Gert I have to agree with you on both points ...............
And, as more of a "consumer" nowadays (and knowing how much immunity testing costs for a single item of equipment!), I know where I would stand if I lived in the US and my recently purchased and expensive equipment displayed the sort of behavior outlined on the apartmenttherapy website ! John E Allen W. London, UK -----Original Message----- From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] Sent: 30 September 2016 09:40 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] [RFI] Part 15 isn't enough.. Well John, The problem is not that immunity regulations are not reasonable (in the US), its mere the simple fact that they are regulations that creates such a heavy opposition. Even under EMC colleagues / members on this list. The opinion in the US is that bad products will weed themselves out by competition, and that in the end only immune ovens survive. And everybody is happy, without regulations ! But for those early buyers of an oven, of course that actually do some kind of immunity testing for the ovens manufacturer on their own cost..... Regards, Ing. Gert Gremmen Approvals manager ------------------------------------------------------------------------------------ + ce marking of electrical/electronic equipment Independent Consultancy + Services Compliance Testing and Design for CE marking according to EC-directives: - Electro Magnetic Compatibility 2004/108/EC - Electrical Safety 2006/95/EC - Medical Devices 93/42/EC - Radio & Telecommunication Terminal Equipment 99/5/EC + Improvement of Product Quality and Reliability testing Education Web: www.cetest.nl (English) Phone : +31 10 415 24 26 ------------------------------------------------------------------- This e-mail and any attachments thereto may contain information that is confidential and/or protected by intellectual property rights and are intended for the sole use of the recipient(s) named above. Any use of the information contained herein (including, but not limited to, total or partial reproduction, communication or distribution in any form) by persons other than the designated recipient(s) is prohibited. If you have received this e-mail in error, please notify the sender either by telephone or by e-mail and delete the material from any computer. Thank you for your co-operation. -----Original Message----- From: john Allen [mailto:john_e_al...@blueyonder.co.uk] Sent: Friday 30 September 2016 10:14 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] [RFI] Part 15 isn't enough.. Cortland Morning I have just read some of stories on the apartmenttherapy website you gave the link to - and the poor customers who had EMI-related problems have my sincere sympathy. What seems clear to me (and presumably to most people viewing the current thread here!) is that relatively simple immunity fixes in the design and manufacture of the products would have prevented most of these problems ever occurring - but that even some the most "reputable" manufacturers were cost cutting to the bone to avoid doing that for the US market. However, where I disagree that about the warranty route being the one to go for because it put the onus of proof heavily on the poor customers, who will generally have no idea whatsoever what the problems with the products are. Most of us have had our own problems with products "under warranty" where it has been difficult or impossible to get the supplier to acknowledge that the product is at fault in some way when we know that it definitely is - and so why rely on a type of measure that often does not work and/or is easily deflected by the supplier (and especially by the local distributors and sales outlets, who generally know even less than the manufacturers about the EMC performance of the products that they sell!). And, as one story clearly showed, manufacturers can and will deny responsibility when the warranty runs out - and if the source of a problem takes a lot of time to track down and the warranty has then expired, then the customer may well have no recourse other than to buy some sort of replacement, often at considerable cost. These types of EMI problems can only get worse as more and more electronic devices are introduced and thus more EMI pollution occurs - and the ONLY people who can fix it are the manufacturers, not the poor and generally clueless customers, and so they should be made to do that before more, and potentially disasterous and life-threatening, incidents occur. Who can do that in the US: either the Federal Government or, in the current situation it appears, the individual States, and you might say that the problem is thus insoluable because of "differences" of opinion/attitude between the Federal and State bodies? However people in the US seem to forget that that is EXACTLY the situation we had in Europe in the late-middle of the 20th Century - every country had its own EMC legislation and that varied from very strictly enforced in Germany to quite lax, or at least "light-touch", as we had (and still do have!) in the UK and elsewhere. Nevertheless the emerging EMC problem was recognized by the national legislatures by the late 70's/early 80's and the EMC Directive (and later the R&TTE & RED) was born, and that is why we now have a reasonably effective and consistent legal and technical framework for EMC - both emissions AND immunity/susceptibility - control across the whole of the Continent, which is a marketplace of roughly the same size as the US! Therefore this sort of issue can "sorted" in the US when the relevant authorities at both Federal and State level are finally made to understand the size of the problem and that it can only get worse unless collective action is taken to address it. John E Allen W. London, UK -----Original Message----- From: Cortland Richmond [mailto:k...@earthlink.net] Sent: 30 September 2016 04:56 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] [RFI] Part 15 isn't enough.. On 9/29/2016 4:14 PM, Ghery S. Pettit wrote: > Preventing harmful interference in all cases is a mighty tough call. How low > do you need to limit emissions? How high a signal must the product be immune > to? The limits in Part 15 provide a reasonable level of protection, assuming > the potential victim is far enough away. Co-located devices may need more > suppression. That's why I think putting it in the form of a warranty is the best way to get manufacturers to pay attention to it. They know if they do pay attention to suppressing interference, the warranty will very rarely be used. Another way is an implied warranty of fitness; I understand the UK and Europe enforce implied warranties of serviceability, which US merchants often refuse to recognize, but twelve states (and the District of Columbia) don't allow them to. See http://consumer.findlaw.com/consumer-transactions/what-is-an-implied-warranty-.html Of course, this isn't legal advice, and I'm neither an attorney nor authorized to give legal advice. I do suspect some manufacturers would refuse to submit bids if a customer firm tried to make them eat the cost of noncompliance, not with the limits, but by causing harmful interference, forbidden even if the victim is right next to the product. Remember the gas oven that got turned on by a cell phone? Here's another one that took *months* to pin down – and had a simple fix the manufacturer might have applied for less than a dollar each: http://www.apartmenttherapy.com/help-my-kitchen-is-possessed-w-147015 Cortland Richmond KA5S - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
