Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) Where?

[Scott Douglas]

On 10/14/2015 4:40 PM, Dan Roman wrote:

The other Brian wrote:


Does anyone have first-hand experience dealing with EMC failures  in the field? 
If you fail by 1db, are you dragged
through the mud, fined, banned, prosecuted, black helicopters circle your 
house, masked men drag you out of bed in
the middle of the night? Or is action taken only on severe non-compliances?  
What's the likely scenario?


Three short stories. Customer complains they are having problems with 
our very large format flat bed laser scanner. Trip to Buffalo, NY in 
January with analyzer, antennas, etc. Found significant "noise" in the 
very quiet RF amplifier circuits. Much chin scratching, head shaking, 
hand wringing later, I found I could listen to a local radio station in 
the video path of our product. Tracking it down was a bear but finally 
found it when I let a scope probe drop and it contacted the metal 
chassis of the product. Zero span was a wonderful tool to let me listen 
to 5 different radio stations on the product and all at frequencies 
below 100 MHz. On the chassis. Then I found it on the power lines. And 
then I found it on the steel column supporting the roof of the metal 
building. The final culprit was a radio station 3 blocks north and 7 
stories up in the air. With a very large antenna on the roof. Made the 
entire building hot and resonant at various frequencies. Fixes to the 
product were difficult, but we eventually succeeded.


Second story was when some government inspector stopped in at a 
customer's store in The Netherlands. Took a sample of our product back 
to the government lab for testing. 9 dB over the limit at 48 MHz. 
Product was a high end DVD player. Just not possible according to my 
test lab reports. Pulled two units from our EU warehouse and had them 
tested in Germany. Made sure the serial numbers bracketed the one the 
government lab said was bad. Not a peep. 4+ dB margin on both units. I 
called a contact at our EU office and she was able to work her way into 
the lab and ask lots of questions for me. She had no electronics 
knowledge, but worked the customs side of things. So she knew a bit 
about handling bureaucrats. Through her, I was able to show the lab had 
a bad test set up. The lab manager re-tested according to my 
configuration "suggestions" and found the unit was compliant after all. 
The original test engineer did not work there shortly thereafter.


Last story just recently. Israeli customer bought some products (AV 
gear) and as we normally do, we allowed them to submit for local country 
approvals. Conducted EMI failed by 12 dB at 4 MHz. Very helpful customer 
took lots of photographs for me. Contacted the factory (in Asia) and 
they suggested an "improvement" that might fix the problem. There was a 
large ferrite core on the AC Mains just in from the appliance inlet that 
fed up to the front of the box where the switching power supply was 
located. The factory "improvement" was to move the ferrite an inch to 
the left and mount it to the side of the chassis and to add several more 
twists to the discrete line/neutral conductor pair. Customer reworked 
the product and it passed. Then the Israeli test lab required them to 
rework the remaining 9  units same way, selected two more for testing 
and all passed. Case closed. Almost. Looked back at the photos in the 
original EMC test reports and the ferrite was in different location from 
the production models Much closer to the inlet and much closer to the 
side of the product keeping it away from the digital audio amplifier  
modules. It looks like the production line was getting sloppy in the 
placement of the ferrite and wire and caused the failure. We added more 
inspection criteria to our factory inspection checklist after that one.


So one customer reported problem and two government gotcha's. 
Fortunately I was able to work the three problems and find solutions 
that did not involve recalls, prohibitions, or fines. And I never had to 
leave the comforts of home. Except for the month I spent in Buffalo one 
winter week in January.


Scott

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Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) Where?

[Ted Eckert]

There are two separate questions.



Have you seen EMC failures in the field? It is fairly common to run into issues 
where one product causes interference where it shouldn’t.

http://www.compliance-club.com/archive/old_archive/Bananaskins.htm



Are you dragged through the mud? At least in the United States, penalties are 
often minor.

https://apps.fcc.gov/edocs_public/attachmatch/DA-09-1031A1.pdf


Ted Eckert
Compliance Engineer
Microsoft Corporation
ted.eck...@microsoft.com

The opinions expressed are my own and do not necessarily reflect those of my 
employer.

-Original Message-
From: Dan Roman [mailto:danp...@verizon.net]
Sent: Wednesday, October 14, 2015 4:40 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) 
Where?



The other Brian wrote:



> Does anyone have first-hand experience dealing with EMC failures  in

> the field? If you fail by 1db, are you dragged through the mud, fined,

> banned, prosecuted, black helicopters circle your house, masked men drag you 
> out of bed in the middle of the night? Or is action taken only on severe 
> non-compliances?  What's the likely scenario?



I've been doing the EMC thing since the mid-80s and I have never had a 
non-compliance in the field (that was brought to my attention).  Only 
non-compliances have been at an EMC lab (internal, external, or by a customer). 
 Am I doing a good job or is all of this blown out of proportion?



I've worked with various company imposed margins from 3 to 10 dB as well as a 
company where a pass was a pass (right at the limit was ok).  What seemed to 
work the best for getting solid EMC compliant product was when the process 
required the engineering director to sign off on releasing it without meeting 
margin.  Doesn't really matter what the value of x is at that point because 
people will do anything not to have to sign their name on a document!

__

Dan Roman, N.C.E.

Senior Member

IEEE Product Safety Engineering Society

mailto:dan.ro...@ieee.org



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Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) Where?

[Dan Roman]

The other Brian wrote:

> Does anyone have first-hand experience dealing with EMC failures  in the 
> field? If you fail by 1db, are you dragged 
> through the mud, fined, banned, prosecuted, black helicopters circle your 
> house, masked men drag you out of bed in 
> the middle of the night? Or is action taken only on severe non-compliances?  
> What's the likely scenario?

I've been doing the EMC thing since the mid-80s and I have never had a 
non-compliance in the field (that was brought to my attention).  Only 
non-compliances have been at an EMC lab (internal, external, or by a customer). 
 Am I doing a good job or is all of this blown out of proportion?

I've worked with various company imposed margins from 3 to 10 dB as well as a 
company where a pass was a pass (right at the limit was ok).  What seemed to 
work the best for getting solid EMC compliant product was when the process 
required the engineering director to sign off on releasing it without meeting 
margin.  Doesn't really matter what the value of x is at that point because 
people will do anything not to have to sign their name on a document!
__
Dan Roman, N.C.E.
Senior Member
IEEE Product Safety Engineering Society
mailto:dan.ro...@ieee.org

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Website:  http://www.ieee-pses.org/
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List rules: http://www.ieee-pses.org/listrules.html

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David Heald: 

Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc.,) Where?

[Gary McInturff]

I think I have told this story before but you asked so now you have to read it. 

Back around 1975 I was minding my own business when I got a letter from the FCC 
stating that the police department's car radios could not transmit when in the 
vicinity of a bank in Fallon Nevada. This was for a class A computing device - 
bank teller and back room automation. I don't remember the whole letter and but 
they obviously wanted to know what we were going to do about it. There was 
urgency to the letter but not a specific date or a direct turn off the 
equipment requirements.

We had a very specific signal to look at from the letter. I reviewed our test 
reports and the signal was not found, certainly not on the suspect list or 
final measurements. We had a 3 dB of margin requirement in our design process. 
We were measuring on our own 10 meter site that was registered with the FCC.( 
It really didn't take much to register in those days, site attenuation, 
physical description of the site etc.). EMC design and control was in its 
infancy for digital devices and this system had 6 to 10 cable interconnected 
devices - a real rat's nest.  

So I jumped on a plane to the Fallon. with the analyzer, antenna, and close 
field probes.  We set up the antenna near one of the teller platforms and 
started looking - nothing, switched to close field probes - nothing. Next 
station - nothing. It was nearing midnight so we started to shut down the 
equipment preparing to come back the next day. All of a sudden as I was 
starting disconnect the antennas a huge spike appeared at the suspect 
frequency. I asked my cohort what he was doing and he responded that he was 
shutting things down. I had him turn them back on and very quickly the spike 
disappeared. Equipment off - large spike, equipment on no spike. Came back the 
next day and called the police radio room again and had her hold the phone to 
their receiver. As soon as I turned off the suspect equipment I could hear the 
tone coming from the receiver via the telephone. I asked them to check their 
logs to see if they could identify any particular time when things seemed to go 
hay!
   wire. All of the complaints were after the bank closed for the day and had 
turned the equipment off.

A little investigation found that a video display was  changed from a +12 Vac 
only unit to one that required +  and -12Vdc. The switch being used to power 
the old display only had a single pole and perfectly acceptable for the old 
single voltage design. From the designers aspect things were working just fine. 
Turn off the power and the display went blank. Undetected by them was that the 
video amplifier was being driven into oscillation when the plus voltage was 
removed. The solution was simply, we could get dual pole switches that fit the 
unit and could be replaced in the field. We determined the number of field 
units, built up power switches and cables and instructed the field service guys 
to make the change. I responded back to the FCC that the problem was found, 
what the root cause of the signal was, and our field updates and projected 
timeline for complete retrofit, along with a note that any new complaints would 
be retrofit immediately. 
I don't really remember whether we got a response back from the FCC saying the 
accepted our resolution - I think we might have - but other than that we never 
heard from them again.
The short of it was - actual field complaint sent to the FCC, they tracked us 
down, we responded with the root analysis and repair information within two 
weeks and life went back to normal.

This and the one other incident does bring up the test modes issue though. The 
requirements at the time were for operating, scrolling H's to all peripherals, 
printers, disc drives etc. all variable control set to maximum etc. at least as 
a minimum
The above is an example of a mode one would never consider - the equipment 
turned off. I also had a problem with a vendor who was selling us a monitor and 
I kept pointing out a signal 30 dB over the limit. He insisted it wasn’t there, 
I insisted it was. Again I jumped on a plane with the offending monitor with 
me. Went to the suppliers test facility and started running tests. Again it was 
a single frequency of concern. He set everything up using a set of support 
equipment he had and turned everything on. He kind of smirked when the 
offending frequency wasn't there. I walked out to the monitor and adjusted the 
contrast form the required maximum to a more user preferred level. The smirk 
was quickly replaced with a whole different look as a plus 30 dB signal sat 
right where I told him it would be.

The point is one has to try to standardize the test setup and modes as much as 
possible - but there are a huge number of permutations that can apply and the 
highly unlikely will undoubtedly  bite you in a sensitive part every so often.



-Original Message-
From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: W

Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) Where?

[Brian O'Connell]

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

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

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

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

Brian
Sr Serrano Salsa Design Moderator


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

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


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

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

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking
 according to EC-directives:
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-Original Message-
From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com]
Sent: Tuesday 13 October 2015 18:44
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) 
Where?

All the issues being raised regarding possible variability must be known to the 
members of various standards committees. Does anyone know that the issues are 
*not* taken into account when the committees set test levels? If standards are 
followed, includi

Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) Where?

[Kunde, Brian]

Throwing in my two cents:

Keep in mind that Measurement Uncertainty goes both ways. For instance,  EMC 
labs will typically have a Measurement Uncertainty between ±4 - ±5db for 
Radiated Emission. That is "Plus or Minus", not just minus.

Since no EMC lab is perfect it is very likely that a product can pass by 4db at 
one lab and fail by 4db at another lab and still be ok.??

I've told this story before, but it is worth repeating.  Years ago in a life 
far far away, my employer at that time (not my current employer) did a buy/sell 
of a computer system built by another company in another land. Let's call is 
land Korea. By contract, this computer was to meet all safety and EMC 
requirements. Our EMC lab was not allowed to test this buy/sell product for 
ignorance is bliss (according to our corporate lawyers). One day, the good 
people of Sweden decided to verify the compliance of this system; to which they 
discovered that it failed Radiated Emissions by 2db. They sent us the test 
report which said that though it failed the limit, it was within their 
measurement uncertainty, so they could not declare the product as 
Non-Compliant.  No action was taken or had to be taken. All parties were happy.

Don't get me wrong. I've been doing this a long time and a huge supporter of 
margin and performing production audits. As an EMC engineer, we are responsible 
to our employer to produce a compliant and reliable product without 
over-burdening the design or the company we work for. It is a narrow path we 
walk. Sometimes decisions are left up to us and we must use our knowledge and 
familiarity with  our own products to decide what margin we must have and what 
areas we can get away with less margin. We all do it. It's part of our jobs.

Measurement Uncertainty makes the mathematicians happy and it gives us EMC 
Engineers something to go to our boss with to help support the argument for 
margin. But for me, we always design for 8db margin, and allow 5db margin 
during production audits. Any signal within 5db must be verified on several 
units and found to be stable. It would be irresponsible to go to production 
with test results with little margin on a single golden unit.

We don't keep golden units. We are confident that we can pull any unit off the 
production line and it will pass all tests with good margin. It is the only way 
I can sleep at night and I am blessed to work for a company who supports the 
decisions our department makes.

CISPR11 section 12 refers to the old 80/80 rule. If you do the statistical 
assessment, for instance, one unit can fail by 2db and be ok as long as you 
test 5 more units and they pass by 5db.  One unit can fail by 4db if the next 7 
units pass by 5db. Interesting, isn't it?  How does this fit within the EU 
CE/DoC scheme where a manufacturer declares that every instrument they put on 
the market is compliant?  So "compliant" doesn't necessarily mean "100% pass 
the limits", does it?

I used to work for a man (again, in another life) who asked if he was going 
55mph in a 55mph zone, if he was breaking the law? Of course the answer is, no. 
But the point he was making is would not another lab have to fail a product by 
more than their Measurement Uncertainty to be able to claim for sure that the 
product "Failed the Limit", and then, wouldn't the lab have to test between 3 
and 12 units to perform a true Statistical Assessment to determine if the 
manufacturer is "Compliant" or not with the EMC Directive?  Very Interesting.

For this reason, I don't think many companies run into trouble with 
non-compliant instruments unless they fail by a fairly large margin or their 
products are causing very noticeable interference. Do you agree? I know it is 
difficult to share stories on this topic because this information can be 
considered confidential but I would love to hear if minor non-compliances are 
ever even found and when they are found what actions, if any,  are taken and 
what penalties are imposed. We only seem to hear about the Big Non-compliances 
and even those stories are very rare in the area of EMC.

Does anyone have first-hand experience dealing with EMC failures  in the field? 
If you fail by 1db, are you dragged through the mud, fined, banned, prosecuted, 
black helicopters circle your house, masked men drag you out of bed in the 
middle of the night? Or is action taken only on severe non-compliances?  What's 
the likely scenario?

The Other Brian


-Original Message-
From: Pearson, John [mailto:john.pear...@polycom.com]
Sent: Tuesday, October 13, 2015 1:34 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) 
Where?

Hello

If you are selling into the EU your DoC declaring to the harmonized std 
(assuming you are taking this route) states that you are confirming that each 
and every item of product placed upon the market is compliant to the limit and 
not just the test sample.  Does that not mean yo

[PSES] SET EMC-PSTC NOMAIL

[Helge Knudsen]

SET EMC-PSTC NOMAIL


Med venlig hilsen / Best regards

Helge Knudsen

Holløselund Strandvej 11
3220 Tisvildeleje

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Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) Where?

[dward]

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


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

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

Regards,

Ing. Gert Gremmen
Approvals manager



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

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


Regards,
Lauren Crane
KLA-Tencor

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