[PSES] Susceptible Immunity / Immune Susceptibility

[Ed Price]

Having dabbled in both the military and commercial markets of EMC, I had always 
heard the military define susceptibility and commercial define immunity. I 
assumed that the difference was solely in the eye of the beholder, either a 
pessimist or an optimist. Nobody wants to be susceptible while everyone wants 
to be immune.

Is there an issue of difference between the two terms, that they may have some 
intrinsic bias toward, or from, a point of view?

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

IEC/CISPR classes all of those as immunity.

 

With best wishes DESIGN IT IN! OOO – Own Opinions Only

  www.jmwa.demon.co.uk J M Woodgate and Associates 
Rayleigh England

Sylvae in aeternum manent.

 

 

-Original Message-

From: dward [  mailto:dw...@pctestlab.com]

Sent: Friday, September 30, 2016 7:26 PM

To:   EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Do not confuse susceptibility of interference with immunity such as ESD, Fast 
Transient, etc.   The susceptibility spoken of is that of Spectrum Protection, 
and the protection of licensed users, not ESD, RF immunity, etc.

Again, this is not immunity in the sense of radiated immunity, ESD, Fast 
Transient etc., but susceptibility only in regards to protection of the 
spectrum. 

 

Dennis Ward


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Re: [PSES] [RFI] Part 15 isn't enough..

[John Woodgate]

IEC/CISPR classes all of those as immunity.

With best wishes DESIGN IT IN! OOO – Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.


-Original Message-
From: dward [mailto:dw...@pctestlab.com] 
Sent: Friday, September 30, 2016 7:26 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Do not confuse susceptibility of interference with immunity such as ESD, Fast 
Transient, etc.   The susceptibility spoken of is that of Spectrum Protection, 
and the protection of licensed users, not ESD, RF immunity, etc.

And, the actual law states "(2) establishing minimum performance standards 
for home electronic equipment and systems to reduce their susceptibility to 
interference from radio frequency energy."  
But then that is the 1982 version. The Telecommunications Act of 1934 amended 
1996 is the current law in force, not the 1982.  Also, while irrelevant, the 
1982 law only changed a few phrases to better describe specific instances.  
Such as adding "or home electronic equipment and systems" after "devices", and 
adding who can train and who can give amateur license testing.
​
The relevant law (i.e. Telecommunications Act of 1934 as amended in 1996) says 
" The Commission may, consistent with the public interest, convenience, and 
necessity, make reasonable regulations (1) governing the interference potential 
of devices which in their operation are capable of emitting radio frequency 
energy by radiation, conduction, or other means in sufficient degree to cause 
harmful interference to radio communications; and (2) establishing minimum 
performance standards for home electronic equipment and systems to reduce their 
susceptibility to interference from radio frequency energy. Such regulations 
shall be applicable to the manufacture, import, sale, offer for sale, or 
shipment of such devices and home electronic equipment and systems, and to the 
use of such devices.

Again, this is not immunity in the sense of radiated immunity, ESD, Fast 
Transient etc., but susceptibility only in regards to protection of the 
spectrum. 


Dennis Ward
This communication and its attachements contain information from PCTEST 
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-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net]
Sent: Friday, September 30, 2016 10:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 1:03 PM, dward wrote:
> Nor will there ever be anything in the FCC rules about immunity simply 
> because that, as Gherry state, has nothing to do with the protection 
> of the Spectrum.

The FCC already has the authority it needs to require *some* RF immunity, and 
has since 1982:

http://www.arrl.org/public-law-97-259

excerpt:


The FCC has opted for voluntary standards, rather than formal rules and 
regulations. The FCC and the ARRL are both active in an industry group (in 
cooperation with the American National Standards Institute, ANSI) that is 
studying "RF immunity issues." The Accredited Standards Committee C-63, has set 
an RFI-rejection standard for certain home electronic equipment. The voluntary 
standard provides for immunity of consumer equipment to some levels of RF field 
strength. This standard is not sufficient for full-power amateur stations under 
"worst case" 
conditions, but it covers the majority of cases. Starting in the second half of 
the 1990s, consumers started to see some built-in immunity in consumer 
products. The industry has a ways to go, but there is some light at the end of 
the tunnel.


Cortland
ka5s

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For p

Re: [PSES] Percentage Fill of Electrical Raceway in Machinery

[Robert Johnson]

For communications circuits (includes voice and data circuits /from a 
communications utility), NFPA 70 article 800.110 (B) applies which says:/
*800.110 Raceways and Cable Routing Assemblies for Communications Wires 
and Cables.**

**(B) Raceway Fill for Communications Wires and Cables.*
"The raceway requirements of Chapters 3 and 9 shall not apply to 
communications wires and cables."


Most computer circuits begin consideration as Class 2  circuits for 
which no exemption for fill requirements seems to appear in 725.130 and 
its references, where I would expect it. However article 725.139(D)(1) 
reclassifies many of them saying:
*725.139 Installation of Conductors of Different Circuits in the Same 
Cable Enclosure, Cable Tray, Raceway , or Cable Routing Assembly.**

**(D) Class 2 and Class 3 Circuits with Communication Circuits.**
**(1) Classified as Communications Circuits.*
"Class 2 and Class 3 circuit conductors shall be permitted in the same 
cable with communications circuits, in which case the Class 2 and class 
3 circuits shall be reclassified as communications circuits and shall be 
installed in accordance with the requirements of Article 800. The cables 
shall be listed as communications cables.


However the fill limits of Chapter 9 Table 1, generally 40%, are good 
guidelines for practical installations and good workmanship. I would 
expect meeting them would be good design practice.


Bob Johnson

On 09/30/2016 01:48 PM, Ted Eckert wrote:


Hello Jim,

I believe the rationale for the limit is heat dissipation, although I 
am not 100% confident in this. Overfilling conduit, raceways or cable 
trays can prevent heat dissipation from conductors and would thus 
change the ampacity calculations required. Based on this, all 
conductors would be subject to the limit, not just power conductors. 
Signal and communication conductors may not add to the heating, but 
they could add thermal insulation. NFPA 70, the NEC, has an entire 
annex (Annex C) that covers the number of conductors allowed in 
conduit and tubing.


Many applications, and many parts of the NEC, prohibit low-voltage 
signaling or communication wires in the same conduit or raceway as 
line-voltage conductors. There are special circumstances where both 
types of conductors are allowed together, but this is not the normal 
application. As such, the code does not anticipate having to provide 
specifications for fill limits with both types of conductors together.


It’s been more than eight years since I worked with these issues 
regularly, so my information is a bit old. However, the code evolves 
slowly, and electrical inspectors’ interpretation of the code evolves 
even more slowly.


Ted Eckert

Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those 
of my employer, my previous employer, NFPA, IBEW, NAFI or OSHA.


*From:* Jim Hulbert [mailto:jim.hulb...@pb.com]
*Sent:* Friday, September 30, 2016 8:10 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] Percentage Fill of Electrical Raceway in Machinery

Greetings.

The U.S. Electrical Standard for Industrial Machinery NFPA 79 in 
13.5.2 states that total cross section area of all conductors and 
cables routed through a raceway or conduit can’t fill more than 50% of 
the cross section area of the raceway.  Does this requirement apply to 
ALL conductors, including low voltage signal or communication cables?  
I understand the rationale for high voltage/high current conductors 
but not for signal conductors.  However, the standard does not seem to 
differentiate.   EN60204-1 is similar to NFPA 79, but I don’t see the 
same restriction on raceway fill.


I have had an NRTL engineer cite a non-conformance for a raceway that 
was too full.  I argued that the cables were just low voltage signal 
cables but it didn’t make a difference to this engineer.  We ended up 
using a larger raceway.


Any thoughts?

*Jim Hulbert*



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Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

Ed

Regulations are not law.  The communication act of 1934 instituted the FCC and 
gave it authority to make regulations based on the law. That law was amended in 
1996.  The FCC cannot implement Law, it can however, implement regulations 
based on the actual law as long as those regulations are in accord with that 
law, and it can, to a certain extent, enforce those regulations through fines 
etc.

 

​

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: Ed Price [mailto:edpr...@cox.net] 
Sent: Friday, September 30, 2016 3:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Dennis:

 

Not true. Congress passes a Communications Act, a law, and it directs the FCC 
to implement that law. These Acts may stand for years or may be superseded with 
a new Act whenever Congress wants to write a new one. The FCC proposes Rules 
which it thinks will implement the spirit and letter of that Communications 
Act, and then the maneuvering begins. The FCC currently has no basis of law to 
“protect the consumer,” but if Congress wishes to do so, the FCC will be 
mandated, funded and expanded to enforce Congressional wishes.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Friday, September 30, 2016 10:04 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Nor will there ever be anything in the FCC rules about immunity simply because 
that, as Gherry state, has nothing to do with the protection of the Spectrum.

 

 

​

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: Friday, September 30, 2016 9:03 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

The intent of the quoted statute is simply to protect licensed users of the 
spectrum from unlicensed unintentional “poachers.”  The licensed user paid for 
their use of the spectrum, and any unlicensed “poacher” must cease and desist 
his use when it interferes with the operation of a licensed user. 

It also says that one unlicensed user has no protection from another unlicensed 
user, and certainly not from a licensed user.

Basically just laying out a “pecking order” in terms of rights to use the 
spectrum.

Nothing here about immunity at all.

Ken Javor
Phone: (256) 650-5261

  _  

From: "Paasche, Dieter" mailto:dieter.paas...@christiedigital.com> >
Reply-To: "Paasche, Dieter" mailto:dieter.paas...@christiedigital.com> >
Date: Fri, 30 Sep 2016 12:59:04 +
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Conversation: [PSES] [RFI] Part 15 isn't enough..
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately. 
 
Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.
 
And finally, isn’t FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)
§15.5   General conditions of operation.
(a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of any given 
frequency by virtue of prior registration or certification of equipment, or, 
for power line carrier systems, on the basis of prior notification of use 
pursuant to §9

Re: [PSES] [RFI] Part 15 isn't enough..

[john Allen]

Cortland

Given the legal and philosophical  "issues" in the USA, that sounds as if it 
MIGHT work - my latest take on this subject, as "discussed" today from both 
sides, is that suppliers and users of intentional emitters should not be 
immune(!) from legal action if they continue to cause interference to 
non-intentional emitters and their use by entirely "innocent" people going 
about their legal daily business and activities at work and at home. Again, 
what is good for the goose (intentional emitter suppliers/users) is good for 
the gander (the rest of the public).

Not a particularly "good" solution IMHO - but maybe the best you collectively 
can hope for at present, given the apparently "entrenched" position of many 
people in the US who oppose any concept of immunity/susceptibility testing for 
general public-use products :-(.

Unfortunately that approach still does not address the, probably widespread, 
issue of one non-intentional product interfering with another one - which, I 
would suggest, is probably the more widespread problem for many of the public 
but they don't know what the issues are or how to fix them. 

For example, in my own case, my first digital sat receiver (around 1998) 
suffered interference from other components in my AV system (and this was a 
quite widely reported problem as I recall), until, with some relevant 
background knowledge to help, I replaced all the old single screened RF 
connections with decent double screened sat-spec cable - most people would not 
know why/how to do that. However, since then, I (and presumably many other 
consumers!) have never suffered the same issues  as the newer receivers are far 
more resilient to external interference because the manufacturers have been 
compelled to comply with the EU immunity requirements!

John E Allen
W. London, UK





-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: 30 September 2016 21:04
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 2:16 PM, Ken Javor wrote:
> I still don't understand what the applicability is, but if that 
> statement about MIL-STD-461 applies to products to be sold 
> commercially, it has serious issues and drawbacks that make it utterly 
> impractical.

I suspect the choice of MIL-Standards was made to reduce emissions more than 
FCC rules require and thus increase the margin available to prevent 
interference in the marketplace.

The problem with lower numerical limits is, however, that either they become 
prohibitively expensive to manufacture, or they will be adopted pro forma and 
ignored in practice – which is often what manufacturers do already facing FCC 
limits.  It does not help to require compliance with standards never meant to 
apply to consumer devices.



A reasonable default limitation – Part 15 – can put a ceiling on the number of 
interference complaints, and a predictably expensive penalty for actually 
causing interference could ensure that manufacturers actually complied with 
those limits, thus my suggestion to require a manufacturer warranty covering 
the costs of remediation should interference occur.  I think that might be 
enough; if coupled with a warranty against susceptibility to nearby 
transmitters, it could substantially reduce the number of complaints from that 
side as well.

Cortland Richmond
KA5S

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Re: [PSES] [RFI] Part 15 isn't enough..

[Ed Price]

Dennis:

 

Not true. Congress passes a Communications Act, a law, and it directs the FCC 
to implement that law. These Acts may stand for years or may be superseded with 
a new Act whenever Congress wants to write a new one. The FCC proposes Rules 
which it thinks will implement the spirit and letter of that Communications 
Act, and then the maneuvering begins. The FCC currently has no basis of law to 
“protect the consumer,” but if Congress wishes to do so, the FCC will be 
mandated, funded and expanded to enforce Congressional wishes.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Friday, September 30, 2016 10:04 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

Nor will there ever be anything in the FCC rules about immunity simply because 
that, as Gherry state, has nothing to do with the protection of the Spectrum.

 

 

​

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: Friday, September 30, 2016 9:03 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

The intent of the quoted statute is simply to protect licensed users of the 
spectrum from unlicensed unintentional “poachers.”  The licensed user paid for 
their use of the spectrum, and any unlicensed “poacher” must cease and desist 
his use when it interferes with the operation of a licensed user. 

It also says that one unlicensed user has no protection from another unlicensed 
user, and certainly not from a licensed user.

Basically just laying out a “pecking order” in terms of rights to use the 
spectrum.

Nothing here about immunity at all.

Ken Javor
Phone: (256) 650-5261

  _  

From: "Paasche, Dieter" 
Reply-To: "Paasche, Dieter" 
Date: Fri, 30 Sep 2016 12:59:04 +
To: 
Conversation: [PSES] [RFI] Part 15 isn't enough..
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately. 
 
Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.
 
And finally, isn’t FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)
§15.5   General conditions of operation.
(a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of any given 
frequency by virtue of prior registration or certification of equipment, or, 
for power line carrier systems, on the basis of prior notification of use 
pursuant to §90.35(g) of this chapter.
(b) 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.
(c) The operator of a radio frequency device shall be required to cease 
operating the device upon notification by a Commission representative that the 
device is causing harmful interference. Operation shall not resume until the 
condition causing the harmful interference has been corrected.
(d) Intentional radiators that produce Class B emissions (damped wave) are 
prohibited.


Sincerely, 
 
Dieter Paasche


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Re: [PSES] [RFI] Part 15 isn't enough..

[Cortland Richmond]

On 9/30/2016 2:16 PM, Ken Javor wrote:

I still don't understand what the applicability is, but if that statement
about MIL-STD-461 applies to products to be sold commercially, it has
serious issues and drawbacks that make it utterly impractical.


I suspect the choice of MIL-Standards was made to reduce emissions more 
than FCC rules require and thus increase the margin available to prevent 
interference in the marketplace.


The problem with lower numerical limits is, however, that either they 
become prohibitively expensive to manufacture, or they will be adopted 
pro forma and ignored in practice – which is often what manufacturers do 
already facing FCC limits.  It does not help to require compliance with 
standards never meant to apply to consumer devices.


A reasonable default limitation – Part 15 – can put a ceiling on the 
number of interference complaints, and a predictably expensive penalty 
for actually causing interference could ensure that manufacturers 
actually complied with those limits, thus my suggestion to require a 
manufacturer warranty covering the costs of remediation should 
interference occur.  I think that might be enough; if coupled with a 
warranty against susceptibility to nearby transmitters, it could 
substantially reduce the number of complaints from that side as well.


Cortland Richmond
KA5S

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Re: [PSES] Percentage Fill of Electrical Raceway in Machinery

[Pete Perkins]

Jim, Ted et al,

 

Ted's comments are cogent here, thanx.  

 

All need to remember that NFPA79 is harmonized with IEC/EN
60204; this was done 15 or more years ago.  The US version contains all the
needed National Differences to meet the US/NEC; the EN version obviously
includes Euro practices.  I have used this harmonization to US
manufacturer's advantage; US practices are most generally acceptable in
Europe when viewed this way.  

 

Specifically, to address the question, 60204 contains
requirements for analysis of appropriate wire sizing within cable trays,
etc.  This analysis is not usually done in the US, the filling requirement
for conduit mentioned is considered to provide the same result.  Of course,
the US insistence on conduit seems much too stringent to the EU.  

 

Finally, it has been my general practice to insist on
separation of circuits within equipment.  I don't like to see power and
control circuits bundled together.  If there were a fire in the assembly the
mains power would appear on the control circuitry and provide an unexpected
electric shock hazard before the protection kicks in.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

  p.perk...@ieee.org

 

From: Ted Eckert [mailto:07cf6ebeab9d-dmarc-requ...@ieee.org] 
Sent: Friday, September 30, 2016 10:48 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Percentage Fill of Electrical Raceway in Machinery

 

Hello Jim,

 

I believe the rationale for the limit is heat dissipation, although I am not
100% confident in this. Overfilling conduit, raceways or cable trays can
prevent heat dissipation from conductors and would thus change the ampacity
calculations required. Based on this, all conductors would be subject to the
limit, not just power conductors. Signal and communication conductors may
not add to the heating, but they could add thermal insulation. NFPA 70, the
NEC, has an entire annex (Annex C) that covers the number of conductors
allowed in conduit and tubing.

 

Many applications, and many parts of the NEC, prohibit low-voltage signaling
or communication wires in the same conduit or raceway as line-voltage
conductors. There are special circumstances where both types of conductors
are allowed together, but this is not the normal application. As such, the
code does not anticipate having to provide specifications for fill limits
with both types of conductors together.

 

It's been more than eight years since I worked with these issues regularly,
so my information is a bit old. However, the code evolves slowly, and
electrical inspectors' interpretation of the code evolves even more slowly.

 

Ted Eckert

Microsoft Corporation

 

The opinions expressed are my own and do not necessarily reflect those of my
employer, my previous employer, NFPA, IBEW, NAFI or OSHA. 

 

From: Jim Hulbert [mailto:jim.hulb...@pb.com] 
Sent: Friday, September 30, 2016 8:10 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] Percentage Fill of Electrical Raceway in Machinery

 

Greetings.

 

The U.S. Electrical Standard for Industrial Machinery NFPA 79 in 13.5.2
states that total cross section area of all conductors and cables routed
through a raceway or conduit can't fill more than 50% of the cross section
area of the raceway.  Does this requirement apply to ALL conductors,
including low voltage signal or communication cables?  I understand the
rationale for high voltage/high current conductors but not for signal
conductors.  However, the standard does not seem to differentiate.
EN60204-1 is similar to NFPA 79, but I don't see the same restriction on
raceway fill.

 

I have had an NRTL engineer cite a non-conformance for a raceway that was
too full.  I argued that the cables were just low voltage signal cables but
it didn't make a difference to this engineer.  We ended up using a larger
raceway.

 

Any thoughts?

 

Jim Hulbert

 

  _  

 

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Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

Do not confuse susceptibility of interference with immunity such as ESD, Fast 
Transient, etc.   The susceptibility spoken of is that of Spectrum Protection, 
and the protection of licensed users, not ESD, RF immunity, etc.

And, the actual law states "(2) establishing minimum performance standards 
for home electronic equipment and systems to reduce their susceptibility to 
interference from radio frequency energy."  
But then that is the 1982 version. The Telecommunications Act of 1934 amended 
1996 is the current law in force, not the 1982.  Also, while irrelevant, the 
1982 law only changed a few phrases to better describe specific instances.  
Such as adding "or home electronic equipment and systems" after "devices", and 
adding who can train and who can give amateur license testing.
​
The relevant law (i.e. Telecommunications Act of 1934 as amended in 1996) says 
" The Commission may, consistent with the public interest, convenience, and 
necessity, make reasonable regulations (1) governing the interference potential 
of devices which in their operation are capable of emitting radio frequency 
energy by radiation, conduction, or other means in sufficient degree to cause 
harmful interference to radio communications; and (2) establishing minimum 
performance standards for home electronic equipment and systems to reduce their 
susceptibility to interference from radio frequency energy. Such regulations 
shall be applicable to the manufacture, import, sale, offer for sale, or 
shipment of such devices and home
electronic equipment and systems, and to the use of such devices.

Again, this is not immunity in the sense of radiated immunity, ESD, Fast 
Transient etc., but susceptibility only in regards to protection fo the 
spectrum. 


Dennis Ward
This communication and its attachements contain information from PCTEST 
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-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: Friday, September 30, 2016 10:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 1:03 PM, dward wrote:
> Nor will there ever be anything in the FCC rules about immunity simply 
> because that, as Gherry state, has nothing to do with the protection 
> of the Spectrum.

The FCC already has the authority it needs to require *some* RF immunity, and 
has since 1982:

http://www.arrl.org/public-law-97-259

excerpt:


The FCC has opted for voluntary standards, rather than formal rules and 
regulations. The FCC and the ARRL are both active in an industry group (in 
cooperation with the American National Standards Institute, ANSI) that is 
studying "RF immunity issues." The Accredited Standards Committee C-63, has set 
an RFI-rejection standard for certain home electronic equipment. The voluntary 
standard provides for immunity of consumer equipment to some levels of RF field 
strength. This standard is not sufficient for full-power amateur stations under 
"worst case" 
conditions, but it covers the majority of cases. Starting in the second half of 
the 1990s, consumers started to see some built-in immunity in consumer 
products. The industry has a ways to go, but there is some light at the end of 
the tunnel.


Cortland
ka5s

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Attachmen

Re: [PSES] [RFI] Part 15 isn't enough..

[Ken Javor]

I still don't understand what the applicability is, but if that statement
about MIL-STD-461 applies to products to be sold commercially, it has
serious issues and drawbacks that make it utterly impractical.

In no particular order:

CS114, RE102, RS103 all have multiple limits based on Service applicability
and platform type. So the list is not specific enough to be applied.

RE102 and RS103 are nowhere near repeatable enough to even remotely qualify
as a barrier to market: any such requirement functioning as a barrier to
market (or gateway, depending on whether the glass is perceived half empty
or half full) must have the sort of repeatability claimed for test methods
such as CISPR 22. Note careful wording there.

CS116 and RS105 - EMP? Maybe for items that control the electrical grid, but
even there the limits would be all wrong because the -461 limits are
tailored for items the size of a vehicle of one sort or another, not cables
that interconnectedly stretch across a continent.

CE106 and the CS103/04/05 requirements were designed for transmit and
receive antennas co-located in close proximity to each other. That sort of
interaction outside an integrated vehicle will definitely occur with mobile
phones and wireless wi-fi router/hotspots, but aside from that isn't an
issue all across the spectrum as it is with a military vehicle with radios
operating across the spectrum.  For instance, imposing CS103/104 on say a
GPS receiver would require a front end filter for the L1/L2 band(s)
whichever is appropriate.  That adds cost and it isn't obvious there is a
need for the typical automotive application.

Ken Javor
Phone: (256) 650-5261


> From: Cortland Richmond 
> Reply-To: 
> Date: Fri, 30 Sep 2016 12:35:59 -0400
> To: 
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> On 9/30/2016 12:04 PM, Ken Javor wrote:
>> Was the original post that started this long thread saying that Part 15
>> wasn't enough, we also needed immunity requirements, or as I understood it,
>> that Part 15 limits weren't low enough?
> 
> The latter, sort of,  but I added immunity (15.17) as a warranty item
> I'd like to see.
> 
> Here's the original:
> 
> Hey Gang,
> I know we have all discussed "part 15 isn't enough", particularly when we
> have talked about things like Solar systems
> 
> I was wondering - What if you were to say
> "System shall be compliant with MIL-STD-461F,
>   parts CE106,
>   CS103,104,105,114,115,116
> RE 102
> and
> RS 103, 105"
> 
> Think that should cover it?  Gives them an objective system of numbers to
> work with
> 
> 73 de KG2V
> Charlie
> 
> 
> 
> 
> Cortland
> KA5S
> 
> -
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to
> 
> 
> 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)
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> 
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Re: [PSES] Percentage Fill of Electrical Raceway in Machinery

[Ted Eckert]

Hello Jim,

I believe the rationale for the limit is heat dissipation, although I am not 
100% confident in this. Overfilling conduit, raceways or cable trays can 
prevent heat dissipation from conductors and would thus change the ampacity 
calculations required. Based on this, all conductors would be subject to the 
limit, not just power conductors. Signal and communication conductors may not 
add to the heating, but they could add thermal insulation. NFPA 70, the NEC, 
has an entire annex (Annex C) that covers the number of conductors allowed in 
conduit and tubing.

Many applications, and many parts of the NEC, prohibit low-voltage signaling or 
communication wires in the same conduit or raceway as line-voltage conductors. 
There are special circumstances where both types of conductors are allowed 
together, but this is not the normal application. As such, the code does not 
anticipate having to provide specifications for fill limits with both types of 
conductors together.

It's been more than eight years since I worked with these issues regularly, so 
my information is a bit old. However, the code evolves slowly, and electrical 
inspectors' interpretation of the code evolves even more slowly.

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer, my previous employer, NFPA, IBEW, NAFI or OSHA.

From: Jim Hulbert [mailto:jim.hulb...@pb.com]
Sent: Friday, September 30, 2016 8:10 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Percentage Fill of Electrical Raceway in Machinery

Greetings.

The U.S. Electrical Standard for Industrial Machinery NFPA 79 in 13.5.2 states 
that total cross section area of all conductors and cables routed through a 
raceway or conduit can't fill more than 50% of the cross section area of the 
raceway.  Does this requirement apply to ALL conductors, including low voltage 
signal or communication cables?  I understand the rationale for high 
voltage/high current conductors but not for signal conductors.  However, the 
standard does not seem to differentiate.   EN60204-1 is similar to NFPA 79, but 
I don't see the same restriction on raceway fill.

I have had an NRTL engineer cite a non-conformance for a raceway that was too 
full.  I argued that the cables were just low voltage signal cables but it 
didn't make a difference to this engineer.  We ended up using a larger raceway.

Any thoughts?

Jim Hulbert



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Re: [PSES] [RFI] Part 15 isn't enough..

[John Woodgate]

To be logical, it is necessary to have emission limits, immunity requirements 
and specified measurement distances. Miss any one, let alone two, and the third 
is impossible to justify.

But the protection of radio services distorts this and leads to much 
misunderstanding. The radio receiver ipso facto doesn't have any immunity on 
the tuned frequency, so emission limits are set by considering what field 
strengths of wanted transmissions give adequate signal-to-noise ratios from the 
receivers, taking into account the undifferentiated levels of man-made and 
galactic EM noise. For example, an emission limit in field strength terms could 
be set to be equal, at a distance of 10 m from the source, to the 
undifferentiated level, thus reducing the S/N of a receiver at that distance by 
3 dB.

Interference with, for example, a microprocessor-controlled toaster is quite 
different. In this case, the toaster can reasonably be expected NOT to be an 
efficient radio receiver, so an immunity requirement can be set, such that the 
field strength of the source in the example above does not cause malfunction if 
the toaster is 10 m away. 

Of course, other measurement distances can be specified, taking into account 
the likely sources and victims in a given environment, and how far apart they 
are likely to be.

With best wishes DESIGN IT IN! OOO – Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.


-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: Friday, September 30, 2016 5:36 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 12:04 PM, Ken Javor wrote:
> Was the original post that started this long thread saying that Part 
> 15 wasn't enough, we also needed immunity requirements, or as I understood 
> it, that Part 15 limits weren't low enough?

The latter, sort of,  but I added immunity (15.17) as a warranty item I'd like 
to see.

Here's the original:

Hey Gang,
I know we have all discussed "part 15 isn't enough", particularly when we have 
talked about things like Solar systems

I was wondering - What if you were to say "System shall be compliant with 
MIL-STD-461F,
  parts CE106,
  CS103,104,105,114,115,116
RE 102
and
RS 103, 105"

Think that should cover it?  Gives them an objective system of numbers to work 
with

73 de KG2V
Charlie




Cortland
KA5S

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Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

Dieter

The simple answer to your question “isn’t FCC indirectly stating that immunity 
has to be met as well?  FCC Part 15.5 (b), is no.  While the FCC says that the 
manufacturer should consider methods to avoid interference, the impetus on 
15.5b only deals with interference to licensed users of the spectrum and not 
with any immunity issues not directly related to the protection of the 
spectrum. 

 

​

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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it from your computer system.  Usage of PCTEST email addresses for non-business 
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or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com] 
Sent: Friday, September 30, 2016 5:59 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately. 

 

Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.

 

And finally, isn’t FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)

§15.5   General conditions of operation.

(a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of any given 
frequency by virtue of prior registration or certification of equipment, or, 
for power line carrier systems, on the basis of prior notification of use 
pursuant to §90.35(g) of this chapter.

(b) 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.

(c) The operator of a radio frequency device shall be required to cease 
operating the device upon notification by a Commission representative that the 
device is causing harmful interference. Operation shall not resume until the 
condition causing the harmful interference has been corrected.

(d) Intentional radiators that produce Class B emissions (damped wave) are 
prohibited.

 

Sincerely, 

 

Dieter Paasche

 



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David H

Re: [PSES] [RFI] Part 15 isn't enough..

[Cortland Richmond]

On 9/30/2016 1:03 PM, dward wrote:
Nor will there ever be anything in the FCC rules about immunity simply 
because that, as Gherry state, has nothing to do with the protection 
of the Spectrum.


The FCC already has the authority it needs to require *some* RF 
immunity, and has since 1982:


http://www.arrl.org/public-law-97-259

excerpt:


The FCC has opted for voluntary standards, rather than formal rules and 
regulations. The FCC and the ARRL are both active in an industry group 
(in cooperation with the American National Standards Institute, ANSI) 
that is studying "RF immunity issues." The Accredited Standards 
Committee C-63, has set an RFI-rejection standard for certain home 
electronic equipment. The voluntary standard provides for immunity of 
consumer equipment to some levels of RF field strength. This standard is 
not sufficient for full-power amateur stations under "worst case" 
conditions, but it covers the majority of cases. Starting in the second 
half of the 1990s, consumers started to see some built-in immunity in 
consumer products. The industry has a ways to go, but there is some 
light at the end of the tunnel.



Cortland
ka5s

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Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

Ops sorry Ghery, I put one to many r’s in your name.

 

​

Dennis Ward

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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: Friday, September 30, 2016 10:04 AM
To: 'Ken Javor' ; 'EMC-PSTC@LISTSERV.IEEE.ORG' 

Subject: RE: [PSES] [RFI] Part 15 isn't enough..

 

Nor will there ever be anything in the FCC rules about immunity simply because 
that, as Gherry state, has nothing to do with the protection of the Spectrum.

 

 

​

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: Friday, September 30, 2016 9:03 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

The intent of the quoted statute is simply to protect licensed users of the 
spectrum from unlicensed unintentional “poachers.”  The licensed user paid for 
their use of the spectrum, and any unlicensed “poacher” must cease and desist 
his use when it interferes with the operation of a licensed user. 

It also says that one unlicensed user has no protection from another unlicensed 
user, and certainly not from a licensed user.

Basically just laying out a “pecking order” in terms of rights to use the 
spectrum.

Nothing here about immunity at all.

Ken Javor
Phone: (256) 650-5261

  _  

From: "Paasche, Dieter" mailto:dieter.paas...@christiedigital.com> >
Reply-To: "Paasche, Dieter" mailto:dieter.paas...@christiedigital.com> >
Date: Fri, 30 Sep 2016 12:59:04 +
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Conversation: [PSES] [RFI] Part 15 isn't enough..
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately. 
 
Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.
 
And finally, isn’t FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)
§15.5   General conditions of operation.
(a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of any given 
frequency by virtue of prior registration or certification of equipment, or, 
for power line carrier systems, on the basis of prior notification of use 
pursuant to §90.35(g) of this chapter.
(b) 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.
(c) The operator of a radio frequency device shall be required to cease 
operating the device upon notification by a Commission representative that the 
device is causing harmful interference. Operation shall not resume until the 
condition causing the harmful interference has been corrected.
(d) Intentional radiators that produce Class B emissions (damped wave) are 
prohibited.


Sincerely, 
 
Dieter Paasche


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 
mailto:emc-p...@ieee.org> >

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Re: [PSES] [RFI] Part 15 isn't enough..

[dward]

Nor will there ever be anything in the FCC rules about immunity simply because 
that, as Gherry state, has nothing to do with the protection of the Spectrum.

 

 

​

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: Friday, September 30, 2016 9:03 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

The intent of the quoted statute is simply to protect licensed users of the 
spectrum from unlicensed unintentional “poachers.”  The licensed user paid for 
their use of the spectrum, and any unlicensed “poacher” must cease and desist 
his use when it interferes with the operation of a licensed user. 

It also says that one unlicensed user has no protection from another unlicensed 
user, and certainly not from a licensed user.

Basically just laying out a “pecking order” in terms of rights to use the 
spectrum.

Nothing here about immunity at all.

Ken Javor
Phone: (256) 650-5261



  _  

From: "Paasche, Dieter" mailto:dieter.paas...@christiedigital.com> >
Reply-To: "Paasche, Dieter" mailto:dieter.paas...@christiedigital.com> >
Date: Fri, 30 Sep 2016 12:59:04 +
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Conversation: [PSES] [RFI] Part 15 isn't enough..
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately. 
 
Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.
 
And finally, isn’t FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)
§15.5   General conditions of operation.
(a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of any given 
frequency by virtue of prior registration or certification of equipment, or, 
for power line carrier systems, on the basis of prior notification of use 
pursuant to §90.35(g) of this chapter.
(b) 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.
(c) The operator of a radio frequency device shall be required to cease 
operating the device upon notification by a Commission representative that the 
device is causing harmful interference. Operation shall not resume until the 
condition causing the harmful interference has been corrected.
(d) Intentional radiators that produce Class B emissions (damped wave) are 
prohibited.


Sincerely, 
 
Dieter Paasche


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Re: [PSES] [RFI] Part 15 isn't enough..

[John Allen]

Ghery

Does suing the relevant Federal authority happen (at least nowadays) with other 
aspects of Federal legislation, e.g. if the relevant Federal Motor Vehicle 
Safety Standards (FMVSS) for motor vehicle safety standard were thought to be 
inadequate would the NHTSA be sued - similarly with OSHA or the Consumer 
Product Safety Commission (CPSC) ?

If Yes, then you may have a good point, but if No/rarely then I think your 
point is not so well made, as, generally, EMC issues don't have quite the same 
potentially catastrophic effects (unless they cause aircraft crashes and so on) 
as inadequate motor vehicle safety, occupational safety or safety of consumer 
products, and so the likelihood of the FCC being hit by a major law suite would 
seem lower. 

John E Allen
W. London, UK

-Original Message-
From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: 30 September 2016 16:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

The FCC also is taking the route mandated by their charter - protect the radio 
users from interference.  Part 15 apparently does that adequately as 
interference complaints to the FCC have dropped to the noise level.  Not so 
before Part 15, Subpart J was published in the late 1970s.  Part 15 is doing 
its job.  Immunity testing isn't a "protection of the spectrum" issue.  
Besides, with the legal climate in the US, if the FCC mandated a certain level 
of immunity and someone was injured because that level wasn't high enough 
(allegedly or in actuality) the FCC would be sued.  Might not be successfully, 
but it is something to be avoided.  Keep in mind that the commissioners are 
political appointees.  Their job is to do their job while not making the 
President look bad.  Getting hauled into court doesn't do that so well.  Just 
another viewpoint...

Ghery S. Pettit

-Original Message-
From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Friday, September 30, 2016 8:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Cortland 

Sound like Congress being "ruled" by "big" and/or "small business" interests to 
make the FCC take the path of least resistance - I would have thought that 
their approach might have been deemed as being not in the general public 
interest, but I can now see where you are coming from on the warrantee front.

OTOH, from what I think you wrote earlier, some States would not permit that 
warrantee approach - sounds like more "vested interests" coming into play there.

Looks like rather a no-win situation on immunity improvements for products for 
the general public in the foreseeable future - unless, possibly, one or more 
important States were persuaded to pass appropriate legislation on the basis of 
the dangers from not doing so, as has been the cases related to environmental 
protection and energy conservation (and so on) that have affected the design 
and sale of electronic equipment 

Oh well, maybe someday EMC issues really will begin to "bite" a lot more people 
across the country and something will, most belatedly, be done at the Federal 
level.

John E Allen
W. London, UK

-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net]
Sent: 30 September 2016 14:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 8:59 AM, Dieter Paasche wrote:
> The operator of a radio frequency device shall be required to cease 
> operating the device *upon notification by a Commission
> representative* that the device is causing harmful interference.
[emphasis added]

The FCC has been reluctant to make that notification even after numerous 
complaints, as being too zealous in enforcing the Rules has historically 
resulted in Congress reducing the funds available to do so. You know the saying 
'Was nicht ausdrücklich erlaubt ist, ist verboten'; we have gone quite the 
opposite way to "Alles was nicht erlaubt ist, ist pflichtig" 
–  at least when there is profit to be had.

This is why I advocate placing a requirement the vendor warrant noninterference 
and RF immunity in the purchase contract.  What laws can't do, money can.

Cortland Richmond
KA5S

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 


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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:  http://www.ieee-pses.org/list.html (including how to 
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For help, send mail to the list administrators:
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Mike Cantwell 

For policy questions, send mail 

Re: [PSES] [RFI] Part 15 isn't enough..

[John Allen]

Maybe my earlier comment about things coming to pass in the future might just 
have some very shallow roots even now?

 

John E Allen

W. London, UK

 

From: Ken Wyatt [mailto:k...@emc-seminars.com] 
Sent: 30 September 2016 16:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

I agree with Ghery that interference complaints from typical PC/ITE systems 
have dropped, but they’ve been getting numerous complaints lately, related to 
interference from lighting and in particular, out of compliance switching power 
supplies from offshore.

 

See: 
http://www.interferencetechnology.com/fcc-wants-help-understanding-spectral-noise-floor/

 

The overall noise floor below 200 MHz has increased to the point where the FCC 
is asking industry (and individuals) for historical noise floor data to assist 
with their analysis of the situation.

 

Cheers, Ken


___

 

I'm here to help you succeed! Feel free to call or email with any questions 
related to EMC or EMI troubleshooting - at no obligation. I'm always happy to 
help!


Kenneth Wyatt
Wyatt Technical Services LLC

56 Aspen Dr.
Woodland Park, CO 80863


Phone: (719) 310-5418


Email Me!   | Web Site 
  | Blog  

The EMC Blog (EDN)  
Subscribe to Newsletter 
 
Connect with me on LinkedIn  

 

On Sep 30, 2016, at 9:26 AM, Ghery S. Pettit  wrote:

 

The FCC also is taking the route mandated by their charter - protect the radio 
users from interference.  Part 15 apparently does that adequately as 
interference complaints to the FCC have dropped to the noise level.  Not so 
before Part 15, Subpart J was published in the late 1970s.  Part 15 is doing 
its job.  Immunity testing isn't a "protection of the spectrum" issue.  
Besides, with the legal climate in the US, if the FCC mandated a certain level 
of immunity and someone was injured because that level wasn't high enough 
(allegedly or in actuality) the FCC would be sued.  Might not be successfully, 
but it is something to be avoided.  Keep in mind that the commissioners are 
political appointees.  Their job is to do their job while not making the 
President look bad.  Getting hauled into court doesn't do that so well.  Just 
another viewpoint...

Ghery S. Pettit

-Original Message-
From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Friday, September 30, 2016 8:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Cortland 

Sound like Congress being "ruled" by "big" and/or "small business" interests to 
make the FCC take the path of least resistance - I would have thought that 
their approach might have been deemed as being not in the general public 
interest, but I can now see where you are coming from on the warrantee front.

OTOH, from what I think you wrote earlier, some States would not permit that 
warrantee approach - sounds like more "vested interests" coming into play there.

Looks like rather a no-win situation on immunity improvements for products for 
the general public in the foreseeable future - unless, possibly, one or more 
important States were persuaded to pass appropriate legislation on the basis of 
the dangers from not doing so, as has been the cases related to environmental 
protection and energy conservation (and so on) that have affected the design 
and sale of electronic equipment 

Oh well, maybe someday EMC issues really will begin to "bite" a lot more people 
across the country and something will, most belatedly, be done at the Federal 
level.

John E Allen
W. London, UK

-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net]
Sent: 30 September 2016 14:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 8:59 AM, Dieter Paasche wrote:



The operator of a radio frequency device shall be required to cease 
operating the device *upon notification by a Commission
representative* that the device is causing harmful interference.

[emphasis added]

The FCC has been reluctant to make that notification even after numerous 
complaints, as being too zealous in enforcing the Rules has historically 
resulted in Congress reducing the funds available to do so. You know the saying 
'Was nicht ausdrücklich erlaubt ist, ist verboten'; we have gone quite the 
opposite way to "Alles was nicht erlaubt ist, ist pflichtig" 
–  at least when there is profit to be had.

This is why I advocate placing a requirement the vendor warrant noninterference 
and RF immunity in the purchase contract.  What laws can't do, money can.

Cortland Richmond
KA5S

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a messag

Re: [PSES] [RFI] Part 15 isn't enough..

[Cortland Richmond]

On 9/30/2016 12:04 PM, Ken Javor wrote:

Was the original post that started this long thread saying that Part 15
wasn't enough, we also needed immunity requirements, or as I understood it, 
that Part 15 limits weren't low enough?


The latter, sort of,  but I added immunity (15.17) as a warranty item 
I'd like to see.


Here's the original:

Hey Gang,
I know we have all discussed "part 15 isn't enough", particularly when we
have talked about things like Solar systems

I was wondering - What if you were to say
"System shall be compliant with MIL-STD-461F,
 parts CE106,
 CS103,104,105,114,115,116
RE 102
and
RS 103, 105"

Think that should cover it?  Gives them an objective system of numbers to
work with

73 de KG2V
Charlie




Cortland
KA5S

-

This message is from the IEEE Product Safety Engineering Society emc-pstc discussion 
list. To post a message to the list, send your e-mail to 

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: 

Re: [PSES] [RFI] Part 15 isn't enough..

[Ken Wyatt]

I agree with Ghery that interference complaints from typical PC/ITE systems 
have dropped, but they’ve been getting numerous complaints lately, related to 
interference from lighting and in particular, out of compliance switching power 
supplies from offshore.

See: 
http://www.interferencetechnology.com/fcc-wants-help-understanding-spectral-noise-floor/
 


The overall noise floor below 200 MHz has increased to the point where the FCC 
is asking industry (and individuals) for historical noise floor data to assist 
with their analysis of the situation.

Cheers, Ken

___

I'm here to help you succeed! Feel free to call or email with any questions 
related to EMC or EMI troubleshooting - at no obligation. I'm always happy to 
help!

Kenneth Wyatt
Wyatt Technical Services LLC
56 Aspen Dr.
Woodland Park, CO 80863

Phone: (719) 310-5418

Email Me!  | Web Site 
 | Blog 
The EMC Blog (EDN) 
Subscribe to Newsletter 
Connect with me on LinkedIn 
> On Sep 30, 2016, at 9:26 AM, Ghery S. Pettit  wrote:
> 
> The FCC also is taking the route mandated by their charter - protect the 
> radio users from interference.  Part 15 apparently does that adequately as 
> interference complaints to the FCC have dropped to the noise level.  Not so 
> before Part 15, Subpart J was published in the late 1970s.  Part 15 is doing 
> its job.  Immunity testing isn't a "protection of the spectrum" issue.  
> Besides, with the legal climate in the US, if the FCC mandated a certain 
> level of immunity and someone was injured because that level wasn't high 
> enough (allegedly or in actuality) the FCC would be sued.  Might not be 
> successfully, but it is something to be avoided.  Keep in mind that the 
> commissioners are political appointees.  Their job is to do their job while 
> not making the President look bad.  Getting hauled into court doesn't do that 
> so well.  Just another viewpoint...
> 
> Ghery S. Pettit
> 
> -Original Message-
> From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
> Sent: Friday, September 30, 2016 8:00 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> Cortland 
> 
> Sound like Congress being "ruled" by "big" and/or "small business" interests 
> to make the FCC take the path of least resistance - I would have thought that 
> their approach might have been deemed as being not in the general public 
> interest, but I can now see where you are coming from on the warrantee front.
> 
> OTOH, from what I think you wrote earlier, some States would not permit that 
> warrantee approach - sounds like more "vested interests" coming into play 
> there.
> 
> Looks like rather a no-win situation on immunity improvements for products 
> for the general public in the foreseeable future - unless, possibly, one or 
> more important States were persuaded to pass appropriate legislation on the 
> basis of the dangers from not doing so, as has been the cases related to 
> environmental protection and energy conservation (and so on) that have 
> affected the design and sale of electronic equipment 
> 
> Oh well, maybe someday EMC issues really will begin to "bite" a lot more 
> people across the country and something will, most belatedly, be done at the 
> Federal level.
> 
> John E Allen
> W. London, UK
> 
> -Original Message-
> From: Cortland Richmond [mailto:k...@earthlink.net]
> Sent: 30 September 2016 14:58
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> On 9/30/2016 8:59 AM, Dieter Paasche wrote:
>> The operator of a radio frequency device shall be required to cease 
>> operating the device *upon notification by a Commission
>> representative* that the device is causing harmful interference.
> [emphasis added]
> 
> The FCC has been reluctant to make that notification even after numerous 
> complaints, as being too zealous in enforcing the Rules has historically 
> resulted in Congress reducing the funds available to do so. You know the 
> saying 'Was nicht ausdrücklich erlaubt ist, ist verboten'; we have gone quite 
> the opposite way to "Alles was nicht erlaubt ist, ist pflichtig" 
> –  at least when there is profit to be had.
> 
> This is why I advocate placing a requirement the vendor warrant 
> noninterference and RF immunity in the purchase contract.  What laws can't 
> do, money can.
> 
> Cortland Richmond
> KA5S
> 
> -
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc 
> discussion list. To post a message to the list, send your e-mail to 
> 
> 
> All emc-pstc postings are archived and searchable on 

Re: [PSES] [RFI] Part 15 isn't enough..

[Ken Javor]

Was the original post that started this long thread saying that Part 15
wasn't enough, we also needed immunity requirements, or as I understood it,
that Part 15 limits weren't low enough?

Ken Javor
Phone: (256) 650-5261


> From: Joe Randolph 
> Reply-To: Joe Randolph 
> Date: Fri, 30 Sep 2016 11:43:55 -0400
> To: 
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> There are other countries not mentioned that have immunity requirements, at
> least for the telecom product that I work with.
> 
> Mexico and Brazil immediately come to mind because their immunity requirements
> are in some cases more stringent than the EU requirements.
> 
> I believe there are others that do not immediately come to mind because they
> have harmonized their requirements with the EU and it's basically no
> additional work if the product already meets the EU requirements.
> 
> 
> Joe Randolph
> Telecom Design Consultant
> Randolph Telecom, Inc.
> 781-721-2848 (USA)
> j...@randolph-telecom.com
> http://www.randolph-telecom.com
> 
> -Original Message-
> From: ce-test, qualified testing bv - Gert Gremmen
> [mailto:g.grem...@cetest.nl]
> Sent: Friday, September 30, 2016 3:38 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> Hi  Ghery,
> 
> You need to get your numbers right Those tree entities outnumber your
> "real world" by 7.
> Economically by a factor 2...
>  
> 
> 
> Regards,
> 
> Ing. Gert Gremmen
> Approvals manager
> --
> --
> 
> 
> + ce marking of electrical/electronic equipment Independent Consultancy
> + Services Compliance Testing and Design for CE marking
>  according to EC-directives:
> - Electro Magnetic Compatibility 2004/108/EC
> - Electrical Safety 2006/95/EC
> - Medical Devices 93/42/EC
> - Radio & Telecommunication Terminal Equipment 99/5/EC
> + Improvement of Product Quality and Reliability testing Education
> 
> Web:www.cetest.nl (English)
> Phone :  +31 10 415 24 26
> ---
> This e-mail and any attachments thereto may contain information that is
> confidential and/or protected by intellectual property rights and are intended
> for the sole use of the recipient(s) named above.
> Any use of the information contained herein (including, but not limited to,
> total or partial reproduction, communication or distribution in any form) by
> persons other than the designated
> recipient(s) is prohibited. If you have received this e-mail in error, please
> notify the sender either by telephone or by e-mail and delete the material
> from any computer.
> Thank you for your co-operation.
> 
> From: Ghery S. Pettit [mailto:n6...@comcast.net]
> Sent: Friday 30 September 2016 00:20
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> Immunity testing is required in the EU, South Korea and China.  Nowhere else
> in the world is it required for commercial products.  I’d say that the US is
> in the “real world”.
> 
> Ghery S. Pettit
> 
> From: Ken Javor [mailto:ken.ja...@emccompliance.com]
> Sent: Thursday, September 29, 2016 3:01 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> Without getting into the specifics of this particular argument, the idea that
> the “rest of the world” has dome something doesn’t necessarily imply that
> North America is “behind.”  In the same sense that if a train has derailed and
> the locomotive is headed over a cliff, we don’t say the caboose is behind and
> needs to catch up.
> 
> Ken Javor
> Phone: (256) 650-5261
> 
> From: john Allen 
> Reply-To: john Allen 
> Date: Thu, 29 Sep 2016 22:44:48 +0100
> To: 
> Subject: Re: [PSES] [RFI] Part 15 isn't enough..
> 
> Dennis
>  
> I really  do wonder what World you live in – but then, TBH, based on your
> previous comments of a similar nature, I did not expect anything else!
>  
> OK, Government “interference” is unwelcome in many cases but Brian O’Connell’s
> post is a  poignant “real world”  comment on what suppliers are facing, and
> what the Government should face up to and address – for the greater good of
> everyone in YOUR country.
>  
> Without getting trying to “personal”,  “get real”! - a lot of the rest of the
> “real world” has already adopted appropriate requirements to try to prevent
> undue interference problems and so N. America is behind on this issue.
>  
> John E Allen.
> W. London, UK
>  
> 
> From: dward [mailto:dw...@pctestlab.com]
> Sent: 29 September 2016 22:28
> To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: RE: [PSES] [RFI] Part 15 isn't enough..
> 
> The federal government already interferes with US citizens far too much as it
> is – we do not need, nor do most of us want more federal intrusion.  The feds
> are there to keep the wolves at bay and keep out of our liv

Re: [PSES] [RFI] Part 15 isn't enough..

[Ken Javor]

The intent of the quoted statute is simply to protect licensed users of the
spectrum from unlicensed unintentional ³poachers.²  The licensed user paid
for their use of the spectrum, and any unlicensed ³poacher² must cease and
desist his use when it interferes with the operation of a licensed user.

It also says that one unlicensed user has no protection from another
unlicensed user, and certainly not from a licensed user.

Basically just laying out a ³pecking order² in terms of rights to use the
spectrum.

Nothing here about immunity at all.

Ken Javor
Phone: (256) 650-5261



From: "Paasche, Dieter" 
Reply-To: "Paasche, Dieter" 
Date: Fri, 30 Sep 2016 12:59:04 +
To: 
Conversation: [PSES] [RFI] Part 15 isn't enough..
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I believe that changing part 15 will be very difficult since it
is a legal  (political) document and would need congress approval for
changes. Different that than in the EU where you have directives and
harmonized standards somehow separately.
 
Also the US is part of international committees and heavily participates on
emissions and immunity standards. However implementation and enforcing is
always difficult.
 
And finally, isn¹t FCC indirectly stating that immunity has to be met as
well?  FCC Part 15.5 (b)
§15.5   General conditions of operation.
(a) Persons operating intentional or unintentional radiators shall not be
deemed to have any vested or recognizable right to continued use of any
given frequency by virtue of prior registration or certification of
equipment, or, for power line carrier systems, on the basis of prior
notification of use pursuant to §90.35(g) of this chapter.
(b) 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.
(c) The operator of a radio frequency device shall be required to cease
operating the device upon notification by a Commission representative that
the device is causing harmful interference. Operation shall not resume until
the condition causing the harmful interference has been corrected.
(d) Intentional radiators that produce Class B emissions (damped wave) are
prohibited.
 

Sincerely, 
 
Dieter Paasche
 

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Re: [PSES] [RFI] Part 15 isn't enough..

[Joe Randolph]

There are other countries not mentioned that have immunity requirements, at 
least for the telecom product that I work with.  

Mexico and Brazil immediately come to mind because their immunity requirements 
are in some cases more stringent than the EU requirements. 

I believe there are others that do not immediately come to mind because they 
have harmonized their requirements with the EU and it's basically no additional 
work if the product already meets the EU requirements.


Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848 (USA)
j...@randolph-telecom.com
http://www.randolph-telecom.com

-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] 
Sent: Friday, September 30, 2016 3:38 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Hi  Ghery,

You need to get your numbers right Those tree entities outnumber your "real 
world" by 7.
Economically by a factor 2...
 


Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing Education

Web:www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information that is 
confidential and/or protected by intellectual property rights and are intended 
for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not limited to, 
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From: Ghery S. Pettit [mailto:n6...@comcast.net]
Sent: Friday 30 September 2016 00:20
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Immunity testing is required in the EU, South Korea and China.  Nowhere else in 
the world is it required for commercial products.  I’d say that the US is in 
the “real world”.

Ghery S. Pettit

From: Ken Javor [mailto:ken.ja...@emccompliance.com]
Sent: Thursday, September 29, 2016 3:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Without getting into the specifics of this particular argument, the idea that 
the “rest of the world” has dome something doesn’t necessarily imply that North 
America is “behind.”  In the same sense that if a train has derailed and the 
locomotive is headed over a cliff, we don’t say the caboose is behind and needs 
to catch up.

Ken Javor
Phone: (256) 650-5261

From: john Allen 
Reply-To: john Allen 
Date: Thu, 29 Sep 2016 22:44:48 +0100
To: 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dennis
 
I really  do wonder what World you live in – but then, TBH, based on your 
previous comments of a similar nature, I did not expect anything else!
 
OK, Government “interference” is unwelcome in many cases but Brian O’Connell’s 
post is a  poignant “real world”  comment on what suppliers are facing, and 
what the Government should face up to and address – for the greater good of 
everyone in YOUR country.
 
Without getting trying to “personal”,  “get real”! - a lot of the rest of the 
“real world” has already adopted appropriate requirements to try to prevent 
undue interference problems and so N. America is behind on this issue.
 
John E Allen.
W. London, UK
 

From: dward [mailto:dw...@pctestlab.com]
Sent: 29 September 2016 22:28
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

The federal government already interferes with US citizens far too much as it 
is – we do not need, nor do most of us want more federal intrusion.  The feds 
are there to keep the wolves at bay and keep out of our lives.  Besides, the 
open market in the US seems to take care of itself in the interference area.  
Does not take long for the consumer to know what is trash and what works.
The only regulations dealing with the spectrum that is needed is the regulation 
to help stop interference to licensed services. That was the intent of the FCC 
to start and there is no reason to change it.
 
 

​
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 m

Re: [PSES] [RFI] Part 15 isn't enough..

[Ghery S. Pettit]

The FCC also is taking the route mandated by their charter - protect the radio 
users from interference.  Part 15 apparently does that adequately as 
interference complaints to the FCC have dropped to the noise level.  Not so 
before Part 15, Subpart J was published in the late 1970s.  Part 15 is doing 
its job.  Immunity testing isn't a "protection of the spectrum" issue.  
Besides, with the legal climate in the US, if the FCC mandated a certain level 
of immunity and someone was injured because that level wasn't high enough 
(allegedly or in actuality) the FCC would be sued.  Might not be successfully, 
but it is something to be avoided.  Keep in mind that the commissioners are 
political appointees.  Their job is to do their job while not making the 
President look bad.  Getting hauled into court doesn't do that so well.  Just 
another viewpoint...

Ghery S. Pettit

-Original Message-
From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Friday, September 30, 2016 8:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Cortland 

Sound like Congress being "ruled" by "big" and/or "small business" interests to 
make the FCC take the path of least resistance - I would have thought that 
their approach might have been deemed as being not in the general public 
interest, but I can now see where you are coming from on the warrantee front.

OTOH, from what I think you wrote earlier, some States would not permit that 
warrantee approach - sounds like more "vested interests" coming into play there.

Looks like rather a no-win situation on immunity improvements for products for 
the general public in the foreseeable future - unless, possibly, one or more 
important States were persuaded to pass appropriate legislation on the basis of 
the dangers from not doing so, as has been the cases related to environmental 
protection and energy conservation (and so on) that have affected the design 
and sale of electronic equipment 

Oh well, maybe someday EMC issues really will begin to "bite" a lot more people 
across the country and something will, most belatedly, be done at the Federal 
level.

John E Allen
W. London, UK

-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net]
Sent: 30 September 2016 14:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 8:59 AM, Dieter Paasche wrote:
> The operator of a radio frequency device shall be required to cease 
> operating the device *upon notification by a Commission
> representative* that the device is causing harmful interference.
[emphasis added]

The FCC has been reluctant to make that notification even after numerous 
complaints, as being too zealous in enforcing the Rules has historically 
resulted in Congress reducing the funds available to do so. You know the saying 
'Was nicht ausdrücklich erlaubt ist, ist verboten'; we have gone quite the 
opposite way to "Alles was nicht erlaubt ist, ist pflichtig" 
–  at least when there is profit to be had.

This is why I advocate placing a requirement the vendor warrant noninterference 
and RF immunity in the purchase contract.  What laws can't do, money can.

Cortland Richmond
KA5S

-

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This message is from the IEEE Product Safety Engineering Socie

[PSES] Percentage Fill of Electrical Raceway in Machinery

[Jim Hulbert]

Greetings.

The U.S. Electrical Standard for Industrial Machinery NFPA 79 in 13.5.2 states 
that total cross section area of all conductors and cables routed through a 
raceway or conduit can't fill more than 50% of the cross section area of the 
raceway.  Does this requirement apply to ALL conductors, including low voltage 
signal or communication cables?  I understand the rationale for high 
voltage/high current conductors but not for signal conductors.  However, the 
standard does not seem to differentiate.   EN60204-1 is similar to NFPA 79, but 
I don't see the same restriction on raceway fill.

I have had an NRTL engineer cite a non-conformance for a raceway that was too 
full.  I argued that the cables were just low voltage signal cables but it 
didn't make a difference to this engineer.  We ended up using a larger raceway.

Any thoughts?

Jim Hulbert




-

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Re: [PSES] [RFI] Part 15 isn't enough..

[John Allen]

Cortland 

Sound like Congress being "ruled" by "big" and/or "small business" interests to 
make the FCC take the path of least resistance - I would have thought that 
their approach might have been deemed as being not in the general public 
interest, but I can now see where you are coming from on the warrantee front.

OTOH, from what I think you wrote earlier, some States would not permit that 
warrantee approach - sounds like more "vested interests" coming into play there.

Looks like rather a no-win situation on immunity improvements for products for 
the general public in the foreseeable future - unless, possibly, one or more 
important States were persuaded to pass appropriate legislation on the basis of 
the dangers from not doing so, as has been the cases related to environmental 
protection and energy conservation (and so on) that have affected the design 
and sale of electronic equipment 

Oh well, maybe someday EMC issues really will begin to "bite" a lot more people 
across the country and something will, most belatedly, be done at the Federal 
level.

John E Allen
W. London, UK

-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: 30 September 2016 14:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 8:59 AM, Dieter Paasche wrote:
> The operator of a radio frequency device shall be required to cease 
> operating the device *upon notification by a Commission
> representative* that the device is causing harmful interference.
[emphasis added]

The FCC has been reluctant to make that notification even after numerous 
complaints, as being too zealous in enforcing the Rules has historically 
resulted in Congress reducing the funds available to do so. You know the 
saying 'Was nicht ausdrücklich erlaubt ist, ist verboten'; we have gone 
quite the opposite way to "Alles was nicht erlaubt ist, ist pflichtig" 
–  at least when there is profit to be had.

This is why I advocate placing a requirement the vendor warrant 
noninterference and RF immunity in the purchase contract.  What laws 
can't do, money can.

Cortland Richmond
KA5S

-

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Re: [PSES] [RFI] Part 15 isn't enough..

[Cortland Richmond]

On 9/30/2016 8:59 AM, Dieter Paasche wrote:
The operator of a radio frequency device shall be required to cease 
operating the device *upon notification by a Commission 
representative* that the device is causing harmful interference.

[emphasis added]

The FCC has been reluctant to make that notification even after numerous 
complaints, as being too zealous in enforcing the Rules has historically 
resulted in Congress reducing the funds available to do so. You know the 
saying 'Was nicht ausdrücklich erlaubt ist, ist verboten'; we have gone 
quite the opposite way to "Alles was nicht erlaubt ist, ist pflichtig" 
–  at least when there is profit to be had.


This is why I advocate placing a requirement the vendor warrant 
noninterference and RF immunity in the purchase contract.  What laws 
can't do, money can.


Cortland Richmond
KA5S

-

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Re: [PSES] [RFI] Part 15 isn't enough..

[John Allen]

Dieter

 

Yes, that’s what the words state, and have done for years – but, with no
clear requirements or guidelines as to the technical requirements (tests,
limits, pass/fail conditions etc.) or the actual need to do verification,
then many/most suppliers appear to me to ignore those words! I think the
same was true in Europe during the period after the original EMC Directive
(76/889/EEC) was published but before the CE marking requirement version
(89/336/EC) came out and required “proof” of compliance in the form of test
reports, tech files and the CE marking – after that, things gradually began
to change! 

 

The big problem in 1989, and for some years after, was the almost total lack
of standards against which to do the tests and assessments on non-military
products. However, some 25+ years later, the same cannot be said as there
are many international, and even US trade-body, standards which could almost
immediately be used as the basis for realistic sets of requirements to be
formulated.

 

Many multi-national and US companies already do that as normal development
practice, but in the current US legislative environment they can then “cost
cut” for the US market by either not doing that testing on US-market
specific products, or “cost reducing” their internationally-sold products
for sale in that market. That’s probably why the products from some major
multinationals (as mentioned in the previously linked website) could not be
sold elsewhere in the major World markets without suitable compliance and
verification, and yet can be sold in the US. 

 

John E Allen

W. London, UK

 

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com] 
Sent: 30 September 2016 13:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

In general I believe that changing part 15 will be very difficult since it
is a legal  (political) document and would need congress approval for
changes. Different that than in the EU where you have directives and
harmonized standards somehow separately. 

 

Also the US is part of international committees and heavily participates on
emissions and immunity standards. However implementation and enforcing is
always difficult.

 

And finally, isn’t FCC indirectly stating that immunity has to be met as
well?  FCC Part 15.5 (b)

§15.5   General conditions of operation.

(a) Persons operating intentional or unintentional radiators shall not be
deemed to have any vested or recognizable right to continued use of any
given frequency by virtue of prior registration or certification of
equipment, or, for power line carrier systems, on the basis of prior
notification of use pursuant to §90.35(g) of this chapter.

(b) 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.

(c) The operator of a radio frequency device shall be required to cease
operating the device upon notification by a Commission representative that
the device is causing harmful interference. Operation shall not resume until
the condition causing the harmful interference has been corrected.

(d) Intentional radiators that produce Class B emissions (damped wave) are
prohibited.

 

Sincerely, 

 

Dieter Paasche

 



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Re: [PSES] [RFI] Part 15 isn't enough..

[Paasche, Dieter]

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately.

Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.

And finally, isn't FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)
§15.5   General conditions of operation.
(a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of any given 
frequency by virtue of prior registration or certification of equipment, or, 
for power line carrier systems, on the basis of prior notification of use 
pursuant to §90.35(g) of this chapter.
(b) 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.
(c) The operator of a radio frequency device shall be required to cease 
operating the device upon notification by a Commission representative that the 
device is causing harmful interference. Operation shall not resume until the 
condition causing the harmful interference has been corrected.
(d) Intentional radiators that produce Class B emissions (damped wave) are 
prohibited.

Sincerely,

Dieter Paasche



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Re: [PSES] [RFI] Part 15 isn't enough..

[john Allen]

Gert

I have to agree with you on both points ...

And, as more of a "consumer" nowadays (and knowing how much immunity testing 
costs for a single item of equipment!),  I know where I would stand if I lived 
in the US and my recently purchased and expensive equipment displayed the sort 
of behavior outlined on the apartmenttherapy website !

John E Allen
W. London, UK

-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] 
Sent: 30 September 2016 09:40
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Well  John,

The problem is not that immunity regulations are not reasonable (in the US), 
its mere the simple fact that they are regulations that  creates such a heavy 
opposition.
Even under EMC colleagues / members on this list. 

The opinion in the US is that bad products will weed themselves out by 
competition, and that  in the end only immune ovens survive. And everybody is 
happy, without regulations !

But for those early buyers of an oven, of course that actually do some  kind of 
immunity testing for the ovens manufacturer on their own cost.




Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment Independent Consultancy 
+ Services Compliance Testing and Design for CE marking
 according to EC-directives:
- Electro Magnetic Compatibility 2004/108/EC
- Electrical Safety 2006/95/EC
- Medical Devices 93/42/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing Education

Web:www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information that is 
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Any use of the information contained herein (including, but not limited to, 
total or partial reproduction, communication or distribution in any form) by 
persons other than the designated
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Thank you for your co-operation.


-Original Message-
From: john Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Friday 30 September 2016 10:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Cortland

Morning

I have just read some of stories on the apartmenttherapy website you gave the 
link to - and the poor customers who had EMI-related problems have my sincere 
sympathy.

What seems clear to me (and presumably to most people viewing the current 
thread here!) is that relatively simple immunity fixes in the design and 
manufacture  of the products would have prevented most of these problems ever 
occurring - but that even some the most "reputable" manufacturers were cost 
cutting to the bone to avoid doing that for the US market.

However, where I disagree that about the warranty route being the one to go for 
because it put the onus of proof heavily on the poor customers, who will 
generally have no idea whatsoever what the problems with the products are. Most 
of us have had our own problems with products "under warranty" where it has 
been difficult or impossible to get the supplier to acknowledge that the 
product is at fault in some way when we know that it definitely is - and so why 
rely on a type of measure that often does not work and/or is easily deflected 
by the supplier (and especially by the local distributors and sales outlets, 
who generally know even less than the manufacturers about the EMC performance 
of the products that they sell!).

And, as one story clearly showed, manufacturers can and will deny  
responsibility when the warranty runs out - and if the source of a problem 
takes a lot of time to track down and the warranty has then expired, then the 
customer may well have no recourse other than to buy some sort of replacement, 
often at considerable cost.

These types of EMI problems can only get worse as more and more electronic 
devices are introduced and thus more EMI pollution occurs - and the ONLY people 
who can fix it are the manufacturers, not the poor and generally clueless 
customers, and so they should be made to do that before more, and potentially 
disasterous and life-threatening, incidents occur. 

Who can do that in the US: either the Federal Government or, in the current 
situation it appears, the individual States, and you might say that the problem 
is thus insoluable because of "differences" of opinion/attitude between the 
Federal and State bodies? 

However people in the US seem to forget that that is EXACTLY the situation we 
had in Europe 

Re: [PSES] [RFI] Part 15 isn't enough..

[ce-test, qualified testing bv - Gert Gremmen]

Well  John,

The problem is not that immunity regulations are not reasonable (in the US),
its mere the simple fact that they are regulations that  creates such a heavy 
opposition.
Even under EMC colleagues / members on this list. 

The opinion in the US is that bad products will weed themselves out by 
competition, and that
 in the end only immune ovens survive. And everybody is happy, without 
regulations !

But for those early buyers of an oven, of course that actually do some  kind of 
immunity testing
for the ovens manufacturer on their own cost.




Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
    - Electro Magnetic Compatibility 2004/108/EC
    - Electrical Safety 2006/95/EC
    - Medical Devices 93/42/EC
    - Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:    www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
and are intended for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not 
limited to, total or partial reproduction, communication or 
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recipient(s) is prohibited. If you have received this e-mail in error, 
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Thank you for your co-operation.


-Original Message-
From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Friday 30 September 2016 10:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Cortland

Morning

I have just read some of stories on the apartmenttherapy website you gave the 
link to - and the poor customers who had EMI-related problems have my sincere 
sympathy.

What seems clear to me (and presumably to most people viewing the current 
thread here!) is that relatively simple immunity fixes in the design and 
manufacture  of the products would have prevented most of these problems ever 
occurring - but that even some the most "reputable" manufacturers were cost 
cutting to the bone to avoid doing that for the US market.

However, where I disagree that about the warranty route being the one to go for 
because it put the onus of proof heavily on the poor customers, who will 
generally have no idea whatsoever what the problems with the products are. Most 
of us have had our own problems with products "under warranty" where it has 
been difficult or impossible to get the supplier to acknowledge that the 
product is at fault in some way when we know that it definitely is - and so why 
rely on a type of measure that often does not work and/or is easily deflected 
by the supplier (and especially by the local distributors and sales outlets, 
who generally know even less than the manufacturers about the EMC performance 
of the products that they sell!).

And, as one story clearly showed, manufacturers can and will deny  
responsibility when the warranty runs out - and if the source of a problem 
takes a lot of time to track down and the warranty has then expired, then the 
customer may well have no recourse other than to buy some sort of replacement, 
often at considerable cost.

These types of EMI problems can only get worse as more and more electronic 
devices are introduced and thus more EMI pollution occurs - and the ONLY people 
who can fix it are the manufacturers, not the poor and generally clueless 
customers, and so they should be made to do that before more, and potentially 
disasterous and life-threatening, incidents occur. 

Who can do that in the US: either the Federal Government or, in the current 
situation it appears, the individual States, and you might say that the problem 
is thus insoluable because of "differences" of opinion/attitude between the 
Federal and State bodies? 

However people in the US seem to forget that that is EXACTLY the situation we 
had in Europe in the late-middle of the 20th Century - every country had its 
own EMC legislation and that varied from very strictly enforced in Germany to 
quite lax, or at least "light-touch", as we had (and still do have!) in the UK 
and elsewhere. Nevertheless the emerging EMC problem was recognized by the 
national legislatures by the late 70's/early 80's and the EMC Directive (and 
later the R&TTE & RED) was born, and that is why we now have a reasonably 
effective and consistent legal and technical framework for EMC - both emissions 
AND immunity/susceptibility - control across the whole of the Conti

Re: [PSES] [RFI] Part 15 isn't enough..

[john Allen]

Cortland

Morning

I have just read some of stories on the apartmenttherapy website you gave the 
link to - and the poor customers who had EMI-related problems have my sincere 
sympathy.

What seems clear to me (and presumably to most people viewing the current 
thread here!) is that relatively simple immunity fixes in the design and 
manufacture  of the products would have prevented most of these problems ever 
occurring - but that even some the most "reputable" manufacturers were cost 
cutting to the bone to avoid doing that for the US market.

However, where I disagree that about the warranty route being the one to go for 
because it put the onus of proof heavily on the poor customers, who will 
generally have no idea whatsoever what the problems with the products are. Most 
of us have had our own problems with products "under warranty" where it has 
been difficult or impossible to get the supplier to acknowledge that the 
product is at fault in some way when we know that it definitely is - and so why 
rely on a type of measure that often does not work and/or is easily deflected 
by the supplier (and especially by the local distributors and sales outlets, 
who generally know even less than the manufacturers about the EMC performance 
of the products that they sell!).

And, as one story clearly showed, manufacturers can and will deny  
responsibility when the warranty runs out - and if the source of a problem 
takes a lot of time to track down and the warranty has then expired, then the 
customer may well have no recourse other than to buy some sort of replacement, 
often at considerable cost.

These types of EMI problems can only get worse as more and more electronic 
devices are introduced and thus more EMI pollution occurs - and the ONLY people 
who can fix it are the manufacturers, not the poor and generally clueless 
customers, and so they should be made to do that before more, and potentially 
disasterous and life-threatening, incidents occur. 

Who can do that in the US: either the Federal Government or, in the current 
situation it appears, the individual States, and you might say that the problem 
is thus insoluable because of "differences" of opinion/attitude between the 
Federal and State bodies? 

However people in the US seem to forget that that is EXACTLY the situation we 
had in Europe in the late-middle of the 20th Century - every country had its 
own EMC legislation and that varied from very strictly enforced in Germany to 
quite lax, or at least "light-touch", as we had (and still do have!) in the UK 
and elsewhere. Nevertheless the emerging EMC problem was recognized by the 
national legislatures by the late 70's/early 80's and the EMC Directive (and 
later the R&TTE & RED) was born, and that is why we now have a reasonably 
effective and consistent legal and technical framework for EMC - both emissions 
AND immunity/susceptibility - control across the whole of the Continent, which 
is a marketplace of roughly the same size as the US! 

Therefore this sort of issue can "sorted" in the US when the relevant 
authorities at both Federal and State level are finally made to understand the 
size of the problem and that it can only get worse unless collective action is 
taken to address it.

John E Allen
W. London, UK



-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: 30 September 2016 04:56
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/29/2016 4:14 PM, Ghery S. Pettit wrote:
> Preventing harmful interference in all cases is a mighty tough call.  How low 
> do you need to limit emissions?  How high a signal must the product be immune 
> to?  The limits in Part 15 provide a reasonable level of protection, assuming 
> the potential victim is far enough away.  Co-located devices may need more 
> suppression.

That's why I think putting it in the form of a warranty is the best way to get 
manufacturers to pay attention to it.  They know if they do pay attention to 
suppressing interference, the warranty will very rarely be used. Another way is 
an implied warranty of fitness; I understand the UK and Europe enforce implied 
warranties of serviceability, which US merchants often refuse to recognize, but 
twelve states (and the District of Columbia) don't allow them to. See 
http://consumer.findlaw.com/consumer-transactions/what-is-an-implied-warranty-.html


Of course, this isn't legal advice, and I'm neither an attorney nor authorized 
to give legal advice.

I do suspect some manufacturers would refuse to submit bids if a customer firm 
tried to make them eat the cost of noncompliance, not with the limits, but by 
causing harmful interference, forbidden even if the victim is right next to the 
product.

Remember the gas oven that got turned on by a cell phone? Here's another one 
that took *months* to pin down – and had a simple fix the manufacturer might 
have applied for less than a dollar each:

http://www.apartmentth

Re: [PSES] [RFI] Part 15 isn't enough..

[ce-test, qualified testing bv - Gert Gremmen]

Hi  Ghery,

You need to get your numbers right Those tree entities outnumber your "real 
world" by 7.
Economically by a factor 2...
 


Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
 according to EC-directives:
    - Electro Magnetic Compatibility 2004/108/EC
    - Electrical Safety 2006/95/EC
    - Medical Devices 93/42/EC
    - Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:    www.cetest.nl (English) 
Phone :  +31 10 415 24 26
---
This e-mail and any attachments thereto may contain information 
that is confidential and/or protected by intellectual property rights 
and are intended for the sole use of the recipient(s) named above. 
Any use of the information contained herein (including, but not 
limited to, total or partial reproduction, communication or 
distribution in any form) by persons other than the designated 
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please notify the sender either by telephone or by e-mail and 
delete the material from any computer. 
Thank you for your co-operation.

From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: Friday 30 September 2016 00:20
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Immunity testing is required in the EU, South Korea and China.  Nowhere else in 
the world is it required for commercial products.  I’d say that the US is in 
the “real world”.

Ghery S. Pettit

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Thursday, September 29, 2016 3:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Without getting into the specifics of this particular argument, the idea that 
the “rest of the world” has dome something doesn’t necessarily imply that North 
America is “behind.”  In the same sense that if a train has derailed and the 
locomotive is headed over a cliff, we don’t say the caboose is behind and needs 
to catch up.

Ken Javor
Phone: (256) 650-5261

From: john Allen 
Reply-To: john Allen 
Date: Thu, 29 Sep 2016 22:44:48 +0100
To: 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dennis
 
I really  do wonder what World you live in – but then, TBH, based on your 
previous comments of a similar nature, I did not expect anything else!
 
OK, Government “interference” is unwelcome in many cases but Brian O’Connell’s 
post is a  poignant “real world”  comment on what suppliers are facing, and 
what the Government should face up to and address – for the greater good of 
everyone in YOUR country.
 
Without getting trying to “personal”,  “get real”! - a lot of the rest of the 
“real world” has already adopted appropriate requirements to try to prevent 
undue interference problems and so N. America is behind on this issue.
 
John E Allen.
W. London, UK
 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 29 September 2016 22:28
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

The federal government already interferes with US citizens far too much as it 
is – we do not need, nor do most of us want more federal intrusion.  The feds 
are there to keep the wolves at bay and keep out of our lives.  Besides, the 
open market in the US seems to take care of itself in the interference area.  
Does not take long for the consumer to know what is trash and what works.
The only regulations dealing with the spectrum that is needed is the regulation 
to help stop interference to licensed services. That was the intent of the FCC 
to start and there is no reason to change it.
 
 

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
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From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 2:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Dennis
 
And why not – seriously?
 
As was said many years ago – and often repeated! - “what’s right for the goose 
is right for the gander”.
 
In t