I won't get into whether you were intending to impugn my truthfulness, and 
shall assume you just used an unfortunate turn of phrase.

I had already said I was not aware of the previous communications on this 
issue, so I could not have been aware that you were restricting the 
discussion to "the kinds of emissions controlled by CISPR 22 and Title 47, 
part 15B of the US Code of Federal Regulations". 

I thought the concern was for spurious emissions in the wider sense of 
electromagnetic engineering. 

I don't believe that CISPR 22 (or any other European EMC standards) even 
mentions the term 'spurious emissions'  much less defines it. Also, CISPR 22 
does not control all the possible emissions from equipment that comes under 
its scope, for example it does not limit emissions above 1GHz as yet, or 
below 150kHz. 

Anyway, CIPSR22 and Title 47, part 15B of the US Code of Federal Regulations 
only covers certain kinds of equipment, and other EMC standards may allow 
higher levels of 'spurious' emissions. 

To take just one example: EN 50199:1996 covers the emissions from welding 
equipment and allows such high levels of emissions that it requires 
manufacturers of such machinery to warn users that even though the welding 
equipment meets the limits of the standard it could still cause interference 
to computers, safety critical equipment, pacemakers, hearing aids, etc. 
Other examples of standards which permit much high levels of what one could 
call 'spurious' emissions include EN 61800-3 (industrial drives) and EN 
50091-2:1996 (uninterruptible power systems).

And I'm not sure whether you would call the leakages from ISM equipment (as 
defined by CISPR 11) 'spurious'. Is an induction furnace or dielectric heater 
an intentional transmitter? The semantics of the phrase 'spurious emissions' 
get very complicated the wider one casts one's net and what one might call 
the 'spurious emissions' from some ISM equipment can be extremely powerful 
indeed.

But in any case I disagree with your claim that the limited set of possible 
spurious emissions that you say you concerned with have such low powers that 
it is impossible for them to only affect radio receivers.
I refer again to the airplane compass interference example given in the IEE's 
guide on EMC and Functional Safety. A compass in an airliner is not a radio 
receiver, yet this one was interfered with by a laptop computer in the 
passenger cabin. 
I don't have many more details on the official investigation into this 
incident but it might have been that the laptop computer concerned did not 
comply with Title 47, part 15B of the US Code of Federal Regulations so its 
spurious emissions were higher than they should have been.
On the other hand the passenger cabin is a long way from the pilots 
instrumentation console so it may be that a similar laptop that did meet 
Title 47, part 15B of the US Code of Federal Regulations might have caused 
the same level of interference if it was closer to the compass's electronics.

Some electronics are simply very sensitive to demodulation of spurious 
emissions at specific frequencies, whether by accident or intention of their 
design or manufacture, so it is impossible to be categorical about their 
susceptibility to even very low levels of electromagnetic fields.

Regards, Keith Armstrong

In a message dated 31/12/01 20:47:15 GMT Standard Time, 
ken.ja...@emccompliance.com writes:

> Subj:Re: EMC-related safety issues
> Date:31/12/01 20:47:15 GMT Standard Time
> From:    ken.ja...@emccompliance.com (Ken Javor)
> To:    cherryclo...@aol.com, emc-p...@majordomo.ieee.org
> 
> In a court of law one must swear to tell the truth, the whole truth, and 
> nothing but the truth.  What you stated below is merely part of the truth.  
> The rest of the truth is that spurious emissions emitted by unintentional 
> radiators (the kinds of emissions controlled by CISPR 22 and Title 47, part 
> 15B of the US Code of Federal Regulations) are at such low levels that 
> there is no ability to cause an adverse reaction to anything except a radio 
> receiver.  It is only the field intensities associated with intentional rf 
> transmissions that are capable of stimulating electronics operating at 
> higher levels than radio receivers.
> 
> ----------
> From: cherryclo...@aol.com
> To: ken.ja...@emccompliance.com, emc-p...@majordomo.ieee.org
> Subject: Re: EMC-related safety issues
> Date: Mon, Dec 31, 2001, 12:45 PM
> 
> 
> >> Dear Ken 
>> Any electromagnetic emissions, whether conducted or radiated, including 
>> spurious emissions (however you wish to define the word 'spurious') can be 
>> demodulated by the non-linear processes in semiconductors, vacuum tubes, 
>> and the like. So the spread of possible problems goes beyond merely 
>> preventing the reception of radio communications. 
>> 
>> I didn't catch the previous correspondence on this issue, but it seems to 
>> me that a very narrow definition of the word 'intrinsic' is being used - 
>> and this could be misconstrued by some engineers (or their managers) who 
>> are more semantically challenged and possibly lead to possible safety 
>> hazards for the users of their products or systems, or third parties. 
>> 
>> Regards, 
>> Keith Armstrong 
>> www.cherryclough.com 
>> 
>> 
>> 
>> 
>> In a message dated 31/12/01 15:46:21 GMT Standard Time, 
>> ken.ja...@emccompliance.com writes: 
>> 
>> >>> Subj:Re: EMC-related safety issues 
>>> Date:31/12/01 15:46:21 GMT Standard Time 
>>> From:    ken.ja...@emccompliance.com (Ken Javor) 
>>> Sender:    owner-emc-p...@majordomo.ieee.org 
>>> Reply-to: ken.ja...@emccompliance.com <mailto:ken.ja...@emccompliance.com>
>>>   (Ken Javor) 
>>> To:    cherryclo...@aol.com, emc-p...@majordomo.ieee.org 
>>> 
>>> All of this message is very interesting and I have no problem with it at 
>>> all.  That doesn't change the fact that, as I and others stated earlier, 
>>> there is no intrinsic safety issue with a spurious emission.  Spurious 
>>> emissions only affect the ability to receive a radio signal.  That was 
>>> and is the only issue.  The fact that sometimes reception of that radio 
>>> signal is safety-critical is another matter entirely. 
>>> 
>>> ---------- 
>>> From: cherryclo...@aol.com 
>>> To: emc-p...@majordomo.ieee.org 
>>> Subject: EMC-related safety issues 
>>> Date: Mon, Dec 31, 2001, 7:12 AM 
>>> 
>>> 
>>> >>>> Dear all 
>>>> There was a discussion about electromagnetic emissions and safety issues 
>>>> a couple of weeks ago which I only caught the tail end of, so I hope my 
>>>> comments below are relevant and useful. 
>>>> I would also like to make a plea for assistance. 
>>>> 
>>>> Spurious emissions and safety. 
>>>> Even if we ignore 'leakages' from intentional transmitters and 
>>>> industrial RF processing equipment (such as dielectric heaters) and also 
>>>> ignore biological (human health) hazards, it is quite clear that 
>>>> spurious emissions can increase the risks of some safety hazards. 
>>>> 
>>>> I have worked on problems where spurious emissions from 
>>>> microprocessor-based systems were interfering with safety-related radio 
>>>> communications, and also on a pulsed-laser welder that interfered with 
>>>> helicopter air traffic control radio communications. The laser could 
>>>> only be operated when the nearby airport was closed to helicopters 
>>>> during the night. 
>>>> 
>>>> Section 7 of the 'core' of the IEE's professional guidance document on 
>>>> 'EMC and Functional Safety' includes an example of a airplane 
>>>> passenger's laptop significantly affecting the pilot's compass reading. 
>>>> You can download this useful guide for free from 
>>>> www.iee.org.uk/Policy/Areas/Electro (note: this URL may be case 
>>>> sensitive). 
>>>> 
>>>> Another useful source of interference anecdotes is the "Banana Skins" 
>>>> column in the EMC and Compliance Journal, which may be read at 
>>>> www.compliance-club.com. The two most recent issues are 'live' on the 
>>>> site and the others can be read by searching its archives. 
>>>> 
>>>> The IEE's Guide on EMC and Functional Safety. 
>>>> This guide adopts much the same approach to dealing with EMC-related 
>>>> safety issues as IEC/TS 61000-1-2:2001 "Electromagnetic Compatibility 
>>>> (EMC) - Part1-2: General - Methodology for the achievement of the 
>>>> functional safety of electrical and electronic equipment with regard to 
>>>> electromagnetic phenomena". 
>>>> (A key member of the IEC 61000-1-2 committee is a very senior safety 
>>>> expert and also a key member of the IEE Working Group that created this 
>>>> guide - helping to ensure compatibility between the two documents.) 
>>>> I understand that - after any modifications found necessary during its 
>>>> trial period - IEC/TS 61000-1-2 will probably become harmonised under 
>>>> the Low Voltage and Machinery safety directives. 
>>>> 
>>>> The IEE's guide on EMC and Functional Safety has been published for 18 
>>>> months and downloaded by many thousands of professionals. I chaired a 
>>>> well-attended one-day seminar on it in London UK in February 2001 and 
>>>> presented a well-attended paper on it at the IEEE EMC International EMC 
>>>> Symposium in Montreal Canada last August (pages 774-779 in Volume 2 of 
>>>> the Proceedings). A number of articles about this IEE guide and the 
>>>> issues associated with EMC-related functional safety have appeared 
>>>> during 2000 and 2001 in international trade journals, most recently in 
>>>> ITEM UPDATE 2001 (pages 52-59). 
>>>> 
>>>> The IEE has received many congratulations on this guide but so far has 
>>>> received no negative comments or suggestions for improvement - but of 
>>>> course it is far from perfect and the WG that wrote it expects to update 
>>>> and improve it during 2002 and 2003. 
>>>> 
>>>> 
>>> 
>> All suggestions for corrections, additions, or improvements from emc-pstc 
>> members or anyone else are most welcome. If you don't want to share your 
>> input with the whole emc-pstc group please send it to me directly at 
>> keith.armstr...@cherryclough.com or cherryclo...@aol.com, or else send 
>> them directly to Robert Croll in the Policy Division of the IEE: 
>> rjecr...@iee.org.uk. 
>> 
>> Many thanks! 
>> 
>> Finally, I wish you all a wonderful 2002! 
>> 
>> Keith Armstrong 
>> Cherry Clough Consultants 
>> http://www.cherryclough.com 
>> 

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