A margin is not indicative of any specific measurement uncertainty. Measurement 
uncertainties can only provide a relevant margin for a particular measurement 
at a particular site for a particular configuration.

Have only read the measurement uncertainty stuff in C63.23, CISPR16-4-2, and 
CISPR22. Read outline-style draft of C63.11, and did not understand how the 
specified analysis for uncertainty could be used for a 'blanket' margin 
declaration.

If anyone has specific example of standard with an uncertainty method that 
could be used as basis for universal margin, would very much like to hear about 
it.

Will not comment on requirements per administrative law, as the FCC (title 47) 
and OSHA (title 29) tend to periodically re-write stuff to comply with 
directives and policies of each POTUS. But statutory law is clear about what is 
being referenced.

Brian
Sr Serrano Salsa Design Moderator


-----Original Message-----
From: dward [mailto:dw...@pctestlab.com] 
Sent: Wednesday, October 14, 2015 12:01 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) 
Where?

Actually, that is not exactly correct.  While many standards are written as 
'voluntary' the FCC does in fact incorporate by reference some ANSI standards.  
To incorporate by reference means that the full content of the referenced 
document is part and parcel of the document to which it is referenced - except 
when specific disallowance of particular parts of the referenced std are 
mentioned.  So, if the standard says there is a needed uncertainty, then it 
could very well also, in legal terms, mean that the CFRs in fact incorporate 
these uncertainties by reference to that stated standard.  While it may not be 
enforced as yet, there is the possibility that, in a court of law, since some 
ANSI stds, except where specifically disallowed, are included by reference to 
the rules, uncertainties may also be included by that same reference.


​​​​​
Dennis Ward
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-----Original Message-----
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] 
Sent: Tuesday, October 13, 2015 10:49 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) 
Where?

They are not. No public standard enforces any margin.
Even measurement uncertainty is not taken into account, unless (in some 
standards) your uncertainty is larger than an assumed (calculated) value 
(depending on test set up and test type).

Regards,

Ing. Gert Gremmen
Approvals manager
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-----Original Message-----
From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com]
Sent: Tuesday 13 October 2015 18:44
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) 
Where?

All the issues being raised regarding possible variability must be known to the 
members of various standards committees. Does anyone know that the issues are 
*not* taken into account when the committees set test levels? If standards are 
followed, including any instructions regarding EUT sampling and measurement 
uncertainty, why assume additional margins must be applied?


Regards,
Lauren Crane
KLA-Tencor

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