[PSES] FW: [PSES] Question on 15.407 spurious emissions testing method enforcement

[itl-emc user group]

From: micha...@acbcert.com 
Sent: Thursday, November 21, 2019 11:24 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Question on 15.407 spurious emissions testing method 
enforcement

Hi Charles, I hope you are well.

When performing your 15.109 emissions (part 15 subpart B) on the digital device 
part of the product, you should have the transmitter part active (powered) but 
it does not need to be transmitting.   Receiver mode would be nice, or active 
scanning, or something like that.
You then test your unintentional radiator emissions from the whole product, to 
Part 15.109, with module powered but not transmitting.
Remember that your module may now become the highest frequency item in your 
product, so consider that when figuring out which frequency to test to.
(e.g., if you installed a 5.85 GHz WLAN, then your 15.109 emissions need to be 
done up to ≥29.25 GHz).
If you see emissions exceeding the limit which are from the digital device 
operation of any part of your product (host or module), it is a fail.

Then, with your module transmitting, you need to perform the checks to ensure 
that the final product meets the transmitter spurious emissions tests/limits of 
15.407.
If you see emissions exceeding the limit which are from the transmitter part of 
your product, or a result of the interaction between transmitter and host, it 
is a fail.

If you see a fail, fix it, get it passing, sell it, get rich, retire.   I think 
that's the plan, at least.


Thanks,

Michael.


Michael Derby
Senior Regulatory Engineer
Director
ACB Europe

Certification Resource for the Wireless Industry
Web:   www.acbcert.com

e-mail:micha...@acbcert.com
Mobile phone:   (+44) 7939 880829   (UK area code)
Corporate office phone: USA:   (+1) 703 847 4700




From: Grasso, Charles mailto:charles.gra...@dish.com>>
Sent: 20 November 2019 17:38
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Question on 15.407 spurious emissions testing method enforcement

EMC Gurus,

According to KDB789033 (Note3) : After January 01, 2019 all emissions are 
required to meet the limits as specified in the rules and it will not be 
sufficient to
show compliance to the limits specified in Section 15.209.  [This means that, 
for Bands 1, 2a, and 2c, there is ONLY a Peak limit for spurious radiated 
emissions
that are outside of the restricted bands (-27 dBm/MHz, or 68.2 dBuV/m @ 3m).  
[There is no Average limit for these spurs that are not in restricted bands.]

Question: Based on the modular method for applying FCC regulations it is my 
understanding that a radio should be tested to compliance for limits as 
specified in Sections 15.407(b)(1-3)
BUT then (even with the radio on) the digital portion of an EUT needs to show 
compliance to only 15.109? In other words, when testing the digital portion of 
a radio
*any* radio spurious emissions that exceed the 109 limits can be ignored?

Am I wrong?

Thanks!

Charles Grasso
(w) 303-706-5467
(c) 303-204-2974

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Re: [PSES] HV relay

[Boštjan Glavič]

Dear all

Thank you for your valuable feedbacks. I have now enough arguments for customer.

Best regards
Bostjan


From: Richard Nute 
Sent: Tuesday, November 26, 2019 6:41:05 AM
To: 'Boštjan Glavič' ; EMC-PSTC@LISTSERV.IEEE.ORG 

Subject: RE: [PSES] HV relay


Dear Boštjan:

As you know, a relay, including a vacuum relay, has two circuits.  One is the 
coil that controls the contacts.  The other is the contacts.  Usually, these 
are separate circuits.  If the one of the circuits provides a safeguard 
function, then the two circuits must meet clearance and creepage requirements 
so as not to compromise the safeguard insulation.

Usually, the open contacts do not provide a safeguard insulation (functional 
only), hence, no safeguard clearance or creepage requirements apply to the open 
contacts.

Some interpretations or applications, e.g., power disconnect, may apply 
clearance and creepage to the open contacts.

Best regards,
Rich




From: Boštjan Glavič 
Sent: Monday, November 25, 2019 7:22 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] HV relay

Dear experts,

Is anyone familiar with requirements for HV relay in vacuum? Are clearances and 
creepage distances between contacts applicable for such relay?

Thank you for your support.

Best regards,
Boštjan

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Re: [PSES] HV relay

[Richard Nute]

 

Dear Boštjan:

 

As you know, a relay, including a vacuum relay, has two circuits.  One is
the coil that controls the contacts.  The other is the contacts.  Usually,
these are separate circuits.  If the one of the circuits provides a
safeguard function, then the two circuits must meet clearance and creepage
requirements so as not to compromise the safeguard insulation.  

 

Usually, the open contacts do not provide a safeguard insulation (functional
only), hence, no safeguard clearance or creepage requirements apply to the
open contacts.

 

Some interpretations or applications, e.g., power disconnect, may apply
clearance and creepage to the open contacts.  

 

Best regards,

Rich

 

 

 

 

From: Boštjan Glavič  
Sent: Monday, November 25, 2019 7:22 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] HV relay

 

Dear experts,

 

Is anyone familiar with requirements for HV relay in vacuum? Are clearances
and creepage distances between contacts applicable for such relay?

 

Thank you for your support.

 

Best regards,

Boštjan

 


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Re: [PSES] HV relay

[Douglas Powell]

Sorry, typo should be IEC 60664-1.

Doug


On Mon, Nov 25, 2019 at 9:07 AM Doug Powell  wrote:

> BOštjan
>
> In the past when I've had to deal with this, I explained to the safety
> inspector that internal spacings (clearance and creepage) are not
> applicable. Nearly all IEC based standards use IEC 60644-1 as the basis of
> their spacings determination. Since there is no atmosphere inside a vacuum
> relay, things like pollution degree do not apply, additionally you can
> invoke the Paschen's Law for voltage standoff capability, which is very
> high for a deep vacuum.  I have achieved 30 kV with just few millimeters.
> Of course, nearly all vacuum HV relays use shaped electrodes for homogenous
> e-field control.
>
> That said, normal spacings concern still apply to the exterior surfaces of
> the relay.  Since most of these are made of glass-like materials or
> ceramics you can claim CTI I for the material class.
>
> Best fo luck, doug
>
> --
> Douglas E Powell
> doug...@gmail.com
> https://www.linkedin.com/in/dougp01
>
> Currently working from my Android phone
> *From:* bostjan.gla...@siq.si
> *Sent:* November 25, 2019 8:22 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Reply-to:* bostjan.gla...@siq.si
> *Subject:* [PSES] HV relay
>
> Dear experts,
>
>
>
> Is anyone familiar with requirements for HV relay in vacuum? Are
> clearances and creepage distances between contacts applicable for such
> relay?
>
>
>
> Thank you for your support.
>
>
>
> Best regards,
>
> BOštjan
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
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-- 

Douglas E Powell

doug...@gmail.com
http://www.linkedin.com/in/dougp01

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Re: [PSES] HV relay

[Doug Powell]

  BOštjanIn the past when I've had to deal with this, I explained to the safety inspector that internal spacings (clearance and creepage) are not applicable. Nearly all IEC based standards use IEC 60644-1 as the basis of their spacings determination. Since there is no atmosphere inside a vacuum relay, things like pollution degree do not apply, additionally you can invoke the Paschen's Law for voltage standoff capability, which is very high for a deep vacuum.  I have achieved 30 kV with just few millimeters. Of course, nearly all vacuum HV relays use shaped electrodes for homogenous e-field control.  That said, normal spacings concern still apply to the exterior surfaces of the relay.  Since most of these are made of glass-like materials or ceramics you can claim CTI I for the material class.  Best fo luck, doug--Douglas E Powelldoug...@gmail.comhttps://www.linkedin.com/in/dougp01  Currently working from my Android phone   From: bostjan.gla...@siq.siSent: November 25, 2019 8:22 AMTo: EMC-PSTC@LISTSERV.IEEE.ORGReply-to: bostjan.gla...@siq.siSubject: [PSES] HV relay  
Dear experts,
 
Is anyone familiar with requirements for HV relay in vacuum? Are clearances and creepage distances between contacts applicable for such relay?
 
Thank you for your support.
 
Best regards,
BOštjan

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Re: [PSES] HV relay

[Scott Aldous]

Hi Boštjan,

I've worked with this type of relay in the past. Distance between contacts
in the vacuum is unlikely to meet standard clearance requirements if you
are relying on the contact gap for safety isolation. Presumably the reason
for the vacuum in the first place is to provide very low pressure in order
to take advantage of the low end of Paschen's curve (see Paschen's law
 from Wikipedia), so smaller
clearances can be used without breakdown.

IEC 62368-1, Annex K (for safety interlocks) has some requirements that
might be useful, but the 3rd edition is clearer than 2nd. See K.7.1 from
3rd edition. There is an allowance for the contact gap to be evaluated by
electric strength test rather than the separation requirements outlined in
a), b) or c), as well as some other clauses that must be applied including
endurance test.

Note that reed switches tend to fail closed as the contacts can stick, so
some type of periodic functional check or other detection method is
advisable. Also, the standard doesn't address reliability of the vacuum
integrity over the life of the relay other than by application of the
endurance test.

On Mon, Nov 25, 2019 at 7:22 AM Boštjan Glavič 
wrote:

> Dear experts,
>
>
>
> Is anyone familiar with requirements for HV relay in vacuum? Are
> clearances and creepage distances between contacts applicable for such
> relay?
>
>
>
> Thank you for your support.
>
>
>
> Best regards,
>
> BOštjan
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including how to
> unsubscribe) 
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>
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>


-- 
Scott Aldous | Regulatory Compliance Program Manager |
scottald...@google.com | 650-253-1994

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[PSES] HV relay

[Boštjan Glavič]

Dear experts,

Is anyone familiar with requirements for HV relay in vacuum? Are clearances and 
creepage distances between contacts applicable for such relay?

Thank you for your support.

Best regards,
BOštjan

-

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