The question of ethics or morality is at the heart of this discussion which
makes it much more important than technical discussions about
electromagnetism, which is the ONLY reason I have pursued this so far.  I
was critical of the IEE safety guide on MORAL grounds.  It is part of the
morality which says that businessmen or producers are considered guilty
until proven innocent because of what they are - profit-making producers.
That it is immoral to make a profit and anyone doing so is taking advantage
of someone else.  This is not the morality which built the USA into the
world's wealthiest nation, but it is the morality which will reduce us to
the most impecunious.  The strict Muslim countries that have been in the
news of late forbid loaning of money at interest, because the Koran forbids
usury.  It is no accident that these countries all belong to the third
world.  Progress depends on the ability to raise capital.  The most
efficient way to do that is for people who have profited from past ventures
to invest those profits in new ventures.  That is what banks facilitate.  If
there are no profits, then there is no money to borrow and to start a
venture and progress stops or becomes agonizingly slow.   A policy which
says that producers are liable for unlimited damages without needing to show
defect or negligence is on a moral level with the prohibition of lending
money at interest.  We have to decide if we wish to live in a civilized
world or not.  That is a question of moral significance.

The idea that businessmen are immoral greedy people who give no thought to
the quality of their products is an ugly lie spread by enemies of
capitalism.  A little thought will show that businessmen who operate like
this do not stay in business long because their products get a bad
reputation.  Certainly you can find examples of bad or ignorant behavior.
Does this justify policies which assume all businessmen are evil and that
they must be reined in by pure-hearted regulators?  What makes the
regulators pure-hearted?  That they don't make profit, but siphon profits
away?  What is the cost of the regulation relative to the benefit?  What
marvelous inventions didn't occur because the seed money necessary to
initiate a development wasn't there?

When engineers make false claims that unintentional RE from ITE can cause
safety-critical circuits to fail catastrophically, we engage in another
moral transgression.  We attempt to get a short term gain at the cost of
long  term loss.  The short term gain is to make ourselves and our
profession look more important.  But the long term loss is that of the
little boy who cried wolf.  After a long enough period of false alarms, we
will lose the respect and ear of management and if we must raise a REAL
issue, it will fall on deaf ears.  I have no way of knowing, but I wonder
how many unfulfilled warnings the managers who OK'd the launch of 51L
(Challenger) had listened to prior to making their fateful decision.

on 1/6/02 10:24 AM, cherryclo...@aol.com at cherryclo...@aol.com wrote:

Dear John 
The incubator I described was already on the EU market in the latter half of
the 1990s, when I helped to test and fix it.

And I'm sorry to disappoint but I have already experienced several similar
examples I could quote, such as the electric blanket that would change its
heat settings randomly when a bedside light was switched on or off, or from
other low-level mains transients.
This is a potentially fatal issue for certain kinds of invalid, or people
who are blind drunk (surely no person reading this would ever be in such a
state) ­ and by the way, this is not me being emotive again, it was the
expressed concern of the manufacturer and one of the reasons why they called
me in. They sacked their Technical Director over this incident.
They also didn't do a product recall despite having an estimated 100,000
products with the problem already out in the field. Of course, as a
responsible engineer (and to cover my ass) I wrote them a letter
recommending that they did a product recall (while thinking of the designers
of the Challenger Space Shuttle's infamous O-ring seals).

I find that many independent EMC people have dozens of similar examples,
which they can't talk about very much because of commercial
confidentiality.. This is one reason why the EMC + Compliance Journal
(www.compliance-club.com) started its 'Banana Skins' column - to help
educate practising engineers about real EMC engineering problems they almost
certainly weren't taught about at college and may not (yet) have experienced
for themselves. 

I also have personal experience of a UK company that in the late 90's was
selling a range of over 110 CE-marked products (such as incubators) intended
for medical and chemical laboratories although less than 10% of their
products met both the EMCD and the LVD. The company in question had just
been purchased by another, which is why I was involved.

Interestingly, the new owners continued to sell the non-compliant products
while they re-engineered them one at a time to be compliant (which took
several years). 

My simple investigations over a number of years into a number of companies'
CE marked products have led me to be very cynical. As a rule of thumb I
guess that around 30% of CE marked products are non-compliant with EMC or
LVD, with another 30% being borderline cases. This seems to be borne out by
recent enforcement surveys in Finland and in the UK and published articles
from some test labs.

Changing to another of your criticisms below...
If you think my proposed statement is fog-filled, what do you propose
instead? 
Lets have constructive criticism instead of merely criticism.

In fact, in most scientific or engineering activities, one can only make
public statements using foggy words like 'generally'.
Remember the UK government's teams of scientific advisors and their
pronouncements on BSE and the foot and mouth epidemic? Would you have
expected them to produce precise and accurate predictions?
I am of the opinion that the outbreak of foot and mouth disease in the UK
was better understood, had fewer variables, and could be better controlled
than many real-life EMC-related safety engineering problems.

I believe the debate in question (whether "unintentional emitters" can
interfere with electronic circuits which are not intentional radio
receivers) cannot be answered with a definitive yes or no.
I believe that each safety-related application needs to be investigated and
firm engineering conclusions drawn. Even then, when one actually does such
exercises in real life (and I have) one still finds statements concerning
personal estimates of probability are necessary.
You can deride these as being 'foggy' if you like but I don't think even you
could be more precise in such circumstances.

Absolute certainty just does not exist in the real engineering world of
interactions between complex systems and I am sure you understand this well.

As for the rest of your comments, I plead guilty to raising the emotional
stakes. 

I deliberately used emotive arguments because I find that most designers
(and test lab engineers) prefer to keep their heads down doing the
engineering work they believe they are paid to do.

Where people could be injured or killed by their products I generally find
that designers are uncomfortable even thinking about this. Maybe this is
because it would mean them fighting with their management to get more
resources allocated.

I also find that most designers (and their managers) - if they think about
their potential 'victims' at all - also tend to think of them as 'other
people'. 
They don't seem to think of their customers ands third parties as if they
were members of their own family (as if other people's families were less
important). 
So this is an emotive litmus test I often use to test designers' and
managers ethics. 

Yes, ETHICS. 
Now that the word has been mentioned no doubt there will be a new thread
begun, full of people complaining that behaving ethically is hard to do,
will harm their employers' profits, and is a trick by blood-sucking lawyers
to make more money.

But before anyone responds on this topic I suggest they first of all read
the ethical policies that their professional institution (the IEEE or the
IEE for example) requires them to follow.
I have to say that fewer than 10% of the designers I meet even know about,
much less follow, the ethical policies that their professional institutions
require of them. But if a professional engineer has to defend his design
decisions in court, he will often find that juries will expect him/her to
have behaved in an ethical manner according to the policies set out by the
professional institutions they are members of (at least they will when they
are so primed by the lawyers for the plaintiff).

And anyone who doesn't like the IEEE's ethical policy shouldn't just moan
about it, they should persuade the IEEE to change it to something they
prefer (ditto for IEE members and other institutions).

We all need to remember that someone once (correctly) said: "Doctors and
surgeons kill people one at a time, but engineers do it by the thousand.".

Regards, Keith Armstrong

In a message dated 05/01/02 21:01:21 GMT Standard Time, j...@jmwa.demon.co.uk
writes: 

Subj:Re: EMC-related safety issues
List-Post: emc-pstc@listserv.ieee.org
Date:05/01/02 21:01:21 GMT Standard Time
From:    j...@jmwa.demon.co.uk (John Woodgate)
Sender:    owner-emc-p...@majordomo.ieee.org
Reply-to: j...@jmwa.demon.co.uk (John Woodgate)
To:    emc-p...@majordomo.ieee.org

I read in !emc-pstc that cherryclo...@aol.com wrote (in <132.6f59d2b.296
89...@aol.com>) about 'EMC-related safety issues', on Sat, 5 Jan 2002:
>    Dear Cortland 
>    People can't simply say: "ordinary semiconductors won't demodulate RF
levels 
>    produced by an unintentional radiator"  even the smallest amount of RF can
>    be demodulated  there are no hysteresis or threshold effects in a PN
>    semiconductor junction or FET that is biased into its conduction region (at
>    least not until you get below signal levels equivalent to less than a
single 
>    electron). 

The question is not whether demodulation occurs, but whether the
recovered modulation is at a level to cause a problem. 1 mV of r.f.
can't produce even 1 mV of recovered modulation.
> 
>    What I am sure most engineers would really mean to say is:
>    "ordinary semiconductors exposed to RF levels from an information
technology 
>    product which is fully compliant with all relevant EMC emissions standards
>    and is at 10 metres distance will generally not demodulate a sufficient
>    level of interference to make an appreciable difference to most electronic
>    systems." 

I don't think most engineers would go along with a statement with such a
high fog-factor. That is one of the points of contention; this subject
seems to attract fog-factor like a superconducting magnet.
> 
>    Now we have a statement which has some scientific rigor and some
engineering 
>    validity to it.

Are you seriously putting that forward? It's so vague, IMO, as to be not
useful; it does not help in any way to realise solutions.

>    (Although I do worry that in Europe our harmonised EMC standards only test
>    emissions up to 1GHz, so what does that say about the possible emitted
>    fields strengths from a PC with a 1.2GHz clock frequency?)

Extension up to 3 GHz (much higher in some cases) is being studied
intensively. One major problem is that repeatable measurements above 1
GHz are very difficult to achieve.
> 
>    Let's see if we can put some meat into this discussion with a real-life
>    example... 

Well, it's a very extreme case of real life! I doubt that you'll come
across another one before you retire!
> 
>    I once tested a blood sample incubator for RF field immunity.

When was this? Before or after 1976, when EMC of medical equipment first
(AFAIK) surfaced as a matter to be studied intensively.

[Big snip] 
> 
>    How many people reading this would be now be quite happy to place even a
>    fully-compliant PC (compliant at 10 metres distance, that is) right next to
>    the unmodified incubator?
> 
>    If it helps, imagine that it is your young daughter whose blood sample is
in 
>    the incubator to discover which drugs she needs to survive.
> 
>    Shall we have a vote on how close we would be prepared to place the PC?
>    Might be interesting.

This appeal to emotion is out of place.
> 
>    Let's not even think about the problems of proximity to cellphones and
other 
>    intentional radiators.
> 
>    I didn't mention that the incubator was a small model used for mobile
>    screening, for installation in a truck adapted for medical screening
>    purposes which travels to various communities and parks there for a few
days 
>    while it tests the local people for disease - hardly a very well controlled
>    electromagnetic environment.
> 
>    What does the above imply for similar incubators in countries that do not
>    have mandatory EMC immunity standards? Or for older incubators in the EU
>    that have never had to meet the EMC directive?
> 
>    (Please don't reply with the old chestnut that "we haven't heard of any
>    problems so far, so everything must be OK" - people who should have known
>    better were using that phrase before September 11th. It is just not an
>    acceptable argument where safety issues are involved, as any expert in
>    safety law will tell you. Try: "I've been driving past that school at 40mph
>    for ten years and haven't hit a kid yet, so it must be safe mustn't it?" as
>    a test of the concept.)

More emotion. This is another point of contention: as soon as any
critique is offered to some pronouncement, these emotional arguments are
trotted out. I had a similar experience with a militant carer of
disabled people. Anything that suggested that her views were perhaps
just a *little* extreme (like scrapping all London's black cabs
overnight because they won't accommodate a wheelchair with the user in
it) was greeted with 'Oh, so you are prejudiced against disabled people,
are you?' 

IMO, your reasoning is utterly unreasonable. Designers are not
omniscient, or had better assume they are not. So they must assume that
they have not thought of every possible scenario down to that 10^-9
probability. How, then, can the designer be reasonably assured that his
design is satisfactory, if he cannot rely on the absence of reports of
problems? Is he to continue to refine it for years and years, before
releasing it, just in case he, or someone else, may think of yet another
risk scenario? 
> 


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