Re: [PSES] [EXTERNAL] Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Ken Javor]

The original post was not class A vs. Class B, but whether any FCC
requirement applied.  I can't see how they could not be required to qualify
to class A.

Ken Javor
Phone: (256) 650-5261


> From: Brian O'Connell 
> Reply-To: Brian O'Connell 
> Date: Thu, 18 Feb 2016 20:21:52 +
> To: 
> Conversation: [PSES] [EXTERNAL]  Re: [PSES] 47 CFR Part 15 Subpart B /
> ICES-003 applicable/mandatory for an industrial personal computer?
> Subject: Re: [PSES] [EXTERNAL]  Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003
> applicable/mandatory for an industrial personal computer?
> 
> Generally agree, but government people can be capricious. For several years,
> have loaned a 'measurement device' to customers having issues with interfacing
> our stuff to their stuff. The device is marked "Property of the Empire. For
> Test and Evaluation Only". The device is a small plastic box with an USB port
> and a terminal block for analog and digital inputs that is embedded inside the
> customer's equipment; and the box has no display/keyboard/etc. Inside this
> little box is an ARM 4 processor and other stuff to measure and record.
> 
> There was one site where the box was supposedly interfering with a zigbee
> mesh, which resulted in another supplier making complaint. The brilliant and
> charming government people said that my little box was essentially a computer
> so should be Class B.
> 
> The customer's laptop computer, while connected to the 'device' USB port,
> caused the interference. The customer had defeated electromechanical
> interlocks to run his equipment with their computer connected to my USB port.
> 
> There are several mundane morals to this silly story, but will not restate the
> obvious.
> 
> Brian
> 
> 
> From: Gary McInturff [mailto:gary.mcintu...@esterline.com]
> Sent: Thursday, February 18, 2016 11:49 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] [EXTERNAL] Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003
> applicable/mandatory for an industrial personal computer?
> 
> I interpreted the original post correctly this was a system that was developed
> by the original posters company expressly to be used in the industrial market.
> It might look like a personal computer but there is another factor to be
> considered.
> The OEC document provides an escape clause, if you will, in a couple of places
> if you read it carefully enough. The term ³marketed² is important in this
> context.  Since I don¹t know who can see snippets of a PDF file and I don¹t
> want type out the paragraphs I¹m going to just refer you to section 15.3 (h),
> 15.3 (i) and 15.3(s)
> Section (s) defines a personal computer stating ³computers that are ³marketed²
> through retail outlets, mail order, and advertised to the general public.
>     If the original poster is building a computer that isn¹t marketed to
> the average consumer, advertises in trade magazines rather that Best Buy type
> circulars, and/or is too big or bulky or even lacking consumer esthetics then
> it¹s not a personal computer is industrial equipment. The marketing can also
> include price and supported software functions. 3X the price of an average
> computer, optimized to support only a CNC machine etc. takes it out of the
> personnel computer definition.
> 
> Section h and I essentially do the same thing: Class A digital devices are
> ones that are are ³marketed Exclusively² for use in Business, industrial and
> commercial environments.
> 
> I had this discussion many years ago with the FCC. We were building banking
> automation systems, and we developed our own workstations hardware (IBM
> compatible) and banking specific software. I believe it was running MS O/S,
> and one could play with Excel or Lotus if you bought those applications and
> loaded it onto the computer but the marketing was as I described above,
> advertised in trade journals, was pricey, and was supplied only with our
> custom designed banking automation software. The agreed FCC agree it was not a
> personal computer and was in fact an industrial machine.
> 
> For what it¹s worth
> Gary
> 
> -
> 
> 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
> 
> 
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
> 
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used
> formats), large files, etc.
> 
> Website:  http://www.ieee-pses.org/
> Instructions:  http://www.ieee-pses.org/list.html (including how to
> unsubscribe)
> List rules: http://www.ieee-pses.org/listrules.html
> 
> For help, send mail to the list administrators:
> Scott Douglas 
> Mike Cantwell 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[dward]

Probably one of the beneficial aspects of the FCC is that they tend to take the 
manufacturers word for how and where their devices are to be used.  Thus, 
unless the documentation or other information clearly indicates one of those 
purposes is for use in the residential environments, the FCC accepts the 
manufacturers premises if it states ‘commercial use only’ or otherwise 
indicates how they control where the devices are used.  That does not mean 
however that a company can go out to Best Buy and purchase a batch of laptops 
clearly intended for personal use and say they are ‘business computers’.  They 
are still PCs but used in a commercial environment.  

 

So the idea that “Our company uses PCs with our products which are considered 
“Laboratory Equipment”. Our products only have to meet the Class A 
requirements…” may not be totally correct unless the computers the company 
actually buys is a Class A computer and not PC (Personal Computers).  

 

As 15.3s states, “…notwithstanding business applications. Such computers are 
considered Class B digital devices.” 

 

The guiding factor in a computer, computing device or digital device being 
Class B is in the following conditions:

(1)   Marketed through a retail outlet or direct mail order catalog.  (2) 
Notices of sale or advertisements are distributed or directed to the general 
public or hobbyist users rather than restricted to commercial users.  (3) 
Operates on a battery or 120 volt electrical supply.

As the FCC rules state, the proof for classifying a digital device as other 
than Class B lies with the responsible party to demonstrate.

 

​Thanks 

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
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or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: Thursday, February 18, 2016 11:29 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

I don’t think the answer can be found chapter and verse from some standard, but 
look at the historical evidence.  Any electrical equipment, no matter what it 
is or what it does, what it is initially used for or how it is marketed, if it 
is likely to end up in homes or used in residential areas then it must meet the 
Class B requirements.  

 

Years ago, computers sold to the military only had to be Class A. But when old 
computers were replaced with new ones, the old ones found their way into 
people’s home. So now all computers have to be Class B.

 

Computers with a Network Card used to only have to be Class A because “no one 
would ever use a network at home”.  But, as soon as it became common for people 
to have home networks, computers and network cards had to meet Class B.  

 

So, if you use a stand-a-lone PC with an industrial device which can 
practically be used in homes, then the PC would have to meet Class B.  

 

Our company uses PCs with our products which are considered “Laboratory 
Equipment”. Our products only have to meet the Class A requirements, but the 
PCs have to meet Class B because no matter how we use it or what environment we 
use it, it is still a PC and could end up in someone’s home.  

 

I hope this was helpful.

 

The Other Brian

 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Thursday, February 18, 2016 1:24 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

Again I’m posing questions/observations, not acting as an expert, but it seems 
to me that a stand-alone computer, regardless of its purpose in a specific 
application, is not test equipment. By stand-alone, I mean not a PC embedded in 
a piece of test equipment.

Ken Javor
Phone: (256) 650-5261

  _  

From: Bill Stumpf  >
Reply-To: Bill Stumpf  >
Date: Thu, 18 Feb 2016 17:13:21 +
To:  >
Conversation: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Dennis is 100% right. The 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[dward]

Correct.  By definition a PC CANNOT be a piece of test equipment.   PC means 
Personal Computer, which is clearly defined by the FCC as a Class B digital 
device, not a piece of test equipment.  And, if the device is designed so it 
could only be used for one specific control purpose, then, while it may be a 
digital device or even a computing device, it is not a PC.

A PC is a very specific device in the FCC rules.  One problem in our industry 
is that we lump most all computing devices into the term PC and it causes a lot 
of problems if one is not careful.  

As someone once said “Words mean things”.

​

Dennis Ward

This communication and its attachements 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 attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Thursday, February 18, 2016 12:24 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

But how is a PC test equipment in any sense of the word?  The most a PC can be 
is an automated controller of test equipment. Since it can be used for any 
number of other applications, it is not test equipment, right?  Unless the PC 
manufacturer designed that PC so that it could only be used for one specific 
control purpose.

Ken Javor
Phone: (256) 650-5261



  _  

From: dward  >
Reply-To: dward  >
Date: Thu, 18 Feb 2016 12:13:32 -0800
To:  >
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

The answer is - look at what is not required to be tested and what is exempt 
from Part 15.  For example, when was the last time a spectrum analyzer was 
required to meet Part 15 digital device requirements? Or when was the last time 
that Scientific test equipment was required to meet Part 15 Digital Device 
requirements?  Never.  The reason is that the concept of test equipment is for 
all three types listed and not only Medical Test Equipment.   One would not 
want the FCC to list test equipment as ONLY Medical test equipment, that would 
be unrealistic.
 
 

​
Dennis Ward
This communication and its attachements 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 attachments(s) are free from computer virus or other defect.  Thank you.
 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Thursday, February 18, 2016 11:58 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

This is an interesting point.   My interpretation has always been that “test” 
only applies to “medical” and that the exemption applied to all industrial and 
commercial equipment.  Oh the joys of the English language.  If we wrote 
software like this we’d likely end up with planes crashing into the ocean:)

So what is the correct interpretation?
 
-Dave
 

From: Bill Stumpf [mailto:bstu...@dlsemc.com] 
Sent: Thursday, February 18, 2016 12:13 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Dennis is 100% right. The exemption applies exclusively to products which are 
industrial, commercial, or medical test equipment.  The "test equipment" 
classification applies to all of these categories, not only medical devices - 
at least this is my interpretation.  So if the digital device is not test 
equipment, the exemption does not apply.  If the exemption applies, it only 
pertains to the technical requirements of Part 15.  The general operation 
requirements of 

Re: [PSES] [EXTERNAL] Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Brian O'Connell]

Generally agree, but government people can be capricious. For several years, 
have loaned a 'measurement device' to customers having issues with interfacing 
our stuff to their stuff. The device is marked "Property of the Empire. For 
Test and Evaluation Only". The device is a small plastic box with an USB port 
and a terminal block for analog and digital inputs that is embedded inside the 
customer's equipment; and the box has no display/keyboard/etc. Inside this 
little box is an ARM 4 processor and other stuff to measure and record. 

There was one site where the box was supposedly interfering with a zigbee mesh, 
which resulted in another supplier making complaint. The brilliant and charming 
government people said that my little box was essentially a computer so should 
be Class B. 

The customer's laptop computer, while connected to the 'device' USB port, 
caused the interference. The customer had defeated electromechanical interlocks 
to run his equipment with their computer connected to my USB port.

There are several mundane morals to this silly story, but will not restate the 
obvious.

Brian


From: Gary McInturff [mailto:gary.mcintu...@esterline.com] 
Sent: Thursday, February 18, 2016 11:49 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 
applicable/mandatory for an industrial personal computer?

I interpreted the original post correctly this was a system that was developed 
by the original posters company expressly to be used in the industrial market. 
It might look like a personal computer but there is another factor to be 
considered.
The OEC document provides an escape clause, if you will, in a couple of places 
if you read it carefully enough. The term “marketed” is important in this 
context.  Since I don’t know who can see snippets of a PDF file and I don’t 
want type out the paragraphs I’m going to just refer you to section 15.3 (h), 
15.3 (i) and 15.3(s)
Section (s) defines a personal computer stating “computers that are “marketed” 
through retail outlets, mail order, and advertised to the general public.
    If the original poster is building a computer that isn’t marketed to 
the average consumer, advertises in trade magazines rather that Best Buy type 
circulars, and/or is too big or bulky or even lacking consumer esthetics then 
it’s not a personal computer is industrial equipment. The marketing can also 
include price and supported software functions. 3X the price of an average 
computer, optimized to support only a CNC machine etc. takes it out of the 
personnel computer definition.

Section h and I essentially do the same thing: Class A digital devices are ones 
that are are “marketed Exclusively” for use in Business, industrial and 
commercial environments.

I had this discussion many years ago with the FCC. We were building banking 
automation systems, and we developed our own workstations hardware (IBM 
compatible) and banking specific software. I believe it was running MS O/S, and 
one could play with Excel or Lotus if you bought those applications and loaded 
it onto the computer but the marketing was as I described above, advertised in 
trade journals, was pricey, and was supplied only with our custom designed 
banking automation software. The agreed FCC agree it was not a personal 
computer and was in fact an industrial machine. 

For what it’s worth
Gary

-

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 


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html

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For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Ken Javor]

But how is a PC test equipment in any sense of the word?  The most a PC can
be is an automated controller of test equipment. Since it can be used for
any number of other applications, it is not test equipment, right?  Unless
the PC manufacturer designed that PC so that it could only be used for one
specific control purpose.

Ken Javor
Phone: (256) 650-5261



From: dward 
Reply-To: dward 
Date: Thu, 18 Feb 2016 12:13:32 -0800
To: 
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory
for an industrial personal computer?

The answer is - look at what is not required to be tested and what is exempt
from Part 15.  For example, when was the last time a spectrum analyzer was
required to meet Part 15 digital device requirements? Or when was the last
time that Scientific test equipment was required to meet Part 15 Digital
Device requirements?  Never.  The reason is that the concept of test
equipment is for all three types listed and not only Medical Test
Equipment.   One would not want the FCC to list test equipment as ONLY
Medical test equipment, that would be unrealistic.
 
 

​
Dennis Ward
This communication and its attachements 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 attachments(s) are free from computer virus or other
defect.  Thank you.
 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com]
Sent: Thursday, February 18, 2016 11:58 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory
for an industrial personal computer?
 
This is an interesting point.   My interpretation has always been that
“test” only applies to “medical” and that the exemption applied to all
industrial and commercial equipment.  Oh the joys of the English language.
If we wrote software like this we’d likely end up with planes crashing into
the oceanJ
 
So what is the correct interpretation?
 
-Dave
 

From: Bill Stumpf [mailto:bstu...@dlsemc.com]
Sent: Thursday, February 18, 2016 12:13 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory
for an industrial personal computer?
 
Dennis is 100% right. The exemption applies exclusively to products which
are industrial, commercial, or medical test equipment.  The "test equipment"
classification applies to all of these categories, not only medical devices
- at least this is my interpretation.  So if the digital device is not test
equipment, the exemption does not apply.  If the exemption applies, it only
pertains to the technical requirements of Part 15.  The general operation
requirements of 15.5 always apply. As to the Class A/B application, you have
to look at how the device is marketed. If it is not marketed to the consumer
and is not intended to be used in the home, then Class A applies.
 
Bill Stumpf
 
 

From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, February 18, 2016 11:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory
for an industrial personal computer?
 
In addition to the previous comment I made, it is noted that the FCC defines
ISM equipment as “Equipment or appliances designed to generate and use
locally RF energy for industrial, scientific, medical, domestic or similar
purposes, excluding applications in the field of telecommunication.”  So,
unless a digital device meets the exemption requirements 15.103 and if it is
not a piece of test equipment, it is subject to Part 15.  Now then you must
look to see if it is Class A or Class B.
 

​
Dennis Ward
This communication and its attachements 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 attachments(s) are free from computer virus or other
defect.  Thank you.
 

From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, February 18, 2016 8:46 AM
To: 'Ted Eckert' ; 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Bill Stumpf]

I've always found the way that exemption is written as ambiguous.  The text 
below from OET 62 "Digital devices that are exempt from FCC technical 
standards" seems to be a little more informative.

Digital devices used EXCLUSIVELY as industrial, commercial or medical test 
equipment. "Test equipment" includes devices used for maintenance, research, 
evaluation, simulation and other analytical or scientific applications in areas 
such as industrial plants, public utilities, hospitals, universities, 
laboratories, automotive service centers and electronic repair shops. Devices 
designed for home use, such as consumer blood pressure meters, bathroom scales 
and digital thermometers, do not fall under this exemption.

Bill


From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com]
Sent: Thursday, February 18, 2016 1:58 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

This is an interesting point.   My interpretation has always been that “test” 
only applies to “medical” and that the exemption applied to all industrial and 
commercial equipment.  Oh the joys of the English language.  If we wrote 
software like this we’d likely end up with planes crashing into the ocean☺

So what is the correct interpretation?

-Dave

From: Bill Stumpf [mailto:bstu...@dlsemc.com]
Sent: Thursday, February 18, 2016 12:13 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Dennis is 100% right. The exemption applies exclusively to products which are 
industrial, commercial, or medical test equipment.  The "test equipment" 
classification applies to all of these categories, not only medical devices - 
at least this is my interpretation.  So if the digital device is not test 
equipment, the exemption does not apply.  If the exemption applies, it only 
pertains to the technical requirements of Part 15.  The general operation 
requirements of 15.5 always apply. As to the Class A/B application, you have to 
look at how the device is marketed. If it is not marketed to the consumer and 
is not intended to be used in the home, then Class A applies.

Bill Stumpf


From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, February 18, 2016 11:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

In addition to the previous comment I made, it is noted that the FCC defines 
ISM equipment as “Equipment or appliances designed to generate and use locally 
RF energy for industrial, scientific, medical, domestic or similar purposes, 
excluding applications in the field of telecommunication.”  So, unless a 
digital device meets the exemption requirements 15.103 and if it is not a piece 
of test equipment, it is subject to Part 15.  Now then you must look to see if 
it is Class A or Class B.

​
Dennis Ward
This communication and its attachements 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 attachments(s) are free from computer virus or other defect.  Thank you.

From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, February 18, 2016 8:46 AM
To: 'Ted Eckert' >; 
'EMC-PSTC@LISTSERV.IEEE.ORG' 
>
Subject: RE: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Several issues.  First, 15.123 is not the clause exempting devices it is a 
clause referring to labeling of digital ready devices.

Clause 15.103 is for exemption of devices.  So, while it may say exempt, 
unintentional radiator devices are still subject to 15.5 and 15.29 with 
‘strong’ recommendation to comply to part 15.  (NOTE: 15.5b states “Operation 
of an intentional, unintentional, or incidental radiator is subject to the 
conditions that no harmful interference is caused and that interference must be 
accepted that may be caused by the operation of an authorized radio station, by 
another intentional or unintentional radiator, by industrial, scientific and 
medical (ISM) equipment, or by an incidental radiator.”   15.103 main paragraph 
states, “Although not mandatory, it is strongly recommended that the 
manufacturer of 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[dward]

The answer is - look at what is not required to be tested and what is exempt 
from Part 15.  For example, when was the last time a spectrum analyzer was 
required to meet Part 15 digital device requirements? Or when was the last time 
that Scientific test equipment was required to meet Part 15 Digital Device 
requirements?  Never.  The reason is that the concept of test equipment is for 
all three types listed and not only Medical Test Equipment.   One would not 
want the FCC to list test equipment as ONLY Medical test equipment, that would 
be unrealistic.

 

 

​

Dennis Ward

This communication and its attachements 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 attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Thursday, February 18, 2016 11:58 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

This is an interesting point.   My interpretation has always been that “test” 
only applies to “medical” and that the exemption applied to all industrial and 
commercial equipment.  Oh the joys of the English language.  If we wrote 
software like this we’d likely end up with planes crashing into the ocean:)

 

So what is the correct interpretation?

 

-Dave

 

From: Bill Stumpf [mailto:bstu...@dlsemc.com] 
Sent: Thursday, February 18, 2016 12:13 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

Dennis is 100% right. The exemption applies exclusively to products which are 
industrial, commercial, or medical test equipment.  The "test equipment" 
classification applies to all of these categories, not only medical devices - 
at least this is my interpretation.  So if the digital device is not test 
equipment, the exemption does not apply.  If the exemption applies, it only 
pertains to the technical requirements of Part 15.  The general operation 
requirements of 15.5 always apply. As to the Class A/B application, you have to 
look at how the device is marketed. If it is not marketed to the consumer and 
is not intended to be used in the home, then Class A applies.  

 

Bill Stumpf

 

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Thursday, February 18, 2016 11:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

In addition to the previous comment I made, it is noted that the FCC defines 
ISM equipment as “Equipment or appliances designed to generate and use locally 
RF energy for industrial, scientific, medical, domestic or similar purposes, 
excluding applications in the field of telecommunication.”  So, unless a 
digital device meets the exemption requirements 15.103 and if it is not a piece 
of test equipment, it is subject to Part 15.  Now then you must look to see if 
it is Class A or Class B.  

 

​

Dennis Ward

This communication and its attachements 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 attachments(s) are free from computer virus or other defect.  Thank you.

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Thursday, February 18, 2016 8:46 AM
To: 'Ted Eckert'  >; 
'EMC-PSTC@LISTSERV.IEEE.ORG'  >
Subject: RE: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

Several issues.  First, 15.123 is not the clause exempting devices it is a 
clause referring to labeling of digital ready devices.  

 

Clause 15.103 is for exemption of devices.  So, while it may say exempt, 
unintentional 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Nyffenegger, Dave]

This is an interesting point.   My interpretation has always been that “test” 
only applies to “medical” and that the exemption applied to all industrial and 
commercial equipment.  Oh the joys of the English language.  If we wrote 
software like this we’d likely end up with planes crashing into the ocean☺

So what is the correct interpretation?

-Dave

From: Bill Stumpf [mailto:bstu...@dlsemc.com]
Sent: Thursday, February 18, 2016 12:13 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Dennis is 100% right. The exemption applies exclusively to products which are 
industrial, commercial, or medical test equipment.  The "test equipment" 
classification applies to all of these categories, not only medical devices - 
at least this is my interpretation.  So if the digital device is not test 
equipment, the exemption does not apply.  If the exemption applies, it only 
pertains to the technical requirements of Part 15.  The general operation 
requirements of 15.5 always apply. As to the Class A/B application, you have to 
look at how the device is marketed. If it is not marketed to the consumer and 
is not intended to be used in the home, then Class A applies.

Bill Stumpf


From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, February 18, 2016 11:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

In addition to the previous comment I made, it is noted that the FCC defines 
ISM equipment as “Equipment or appliances designed to generate and use locally 
RF energy for industrial, scientific, medical, domestic or similar purposes, 
excluding applications in the field of telecommunication.”  So, unless a 
digital device meets the exemption requirements 15.103 and if it is not a piece 
of test equipment, it is subject to Part 15.  Now then you must look to see if 
it is Class A or Class B.

​
Dennis Ward
This communication and its attachements 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 attachments(s) are free from computer virus or other defect.  Thank you.

From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, February 18, 2016 8:46 AM
To: 'Ted Eckert' >; 
'EMC-PSTC@LISTSERV.IEEE.ORG' 
>
Subject: RE: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Several issues.  First, 15.123 is not the clause exempting devices it is a 
clause referring to labeling of digital ready devices.

Clause 15.103 is for exemption of devices.  So, while it may say exempt, 
unintentional radiator devices are still subject to 15.5 and 15.29 with 
‘strong’ recommendation to comply to part 15.  (NOTE: 15.5b states “Operation 
of an intentional, unintentional, or incidental radiator is subject to the 
conditions that no harmful interference is caused and that interference must be 
accepted that may be caused by the operation of an authorized radio station, by 
another intentional or unintentional radiator, by industrial, scientific and 
medical (ISM) equipment, or by an incidental radiator.”   15.103 main paragraph 
states, “Although not mandatory, it is strongly recommended that the 
manufacturer of an exempted device endeavor to have the device meet the 
specific technical standards in this part.”  So to say there are no mandatory 
EMC requirements is not accurate, as, while being exempt from any specific 
technical requirement, they are required NOT to interfere etc.

It should also be noted that this exemption is ONLY for test equipment, not all 
digital equipment.  NOTE: 15.103c says “​A digital device used exclusively 
as industrial, commercial, or medical test equipment.”   It is not saying a 
piece of medical test equipment and all other industrial or commercial 
equipment.  It is saying industrial test equipment, commercial test equipment 
or medical test equipment.

Also, be careful with the concept of fixed in regards exclusive use in these 
areas to exemption under 15.103.  Exclusive does not mean fixed, it simply 
means that it is the ONLY area in which it is used, it means it cannot be taken 
out of the industrial, commercial or medical environment.  I would think that 
test equipment would not be fixed and since the 

Re: [PSES] [EXTERNAL] Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Gary McInturff]

I interpreted the original post correctly this was a system that was developed 
by the original posters company expressly to be used in the industrial market. 
It might look like a personal computer but there is another factor to be 
considered.
The OEC document provides an escape clause, if you will, in a couple of places 
if you read it carefully enough. The term “marketed” is important in this 
context.  Since I don’t know who can see snippets of a PDF file and I don’t 
want type out the paragraphs I’m going to just refer you to section 15.3 (h), 
15.3 (i) and 15.3(s)
Section (s) defines a personal computer stating “computers that are “marketed” 
through retail outlets, mail order, and advertised to the general public.
If the original poster is building a computer that isn’t marketed to 
the average consumer, advertises in trade magazines rather that Best Buy type 
circulars, and/or is too big or bulky or even lacking consumer esthetics then 
it’s not a personal computer is industrial equipment. The marketing can also 
include price and supported software functions. 3X the price of an average 
computer, optimized to support only a CNC machine etc. takes it out of the 
personnel computer definition.

Section h and I essentially do the same thing: Class A digital devices are ones 
that are are “marketed Exclusively” for use in Business, industrial and 
commercial environments.

I had this discussion many years ago with the FCC. We were building banking 
automation systems, and we developed our own workstations hardware (IBM 
compatible) and banking specific software. I believe it was running MS O/S, and 
one could play with Excel or Lotus if you bought those applications and loaded 
it onto the computer but the marketing was as I described above, advertised in 
trade journals, was pricey, and was supplied only with our custom designed 
banking automation software. The agreed FCC agree it was not a personal 
computer and was in fact an industrial machine.

For what it’s worth
Gary

From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com]
Sent: Thursday, February 18, 2016 10:04 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 
applicable/mandatory for an industrial personal computer?

There is an intriguing aspect of Michaels original question. He states the 
object is an “industrial personal computer in an industrial plant for 
measurement purposes.” There seems to be significant ambiguity related to what 
“test” means in 15.103c… particularly, is it to mean A. test device for other 
equipment (such as an oscilloscope), or B. anything that tests another object 
(such as a camera attached to a computer that does dimensional analysis of work 
pieces as they pass by) or both? There may even be a third possibility, and 
that is C. test in the sense of prototype.

I have seen A defended as the correct reading because it implies there is other 
equipment ‘in the equation’ that might be opened or in a state of failure when 
the test equipment is being used and so it make sense to carve out the 
exemption.

I have seen B defended in some contexts by the FCC such as a test noise source 
in an anechoic chamber, and I have received FCC guidance by email also 
supporting this idea.

However, I have not been able to find a definitive public guidance statement 
from the FCC

The definition given for test equipment does not resolve the ambiguity – “Test 
equipment” is “equipment that is intended primarily for purposes of performing 
measurements or scientific investigations [and] includes, but is not limited 
to, field strength meters, spectrum analyzers, and modulation monitors.”

It also seems important that the language of FCC is in terms of ‘devices’ more 
often than ‘products’ or ‘equipment’, thus a product or equipment might contain 
several devices each of which must have their particular FCC concerns addressed.

Regards,
Lauren Crane

KLA-Tencor
Public | Unrestricted

From: Bill Stumpf [mailto:bstu...@dlsemc.com]
Sent: Thursday, February 18, 2016 11:13 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Dennis is 100% right. The exemption applies exclusively to products which are 
industrial, commercial, or medical test equipment.  The "test equipment" 
classification applies to all of these categories, not only medical devices - 
at least this is my interpretation.  So if the digital device is not test 
equipment, the exemption does not apply.  If the exemption applies, it only 
pertains to the technical requirements of Part 15.  The general operation 
requirements of 15.5 always apply. As to the Class A/B application, you have to 
look at how the device is marketed. If it is not marketed to the consumer and 
is not intended to be used in the home, then Class A applies.

Bill Stumpf


From: dward 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[dward]

The FCC defines test equipment as “equipment that is intended primarily for 
purposes of performing measurements or scientific investigations. Such 
equipment includes, but is not limited to, field strength meters, spectrum 
analyzers, and modulation monitors.”

 

​The inquirer stated the device is an “industrial personal computer…” which 
is wrong.  First off, there is no such thing as an ‘industrial personal 
computer’ as the FCC defines personal computer (industrial or otherwise) as “an 
electronic computer that is marketed for use in the home, notwithstanding 
business applications. Such computers are considered Class B digital devices.”  
So, even if used in a business or industrial environment, it is still a 
Personal Computer subject to Part 15 Class B.  

 

Perhaps it is meant that the device is a ‘business computer used in an 
industrial plant…”  Then it would be class A, but it is still a computer (i.e. 
a Digital Device, previously called a ‘computing device’ by the FCC).  NOTE:  
The term ‘Digital Device’ defined by the FCC is “An unintentional radiator 
(device or system) that generates and uses timing signals or pulses at a rate 
in excess of 9,000 pulses (cycles) per second and uses digital techniques; 
inclusive of telephone equipment that uses digital techniques or any device or 
system that generates and uses radio frequency energy for the purpose of 
performing data processing functions, such as electronic computations, 
operations, transformations, recording, filing, sorting, storage, retrieval, or 
transfer.”  

 

While the specific computer may be used in an industrial environment for 
measurement purposes, unless it is manufactured so that only measurement can be 
done and it makes those measurements without use of other ‘test equipment’, the 
primary purpose would fit a Class A Digital Device as defined and thus is still 
subject to Part 15 rules.

 

So, while a piece of test equipment may contain a digital device and be exempt 
under 15.103c or d, the device in question would not seem to fit the definition 
of test equipment as its purpose is a computer used in the measurement process. 
 Trying to make this a piece of test equipment would be the same as a test lab 
trying to say the computer connected to the analyzer which records and 
processes data from that analyzer is a piece of test equipment.  The analyzer 
is the test equipment, and even if the device can be programmed to record 
measurement data from a piece of test equipment to which it is connected (i.e. 
the analyzer of power meter), its primary purpose still fits the definition of 
a Digital Device (Computing Device) as it performs data processing functions, 
electronic calculations etc, and not actual measurements.  Consequently, 
subject to the rules under Part 15 for either Class A or B depending on other 
uses.

 

Thanks 

 

Dennis Ward

This communication and its attachements 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 attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] 
Sent: Thursday, February 18, 2016 10:04 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

There is an intriguing aspect of Michaels original question. He states the 
object is an “industrial personal computer in an industrial plant for 
measurement purposes.” There seems to be significant ambiguity related to what 
“test” means in 15.103c… particularly, is it to mean A. test device for other 
equipment (such as an oscilloscope), or B. anything that tests another object 
(such as a camera attached to a computer that does dimensional analysis of work 
pieces as they pass by) or both? There may even be a third possibility, and 
that is C. test in the sense of prototype. 

 

I have seen A defended as the correct reading because it implies there is other 
equipment ‘in the equation’ that might be opened or in a state of failure when 
the test equipment is being used and so it make sense to carve out the 
exemption. 

 

I have seen B defended in some contexts by the FCC such as a test noise source 
in an anechoic chamber, and I have received FCC guidance by email also 
supporting this idea.  

 

However, I have not been able to find a definitive public guidance statement 
from the FCC 

 

The definition given for test equipment 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Kunde, Brian]

I don’t think the answer can be found chapter and verse from some standard, but 
look at the historical evidence.  Any electrical equipment, no matter what it 
is or what it does, what it is initially used for or how it is marketed, if it 
is likely to end up in homes or used in residential areas then it must meet the 
Class B requirements.

Years ago, computers sold to the military only had to be Class A. But when old 
computers were replaced with new ones, the old ones found their way into 
people’s home. So now all computers have to be Class B.

Computers with a Network Card used to only have to be Class A because “no one 
would ever use a network at home”.  But, as soon as it became common for people 
to have home networks, computers and network cards had to meet Class B.

So, if you use a stand-a-lone PC with an industrial device which can 
practically be used in homes, then the PC would have to meet Class B.

Our company uses PCs with our products which are considered “Laboratory 
Equipment”. Our products only have to meet the Class A requirements, but the 
PCs have to meet Class B because no matter how we use it or what environment we 
use it, it is still a PC and could end up in someone’s home.

I hope this was helpful.

The Other Brian

From: Ken Javor [mailto:ken.ja...@emccompliance.com]
Sent: Thursday, February 18, 2016 1:24 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Again I’m posing questions/observations, not acting as an expert, but it seems 
to me that a stand-alone computer, regardless of its purpose in a specific 
application, is not test equipment. By stand-alone, I mean not a PC embedded in 
a piece of test equipment.

Ken Javor
Phone: (256) 650-5261


From: Bill Stumpf >
Reply-To: Bill Stumpf >
Date: Thu, 18 Feb 2016 17:13:21 +
To: >
Conversation: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Dennis is 100% right. The exemption applies exclusively to products which are 
industrial, commercial, or medical test equipment.  The "test equipment" 
classification applies to all of these categories, not only medical devices - 
at least this is my interpretation.  So if the digital device is not test 
equipment, the exemption does not apply.  If the exemption applies, it only 
pertains to the technical requirements of Part 15.  The general operation 
requirements of 15.5 always apply. As to the Class A/B application, you have to 
look at how the device is marketed. If it is not marketed to the consumer and 
is not intended to be used in the home, then Class A applies.

Bill Stumpf



From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, February 18, 2016 11:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

In addition to the previous comment I made, it is noted that the FCC defines 
ISM equipment as “Equipment or appliances designed to generate and use locally 
RF energy for industrial, scientific, medical, domestic or similar purposes, 
excluding applications in the field of telecommunication.”  So, unless a 
digital device meets the exemption requirements 15.103 and if it is not a piece 
of test equipment, it is subject to Part 15.  Now then you must look to see if 
it is Class A or Class B.


​
Dennis Ward
This communication and its attachements 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 attachments(s) are free from computer virus or other defect.  Thank you.


From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, February 18, 2016 8:46 AM
To: 'Ted Eckert' >; 
'EMC-PSTC@LISTSERV.IEEE.ORG' 
>
Subject: RE: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Several issues.  First, 15.123 is not the clause exempting devices it is a 
clause referring to labeling of digital ready devices.

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Douglas Nix]

I cannot speak to the FCC requirements, however, I can say that the Industry 
Canada requirements apply, although they are seldom enforced in the industrial 
sector. Enforcement is usually done on a complaints basis only.

Doug Nix
d...@ieee.org 


> On 18-Feb-16, at 13:04, Crane, Lauren  wrote:
> 
> There is an intriguing aspect of Michaels original question. He states the 
> object is an “industrial personal computer in an industrial plant for 
> measurement purposes.” There seems to be significant ambiguity related to 
> what “test” means in 15.103c… particularly, is it to mean A. test device for 
> other equipment (such as an oscilloscope), or B. anything that tests another 
> object (such as a camera attached to a computer that does dimensional 
> analysis of work pieces as they pass by) or both? There may even be a third 
> possibility, and that is C. test in the sense of prototype.
>  
> I have seen A defended as the correct reading because it implies there is 
> other equipment ‘in the equation’ that might be opened or in a state of 
> failure when the test equipment is being used and so it make sense to carve 
> out the exemption.
>  
> I have seen B defended in some contexts by the FCC such as a test noise 
> source in an anechoic chamber, and I have received FCC guidance by email also 
> supporting this idea.  
>  
> However, I have not been able to find a definitive public guidance statement 
> from the FCC
>  
> The definition given for test equipment does not resolve the ambiguity – 
> “Test equipment” is “equipment that is intended primarily for purposes of 
> performing measurements or scientific investigations [and] includes, but is 
> not limited to, field strength meters, spectrum analyzers, and modulation 
> monitors.”
>  
> It also seems important that the language of FCC is in terms of ‘devices’ 
> more often than ‘products’ or ‘equipment’, thus a product or equipment might 
> contain several devices each of which must have their particular FCC concerns 
> addressed.
>  
> Regards,
> Lauren Crane
>  
> KLA-Tencor
> Public | Unrestricted
>  
> From: Bill Stumpf [mailto:bstu...@dlsemc.com] 
> Sent: Thursday, February 18, 2016 11:13 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
> for an industrial personal computer?
>  
> Dennis is 100% right. The exemption applies exclusively to products which are 
> industrial, commercial, or medical test equipment.  The "test equipment" 
> classification applies to all of these categories, not only medical devices - 
> at least this is my interpretation.  So if the digital device is not test 
> equipment, the exemption does not apply.  If the exemption applies, it only 
> pertains to the technical requirements of Part 15.  The general operation 
> requirements of 15.5 always apply. As to the Class A/B application, you have 
> to look at how the device is marketed. If it is not marketed to the consumer 
> and is not intended to be used in the home, then Class A applies. 
>  
> Bill Stumpf
>  
>  
> From: dward [mailto:dw...@pctestlab.com ] 
> Sent: Thursday, February 18, 2016 11:06 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG 
> Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
> for an industrial personal computer?
>  
> In addition to the previous comment I made, it is noted that the FCC defines 
> ISM equipment as “Equipment or appliances designed to generate and use 
> locally RF energy for industrial, scientific, medical, domestic or similar 
> purposes, excluding applications in the field of telecommunication.”  So, 
> unless a digital device meets the exemption requirements 15.103 and if it is 
> not a piece of test equipment, it is subject to Part 15.  Now then you must 
> look to see if it is Class A or Class B.  <>
>  
> ​
> Dennis Ward
> This communication and its attachements 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 attachments(s) are free from computer virus or other 
> defect.  Thank you.
>  
> From: dward [mailto:dw...@pctestlab.com ] 
> Sent: Thursday, February 18, 2016 8:46 AM
> To: 'Ted Eckert'  >; 'EMC-PSTC@LISTSERV.IEEE.ORG' 
> >
> 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Ken Javor]

Again I’m posing questions/observations, not acting as an expert, but it
seems to me that a stand-alone computer, regardless of its purpose in a
specific application, is not test equipment. By stand-alone, I mean not a PC
embedded in a piece of test equipment.

Ken Javor
Phone: (256) 650-5261



From: Bill Stumpf 
Reply-To: Bill Stumpf 
Date: Thu, 18 Feb 2016 17:13:21 +
To: 
Conversation: [PSES] 47 CFR Part 15 Subpart B / ICES-003
applicable/mandatory for an industrial personal computer?
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory
for an industrial personal computer?

Dennis is 100% right. The exemption applies exclusively to products which
are industrial, commercial, or medical test equipment.  The "test equipment"
classification applies to all of these categories, not only medical devices
- at least this is my interpretation.  So if the digital device is not test
equipment, the exemption does not apply.  If the exemption applies, it only
pertains to the technical requirements of Part 15.  The general operation
requirements of 15.5 always apply. As to the Class A/B application, you have
to look at how the device is marketed. If it is not marketed to the consumer
and is not intended to be used in the home, then Class A applies.
 
Bill Stumpf
 
 

From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, February 18, 2016 11:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory
for an industrial personal computer?
 
In addition to the previous comment I made, it is noted that the FCC defines
ISM equipment as “Equipment or appliances designed to generate and use
locally RF energy for industrial, scientific, medical, domestic or similar
purposes, excluding applications in the field of telecommunication.”  So,
unless a digital device meets the exemption requirements 15.103 and if it is
not a piece of test equipment, it is subject to Part 15.  Now then you must
look to see if it is Class A or Class B.
 

​
Dennis Ward
This communication and its attachements 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 attachments(s) are free from computer virus or other
defect.  Thank you.
 

From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, February 18, 2016 8:46 AM
To: 'Ted Eckert' ; 'EMC-PSTC@LISTSERV.IEEE.ORG'

Subject: RE: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory
for an industrial personal computer?
 
Several issues.  First, 15.123 is not the clause exempting devices it is a
clause referring to labeling of digital ready devices.
 
Clause 15.103 is for exemption of devices. So, while it may say exempt,
unintentional radiator devices are still subject to 15.5 and 15.29 with
‘strong’ recommendation to comply to part 15.  (NOTE: 15.5b states
“Operation of an intentional, unintentional, or incidental radiator is
subject to the conditions that no harmful interference is caused and that
interference must be accepted that may be caused by the operation of an
authorized radio station, by another intentional or unintentional radiator,
by industrial, scientific and medical (ISM) equipment, or by an incidental
radiator.”   15.103 main paragraph states, “Although not mandatory, it is
strongly recommended that the manufacturer of an exempted device endeavor to
have the device meet the specific technical standards in this part.”  So to
say there are no mandatory EMC requirements is not accurate, as, while being
exempt from any specific technical requirement, they are required NOT to
interfere etc.  
 
It should also be noted that this exemption is ONLY for test equipment, not
all digital equipment.  NOTE: 15.103c says “​A digital device used
exclusively as industrial, commercial, or medical test equipment.”   It is
not saying a piece of medical test equipment and all other industrial or
commercial equipment.  It is saying industrial test equipment, commercial
test equipment or medical test equipment.
 

Also, be careful with the concept of fixed in regards exclusive use in these
areas to exemption under 15.103.  Exclusive does not mean fixed, it simply
means that it is the ONLY area in which it is used, it means it cannot be
taken out of the industrial, commercial or medical environment.  I would
think that test equipment would not be fixed and since the exemption 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Crane, Lauren]

There is an intriguing aspect of Michaels original question. He states the 
object is an “industrial personal computer in an industrial plant for 
measurement purposes.” There seems to be significant ambiguity related to what 
“test” means in 15.103c… particularly, is it to mean A. test device for other 
equipment (such as an oscilloscope), or B. anything that tests another object 
(such as a camera attached to a computer that does dimensional analysis of work 
pieces as they pass by) or both? There may even be a third possibility, and 
that is C. test in the sense of prototype.

I have seen A defended as the correct reading because it implies there is other 
equipment ‘in the equation’ that might be opened or in a state of failure when 
the test equipment is being used and so it make sense to carve out the 
exemption.

I have seen B defended in some contexts by the FCC such as a test noise source 
in an anechoic chamber, and I have received FCC guidance by email also 
supporting this idea.

However, I have not been able to find a definitive public guidance statement 
from the FCC

The definition given for test equipment does not resolve the ambiguity – “Test 
equipment” is “equipment that is intended primarily for purposes of performing 
measurements or scientific investigations [and] includes, but is not limited 
to, field strength meters, spectrum analyzers, and modulation monitors.”

It also seems important that the language of FCC is in terms of ‘devices’ more 
often than ‘products’ or ‘equipment’, thus a product or equipment might contain 
several devices each of which must have their particular FCC concerns addressed.

Regards,
Lauren Crane

KLA-Tencor
Public | Unrestricted

From: Bill Stumpf [mailto:bstu...@dlsemc.com]
Sent: Thursday, February 18, 2016 11:13 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Dennis is 100% right. The exemption applies exclusively to products which are 
industrial, commercial, or medical test equipment.  The "test equipment" 
classification applies to all of these categories, not only medical devices - 
at least this is my interpretation.  So if the digital device is not test 
equipment, the exemption does not apply.  If the exemption applies, it only 
pertains to the technical requirements of Part 15.  The general operation 
requirements of 15.5 always apply. As to the Class A/B application, you have to 
look at how the device is marketed. If it is not marketed to the consumer and 
is not intended to be used in the home, then Class A applies.

Bill Stumpf


From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, February 18, 2016 11:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

In addition to the previous comment I made, it is noted that the FCC defines 
ISM equipment as “Equipment or appliances designed to generate and use locally 
RF energy for industrial, scientific, medical, domestic or similar purposes, 
excluding applications in the field of telecommunication.”  So, unless a 
digital device meets the exemption requirements 15.103 and if it is not a piece 
of test equipment, it is subject to Part 15.  Now then you must look to see if 
it is Class A or Class B.

​
Dennis Ward
This communication and its attachements 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 attachments(s) are free from computer virus or other defect.  Thank you.

From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, February 18, 2016 8:46 AM
To: 'Ted Eckert' >; 
'EMC-PSTC@LISTSERV.IEEE.ORG' 
>
Subject: RE: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Several issues.  First, 15.123 is not the clause exempting devices it is a 
clause referring to labeling of digital ready devices.

Clause 15.103 is for exemption of devices.  So, while it may say exempt, 
unintentional radiator devices are still subject to 15.5 and 15.29 with 
‘strong’ recommendation to comply to part 15.  (NOTE: 15.5b states “Operation 
of an intentional, unintentional, or incidental radiator is subject to the 
conditions that no harmful interference is caused and that interference 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Bill Stumpf]

Dennis is 100% right. The exemption applies exclusively to products which are 
industrial, commercial, or medical test equipment.  The "test equipment" 
classification applies to all of these categories, not only medical devices - 
at least this is my interpretation.  So if the digital device is not test 
equipment, the exemption does not apply.  If the exemption applies, it only 
pertains to the technical requirements of Part 15.  The general operation 
requirements of 15.5 always apply. As to the Class A/B application, you have to 
look at how the device is marketed. If it is not marketed to the consumer and 
is not intended to be used in the home, then Class A applies.

Bill Stumpf


From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, February 18, 2016 11:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

In addition to the previous comment I made, it is noted that the FCC defines 
ISM equipment as “Equipment or appliances designed to generate and use locally 
RF energy for industrial, scientific, medical, domestic or similar purposes, 
excluding applications in the field of telecommunication.”  So, unless a 
digital device meets the exemption requirements 15.103 and if it is not a piece 
of test equipment, it is subject to Part 15.  Now then you must look to see if 
it is Class A or Class B.

​
Dennis Ward
This communication and its attachements 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 attachments(s) are free from computer virus or other defect.  Thank you.

From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, February 18, 2016 8:46 AM
To: 'Ted Eckert' >; 
'EMC-PSTC@LISTSERV.IEEE.ORG' 
>
Subject: RE: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Several issues.  First, 15.123 is not the clause exempting devices it is a 
clause referring to labeling of digital ready devices.

Clause 15.103 is for exemption of devices.  So, while it may say exempt, 
unintentional radiator devices are still subject to 15.5 and 15.29 with 
‘strong’ recommendation to comply to part 15.  (NOTE: 15.5b states “Operation 
of an intentional, unintentional, or incidental radiator is subject to the 
conditions that no harmful interference is caused and that interference must be 
accepted that may be caused by the operation of an authorized radio station, by 
another intentional or unintentional radiator, by industrial, scientific and 
medical (ISM) equipment, or by an incidental radiator.”   15.103 main paragraph 
states, “Although not mandatory, it is strongly recommended that the 
manufacturer of an exempted device endeavor to have the device meet the 
specific technical standards in this part.”  So to say there are no mandatory 
EMC requirements is not accurate, as, while being exempt from any specific 
technical requirement, they are required NOT to interfere etc.

It should also be noted that this exemption is ONLY for test equipment, not all 
digital equipment.  NOTE: 15.103c says “​A digital device used exclusively 
as industrial, commercial, or medical test equipment.”   It is not saying a 
piece of medical test equipment and all other industrial or commercial 
equipment.  It is saying industrial test equipment, commercial test equipment 
or medical test equipment.

Also, be careful with the concept of fixed in regards exclusive use in these 
areas to exemption under 15.103.  Exclusive does not mean fixed, it simply 
means that it is the ONLY area in which it is used, it means it cannot be taken 
out of the industrial, commercial or medical environment.  I would think that 
test equipment would not be fixed and since the exemption for digital devices 
in these areas is for test equipment, I doubt if it means fixed.

Thanks
Dennis Ward
This communication and its attachements 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 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[dward]

In addition to the previous comment I made, it is noted that the FCC defines 
ISM equipment as “Equipment or appliances designed to generate and use locally 
RF energy for industrial, scientific, medical, domestic or similar purposes, 
excluding applications in the field of telecommunication.”  So, unless a 
digital device meets the exemption requirements 15.103 and if it is not a piece 
of test equipment, it is subject to Part 15.  Now then you must look to see if 
it is Class A or Class B.  

 

​

Dennis Ward

This communication and its attachements 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 attachments(s) are free from computer virus or other defect.  Thank you.

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Thursday, February 18, 2016 8:46 AM
To: 'Ted Eckert' ; 'EMC-PSTC@LISTSERV.IEEE.ORG' 

Subject: RE: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

Several issues.  First, 15.123 is not the clause exempting devices it is a 
clause referring to labeling of digital ready devices.  

 

Clause 15.103 is for exemption of devices.  So, while it may say exempt, 
unintentional radiator devices are still subject to 15.5 and 15.29 with 
‘strong’ recommendation to comply to part 15.  (NOTE: 15.5b states “Operation 
of an intentional, unintentional, or incidental radiator is subject to the 
conditions that no harmful interference is caused and that interference must be 
accepted that may be caused by the operation of an authorized radio station, by 
another intentional or unintentional radiator, by industrial, scientific and 
medical (ISM) equipment, or by an incidental radiator.”   15.103 main paragraph 
states, “Although not mandatory, it is strongly recommended that the 
manufacturer of an exempted device endeavor to have the device meet the 
specific technical standards in this part.”  So to say there are no mandatory 
EMC requirements is not accurate, as, while being exempt from any specific 
technical requirement, they are required NOT to interfere etc.  

 

It should also be noted that this exemption is ONLY for test equipment, not all 
digital equipment.  NOTE: 15.103c says “​A digital device used exclusively 
as industrial, commercial, or medical test equipment.”   It is not saying a 
piece of medical test equipment and all other industrial or commercial 
equipment.  It is saying industrial test equipment, commercial test equipment 
or medical test equipment.

 

Also, be careful with the concept of fixed in regards exclusive use in these 
areas to exemption under 15.103.  Exclusive does not mean fixed, it simply 
means that it is the ONLY area in which it is used, it means it cannot be taken 
out of the industrial, commercial or medical environment.  I would think that 
test equipment would not be fixed and since the exemption for digital devices 
in these areas is for test equipment, I doubt if it means fixed.

 

Thanks 

Dennis Ward

This communication and its attachements 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 attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ted Eckert [mailto:ted.eck...@microsoft.com] 
Sent: Thursday, February 18, 2016 6:37 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

Hello Michael,

 

Whether or not EMC requirement apply in North America may depend on whether the 
industrial computer is in a fixed location. Digital devices that are part of 
industrial equipment are generally exempted. Incorporated devices are fixed in 
location and there is a general assumption that the environment is such that 
residential radio receivers, such as televisions, will not be within 3 meters 
of the equipment.

 

A personal computer 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[dward]

Several issues.  First, 15.123 is not the clause exempting devices it is a 
clause referring to labeling of digital ready devices.  

 

Clause 15.103 is for exemption of devices.  So, while it may say exempt, 
unintentional radiator devices are still subject to 15.5 and 15.29 with 
‘strong’ recommendation to comply to part 15.  (NOTE: 15.5b states “Operation 
of an intentional, unintentional, or incidental radiator is subject to the 
conditions that no harmful interference is caused and that interference must be 
accepted that may be caused by the operation of an authorized radio station, by 
another intentional or unintentional radiator, by industrial, scientific and 
medical (ISM) equipment, or by an incidental radiator.”   15.103 main paragraph 
states, “Although not mandatory, it is strongly recommended that the 
manufacturer of an exempted device endeavor to have the device meet the 
specific technical standards in this part.”  So to say there are no mandatory 
EMC requirements is not accurate, as, while being exempt from any specific 
technical requirement, they are required NOT to interfere etc.  

 

It should also be noted that this exemption is ONLY for test equipment, not all 
digital equipment.  NOTE: 15.103c says “​A digital device used exclusively 
as industrial, commercial, or medical test equipment.”   It is not saying a 
piece of medical test equipment and all other industrial or commercial 
equipment.  It is saying industrial test equipment, commercial test equipment 
or medical test equipment.

 

Also, be careful with the concept of fixed in regards exclusive use in these 
areas to exemption under 15.103.  Exclusive does not mean fixed, it simply 
means that it is the ONLY area in which it is used, it means it cannot be taken 
out of the industrial, commercial or medical environment.  I would think that 
test equipment would not be fixed and since the exemption for digital devices 
in these areas is for test equipment, I doubt if it means fixed.

 

Thanks 

Dennis Ward

This communication and its attachements 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 attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ted Eckert [mailto:ted.eck...@microsoft.com] 
Sent: Thursday, February 18, 2016 6:37 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

Hello Michael,

 

Whether or not EMC requirement apply in North America may depend on whether the 
industrial computer is in a fixed location. Digital devices that are part of 
industrial equipment are generally exempted. Incorporated devices are fixed in 
location and there is a general assumption that the environment is such that 
residential radio receivers, such as televisions, will not be within 3 meters 
of the equipment.

 

A personal computer that has been ruggedized for use in industrial environments 
may still be subject to EMC requirements if it is movable. An industrial 
laptop, for example, may be used in a factory part of the time and in an office 
environment the rest of the time. 

 

I believe the key word is “exclusively” in the regulation you quoted. For a 
device to be exempted, it must be designed and marketed such that it is 
reasonably expected it will only be used in industrial environments.

 

Best regards,

Ted Eckert

Microsoft Corporation

 

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

 

 

From: loerzer_mob...@globalnorm.de   
[mailto:loerzer_mob...@globalnorm.de] 
Sent: Thursday, February 18, 2016 2:09 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an 
industrial personal computer?

 

Hi,

 

I am sorry if my question was answered anytime before. Nevertheless here my 
question:

 

An European manufacturer has applied EN 61326-1 and EN 61010-1 for an 
industrial personal computer in an industrial plant for measurement purposes.

 

What are the mandatory requirements regarding EMC in US/Canada?

 

Is ICES-003 mandatory for Canada? If not in my understanding ICES-001 is also 
not applicable.

Is § 15.123 "exempted devices" (A digital device used exclusively as 
industrial, commercial, or medical test equipment.) for US applicable?  If yes, 
47 CFR Part 18 is in my opion also 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Larry K. Stillings]

Ken,

 

I think FCC Document OET 62 from the 1990's gives a pretty good overview of the 
classes, exemptions etc. Instead of me just reciting it, you can read it here

 

https://transition.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet62/oet62rev.pdf

 

Larry K. Stillings
Compliance Worldwide, Inc. 
Test Locally, Sell Globally and Launch Your Products Around the World! 
FCC - Wireless - Telecom - CE Marking - International Approvals - Product 
Safety 
357 Main Street
Sandown, NH 03873
(603) 887 3903 Fax 887-6445
www.complianceworldwide.com

Privileged/Confidential Information may be contained in this message. If you 
are not the addressee indicated in this message (or responsible for delivery of 
the message to such person), you may not copy or deliver this message to 
anyone. In such case, you should destroy this message and kindly notify the 
sender by reply email. Please advise immediately if you or your employer do not 
consent to Internet email for messages of this kind. Opinions, conclusions and 
other information in this message that do not relate to the official business 
of my firm shall be understood as neither given nor endorsed by it.

 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Thursday, February 18, 2016 11:27 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

 

Can anyone else chime in?

I thought the the whole point of Class A was unintentional radiators that could 
not be used residentially, i.e., only in an office or plant environment, and 
thus would be directly applicable to the situation described in the original 
post.

Ken Javor
Phone: (256) 650-5261





From: Ted Eckert 
Reply-To: Ted Eckert 
Date: Thu, 18 Feb 2016 15:42:58 +
To: 
Conversation: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

I believe unintentional radiators are exempted. Intentional radiators would not 
be exempted. My company uses the term "EMC" primarily for CISPR 22/24 (or 
CISPRT 32/35) compliance and uses the term "radio" for intentional radiators. I 
instinctively responded to the original question about "EMC" without thinking 
about the more general context of this list server.
 

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.
 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Thursday, February 18, 2016 7:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

I have to ask, not as an expert on this topic, but just because the below is 
not my understanding, such as it is. I thought that Class A covered digital 
equipment as an unintentional radiator if the device could manifestly not be 
used in a residential setting. That would seem to cover office and plant 
environments. I don't see why there would be an exemption against Class A for 
something used in an industrial environment?

Ken Javor
Phone: (256) 650-5261



From: Ted Eckert 
Reply-To: Ted Eckert 
Date: Thu, 18 Feb 2016 14:37:22 +
To: 
Conversation: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Hello Michael,
 
Whether or not EMC requirement apply in North America may depend on whether the 
industrial computer is in a fixed location. Digital devices that are part of 
industrial equipment are generally exempted. Incorporated devices are fixed in 
location and there is a general assumption that the environment is such that 
residential radio receivers, such as televisions, will not be within 3 meters 
of the equipment.
 
A personal computer that has been ruggedized for use in industrial environments 
may still be subject to EMC requirements if it is movable. An industrial 
laptop, for example, may be used in a factory part of the time and in an office 
environment the rest of the time. 
 
I believe the key word is "exclusively" in the regulation you quoted. For a 
device to be exempted, it must be designed and marketed such that it is 
reasonably expected it will only be used in industrial environments.
 
Best regards,
Ted Eckert
Microsoft Corporation
 
The opinions expressed are my own and do not necessarily reflect those of my 
employer.
 
 

From: 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Ken Javor]

Can anyone else chime in?

I thought the the whole point of Class A was unintentional radiators that
could not be used residentially, i.e., only in an office or plant
environment, and thus would be directly applicable to the situation
described in the original post.

Ken Javor
Phone: (256) 650-5261



From: Ted Eckert 
Reply-To: Ted Eckert 
Date: Thu, 18 Feb 2016 15:42:58 +
To: 
Conversation: [PSES] 47 CFR Part 15 Subpart B / ICES-003
applicable/mandatory for an industrial personal computer?
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory
for an industrial personal computer?

I believe unintentional radiators are exempted. Intentional radiators would
not be exempted. My company uses the term ³EMC² primarily for CISPR 22/24
(or CISPRT 32/35) compliance and uses the term ³radio² for intentional
radiators. I instinctively responded to the original question about ³EMC²
without thinking about the more general context of this list server.
 

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.
 

From: Ken Javor [mailto:ken.ja...@emccompliance.com]
Sent: Thursday, February 18, 2016 7:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory
for an industrial personal computer?
 
I have to ask, not as an expert on this topic, but just because the below is
not my understanding, such as it is. I thought that Class A covered digital
equipment as an unintentional radiator if the device could manifestly not be
used in a residential setting. That would seem to cover office and plant
environments. I don¹t see why there would be an exemption against Class A
for something used in an industrial environment?

Ken Javor
Phone: (256) 650-5261


From: Ted Eckert 
Reply-To: Ted Eckert 
Date: Thu, 18 Feb 2016 14:37:22 +
To: 
Conversation: [PSES] 47 CFR Part 15 Subpart B / ICES-003
applicable/mandatory for an industrial personal computer?
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory
for an industrial personal computer?

Hello Michael,
 
Whether or not EMC requirement apply in North America may depend on whether
the industrial computer is in a fixed location. Digital devices that are
part of industrial equipment are generally exempted. Incorporated devices
are fixed in location and there is a general assumption that the environment
is such that residential radio receivers, such as televisions, will not be
within 3 meters of the equipment.
 
A personal computer that has been ruggedized for use in industrial
environments may still be subject to EMC requirements if it is movable. An
industrial laptop, for example, may be used in a factory part of the time
and in an office environment the rest of the time.
 
I believe the key word is ³exclusively² in the regulation you quoted. For a
device to be exempted, it must be designed and marketed such that it is
reasonably expected it will only be used in industrial environments.
 
Best regards,
Ted Eckert
Microsoft Corporation
 
The opinions expressed are my own and do not necessarily reflect those of my
employer.
 
 

From: loerzer_mob...@globalnorm.de [mailto:loerzer_mob...@globalnorm.de]
Sent: Thursday, February 18, 2016 2:09 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for
an industrial personal computer?


Hi,

 

I am sorry if my question was answered anytime before. Nevertheless here my
question:

 

An European manufacturer has applied EN 61326-1 and EN 61010-1 for an
industrial personal computer in an industrial plant for measurement
purposes.

 

What are the mandatory requirements regarding EMC in US/Canada?

 

Is ICES-003 mandatory for Canada? If not in my understanding ICES-001 is
also not applicable.

Is § 15.123 "exempted devices" (A digital device used exclusively as
industrial, commercial, or medical test equipment.) for US applicable?  If
yes, 47 CFR Part 18 is in my opion also not applicable.

 

Therefore NO mandatory EMC requirements for equipment which are in the scope
of EN 61326-1 are existing in US/Canada?

 

Thanks for comments in advance.

 

Michael
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Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Ted Eckert]

I believe unintentional radiators are exempted. Intentional radiators would not 
be exempted. My company uses the term "EMC" primarily for CISPR 22/24 (or 
CISPRT 32/35) compliance and uses the term "radio" for intentional radiators. I 
instinctively responded to the original question about "EMC" without thinking 
about the more general context of this list server.

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.

From: Ken Javor [mailto:ken.ja...@emccompliance.com]
Sent: Thursday, February 18, 2016 7:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

I have to ask, not as an expert on this topic, but just because the below is 
not my understanding, such as it is. I thought that Class A covered digital 
equipment as an unintentional radiator if the device could manifestly not be 
used in a residential setting. That would seem to cover office and plant 
environments. I don't see why there would be an exemption against Class A for 
something used in an industrial environment?

Ken Javor
Phone: (256) 650-5261


From: Ted Eckert >
Reply-To: Ted Eckert >
Date: Thu, 18 Feb 2016 14:37:22 +
To: >
Conversation: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory 
for an industrial personal computer?

Hello Michael,

Whether or not EMC requirement apply in North America may depend on whether the 
industrial computer is in a fixed location. Digital devices that are part of 
industrial equipment are generally exempted. Incorporated devices are fixed in 
location and there is a general assumption that the environment is such that 
residential radio receivers, such as televisions, will not be within 3 meters 
of the equipment.

A personal computer that has been ruggedized for use in industrial environments 
may still be subject to EMC requirements if it is movable. An industrial 
laptop, for example, may be used in a factory part of the time and in an office 
environment the rest of the time.

I believe the key word is "exclusively" in the regulation you quoted. For a 
device to be exempted, it must be designed and marketed such that it is 
reasonably expected it will only be used in industrial environments.

Best regards,
Ted Eckert
Microsoft Corporation

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



From: loerzer_mob...@globalnorm.de 
[mailto:loerzer_mob...@globalnorm.de]
Sent: Thursday, February 18, 2016 2:09 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an 
industrial personal computer?


Hi,



I am sorry if my question was answered anytime before. Nevertheless here my 
question:



An European manufacturer has applied EN 61326-1 and EN 61010-1 for an 
industrial personal computer in an industrial plant for measurement purposes.



What are the mandatory requirements regarding EMC in US/Canada?



Is ICES-003 mandatory for Canada? If not in my understanding ICES-001 is also 
not applicable.

Is § 15.123 "exempted devices" (A digital device used exclusively as 
industrial, commercial, or medical test equipment.) for US applicable?  If yes, 
47 CFR Part 18 is in my opion also not applicable.



Therefore NO mandatory EMC requirements for equipment which are in the scope of 
EN 61326-1 are existing in US/Canada?



Thanks for comments in advance.



Michael
-

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discussion list. To post a message to the list, send your e-mail to 
>

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Re: [PSES] grounding of output of solar inverter

[Brian Gregory]

 Brian is right;  all NEC rules apply to the installation.  In this case, the 
practical solution could be a sub-panel for the house loads that are served by 
the inverter, but there are several ways it could be done.  You are looking 
inside the inverter (and the inverter safety standard) for the solution.  Look 
outside the box. Colorado Brian

-- Original Message --
From: "Brian O'Connell" 
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] grounding of output of solar inverter
Date: Tue, 16 Feb 2016 17:27:37 +

Reference articles 250 and 690 of the NEC (NFPA70). Canada and Mexico code 
similar.

Brian

From: Botjan Glavi [mailto:bostjan.gla...@siq.si] 
Sent: Monday, February 15, 2016 9:05 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] grounding of output of solar inverter

Dear experts,

Is anyone familiar with UL 1741? I am dealing with solar inverter for US 
market. Solar inverter can operate in utility interactive mode (feeding the 
grid) or in a standalone mode where only homeloads are supplied by 
inverter (anti-islanding relays are open, due to problems with the grid). When 
anti-islanding relays are open, I have an issue of grounding the neutral 
conductor of output for homeloads. How can this grounding be achieved? Clause 
19.2 does not allow grounding inside the unit (or I have understood it 
incorrectly and it only prohibits fixed connection) and clause 19.3 requires 
that output is grounded. Below is extract from the standard.
Any idea? I think it is the same issue as with UPS.

19.2 An inverter intended to be utility-interactive shall not have a 
direct/solid electrical connection between any output ac conductor and the 
enclosure.

19.3 Other than as specified in 19.2, each ac output circuit shall have a 
grounded conductor. The ac output circuit conductor to be grounded shall be as 
follows:
a) Single-phase, 2-wire - one conductor.
b) Single-phase, 3-wire - the neutral conductor.
c) Multiphase system having one wire common to all phases - the common 
conductor.
d) Multiphase system in which one phase is used as in item (b) - the neutral 
conductor.

19.4 The conductor specified in 19.3 is to be connected by a bonding jumper 
connected between the grounded conductor and:
a) The enclosure of a metal-enclosed unit, or
b) For a nonmetallic enclosed unit, the metal chassis that is bonded to the 
equipment grounding
conductor or terminal. See 18.2.1.

Thank you for your support.

Best regards,
Bostjan

-

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discussion list. To post a message to the list, send your e-mail to 


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formats), large files, etc.

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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 


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
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For policy questions, send mail to:
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Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Ken Javor]

I have to ask, not as an expert on this topic, but just because the below is
not my understanding, such as it is. I thought that Class A covered digital
equipment as an unintentional radiator if the device could manifestly not be
used in a residential setting. That would seem to cover office and plant
environments. I don¹t see why there would be an exemption against Class A
for something used in an industrial environment?

Ken Javor
Phone: (256) 650-5261



From: Ted Eckert 
Reply-To: Ted Eckert 
Date: Thu, 18 Feb 2016 14:37:22 +
To: 
Conversation: [PSES] 47 CFR Part 15 Subpart B / ICES-003
applicable/mandatory for an industrial personal computer?
Subject: Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory
for an industrial personal computer?

Hello Michael,
 
Whether or not EMC requirement apply in North America may depend on whether
the industrial computer is in a fixed location. Digital devices that are
part of industrial equipment are generally exempted. Incorporated devices
are fixed in location and there is a general assumption that the environment
is such that residential radio receivers, such as televisions, will not be
within 3 meters of the equipment.
 
A personal computer that has been ruggedized for use in industrial
environments may still be subject to EMC requirements if it is movable. An
industrial laptop, for example, may be used in a factory part of the time
and in an office environment the rest of the time.
 
I believe the key word is ³exclusively² in the regulation you quoted. For a
device to be exempted, it must be designed and marketed such that it is
reasonably expected it will only be used in industrial environments.
 
Best regards,
Ted Eckert
Microsoft Corporation
 
The opinions expressed are my own and do not necessarily reflect those of my
employer.
 
 

From: loerzer_mob...@globalnorm.de [mailto:loerzer_mob...@globalnorm.de]
Sent: Thursday, February 18, 2016 2:09 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for
an industrial personal computer?
 

Hi,

 

I am sorry if my question was answered anytime before. Nevertheless here my
question:

 

An European manufacturer has applied EN 61326-1 and EN 61010-1 for an
industrial personal computer in an industrial plant for measurement
purposes.

 

What are the mandatory requirements regarding EMC in US/Canada?

 

Is ICES-003 mandatory for Canada? If not in my understanding ICES-001 is
also not applicable.

Is § 15.123 "exempted devices" (A digital device used exclusively as
industrial, commercial, or medical test equipment.) for US applicable?  If
yes, 47 CFR Part 18 is in my opion also not applicable.

 

Therefore NO mandatory EMC requirements for equipment which are in the scope
of EN 61326-1 are existing in US/Canada?

 

Thanks for comments in advance.

 

Michael
-

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


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html


Attachments are not permitted but the IEEE PSES Online Communities site at
http://product-compliance.oc.ieee.org/
  can be used for graphics (in well-used
formats), large files, etc.

Website: http://www.ieee-pses.org/

Instructions: http://www.ieee-pses.org/list.html (including how to
unsubscribe) 

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


For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

Re: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[Ted Eckert]

Hello Michael,

Whether or not EMC requirement apply in North America may depend on whether the 
industrial computer is in a fixed location. Digital devices that are part of 
industrial equipment are generally exempted. Incorporated devices are fixed in 
location and there is a general assumption that the environment is such that 
residential radio receivers, such as televisions, will not be within 3 meters 
of the equipment.

A personal computer that has been ruggedized for use in industrial environments 
may still be subject to EMC requirements if it is movable. An industrial 
laptop, for example, may be used in a factory part of the time and in an office 
environment the rest of the time.

I believe the key word is “exclusively” in the regulation you quoted. For a 
device to be exempted, it must be designed and marketed such that it is 
reasonably expected it will only be used in industrial environments.

Best regards,
Ted Eckert
Microsoft Corporation

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


From: loerzer_mob...@globalnorm.de [mailto:loerzer_mob...@globalnorm.de]
Sent: Thursday, February 18, 2016 2:09 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an 
industrial personal computer?

Hi,

I am sorry if my question was answered anytime before. Nevertheless here my 
question:

An European manufacturer has applied EN 61326-1 and EN 61010-1 for an 
industrial personal computer in an industrial plant for measurement purposes.

What are the mandatory requirements regarding EMC in US/Canada?

Is ICES-003 mandatory for Canada? If not in my understanding ICES-001 is also 
not applicable.
Is § 15.123 "exempted devices" (A digital device used exclusively as 
industrial, commercial, or medical test equipment.) for US applicable?  If yes, 
47 CFR Part 18 is in my opion also not applicable.

Therefore NO mandatory EMC requirements for equipment which are in the scope of 
EN 61326-1 are existing in US/Canada?

Thanks for comments in advance.

Michael
-


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 
>

All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/
 can be used for graphics (in well-used formats), large files, etc.

Website: 
http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including how to 
unsubscribe)
List rules: 
http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas >
Mike Cantwell >

For policy questions, send mail to:
Jim Bacher >
David Heald >

-

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 


All emc-pstc postings are archived and searchable on the web at:
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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:  

[PSES] 47 CFR Part 15 Subpart B / ICES-003 applicable/mandatory for an industrial personal computer?

[loerzer_mob...@globalnorm.de]

Hi,
 
I am sorry if my question was answered anytime before. Nevertheless here my
question:
 
An European manufacturer has applied EN 61326-1 and EN 61010-1 for an industrial
personal computer in an industrial plant for measurement purposes.
 
What are the mandatory requirements regarding EMC in US/Canada?
 
Is ICES-003 mandatory for Canada? If not in my understanding ICES-001 is also
not applicable.
Is § 15.123 "exempted devices" (A digital device used exclusively as industrial,
commercial, or medical test equipment.) for US applicable?  If yes, 47 CFR Part
18 is in my opion also not applicable.
 
Therefore NO mandatory EMC requirements for equipment which are in the scope of
EN 61326-1 are existing in US/Canada?
 
Thanks for comments in advance.
 
Michael

-

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 


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: