Re: [PSES] Mandatory certification

[Kevin Robinson]

>From OSHA's perspective, the employer where the equipment is installed is
responsible for ensuring the equipment is "acceptable" as defined in 29 CFR
1910.399
https://www.govinfo.gov/content/pkg/CFR-2019-title29-vol5/pdf/CFR-2019-title29-vol5-sec1910-399.pdf
.

In reality, most manufacturers assume the burden of certification as it
helps with the sale of the product and certification requires intimate
knowledge of the product components and specifications.

That said, if the product is sold in retail stores, most major retailers
require product certification before the product can be sold on their
shelves.



On Fri, Feb 21, 2020 at 3:57 PM Stultz, Mark 
wrote:

> Hello Kevin,
>
>
>
> Thanks for the great explanation.  Who is ultimately responsible for
> ensuring that equipment is certified by a NRTL?  Does the final
> responsibility fall on the purchaser/end-user or on the manufacturer?
>
>
>
> Best regards,
>
>
>
> *Mark Stultz* | CMSE® | Sealed Air | Automated Packaging Systems |
> Streetsboro, OH | 330-342-2402
>
>
>
> *From:* Kevin Robinson 
> *Sent:* Friday, February 21, 2020 11:49 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Mandatory certification
>
>
>
>
>
>  *CAUTION:* This email originated from outside of the organization. Do
> not click links or open attachments unless you recognize the sender and
> know the content is safe.
>
>
>
> Brian,
>
>
>
> I manage the NRTL Program for OSHA.  As I am responding from my personal
> address, nothing I say here can be considered as a response from OSHA (but
> if you contact me at robinson.ke...@dol.gov, I will state the same thing
> I say here.)
>
>
>
> As for low production units, you might be able to save costs by utilizing
> families.  If you can determine the worst case condition(s) you might be
> able to simply test a few products and have that representative of all of
> the units you manufacture.  As for costs, when I worked for a NRTL (granted
> this was 12 years ago), three field evaluations were about the same cost as
> a full certification.  Yes, you might have factory surveillance costs and
> certification mark costs, but compared to the actual testing and
> certification, those costs are minimal.
>
>
>
> With regard to your interpretation of 29 CFR 1910.399:
>
>
>
> 1) This clause only covers NRTL Certification.  Field evaluations are NOT
> part of the NRTL program.  NRTLs who are issuing Field certificates and
> labels are doing so under their own name and not as a NRTL.
>
>
>
> 2) There are some products for which no NRTL has been able to demonstrate
> they have the necessary test equipment and procedures for.  For example,
> several years ago, OSHA  required crane insulating links to be tested and
> certified by a NRTL.  Until last year, there was no test standard for
> insulating links and the equipment required is very specialized.  OSHA has
> not yer recognized a NRTL to test and certify these insulating links.
> There are other examples where there are no standards for certain products,
> or where no NRTL has the capability to test to the standard.  In such an
> instance, the local AHJ may approve of the installation, or if another
> Federal Agency has jurisdiction, they may approve of the installation.  In
> my experience, this is very rare, but it is an option.
>
>
>
> 3) This option only applies to unique custom made equipment that is made
> specifically for an employer.  The example I always give is the requirement
> would apply if a potato farmer contracted with a company to make a custom
> machine that he designed to separate rocks from his potato crop.  This was
> a machine made to his exact and custom specifications, and there is nothing
> else like it.  The manufacturer could conduct some basic safety testing and
> prepare a report to give to the employer to present to OSHA if they ever
> asked for it. Either the manufacturer could do the testing themselves, or
> they could hire someone to conduct the testing for them.  The requirement
> however would NOT apply if you created a "Custom" computer purchased from a
> major manufacturer (ex Dell, Apple, Lenovo etc.) .  While you can go to
> their website and build a custom machine to your exact specifications, the
> big manufacturers aren't really making custom machines.
>
>
>
> *Everything below this represents my own personal opinion and is something
> I would not say in any official capacity (mostly because manufacturer self
> declaration has so many implications in a broad spectrum of areas).*
>
>
>
> As for allowing manufacturer self declaration, I would encourage you to
> look at a Request for Information (RFI) that OSHA published almost 10 years
> ago https://www.regulations.gov/document?D=OSHA-2008-0032-0099
> 

Re: [PSES] Mandatory certification

[Kevin Robinson]

Lauren,


1.   No NRTL per se offers field labeling because field labeling is not
in scope of NRTL ‘responsibilities’. An NRTL company might offer it, but it
is not an NRTL function.

<<>> Correct.  As Field inspections/certifications are not a
function of OSHA's NRTL Program, if an NRTL is offering such an evaluation
(and most do), they are issuing it based on the reputation of their brand,
or possibly as accredited by an accreditation body to NFPA 790 & 791.  They
are however not operating as an NRTL.


2.   {Quite to my surprise!} the implication of 29 CFR 1910.399(2) is
that a company essentially has to try each NRTL to see if it “accepts,
certifies, lists, labels, or determines to be safe” an equipment as part of
their NRTL scope. Only if all NRTLs are reasonably investigated could one
‘advance’ in the clause to e.g., turning to a local authority (to the
location of installation) for enforcing occupational safety provisions of
the National Electrical Code etc… at which point field labeling could be
acceptable if such authority found it so.

<<>> OSHA has not said officially (in the form of an official
interpretation)
https://www.osha.gov/laws-regs/standardinterpretations/standardnumber/1910 to
what end a manufacturer must go to prove that no NRTL can certify a piece
of equipment, but yes, that is generally correct that you should reach out
to all of the NRTLs before invoking this clause.


3.   29 CFR 1910.399(3) is not really applicable to a case of equipment
customization such as adding customer specific bells or whistles to a
product that is otherwise common to units sold to other customers. It is
focused on ‘extremely’ bespoke equipment essentially designed by the
workplace owner.

<<>> Correct.

On Fri, Feb 21, 2020 at 3:52 PM  wrote:

> Kevin,
>
>
>
> Thanks for this detailed assessment.  I would like to make sure I
> understand your guidance.
>
>
>
> 1.   No NRTL per se offers field labeling because field labeling is
> not in scope of NRTL ‘responsibilities’. An NRTL company might offer it,
> but it is not an NRTL function.
>
> 2.   {Quite to my surprise!} the implication of 29 CFR 1910.399(2) is
> that a company essentially has to try each NRTL to see if it “accepts,
> certifies, lists, labels, or determines to be safe” an equipment as part of
> their NRTL scope. Only if all NRTLs are reasonably investigated could one
> ‘advance’ in the clause to e.g., turning to a local authority (to the
> location of installation) for enforcing occupational safety provisions of
> the National Electrical Code etc… at which point field labeling could be
> acceptable if such authority found it so.
>
> 3.   29 CFR 1910.399(3) is not really applicable to a case of
> equipment customization such as adding customer specific bells or whistles
> to a product that is otherwise common to units sold to other customers. It
> is focused on ‘extremely’ bespoke equipment essentially designed by the
> workplace owner.
>
>
>
> Are those roughly correct? (any further clarifications welcome).
>
>
>
> Regards,
>
> -Lauren Crane
>
>
>
> *From:* Kevin Robinson 
> *Sent:* Friday, February 21, 2020 10:49 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Mandatory certification
>
>
>
> Brian,
>
>
>
> I manage the NRTL Program for OSHA.  As I am responding from my personal
> address, nothing I say here can be considered as a response from OSHA (but
> if you contact me at robinson.ke...@dol.gov, I will state the same thing
> I say here.)
>
>
>
> As for low production units, you might be able to save costs by utilizing
> families.  If you can determine the worst case condition(s) you might be
> able to simply test a few products and have that representative of all of
> the units you manufacture.  As for costs, when I worked for a NRTL (granted
> this was 12 years ago), three field evaluations were about the same cost as
> a full certification.  Yes, you might have factory surveillance costs and
> certification mark costs, but compared to the actual testing and
> certification, those costs are minimal.
>
>
>
> With regard to your interpretation of 29 CFR 1910.399:
>
>
>
> 1) This clause only covers NRTL Certification.  Field evaluations are NOT
> part of the NRTL program.  NRTLs who are issuing Field certificates and
> labels are doing so under their own name and not as a NRTL.
>
>
>
> 2) There are some products for which no NRTL has been able to demonstrate
> they have the necessary test equipment and procedures for.  For example,
> several years ago, OSHA  required crane insulating links to be tested and
> certified by a NRTL.  Until last year, there was no test standard for
> insulating links and the equipment required is very specialized.  OSHA has
> not yer recognized a NRTL to test and certify these insulating links.
> There are other examples where there are no standards for certain products,
> or where no NRTL has the capability to test to the standard.  In such an
> instance, the local AHJ may

Re: [PSES] Mandatory certification

[Stultz, Mark]

Hello Kevin,

Thanks for the great explanation.  Who is ultimately responsible for ensuring 
that equipment is certified by a NRTL?  Does the final responsibility fall on 
the purchaser/end-user or on the manufacturer?

Best regards,

Mark Stultz | CMSE® | Sealed Air | Automated Packaging Systems | Streetsboro, 
OH | 330-342-2402

From: Kevin Robinson 
Sent: Friday, February 21, 2020 11:49 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Mandatory certification


 CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.

Brian,

I manage the NRTL Program for OSHA.  As I am responding from my personal 
address, nothing I say here can be considered as a response from OSHA (but if 
you contact me at robinson.ke...@dol.gov, I will 
state the same thing I say here.)

As for low production units, you might be able to save costs by utilizing 
families.  If you can determine the worst case condition(s) you might be able 
to simply test a few products and have that representative of all of the units 
you manufacture.  As for costs, when I worked for a NRTL (granted this was 12 
years ago), three field evaluations were about the same cost as a full 
certification.  Yes, you might have factory surveillance costs and 
certification mark costs, but compared to the actual testing and certification, 
those costs are minimal.

With regard to your interpretation of 29 CFR 1910.399:

1) This clause only covers NRTL Certification.  Field evaluations are NOT part 
of the NRTL program.  NRTLs who are issuing Field certificates and labels are 
doing so under their own name and not as a NRTL.

2) There are some products for which no NRTL has been able to demonstrate they 
have the necessary test equipment and procedures for.  For example, several 
years ago, OSHA  required crane insulating links to be tested and certified by 
a NRTL.  Until last year, there was no test standard for insulating links and 
the equipment required is very specialized.  OSHA has not yer recognized a NRTL 
to test and certify these insulating links.  There are other examples where 
there are no standards for certain products, or where no NRTL has the 
capability to test to the standard.  In such an instance, the local AHJ may 
approve of the installation, or if another Federal Agency has jurisdiction, 
they may approve of the installation.  In my experience, this is very rare, but 
it is an option.

3) This option only applies to unique custom made equipment that is made 
specifically for an employer.  The example I always give is the requirement 
would apply if a potato farmer contracted with a company to make a custom 
machine that he designed to separate rocks from his potato crop.  This was a 
machine made to his exact and custom specifications, and there is nothing else 
like it.  The manufacturer could conduct some basic safety testing and prepare 
a report to give to the employer to present to OSHA if they ever asked for it. 
Either the manufacturer could do the testing themselves, or they could hire 
someone to conduct the testing for them.  The requirement however would NOT 
apply if you created a "Custom" computer purchased from a major manufacturer 
(ex Dell, Apple, Lenovo etc.) .  While you can go to their website and build a 
custom machine to your exact specifications, the big manufacturers aren't 
really making custom machines.

Everything below this represents my own personal opinion and is something I 
would not say in any official capacity (mostly because manufacturer self 
declaration has so many implications in a broad spectrum of areas).

As for allowing manufacturer self declaration, I would encourage you to look at 
a Request for Information (RFI) that OSHA published almost 10 years ago 
https://www.regulations.gov/document?D=OSHA-2008-0032-0099
  You can review all of the questions OSHA asked and the public responses here 
https://www.regulations.gov/docket?D=OSHA-2008-0032.
  The United States has a very robust product safety system and as a result, 
there are very few injuries as a direct result of products that are NRTL 
certified.  While you may feel that $6000 - 8000 is expensive to product 
certification, I have to ask, and I do

Re: [PSES] Mandatory certification

[lauren . crane]

Kevin,

Thanks for this detailed assessment.  I would like to make sure I understand 
your guidance.


1.   No NRTL per se offers field labeling because field labeling is not in 
scope of NRTL ‘responsibilities’. An NRTL company might offer it, but it is not 
an NRTL function.

2.   {Quite to my surprise!} the implication of 29 CFR 1910.399(2) is that 
a company essentially has to try each NRTL to see if it “accepts, certifies, 
lists, labels, or determines to be safe” an equipment as part of their NRTL 
scope. Only if all NRTLs are reasonably investigated could one ‘advance’ in the 
clause to e.g., turning to a local authority (to the location of installation) 
for enforcing occupational safety provisions of the National Electrical Code 
etc… at which point field labeling could be acceptable if such authority found 
it so.

3.   29 CFR 1910.399(3) is not really applicable to a case of equipment 
customization such as adding customer specific bells or whistles to a product 
that is otherwise common to units sold to other customers. It is focused on 
‘extremely’ bespoke equipment essentially designed by the workplace owner.

Are those roughly correct? (any further clarifications welcome).

Regards,
-Lauren Crane

From: Kevin Robinson 
Sent: Friday, February 21, 2020 10:49 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Mandatory certification

Brian,

I manage the NRTL Program for OSHA.  As I am responding from my personal 
address, nothing I say here can be considered as a response from OSHA (but if 
you contact me at robinson.ke...@dol.gov, I will 
state the same thing I say here.)

As for low production units, you might be able to save costs by utilizing 
families.  If you can determine the worst case condition(s) you might be able 
to simply test a few products and have that representative of all of the units 
you manufacture.  As for costs, when I worked for a NRTL (granted this was 12 
years ago), three field evaluations were about the same cost as a full 
certification.  Yes, you might have factory surveillance costs and 
certification mark costs, but compared to the actual testing and certification, 
those costs are minimal.

With regard to your interpretation of 29 CFR 1910.399:

1) This clause only covers NRTL Certification.  Field evaluations are NOT part 
of the NRTL program.  NRTLs who are issuing Field certificates and labels are 
doing so under their own name and not as a NRTL.

2) There are some products for which no NRTL has been able to demonstrate they 
have the necessary test equipment and procedures for.  For example, several 
years ago, OSHA  required crane insulating links to be tested and certified by 
a NRTL.  Until last year, there was no test standard for insulating links and 
the equipment required is very specialized.  OSHA has not yer recognized a NRTL 
to test and certify these insulating links.  There are other examples where 
there are no standards for certain products, or where no NRTL has the 
capability to test to the standard.  In such an instance, the local AHJ may 
approve of the installation, or if another Federal Agency has jurisdiction, 
they may approve of the installation.  In my experience, this is very rare, but 
it is an option.

3) This option only applies to unique custom made equipment that is made 
specifically for an employer.  The example I always give is the requirement 
would apply if a potato farmer contracted with a company to make a custom 
machine that he designed to separate rocks from his potato crop.  This was a 
machine made to his exact and custom specifications, and there is nothing else 
like it.  The manufacturer could conduct some basic safety testing and prepare 
a report to give to the employer to present to OSHA if they ever asked for it. 
Either the manufacturer could do the testing themselves, or they could hire 
someone to conduct the testing for them.  The requirement however would NOT 
apply if you created a "Custom" computer purchased from a major manufacturer 
(ex Dell, Apple, Lenovo etc.) .  While you can go to their website and build a 
custom machine to your exact specifications, the big manufacturers aren't 
really making custom machines.

Everything below this represents my own personal opinion and is something I 
would not say in any official capacity (mostly because manufacturer self 
declaration has so many implications in a broad spectrum of areas).

As for allowing manufacturer self declaration, I would encourage you to look at 
a Request for Information (RFI) that OSHA published almost 10 years ago 
https://www.regulations.gov/document?D=OSHA-2008-0032-0099  You can review all 
of the questions OSHA asked and the public responses here 
https://www.regulations.gov/docket?D=OSHA-2008-0032.  The United States has a 
very robust product safety system and as a result, there are very few injuries 
as a direct result of products that are NRTL certified.  While you may feel 
that

Re: [PSES] Mandatory certification

[Kevin Robinson]

Brian,

I manage the NRTL Program for OSHA.  As I am responding from my personal
address, nothing I say here can be considered as a response from OSHA (but
if you contact me at robinson.ke...@dol.gov, I will state the same thing I
say here.)

As for low production units, you might be able to save costs by utilizing
families.  If you can determine the worst case condition(s) you might be
able to simply test a few products and have that representative of all of
the units you manufacture.  As for costs, when I worked for a NRTL (granted
this was 12 years ago), three field evaluations were about the same cost as
a full certification.  Yes, you might have factory surveillance costs and
certification mark costs, but compared to the actual testing and
certification, those costs are minimal.

With regard to your interpretation of 29 CFR 1910.399:

1) This clause only covers NRTL Certification.  Field evaluations are NOT
part of the NRTL program.  NRTLs who are issuing Field certificates and
labels are doing so under their own name and not as a NRTL.

2) There are some products for which no NRTL has been able to demonstrate
they have the necessary test equipment and procedures for.  For example,
several years ago, OSHA  required crane insulating links to be tested and
certified by a NRTL.  Until last year, there was no test standard for
insulating links and the equipment required is very specialized.  OSHA has
not yer recognized a NRTL to test and certify these insulating links.
There are other examples where there are no standards for certain products,
or where no NRTL has the capability to test to the standard.  In such an
instance, the local AHJ may approve of the installation, or if another
Federal Agency has jurisdiction, they may approve of the installation.  In
my experience, this is very rare, but it is an option.

3) This option only applies to unique custom made equipment that is made
specifically for an employer.  The example I always give is the requirement
would apply if a potato farmer contracted with a company to make a custom
machine that he designed to separate rocks from his potato crop.  This was
a machine made to his exact and custom specifications, and there is nothing
else like it.  The manufacturer could conduct some basic safety testing and
prepare a report to give to the employer to present to OSHA if they ever
asked for it. Either the manufacturer could do the testing themselves, or
they could hire someone to conduct the testing for them.  The requirement
however would NOT apply if you created a "Custom" computer purchased from a
major manufacturer (ex Dell, Apple, Lenovo etc.) .  While you can go to
their website and build a custom machine to your exact specifications, the
big manufacturers aren't really making custom machines.

*Everything below this represents my own personal opinion and is something
I would not say in any official capacity (mostly because manufacturer self
declaration has so many implications in a broad spectrum of areas).*

As for allowing manufacturer self declaration, I would encourage you to
look at a Request for Information (RFI) that OSHA published almost 10 years
ago https://www.regulations.gov/document?D=OSHA-2008-0032-0099  You can
review all of the questions OSHA asked and the public responses here
https://www.regulations.gov/docket?D=OSHA-2008-0032.  The United States has
a very robust product safety system and as a result, there are very few
injuries as a direct result of products that are NRTL certified.  While you
may feel that $6000 - 8000 is expensive to product certification, I have to
ask, and I don't mean to get dramatic, but what is the cost of the loss of
someone's vision because a centrifuge exploded and a piece of shrapnel
landed in someone's eye? What is the cost of someone losing the use of
their hand due to an electric shock that caused nerve damage?  What is the
cost of someone's life because they received a lethal amount of leakage
current from an equipment enclosure and a nearby electrical conduit?
Regulatory testing always seems excessive, until it isn't.  Every
manufacturer and industry believes that their products are "low risk", so
where does the line get drawn?

Kevin Robinson

On Fri, Feb 21, 2020 at 10:35 AM Brian Kunde  wrote:

> Not all companies manufacturers high volume consumer goods. Our company
> designs and builds analytical test equipment (laboratory equipment) which
> is very expensive (relatively speaking) and built one at a time per our
> customer requirements.  We have about 50 Families of products; each with
> dozens of variations. Even our best selling product family might only sell
> less than 50 units per year, and many models may not see a single sale in a
> year.  Yet when someone needs one, we build it.
>
> Some of our customers require NRTL certification.
>
> We have approached several NRTLs requesting Certification for our
> production units.  Nope.  Their 'certification programs' do not
> accommodate low volume

Re: [PSES] Mandatory certification

[Brian Kunde]

Not all companies manufacturers high volume consumer goods. Our company
designs and builds analytical test equipment (laboratory equipment) which
is very expensive (relatively speaking) and built one at a time per our
customer requirements.  We have about 50 Families of products; each with
dozens of variations. Even our best selling product family might only sell
less than 50 units per year, and many models may not see a single sale in a
year.  Yet when someone needs one, we build it.

Some of our customers require NRTL certification.

We have approached several NRTLs requesting Certification for our
production units.  Nope.  Their 'certification programs' do not
accommodate low volume production, such as ours.  The ONLY option we have
is NRTL Field Evaluations.

NOTE: If anyone out there in cyberland knows of an NRTL or other local
authority who can provide an alternate but acceptable service, please let
me know!!

We started paying for NRTL FES (Field Evaluation Services) more than 20
years ago.  It started out maybe one per year at a cost of only a few
hundred dollars (US).  Now we get 12-15 requests a year and the cost has
sky-rocketed to nearly $4000.  We beg and plead to our NRTLs to do
everything possible to keep down the costs without success.  AGAIN, if
anyone knows of an acceptable alternative, please let me know.

Ok, let's talk about the 3 definitions the Federal Register 29 section
1910-399 gives for Acceptable by OSHA.  I will paraphrase below:

Number 1:  Products must be tested and labeled by an NRTL.  This can be
done through a Certification Program with an NRTL or by a Field
Evaluation.  Does anyone know another way to get an NRTL sticker on your
products?  Please share.

Number 2:  For products that no NRTL accepts, certifies, lists, labels, or
determines to be safe.  What does this mean?  In our case, if NRTLs will
not Certify our products because of how we manufacturer them in low volume,
does this section apply?  And if so, who is the "federal agency, state,
municipal, or other local authority that will test my product and stick a
label on it that will be acceptable to our customers?  Local to the
manufacturer or local to the customer purchasing the equipment?  Can anyone
provide me with a name, company name, phone or email of such a person?
 Practically speaking, I don't think this option will work.  If anyone has
a real-life example of how this works, please fill me in. I would really
appreciate it.

Number 3: Custom-made equipment is SUPPOSED to be "ACCEPTABLE" if it is
"determined to be safe for its intended use *by its manufacturer*".  Is
this crazy or what?  Can I be so bold as to say that THIS IS LAW???  Ok, so
how is this accomplished?  The manufacturer has a top-notch safety
compliance lab that generates a test report with "test data" showing the
product to be SAFE.  Then what?  The manufacturer has no marking.  How do I
convince a Customer that this method is or should be acceptable by OSHA?
NOTE: In the last 25 years, I have successfully used this approach. I sent
a detailed safety test report in CB (like) format to an OSHA inspector at
our customer site and it was accepted. But don't get your hopes up.

BOTTOM LINE:  If you do business with customers who are associated with
federal or state organization, schools, universities, military
subcontractors, customers in California or Washington, etc., chances are
you ONLY have Option ONE above which can be accomplished by an NRTL
Certification Program or by a Field Evaluation.  However, as I mentioned,
either choice is getting crazy expensive.  Something has to be done and
soon. Many test labs are struggling to keep their doors open including
NRTLs.  Many have closed down in the last 10 years.

Final Comment:  Last year we had a small supporting product that we sold to
a customer who wanted an NRTL Label on it. The retail price of the device
was only $2000 (US) but the NRTL charged us $4000 for the Field
Evaluation.  As a federal subcontractor, the customer paid for it because
they had no choice.  Something needs to be done.  An alternative must be
found.  Like Europe, for low-risk devices, OSHA should allow manufacturers
to test their own products and do a Manufacturer's Declaration of
Compliance with some kind of recognized marking.

This issue comes up about every year and I really really hope that someday
North American authorities will come up with a solution.  It is a crazy and
very expensive mess for may manufacturers.  Is there someone in the US
Government we can talk to, complain to, plead to?

I now return you to your regularly scheduled program.

The Other Brian





On Thu, Feb 20, 2020 at 10:09 PM Kevin Robinson 
wrote:

> Clause 2 under the definition for “acceptable” can only be used under
> specific conditions, specifically if no NRTL has the capability to test and
> certify the equipment.  In such cases, the equipment/installation would be
> acceptable to OSHA if a state/federal agency determined it was safe.  T

Re: [PSES] SV: [PSES] Ground copper fill on signal layer on multilayer PCB

[Istvan Novak]

Hi Amund,

Since your potential problem appears to be at relatively low 
frequencies, an alternative to edge plating would be stitching the 
ground planes along the board edges with closely spaced vias.  We have 
done this at SUN Microsystems also as a preventive measure. On the other 
hand, you should also consider the possibility that the leaking happens 
not through the edge of the board but through components connected to 
internal traces but sitting on the top or bottom of the board.  What I 
am saying is that it is not necessarily the edge of the board that 
radiates.  You could check this by poking around with a close-field 
probe, even uncalibrated unshielded home-made small loop or monopole 
antennas might give you a useful hint where the noise is coming from.  
You could also put absorbing sheets to the edge of the board to see if 
it makes a difference in the overall radiation.


Best regards,

Istvan Novak

Samtec



On 2/19/2020 1:50 AM, Amund Westin wrote:


Hi Ken

No, I have not considered edge-plating. I’ll look into this now.

We have some high frequency noise (400-500MHz) from differential lines 
leaking out from an inner layer of a multilayer pcb. Edge-plating 
might be a good solution.


Thanks for the tip.

BR
Amund

*Fra:* IBM Ken
*Sendt:* 18. februar 2020 23:18
*Til:* EMC-PSTC@LISTSERV.IEEE.ORG
*Emne:* Re: [PSES] Ground copper fill on signal layer on multilayer PCB

Hi Amund!  Have you also considered edge-plating?  Are you trying to 
reduce radiated noise outside your product, or cross-talk within the 
product (or both)?


On Tue, Feb 18, 2020 at 3:03 AM Amund Westin > wrote:


Between two solid ground planes, we have a signal layer, routing
high speed differential lines.

What do you recommend:

 1. fill the remaining area with copper in the signal layer
 2. fill only the border of the layer (5mm ground copper trace
around the layer edge)
 3. no fill at all

Best regards

Amund

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[PSES] Industrial PSU to Australia...

[Matthew Wilson | GBE]

Hello all, I've had an enquiry for a product we produce from Australia from an 
entity (not individual) down under.  The product in question is an 'industrial' 
power supply unit, 230V 50Hz AC in, 115V 400Hz out up to 3kW. It is 
self-declared CE mark for EMC & LVD (EN 61326-1 and EN 61010-1) plus RoHS.   So 
I was trying to see what needs to be done to meet Australian requirements to 
import and place on the market.  It appears, however, that there is plenty of 
guidance for the RCM requirements but not that much for a product which doesn't 
fall in to that category by virtue of not being a 'consumer' 'household' 
product.  E.g. from
https://www.saaapprovals.com.au/resources/frequently-asked-questions/

"Frequently Asked Questions
1. What are the requirements for importing and/or selling electrical products?

All electrical equipment imported, and sold in, Australia must be proven to be 
electrically safe. All electrical products, regardless of use, must comply with 
AS/NZS 3820 which is the general electrical safety standard.

If the item is for use in a house, or is to be sold over the internet to 
individuals without a registered ABN, then the product must comply with the 
requirements of the RCM, as detailed in AS/NZS 4417.2 and on www.eess.gov.au. 
High risk electrical articles must be certified by a State regulator, or a 
JAS-ANZ accredited certifier like SAA."

That doesn't really expand on what is required if the product is not for 'use 
in a house' and going to be sold/imported to an entity with a registered ABN.

Anyway thanks for reading, any pointers gratefully received.

Kind regards,



Matthew Wilson
Technical Director
GB Electronics (UK) Ltd
matthew.wil...@gbelectronics.com
https://gbelectronics.uk
+44 (0)1903 244 500
Ascot House//Mulberry Close//Woods Way
Goring-by-Sea//West Sussex//BN12 4QY//UK

Disclaimer: This email and any files transmitted with it are confidential and 
intended solely for the use of the individual or entity to whom they are 
addressed. If you have received this email in error please delete it from your 
system, do not use or disclose the information in any way and notify the sender 
immediately. The contents of this message may contain personal views which are 
not the views of the company, unless specifically stated.
​GB Electronics (UK) Ltd is a company registered in England and Wales under 
number 06210991.
​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West 
Sussex, BN12 4QY.

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