Re: [PSES] Critical component in EMC report
EMC testing is a service to our clients, so as to allow them to sign their Declaration of Compliance/conformance. The EMC test report needs to enable our customer to efficiently and accurately create compliant products. A problem with many small and medium enterprises is that they actually do not know what they exactly offered for testing. BOMs with almost unspecified parts are common. Mechanical drawings of the enclosure are often missing and I have yet to see a customer provide me with a professional grounding diagram for EMC. (Listing materials, paintings and EMC fixtures for example) In fact most customers do NOT know what parts of the equipment are relevant for EMC. How ever can they produce compliant products ? So our EMC reports do “freeze” a state of the product, by listing all relevant (in our opinion) construction details. Starting with a diagram part list, pcb lay-outs and technical drawing, component brands and grounding details are included. Software version is recorded as well as hardware revisions. Drawings are dated and recorded. For those customers that need to provide the test reports to their customer, we issue a “results-only version” on request. Too often this has proven to be useful, as our customer can fall back of the details in the test report to detect the cause of a sudden failure. Regards, Ing. Gert Gremmen, BSc g.grem...@cetest.nl mailto:g.grem...@cetest.nl www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Before printing, think about the environment. Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens Bill Owsley Verzonden: Friday, March 15, 2013 5:34 AM Aan: Scott Xe; Anthony Thomson; EMC-PSTC@LISTSERV.IEEE.ORG Onderwerp: Re: [PSES] Critical component in EMC report Indeed !!! and that is why EMC Design Engineers and Consultants continue to be employed. We know the magic and how to deploy it. A few are better than most the others, but that is the challenge, finding the ones that know the proper incantations to invoke for a first time pass, or at least a second pass. Test labs just tell you that the product has failed the requirements, and provide some data. The engineering folks have to guess from that data just what in the hell has happened. If they had a problem in the first place, means that they are not qualified to figure out what has failed. Call in a consultant... he is most likely a retired Test Engineer and has lot of experience with ferrites and copper tape. But if that gets you under the limits - great!! Or call in an EMC Design Engineer. They fix things on the pcb's and schematics. It's not cheap, but it sure goes right to the source of problem and also fixes SI, signal integrity. Your design can start at 10 MHz and ship at 200MHz with no changes to the layout. The same applies today with the proper scaling as mentioned by Dr, Howard Johnson of the black magic books. From: Scott Xe scott...@gmail.com To: Anthony Thomson ton...@europe.com; EMC-PSTC@LISTSERV.IEEE.ORG Sent: Thursday, March 14, 2013 9:25 AM Subject: Re: [PSES] Critical component in EMC report Thanks for all responded! For large companies, they may have test facilities and knowledgeable engineers to vary their products before sending to 3rd part lab for verification/certification. For medium and small companies, they have no test facilities and the engineers who may not have got the professional training in EMC requirements rely on the 3rd party lab for spotting out the failures and the advice for problem fixing. Dealing with such companies would be at risk as the test report may not help them too much. Regards, Scott On 14/3/13 4:40 PM, Anthony Thomson ton...@europe.com wrote: Scott, EMC compliance is the sole responsibility of the manufacturer (or whoever places the product on the market). It’s entirely up to you how you control ongoing compliance (or not). T - Original Message - From: Scott Xe Sent: 03/13/13 03:48 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Critical component in EMC report It is common not to have critical component list in EMC reports issued from 3rd party laboratories. Those information are essential to track if the correct parts to be used in mass production. What is main reason not to have it as a common practice in the field? Thanks and regards, Scott - This message is from the IEEE Product Safety Engineering Society emc-pstc
[PSES] SV: [PSES] RTTE - Radio product or not
Product A contains some fundamental radio parameters that you have mention (modulation, demodulation) and probably some others as well such as Frequency accuracy/stability. Does it offer any useful functionality without being connected to B? == Yes, even though it’s not possible to verify all radio parameters because Item B is missing, it should be possible to check some relevant requirements in the ETSI/EN 301 XXX standards on the TX/RX ports of Item A. == No, Item A doesn’t have any functionality when Item B is missing. Regards Amund Fra: Charlie Blackham [mailto:char...@sulisconsultants.com] Sendt: 19. mars 2013 20:12 Til: amund; EMC-PSTC@LISTSERV.IEEE.ORG Emne: RE: [PSES] RTTE - Radio product or not Amund I’d look at it the other way around: Product B isn’t a radio without product A attached, therefore product A is part of a radio system and the RTTE Directive applies. Product A contains some fundamental radio parameters that you have mention (modulation, demodulation) and probably some others as well such as Frequency accuracy/stability. Does it offer any useful functionality without being connected to B? (some other regulatory regimes often only require “certification” of the bit that actually “transmits”, but the RTTE directive is a bit different) Regards Charlie From: Amund Westin [mailto:am...@westin-emission.no] Sent: 19 March 2013 10:41 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] RTTE - Radio product or not Item A: Processing unit. Connection to PC and LAN (not directly to telecom network). Radio modulator demodulator. Output radio signal 800MHz / 0dbm on cable to Item B. Item B: Upconverter to 10GHz and High Power Amplifier and antenna Item A and B together is a complete radio system and RTTE apply. Item A stand-alone: I would say that it’s not a radio product since it does not transmit / receive to space. The radio signals (TX and RX) in on the cable to Item B and could be categorized as a signal line. LAN connection is not directly coupled to public telecom network. RTTE will not apply, that’s my opinion. The system integrator (Item A + B) will put his system into use and should be responsible for fulfilling RTTE. Folks, do you agree? Cheers, Amund PS: From RTTE guidelines: Telecommunications terminal equipment is defined as a product enabling communication or a relevant component thereof which is intended to be connected directly or indirectly by any means The wording “indirect” makes maybe Item A to a telecom terminal equipment …. - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Critical component in EMC report
In message FCA549BE3ECF9D4CB8CB8576837EA489140DA4@ZEUS.cetest.local, dated Wed, 20 Mar 2013, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: So our EMC reports do “freeze” a state of the product, by listing all relevant (in our opinion) construction details. Starting with a diagram part list, pcb lay-outs and technical drawing, component brands and grounding details are included. Software version is recorded as well as hardware revisions. Drawings are dated and recorded. You are actually providing part of the 'EMC assessment' document that the manufacturer is required by the EMC Directive to produce. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] SV: [PSES] RTTE - Radio product or not
Thanks! I see the 'intended function' ... Agree that Item A should be handled as a radio product. But it will be hard to make compliance to radio standards since the product Item, A is only a part of a total radio systems. Radio parameters according to ETSI / EN standards will not be able to check before a complete systems (Item A + B) is running. These parameters will not be able to check before the complete system is running. Let me just comment that Item A is made by a single manufacturer and Item B is made by manufacturer B and there are many possible Item B's on the market. Testing out all possible configurations of Itema A + Item B is considered unacceptable, since it will cover 95% of configurations which never will be used and it would also cost a huge amount of $$. Thanks. #Amund -Opprinnelig melding- Fra: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sendt: 19. mars 2013 20:42 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: Re: [PSES] RTTE - Radio product or not In message 3f0347ac6ed9504191f91f07629fbb0c01540...@thhsle14mbx2.hslive.net, dated Tue, 19 Mar 2013, Charlie Blackham char...@sulisconsultants.com writes: Product B isn’t a radio without product A attached, therefore product A is part of a radio system and the RTTE Directive applies. I would tentatively agree: in CENELEC long ago, the question was (half seriously) raised as to whether a washing machine with a microprocessor was a household appliance or ITE. The answer was that the 'intended function' is definitive. I think this can be extended to products like A and B, which are not intended to work alone but are components of a system. The 'intended function' of the system is a radio, so the component parts are 'radio'. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] RTTE - Radio product or not
Amund, The definition of radio equipment in the context of the directive is quite clear: “radio equipment means a product, or relevant component thereof, capable of communication by means of the emission and/or reception of radio waves utilising the spectrum allocated to terrestrial/space radiocommunication;” I think therefore it is clear that system components A B fall under the RTTED. However… I guess it’s entirely possible that any meaningful assessment against the RTTED may not be possible on the separate components assuming both are required to implement the ‘radio’. In this case, the Commission’s 2009 guide offers some very helpful advice: “Where a radio system is integrated on site — as in the case of microwave point-to-point and point-to-multipoint systems — the system integrators responsible for ensuring compliance of the system with the Directive when the system is brought into service.” So my opinion would be that each component of the system falls under the RTTED and it is the system integrator’s responsibility for compliance. Just my ‘two-penneth’. T - Original Message - From: Amund Westin Sent: 03/19/13 10:41 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] RTTE - Radio product or not Item A: Processing unit. Connection to PC and LAN (not directly to telecom network). Radio modulator demodulator. Output radio signal 800MHz / 0dbm on cable to Item B. Item B: Upconverter to 10GHz and High Power Amplifier and antenna Item A and B together is a complete radio system and RTTE apply. Item A stand-alone: I would say that it’s not a radio product since it does not transmit / receive to space. The radio signals (TX and RX) in on the cable to Item B and could be categorized as a signal line. LAN connection is not directly coupled to public telecom network. RTTE will not apply, that’s my opinion. The system integrator (Item A + B) will put his system into use and should be responsible for fulfilling RTTE. Folks, do you agree? Cheers, Amund PS: From RTTE guidelines: Telecommunications terminal equipment is defined as a product enabling communication or a relevant component thereof which is intended to be connected directly or *indirectly by any means The wording “indirect” makes maybe Item A to a telecom terminal equipment …. - 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 LT; emc-p...@ieee.org GT; 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas LT; emcp...@radiusnorth.net GT; Mike Cantwell LT; mcantw...@ieee.org GT; For policy questions, send mail to: Jim Bacher LT; j.bac...@ieee.org GT; David Heald LT; dhe...@gmail.com GT; - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Critical component in EMC report
So our EMC reports do “freeze” a state of the product, by listing all relevant (in our opinion) construction details. Test Reports from independent test laboratories should NEVER, NEVER EVER, incorporate subjective opinions. It is your duty to identify the EUT by means of serial numbers, h/w s/w revisions, photographs, objective descriptions, declarations of the build from the client etc., and describe the test configuration and set-up by means of diagrams, photographs, operating instructions etc. In fact, accreditation bodies expressly prohibit independent laboratories from expressing opinions. Assistance in identifying EMC critical design elements would be a consultancy service and could only be conducted in collaboration with the design authority. That same consultancy organisation cannot produce an independent test report. T - Original Message - From: ce-test, qualified testing bv - Gert Gremmen Sent: 03/20/13 08:48 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Critical component in EMC report EMC testing is a service to our clients, so as to allow them to sign their Declaration of Compliance/conformance. The EMC test report needs to enable our customer to efficiently and accurately create compliant products. A problem with many small and medium enterprises is that they actually do not know what they exactly offered for testing. BOMs with almost unspecified parts are common. Mechanical drawings of the enclosure are often missing and I have yet to see a customer provide me with a professional grounding diagram for EMC. (Listing materials, paintings and EMC fixtures for example) In fact most customers do NOT know what parts of the equipment are relevant for EMC. How ever can they produce compliant products ? So our EMC reports do “freeze” a state of the product, by listing all relevant (in our opinion) construction details. Starting with a diagram part list, pcb lay-outs and technical drawing, component brands and grounding details are included. Software version is recorded as well as hardware revisions. Drawings are dated and recorded. For those customers that need to provide the test reports to their customer, we issue a “results-only version” on request. Too often this has proven to be useful, as our customer can fall back of the details in the test report to detect the cause of a sudden failure. Regards, Ing. Gert Gremmen, BSc g.grem...@cetest.nl www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Before printing, think about the environment. Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] *Namens *Bill Owsley *Verzonden:* Friday, March 15, 2013 5:34 AM *Aan:* Scott Xe; Anthony Thomson; EMC-PSTC@LISTSERV.IEEE.ORG *Onderwerp:* Re: [PSES] Critical component in EMC report Indeed !!! and that is why EMC Design Engineers and Consultants continue to be employed. We know the magic and how to deploy it. A few are better than most the others, but that is the challenge, finding the ones that know the proper incantations to invoke for a first time pass, or at least a second pass. Test labs just tell you that the product has failed the requirements, and provide some data. The engineering folks have to guess from that data just what in the hell has happened. If they had a problem in the first place, means that they are not qualified to figure out what has failed. Call in a consultant... he is most likely a retired Test Engineer and has lot of experience with ferrites and copper tape. But if that gets you under the limits - great!! Or call in an EMC Design Engineer. They fix things on the pcb's and schematics. It's not cheap, but it sure goes right to the source of problem and also fixes SI, signal integrity. Your design can start at 10 MHz and ship at 200MHz with no changes to the layout. The same applies today with the proper scaling as mentioned by Dr, Howard Johnson of the black magic books. - From: Scott Xe scott...@gmail.com *To:* Anthony Thomson ton...@europe.com ; EMC-PSTC@LISTSERV.IEEE.ORG *Sent:* Thursday, March 14, 2013 9:25 AM *Subject:* Re: [PSES] Critical component in EMC report Thanks for all responded! For large companies, they may have test facilities and knowledgeable engineers to vary their products before sending to 3rd part lab for verification/certification. For medium and small companies, they have no test facilities and the engineers who may not have got the professional training in EMC requirements rely on the 3rd party lab for spotting out the failures and the advice for problem fixing. Dealing with such companies would be at risk as the test report may not help them too much. Regards, Scott On 14/3/13 4:40 PM, Anthony Thomson ton...@europe.com wrote: Scott, EMC compliance is the sole responsibility of the manufacturer (or whoever places the product on the market). It’s entirely up to you how you control ongoing compliance
Re: [PSES] Critical component in EMC report
In message 20130320101108.151...@gmx.com, dated Wed, 20 Mar 2013, Anthony Thomson ton...@europe.com writes: In fact, accreditation bodies expressly prohibit independent laboratories from expressing opinions. I think you are interpreting 'opinions' very strictly. Your list: It is your duty to identify the EUT by means of serial numbers, h/w s/w revisions, photographs, objective descriptions, declarations of the build from the client etc., and describe the test configuration and set-up by means of diagrams, photographs, operating instructions etc. is bound to include subjective elements. For example, how many photographs are to be included? 5? 10? 100? How 'objective' is the description written by a human being? How much detail of the test configuration is required? All connectors individually listed by a serial number stamped on each connector? It is only reasonable to include only those matters that are *relevant to EMC*, and that selection process is bound to have a subjective element. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Critical component in EMC report
In message FCA549BE3ECF9D4CB8CB8576837EA489140DA9@ZEUS.cetest.local, dated Wed, 20 Mar 2013, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: To John, Indeed these additions are part of the EMC assessment document, but what customer actually creates an EMC assessment document, if testing to harmonized standards is equivalent to that Perhaps only those that take my advice. (;-) -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] RTTE - Radio product or not
I remember this ground radar, that I had for testing a number of years ago, operating by sending an ground impulse with an antenna that was shielded upwards, followed by receiving that echo from the ground. From different authorities, I got different responses onto the applicability of the RTTD or EMC directive. Using the definition : “ radio equipment means a product, or relevant component thereof, capable of communication by means of the emission and/or reception of radio waves utilising the spectrum allocated to terrestrial/space radiocommunication;” created even more problems, as the question rose if the soil is part of the space allocate for radio communication. The device was so well constructed , that it passed Class A emissions, but some authorities (notably the Swiss) insisted on applying the RTTE directive, and wanted the device to be classified in terms of frequency use, modulation method and used bandwidth (and more) and finally decided to refuse it’s use on Swiss soil. Regards, Ing. Gert Gremmen, BSc g.grem...@cetest.nl mailto:g.grem...@cetest.nl www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Before printing, think about the environment. Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens Anthony Thomson Verzonden: Wednesday, March 20, 2013 10:29 AM Aan: EMC-PSTC@LISTSERV.IEEE.ORG Onderwerp: Re: [PSES] RTTE - Radio product or not Amund, The definition of radio equipment in the context of the directive is quite clear: “ radio equipment means a product, or relevant component thereof, capable of communication by means of the emission and/or reception of radio waves utilising the spectrum allocated to terrestrial/space radiocommunication;” I think therefore it is clear that system components A B fall under the RTTED. However… I guess it’s entirely possible that any meaningful assessment against the RTTED may not be possible on the separate components assuming both are required to implement the ‘radio’. In this case, the Commission’s 2009 guide offers some very helpful advice: “Where a radio system is integrated on site — as in the case of microwave point-to-point and point-to-multipoint systems — the system integrators responsible for ensuring compliance of the system with the Directive when the system is brought into service.” So my opinion would be that each component of the system falls under the RTTED and it is the system integrator’s responsibility for compliance. Just my ‘two-penneth’. T - Original Message - From: Amund Westin Sent: 03/19/13 10:41 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] RTTE - Radio product or not Item A: Processing unit. Connection to PC and LAN (not directly to telecom network). Radio modulator demodulator. Output radio signal 800MHz / 0dbm on cable to Item B. Item B: Upconverter to 10GHz and High Power Amplifier and antenna Item A and B together is a complete radio system and RTTE apply. Item A stand-alone: I would say that it’s not a radio product since it does not transmit / receive to space. The radio signals (TX and RX) in on the cable to Item B and could be categorized as a signal line. LAN connection is not directly coupled to public telecom network. RTTE will not apply, that’s my opinion. The system integrator (Item A + B) will put his system into use and should be responsible for fulfilling RTTE. Folks, do you agree? Cheers, Amund PS: From RTTE guidelines: Telecommunications terminal equipment is defined as a product enabling communication or a relevant component thereof which is intended to be connected directly or indirectly by any means The wording “indirect” makes maybe Item A to a telecom terminal equipment …. - 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 LT;emc-p...@ieee.orgGT; 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list
Re: [PSES] RTTE - Radio product or not
In message FCA549BE3ECF9D4CB8CB8576837EA489140DAA@ZEUS.cetest.local, dated Wed, 20 Mar 2013, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: and finally decided to refuse it’s use on Swiss soil. Well, they haven't got much; Switzerland is mostly rock. Seriously, it is surprising that dinosaurs survive there. Ground radar is *essentially* terrestrial. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] RTTE - Radio product or not
Gert You don’t say how long ago this was, but Ground Penetrating Radar is (now) covered by RTTE, as detailed in ERC recommendation 70-03, and ETSI EN 302 066-2. Regards Charlie From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] Sent: 20 March 2013 12:25 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RTTE - Radio product or not I remember this ground radar, that I had for testing a number of years ago, operating by sending an ground impulse with an antenna that was shielded upwards, followed by receiving that echo from the ground. From different authorities, I got different responses onto the applicability of the RTTD or EMC directive. Using the definition : “ radio equipment means a product, or relevant component thereof, capable of communication by means of the emission and/or reception of radio waves utilising the spectrum allocated to terrestrial/space radiocommunication;” created even more problems, as the question rose if the soil is part of the space allocate for radio communication. The device was so well constructed , that it passed Class A emissions, but some authorities (notably the Swiss) insisted on applying the RTTE directive, and wanted the device to be classified in terms of frequency use, modulation method and used bandwidth (and more) and finally decided to refuse it’s use on Swiss soil. Regards, Ing. Gert Gremmen, BSc g.grem...@cetest.nlmailto:g.grem...@cetest.nl www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Before printing, think about the environment. Van: emc-p...@ieee.orgmailto:emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens Anthony Thomson Verzonden: Wednesday, March 20, 2013 10:29 AM Aan: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Onderwerp: Re: [PSES] RTTE - Radio product or not Amund, The definition of radio equipment in the context of the directive is quite clear: “ radio equipment means a product, or relevant component thereof, capable of communication by means of the emission and/or reception of radio waves utilising the spectrum allocated to terrestrial/space radiocommunication;” I think therefore it is clear that system components A B fall under the RTTED. However… I guess it’s entirely possible that any meaningful assessment against the RTTED may not be possible on the separate components assuming both are required to implement the ‘radio’. In this case, the Commission’s 2009 guide offers some very helpful advice: “Where a radio system is integrated on site — as in the case of microwave point-to-point and point-to-multipoint systems — the system integrators responsible for ensuring compliance of the system with the Directive when the system is brought into service.” So my opinion would be that each component of the system falls under the RTTED and it is the system integrator’s responsibility for compliance. Just my ‘two-penneth’. T - Original Message - From: Amund Westin Sent: 03/19/13 10:41 AM To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] RTTE - Radio product or not Item A: Processing unit. Connection to PC and LAN (not directly to telecom network). Radio modulator demodulator. Output radio signal 800MHz / 0dbm on cable to Item B. Item B: Upconverter to 10GHz and High Power Amplifier and antenna Item A and B together is a complete radio system and RTTE apply. Item A stand-alone: I would say that it’s not a radio product since it does not transmit / receive to space. The radio signals (TX and RX) in on the cable to Item B and could be categorized as a signal line. LAN connection is not directly coupled to public telecom network. RTTE will not apply, that’s my opinion. The system integrator (Item A + B) will put his system into use and should be responsible for fulfilling RTTE. Folks, do you agree? Cheers, Amund PS: From RTTE guidelines: Telecommunications terminal equipment is defined as a product enabling communication or a relevant component thereof which is intended to be connected directly or indirectly by any means The wording “indirect” makes maybe Item A to a telecom terminal equipment …. - 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 LT;emc-p...@ieee.orgmailto:emc-p...@ieee.orgGT; 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott
Re: [PSES] SV: [PSES] RTTE - Radio product or not
Amund, Regarding your second paragraph, a cost-effective approach is to develop a Test Plan that specifies tests on a reasonable number of combinations, submit it to a Notified Body for review, then get the Notified Body Expert Opinion based on that plan and the test results. Best Regards, Mike -Original Message- From: Amund Westin [mailto:am...@westin-emission.no] Sent: Wednesday, March 20, 2013 1:44 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] SV: [PSES] RTTE - Radio product or not Thanks! I see the 'intended function' ... Agree that Item A should be handled as a radio product. But it will be hard to make compliance to radio standards since the product Item, A is only a part of a total radio systems. Radio parameters according to ETSI / EN standards will not be able to check before a complete systems (Item A + B) is running. These parameters will not be able to check before the complete system is running. Let me just comment that Item A is made by a single manufacturer and Item B is made by manufacturer B and there are many possible Item B's on the market. Testing out all possible configurations of Itema A + Item B is considered unacceptable, since it will cover 95% of configurations which never will be used and it would also cost a huge amount of $$. Thanks. #Amund -Opprinnelig melding- Fra: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sendt: 19. mars 2013 20:42 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: Re: [PSES] RTTE - Radio product or not In message 3f0347ac6ed9504191f91f07629fbb0c01540...@thhsle14mbx2.hslive.net, dated Tue, 19 Mar 2013, Charlie Blackham char...@sulisconsultants.com writes: Product B isn’t a radio without product A attached, therefore product A is part of a radio system and the RTTE Directive applies. I would tentatively agree: in CENELEC long ago, the question was (half seriously) raised as to whether a washing machine with a microprocessor was a household appliance or ITE. The answer was that the 'intended function' is definitive. I think this can be extended to products like A and B, which are not intended to work alone but are components of a system. The 'intended function' of the system is a radio, so the component parts are 'radio'. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com This e-mail may contain privileged or confidential information. If you are not the intended recipient: (1) you may not disclose, use, distribute, copy or rely upon this message or attachment(s); and (2) please notify the sender by reply e-mail, and then delete this message and its attachment(s). Underwriters Laboratories Inc. and its affiliates disclaim all liability for any errors, omissions, corruption or virus in this message or any attachments. - 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:
Re: [PSES] Critical component in EMC report
Whoa Anthony, back up a little. Test reports can contain what the heck a lab likes, as long as interpretations are indicated as such. These words extracted from ISO 17025, the most common test document: Clause 5.10 covers reporting the results: Clause 5.10.1 The results shall be reported, usually in a test report or a calibration certificate (see Note 1), and shall include all the information requested by the customer and necessary for the interpretation of the test or calibration results and all information required by the method used. So, Point 1, if the customer asks for an interpretation, then the standard says the lab provides it. Clause 5.10.3.1 d) where appropriate and needed, opinions and interpretations ( See 5.10.5 ) Clause 5.10.5 When opinions and interpretations are included, the laboratory shall document the basis upon which the opinions and interpretations have been made. Opinions and interpretations shall be clearly marked as such in a test report. Point 2 ) Here a lab is told how to deal with opinions and interpretations. As for Assessing bodies forbidding inclusion of opinions and interpretations, well, here is the section from the NVLAP checklist dealing with 5.10.5: 5.10.5 Opinions and interpretations When opinions and interpretations are included, the laboratory shall document the basis upon which the opinions and interpretations have been made. Opinions and interpretations shall be clearly marked as such in a test report. NOTE 1 Opinions and interpretations should not be confused with inspections and product certifications as intended in ISO/IEC 17020 and ISO/IEC Guide 65. NOTE 2 Opinions and interpretations included in a test report may comprise, but not be limited to, the following: i) an opinion on the statement of compliance/noncompliance of the results with requirements; ii) fulfillment of contractual requirements; iii) recommendations on how to use the results; iv) guidance to be used for improvements. NOTE 3 In many cases it might be appropriate to communicate the opinions and interpretations by direct dialogue with the customer. Such dialogue should be written down. Perhaps a change in assessing body is in order? As for an organisation doing both design and test, I am all for it. In my visits to manufacturers test facilities from Japan to Israel, I have been most impressed by the majority that go well above and beyond what any 3rd party lab would do in testing product. They simply cannot ship millions of widgets every month with the threat of a recall from poor evaluation of their widget. My $ worth. Derek. -Original Message- From: Anthony Thomson ton...@europe.com To: EMC-PSTC EMC-PSTC@LISTSERV.IEEE.ORG Sent: Wed, Mar 20, 2013 5:11 am Subject: Re: [PSES] Critical component in EMC report So our EMC reports do “freeze” a state of the product, by listing all relevant (in our opinion) construction details. Test Reports from independent test laboratories should NEVER, NEVER EVER, incorporate subjective opinions. It is your duty to identify the EUT by means of serial numbers, h/w s/w revisions, photographs, objective descriptions, declarations of the build from the client etc., and describe the test configuration and set-up by means of diagrams, photographs, operating instructions etc. In fact, accreditation bodies expressly prohibit independent laboratories from expressing opinions. Assistance in identifying EMC critical design elements would be a consultancy service and could only be conducted in collaboration with the design authority. That same consultancy organisation cannot produce an independent test report. T - Original Message - From: ce-test, qualified testing bv - Gert Gremmen Sent: 03/20/13 08:48 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Critical component in EMC report EMC testing is a service to our clients, so as to allow them to sign their Declaration of Compliance/conformance. The EMC test report needs to enable our customer to efficiently and accurately create compliant products. A problem with many small and medium enterprises is that they actually do not know what they exactly offered for testing. BOMs with almost unspecified parts are common. Mechanical drawings of the enclosure are often missing and I have yet to see a customer provide me with a professional grounding diagram for EMC. (Listing materials, paintings and EMC fixtures for example) In fact most customers do NOT know what parts of the equipment are relevant for EMC. How ever can they produce compliant products ? So our EMC reports do “freeze” a state of the product, by listing all relevant (in our opinion) construction details. Starting with a diagram part list, pcb lay-outs and technical drawing, component brands and grounding details are included. Software version is recorded as well as
Re: [PSES] Critical component in EMC report
In message 007e01ce2597$cbb50290$631f07b0$@pctestlab.com, dated Wed, 20 Mar 2013, Dward dw...@pctestlab.com writes: So, while a test lab may not want to as it would most likely cause them to lose a client, they could actually say something to the effect of “While this device passed, in our opinion it is really a piece of junk and should never be sold.” Or, if they really want the clients business, they could say “This device is the best thing since sliced bread.” It must be a poor second best, because extensive tests have shown that sliced bread produces no emissions and has very high immunity at all frequencies. Indeed, exposure to high-intensity infra-red frequencies improves it, according to some opinions, but others describe those results as 'toast'. Experienced test houses have carefully-shaped sentences to express their views, such as 'This product will pass the relevant standard when the following improvements in performance are made (see pages 2 to 5).' -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Critical component in EMC report
In message 8cff3b820c7f441-bdc-3a...@webmail-m249.sysops.aol.com, dated Wed, 20 Mar 2013, Derek Walton lfresea...@aol.com writes: the excerpts are verbatim words from the standard. Nothing inaccurate about it. Please don't keep quoting the whole thread back to the beginning of time. That last message fell through the bottom of my display and has emerged in the south Pacific. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Critical component in EMC report
From: Dward [mailto:dw...@pctestlab.com] Sent: Wednesday, March 20, 2013 12:53 PM To: 'Derek Walton'; 'EMC-PSTC@LISTSERV.IEEE.ORG' Subject: RE: [PSES] Critical component in EMC report I would have to disagree with you. I do not know what version you are reciting, but 17025 does not contain the statement that the lab cannot give an opinion. Laboratories are accredited to ISO 17025 and 17025 allows opinions. And the applicant is in fact looking for an opinion from the lab. Even the statement that the device complies with a particular standard is an opinion. An opinion based on the accuracies of a test labs equipment, setup, and any objective evidence resulting in testing etc, but still only an opinion. And, while they may be based on objective evidence, opinions are always subjective as the originate from a person’s mind and how he/she thinks. From 17025: Section 4.7 “Service to the customer” - NOTE 2 Customers value the maintenance of good communication, advice and guidance in technical matters, and opinions and interpretations based on results. Section 5.2.1 – “Personnel” NOTE 2 The personnel responsible for the opinions and interpretation included in test reports should, in addition to the appropriate qualifications, training, experience and satisfactory knowledge of the testing carried out, also have: Section 5.2.4 – the responsibilities for reporting opinions and interpretations. Section 5.2.5 The management shall authorize specific personnel to perform particular types of sampling, test and/or calibration, to issue test reports and calibration certificates, to give opinions and interpretations and to operate particular types of equipment. Section 5.10.3 Test reports - where appropriate and needed, opinions and interpretations (see 5.10.5); Section 5.10.5 “Opinions and interpretations” When opinions and interpretations are included, the laboratory shall document the basis upon which the opinions and interpretations have been made. NOTE 1 Opinions and interpretations should not be confused with inspections and product certifications as intended in ISO/IEC 17020 and ISO/IEC Guide 65 NOTE 2 Opinions and interpretations included in a test report may comprise, but not be limited to, the following: In fact, a good report would have to contain an opinion on the pass or fail of testing, otherwise, it is not a compliance report, it is just a document providing test results. So, as you see, reports can and do contain opinions. Thanks Dennis Ward Senior Certification Engineer PCTEST This communication and its attachments contain information from PCTEST Engineering Laboratory, Inc., and is intended for the exclusive use of the recipient (s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachment(s) are free from computer virus or other defect. Thank you. From: Derek Walton [mailto:lfresea...@aol.com] Sent: Wednesday, March 20, 2013 12:28 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Critical component in EMC report Hi Dennis, the excerpts are verbatim words from the standard. Nothing inaccurate about it. These were the words stated in the thread: SNIP Test Reports from independent test laboratories should NEVER, NEVER EVER, incorporate subjective opinions. It is your duty to identify the EUT by means of serial numbers, h/w s/w revisions, photographs, objective descriptions, declarations of the build from the client etc., and describe the test configuration and set-up by means of diagrams, photographs, operating instructions etc. In fact, accreditation bodies expressly prohibit independent laboratories from expressing opinions. SNIP I refuted both these and gave the grounds for why both were not true. What the standard and assessing bodies allow has no bearing on the professional relationship between lab and client. It can't be interpreted as follow the standard unless the lab or client gets upset... Up to $1:50 now ;-) Derek. -Original Message- From: Dward mailto:dw...@pctestlab.com dw...@pctestlab.com To: 'Anthony Thomson' mailto:ton...@europe.com ton...@europe.com; EMC-PSTC mailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG Sent: Wed, Mar 20, 2013 1:32 pm Subject: RE: [PSES] Critical component in EMC report Actually, that is not accurate. While it may be dangerous to the test lab and client relationships, depending on the ‘opinion’, test labs can put their opinions in their reports. Section 5.10.5 of ISO17025 states that opinions
