Cortland Given the legal and philosophical "issues" in the USA, that sounds as if it MIGHT work - my latest take on this subject, as "discussed" today from both sides, is that suppliers and users of intentional emitters should not be immune(!) from legal action if they continue to cause interference to non-intentional emitters and their use by entirely "innocent" people going about their legal daily business and activities at work and at home. Again, what is good for the goose (intentional emitter suppliers/users) is good for the gander (the rest of the public).
Not a particularly "good" solution IMHO - but maybe the best you collectively can hope for at present, given the apparently "entrenched" position of many people in the US who oppose any concept of immunity/susceptibility testing for general public-use products :-(. Unfortunately that approach still does not address the, probably widespread, issue of one non-intentional product interfering with another one - which, I would suggest, is probably the more widespread problem for many of the public but they don't know what the issues are or how to fix them. For example, in my own case, my first digital sat receiver (around 1998) suffered interference from other components in my AV system (and this was a quite widely reported problem as I recall), until, with some relevant background knowledge to help, I replaced all the old single screened RF connections with decent double screened sat-spec cable - most people would not know why/how to do that. However, since then, I (and presumably many other consumers!) have never suffered the same issues as the newer receivers are far more resilient to external interference because the manufacturers have been compelled to comply with the EU immunity requirements! John E Allen W. London, UK -----Original Message----- From: Cortland Richmond [mailto:k...@earthlink.net] Sent: 30 September 2016 21:04 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] [RFI] Part 15 isn't enough.. On 9/30/2016 2:16 PM, Ken Javor wrote: > I still don't understand what the applicability is, but if that > statement about MIL-STD-461 applies to products to be sold > commercially, it has serious issues and drawbacks that make it utterly > impractical. I suspect the choice of MIL-Standards was made to reduce emissions more than FCC rules require and thus increase the margin available to prevent interference in the marketplace. The problem with lower numerical limits is, however, that either they become prohibitively expensive to manufacture, or they will be adopted pro forma and ignored in practice – which is often what manufacturers do already facing FCC limits. It does not help to require compliance with standards never meant to apply to consumer devices. A reasonable default limitation – Part 15 – can put a ceiling on the number of interference complaints, and a predictably expensive penalty for actually causing interference could ensure that manufacturers actually complied with those limits, thus my suggestion to require a manufacturer warranty covering the costs of remediation should interference occur. I think that might be enough; if coupled with a warranty against susceptibility to nearby transmitters, it could substantially reduce the number of complaints from that side as well. Cortland Richmond KA5S - ---------------------------------------------------------------- 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> - ---------------------------------------------------------------- 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>