RE: opinions, please

[Frazee, Douglas (Douglas)]

Dave,
For CE-Marking, EN55022 requires testing in a system configuration complete
with keyboard, mouse, peripherals etc.  Many labs maintain a known Class B
compliant “golden” host PC for evaluating their clients PC components
and/or peripherals.  Note that FCC part 15 has a defined program for
certifying PC components and subassemblies that allows PC vendors to assemble,
mark and sell the PC based on use of all FCC 15 certified components without
testing the assembled PC.  The FCC15 procedure also requires testing in a
system configuration, however, with the PC cover removed.  The resulting
measurements may be up to 6dB above limit.  If emissions are measured above
limit with the cover removed, the cover is replaced and the subject emanations
re-measured.  With cover(s) in place, all measurements must be in compliance
with specification limits.  I believe that the US & EU requirements are close
enough that a single test and report can meet both requirements.
 
Douglas G. Frazee
Regulatory Compliance Manager
Lucent Technologies
PSAX Division
dfra...@lucent.com
 

From: drcuthb...@micron.com [mailto:drcuthb...@micron.com]
Sent: Tuesday, November 11, 2003 5:34 PM
To: doug.pow...@aei.com; lfresea...@aol.com
Cc: emc-p...@majordomo.ieee.org
Subject: RE: opinions, please
 
I do have a custom shielded test fixture that will allow the DIMM to be tested
alone. Any desired READ or WRITE pattern can be used. The stimulus equipment
resides in a shielded rack directly beneath the DIMM. The DIMM is mounted
vertically and is free to radiate into the hemisphere above the rack. Now,
what level do I test for? CISPR 22 ? I was told that a mother board can be CE
Marked if it is <6dB over the limit. The theory being that the enclosure will
(might?) provide >6dB of attenuation. If this is so then do I test the DIMM
this way?
 
The reason I asked about DIMMs is because after reading the appropriate
documents I was convinced that it had to be tested and later changed my mind.
Now I'm leaning towards testing being a requirement. 
 
   Dave Cuthbert
   Micron Technology

From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of POWELL, DOUG
Sent: Tuesday, November 11, 2003 2:49 PM
To: 'lfresea...@aol.com'
Cc: emc-p...@majordomo.ieee.org
Subject: RE: opinions, please
Derek,
 
Do you have a suggestion as to how the test should be performed?
 
-doug

Douglas E. Powell 
Corporate Compliance Dept.
Advanced Energy Industries, Inc. 
Fort Collins, CO 80525 USA 

From: lfresea...@aol.com [mailto:lfresea...@aol.com]
Sent: Tuesday, November 11, 2003 8:56 AM
To: john.radom...@modicon.com; mcinturff3...@msn.com
Cc: emc-p...@majordomo.ieee.org
Subject: Re: opinions, please
In a message dated 11/11/2003 9:36:21 AM Central Standard Time,
john.radom...@modicon.com writes:

The EMC guidelines read:  "... If the component is intended to be placed on
the market as a single commercial unit for distribution and/or final use
this function has to be available WITHOUT further adjustment or connections
other than SIMPLE ones which can be performed by any person not fully aware
of the EMC implications..."
After seeing all the other list positings and thinking some more, I'm going to
change my opinion on what this should be marked as. Originally, I said
component. But...
 
This is a module that when added to a PC brings new capibility. But, it also
adds a path for noise to exit a system that the manufacturer may have tested (
if they even did ) differently. 
 
So I guess, I would say now that the module should be CE marked, and at a
minimum, the contribution it makes to radiated emissions determined.
 
I guess my second 2 cents worth
 
Derek N. Walton
Owner, L F Research EMI Design and Test Facility
Poplar Grove,
IL 61065
___
This message, including any attachments, may contain information
that is confidential and proprietary information of Advanced 
Energy Industries, Inc.  The dissemination, distribution, use 
or copying of this message or any of its attachments is 
strictly prohibited without the express written consent of 
Advanced Energy Industries, Inc.

RE: opinions, please

[Frazee, Douglas (Douglas)]

I took a second look at the EMCD guidelines, chapter 6 and have changed my
opinion. 

In the EMCD guidelines, if the DRAMS are sold to the end user, applicability
of the EMCD comes down to whether the DRAM modules perform a "direct function"
to the end user.  The examples given in chapter 6 of the EMCD guideline
(required reading for all involved with CE-Mark/EMCD compliance btw) put
components such as memory modules into a gray area, or do they?  

In my previous response, I rationalized that (ref. Ch6 of the EMCD guidelines)
the SDRAM does not perform a direct function to the end user, now I'm not so
sure.  Note that although the SDRAM type memory module is not specifically
used as an example, the hard disk drive is.and the hard disk is considered
to perform a direct function and is subject to the provisions of the EMCD. 
Does this change anyone else's opinion as to whether the EMCD applies? 
Certainly the function provided by a hard disk drive and compact flash memory
card is very similar.  Is an SDRAM module so different that it does not
require testing?  SimpleTech apparently feels CE-Marking is prudent:
http://www.newegg.com/app/Showimage.asp?image=20-150-310-02.jpg

In regards to one contributor's question as to how an SDRAM module would be
tested, essentially the modules are installed and tested into a host PC,
complete with monitor keyboard etc.  There are detailed procedures in both EN
55022/CISPR 22 and in FCC Part 15.  Although I'm not in the ITE arena, I am
aware that there are some differences in the specific procedures for the EMCD
versus FCC Part 15.  FCC 15 explicitly allows PC manufacturers to sell a PC
assembled from FCC compliant components without testing the assembled PC,
though special marking is required.  I don't believe there is an "official"
parallel to the FCC procedure for CE-Marking, though a small PC assembler
could legally CE-mark without testing and build his compliance file with
compliance documentation for the PC components. 


Douglas G. Frazee
Regulatory Compliance Manager
Lucent Technologies
PSAX Division
(301) 809-4415
(301) 352-4680 FAX
dfra...@lucent.com

 -Original Message-
From:   Doug Massey [mailto:dmas...@acstestlab.com] 
Sent:   Monday, November 10, 2003 9:26 AM
To: emc-p...@majordomo.ieee.org
Subject:RE: opinions, please


I have to throw my opinion in on this one, couldn't resist -

Let's not beat around the bush - NO,  the CE mark does not apply.

Most certainly, it is exempt from the LVD.
 
As to EMC, this device has no clock to radiate by itself. It is subject
to the EMCD when and only when incorporated into an end product. Of
course, you are offering it for sale stand-alone, for incorporation into
an end product. Said end product, assumed to be CE Marked itself, should
have been tested in a full, representative configuration, so it is
assumed that all available memory expansion slots were populated, and
hopefully, being exercised during the testing. Your memory device should
be significantly like the memory device installed in the end product
during testing. All emissions and immunity characteristics of said
product should be dependent on other design features, NOT on the
particular memory module installed.

No, this rationale does not follow any textbook definition of component
or system - I guess, by necessity, any definition would be vague. It
just makes common sense to me. If this seems a bit cavalier, ask this
question:

Should the individual IC's on the memory module be CE Marked?

Is it a good idea to test your device for immunity? Yes, if you have
protections designed in, but then the testing is purely a design
verification test, not for the purpose of CE Marking, but rather, to
insure that your design functions as intended.

And as to the modem card mentioned in a previous reply to this thread, I
think it is marked to indicate compliance to the RTTE Directive, which
considers the modem card a system - ie, when added to a product, the
RTTE Directive still applies only to the modem, and not to the complete
system. In other words, the RTTED is explicitly applicable to the modem
card, and there is no questions as to component vs system in the RTTE.

Doug Massey
Product Safety Engineer
Advanced Compliance Solutions
Ph. (770) 831-8048
FAX (770) 831-8598
Visit our web home at http://www.acstestlab.com



From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org] On Behalf Of Gordon,Ian
Sent: Monday, November 10, 2003 4:11 AM
To: 'drcuthb...@micron.com'; emc-p...@majordomo.ieee.org
Subject: RE: opinions, please


Dave at al
How will you test it as a free standing unit? Won't you need to build it
into a pc and then test it? I know CE + CE doesn't give CE but if you
did
that with a representative pc and assuming the system continues to be
compliant are you not showing "due diligence"? 
I still wouldn't have thought a CE mark was appropriate though.

Ian Gordon
 

RE: opinions, please

[Frazee, Douglas (Douglas)]

Interesting question..here's my opinion.

I assume you are concerned only with the EMC Directive.  The EMCD guidelines
document http://europa.eu.int/comm/ente
prise/electr_equipment/emc/guides/index.htm 
has detailed information on application of the EMCD to components.  Memory
modules are not specifically used as an example and seem to fall somewhat in a
gray area.  Certainly if the modules were being sold only as an OEM product,
CE marking is not required.  If the are being directly sold to the end user,
then I believe the flowchart decision as to whether the EMCD applies or not
depends on whether the component performs a "direct function".  Here, I would
rationalize that PC plug-in products such as modems, sound cards, video cards
etc. perform "direct functions"; the DRAM module does not, it is strictly a
component that is required for the PC to operate.  Thus application of the EMC
Directive is not mandatory even if marketed directly to the end user.  

However, if your firm feels that CE-marking provides product benefits such as
enhanced marketability, you will be able to optionally test, declare
compliance and CE-Mark to the EMCD using EN55022/55024.

Douglas G. Frazee
Regulatory Compliance Manager
Lucent Technologies
PSAX Division
dfra...@lucent.com

 -Original Message-
From:   drcuthb...@micron.com [mailto:drcuthb...@micron.com] 
Sent:   Friday, November 07, 2003 12:37 PM
To: emc-p...@majordomo.ieee.org
Subject:opinions, please


I have a question: Is a Memory Module (DIMM) considered a component or an
apparatus? 

I'm trying to decide whether the CE MARK is applicable to this type of product.

   Dave Cuthbert
   Micron Technology



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RE: laser safety label

[Frazee, Douglas (Douglas)]

I think you'll find all you need to know here;
http://www.fda.gov/cdrh/comp/guidance/1346.html


Douglas G. Frazee
Regulatory Compliance Manager
Lucent Technologies
PSAX Division
dfra...@lucent.com

 -Original Message-
From:   Neil Helsby [mailto:nei...@solid-state-logic.com] 
Sent:   Thursday, June 26, 2003 10:58 AM
To: emc-p...@majordomo.ieee.org
Subject:laser safety label


In the USA, what safety labels and/or manual information is required when a
class 1 (fibre optic) device is fitted to a panel for equipment 
interconnection? Are the requirements the same as those for EN 60825-1?

Many thanks for your assistance.

Regards,

Neil Helsby


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RE: Performance Criterion

[Frazee, Douglas (Douglas)]

Ghery,
I was hoping my response would get a discussion going and am pleased that you
responded.  Please be aware, however that the basic message I wanted to get
across is that while there are clear passes (#1) and clear failures (#9);
there are also gray areas.  In these gray areas, whether the EUT is found
compliant or not depends on a number of factors and is subject to
interpretation.  If the manufacturer wishes to use a permissible loss of
performance, it is best to have this information submitted before the test is
performed to avoid the appearance of changing the rules after the game has
started in order to come out a winner!  There are also subtle differences in
the criteria B definition from standard to standard, and even in the same
standard, depending on the equipment type.
 
Our products are certified both to 55024 & EN 300 386 V 1.3.1.  I was not
familiar with the 61000-6-2 standard that Ralph inquired about but I reviewed
the definition of criteria B in that standard before I responded.  In each
standard criteria B is applicable for transient phenomena such as ESD and
allows for some degradation.  However, the wording differs in each standard,
which can affect compliance for “gray area” type test results.  Even in
CISPR 24, if you are required to use specific criteria for TTE included in
Annex. A, the criteria is different and may possibly affect compliance.
 
61000-6-2 Criteria B: “The apparatus shall continue to operate as intended
after the test.  No degradation of performance or loss of function is allowed
below a performance level specified by the manufacturer, when the product is
used as intended.  The performance level may be replaced by a permissible loss
of performance.  During the test, degradation of performance is however
allowed.  No change of actual operating state or stored data is allowed.  If
the minimum performance level or permissible performance loss is not specified
by the manufacturer, either of these may be derived from what the user may
reasonably expect from the apparatus if used as intended.”
 
Note that the above wording does not allow changes in operating state or
stored data either during or after the test.  In this regard the 61000-6-2
criteria is more severe than the general CISPR 24 criteria.  Thus, I stand by
my initial e-mail’s #5.  Under 61000-6-2 Criteria B, if the EUTs stored data
or operating state changes as a result of the transient test, the EUT is
non-compliant.  
 
For telecommunication network (switching) equipment under 300 386 v 1.3.1
paragraph 11.3.1.2; it is permissible for data errors to occur as a result of
transient phenomena, however except for a specific exception for surge
testing, established connections must be maintained throughout the testing. 
Thus the result Ralph described is:
 
1.   Compliant under the general CISPR 24 criteria B
2.   Non-compliant under CISPR 24 Annex A criteria B (TTE w/digital
interface, TTE w/analog interfaces, FAX)
3.   Compliant under CISPR 24 Annex B criteria B (data processing
equipment)
4.   In a gray area under 61000-6-2
5.   Non-compliant under 300 386 V 1.3.1 for telecom. switching equipment
 
The above list is partial, but I think my point is clear.  Note that CISPR 24
has 7 Annexes for specific categories of ITE with operating criteria for
immunity testing specifically tailored for each equipment type.   Thanks to
Ralph for presenting such an interesting test result example! 
 
Douglas G. Frazee
Regulatory Compliance Manager
Lucent Technologies
PSAX Division
dfra...@lucent.com
 

From: Pettit, Ghery [mailto:ghery.pet...@intel.com]
Sent: Thursday, April 24, 2003 4:51 PM
To: 'Frazee, Douglas (Douglas)'; Pettit, Ghery; 'Ralph McDiarmid'; 'EMC-PSTC'
Subject: RE: Performance Criterion
 
I'm going to contest this, but only slightly.
 
CISPR 24 defines Performance criterion B as:
 
"After the test, the equipment shall continue to operate as intended without
operator intervention.  No degradation of performance or loss of function is
allowed, after the application of the phenomena below a performance level
specified by the manufacturer, when the equipment is used as intended.  The
performance level may be replaced by a permissible loss of performance.
 
During the test, degradation of performance is allowed.  However, no change of
operating state or stored data is allowed to persist after the test.
 
If the minimum performance level (or the permissible performance loss) is not
specified by the manufacturer, then either of these may be derived from the
product description and documentation, and by what the end user may reasonably
expect from the equipment if used as intended."
 
Note that the change in operating state or stored data is a bit different than
quoted by Doug.  Obviously communications will be disrupted while the product
re-boots, but re-sends should be possible and self-recovery would progress. 
Unless the recovery period was 

RE: Performance Criterion

[Frazee, Douglas (Douglas)]

Ralph, Ghery’s response is somewhat correct, however I’d like to add
several points.
 
The definition of criterion B in 61000-6-2 allows degradation during the
immunity test.  It also states that, “No change of operating state or stored
data is allowed.”  Thus, if communications are interrupted as a result of
the ESD forcing a reboot, corrupting stored data, etc.; the EUT is
non-compliant.  
 
Further, if the manufacturer has not specified a permissible performance loss
(test plan is helpful here); it is appropriate to consult the user manual,
product specifications and/or derive the minimum performance level“ from
what the user may reasonably expect from the apparatus when used as
intended.”  This opens it up to interpretation!
 
What is the impact of a 1-minute loss of communications, is it no impact, a
minor annoyance or is it likely to set off an unpleasant chain reaction or
cause a hazardous condition?  I’m afraid that under the condition you
describe, compliance may not be clear cut.  Here’s a summary of my
interpretations:
 
1)   EUT completely unaffected by ESD – compliant.
2)   EUT shows degradation as a direct result of ESD, self-recovers
immediately, operating state and stored data is unaffected – compliant.
3)   EUT shows degradation as a direct result of ESD, operating state and
stored data are unaffected, EUT self-recovers but not immediately. 
Manufacturer has defined a permissible performance level either in general or
as a result of ESD or transient electromagnetic phenomena.  Observed
degradation is acceptable within the manufacturer defined parameters –
compliant.
4)   EUT shows degradation as a direct result of ESD, operating state and
stored data are unaffected, EUT self-recovers but not immediately. 
Manufacturer has defined a permissible performance level either in general or
as a result of ESD or transient electromagnetic phenomena.  Observed
degradation is not acceptable within the manufacturer defined parameters –
non-compliant.
5)   EUT shows degradation as a direct result of ESD, operating state
and/or stored data are affected. – non-compliant.
6)   EUT shows degradation as a direct result of ESD, operating state and
stored data are unaffected, EUT does not self-recover. – non-compliant.
7)   EUT shows degradation as a direct result of ESD, operating state and
stored data are unaffected, EUT self-recovers but not immediately. 
Manufacturer has not defined a permissible performance level either in general
or as a result of ESD or transient electromagnetic phenomena.  Minimum
performance level is determined from EUT documentation and/or from what the
user may reasonably expect from the apparatus when used as intended.  Observed
degradation is not acceptable within the parameters of minimum acceptable
performance – non-compliant.
8)   EUT shows degradation as a direct result of ESD, operating state and
stored data are unaffected, EUT self-recovers but not immediately. 
Manufacturer has not defined a permissible performance level either in general
or as a result of ESD or transient electromagnetic phenomena.  Minimum
performance level is determined from EUT documentation and/or from what the
user may reasonably expect from the apparatus when used as intended.  Observed
degradation is acceptable within the parameters of minimum acceptable
performance –compliant.
9)   EUT releases smoke as a result of ESD infusion, shows no signs of
life after test – non-compliant.
10)   EUT shows degradation as a direct result of ESD, operating state and
stored data are unaffected, EUT self-recovers but not immediately. 
Manufacturer has not defined a permissible performance level either in general
or as a result of ESD or transient electromagnetic phenomena.  Minimum
performance level is determined from EUT documentation and/or from what the
user may reasonably expect from the apparatus when used as intended.  Observed
degradation is acceptable within the parameters of minimum acceptable
performance however tester is having a lousy day – non-compliant.
 
Douglas G. Frazee
Regulatory Compliance Manager
Lucent Technologies
PSAX Division
dfra...@lucent.com
 

From: Pettit, Ghery [mailto:ghery.pet...@intel.com]
Sent: Thursday, April 24, 2003 11:13 AM
To: 'Ralph McDiarmid'; 'EMC-PSTC'
Subject: RE: Performance Criterion
 
Ralph,
 
If a product self-recovers without operator intervention, then you can say it
meets criterion B.  The manufacturer has the ability within these criteria to
define the acceptable loss of function, as well.  If 1 minute is an acceptable
time for the self-recovery, the product passes.  If operator intervention was
required, then a clear failure of criterion B would exist.
 
Ghery Pettit
 
 

From: Ralph McDiarmid [mailto:ralph.mcdiar...@xantrex.com] 
Sent: Wednesday, April 23, 2003 5:01 PM
To: 'EMC-PSTC'
Subject: Performance Criterion
 
I have a question about Performance Criterion B as described in EN61000-6-2.
 
Scenario:
A product temporary lo

RE: Fw, Yahoo Groups Recommendation?: Changes to IEEE emc-pstc we b-based services...

[Frazee, Douglas (Douglas)]

I believe it has already been mentioned but Yahoo Groups & e-mail are also
blocked by Lucent Technologies CIO.  In our case I would say that the chance
of CIO unblocking Yahoo Groups so that we can participate in EMC-PSTC is
between Slim & None and Slim just jumped out the window!  Reasons for blocking
these domains include virus risks to the network.  We do have an avenue for
requesting that particular sites or domains be unblocked, by describing the
“legitimate business purpose for access”, however, I believe that the odds
on result is that a switch to Yahoo Groups will result in a loss of at-work
access for many large company members!
 
Doug Frazee
PSAX Compliance Manager
Lucent Technologies
 

From: Eric George [mailto:i...@ergonomicsusa.com]
Sent: Thursday, March 13, 2003 8:34 PM
To: Garnier, David S (MED); 'Guy Boone'; emc-p...@majordomo.ieee.org
Subject: Re: Fw, Yahoo Groups Recommendation?: Changes to IEEE emc-pstc
web-based services...
 
Sure seems like a case of control mania by a service provider Czar.  Surely
one address within a domain can be accepted.
Dave George
- Original Message - 

From: Garnier,   David S (MED) 
To: 'Guy Boone'   ; emc-p...@majordomo.ieee.org 
Sent: Thursday, March 13, 2003 12:54 PM
Subject: RE: Fw, Yahoo Groups Recommendation?: Changes to IEEE emc-pstc
web-based services...
 
Pardon me if this has been decided already but I think you need to be 
made aware of this.
 
Our corporate net nanny has blocked access to all Yahoo accounts 
(and other free mail accounts) - moving the EMC listserve there would 
prevent access from anyone within the GE.COM domain.  Our local IEEE
EMC chapter is blocked, (all appeals for access have been ignored.)
 
You might me asking yourself "why should I care?" (Dave could certainly
subscribe to the listserve at home - ((please enable the digest mode.)) 
This company is a trendsetter and many others emulate our practices, 
your impending move may impact other subscribers in the future.
 
David Garnier 
e GE Medical Systems 
___ 
David S. Garnier 
Senior Technician 
PET Engineering 
3000 N. Grandview Ave - M/S W-1250 
Waukesha, Wi. 53188 
Tel: 262.312.7246 

 

From: Guy Boone [mailto:bo...@sympatico.ca]
Sent: Wednesday, March 05, 2003 3:24 PM
To: emc-p...@majordomo.ieee.org
Subject: Fw, Yahoo Groups Recommendation?: Changes to IEEE emc-pstc web-based
services...
Jim/Richard;
 
Any update on the data transfer from   
http://ieeepstc.mindcruiser.com/ to   <
ttps://www.ieeecommunities.org/emc-pstc>
https://www.ieeecommunities.org/emc-pstc...  or a tentative date?
 
For your information... the Yahoo group 

http://groups.yahoo.com/group/emc-pstc/ can be easily configured to operate
both as a listserver-based service and a web-based service.  As a web-based
service,  
https://www.ieeecommunities.org/emc-pstc does offer some advantages over Yahoo
Groups (as referenced below)...  but as a listserver-based service, it's
advantage over majordomo is that it allows the member to control the delivery
of messages (ie, individual emails, daily digest or no email) and messages can
be viewed online http://groups.yahoo.com/group/emc-pstc/messages. 
 
I would recommend that you consider a migration to Yahoo Groups, once the data
transfer to  
https://www.ieeecommunities.org/emc-pstc is complete.  Should the planned data
transfer be not possible, you may want to consider a full migration to Yahoo
Groups, as listserver/web-based solution.
 
Here in Ottawa, Canada... we have a group called RAFT - Regulatory Approvals
Forum for Technology, and have been using Yahoo Groups 

http://groups.yahoo.com/group/RAFT-Global/ for the past 2 years.
 
I have joined  
http://groups.yahoo.com/group/emc-pstc/ some time ago...  If you want to give
it some consideration, I can volunteer to make the additional configuration
changes.  Please let me know your thought, and the Group owner will need to
have me assigned as Moderator.
 
Regards,
  
    Guy Boone, P. Eng
  Electrical Engineer, specializing in Safety Compliance,
 Power/Control Systems Design & Buildings Engineering
 Steering Committee Member  -  
www.RAFT-Global.org
 35 Athena Way  Tel: 613-823-7534
 Ottawa (Nepean), ON K2G 6S1   Cell: 613-850-6533 

From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Jim Bacher
Sent: January 23, 2003 10:54 AM
To: 'Andre, Pierre-Marie'; emc-p...@majordomo.ieee.org
Subject: RE: EMC-PSTC Email Forum 
 
 
We have had a couple major glitches with the movement of 

RE: Singapore and IDA license

[Frazee, Douglas (Douglas)]

IDA is the Singapore telecom type approval authority.  IDA approvals are
required for equipment which connects directly to the public
telecommunications network.  You will find links to Type Approval regulatory
bodies, worldwide, including IDA on this website: 
http://www.patton-assoc.com/  Testing may be performed outside of Singapore
with the approval process requiring a formal application and technical
documentation review by IDA.  The approval certificate must be held by your
company's local representative in Singapore.  Reports & application in English.

I can recommend a couple of labs/consultants who can assist with your
approval: Elliott Labs / Martyn Lambert (877) 245-7800 and Compliance
International, Fred Borda www.typeapproval.com

Good Luck,

Douglas G. Frazee 
Lucent PSAX Compliance Manager 
+01 301 809 4415 
+01 301 352 4730 FAX 
dfra...@lucent.com 



From: Rob Humphrey [mailto:rob.humph...@reuters.com]
Sent: Friday, January 17, 2003 5:02 AM
To: emc-p...@majordomo.ieee.org
Subject: Singapore and IDA license



I have been advised by the Singapore authorities that I need to get an IDA
license .

What is it and how do I get one?

Thanks in anticipation


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RE: EN61000-3-2

[Frazee, Douglas (Douglas)]

Actually, it's none of the above and depends what version you tested to.  EN 
61000-3-2 has been controversial with a number 
of Annexes and thus makes an excellent example.  If you visit this official EU 
site 
http://europa.eu.int/comm/enterprise/newapproach/standardization/harmstds/reflist/emc.html
 

 
you'll find a listing of Harmonized Standards under the EMC Directive.  Note, 
especially the last two columns: 
 
Reference of the superseded standard 
and 
Date of cessation of presumption of conformity of the superseded standard
 
The information in these columns tells you, along with the relevant notes, 
which standard versions may be listed on your EU Declaration 
and the latest date at which you must declare to Annexed or new issues.  Note 
that a standard may be used to support an EMC 
Directive Declaration of Conformity as soon as it appears on this list.  
Scrolling down to  down to EN 61000-3-2 you'll should be able 
to conclude the following:
 
EN 60555-2:1987Not 
valid beyond 01.01.2001
EN 61000-3-2:1995+A13:1997  Not valid 
beyond 01.01.2001
EN 61000-3-2:1995+A1:1997+A2:1998  required 01.01.2001, 
not valid beyond 01.01.2004
EN 61000-3-2:1995+A1:1997+A2:1998+A14:2000  May be applied now, 
mandatory 01.01.2004, not valid beyond 01.01.2004
EN 61000-3-2:2000  May be 
applied now, mandatory 01.01.2004  
 
So at the present time it is acceptable to use three different versions of the 
standard shown in bold text, above.  Note that A14 is essentially 
optional as it expires on the same date at which it becomes mandatory.  
However, without revisiting the details, it's use will make it easier
for certain equipment to comply, and thus is widely used at this time.  Note 
that product previously qualified to a standard, slated to be 
superseded, must be re-qualified and declared compliant to the new standard if 
the product is to continue to be placed on the European 
market beyond the "date of cessation of presumption of conformity of the 
superseded standard.   

Douglas G. Frazee 
Lucent PSAX Compliance Manager 
dfra...@lucent.com   

-Original Message-
From: cecil.gitt...@kodak.com [mailto:cecil.gitt...@kodak.com]
Sent: Tuesday, September 24, 2002 3:42 PM
To: emc-p...@majordomo.ieee.org
Subject: EN61000-3-2



Does anyone have knowledge on how the standard EN61000-3-2 should be listed? 
Is it EN61000-3-2:1995, EN61000-3-2:1995 A2:1998 or EN61000-2-3:1995 A14:2000? 

Regards 

Cecil A. Gittens

RE: Isolated grounds in central office

[Frazee, Douglas (Douglas)]

Note that if your equipment uses DC-DC converters in excess of 150 watts, 
GR-1089 R9-9 requires the output of the converter to be referenced to earth 
ground.  Further, this connection must be robust enough to survive full fault 
current iaw R9-20.
 

Douglas G. Frazee 
-Original Message-
From: Stone, Richard A (Richard) [mailto:rsto...@lucent.com]
Sent: Tuesday, September 10, 2002 3:27 PM
To: 'j...@aol.com'; emc-p...@majordomo.ieee.org
Cc: jfinlay...@telica.com; dorin.op...@alcatel.com; 
john.juh...@ge-interlogix.com
Subject: RE: Isolated grounds in central office



thanks Joe,
many of us share your opinions...
will await more on this subject.
Richard

-Original Message-
From: j...@aol.com [mailto:j...@aol.com]
Sent: Tuesday, September 10, 2002 2:58 PM
To: emc-p...@majordomo.ieee.org
Cc: jfinlay...@telica.com; dorin.op...@alcatel.com; 
john.juh...@ge-interlogix.com
Subject: Isolated grounds in central office


In a message dated 9/10/2002John Juhasz writes:




Be careful Dorin. For Central Offices, they need to be isolated.




Hi Guys:

I changed the subject heading on this response (was "Inrush and EN61000-3-3") 
to better reflect the direction this thread has taken.

The subject of isolating circuit ground from frame ground in a CO seems to be 
controversial.  On one hand, I have heard stories such as John's about various 
RBOCs insisting on this.  On the other hand, I have not seen the actual written 
requirements that were being imposed or the rationale behind them.  For safety, 
functionality, and EMC considerations, I think it is generally better to tie 
circuit ground to frame ground in a robust fashion.

One person told me that Verizon had insisted that circuit ground be brought out 
to an isolated terminal post that could then be externally tied to frame 
ground.  This made a mess out of his design, and so far I have avoided this 
approach in my own designs without getting nailed.

It seems that there is some confusion about whether this isolation is required 
and if so, why it is required.  The whole subject of grounding within a CO can 
become quite complicated, especially when lightning is taken into 
consideration.  I understand that TR-NWT-000295, "Isolated Ground Planes: 
Definition and Application to Telephone Central Offices" addresses some of 
these issues, but not in a clear manner (imagine that for a Telcordia 
document!).

If anyone can provide a clear explanation of when isolation of circuit ground 
and frame ground is required in a C.O. and why, I would be most interested to 
know.



Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848
http://www.randolph-telecom.com

Hazard/Product Safety Opportunity

[Frazee, Douglas (Douglas)]

Posted for Steffani Brooks, please respond directly to her, only:
sbro...@hallkinion.com  
location: Dallas, Texas
duration: appriox. 1-month
 
Douglas G. Frazee 
Lucent PSAX Compliance Manager 
dfra...@lucent.com   
-Original Message-
From: Steffani Brooks [mailto:sbro...@hallkinion.com]
Sent: Tuesday, February 12, 2002 11:49 AM
To: dfra...@lucent.com
Subject: Hazard/Product Safety Consultant Description


Doug,
 
Thank you so very much for your assistance regarding the contract opening I
have here in Dallas.  
 
We have a client here in the Telecom Corridor who is currently in need of a
Hazard/Product Safety Consultant who is well versed in UL, CE, and NEBS
regulatory compliance issues.  I have included a description below:
 
Job Description- consultant to internal hazard analysis team specializing in
the area of telecom regulatory agency issues including UL, NEBS and CE mark
related to safety. Responsibilities to include active participation in
meetings accumulating hazard risks inside an all optical router product,
research into specific areas of regulations and/or upcoming changes on
behalf of the team, assistance in identifying hazards based on past
experience. Will also participate in generation of final report.
 
Experience Required- B.S. Degree in electrical or related  discipline,
advanced degree a plus. Minimum 10 years relevant  experience in the telecom
field, particularly in the area of regulatory safety compliance. Experience
in hazard analysis  investigation and reporting a plus. Must be current on
latest  rules and regulations and be capable of quickly answering  specific
questions about the scope and intent of those rules  and regulations. Must
work well in team environment and be  focused on getting a job done rather
than simply exploring.
 
Credentials and/or experience with any of the agencies listed above is a
plus.
 
Please let any interested party know that they can contact me directly by
email at sbro...@hallkinion.com   or toll
free at 888-989-4254.
 
Thank you again, Doug, and if you have any questions or comments, please
feel free to contact me by phone or email.
 
Hope you have a wonderful day!
 
Best regards,
 
Steffani Brooks
Technical Recruiter
Hall Kinion & Associates
Dallas, TX
Local: 972-783-0100 x215
Toll Free: 888-989-4254 x215
Fax: 972-783-2740
www.hallkinion.com  

RE: CE test suite for computers

[Frazee, Douglas (Douglas)]

Ghery, I believe 61000-3-2, Class D is also required.
Doug Frazee 
Regulatory Compliance Manager 
Lucent Technologies, Broadband Carrier Networks 
Access Technology Division 
InterNetworking Systems 
(301) 809-4415 
(301) 352-4730 FAX 
dfra...@lucent.com 

-Original Message-
From: Pettit, Ghery [mailto:ghery.pet...@intel.com]
Sent: Thursday, August 16, 2001 4:39 PM
To: 'Stuart Lopata'; emc
Subject: RE: CE test suite for computers


Stuart,
 
For ITE the requirements are EN 55022:1994 (through 1 August 2003) and EN
55024:1998.  If you wish to test to anything else, you need to go through a
Competent Body and convince them that the alternate standards are adequate.
 
Ghery Pettit
Intel
 
-Original Message-
From: Stuart Lopata [mailto:stu...@timcoengr.com]
Sent: Thursday, August 16, 2001 12:14 PM
To: emc
Subject: CE test suite for computers


Any info about the test suite for computers (for commercial & professional
markets in EU) to meet the EMC directive for the CE mark?
 
Also wondering if there is any collection of non-harmonized standards that
are currently accepted for CE mark testing?
 
to my knowledge, EMC testing for computers requires the following. (so
far)
 
EN 55022 for ITE equipment
EN 61000 3-1 through 3-11
 
Sincerely,
 
Stuart Lopata

RE: EMC and power supply

[Frazee, Douglas (Douglas)]

I've read several responses that all indicate that the modified ITE MUST be
retested for CE-compliance.  If the product in question is a PC, this is not
the case.  Both the FCC and EU allow PC's to be assembled from CE-marked
components without additional testing.  See FCC rules and EMC Directive
guidelines for full details.  However, the points made are correct.
CE+CE=CE is not guaranteed and the manufacturer/integrator is responsible
for the compliance of the product.  Therefore, it is a question of how much
risk that you are willing to take.  

Under these guidelines, the power supply manufacturer is supposed to perform
a full 55022/55024/FCC part 15 test program with the power supply installed
into a representative PC, complete with monitor & keyboard.  Power supply
compliance is based on testing results of this PC.

Perhaps the best approach is to request a full compliance file from the PS
manufacturer, examine it carefully and subject the modified PC to a limited
or full test program based on your confidence in the PS test reports.  

Doug Frazee
Regulatory Compliance Manager
Lucent Technologies, Broadband Carrier Networks
Access Technology Division
InterNetworking Systems
dfra...@lucent.com



-Original Message-
From: Alex McNeil [mailto:alex.mcn...@ingenicofortronic.com]
Sent: Friday, August 17, 2001 3:37 AM
To: 'am...@westin.org'
Cc: emc-p...@majordomo.ieee.org
Subject: RE: EMC and power supply



Hi Amund,

I have experienced a CE Marked power supply, which was used to replace an
existing one failing EMC EN55022 as part of the system i.e. Product + Power
Supply. This was purchased to the same specification but from a different
manufacturer. It seems that power supply manufacturers tend to EMC test
their products with resistive loads only and not always at full load. Also,
the loading is obviously different when connected to an actual product. 

In my opinion you must always re-test the system when one of the major
sub-assemblies or components are changed, including alternative parts. You
are responsible for the system EMC. The power supply manufacturer is not
responsible for his CE marked power supply (assuming he has valid reports
etc. to back up his Declaration of Conformity) failing in the system.

The rule CE + CE not= CE is a valid statement unless proven otherwise
(tested). Always abide by this and you won't go wrong. 

I hope this helps!

Regards
ALEX

 -Original Message-
From:   am...@westin.org [mailto:am...@westin.org] 
Sent:   Thursday, August 16, 2001 10:33 PM
To: emc-p...@majordomo.ieee.org
Subject:EMC and power supply


Hi all,

1. We plan to EMC test a stand alone power supply (PS1)
2. We have an IT product which has passed the EMC test.
3. We want to remove the current power supply in the IT product and replace
it 
with the power supply (PS1) after it has passed the EMC tests.

If power supply (PS1) pass the EMC test, do we have to make any re-tests on
the 
IT product ? I recall some talks about CE+CE not CE.

Any suggestions ?

Best regards
Amund Westin, Oslo/Norway

-- 
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