Position Available - EMC Engineer
Greetings EMC Professionals! Emulex Corporation, the market leader in Fibre Channel Host Bus Adapters, has a position available for an EMC Test Engineer. Emulex is located in Costa Mesa, California and offers a competitve compensation package. For more information on the position, check our web site at: http://respond.webhire.com/emulex/jd45.html Please email me your resume directly if you are interested. You can direct the email to: randall.flind...@emulex.com Regards, Randy Flinders EMC Engineer Emulex Corporation 3535 Harbor Blvd. Costa Mesa, Ca. 92626 714-513-8012 voice 714-513-8265 fax randall.flind...@emulex.com www.emulex.com aka. chairman Orange County Chapter IEEE EMC Society r.flind...@ieee.org www.emcs.org attachment: Randall.Flinders.vcf
RE: Got another beef about an NRTL (haven't we all?)
On Component Recognition: 1) I can certainly sympathize with an NRTL reserving the right to reject another NRTL's component recognition/certification. After all, an NRTL has the right and RESPONSIBITY to protect the integrity of its mark. It seems to me an NRTL listing equipment may be a bit foolish if it does not at least give a cursory review to the report of the NRTL giving component recognition...No NRTL is perfectcertainly some are better than others. (A certain popular NRTL I find myself having to constantly babysitsome of its offices and engineers are VERY good, but the other 50% I have dealt with were incompetent to the point of abysmal absurdity...I have had issues with its own engineers not accepting another offices (same NRTL) component certification because the two different offices (remember - SAME NRTL) had a different Interpretation on a matter. One office would be obviously wrong...this happened more than once...cost our company and our CUSTOMERS a LOT of time and money...I will say no more). It would be nice, however, if there was more of a spirit of cooperations between the various NRTL'sIn the case of component certification/recognition, it seems that BOTH the NRTL granting the component certification, and the NRTL granting the equipment listing (UL terminology here) would have a long term interest in trying to minimize thier customers testing costs headache. Especially these days, when its necessary to make every penny count. A spirit of cooperation would go a long way here. I have had a few experiences with Wyle myself, and the few I have had left me with a good impression of Wyle regarding this issue. I have never give Wyle my business only because they are not nearly as accepted at the component level as UL CSA. 2) Being that I work at a component manufacturer, I can sympathize with your suppliers who are tight fisted with thier UL reports. Certainly, it is silly to think that a modem manufacturer, for example, is only asking for my UL report in order to go into competition against me, a transformer manufacturer. But there ARE certain companies out there which have no sense of propriety, and hand our design information off to cheap competitors. Then we are in a position of providing these companies free engineering support. We like our jobs, but we have to eat too. (In my experience, Tania, your company has not been one of these, this is not a jab against your organization.) But understand, after being repeatedly burned...a component supplier can get paranoid. My company typically is not extremely free in sharing our UL or CB reports with our customer. Not that we NEVER share our UL reports, but we just like to be sure first. One option when dealing with a supplier who does not wish to share UL report, is to ask if they would be willing to share thier UL reports directly with your NRTL Engineer. This way, your NRTL Engineer gets the information he/she needs, and your supplier has little reason for suspicion. Just my humble thoughts on the matter. Regards, Mel Pedersen -Original Message- From: Grant, Tania (Tania) [mailto:tgr...@lucent.com] Sent: Wednesday, October 25, 2000 1:07 PM To: 'Loop, Robert' Cc: emc-p...@majordomo.ieee.org Subject: RE: Got another beef about an NRTL (haven't we all?) Importance: High Thank you, Robert, for providing information that Wyle accepts other NRTL's test reports; however, I note your term ...typically will accept I, therefore, infer, that Wyle reserves the right to not accept whenever, for whatever reason, this warrants. Also, it would be helpful if you clarified whether Wyle requires the submission of the other NRTL test report in order to evaluate a product. I know that in the past I sometimes had trouble obtaining UL test reports from our vendors because they were afraid that we would use the information to go in competition against them! UL, however, has a vast database of Recognized components which is not available to other NRTLs. Thus, UL can check out the actual testing performed on these Recognized parts and use engineering judgement as to how that might affect the equipment under evaluation. Thus, you don't have to provide UL with their own test reports, but I find it extremely helpful, especially in the case of power supplies. Listed equipment is less of a risk,-- however, Listed units were approved to be used by an end-user and are not evaluated when stuffed and interconnected into somebody else's equipment or cabinet.Again, without a test report, the final evaluation may not be complete. Thus, I would think that anybody using other NRTLs than UL should always obtain all test reports of critical components. I am not being partial to UL and singing their praises;-- I am stating facts. Don't underestimate the vast UL Listing and Recognized (and Classified) database that UL has. UL can pull the Listing or Recognition at any time for non-compliance.
Re: A1 of EN61000-4-3
Larry, Thank you very much for the clarification! Can we try to conclude that (1) The modulation parameters of A1 are the same as original EN61000-4-3. (2) If both EN 61000-4-3 and A1 are stipulated at the same test amplitude, say 3 V/m, we don't have to retest 800-960 MHz of A1 after passing EN61000-4-3. If there is a special concern with the interference from cell phones, we may raise the test amplitude of A1 to say 10 V/m. Then we have to retest 800-960 MHz of A1 after EN61000-4-3. (3) The frequency range of 1.4-2.0 GHz in A1 would not be affected anyhow. Please correct me. Best Regards, Barry Ma On Wed, 25 October 2000, stillin...@aol.com wrote: Barry, I have the copy of A1 and do verify that it states 80% AM from 800 to 960. Appendix A in the Amendment provides the rational why 80% AM was chosen. Appendix A in a nutshell: Sine Wave AM, Square Wave AM and Pulsed RF signals were compared on a variety of products. It was concluded in Section A.4 that: In summary, sine wave modulation has the following advantages - narrow band detection response in analogue systems reducing background noise problems; - universal applicability, i.e. no attempt to simulate the behavior of the disturbing source; same modulation at all frequencies; - always at least as severe as pulse modulation. For the reasons stated above, the modulation method defined in this standard is 80% AM sine wave. Larry Stillings Compliance Worldwide, Inc. www.cw-inc.com ___ Free Unlimited Internet Access! Try it now! http://www.zdnet.com/downloads/altavista/index.html ___ --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
VHF oscillator circuit design Questions
Hello everyone, I really apprecaite any inputs on that subjects, thanks in advance: This is problem, I hope that I would not bore you will very much details. We are designing a 12 layer board that has a @ 2.5 Ghz circuit. The circuit contains a source crystal oscillator a ~ 78 Mhz PECL signal ,this feeds into a PECL/TTL converter (plastic with no metal case), then the output of the converter is feeding into a CLK multilayer (plastic with no metal case)that generated a differential output of 2.5 Ghz. All the power and Clk ( ref and others) are on the first layer (however very short ( electrically, the maximum length of 5 mm). The GND for all those chips are done through the voltage return pins ONLY for each one to Digital DGND ground that is on the 2nd layer. There is no shielding or localized grounding for those three components. Emission is measured at 2.5 Ghz is quite high, and we relaying the board by doing the following: 1. Introduce a localize GND on the 1st layer that is a solid Cu plane, all three components will sit on that GND. The GND will have vias connected to the DGND in the 2nd layer. 2. All the traces that going to and/from those chips will be buried in the forth layer ( layer 3 is Voltage plane). So effectively will be slightly longer than 5 mm ( 6mm)). 3. we are putting a metal SMT can on top this circuit will completely Seal the components and preventing them from radiating. Q1. Do I need to barry those traced or can I run them through the localized GND in the 1st layer? Q2 If I need to use a heat sink on the multilayer, How can use it without defeating the purpose of the metal RF can? Q3 Did I miss any thing interms of the layout, for better EMC? Q4 how much should I expect of reduction in EM radiation, when adding that change? Any helpful inputs will be very appreciated. THanks very much for your responses. Sami Alkar Compliance Engineer samii...@hotmail.com _ Get Your Private, Free E-mail from MSN Hotmail at http://www.hotmail.com. Share information about yourself, create your own public profile at http://profiles.msn.com. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
Re: A1 of EN61000-4-3
Barry, I have the copy of A1 and do verify that it states 80% AM from 800 to 960. Appendix A in the Amendment provides the rational why 80% AM was chosen. Appendix A in a nutshell: Sine Wave AM, Square Wave AM and Pulsed RF signals were compared on a variety of products. It was concluded in Section A.4 that: In summary, sine wave modulation has the following advantages - narrow band detection response in analogue systems reducing background noise problems; - universal applicability, i.e. no attempt to simulate the behavior of the disturbing source; same modulation at all frequencies; - always at least as severe as pulse modulation. For the reasons stated above, the modulation method defined in this standard is 80% AM sine wave. Larry Stillings Compliance Worldwide, Inc. www.cw-inc.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: A1 of EN61000-4-3
The idea in the overlapping ranges is that at 800-890 MHz the test level may be selected to be different than in the rest of the band. Otherwise the test is same. regards, Ari Honkala -Original Message- From: EXT Maxwell, Chris [mailto:chr...@gnlp.com] Sent: Wednesday, October 25, 2000 9:36 PM To: 'Barry Ma'; emc-p...@ieee.org Subject: RE: A1 of EN61000-4-3 Do they have the same modulation parameters? I always assumed that the 800-960Mhz tests were pulse modulation tests using 200Hz, 50% duty cycle square waves. If not, then I'm just as confused as you are. -Original Message- From: Barry Ma [SMTP:barry...@altavista.com] Sent: Wednesday, October 25, 2000 11:47 AM To: emc-p...@ieee.org Subject:RE: A1 of EN61000-4-3 Hi group, Thanks for all replies in respond to my question on the Amendment 1 of EN61000-4-3 a few days ago. But there is another unclear issue left with the A1. Please help. I think the intention of A1 is to simulate the interference from near cell phones. That's why A1 has two frequency ranges: 800-960 MHz and 1.4-2.0 GHz. What I'm kind of confused is that the 80-1000 MHz frequency range of original EN1000-4-3 already includes 800-960 MHz of A1. It seems to make no sense to re-test a subset (800-960 MHz) after passing 80-1000 MHz. - They both have the same modulation parameters: 80% AM at 1 KHz. It makes sense, on the other hand, to test another frequency range 1.4-2.0 GHz of A1, which is out of 80-1000 MHz. Thanks. Best Regards, Barry Mab...@anritsu.com ANRITSUwww.anritsu.com Morgan Hill, CA 95037 Tel. 408-778-2000 x 4465 __ _ Free Unlimited Internet Access! Try it now! http://www.zdnet.com/downloads/altavista/index.html __ _ --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Poland Type Approval
I found this contact information at the ERO web site (http://www.ero.dk/ http://www.ero.dk/ ). This may or may not be the contact for certification. POLAND Mr Stanislaw CYDZIK Telephone +48 22 53 05 109 Deputy Director of Department European Telefax +48 22 53 05 914 Integration and International Relations E-mail integ...@ml.gov.pl mailto:integ...@ml.gov.pl Ministry of Posts and Telecommunications Stawki 2, St. 00-990 WARSZAWA POLAND Richard Woods -- From: Frank Harkins [SMTP:fhark...@solectek.com] Sent: Wednesday, October 25, 2000 4:08 PM To: emc-p...@majordomo.ieee.org Subject: Poland Type Approval Hi Group I hope some one can help me find the proper authority and regulations for Poland to type approve certify a DSS device in the ISM 2.4Ghz range ..I am at a dead end and any help would be appreciated. Frank --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: A1 of EN61000-4-3
Sorry, there's a typo in my quotation that I just sent: The requirement for 9005 MHz pulse modulation in ENV 50204 was replaced by 800-960 MHz and 1.4-2.0 GHz, 80% amplitude modulation in Amendment 1:1998 of EN61000-4-3. 9005 MHz should have been 900 + - 5 MHz. ___ Free Unlimited Internet Access! Try it now! http://www.zdnet.com/downloads/altavista/index.html ___ --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Beta Units and the FCC
2.806 I need to throw my blue copy of the FCC rules away. Thanks, Michael Cantwell, PE, NCE Flextronics International EMC Laboratories 762 Park Avenue Youngsville, NC 27596 Tel: (919) 554-0901 Fax: (919) 556-2043 --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
Poland Type Approval
Hi Group I hope some one can help me find the proper authority and regulations for Poland to type approve certify a DSS device in the ISM 2.4Ghz range ..I am at a dead end and any help would be appreciated. Frank --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: A1 of EN61000-4-3
Chris, Unfortunately I don't have a copy of A1 at hand. Please allow me to quote a text from an article in EE July 2000, p. S-55: The requirement for 900+/-5 MHz pulse modulation in ENV 50204 was replaced by 800-960 MHz and 1.4-2.0 GHz, 80% amplitude modulation in Amendment 1:1998 of EN61000-4-3. That text inspired my question because I got an impression that the pulse modulation of ENV50204 has been replaced by A1 with 80% AM. Can anybody who has a copy of A1 to verify? Thanks in advance. Barry - On Wed, 25 October 2000, Maxwell, Chris wrote: Do they have the same modulation parameters? I always assumed that the 800-960Mhz tests were pulse modulation tests using 200Hz, 50% duty cycle square waves. If not, then I'm just as confused as you are. ___ Free Unlimited Internet Access! Try it now! http://www.zdnet.com/downloads/altavista/index.html ___ --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Beta units and the FCC
Buy the way, in my opinion, the line about its only out in two places and by 4 dB is a slipper slope. Sales guys are forever trying to use that to get the product out to the street - hey who's going to catch us its only two frequencies. The next thing that happens is that you're on the next project and this thing is flying out the door, and you have even more trouble trying to get the company to be compliant on the next project. The only reason I mentioned this was just to point out that we weren't bringing down aircraft when we powered up the unit. The unit will comply when offered for sale, that's my job. Mike -Original Message- From: Gary McInturff [mailto:gary.mcintu...@worldwidepackets.com] Sent: Wednesday, October 25, 2000 9:00 AM To: 'Mike Morrow'; EMC Society Subject: RE: Beta units and the FCC Just for clarification on when or when you can't sell stuff. Couple of paragraphs from CFR 47 2.803 Equipment requiring /Commission approval A) Equipment can't be sold B) paragraph a) doesn't prohibit conditional sales where delivery is contingent upon compliance, nor agreements to produce new products which will be compliant. d) Not withstanding 2) equipment can be offered for sale to a business, not residential or resellers to residential equipment, which is non-compliant if the buyer is advised in writing at the time of offer for sale that the equipment must meet the FCC rules and will meet them before delivery. In this case the warning doesn't have to be present. Here is the section that I rely on. e) 1 Notwithstanding a) the device can be operated of labeled in the following situations. (iv) Evaluation of product performance and customer acceptability at the manufacturing facility during development, design, or pre-production states: or 2) Manufacturers facilities extends to entities working under the authorization of the responsible party in connection with the development and manufacture, but not marketing, of the equipment Sounds like a classic description of Beta test to me. If I weren't still twinking with the product and wringing out the last few bugs, which can only be found in the field under actual conditions it wouldn't be a Beta test. The customer has agreed to be a beta test site and usually gets a reduced price or something along that line to help with the final design checkout because he is somewhat at risk for the correct operation. Buy the way, in my opinion, the line about its only out in two places and by 4 dB is a slipper slope. Sales guys are forever trying to use that to get the product out to the street - hey who's going to catch us its only two frequencies. The next thing that happens is that you're on the next project and this thing is flying out the door, and you have even more trouble trying to get the company to be compliant on the next project. Gary -Original Message- From: Mike Morrow [mailto:mi...@ucentric.com] Sent: Wednesday, October 25, 2000 9:22 AM To: EMC Society Subject: Beta units and the FCC What are the rules regarding a piece of equipment that is being beta tested (not for sale, not being offered for sale) that does not currently comply with Part 15B limits? Everything I've read (47CFR Part 2.803) revolves around marketing and sales of the equipment, but nothing about equipment that is being given to someone for evaluation. FYI, the unit only has two failing frequencies and it only fails by about 4 db. I am planning on putting a not for sale sticker on the units as well. Thanks in advance. Mike Morrow Senior Compliance Engineer Ucentric Systems 978-897-6482 mi...@ucentric.com www.ucentric.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Got another beef about an NRTL (haven't we all?)
Bravo Robert - you're right on the mark. Dan Kinney Horner APG -Original Message- From: Loop, Robert [SMTP:rl...@hnt.wylelabs.com] Sent: Wednesday, October 25, 2000 11:58 AM To: tgr...@lucent.com Cc: emc-p...@majordomo.ieee.org Subject: RE: Got another beef about an NRTL (haven't we all?) Hi Tania, At Wyle Laboratories (one of the many NRTL's), we typically will accept test data from another NRTL. Our assumption is that other NRTL demonstrated proficiency to OSHA requirements and probably many others (A2LA, NVLAP, ISO Guide 25, etc.), hence their test data is assumed to be valid. It is not practical to retest every approved component or sub-assembly as if it had never been investigated by another NRTL. The time and cost to the customer would put us out of the product safety business. Each standard that we investigate a product to is done on a clause-by-clause basis to ensure nothing is missed. And the test methodology is adequately described in the standard to ensure uniformity of testing. As long as the COA's are reviewed and tested accordingly in the end-product application, we have done our job in ensuring the safety of the final assembly. One of the complaints from industry that has lead to worldwide harmonized standards was that different countries were using safety marks as a trade barrier. My personal opinion is that this holds true with any NRTL that will not accept test data from another NRTL without a signed MRA in place. It is not an easy accomplishment to achieve NRTL status, OSHA holds the bar pretty high up. Refusing to accept test data from another NRTL, is a way of saying that OSHA doesn't know its business on how to qualify a lab (again, my opinion). UL has a stranglehold on component recognition by requiring retesting of any component approved by another NRTL. The net effect is that this denies a large segment of business to its competitors. Fair? Hardly. Smart business strategy? Absolutely! That is my not-for-profit opinion and not my employers. Sincerely, Robert Loop Engineering Supervisor Wyle Laboratories Product Safety ph - (256) 837-4411 x313 fax- (256) 721-0144 e-mail: rl...@hnt.wylelabs.com -- From: Grant, Tania (Tania)[SMTP:tgr...@lucent.com] Reply To: Grant, Tania (Tania) Sent: Tuesday, October 24, 2000 5:37 PM To: 'duncan.ho...@snellwilcox.com'; emc-p...@majordomo.ieee.org Subject:RE: Got another beef about an NRTL Importance: High All right, let's get specific here and actually use some names! UL has a Mutual Recognition Agreement with CSA to accept each other's test reports. This agreement also specifies details about how they conduct the various tests (it used to be that earth leakage current measurements were performed differently by the two agencies). The agreement also allows them to harmonize standards, and many have been harmonized since the MRA was first signed. Where the standards still differ, my understanding is that both UL and CSA will perform both sets of test to satisfy both agencies' requirements. I am not aware that MRAs exist between the different NRTLs. And how is one NRTL going to know whether the test procedures are the same between the different NRTLs? In other words, there is no allegiance between them. And yes, they do compete. But so did UL and CSA, but now they sing the same tune. Any NRTL mark is good, per OSHA and the U.S. NEC, for end-use product. But if you are incorporating components and other equipment into your systems, you need to specify your expectations when you purchase parts. We specify X NRTL and we get that. Tania Grant, tgr...@lucent.com Lucent Technologies, Switching Solutions Group Intelligent Network and Messaging Solutions -Original Message- From: duncan.ho...@snellwilcox.com [ mailto:duncan.ho...@snellwilcox.com mailto:duncan.ho...@snellwilcox.com ] Sent: Tuesday, October 24, 2000 3:58 AM To: emc-p...@majordomo.ieee.org Subject: Got another beef about an NRTL Group, What about another scenario that I have been in with two NRTL's. For the sake of embarrassment,lets call them 'NRTL A' and 'NRTL B' Firstly any components or equipment recognised or listed by an NRTL are deemed 'acceptable' to OSHA so long as it is used as prescribed in its conditions of acceptability or use. so can I presume that as OSHA accepts any NRTL mark they are all of equal standing. Why is it then that NRTL A will not accept a power supply approved by NRTL B. The latter is true for NRTL B who will accept NRTL A's mark with no problems (in all cases the conditions of acceptability are followed) So long as the conditions of acceptability are followed and there are no engineering reasons for NRTL A to reject NRTL B's approval
DC Fuse for Power Supply
Doug, I ran into a problem in 1990 where we needed to add a primary fuse to a brick power supply, without changing the circuit board or the case. We had two holes in the circuit board where we could install a pigtailed fuse if we could find one that would meet UL and SEMKO requirements. (SEMKO did not allow soldered-on pigtails on primary fuses). Our solution, and I have yet to see a better alternative, was to buy 5mm x 20mm fuses from Schurter with push-on endcaps. These endcaps have the lead wires welded on, meeting the word and the spirit of the EMKO Deviations that applied at that time. Since no heat is applied when these endcaps are installed on the fuses, they have no effect on their electrical characteristics. I've given my Schurter catalog to the engineer who's taken over specifying/qualifying power supplies from me, so I don't have the part number handy, and I don't know if these fuses are available in the rating you need. But this, or something like this, might get you out of your bind. John Barnes Advisory Engineer Lexmark International --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: A1 of EN61000-4-3
Do they have the same modulation parameters? I always assumed that the 800-960Mhz tests were pulse modulation tests using 200Hz, 50% duty cycle square waves. If not, then I'm just as confused as you are. -Original Message- From: Barry Ma [SMTP:barry...@altavista.com] Sent: Wednesday, October 25, 2000 11:47 AM To: emc-p...@ieee.org Subject: RE: A1 of EN61000-4-3 Hi group, Thanks for all replies in respond to my question on the Amendment 1 of EN61000-4-3 a few days ago. But there is another unclear issue left with the A1. Please help. I think the intention of A1 is to simulate the interference from near cell phones. That's why A1 has two frequency ranges: 800-960 MHz and 1.4-2.0 GHz. What I'm kind of confused is that the 80-1000 MHz frequency range of original EN1000-4-3 already includes 800-960 MHz of A1. It seems to make no sense to re-test a subset (800-960 MHz) after passing 80-1000 MHz. - They both have the same modulation parameters: 80% AM at 1 KHz. It makes sense, on the other hand, to test another frequency range 1.4-2.0 GHz of A1, which is out of 80-1000 MHz. Thanks. Best Regards, Barry Mab...@anritsu.com ANRITSUwww.anritsu.com Morgan Hill, CA 95037 Tel. 408-778-2000 x 4465 ___ Free Unlimited Internet Access! Try it now! http://www.zdnet.com/downloads/altavista/index.html ___ --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Got another beef about an NRTL (haven't we all?)
Thank you, Robert, for providing information that Wyle accepts other NRTL's test reports; however, I note your term ...typically will accept I, therefore, infer, that Wyle reserves the right to not accept whenever, for whatever reason, this warrants. Also, it would be helpful if you clarified whether Wyle requires the submission of the other NRTL test report in order to evaluate a product. I know that in the past I sometimes had trouble obtaining UL test reports from our vendors because they were afraid that we would use the information to go in competition against them! UL, however, has a vast database of Recognized components which is not available to other NRTLs. Thus, UL can check out the actual testing performed on these Recognized parts and use engineering judgement as to how that might affect the equipment under evaluation. Thus, you don't have to provide UL with their own test reports, but I find it extremely helpful, especially in the case of power supplies. Listed equipment is less of a risk,-- however, Listed units were approved to be used by an end-user and are not evaluated when stuffed and interconnected into somebody else's equipment or cabinet.Again, without a test report, the final evaluation may not be complete. Thus, I would think that anybody using other NRTLs than UL should always obtain all test reports of critical components. I am not being partial to UL and singing their praises;-- I am stating facts. Don't underestimate the vast UL Listing and Recognized (and Classified) database that UL has. UL can pull the Listing or Recognition at any time for non-compliance. Each time they evaluate a product, they check that the Listing or Recognition is still valid. (How often has your UL evaluation been held up because some part was not in UL's database and you had to scramble to obtain the UL N of A (Notice of Authorization) of this newly UL approved part?) Other NRTLs can check their own files, but they cannot validate the status of another NRTL's approved part (unless they telephone each time. And how many actually do that) I find that this is a big loophole for any manufacturer who uses other approved units in their own equipment. Moral: you need to obtain those test reports and hope that the other NRTL accepts this data. Also note that legally, UL Recognition (note the capital R) is a specific term describing a UL process (and not anybody else's) of evaluating and approving components; component recognition is NOT in the public domain and UL does not have to share its Recognized component database that they carefully built over the ages. To describe this as ... stranglehold on component recognition... is a bit unfair. Let's just say that their lawyers are better and more forward thinking than some others. Tania Grant, tgr...@lucent.com Lucent Technologies, Switching Solutions Group Intelligent Network and Messaging Solutions -Original Message- From: Loop, Robert [ mailto:rl...@hnt.wylelabs.com mailto:rl...@hnt.wylelabs.com ] Sent: Wednesday, October 25, 2000 9:58 AM To: tgr...@lucent.com Cc: emc-p...@majordomo.ieee.org Subject: RE: Got another beef about an NRTL (haven't we all?) Hi Tania, At Wyle Laboratories (one of the many NRTL's), we typically will accept test data from another NRTL. Our assumption is that other NRTL demonstrated proficiency to OSHA requirements and probably many others (A2LA, NVLAP, ISO Guide 25, etc.), hence their test data is assumed to be valid. It is not practical to retest every approved component or sub-assembly as if it had never been investigated by another NRTL. The time and cost to the customer would put us out of the product safety business. Each standard that we investigate a product to is done on a clause-by-clause basis to ensure nothing is missed. And the test methodology is adequately described in the standard to ensure uniformity of testing. As long as the COA's are reviewed and tested accordingly in the end-product application, we have done our job in ensuring the safety of the final assembly. One of the complaints from industry that has lead to worldwide harmonized standards was that different countries were using safety marks as a trade barrier. My personal opinion is that this holds true with any NRTL that will not accept test data from another NRTL without a signed MRA in place. It is not an easy accomplishment to achieve NRTL status, OSHA holds the bar pretty high up. Refusing to accept test data from another NRTL, is a way of saying that OSHA doesn't know its business on how to qualify a lab (again, my opinion). UL has a stranglehold on component recognition by requiring retesting of any component approved by another NRTL. The net effect is that this denies a large segment of business to its competitors. Fair? Hardly. Smart business strategy? Absolutely! That is my not-for-profit opinion and not my employers. Sincerely, Robert Loop Engineering
RE: Beta units and the FCC
47 CFR 2.806(c)(3), (4), and (5) addresses this issue. (3) Any digital device may be operated at the manufacturer's facilities during development, design or preproduction states for evalutaion or product performance and determination of customer acceptability. (4) extends (3) to include user's site. (5) clarifies (4) and (5) a little more. The not for sale or lease stickers and informing the user that the unit does not comply with the FCC rules as stated in 2.803 or 2.805 also keeps you out of trouble. -Original Message- From: Mike Morrow [mailto:mi...@ucentric.com] Sent: Wednesday, October 25, 2000 12:22 PM To: EMC Society Subject: Beta units and the FCC What are the rules regarding a piece of equipment that is being beta tested (not for sale, not being offered for sale) that does not currently comply with Part 15B limits? Everything I've read (47CFR Part 2.803) revolves around marketing and sales of the equipment, but nothing about equipment that is being given to someone for evaluation. FYI, the unit only has two failing frequencies and it only fails by about 4 db. I am planning on putting a not for sale sticker on the units as well. Thanks in advance. Mike Morrow Senior Compliance Engineer Ucentric Systems 978-897-6482 mi...@ucentric.com www.ucentric.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Beta units and the FCC
On Wed, 25 October 2000, jestuckey wrote: ... [editted by BM] My recommendation would to include the following text (in a conspicuous font and type set) in all documentation sent with an evaluation or test package, regardless of the quantities or receiving agent : This device has not been authorized as required by the rules of the Federal Communications Commission. This device is not, and may not be, offered for sale or lease, or sold or leased, until authorization is obtained. Additionally, I recommend that a label with the following wording be attached to the board itself: PROTOTYPE for EVALUATION ONLY This board has not been tested for conformance to FCC Rules. JOHN E. STUCKEY EMC Engineer Micron Technology, Inc. Integrated Products Group Micron Architectures Lab 8455 West Emerald Boise, ID 83704 Ph. 208.363.5313 Fx. 208.363.5596 jestuc...@micron.com - What John said reminds me of a real story. About 10 years ago a friend of mine was working for a small PC company as an EMC engineer. A marketing person moved that label with the text of This device has not been authorized as required by the rules of the Federal Communications Commission. ... from the conspicuous front to the back of the PC in a computer show. This action was found by FCC and caused a fine to the company. BM Thanks. Best Regards, Barry Mab...@anritsu.com ANRITSUwww.anritsu.com Morgan Hill, CA 95037 Tel. 408-778-2000 x 4465 ___ Free Unlimited Internet Access! Try it now! http://www.zdnet.com/downloads/altavista/index.html ___ --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Got another beef about an NRTL (haven't we all?)
Hi Tania, At Wyle Laboratories (one of the many NRTL's), we typically will accept test data from another NRTL. Our assumption is that other NRTL demonstrated proficiency to OSHA requirements and probably many others (A2LA, NVLAP, ISO Guide 25, etc.), hence their test data is assumed to be valid. It is not practical to retest every approved component or sub-assembly as if it had never been investigated by another NRTL. The time and cost to the customer would put us out of the product safety business. Each standard that we investigate a product to is done on a clause-by-clause basis to ensure nothing is missed. And the test methodology is adequately described in the standard to ensure uniformity of testing. As long as the COA's are reviewed and tested accordingly in the end-product application, we have done our job in ensuring the safety of the final assembly. One of the complaints from industry that has lead to worldwide harmonized standards was that different countries were using safety marks as a trade barrier. My personal opinion is that this holds true with any NRTL that will not accept test data from another NRTL without a signed MRA in place. It is not an easy accomplishment to achieve NRTL status, OSHA holds the bar pretty high up. Refusing to accept test data from another NRTL, is a way of saying that OSHA doesn't know its business on how to qualify a lab (again, my opinion). UL has a stranglehold on component recognition by requiring retesting of any component approved by another NRTL. The net effect is that this denies a large segment of business to its competitors. Fair? Hardly. Smart business strategy? Absolutely! That is my not-for-profit opinion and not my employers. Sincerely, Robert Loop Engineering Supervisor Wyle Laboratories Product Safety ph - (256) 837-4411 x313 fax- (256) 721-0144 e-mail: rl...@hnt.wylelabs.com -- From: Grant, Tania (Tania)[SMTP:tgr...@lucent.com] Reply To: Grant, Tania (Tania) Sent: Tuesday, October 24, 2000 5:37 PM To: 'duncan.ho...@snellwilcox.com'; emc-p...@majordomo.ieee.org Subject: RE: Got another beef about an NRTL Importance: High All right, let's get specific here and actually use some names! UL has a Mutual Recognition Agreement with CSA to accept each other's test reports. This agreement also specifies details about how they conduct the various tests (it used to be that earth leakage current measurements were performed differently by the two agencies). The agreement also allows them to harmonize standards, and many have been harmonized since the MRA was first signed. Where the standards still differ, my understanding is that both UL and CSA will perform both sets of test to satisfy both agencies' requirements. I am not aware that MRAs exist between the different NRTLs. And how is one NRTL going to know whether the test procedures are the same between the different NRTLs? In other words, there is no allegiance between them. And yes, they do compete. But so did UL and CSA, but now they sing the same tune. Any NRTL mark is good, per OSHA and the U.S. NEC, for end-use product. But if you are incorporating components and other equipment into your systems, you need to specify your expectations when you purchase parts. We specify X NRTL and we get that. Tania Grant, tgr...@lucent.com Lucent Technologies, Switching Solutions Group Intelligent Network and Messaging Solutions -Original Message- From: duncan.ho...@snellwilcox.com [ mailto:duncan.ho...@snellwilcox.com mailto:duncan.ho...@snellwilcox.com ] Sent: Tuesday, October 24, 2000 3:58 AM To: emc-p...@majordomo.ieee.org Subject: Got another beef about an NRTL Group, What about another scenario that I have been in with two NRTL's. For the sake of embarrassment,lets call them 'NRTL A' and 'NRTL B' Firstly any components or equipment recognised or listed by an NRTL are deemed 'acceptable' to OSHA so long as it is used as prescribed in its conditions of acceptability or use. so can I presume that as OSHA accepts any NRTL mark they are all of equal standing. Why is it then that NRTL A will not accept a power supply approved by NRTL B. The latter is true for NRTL B who will accept NRTL A's mark with no problems (in all cases the conditions of acceptability are followed) So long as the conditions of acceptability are followed and there are no engineering reasons for NRTL A to reject NRTL B's approval then what happens next. Is there any recourse or would we have to go to one NRTL and get the whole lot retested. If there is no engineering reason, can an NRTL reject anothers recognition just because it distlikes it or maybe sees it as competition! Has anyone else had a similar experience, if so what did you do to resolve it without paying out for more NRTL approvals on an already recognised component. Any comments would be greatly
Re: Beta units and the FCC
In my understanding of FCC rules, your beta unit with a not for sale' sticker on it has no obligation to be compliant with Part 15B limit even if 15 dB above. Barry Ma On Wed, 25 October 2000, Mike Morrow wrote: What are the rules regarding a piece of equipment that is being beta tested (not for sale, not being offered for sale) that does not currently comply with Part 15B limits? Everything I've read (47CFR Part 2.803) revolves around marketing and sales of the equipment, but nothing about equipment that is being given to someone for evaluation. FYI, the unit only has two failing frequencies and it only fails by about 4 db. I am planning on putting a not for sale sticker on the units as well. Thanks in advance. Mike Morrow Senior Compliance Engineer Ucentric Systems 978-897-6482 mi...@ucentric.com www.ucentric.com ___ Free Unlimited Internet Access! Try it now! http://www.zdnet.com/downloads/altavista/index.html ___ --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Beta units and the FCC
Mike, You're in the right neighborhood, I think if you refer to 47 CFR part 2.803 section 2 paragraphs iv v, you'll get the answers you need. There are clear stipulations noted on when a product which is non-compliant can be taken outside the manufacturer's facility for evaluation and is so what the labeling requirements are. Unfortunately, it does consist of more than a not for sale sticker. Don Rhodes Principal EMC Engineer 503.685.8588 voice 503.685.7256 fax -Original Message- From: Mike Morrow [mailto:mi...@ucentric.com] Sent: Wednesday, October 25, 2000 9:22 AM To: EMC Society Subject: Beta units and the FCC What are the rules regarding a piece of equipment that is being beta tested (not for sale, not being offered for sale) that does not currently comply with Part 15B limits? Everything I've read (47CFR Part 2.803) revolves around marketing and sales of the equipment, but nothing about equipment that is being given to someone for evaluation. FYI, the unit only has two failing frequencies and it only fails by about 4 db. I am planning on putting a not for sale sticker on the units as well. Thanks in advance. Mike Morrow Senior Compliance Engineer Ucentric Systems 978-897-6482 mi...@ucentric.com www.ucentric.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
Beta units and the FCC
What are the rules regarding a piece of equipment that is being beta tested (not for sale, not being offered for sale) that does not currently comply with Part 15B limits? Everything I've read (47CFR Part 2.803) revolves around marketing and sales of the equipment, but nothing about equipment that is being given to someone for evaluation. FYI, the unit only has two failing frequencies and it only fails by about 4 db. I am planning on putting a not for sale sticker on the units as well. Thanks in advance. Mike Morrow Senior Compliance Engineer Ucentric Systems 978-897-6482 mi...@ucentric.com www.ucentric.com attachment: winmail.dat
RE: Beta units and the FCC
Just for clarification on when or when you can't sell stuff. Couple of paragraphs from CFR 47 2.803 Equipment requiring /Commission approval A) Equipment can't be sold B) paragraph a) doesn't prohibit conditional sales where delivery is contingent upon compliance, nor agreements to produce new products which will be compliant. d) Not withstanding 2) equipment can be offered for sale to a business, not residential or resellers to residential equipment, which is non-compliant if the buyer is advised in writing at the time of offer for sale that the equipment must meet the FCC rules and will meet them before delivery. In this case the warning doesn't have to be present. Here is the section that I rely on. e) 1 Notwithstanding a) the device can be operated of labeled in the following situations. (iv) Evaluation of product performance and customer acceptability at the manufacturing facility during development, design, or pre-production states: or 2) Manufacturers facilities extends to entities working under the authorization of the responsible party in connection with the development and manufacture, but not marketing, of the equipment Sounds like a classic description of Beta test to me. If I weren't still twinking with the product and wringing out the last few bugs, which can only be found in the field under actual conditions it wouldn't be a Beta test. The customer has agreed to be a beta test site and usually gets a reduced price or something along that line to help with the final design checkout because he is somewhat at risk for the correct operation. Buy the way, in my opinion, the line about its only out in two places and by 4 dB is a slipper slope. Sales guys are forever trying to use that to get the product out to the street - hey who's going to catch us its only two frequencies. The next thing that happens is that you're on the next project and this thing is flying out the door, and you have even more trouble trying to get the company to be compliant on the next project. Gary -Original Message- From: Mike Morrow [mailto:mi...@ucentric.com] Sent: Wednesday, October 25, 2000 9:22 AM To: EMC Society Subject: Beta units and the FCC What are the rules regarding a piece of equipment that is being beta tested (not for sale, not being offered for sale) that does not currently comply with Part 15B limits? Everything I've read (47CFR Part 2.803) revolves around marketing and sales of the equipment, but nothing about equipment that is being given to someone for evaluation. FYI, the unit only has two failing frequencies and it only fails by about 4 db. I am planning on putting a not for sale sticker on the units as well. Thanks in advance. Mike Morrow Senior Compliance Engineer Ucentric Systems 978-897-6482 mi...@ucentric.com www.ucentric.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: A1 of EN61000-4-3
Hi group, Thanks for all replies in respond to my question on the Amendment 1 of EN61000-4-3 a few days ago. But there is another unclear issue left with the A1. Please help. I think the intention of A1 is to simulate the interference from near cell phones. That's why A1 has two frequency ranges: 800-960 MHz and 1.4-2.0 GHz. What I'm kind of confused is that the 80-1000 MHz frequency range of original EN1000-4-3 already includes 800-960 MHz of A1. It seems to make no sense to re-test a subset (800-960 MHz) after passing 80-1000 MHz. - They both have the same modulation parameters: 80% AM at 1 KHz. It makes sense, on the other hand, to test another frequency range 1.4-2.0 GHz of A1, which is out of 80-1000 MHz. Thanks. Best Regards, Barry Mab...@anritsu.com ANRITSUwww.anritsu.com Morgan Hill, CA 95037 Tel. 408-778-2000 x 4465 ___ Free Unlimited Internet Access! Try it now! http://www.zdnet.com/downloads/altavista/index.html ___ --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Beta units and the FCC
47 CFR Ch. I (10-1-98 Edition) § 2.803 § 2.803 Marketing of radio frequency devices prior to equipment authorization. (a) Except as provided elsewhere in this section, no person shall sell or lease, or offer for sale or lease (including advertising for sale or lease), or import, ship, or distribute for the purpose of selling or leasing or offering for sale or lease, any radio frequency device unless: (1) In the case of a device subject to certification, such device has been authorized by the Commission in accordance with the rules in this chapter and is properly identified and labeled as required by § 2.925 and other relevant sections in this chapter; or (2) In the case of a device that is not required to have a grant of equipment authorization issued by the Commission, but which must comply with the specified technical standards prior to use, such device also complies with all applicable administrative (including verification of the equipment or authorization under a Declaration of Conformity, where required), technical, labeling and identification requirements specified in this chapter. (b) The provisions of paragraph (a) of this section do not prohibit conditional sales contracts between manufacturers and wholesalers or retailers where de-livery is contingent upon compliance with the applicable equipment authorization and technical requirements, nor do they prohibit agreements between such parties to produce new products, manufactured in accordance with designated specifications. (c) Notwithstanding the provisions of paragraphs (a), (b), (d) and (f) of this section, a radio frequency device may be advertised or displayed, e.g., at a trade show or exhibition, prior to equipment authorization or, for devices not subject to the equipment authorization requirements, prior to a determination of compliance with the applicable technical requirements provided that the advertising contains, and the display is accompanied by, a conspicuous notice worded as follows: This device has not been authorized as required by the rules of the Federal Communications Commission. This device is not, and may not be, offered for sale or lease, or sold or leased, until authorization is obtained. (1) If the product being displayed is a prototype of a product that has been properly authorized and the prototype, itself, is not authorized due to differences between the prototype and the authorized product, the following disclaimer notice may be used in lieu of the notice stated in paragraph (c) introductory text of this section: Prototype. Not for sale. (2) Except as provided elsewhere in this chapter, devices displayed under the provisions of paragraphs (c) introductory text, and (c)(1) of this section may not be activated or operated. (d) Notwithstanding the provisions of paragraph (a) of this section, the offer for sale solely to business, commercial, industrial, scientific or medical users (but not an offer for sale to other parties or to end users located in a residential environment) of a radio frequency device that is in the conceptual, developmental, design or pre-production stage is permitted prior to equipment authorization or, for devices not subject to the equipment authorization requirements, prior to a determination of compliance with the applicable technical requirements provided that the prospective buyer is advised in writing at the time of the offer for sale that the equipment is subject to the FCC rules and that the equipment will comply with the appropriate rules be-fore delivery to the buyer or to centers of distribution. If a product is marketed in compliance with the provisions of this paragraph, the product does not need to be labeled with the statement in paragraph (c) of this section. (e)(1) Notwithstanding the provisions of paragraph (a) of this section, prior to equipment authorization or determination of compliance with the applicable technical requirements any radio frequency device may be operated, but not marketed, for the following purposes and under the following conditions: (i) Compliance testing; (ii) Demonstrations at a trade show provided the notice contained in paragraph (c) of this section is displayed in a conspicuous location on, or immediately adjacent to, the device; (iii) Demonstrations at an exhibition conducted at a business, commercial, industrial, scientific, or medical location, but excluding locations in a residential environment, provided the notice contained in paragraphs (c) or (d) My recommendation would to include the following text (in a conspicuous font and type set) in all documentation sent with an evaluation or test package, regardless of the quantities or receiving agent : This device has not been authorized as required by the rules of the Federal Communications Commission. This device is not, and may not be, offered for sale or lease, or sold or leased, until authorization is obtained. Additionally, I recommend that a label with the
RE: Got another beef about an NRTL....
Tania, I don't think safety is a matter of pleasure and convenience. However, I do look for value in whatever product or service I purchase for myself and on my employers behalf. If any supplier is going to cost our company more money and time to market, we need to know a sound engineering reason why. Labs are no exception. After all, if we don't make money on this product, how will we pay to safety test the next one? Actually, your reply sort helped me with my point. Even your reply notes that authorities will go after the manufacturer, not the NRTL. That's why manufacturers need to take responsibility (regardless of whether they use an NRTL mark or not). I believe that the option of self declaration (if it's available) should always be considered. I'm not against NRTL's. I think that their efforts have made our lives better and more safe. I just think that we can't give them carte blanch when it comes to turning down perfectly good data from other labs. We need to ask why and we need to be provided with a sound engineering reason. We also need to be informed of all of the other accreditation schemes out there for labs such as A2LA and NVLAP. As compliance engineers, we need to be informed consumers. It keeps us on our toes, keeps the NRTL's on their toes and pushes them to harmonize with one another so that we all spend more time finding real safety issues as opposed to getting into I'm better than you are contests between labs. Personally, I applaud Doug for taking his lab to task. Even though he found out that he indeed needs the fuse, he made a learning mistake. The act of asking the question allowed him to learn the engineering reason why. It also may have taught other readers of the forum. It's a lesson he'll never forget and his future products will be safer because of it. I just wonder why he didn't find out sooner. It seemed like a fairly straightforward issue that his engineer would have been able to articulate to him before he came to the group with his beef. I also applaude the NRTL that Doug used and their engineer. They did their homework, had a legitimate concern and stood firm. It always pays to ask why and what we might learn is worth risking some egg on the face. Personally, I like mine scrambled with some chopped swiss chard, milk and corn meal. New potatoes, home fried in olive oil on the side don't hurt. The conditions of acceptability for scrambled eggs don't rule out a little hot sauce on the end product either. I'm getting hungry ... can't...type..must.get. -Original Message- From: Grant, Tania (Tania) [SMTP:tgr...@lucent.com] Sent: Tuesday, October 24, 2000 6:06 PM To: 'Maxwell, Chris'; emc-p...@majordomo.ieee.org Subject: RE: Got another beef about an NRTL Importance: High Chris, The NRTL mark is not for your pleasure and convenience. It is for consumers who don't want their Christmas lights to light up their whole house. And it also is for whatever local authorities that want to go after the negligent manufacturer to recall product and/or bring him to justice. Tania Grant, tgr...@lucent.com Lucent Technologies, Switching Solutions Group Intelligent Network and Messaging Solutions -Original Message- From: Maxwell, Chris [ mailto:chr...@gnlp.com mailto:chr...@gnlp.com ] Sent: Tuesday, October 24, 2000 10:47 AM To: emc-p...@majordomo.ieee.org Subject: RE: Got another beef about an NRTL This argument highlights why I like the self-declaration route to conformance. If I was NRTL A, I would be VERY cautious about accepting data from NRTL B for a product that will be sold with my (NRTL A) mark on it. I beleive that the system is much more practical when self declaration is used. Then, we as the manufacturer take responsibility for selecting an approved part (approved by NRTL A). We then take responsibility for either selecting an accredited lab (for instance, NRTL B) to test the entire product or we test the product in house using approved equipment and methods. We then self declare our product based upon sound engineering test data, regardless of whether it's from NRTL A, NRTL B or Sam's Discount Compliance Lab (assuming Sam is accredited). I don't even bother with putting the NRTL's mark on the product. After all, if there is a problem, the customer is coming after my company (maybe even me), not the NRTL. Also, most NRTL's limit their liability by saying that they have only performed a type test on a single unit, ... (insert lots of legal blah, blah, blah here) So, why should I worry about an NRTL's legal anxiety about putting their mark on my product? I'm not sure what protection it affords my company (as suming we already have test data from an accredited lab). In the end, Duncan. If I was in your position, I would ask your NRTL to produce a sound ENGINEERING, not legal, not commercial reason
Saudi Arabia
Hello members, It appears that in Saudi Arabia DTMF tones are used instead of FSK signalling for caller id. This is similar to ANI (automatic number identification) signalling used on T1 (CAS lines). It could be that Saudi Arabia use Wink Start on their analogue lines. I need to know if this is true. Also 1. Do they also do DID in a similar fashion (the called number is signalled using DTMF tones) 2. What is the inter digit (DTMF) time 3. Is there a termination DTMF tone. Your comments and links to any useful info is greatly appreciated Thanks Praveen Rao, Email: p...@tennyson.com.au, Ph (direct):+61-3-8558 0452 Tennyson technologies Pty. Ltd. Ph(Switch) : +61-3-8558 0400 Mobile: 0414504762 Fax:+61-3-9558 9965 14 Business Park Drive Notting Hill, Victoria - 3168 Australia Internet: www.tennyson.com.au --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
Huge egg on my face ...
I'm honest. I'll be the first to admit it. Previous beef with NRTL and the fuse issue is resolved. It's my fault. I don't know who said they had basically no sympathy but I liked that answer. Kept me on my toes. Anywho, CoA for recognition of power supply was with a 48vdc branch circuit capable of delivering a maximum of 20 amps. In our application, i.e. central office environment, the branch circuit we are connecting to is capable of 100 amps. I got to hand it to this one test engineer. Was really sharp on this point. Apologies to the NRTL people who are reading this. Especially to that one test engineer who IS reading this list ... Doesn't make a difference if I could make the power supply mfr change over to a DC fuse. The whole thing would have to get retested. So, now I'm on to finding an in-line fuse setup with a 15 amp time-lag 5mmx20mm fuse. chuckle ... Of course IEC-127 only goes to 6.3 amps. Otherwise, we really are going to have to retest the power supply and associated fuse with a source ten times the current of the CO or 1,000 amps!!! Anyone got any ideas for this? I was thinking of putting three in-line fuseholders with a 6.3 amp timelag 5mmx20mm fuse each in parallel with one another ... joking ... just joking ... Thanks for all the support both here and off-line. Regards, one very very humble Doug McKean --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Got another beef about an NRTL....
We had a poll on this forum awhile ago which essentially asked would we accept self certified parts. The answer was pretty distinctly no, and I, speaking only for myself, haven't change my perception one iota. A manufacture essentially telling me - Don't worry it works, trust me! - isn't going to get to far because I am worried about my customers and products not his. I don't have time to review all of his test results and conclusions to make a judgment, especially when I can get a condensed version of it from the competition. This whole issue is kind of a damned if you do and a damned if you don't problem. 1) Obviously, even among those that should know the standards because that is there sole business there is some level of confusion. That problem, again in my opinion, is greatly enhanced the smaller the NRTL for because they lack the overhead to fully train the new hires properly and when they have employee turn-over it is a much larger portion of their staff and experience. So they stay is this really tight lack of experience loop. Then when they do get really good at it, just like the big guys they promote them out of that position. Just the ability to get a peer review is difficult - there is no one to talk with or the time to spend reviewing each others problems. This doesn't mean they can't do an adequate job its just that they have resource constraints that make it very difficult. 2) I know of at least one small NRTL that was so overburdened and who so strongly advertised faster, better and cheaper (no not NASA) that they gave advance authorization to begin marking a product with their logo BEFORE the did any evaluation of the product whatever. I didn't find out about it until later when they claiming invalid construction. Fortunately, the standard didn't back them up and after I brought it to their attention we could proceed to completion. 3) The NRTL acceptance is not pressured by the Boss to get the thing out of the door regardless of problems, we can fix them later. Bosses have other pressures like money, lack of understanding or just plain, ain't letting the gov'ment telling me what to do mentality. I'm being a little factious but I think you get the point. An thread earlier on this site quote the guy in the Washington Post(?) who had doctored samples to get them through UL (I believe it was UL) and then was really upset that UL didn't catch him at it. Way too many manufacturers with that kind of logic to suit me. Yes, the inability to put pressure on a NRTL is a double edged sword. That is mostly, but certainly not all, a scheduling problem, or waiting too long in the development cycle to get product in front of them. The only thing I can suggest is to just be better than they are at their jobs, understand not only what the standard says but what it means, do not be afraid to take them to task if you don't agree, and don't accept an error even if it seems to work in your favor. (The AC versus DC fuse that started this could be one of those types of issues and ultimately it may cost the manufacturer at least one customer). I know this sounds a little self serving but that isn't the intent. I suspect that many of you have electronic copies of where I have mis-spoke, or just plain screwed up. I hate it when that happens, but mostly I just try to learn and not do it again. Geeez, I wonder just what the maximum loading force on this soap box I'm standing on is? Gary -Original Message- From: Maxwell, Chris [mailto:chr...@gnlp.com] Sent: Tuesday, October 24, 2000 10:47 AM To: emc-p...@majordomo.ieee.org Subject: RE: Got another beef about an NRTL This argument highlights why I like the self-declaration route to conformance. If I was NRTL A, I would be VERY cautious about accepting data from NRTL B for a product that will be sold with my (NRTL A) mark on it. I beleive that the system is much more practical when self declaration is used. Then, we as the manufacturer take responsibility for selecting an approved part (approved by NRTL A). We then take responsibility for either selecting an accredited lab (for instance, NRTL B) to test the entire product or we test the product in house using approved equipment and methods. We then self declare our product based upon sound engineering test data, regardless of whether it's from NRTL A, NRTL B or Sam's Discount Compliance Lab (assuming Sam is accredited). I don't even bother with putting the NRTL's mark on the product. After all, if there is a problem, the customer is coming after my company (maybe even me), not the NRTL. Also, most NRTL's limit their liability by saying that they have only performed a type test on a single unit, ... (insert lots of legal blah, blah, blah here) So, why should I worry about an NRTL's legal anxiety about putting their mark on my product? I'm not sure what protection it affords my
