted interference.  I proposed changing
CE limits and measurements to reflect this difference in sensitivity, but no
action was taken.

----------
>From: rehel...@mmm.com
>To: emc-p...@majordomo.ieee.org
>Subject: RE: EMI guard bands
>Date: Thu, Dec 20, 2001, 6:03 AM
>

>
> After listening to this thread, it brings up a question that I have had
> over the years regarding limit lines
> and passing margins.
>
> Are there "EMI guard bands" already built into the limit lines?
>
> I find it very difficult to believe that a group of reasonable people
> developing a limit line would have
> determined that they had thought of every possible EMI interference issue
> and would not have built a
> "safety margin" into that limit.
>
> Does anyone have any historical development data or insights into the
> creation of limits?
>
> Bob Heller
> 3M Product Safety, 76-1-01
> St. Paul, MN 55107-1208
> Tel:  651- 778-6336
> Fax:  651-778-6252
>
>
>
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