Re: [PSES] Rechargeable li-ion batteries in toys for infants...

[Schmidt, Mark]

I believe UL/IEC 62133 would also be applicable to the battery pack and don’t 
forget to contact your local shipping/transport company on li-on battery 
requirements UN3480 and 3481.

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Re: [PSES] Equipment EMI Issue

[Sykes, Bob]

Robert,

Explain the FCC Rules to your customer and that while your equipment conforms 
to the technical requirements, that is not always sufficient to prevent 
interference in all cases.  If their eyes haven't glazed over yet, you might 
explain the effect of source-to-victim separation distance.

The cellular carrier may well be experiencing an interference level of 20dB or 
more.  But is all of that attributable to your customers equipment?  Are there 
other sources?  The carriers are pretty good at locating the loudest/nearest 
source of interference, but typically do not quantify that interference 
strength.  Fortunately it is not necessary if you can get cooperation from both 
parties.  If so……

Perform an "on-off" test while the cell carrier monitors their Received Signal 
Strength Indicator in real time.  Their RSSI will drop by X dB when your 
customer's equipment is switched off.  X represents the maximum reduction in 
interference level that could be achieved if your customer's equipment were 
perfectly quiet.  Now you have a best case (dB) number.  Any remaining 
interference is not yours.

Temporarily shutting down a customer's equipment for this test can be painful.  
It really helps if they understand the situation and the FCC Rules.  The 
cellular carrier interference hunters are generally cooperative and helpful.  
They just want to resolve the issue ASAP.

Hope this helps,
Bob Sykes


From: Moeller, Robert T. [mailto:robert.moel...@banctec.com]
Sent: Wednesday, September 26, 2018 9:41 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Equipment EMI Issue

Hello,
Maybe someone can help with this question:  We have had one of our systems 
installed and operating at a customer site in the US, and now suddenly a local 
Cell Ph Company has made complaint that we have an unintentional signal 
radiating at 780 MHz which is interfering with their Cell Tower.  Our equipment 
is EMC tested to CISPR Class A for business only use, and at 780 Mhz our 
radiated Level at 3Meters is under the Class A limit of 57 dB at 780 Mhz.  
Question is, can the complaining company legally demand that we drop the signal 
further, they may be looking at a necessary reduction of current level by 20 dB 
lower.

Thank You



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Re: [PSES] Equipment EMI Issue

[Cortland Richmond]

One thing that could (and should) have been done when locating near a 
licensed service's site where interference is possible is to analyze the 
probability that interference will occur at the "allowed" amount.    
Compliance of ONE apparatus could be good enough, but a business center 
may have a number on-frequency sources  whose emissions add at the 
victim antenna.


Some years ago, a GR-1089 system under test suddenly became 
non-compliant, which was  was traced to a firmware change; the backup 
controller's clock taking too long to start up if the primary failed, 
was "cleverly" worked around in firmware update leaving the clock on.   
Unfortunately, leaving power on the secondary clock without quasi-random 
modulation pushed its emissions up 6 dB until I suggested also leaving 
that hot as well.



Cortland Richmond




On 26/18 9:40 AM, Moeller, Robert T. wrote:


Hello,

Maybe someone can help with this question: We have had one of our 
systems installed and operating at a customer site in the US, and now 
suddenly a local Cell Ph Company has made complaint that we have an 
unintentional signal radiating at 780 MHz which is interfering with 
their Cell Tower.  Our equipment is EMC tested to CISPR Class A for 
business only use, and at 780 Mhz our radiated Level at 3Meters is 
under the Class A limit of 57 dB at 780 Mhz. Question is, can the 
complaining company legally demand that we drop the signal further, 
they may be looking at a necessary reduction of current level by 20 dB 
lower.


Thank You

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Re: [PSES] Rechargeable li-ion batteries in toys for infants...

[Scott Aldous]

With regard to your first query, if you plan to ship this product to the US
market, you will need to comply with ASTM F963

also. Clause 4.25 has specific requirements for battery operated toys. Even
if not applicable, taking a look may be worthwhile.

On Thu, Sep 27, 2018 at 8:00 AM Schmidt, Mark  wrote:

> Matt,
>
>
>
> I think your problem will be that the POD is removable which then makes it
> user accessible when washing or otherwise. End user will have access to
> pins/connector to charge the battery. I am note a toy expert but If the
> charger is shipped with the toy product then it is intended to be used with
> the toy - what is Note 3 in section 1 (scope) of EN62115.
>
>
>
> Mark
> Please be advised that this email may contain confidential information. If
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> binding effect of any digital or other electronic reproduction of a manual
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> -
> 
>
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-- 
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scottald...@google.com | 650-253-1994

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Re: [PSES] Rechargeable li-ion batteries in toys for infants...

[Schmidt, Mark]

Matt,

I think your problem will be that the POD is removable which then makes it user 
accessible when washing or otherwise. End user will have access to 
pins/connector to charge the battery. I am note a toy expert but If the charger 
is shipped with the toy product then it is intended to be used with the toy - 
what is Note 3 in section 1 (scope) of EN62115.

Mark
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Re: [PSES] Equipment EMI Issue

[S Drysdale]

Hi Robert,

Passing the FCC unintentional limits may give reasonable presumption of
conformity for non-interference to licensed services requirement, however
it does not guarantee such.  As others have pointed out, passing this may
not be sufficient in itself.  However, if the grantee had complained to the
FCC directly without involving you first, and the FCC found your device to
be interfering, the devices compliance might have helped present a
reasonable case of due diligence in your response, but you would still an
obligation to remedy the issue or cease operation.  The due diligence might
have reduced a fine the FCC applied, which can be quite substantial.   As
is, it looks the the grantee went to you first, so that scenario is moot.
It looks like the solution is to work with your customer to fix the
interference or have them cease operation of your device.  That being said,
I'm not sure if a reduction of 20 dB is necessary, but I don't have the
details to provide an informed response.  Sometimes it is an alternative to
shift the frequency in some way such that the interference to in-band of
nearby licensed services is non-existent.

Best Regards,
Scott Drysdale
OOO - Own Opinions Only.



On Wed, Sep 26, 2018 at 9:41 AM Moeller, Robert T. <
robert.moel...@banctec.com> wrote:

> Hello,
>
> Maybe someone can help with this question:  We have had one of our systems
> installed and operating at a customer site in the US, and now suddenly a
> local Cell Ph Company has made complaint that we have an unintentional
> signal radiating at 780 MHz which is interfering with their Cell Tower.
> Our equipment is EMC tested to CISPR Class A for business only use, and at
> 780 Mhz our radiated Level at 3Meters is under the Class A limit of 57 dB
> at 780 Mhz.  Question is, can the complaining company legally demand that
> we drop the signal further, they may be looking at a necessary reduction of
> current level by 20 dB lower.
>
>
>
> Thank You
>
>
>
>
>
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
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>
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> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
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>

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Re: [PSES] Rechargeable li-ion batteries in toys for infants...

[John Woodgate]

I think your interpretation is correct, but you may need to defend it 
against other opinions. But what happens if he becomes Prime Minister? (;-)


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-09-27 11:59, Matthew Wilson wrote:
We are at the initial stages of product design for a sleep aid for 
infants i.e. intended for use with newborn age upwards.  The project 
product name is called 'Jezza' and comprises a soft-toy that in turn 
houses the electronics in a 'pod'.  The pod can be removed from the 
soft-toy to allow machine-washing of 'Jezza'.





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[PSES] Rechargeable li-ion batteries in toys for infants...

[Matthew Wilson]

We are at the initial stages of product design for a sleep aid for infants i.e. 
intended for use with newborn age upwards.  The project product name is called 
'Jezza' and comprises a soft-toy that in turn houses the electronics in a 
'pod'.  The pod can be removed from the soft-toy to allow machine-washing of 
'Jezza'.

We are working through the necessary compliance for toy safety and have a query 
about the use of an internal rechargeable lithium-ion battery pack within the 
'pod' and how we are interpreting the requirements of EN62115.

I thought I would seek the opinions from the list here please just to see if we 
are OK in regards our thinking, which I will explain below.

'Jezza' will need to comply with EN 62115:2005+A2+A11+A12, electrical safety 
for toys.

To provide power for 'Jezza' it is intended that a lithium-ion type battery 
'pack' is contained within the pod.  This battery pack is not user accessible.  
The choice of this type of battery technology is to meet the client's design 
requirements in terms of 'usable battery life' between charging.

The first query is that we have not seen any specific compliance restrictions 
regarding the use of lithium-ion type batteries in toys and especially toys 
intended for use from birth age upwards.  Is anyone, however aware of any 
restrictions, other than of course meeting all the safety requirements with the 
battery pack?  Are there none regarding toys?

The second is regarding the appropriate charging method for this battery.

In the EN 62115 standard is a clause 14.4, "Transformer toys and dual supply 
toys shall not be intended for use by children under 3 years old."

Just to interpret that, in standards "shall" indicates a requirement.  In the 
ISO/IEC Directives, Part 2, Seventh edition, 2016, 3.3.3, a requirement is 
defined as an "expression in the content of a document conveying objectively 
verifiable criteria to be fulfilled and from which no deviation is permitted if 
compliance with the document is to be claimed."

The definition of 'transformer toy' and 'dual supply toy' is given in an 
earlier clause 3.1.3 within EN62115.

3.1.3
transformer toy
toy that is connected  to the supply mains through a transformer for toys and 
using the supply mains as the only source of electrical energy

3.1.4
dual-supply toy
toy that can be operated as a battery toy and either simultaneously or 
alternatively as a transformer toy

3.1.8
transformer for toys
safety isolating transformer specially designed to supply toys operating at 
safety extra-low voltage not exceeding 24V (Note the transformer may supply 
a.c. or d.c. or both).

Just a note - 'transformer' in this standard appears to be being used in a 
colloquial sense as nowadays most power supplies (probably due to ErP directive 
as well as cost) are a switched mode design rather than a basic 'step down' 
transformer type, although the switched mode type may still contain a 
transformer element.

Given the constraints above about re 'Transformer toys and dual supply toys 
shall not be intended for use by children under 3 years old' we are considering 
the design so that the pod has to be taken out of 'Jezza' by a responsible 
person (adult) and then placed on or in (depending on industrial design) a 
'docking station' base to recharge.

The docking station would have a physical interface using pogo pins and lands, 
or maybe a knife connector plug/receptacle, between it and the pod to charge 
the device.  The pod would not function as a sleep-aid when charging.

The dock would be connected to an external mains-DC power supply e.g. 5 or 12V 
output from the power supply to a connector on the dock.  This docking station 
would charge the pod. The arrangement is intended to be very much like a 
cordless DECT telephone or similar.

Separate chargers are not considered to be a toy even if they are supplied with 
it as per Note 3 in section 1 (scope) of EN62115.

We wanted to gather opinion on whether this interpretation, that we can put a 
rechargeable pack within the sealed pod and charge it with a separate dock, is 
correct with regards complying that a 'transformer toy and dual supply toy 
shall not be intended for use by children under 3 years old'.   We take that to 
mean it would not be acceptable to have e.g. a USB socket on the pod for 
connection to a 'charger' via a cable.

Thank you all for reading and any info regarding all that.

Kind regards,


Matthew Wilson
Technical Director
https://gbelectronics.uk







Matthew Wilson
Technical Director


[GBE]
https://gbelectronics.uk


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