e-labeling
Group, Thanks for the responses I got to my inquiry regarding 'e-labeling' - using the product itself to display regulatory information. I got fewer responses than I had hoped. One responder mentioned that as an OEM, he had a lot of headaches from a large PC manufacturer who used an 'e-labeling' scheme. Another mentioned that he had explored this as well, and didn't get very far with gettting buy-in from various agencies. However, for those of you who may have been interested, the FCC did respond to the inquiry I made to them. From Rich Fabina, OET Equipment Authorization Branch Chief: The Commission recently declined to accept FCC ID labels on an LCD screen display in ET Docket No. 00-47 (FCC 01-264). In Paragraphs 33 to 35 of this rulemaking on software defined radios, electronic labeling is discussed. The final word on it was the last sentence of Paragraph 35, At this time, we are only permitting electronic labeling for software defined radios. You may obtain a copy of this rulemaking by going to http://www.fcc.gov/Bureaus/Engineering_Technology/Orders/2001/fcc01264.txt. Clearly this is an area that the Commission has considered but is not ready to move forward with its implementation. Doug Massey Lead Regulatory Engineer LXE, Inc. Ph. (770) 447-4224 x3607 FAX (770) 447-6928 Visit our web home at http://www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: Hazardous Area Designations/Certifications
Hi Chris, Classified area = hazardous location = an area where the atmosphere may be easily ignitable Class = type of hazard; Class 1 = gas vapours; 2 = combustible dust, 3 = ignitable fibers Zone = Frequency of the hazard; Zone 1 means hazard present frequently or for long periods; Zone 2 means hazard present only during maintenance or mishap (leaky valve); Zone 0 means hazard present continuously in normal use (the headspace above the flammable liquid in the holding tank, and the lid of the tank) EEx = Approved to the European version of the Ex standards d = a protection method = 'flameproof enclosure' - contain the explosion n = a protection method = 'non-incendive' - no hot surfaces Gas Group IIB = Ethylene family of gases T3 = maximum product surface temperature of 200 C, under fault conditions Relevant authority for Europe = Notified Body (Notified to the ATEX Directive 94/9/EC) You scratched the surface on a really big topic; here are some links for your education: http://europa.eu.int/comm/enterprise/atex/index.htm - ATEX (94/9/EC) home page, with links to harmonized standards and notified bodies http://europa.eu.int/comm/enterprise/atex/guide/guide_en.pdf - ATEX guideline http://www.iecex.com/home.htm - IEC-EX home (like the CB Scheme for Ex) http://www.ul.com/hazloc/ - UL's hazloc page http://www.epsilon-ltd.com/ - Epsilon Ltd., home page - lots of hazloc info http://www.extronics.com/Ex_Info/protection_concepts.html - EXTronics has a good protection concepts table here. You could impress the questioner by pointing out that 'EEx n' devices are not allowed in Zone 1 areas... I'm guessing you have a European customer who needs a Zone 2 rating - I don't really see network diagnostic equipment being needed in a Zone 1 or 0 location. The full product rating would then likely be: ATEX Group 2 Category IIB, EEx n IIB T3. By the way, the ATEX Directive, mandatory July 1, 2003,requires notification (certification by an ATEX Notified Body) of your quality system per prEN13890, which is essentially ISO9000:2000 + specific ATEX requirements. Periodic factory surviellence is mandated by the Directive (is this a first?). Also note that the Class/Division system of defining HAZLOCS is widely used in North America; although the Class/Zone system has been allowed since 1999 (re 1999NEC Articles 505-510), only one facility has adopted the Class/Zone system to date. There are three, largely separate, approvals efforts for HAZLOC equipment; the USA, Europe, and ROW. The USA requires listing by an OSHA-approved NRTL. Europe requires an ATEX Notification. ROW - Australia, Brazil, Japan, among others - issue a national cert based on IEC standards. Have fun. Doug Massey Lead Regulatory Engineer LXE, Inc. -Original Message- From: Chris Maxwell [mailto:chris.maxw...@nettest.com] Sent: Monday, July 29, 2002 10:52 AM To: EMC-PSTC Internet Forum Subject: Hazardous Area Designations/Certifications Hi all, I have been asked a question regarding the following: use in a Zone 1 and Zone 2 classified area. This equipment shall be certified EEX d and EEx n by a relevant authority (e.g. BASEEFA, CENELEC etc.) and shall be suitable for Gas Group IIB and Temperature Class T3. Can anyone elaborate on the above information? What standard defines Zone 1 or Zone 2? What standard defines EEX d and EEX n? What about Gas Group IIB and Temperature Class T3? Any clarification, elaboration, elucidation and/or explanation that the group members could provide would certainly be appreciated. Thanks, Chris Maxwell | Design Engineer - Optical Division email chris.maxw...@nettest.com | dir +1 315 266 5128 | fax +1 315 797 8024 NetTest | 6 Rhoads Drive, Utica, NY 13502 | USA web www.nettest.com | tel +1 315 797 4449 | --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald:
RE: e-Labeling
Hi Greg, I guess it seems to me that if the device is non-functional, then none of the regulatory information applies. As to the other point about the warning being visible constantly, I agree - careful consideration must be given before using the display to present a warning. I'm more thinking along the lines of radio type approval ID's, etc, the displaying of which have no conceivable detrimental impact on safety. Thanks for your input. Doug -Original Message- From: soundsu...@aol.com [mailto:soundsu...@aol.com] Sent: Thursday, July 25, 2002 11:04 PM To: masse...@ems-t.com; emc-p...@majordomo.ieee.org Subject: Re: e-Labeling Doug, I think it's an interesting idea. Unfortunately, you have as many different regulators to convince as you have labels. As a former certifier, I have a few questions that I think would need to be resolved. For example, if there were some question about the device that an authority needed the label information for, and the device were not functioning, the information would not be retreivable. I don't see how you could argue that the device itself was properly marked in that case. Depending on the particular standard and marking requirement, the packaging materials may suffice for this. Also, I believe that for warnings that are intended to appear on the device itself, the intent of the standard would be that such warnings would have to be displayed continuously, not just when a screen is pulled up or at startup. While there is no guarantee a user will actually read a warning, all users must at least be exposed to the warning. A second user picking up an already switched-on device will not be exposed to the warning prior to use, unless the warning is always present on the screen - I suspect you do not intend to do that. There are other questions lurking in the back of my mind, but it's late and I'm too tired to get them out of the cobwebs. Those two should be enough for you to chew on for now. Good luck. Greg Galluccio www.productapprovals.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
e-Labeling
Hello Group; Today's regulatory labeling requirements in a global marketplace can get quite cumbersome, while devices such as handheld PDA-types tend to get smaller, with fewer flat surfaces available for product labeling. One of my company's objectives towards product labeling is that the system be flexible, with an eye toward future requirements as the product adds features, or moves into new world markets. A handheld product may require laser classification/warning, safety agency mark, national safety and/or EMC mark, FCC, Industry Canda, RTTE, and other national radiofrequency type approval marks for up to three different low power RF devices included in the unit simultaneously. While considering the regulatory labeling requirements for a new handheld computer, it occured to me that a PDA - type device is an ideal medium for storing and displaying information; by definition, that's what it is. The device itself could easily be an 'e-label'. Heck, I could store and display regulatory information such as agency marks, laser classifications, transceiver type approval numbers, etc, etc, ad nauseum. In a Windows CE environment, it's a piece of cake and there would be some definite advantages. Save $$ on labels. The regulatory info is as resistant to chemicals and wear as the device itself is. I can be a bit verbose, and make everything easy to read, instead of the usual too-crowded, too-small format. I could even store the DoC on the device itself. This device presents no potential hazard until it is powered up, and there is no hazard associated with putting the battery pack in. For instance, even with a laser barcode scanner option installed, could I display the aperture warning on start up? The manufacturing date and laser classification reside in memory, available to the display from a Windows icon or recessed dedicated keypad button? Just one example of the possibilities. Just one example of how the intent of the product specific standard may be met, while the letter of the standard may not be. For the purpose of clearing customs, most markings can be applied to packaging, where there's tons of space. I'd like to hear what your opinions are. Doug Massey Lead Regulatory Engineer LXE, Inc. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: 60601-1 leakage current testers
Try BAPCO for test equipment - http://www.bapcoinfo.com/ Doug Massey LXE, Inc. -Original Message- From: Brian McAuliffe [mailto:i...@mcac.ie] Sent: Thursday, July 18, 2002 5:48 AM To: Emc-Pstc Post Subject: 60601-1 leakage current testers any recommendations for sources of hire (preferrably in UK/Ireland) and/or purchase of test equipment suitable for performing the leakage current tests specified in EN60601-1:1990 ? thanks Brian McAuliffe MCA Compliance Solutions Ltd w: www.mcac.ie e: i...@mcac.ie t: +353 (0)65 6823452 m: +353 (0)87 2352554 --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: Radio approval i Japan
I would add these links to Fred's very thorough reply: TELEC: http://www.telec.or.jp/eng/index_e.htm IDA : http://www.ida.gov.sg/Website/IDAhome.nsf/Home?OpenForm I've found both to be very informative, including procedures and application forms on both sites. Doug Massey LXE, Inc. -Original Message- From: Fred Borda [mailto:fbo...@typeapproval.com] Sent: Monday, May 20, 2002 9:38 PM To: Kim Boll Jensen Cc: treg; EMC-PSTC Subject: Re: Radio approval i Japan Hello Kim, Basic approval requirements for radio devices are as follows: Japan Approval is issued by the Telecom Engineering Center (TELEC). In addition to a detailed application procedure that must be completed in Japanese and according to TELEC's format, testing of the equipment is required either at TELEC or at an accredited laboratory. There are no such laboratories outside of Japan right now. Testing is to standards published by the Association of Radio Industries and Businesses (ARIB). We were asked to look at a device for Japan not long ago operating in the 433 MHz band and were told that the frequency was not available for that application. You should look into these specifics for your device (or have someone do it). Bluetooth should be no problem. The applicant for the approval may be a foreign company. Once the equipment is approved by TELEC it must be labeled accordingly. Korea Approval for radio equipment is issued by Radio Research Laboratory (RRL), which is organized under the Ministry of Information and Communications (MIC). The application procedure is handled all in Korean, and testing must be performed at RRL or an accredited laboratory. I don't know of any of these labs located outside Korea. Testing is to Korean national standards. The applicant for the approval must be a Korean company. Approved equipment must be labeled. Taiwan Approval is issued by the Directorate General of Telecommunications (DGT). Testing must be completed to the LP-0002 standard for low power devices by an accredited laboratory. There are laboratories in Taiwan, as well as some (perhaps only one?) recognized outside of Taiwan through the APEC TEL MRA or other MRAs. The applicant for approval for most equipment must be a Taiwan company that holds a radio license. Approved equipment must be labeled. Singapore Approval is issued by the InfoComm Development Authority of Singapore (IDA). Equipment must comply with the technical conditions of IDA standards (TS 14 for the RFID, TS SSS for the Bluetooth device), however IDA will not require testing of the equipment. They will review existing international test reports to grant the approval. The applicant for approval must be a Singapore company that holds an IDA dealer's license. Approved equipment must be labeled. I hope this very basic information helps. By all means contact me off-list if you'd like to go into detail on products. Best regards, -Fred Borda Compliance International At PM 09:12 05/20/02 +0200, Kim Boll Jensen wrote: Hi All Can some one update me with information on the following: 433 MHz SRD and Bluetooth product approval requirements in: Japan Korea Taiwan Singapore I need information on both EMC, Radio and Safety. Best regards, Kim Boll Jensen Bolls Raadgivning Fred Borda Director Marketing Business Development Compliance International www.typeapproval.com -- The experts in telecommunications equipment type approval across the Asia-Pacific region -- 4713 First Street, Suite 280 Pleasanton, California 94566-7362 USA Tel +1.925.417.5571 (direct) Fax +1.925.417.5574 Mobile +1.650.740.5762 fbo...@typeapproval.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald:
RE: 2 questions. 1) HP software for 7400A analyzers, 2) FDA lette rs of Accession
Hi Gary, The FDA makes it clear that they DO NOT assess conformity of laser products; the letter of accession is merely an acknowledgement that a product report or supplemental report has been received and filed. I'm not sure what you're hoping for, but perhaps you should ask the vendor for the actual report, and judge conformity for yourself based on said report. If you're looking for an NRTL listing of a finished product incorporating a laser module, and the NRTL is trying to bill you for doing a CDRH product report, well, they should not, since it is not a requirement for them to do so - ask which clause in the standard requires it. UL60950 clause 0.2 mentions lasers as a potential safety hazard, but the standard gives no detailed requirements. So really, what they're saying is correct - a letter of accession means nothing to a safety assessment. The NRTL we've used generally requires a letter from us stating that a laser product report has been filed with CDRH. They also include the laser classification/warning label in the listing report. Also be aware that if you are incorporating a laser module into a finished product, it is your responsibility to submit product reports and annual reports to the CDRH, and you also have responsibilities for quality assurance, output power measurement in production, and record keeping. The module manufacturer actually has NONE of these responsibilities - CDRH requirements apply to finished products. Perhaps you have been the only unaccepting curmudgeon in the universe ;-) ! Others that incorporate the module into their products may routinely generate their CDRH product reports for the finished product, and the module vendor never hears that a letter of accession for the module is not sufficient to base assumption of conformity of the finished product on. Doug Massey Lead Regulatory Engineer LXE, Inc. -Original Message- From: Gary McInturff [mailto:gary.mcintu...@worldwidepackets.com] Sent: Tuesday, May 14, 2002 6:26 PM To: EMC-PSTC (E-mail) Subject: 2 questions. 1) HP software for 7400A analyzers, 2) FDA letters of Accession 1) I believe someone out there commented on using the HP 74XX series analyzer for pre-compliance measurements. Do you also use the additional software that can be purchased? The unit I played with had no additional software, but I could make measurements against limits lines etc, and it factored in the transceiver gains/losses and then allowed me to export a summary sheet for any reports I wanted to generate. What functions and value does the additional software bring to the table.? 2) Does anybody out there get any traction from a Letters of accession that the FDA sends to a optics vendor after receiving a request for a model addition? This letter says nothing useful for NRTL's and always includes This acknowledgement does not constitute approval or the document. The FEDS are disavowing any level of conformity assessment, and the NRTL's I use tell me they can't use it, even for an unrecognized componet, yet the vendors are insistent that I am the only unaccepting curmudgeon in the entire universe. Sorry if you've heard this before but I just can't believe it keeps happening, and that tells me that I should double check my facts. Thanks Gary --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: NEC Question
Hi gang: I have seen this thread more than once on this forum, regarding the fabled OSHA rule, CFR29 sec. 1910.399 as a basis to propose that ITE product safety in the US is a matter of legislation rather than litigation. It sounds great on the surface, but let's dig a little deeper. 29CFR sec. 1910.399 is the definitions section as applies to Subpart S--Electrical. If we take a look at the scope of Subpart S, found at sec.1910.301, we see that the scope of Subpart S DOES NOT include ITE, unless it is ITE used in Hazardous Locations. The definition found in 1910.399 only applies to all electric equipment and installations used to provide electric power and light for employee workplaces. IMHO, product safety for ITE in the US is a matter of potential litigation, not legislation. There is no federal law along the lines of the LVD that mandates compliance of ITE to any safety standard. Other product types, such as laser devices and medical devices, have applicable federal code governing design, construction, reporting, record keeping, etc. Of course, the wise manufacturer may employ an independent third party (NRTL) to evaluate the product to accepted safety standards - an advance preperation of the defense against a product liability lawsuit - NOT required by US federal code, and certainly 29CFR does NOT require that ITE used by the American worker be approved by an NRTL. The scope of Subpart S is shown below. I heartily welcome any rebuttals to my opinion. Doug Massey Lead Regulatory Engineer LXE, Inc * This subpart addresses electrical safety requirements that are necessary for the practical safeguarding of employees in their workplaces and is divided into four major divisions as follows: (a) Design safety standards for electrical systems. These regulations are contained in Secs. 1910.302 through 1910.330. Sections 1910.302 through 1910.308 contain design safety standards for electric utilization systems. Included in this category are all electric equipment and installations used to provide electric power and light for employee workplaces. Sections 1910.309 through 1910.330 are reserved for possible future design safety standards for other electrical systems. (b) Safety-related work practices. These regulations will be contained in Secs. 1910.331 through 1910.360. (c) Safety-related maintenance requirements. These regulations will be contained in Secs. 1910.361 through 1910.380. (d) Safety requirements for special equipment. These regulations will be contained in Secs. 1910.381 through 1910.398. (e) Definitions. Definitions applicable to each division are contained in Sec. 1910.399. * -Original Message- From: Eric Petitpierre [mailto:eric.petitpie...@pulse.com] Sent: Wednesday, March 20, 2002 1:35 PM To: jjuh...@fiberoptions.com; sbr...@prodigy.net Cc: emc-p...@ieee.org Subject: RE: NEC Question A couple of exceptions to what has been posted before by George and John. Referring to OSHA section 1910.399: With respect to an installation or equipment of a kind which no nationally recognized testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another federal agency, or by a state, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code as applied in this Subpart, or: With respect to custom-made equipment or related installations which are designed, fabricated for, and intended for use by a particular customer, if it is determined to be safe for its intended use by its manufacturer on the basis of test data which the employer keeps and makes available for the inspection to the Assistant Secretary or his authorized representatives. The first part will probably boil down to the same thing, get an NRTL to accept the product. The second part is much more flexible, but limits it to a particular customer. An excercise in Risk Management if you pursue that approach. Regards, Eric Petitpierre Pulsecom Herndon, VA ** 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 notify the system manager. This footnote also confirms that this email message has been swept for the presence of computer viruses. www.hubbell.com - Hubbell Incorporated ** --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to:
RE: ( More) Laser Safety Questions
Peter - I humbly submit that there is no 'flaw' in reminding folks that audits do happen and that they may be subject to one, however rare they may be. I don't argue that the agency is understaffed and overworked, and is more concerned with laser light shows and medical device lasers than with low-power, visible laser devices. Regards, Doug Massey Lead Regulatory Engineer LXE, Inc. -Original Message- From: Peter Tarver [mailto:peter.tar...@sanmina-sci.com] Sent: Thursday, March 14, 2002 11:52 AM To: emc-p...@ieee.org Cc: Massey, Doug C. Subject: RE: ( More) Laser Safety Questions All - The only flaw with this is that, based on my previous discussions with CDRH folks, they have very few auditors and no budget to hire more (this was a few years ago). Therefore, by their admission, the primary methods of keeping manufacturers and importers honest is 1) trust in the manufacturer's basic honesty 2) complaints from competitors, customers, etc. 3) field incidents Their primary concern was keeping up with the laser light shows, which they said they could not set aside auditing on (and for good reason). As a test of the presumption, has anyone on this list ever had a CDRH auditor in their facility, other than related to a laser light show? Regards, Peter L. Tarver, PE Product Safety Manager Sanmina-SCI Homologation Services peter.tar...@sanmina-sci.com -Original Message- From: Massey, Doug C. Sent: Wednesday, March 13, 2002 6:51 AM Hi Jeffrey, I've seen answers to this post regarding enforcement of the IEC standard, as well as to the CDRH rules. However, no one has mentioned FDA audits. The FDA does conduct periodic audits at the manufacturer's location as reported in the Product Reports and Annual Reports submitted to them. The auditor will check record keeping, quality control, and product design aspects such as proper labeling. My company has been producing laser products for many years, and only one audit has been conducted, that anyone can remember. I was the representative during that audit, and I commend the auditor on his professionalism and thoroughness. The auditor was a pleasure to work with, but he was very thorough. Rather than a 'let me see what I can nail you on' attitude, the auditor I dealt with had a 'let me see if I can help you improve your compliance process' attitude. The auditor will call ahead and let you know the date for the audit - an appreciated courtesy, but the date is not negotiable. Note that the FDA only has jurisdiction over manufacturing locations within the US. That's why it falls largely to customs to enforce imported goods, I presume. It is also noteworthy that the FDA has a very broad scope and generally has much bigger fish to fry than a manufacturer of low-power laser devices - I think that's why the frequency of audits for manufacturers like us is so low. You may never have the pleasure. For complete information about penalties and other administrative topics, check http://www.fda.gov/cdrh/radhlth/fdcact5c.html , the Electronic Product Radiation Control section of the Federal Food, Drug, and Cosmetic Act. Section 360pp covers Enforcement and Penalties. Hope this helps. Doug Massey Lead Regulatory Engineer LXE, Inc. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: IP Rating and EN60950
Hi Rich - Annex T of EN60950 refers to EN60529. Dust ingress is not considered. EN60950 clause 1.1.2 refers to Annex T. One thing to note - if you're designing for global use, UL60950 does not accept EN60529 testing - it must be UL50 tested. Which is, IMHO, overkill in many cases since UL50 is for electrical (mains connected) enclosures used outdoors. It does not apply to portable devices, yet UL will apply UL50 and not accept EN60529 test data, because that's the way the standard is written. What UL WILL DO is test to UL50, and use that test data to give you the EN60529 rating. However, even that is done unfairly - for example, in UL's (unpublished, I think)table that cross-references UL50 to EN60529, you must have a 4X rating to equate to an IPx6 rating - however, the 4X rating applies twice the volume and pressure of water. So much for harmonization. Doug Massey LXE, Inc. -Original Message- From: richwo...@tycoint.com [mailto:richwo...@tycoint.com] Sent: Wednesday, March 20, 2002 3:00 PM To: emc-p...@majordomo.ieee.org Subject: IP Rating and EN60950 I would like someone to explain to me why EN60950 does not normative reference EN60529. While the latter is referenced in the OJ, the scope of the standard seems to indicate that it is a basic standard to be referenced in product standards. The scope says, It will remain the reponsibility of the individual Technical Committes to decide on the extent and manner in which the classification is used in their standards and to define 'enclosure' as it applies to their equipment. Richard Woods Sensormatic Electronics Tyco International --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: ( More) Laser Safety Questions
Hi Jeffrey, I've seen answers to this post regarding enforcement of the IEC standard, as well as to the CDRH rules. However, no one has mentioned FDA audits. The FDA does conduct periodic audits at the manufacturer's location as reported in the Product Reports and Annual Reports submitted to them. The auditor will check record keeping, quality control, and product design aspects such as proper labeling. My company has been producing laser products for many years, and only one audit has been conducted, that anyone can remember. I was the representative during that audit, and I commend the auditor on his professionalism and thoroughness. The auditor was a pleasure to work with, but he was very thorough. Rather than a 'let me see what I can nail you on' attitude, the auditor I dealt with had a 'let me see if I can help you improve your compliance process' attitude. The auditor will call ahead and let you know the date for the audit - an appreciated courtesy, but the date is not negotiable. Note that the FDA only has jurisdiction over manufacturing locations within the US. That's why it falls largely to customs to enforce imported goods, I presume. It is also noteworthy that the FDA has a very broad scope and generally has much bigger fish to fry than a manufacturer of low-power laser devices - I think that's why the frequency of audits for manufacturers like us is so low. You may never have the pleasure. For complete information about penalties and other administrative topics, check http://www.fda.gov/cdrh/radhlth/fdcact5c.html , the Electronic Product Radiation Control section of the Federal Food, Drug, and Cosmetic Act. Section 360pp covers Enforcement and Penalties. Hope this helps.
RE: certification mark identification
Gary, This is the symbol of compliance to the EX Directive, and applies to products for use in potentially explosive atmospheres. On the same label you will find an Ex rating, that goes something like this: EEx ia IIb T4. The rating tells one what type of hazardous location the product is safe to use in. A good place to start looking for info on the web is the IECEX home page, at http://www.iecex.com/home.htm . The Safety Link also has some good references to hazardous locations requirements. The Ex symbol may also declare compliance to the newer ATEX Directive, which will supercede the Ex Directive June 2003. The 'EX' in both directives stands for 'explosive'. Doug Massey Lead Regulatory Engineer LXE, Inc. -Original Message- From: Gary McInturff [mailto:gary.mcintu...@worldwidepackets.com] Sent: Wednesday, January 16, 2002 7:37 PM To: EMC-PSTC (E-mail) Subject: certification mark identification Does anybody recognize an Ex inside of a hexagon? Think it might be French. Its on a Capri part. Not even one of mine but trying to do a good dead for one of our suppliers. Thanks in advance Gary --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
RE: Non-compliant product put into EU marked
Robert said: With no revenue, it is an exhibition, a test. What if a company decided to give away a thousand radiocommunications devices in London, and set up the required infrastructure to make them work, all for free? No revenue - but the devices sure did get put into service. Article 7.1 says this should happen only if the product complies with the essential requirements. It's my interpretation that a Beta test is 'putting into service'. Perhaps that's due to my experience - WLAN's - where a Beta test would be a large installation complete with Access Points, and (at least) dozens of clients. Hard to call that anything other than 'putting into service'. A customer agreeing to be a Beta test site probably would also be purchasing the equipment eventually, if not right away. Often equipment installed for beta test is left in service at the site. I'll grant you that Article 8.2 might be interpreted to include beta testing (call it a demonstration?), but I think beta testing will usually violate the spirit if not the text of the article. The article is intended to allow sales/promotional activities in advance of compliance. I think it also depends on how one defines 'beta test'. I'd like to hear how others interpret the RTTED on this point. It's a grey area, for sure. Doug Massey Lead Regulatory Engineer LXE, Inc. -Original Message- From: Robert Macy [mailto:m...@california.com] Sent: Thursday, December 27, 2001 9:56 AM To: Massey, Doug C.; IEEE - PSTC FORUM (E-mail) Subject: Re: Non-compliant product put into EU marked Wow! I've been telling clients that even a Beta test is allowed, as long as absolutely no revenue is derived from it. Can't sell it. Can't rent it. With no revenue, it is an exhibition, a test. Is this wrong? - Robert - Robert A. Macy, PEm...@california.com 408 286 3985 fx 408 297 9121 AJM International Electronics Consultants 619 North First St, San Jose, CA 95112 -Original Message- From: Massey, Doug C. masse...@ems-t.com To: IEEE - PSTC FORUM (E-mail) emc-p...@majordomo.ieee.org List-Post: emc-pstc@listserv.ieee.org Date: Thursday, December 27, 2001 6:20 AM Subject: RE: Non-compliant product put into EU marked Article 8.2 of the RTTED (1999/5/EC) allows exemptions for .. trade fairs, exhibitions, demonstrations, etc.. It also requires that a visible sign clearly indicates that such apparatus may not be marketed or put into service until it has been made to comply. Beta testing at a customer site does not fall under the Art. 8.2 exemptions. A sales team demonstrating the product to a customer could be exempt for the period of their demonstration. However, you can't call a large scale Beta test a demonstration - the Beta test is 'putting into service'. IMHO, it's in clear violation of the RTTED. Doug Massey Lead Regulatory Engineer LXE, Inc. -Original Message- From: am...@westin-emission.no [mailto:am...@westin-emission.no] Sent: Monday, December 17, 2001 5:05 PM To: emc-p...@majordomo.ieee.org Subject: SV: Non-compliant product put into EU marked As far as I know the product shall be produced in a large scale. The reason for putting it on the marked for a time limiting period is (again as far as I know) to run the product ( beta version) in a test installation and thereafter will it go through the entire test program (EMC, LVD, etc). It seems that they did not manage to do the testing before the 1 month test period on the field. Again, I feel they are not doing things in the consecutive order and I also think they are no allowed to put in on the marked, even the short period. Amund -Opprinnelig melding- Fra: Tania Grant [mailto:taniagr...@msn.com] Sendt: 17. desember 2001 19:33 Til: am...@westin-emission.no; emc-p...@majordomo.ieee.org Emne: Re: Non-compliant product put into EU marked Is the manufacturer serious, or completely ignorant? If serious, I would disassociate from them as much as possible. If merely ignorant, and you have some sort of association with them, I would recommend that you educate them fully. Another thought, -- is this product slated for mass distribution, even for only a month, or is it going to another location or a particular customer for some special in-house use or application? What does this customer think? Are they aware, and do they agree to this? The Directives do have special provisions for certain special applications where non-compliant (or is it merely untested !) product can be shipped to Europe, but I believe that under those circumstances, the name of the manufacturer and product model name or designation has to be published broadly in the EU. I don't remember the details. If anyone can shed more light, that would be very nice. taniagr...@msn.com - Original Message - From: am...@westin-emission.no To: emc-p...@majordomo.ieee.org Sent: Sunday, December 16, 2001 2:06 PM Subject: Non-compliant
RE: Non-compliant product put into EU marked
Article 8.2 of the RTTED (1999/5/EC) allows exemptions for .. trade fairs, exhibitions, demonstrations, etc.. It also requires that a visible sign clearly indicates that such apparatus may not be marketed or put into service until it has been made to comply. Beta testing at a customer site does not fall under the Art. 8.2 exemptions. A sales team demonstrating the product to a customer could be exempt for the period of their demonstration. However, you can't call a large scale Beta test a demonstration - the Beta test is 'putting into service'. IMHO, it's in clear violation of the RTTED. Doug Massey Lead Regulatory Engineer LXE, Inc. -Original Message- From: am...@westin-emission.no [mailto:am...@westin-emission.no] Sent: Monday, December 17, 2001 5:05 PM To: emc-p...@majordomo.ieee.org Subject: SV: Non-compliant product put into EU marked As far as I know the product shall be produced in a large scale. The reason for putting it on the marked for a time limiting period is (again as far as I know) to run the product ( beta version) in a test installation and thereafter will it go through the entire test program (EMC, LVD, etc). It seems that they did not manage to do the testing before the 1 month test period on the field. Again, I feel they are not doing things in the consecutive order and I also think they are no allowed to put in on the marked, even the short period. Amund -Opprinnelig melding- Fra: Tania Grant [mailto:taniagr...@msn.com] Sendt: 17. desember 2001 19:33 Til: am...@westin-emission.no; emc-p...@majordomo.ieee.org Emne: Re: Non-compliant product put into EU marked Is the manufacturer serious, or completely ignorant? If serious, I would disassociate from them as much as possible. If merely ignorant, and you have some sort of association with them, I would recommend that you educate them fully. Another thought, -- is this product slated for mass distribution, even for only a month, or is it going to another location or a particular customer for some special in-house use or application? What does this customer think? Are they aware, and do they agree to this? The Directives do have special provisions for certain special applications where non-compliant (or is it merely untested !) product can be shipped to Europe, but I believe that under those circumstances, the name of the manufacturer and product model name or designation has to be published broadly in the EU. I don't remember the details. If anyone can shed more light, that would be very nice. taniagr...@msn.com - Original Message - From: am...@westin-emission.no To: emc-p...@majordomo.ieee.org Sent: Sunday, December 16, 2001 2:06 PM Subject: Non-compliant product put into EU marked Hi all, You place a radio product into the EU marked with the following status: - Not been EMC, radio or safety tested (the previous model was tested and compliant, major modifications have later been implemented) - The product will only be in the marked for a time limiting period ( 1 month) - During the time limiting period it will be operating as in a normal condition - No CE mark on the product and no DoC I mean that you can't do this. You have to confirm that you fulfil the EMC, radio and safety requirements, DoC in place, even that the product just will be in the marked for 1 month and thereafter withdrawal. Any other comments from the list members ? Best regards Amund Westin, Oslo/Norway --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until
RE: ITE equipment in Petrol Station (Gas) outlets
Hello Alex group; For classification of hazardous areas, the definitive references are IEC 79-10 (EN60079-10)in the EU and in the US, it is NFPA no. HLH-97. However, you won't find a picture of a filling station here, with specific zone classifications. You will find the criteria and methods for classification determinations, and some common examples of areas considered to be hazardous. I assume when your equipment is being mounted into the dispensor housing. As Mr. Woodgate pointed out, first check with the customer, check your competitors, and check similar equipment to see what the equipment in use today is rated. Next, I would call the Hazloc experts at TUV, Factory Mutual, or UL, and ask their opinion. It's easy to get carried away trying to classify a location as hazardous. For example, a Zone 2 area is defined as one where an explosive atmosphere exists only in the event of failure or spillage - sounds like the business end of a gas pump, doesn't it? However, since dispensers are located outdoors, ventilation is adequate so that the area around your automobile is not considered a Zone 2 area. Good thing, since most autos are not rated for hazardous locations. For that matter, one could apply the Zone 2 definition to a residence using natural gas - in the event of a failure, a hazardous atmosphere exists. And, there have been explosions caused by such a leak. The ignition source of these explosions is not usually an electrical fault, but rather things like smoking, or a gas pilot light, etc. Because the number of explosions caused by electrical equipment failure is small in comparison to the number of residences, requiring electrical equipment suitable for use in hazardous areas would do little to actually reduce the hazard. The best solution is to apply standards to the plumbing to make it safer, and that's what's been done. So, if your product is used in the vicinity of a petrol dispensing unit, normal use standards apply. However, if it is mounted inside the petrol dispensing unit, this may be considered a Zone 2 location, since ventilation would be poor, but the hazardous atmosphere would only exist in the event of a plumbing failure. I've never seen a petrol dispenser indoors - that's why your question causes me some confusion. Wouldn't there be issues with auto exhaust, spillage, and other sources of hazardous vapor build-ups that would be quite dangerous? It makes me wonder if my assumption that the product is mounted in the dispensor housing is correct. For outdoor use, your equipment may be subject to higher creepage and clearance requirements under the -950 standards, since pollution degree three may apply. If you find that your equipment needs to be rated for Zone 2 areas, the protection method to apply would be non-incendive (IEC 79-15) or encapsulation (EN50028). If you have plenty of room, use EN50028, encapsulate the unit in RTV, thereby excluding the potentially hazardous atmosphere from the electrical circuit, submit to a Notified Body and an NRTL, and be done with it. Evaluation is pretty easy if the whole thing is encapsulated. Many NB's have agreements with NRTL's in the US, making a one-stop process possible. I hope this helps. However, you did not give enough information to give a truly definitive answer. Doug Massey Lead Regulatory Engineer LXE, Inc. -Original Message- From: Christman, Timothy (STP) [mailto:timothy.christ...@guidant.com] Sent: Wednesday, December 05, 2001 8:27 AM To: 'Nick Williams'; Alex McNeil Cc: 'emc-p...@majordomo.ieee.org' Subject: RE: ITE equipment in Petrol Station (Gas) outlets For the US angle, the National Electric Code has an extensive discussion of Hazardous (Classified) Environments (Ch. 5?) -- it might be useful to examine those recommendations to get ideas. I'm not sure what classification applies to gas stations -- link below to OSHA has a couple good tables... http://www.osha-slc.gov/doc/outreachtraining/htmlfiles/hazloc.html Timothy J. Christman Test Engineer Tel 651.582.3141 Fax 651.582.7599 timothy.christ...@guidant.com Guidant Corporation 4100 Hamline Ave. N. St. Paul, MN 55112 USA www.guidant.com Opinions are mine, not my employer's. -Original Message- From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: Tuesday, December 04, 2001 3:59 PM To: Alex McNeil Cc: 'emc-p...@majordomo.ieee.org' Subject: Re: ITE equipment in Petrol Station (Gas) outlets The assessment as to whether the equipment will be installed in a hazardous area is absolutely key to this. If the installation will be in a safe area, there are no special requirements and you just treat this as any other IT application (albeit with extra environmental protection if it's appropriate). If the installation is in an area which may be subjected to flammable gases, even if only rarely, you need to consider special protection measures. For a start, the LVD does not apply so the LVD standards are not
RE: European Harmonization of the 2.4 Ghz Band
Sandy, It depends on the particular device. You can get the full details at this website : http://www.anfr.fr/gb/ This is the site for the French Frequency Agency. You'll have to click on the NEWS button to see the new rules regarding 2.4 Ghz. In a nutshell, there are still power limitations for the full band, and will be until 2004. Power limitations also exist for outdoor use, even after 2004. Bluetooth falls under the category non-specific SRD, I believe. I think the reason for the truncated 2.4 Ghz band in France is that it conflicts with military useage. Agreement has been made to move the military applications to another band, thereby opening the 2.4 band up entirely, but this, as one might imagine, will take some time. Along the same lines, I have heard that Singapore has also opened the full 2.4 GHz band to SRD's, but I have been unable to confirm this. Does anyone have information on Singapore? Doug Massey Lead Regulatory Engineer LXE, Inc. -Original Message- From: Sandy Mazzola [mailto:mazzo...@symbol.com] Sent: Saturday, November 17, 2001 2:03 PM To: emc-p...@majordomo.ieee.org Subject: European Harmonization of the 2.4 Ghz Band To all, I have a question regarding the harmonization of the 2.4 Ghz to 2.4835 Ghz band for usage in Europe. My understanding was that France still allows only a truncated band (2.4465 Ghz-2.4835 Ghz) usage. Will those more learned then me in this area answer if this is still true, will it change any time soon and does this have any power stipulation on it. In other words is it also not harmonized for Bluetooth usage which would be a relatively low power transmitted of either 1 milliwatt or 10 milliwatts. Again Thank You in advance for your responses and have a great day. Sandy Mazzola Santo Mazzola Regulatory Engineer Symbol Technologies Inc 1 Symbol Plaza Holtsville, N. Y. 11742-1300 Phone: (631) 738-5373 Fax: (631) 738-3318 E-mail: mazzo...@symbol.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
Mexico question
Hello folks - Can anyone tell me if an ITE device that does not connect to AC Mains must be NOM certified in order to market the device in Mexico? One internet link says all ITE, another says AC Mains connected equipment - I'm confused. Does anyone have a link to or a list of regulated products? Thanks Doug Massey Safety Approvals Engineer LXE, Inc. Ph. (770) 447-4224 x3607 FAX (770) 447-6928 Visit our web home at http://www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall,
RE: FCC + FCC = FCC?
Just to further confuscate the issue - I once built my own home PC. I bought a box, motherboard, CPU, memory, variety of ISA cards, etc. It worked so well, I built a couple or three more for family and friends, and sold them to those family and friends at a good price. I didn't check radiated emissions. Am I an FCC Outlaw ? Doug Massey LXE, Inc. -Original Message- From: Ken Javor [mailto:ken.ja...@emccompliance.com] Sent: Tuesday, June 19, 2001 8:01 PM To: John Cronin; emc-p...@majordomo.ieee.org Subject: Re: FCC + FCC = FCC? Talk about ripping the lid off of Pandora's box... -- From: John Cronin croni...@hotmail.com To: emc-p...@majordomo.ieee.org Subject: FCC + FCC = FCC? List-Post: emc-pstc@listserv.ieee.org Date: Tue, Jun 19, 2001, 5:24 PM Hi Group This is a question regarding a plug in PC card that has been stated as FCC compliant which is inserted in a PC that is also stated to be FCC compliant and the emissions are found to actually exceed the FCC limits. What is the responsibility of the manufacturer who is intending to place this on the market as a functional unit? Are they liable for the overall unit or can they sell on the basis that it comprises FCC compliant sub assemblies, albeit evidently originally tested in different configurations. If they are liable, how can anyone sell any PC/PC card combination considering that the card could have originally been tested in a so called golden PC. Many thanks John Cronin _ Get Your Private, Free E-mail from MSN Hotmail at http://www.hotmail.com. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Heald davehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall,
RE: Batteries ...
The Battery Act regulates disposal of NiCd and SSLA (Small Sealed Lead Acid) batteries in the US, and mandates that manufacturers provide consumers with a means of safe disposal. Canada has a similar act. I'm unsure of the details in the EU, but I'm sure similar acts exist. There are two harmful elements that the Battery Act is designed to keep out of landfills; Cadmium and Lead. To learn all you need, go to the EPA web page, search on Battery Act or Batteries, and you can find the text of the Battery Act and a helpful guide to battery recycling. Also, the Rechargable Battery Recycling Corporation is a non-profit public service organization that recycles batteries - you'll recognize their logo immediately, as you see it on most battery products. http://www.rbrc.org/rbrc/ It is my understanding that alkaline cells have no special handling precautions; just throw them out. Li-Ions should not be incinerated - if you throw them in the trash, they may end up in a municipal incinerator, where they will explode. More information on proper disposal of all secondary cell chemistries is available at the RBRC web site. Doug Massey LXE, Inc. -Original Message- From: Doug McKean [mailto:dmck...@corp.auspex.com] Sent: Thursday, June 14, 2001 3:56 PM To: EMC-PSTC Discussion Group Subject: Batteries ... Maybe sort of off topic. What's the disposal procedures for batteries such as the A, AA, AAA, C, D, lithiums ... ? Are you supposed to just throw them into the trash? What if a customer a customer calls in to ask such a question and let's say they're in the US, Canada, or Europe? What are you supposed to say or what agency or website? - Doug --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall, --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall,
RE: Typing Shortcuts
Here's some - N/A - Not Applicable PCB - Printed Circuit Board PCA - Printed Circuit Assembly ASAP - As Soon As Possible et al - and others e.g. - for example FUBAR - F*@#ed Up Beyond All Repair LMAO - Laughed My A$$ Off e.g, My PM told my FM, et al, that we need the CPU PCA working ASAP, but it failed EMI EMC pre-testing badly, so I told them it was FUBAR and LMAO. By The Way, I know what BTW stands for Doug -Original Message- From: rehel...@mmm.com [mailto:rehel...@mmm.com] Sent: Wednesday, June 13, 2001 12:19 PM To: emc-p...@majordomo.ieee.org Subject: Typing Shortcuts Over time I have come across many typing shortcuts using the English language, such as: OTOH - on the other hand WRT - with regard to BTW - (I am still trying to figure out this one) Can someone please list the more common ones? I sometimes strain my brain trying to figure them out and they are in my own language. It must be terribly confusing to most of our world-wide colleagues. Thanks, Bob Heller 3M Product Safety, 76-1-01 St. Paul, MN 55107-1208 Tel: 651- 778-6336 Fax: 651-778-6252 --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall, --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall,
New laser standards
Hello Group - Can anyone direct me to an informative article, link, etc., that summarizes the impact of Amendment 2 to IEC 60825-1, released in January of this year ? I've reviewed the amendment and am aware of the basic differences it brings in classification, but it sure would be nice to have a synopsis of all the changes. Also, does anyone know how soon the changes will be incorporated into a new release of the standard ? The IEC website does not list a target date for release, although the status of edition 1.2 shows it being out for printing since early May. Also, CDRH Laser Notice # 50, published late May, harmonizes, to some degree, 21CFR to the IEC 60825-1 standard, with the notable exception of production line test requirments, record keeping, and some product marking requirements, which are being kept by the CDRH. Has anyone heard if the CDRH product report formats will be changed ? I'm thinking an IEC-60825-1 report, with US national deviations, if you will, may be acceptable to the CDRH at some point in the future, in lieu of their existing published report format. Of greater concern is the lack of a specified transition period and mandatory compliance dates in either standard (at least I can't find them). Will existing laser classifications be grandfathered? When will laser product manufacturers be required to label products according to the new classifications? I can see the new classifications causing much confusion among customers, who may have, say, Class2 laser products, then buying additional units of the same product, which might be labeled as Class 2M, for instance. Thanks for your help. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall,
RE: Product Safety: A Matter of Law or Litigation?
Mr. Woodgate says: Because the scope of the standard is quite independent of the scope of the LVD. Again, this begs the question - a matter of law or liability? The LVD is LAW - if a product falls within the scope of the LVD, then the product must be evaluated to the harmonized standard before placing said product in the Community market. Using an independent third party to evaluate the product (a wise choice) is optional. No arguement that the scope of a particular standard is independent of a Directive. EN60950 would be the natural choice of standard, but my question is, where is the law that supports this choice? Mr. Woods says in an earlier reply: ...obtain approval marks for the US and Canada due to the potential of litigation. You will have shown due diligence which may assist in limiting any liability issues. In the EU, however, they have no-fault liability - if someone is hurt by a defect in your equipment, you are at fault no matter what approvals you have. A safety approval in Europe is for useful for marketing purposes only. Good point, and an interesting view. Let me clarify that no-fault liability means that the injured party need only prove that the product was defective, and that the defect caused injury or property damage; the injured party does not have to show negligence on the part of the manufacturer, as is the case here in the states. Also, a safety approval does not relieve the manufacturer from liability in any court in the world, not just the EU. Basically, evaluating a product to an accepted safety standard could be viewed (cynically) as building your liability defense case before marketing your product. So far, I have found no iron-clad reason for evaluating a product outside the scope of the LVD to the EN standard. Many compelling reasons, but it seems to be a matter of litigation rather than law, and the choice is made based on the level of liability risk the manufacturer is comfortable with. I'm not debating the wisdom of said choices. It could be argued that a wrist watch falls within the scope of the EN60950 standard. Modern watches have calculators in them, etc. However, to apply that standard to a device with such low voltage, and low potential for harm seems very extreme. So the risk is very low. However, a battery powered device incorporating Li-Ion batteries, laser devices, LCD backlight inverters, etc, even if the device does not fall within the scope of the LVD, is on the high side of the risk factor scale. It may be a wise choice to evaluate that product to EN60950 before marketing it in the EU. Thank you all for sharing your valued opinions, insights, experience, and knowledge. Best Regards, Doug -Original Message- From: Brian O'Connell [mailto:boconn...@t-yuden.com] Sent: Tuesday, June 05, 2001 9:57 AM To: 'emc-p...@majordomo.ieee.org' Subject: RE: Product Safety: A Matter of Law or Litigation? Once again, Mr. Woodgate has forced me to think... So, as a general policy, would it be valid to be driven by an indvidual standard's scope rather than the Directives? Brian O'Connell Taiyo Yuden (USA), Inc. -Original Message- From: John Woodgate [ mailto:j...@jmwa.demon.co.uk mailto:j...@jmwa.demon.co.uk ] FD27170820E5DD42B1D5B13DE96A775404BF80@mrl01, Massey, Doug C. masse...@ems-t.com inimitably wrote: If the LVD does not apply to the product, then how can I argue that EN60950 applies to the product? Because the scope of the standard is quite independent of the scope of the LVD. --
RE: Product Safety: A Matter of Law or Litigation?
Alex, Thanks for your reply, and I agree. However, I don't need convincing. Here's the rub - EN60950 is a harmonized standard under the LVD. If the LVD does not apply to the product, then how can I argue that EN60950 applies to the product? Doug -Original Message- From: Alex McNeil [mailto:alex.mcn...@ingenicofortronic.com] Sent: Monday, June 04, 2001 12:14 PM To: 'Massey, Doug C.' Cc: 'IEEE Forum' Subject: RE: Product Safety: A Matter of Law or Litigation? Doug, As a general rule you should always have your products Safety Approved. This is showing Due Dilligence in that you have had the product safety evaluated. The latest EN60950:2000 covers ...mains powered or battery-powered ITE with a Rated Voltage not exceeding 600V i.e. there is no lower voltage limit! I hope this helps? Regards ALEX -Original Message- From: Massey, Doug C. [mailto:masse...@ems-t.com] Sent: Monday, June 04, 2001 1:47 PM To: 'IEEE Forum' Subject:Product Safety: A Matter of Law or Litigation? Colleagues: I have been tasked with justifying the need for independent, third party evaluations of the safety of our company's products to applicable standards. Our company manufactures various ITE equipment, either handheld, battery powered devices, or ITE devices powered by vehicle batteries. In particular, the scope of the LVD states that it is applicable to devices rated 50-1000Vac or 75-1500Vdc; most of our products are below 75Vdc. We market these products in 35 countries; North America, the EU/EFTA, and others - in fact, pretty much all of the countries participating in the CB Scheme. In the US, OSHA regs justify this requirement, as our equipment is sold through direct channels solely for logistics applications - in other words, US workers will be using the equipment - it's not for general consumer use. TITLE 29--LABOR PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS--Table of Contents Subpart S--Electrical Sec. 1910.399 Definitions applicable to this subpart. Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this Subpart S: (i) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory; or (ii) With respect to an installation or equipment of a kind which no nationally recognized testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code and found in compliance with the provisions of the National Electrical Code as applied in this subpart; or ... In the EU/EFTA, the justification is not so easy. As I mentioned earlier, the products are exempt from the LVD. The General Product Safety Directive, and the Product Liability Directive, do not give me an easy justification, such as in the case of the OSHA regs stated in US Federal Code. My company has always had all products evaluated to the -950 standards, but has observed that other manufacturers of similar equipment do not have their products evaluated to applicable safety standards, and CE mark their products based on compliance to the EMC Directive, but not to the LVD. I would greatly appreciate your insights, opinions, and assistance with this question. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall, --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac
RE: EN60950 - Changes between 1992 2000 Editions
Hi John - check out http://www.ul.com/ite/60950Analysis_05_07_01.PDF for UL's Certification Impact Analysis of the new standard. Doug Massey LXE, Inc. -Original Message- From: Allen, John [mailto:john.al...@uk.thalesgroup.com] Sent: Thursday, May 31, 2001 6:12 AM To: 'EMC-PSTC' Subject: EN60950 - Changes between 1992 2000 Editions Hi Folks The requirements of the various clauses have been re-arranged between these two editions, so does anyone know of any guides or cross-references as to how the requirements have actually moved around? Thanks in advance. John Allen Thales Defence Communications Division Bracknell UK --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall, --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall,
RE: Li-ion Batteries
Well, I haven't seen anybody weigh in on this yet, so here goes. First of all, Li-Ion batteries have tremendous energy density. I recently watched some videos of Li-Ion cells failing an overcharge test, and it was really impressive. These things looked like a roman candle going off ! They would make great highway flares. So here's my advice and hopefully I can answer some of your questions. 1. Vent. Period. If a cell vents inside your device, the pressure build up inside your battery pack enclosure could be tremendous if an adequate venting mechanism is not provided. 2. In addition to providing reliable overcharge, overvoltage, reverse polarity protection, consider controlling the maximum discharge current as well. With today's cells, most (probably all) incorporate a PTC device built into the cell to interrupt excessive current. I personally would not recommend relying solely on this protective device alone. However, that built-in device will allow you to pass the rapid discharge test of clause 4.3.21 (UL1950 3rd Ed. reference), where you must defeat any current or voltage limiting device in the battery load circuit. 3. Protection circuits for Li-Ion are typically based on an IC controller along with some discreet components making up the circuit. Last time I dealt with getting a Li-Ion pack approved, that IC is not UL recognized, and we could not find any control chips that are. Expect to be asked by the test house to provide technical assistance in determining worst-case faults in that circuit, so that they can ensure the safety of that control circuit under any conceivable single fault condition. Expect the test house to focus more on the battery and associated control circuits than anything else in your portable device, just as they might focus more on the primary side of an AC supply. The greatest energy source, and greatest safety hazard, in your product will be the battery. What standards must these Li-ion batteries needs to comply before we purchase them? UL2054 or UL1642 standards or both ? What about European standards ? 4. UL 1642 is the applicable U.S. standard for cells. UL 2054 could be applied as well to a Li-Ion battery pack as well, but in your case, the requirements within the overall product standard (60950?) should apply. Not sure about the equivalent CENELEC standard. 5. When discussing battery issues, please refer to them as cells or battery packs, so that we all know whether you mean an individual cell or a pack made up of two or more connected cells. I am making assumptions that when you say battery, what you mean is, a removable battery pack, but I guess it's conceivable to have a widget that the cells are permanently mounted inside of, although I can't conceive why anyone would do that, since the typical life of a Li-Ion is going to be around 500 charge-discharge cycles. In the case of a Li-Ion battery pack, the only information required on the pack is the voltage and the IEC symbol referring the user to the operator's manual, where you will be required to have statements regarding the proper replacement of the battery, statements telling the operator not to disassemble, crush, or incinerate the battery pack, and not to operate above a certain temperature (usually around 200 C - this is very important, since people are always using their ITE devices in a friggin walk-in oven at 392 F to crush, disassemble, or incinerate their Li-Ion battery packs). This max temperature comes from the conditions of acceptability for the cell itself, and will vary between brands. Alternately, all of this info can be on the battery pack itself, but it's a lot of text that you may not be able to fit - 60950 does allow the warnings to be in the operator's service guides. We might want the supplier to put our company name on the battery, what can we do (or request from the supplier) to protect ourself on liability issue? If you figure out a way to get your company excused from any liability resulting from use of a product that your company produces, please let me know. Name or no name on it, if you sell that product, you could be liable for any damages. As always, independent third party evaluation of your product's compliance to the accepted national safety standards of the country in which you are marketing the product, along with diligent demonstratable product and process control in the manufacturing of said product is your best defense against product liability. But all that still doesn't ultimately relieve you of liability. Hope this helped. Please note that the opinions expressed above are my own opinions and not neccessarily that of my employer. Doug Massey LXE, Inc. -Original Message- From: Koh N. G. [mailto:koh...@cyberway.com.sg] Sent: Wednesday, May 16, 2001 10:07 AM To: EMC-PSTC Subject: Li-ion Batteries Greeting everyone, Can anyone advice on the requirement for Li-ion batteries? We are currently designing a prototable device which has Li-ion batteries built
RE: UL P.A.G.
I really didn't feel that I should pay for a subscription to the PAG's to clarify points in the standard, until a situation arose where the UL engineer on my project referred to a PAG note, and of course, I had to buy a subscription to verify what I was being told. I still don't think it should be a fee based service - if a standard is so unclear or incomplete that it needs clarification, ANYONE who has purchased the standard should have access to any clarifications. However, I feel I have gotten my $$ worth from three or four of the PAG's. For my money, anytime I can get a clarification to a standard clause, and it's in writing so I know it's more than an individual's opinion, I figure it will be worth its weight in gold one day. Doug Massey LXE, Inc. -Original Message- From: Brian O'Connell [mailto:boconn...@t-yuden.com] Sent: Thursday, May 17, 2001 9:49 AM To: emc-p...@ieee.org Subject: UL P.A.G. I would welcome opinions on the usefulness of a subscription to the UL Practical Application Guidelines. I speak only for myself. thnx mucho Brian --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall, --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall,
CTI
Hello Group - In the UL IQ for Plastics database, the CTI values are given as a single digit number, 0 thru 5. I know that the scale correlates to 100 V thru 600 V, but I forget which way it goes. Does CTI of 5 = 600 V, or is it the other way around? Is this scale given in UL746A or IEC 60112 ? Thanks in advance. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall,
RE: 950 Pollution degree detirmination
The UL interpretation is: Pollution Degree 2, based on the IP66 rating. I think EN60950 3rd Ed., clause 2.10.1 is very open to interpretation - I can make a great case that my power supply inside the enclosure is a subassembly (what else could it be?). Also, that subassembly is sealed against moisture or dust, as evidenced by the type test performed to a harmonized standard. I do understand the intent of PD 1, though, as others have responded in so many words, that's for things that are potted. We're designing to PD 3 spacings - I've already played devil's advocate as you did. I just wanted to hear a few opinions. Doug -Original Message- From: John Juhasz [mailto:jjuh...@fiberoptions.com] Sent: Monday, April 02, 2001 1:35 PM To: Massey, Doug C.; 'IEEE Forum' Subject: RE: 950 Pollution degree detirmination Doug, While I would tend to agree that this may be acceptable, and I would too like to see some sort of 'official' determination on this (I may have a similar situation arise in the next couple of months), I would like to play devil's advocate for a moment to further this discussion . . . As you quoted . . . EN60950 3rd Ed., clause 2.10.1 defines Pollution Degree 1 for components and subassemblies which are sealed so as to exclude dust and moisture (see 2.10.7). It clearly states for components and subassemblies. Your Pollution 1 argument requires the use of the IP66 enclosure. But is the product/enclosure pairing still considered a 'component' or subassembly'? The way I see it is that the product without the enclosure is the component or subassembly, and that installing the product in the IP66 enclosure make the product a 'top-level'. If for some reason the gasketing on the enclosure fails, or it is not closed properly, the product would not comply. Seems risky to me? (This is my opinion only, not that of my employer). John Juhasz Fiber Options Bohemia, NY -Original Message- From: Massey, Doug C. [ mailto:masse...@ems-t.com mailto:masse...@ems-t.com ] Sent: Monday, April 02, 2001 11:47 AM To: 'IEEE Forum' Subject: 950 Pollution degree detirmination Hello group - In the -950 series standards, three Pollution Degrees are defined for detirming insulation coordination. For instance, in EN60950 3rd Ed., clause 2.10.1 defines Pollution Degree 1 for components and subassemblies which are sealed so as to exclude dust and moisture (see 2.10.7). Clause 2.10.7 gives test requirements for temp cycling, humidity, and electric strength tests, although compliance to the clause is given as ...inspection from the outside, measurement, and, if necessary, by test. I would like to use Pollution Degree 1 when evaluating a product that has a dust and water ingress rating of IP66 per IEC - 60529, Degrees of protection provided by enclosures (IP Code) . The product itself is intended for use in a Pollution Degree 3 environment, but the creepages and clearances inside the unit are subject to Pollution Degree 1, thanks to the protection provided by the enclosure. Is the IEC-60529 report, showing a IP rating of IP66, adequate to satisfy the requirements of 2.10.1 2.10.7 for using Pollution Degree 1 when assessing clearance and creepage ? Thanks in advance. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ http://www.rcic.com/ click on Virtual Conference Hall,
950 Pollution degree detirmination
Hello group - In the -950 series standards, three Pollution Degrees are defined for detirming insulation coordination. For instance, in EN60950 3rd Ed., clause 2.10.1 defines Pollution Degree 1 for components and subassemblies which are sealed so as to exclude dust and moisture (see 2.10.7). Clause 2.10.7 gives test requirements for temp cycling, humidity, and electric strength tests, although compliance to the clause is given as ...inspection from the outside, measurement, and, if necessary, by test. I would like to use Pollution Degree 1 when evaluating a product that has a dust and water ingress rating of IP66 per IEC - 60529, Degrees of protection provided by enclosures (IP Code) . The product itself is intended for use in a Pollution Degree 3 environment, but the creepages and clearances inside the unit are subject to Pollution Degree 1, thanks to the protection provided by the enclosure. Is the IEC-60529 report, showing a IP rating of IP66, adequate to satisfy the requirements of 2.10.1 2.10.7 for using Pollution Degree 1 when assessing clearance and creepage ? Thanks in advance. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall,
RE: FLAME RATING OF STANDOFFS
Rich suggested testing the standoff for flammability, then showing the inspector that you are indeed using the same standoff as tested when a factory inspection is performed. This route would make me uncomfortable for a few reasons: 1. It may not pass, 2. Standoffs are a very cheap commodity, and for manufacturing reasons, you wouldn't want to be limited to a single source for this part, 3. you would need to get CofC's from the vendor with each shipment to show continuing compliance at every factory inspection, and 3. Added cost to your product evaluation for flame tests. As Richard Woods pointed out, if the electrical parts (PCB traces) cannot produce a temperature under fault that would cause ignition, then the part can be considered exempt from the V-2 or better requirement. I would suggest doing a fault analysis of the circuit to detirmine what fault could be applied to the circuit to create maximum current through the circuit traces, apply the fault, measure heat rise on the trace, then make a case for engineering judgement to be applied by the project engineer. The test lab will want to perform the tests themselves, of course, but if you provide a good analysis to them for verification, you'll have better luck getting the call on your side. Doug Massey LXE, Inc. -Original Message- From: wo...@sensormatic.com [mailto:wo...@sensormatic.com] Sent: Tuesday, February 20, 2001 12:48 PM To: emc-p...@ieee.org Subject: RE: FLAME RATING OF STANDOFFS Rich said The small-part exemption cited by Terry only applies to small parts separated from electrical parts by at least 13 mm (1/2-inch) of air. Actually, the 13 mm separation only applies for small parts near electrical parts which under fault conditions are likely to produce a temperature that could cause ignition. Thus, small parts can be accepted even if they are close to electrical parts as long as fault testing demonstrates that the small parts cannot catch fire. Richard Woods -- From: Rich Nute [SMTP:ri...@sdd.hp.com] Sent: Tuesday, February 20, 2001 11:45 AM To: kazimier_gawrzy...@dell.com Cc: tjm...@accusort.com; emc-p...@ieee.org Subject: Re: FLAME RATING OF STANDOFFS Hi Kazimier and Terry: Kazimier suggests asking the question: what's the safety concern Unfortunately, safety certification houses do not have the option of accepting products based on the answer to this question. A safety certification house certifies a product to a standard. Supposedly, the requirements contained in the standard make the product safe. In this case, IEC 60950, Sub-clause 4.4.3.2 requires all materials and components be rated V-2 or better. So, the certification house is requiring that the construction comply with the standard. You can't fault the certification house for imposing a requirement explicitly stated in the standard. The small-part exemption cited by Terry only applies to small parts separated from electrical parts by at least 13 mm (1/2-inch) of air. I would guess, from Terry's description and the action of the certification house, that this is not the case. (If it is the case, then you can invoke this sub-clause and the matter is closed.) Fortunately, the standard provides an option of testing. If you test the stand-off for flammability and it is flame-retardant, then your construction is acceptable. Now, instead of proving to the inspector that the material is V-2, you need only prove to the inspector that the stand-off is the manufacturer and model number that was tested. If you can't do this, then there is still another test option. You can test a non-flame- retardant standoff. If the resulting fire does not spread within the equipment, then you have proved that the standoff is indeed inconsequential to any fire. If you prove this, then there is no need to control the material. Best regards, Rich ps: Being a long-time certification house basher, I can't believe I've written a message defending a certification house! Hi Terry, Sounds like a discussion with your agency safety engineer might be in order. It's certain there's a line of reasoning behind the new approach taken by the agency, that you've described below. Question is, since the standard clauses you've called out make certain allowances, the real issue might easily be addressed by asking what's the safety concern? If the agency rep. understands your product, your reasoning and it all falls into an area of interpretation without any blatant standard violations, a certain amount of engineering judgment might help resolve the situation. My opinion only and not that of my employer. Good Luck. Regards, Kaz Gawrzyjal kazimier_gawrzy...@dell.com -Original Message- From: Terry Meck [mailto:tjm...@accusort.com] Sent: Tuesday, February 20, 2001 9:44 AM To: emc-p...@ieee.org Subject: FLAME RATING OF STANDOFFS Hi
RE: Seeking assistance from Chemical Experts
We might be trying to make a mountain out of a molehill here. I agree that a mountain is being made of a molehill - however, I think the TC made the mountain, not those of us who have tried to interpret the mountain. For my part, I have posted this exact question in the past and found the same spread of answers. So, I now use isopropyl alcohol as it is a harsher solvent than kerosene, and being an electronics manufacturer, we have boodles of it around here. If it stands up to the alcohol rub it will take the kerosene rub. Also, we manufacture some medical device products, and those standards call out alcohol for the rub test. (IEC601.1 clause 6.1(z)). Doug Massey LXE, Inc. -Original Message- From: geor...@lexmark.com [mailto:geor...@lexmark.com] Sent: Tuesday, January 02, 2001 4:29 PM To: kmccormick...@hotmail.com Cc: emc-p...@ieee.org Subject: RE: Seeking assistance from Chemical Experts We might be trying to make a mountain out of a molehill here. The basic intent of the various standards is to ensure that power rating information is not easily rubbed off. The international standards IEC/EN60950 (sec. 1.7.15) stipulate 15 second rub tests using water and petroleum spirits. The makeup of these spirits is stipulated. However, if a label withstands the rub test with any of the usual household spirits, e.g. kerosene, isopropyl alcohol, rubbing alcohol, lamp oil, lighter fluid, gasoline etc., it will probably withstand the test same with any of the uniquely specified petroleum spirits. I assume each of us has at one time tried to remove printing or the complete label from a jar or bottle for other uses. My own experience is that if one spirit will work, so will the others. Some (gasoline) will work faster than others (lighter fluid). Conversely, if a randomly chosen spirit will not work, it is time to try a knife blade or blow torch (just kidding about the torch). George Alspaugh kmccormickinc%hotmail@interlock.lexmark.com on 01/02/2001 03:40:42 PM Please respond to kmccormickinc%hotmail@interlock.lexmark.com To: emc-pstc%ieee@interlock.lexmark.com cc:(bcc: George Alspaugh/Lex/Lexmark) Subject: RE: Seeking assistance from Chemical Experts Thanks guys...BUT, I am not trying to convince UL that I am correct. This is all internal to the company I am working with. Just to give you an idea of how confusing this issue is, I have privately received responses stating that all the following are acceptable: Kerosene Isopropyl alcohol Rubbing Alcahol Lamp Oil Hexane Now I am not a chemical expert, but the chemical properties of these chemicals are not similar to one another (the simplest comparison is the boiling point, the above range from 60C - 300C). Calling UL and asking them what they use is easy...the hard part is proving that whatever the subject chemical is, it complies with the standard. Just wondering if anyone has had this experience before. From: Gary McInturff gary.mcintu...@worldwidepackets.com To: 'oover...@lexmark.com' oover...@lexmark.com, kmccormick...@hotmail.com CC: emc-p...@ieee.org Subject: RE: Seeking assistance from Chemical Experts Date: Tue, 2 Jan 2001 12:24:17 -0800 Not only cheap, but sometimes it is much easier just to do it their way than argue with them that you material should or should not be acceptable. Pick your battles. Let them win this one. Gary -Original Message- From: oover...@lexmark.com [mailto:oover...@lexmark.com] Sent: Tuesday, January 02, 2001 10:46 AM To: kmccormick...@hotmail.com Cc: emc-p...@ieee.org Subject: Re: Seeking assistance from Chemical Experts From the UL Test Data Sheets provided to me by my UL engineering office, the material listed in the text of the test data sheet is kerosene. I don't know what the actual physical characteristics are, but if UL uses this for their test I would assume that it is acceptable for me to use. Kerosene is an easy product to obtain and is not that expensive. I have included an excerpt of the UL 1950 test data sheet that I was given by UL. Oscar # Excerpt from the UL 1950 Test Data Sheets # 1.7.15 - PERMANENCE OF MARKING TEST: METHOD A sample of the marking label was subjected to this test. The surface of each marking as noted below was rubbed by hand for a period of 15 seconds with a water soaked cloth, and again for a period of 15 seconds with a cloth soaked with the petroleum spirit noted below. RESULTS TEST CONDITIONS: Use of Marking _ Material_ Held by _ Applied Surface Material_ OBSERVATIONS: Water Kerosene Any Damage? _ _ Legible? _ _ Curled? _ _ Edge Lifted? _ _ Easily Removed Intact?_ _ The marking was/was not
RE: Polarity Markings on AC Adapters
As far as I know, EIAJ CP1104 is the only standard worldwide that has the dc polarity symbol for barrel connectors. (Likewise, as far as I know, Japan has the only standard for barrel connectors.) This symbol is definitely NOT in IEC 417. I'm glad somebody asked that question - I've wondered it myself. Thanks for answering, Rich. Doug Massey LXE, Inc. -Original Message- From: Rich Nute [mailto:ri...@sdd.hp.com] Sent: Thursday, November 30, 2000 12:16 PM To: geor...@lexmark.com Cc: emc-p...@majordomo.ieee.org Subject: Re: Polarity Markings on AC Adapters Hi George: Thanks for the quick response! Does this mean that the symbology is only a Japan requirement? and does it apply to ITE as well as audio-visual equipment? The referenced standard, EIAJ CP1104, is similar to IEC 417. Indeed, EIAJ CP1104 contains many symbols from IEC 417 as well as from other sources. While the symbols are primarily those relating to audio-visual equipment, many of the symbols have much broader application, e.g., ground symbols, ac and dc symbols, etc. I cannot say whether or not these symbols are requirements in Japan or whether or not the standard applies to ITE. I would guess, however, that EIAJ CP1104 is a document which is referenced by end-product standards just as IEC 417 is referenced by end-product standards. (While I have a copy of the standard, it is in Japanese and I cannot read it!) As far as I know, EIAJ CP1104 is the only standard worldwide that has the dc polarity symbol for barrel connectors. (Likewise, as far as I know, Japan has the only standard for barrel connectors.) Best regards, Rich --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
yet another HAZLOC question
Hello group - I have another question about equipment for use in hazardous locations. I find no requirements in any of the relevant standards regarding the proper colors of indicators (LED's). For instance, a red LED on a standard-use product could indicate something benign like battery low - but for people who work in HAZLOCs, does a red indicator mean run like hell, it's gonna blow ? Also, what would be an appropriate color for the enclosure ? Our product being a portable device, we want to make the intrinsically safe version easily distinguishable from our standard product line which would have the same shape, and there may be both at a facility. I'm thinking orange generally means caution to people. Thanks in advance for your input. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Intrinsically safe equipment
Paul, thanks for the reply. Now, the real stickler for me is that we are trying to leverage an existing non-I-safe design - the entire enclosure is plastic. There are materials available with the correct properties but they are prohibitively expensive, and because the shrink factor is different, would require re-tooling, making the development cost prohibitive. Clause 7.3.2 (b)allows an expansion of the size to 100cmsquared if the plastics parts are additionally protected against the occurance of dangerous electrostatic charges. Also, 7.3.2 (c) gives a very ambiguous statement about other methods being acceptable - it's basically an out allowing engineering judgement. I'm interested in learning what some of the other methods are. I believe that the use of a leather case may meet the requirements of sub-clause (b) as long as the size of the openings are constrained to 100cmsquared, and may meet sub-clause (c) with larger openings based on engineering judgement. By the way, the standard still allows warning text. I shy away from that because while it may help in litigation, the bottom line with this type product is someone's life is definitely at stake. Also, I'm not sure what safety measures there may be that can reliably prevent ESD from occuring. Doug -Original Message- From: Finn, Paul [mailto:fi...@pan0.panametrics.com] Sent: Friday, November 17, 2000 6:56 AM To: Massey, Doug C. Subject: RE: Intrinsically safe equipment This requirement addresses the likelihood of ignition to the release of a static electricity which is capable of building up on a non-metallic surface. Prior to ATEX you were able to address this issue by means of a warning label. Know you must either select a suitably rated material, i.e. tested in accordance with 23.4.7.8 which verifies it has a resistance less than 1Gohm at 23C, 50%RH. Or to reduce the total area of the non-metallic surface to 100cmsquared for gas groups IIA, IIB and 20cmsquared for IIC. This can be accomplished by segregating a lager area into smaller sections which meet the requirements. The sections need to be separated by grounded partition. I do not know the requirements for the grounding of the partitions. Paul Finn Panametrics Inc -Original Message- From: Massey, Doug C. [SMTP:masse...@lxe.com] Sent: Thursday, November 16, 2000 2:59 PM To: 'IEEE Forum' Subject: Intrinsically safe equipment Hello group - I'm looking for help regarding the safety of equipment for use in hazardous locations, especially intrisically safe systems. Specifically, I have questions regarding clause 7.3.2 of standard EN 50014:1997, concerning electrostatic charges of enclosures of plastic materials. If anyone has experience with the ATEX Directive standards (IEC-79 based), I would greatly appreciate hearing from you. Please e-mail me directly or call at (770) 447-4224 x3607. I'm afraid this discussion may get a little large for this forum, so I am hesitant to post detailed questions here to a group that may likely be uninterested in the topic. Thanks in advance. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Intrinsically safe equipment
It would seem that this is one issue of signiicant difference between UL913 and ATEX - UL913 recommends constructing a portable device out of a non sparking material such as plastic or brass (clause 14.1). Here UL is addressing a valid concern about the risk of ignition caused by the unit accidentally banging up against something and creating a spark. ATEX does not address this concern, and UL913 doesn't address the concern of ESD caused by a buildup of charge in a material with extremely high surface resistivity. I'm thinking if I make the enclosure out of Flubber, it would meet all requirements. Anybody got the nutty professor's number? Doug -Original Message- From: Linstrom, John (IndSys, GEFanuc, CDI) [mailto:john.linst...@cdynamics.com] Sent: Thursday, November 16, 2000 5:07 PM To: Massey, Doug C. Subject: RE: Intrinsically safe equipment WE were denied an ATEX approval for a HAZLOC box with a plastic overlay on a touchscreen due to ESD concerns. Screen was beyond a certain size (?) and non-dissipative. I looked all over for a high Z optically clear plastic. Needed to be ~ 2gohm/sq, IIRC. No joy. GE would make some if I bought a truckload (thanks!) - so would some others. We finally settled for no ATEX and no touch screen. If it was just a plastic part, colored, etc. I think we could have found a suitable replacement... John Linstrom Computer Dynamics ph 864.672.4363 x266 fx 864.675.0106 john.linst...@cdynamics.com -Original Message- From: Massey, Doug C. [mailto:masse...@lxe.com] Sent: Thursday, November 16, 2000 2:59 PM To: 'IEEE Forum' Subject: Intrinsically safe equipment Hello group - I'm looking for help regarding the safety of equipment for use in hazardous locations, especially intrisically safe systems. Specifically, I have questions regarding clause 7.3.2 of standard EN 50014:1997, concerning electrostatic charges of enclosures of plastic materials. If anyone has experience with the ATEX Directive standards (IEC-79 based), I would greatly appreciate hearing from you. Please e-mail me directly or call at (770) 447-4224 x3607. I'm afraid this discussion may get a little large for this forum, so I am hesitant to post detailed questions here to a group that may likely be uninterested in the topic. Thanks in advance. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
Intrinsically safe equipment
Hello group - I'm looking for help regarding the safety of equipment for use in hazardous locations, especially intrisically safe systems. Specifically, I have questions regarding clause 7.3.2 of standard EN 50014:1997, concerning electrostatic charges of enclosures of plastic materials. If anyone has experience with the ATEX Directive standards (IEC-79 based), I would greatly appreciate hearing from you. Please e-mail me directly or call at (770) 447-4224 x3607. I'm afraid this discussion may get a little large for this forum, so I am hesitant to post detailed questions here to a group that may likely be uninterested in the topic. Thanks in advance. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
FW: EPA Hazardous Materials Lithium Batteries disposal
Hi Jeffrey: As far as the EPA is concerned, Li-ion batteries are not considered as hazardous material. Remember, the EPA is NOT concerned with the safety of your customer, only the effects on the environment. The Battery Management Act is Public Law 104-142, 104th Congress, and there is an EPA publication available, EPA530-K-97-009. The act is concerned with keeping with mercury, lead, and cadmium out of landfills - ie, Ni-Cd and SSLA's (Small Sealed Lead Acid) batteries. For Lithium batteries, the only disposal criteria is DO NOT INCINERATE - the contents are not considered harmful to the environment, but it may explode if heated beyond certain temps. Although it is still a mystery to me why a coin cell exploding in a trash incinerator at 2500 C can cause anyone concern. As to the UL concerns, the text of the safety warning is given in UL1950 3rd Ed., clause 1.7.17. Note that if the battery is in a service area and not operator accessible, this text need only be in service instructions. So if we're talking about a coin cell Lithium battery, most likely UL will want this text in the reference guide only. This text includes the statement Dispose of used batteries according to the manufacturers instructions. Now, you can take the low road and say that you aren't the battery manufacturer, but in my opinion you aren't making things easier for your customer - so you should take the initiative to either publish disposal instructions in your operators guide, or make those instructions available to your tech support folks so that if a customer calls in asking they will know what the answer is. If your battery is a custom Li-ion battery pack, then you become the manufacturer, even though you probably did not manufacture the cells themselves. I have recently addressed this issue with one of our products, and it caused me a bit of consternation. As a quick sanity check, I looked on a variety of battery packs used in various laptop and notebook computers to see what text was there - to my surprise, they all differed slightly (all were UL listed products). What I have learned is that the conditions of acceptability in the UL reports for the cells may dictate what the text says. The only thing you can do in this case is to let UL dictate the text to you, as you most likely don't have access to those reports. The main difference will be warning text restricting the upper operating temp, which in most cases will be much higher than anyone is likely to operate your device under. Here is the text on our battery pack: CAUTION: Risk of fire, explosion, or burns. Do not short circuit, crush, heat above 100 C, incinerate, or disassemble the battery. I have seen that temp range go as high as 200 C, all on UL listed products. I can't find a specific temp in the standard or in the practical applications guides, so all I can say in this case is let UL tell you. I do believe it depends on the conditions of acceptability of the particular cell used. You can get a lot of info from the cell manufacturers - Sanyo, Sony, NEC/Moli Energy. Also the RBRC and PRBA might help - independent battery recycling organizations. The upshot is to put the warning text required by UL in the appropriate location, and let your customers know that the batteries are not to be recycled or incinerated - just dispose of normally. I could never figure out how one disposing of a Lithium battery knows whether the trash can you just tossed it in is bound for an incinerator or not. I'm interested in hearing from anyone with more knowledge of proper disposal. The best I could find out from EPA, vendors,RBRC and PRBA is chuck 'em. Hope this helped. Doug Massey LXE, Inc. -Original Message- From: Collins, Jeffrey [mailto:jcoll...@ciena.com] Sent: Wednesday, November 15, 2000 4:04 PM To: IEEE EMC-PSTC Forum Subject: EPA Hazardous Materials Lithium Batteries disposal Group, I've got two general questions regarding hazardous material: 1). Any experience with identifying materials defined as hazardous by the EPA? (Is there a list somewhere??) My customer is interested in steps that should be taken to: * Avoid exposure * Avoid injury * Proper disposal of the material I took a look at the EPA website but it appears not to be straight forward in identifying what is and is not hazardous. We are the Mfg of Telecom equipment so there are no chemicals or fumes associated with our products. I've also looked at the WEEE Directive but this is a US based customer and they are specifically referencing the EPA. 2). Do you provide any instructions / processes regarding the disposal of Lithium batteries for your customers? If so what documents/standards are you referencing??? All replies are appreciated.. Jeffrey Collins MTS, Principal Compliance Engineer Ciena Core Switching Division jcoll...@ciena.com www.ciena.com --- This message is from the IEEE EMC Society Product Safety
RE: Label Rub test per IEC60950
THANKS TO ALL FOR THE REPLIES - THANKS, NED, FOR THE EXACT ANSWER !! -Original Message- From: Ned Devine [mailto:ndev...@entela.com] Sent: Tuesday, October 10, 2000 10:01 AM To: emc-p...@majordomo.ieee.org Subject: RE: Label Rub test per IEC60950 Hi, The requirement is for The petroleum spirit to be used for the test is aliphatic solvent hexane having a maximum aromatics content of 0,1 % by volume, a kauri-butenol value of 29, an initial boiling point of approximately 65 °C, a dry point of approximately 69 °C and a mass per unit volume of approximately 0,7 kg/l. Our Chemist researched it and found it is Hexane, 95+%. The Aldrich Cat. No. is 20,875-2. The CAS number is 110-5A-3. The Isopropyl Alcohol is 100% (not rubbing alcohol) and is a very aggressive solvent. It is at least as harsh as the Hexane. Ned Devine Entela, Inc. Program Manager III Phone 616 248 9671 Fax 616 574 9752 e-mail ndev...@entela.com -Original Message- From: Robert Johnson [mailto:robe...@ma.ultranet.com] Sent: Sunday, October 08, 2000 11:20 PM To: E Eszlari Cc: emc-p...@majordomo.ieee.org Subject: Re: Label Rub test per IEC60950 As I recall, the chemical that was described is what is sold in the US as kerosene. It appeared way back in the early UL standards that way. Since this is a petroleum distillate characterized mainly by its molecular weight and what temperature it comes off the refining process, describing it is kind of like coming up with a chemical formula for milk. Too messy to try. The term kerosene was not sufficient to properly describe it worldwide, so this description was what was recommended by those in the business. Many have also used cigarette lighter fluid for the test. Functionally it is pretty equivalent, just a lighter distillate. The container's much more convenient. Bob E Eszlari wrote: Hi Doug, I think you will find that the common mineral spirit found in your local hardware store is used by most companies to perform the test in order to get a good idea if the label and print will pass. I have found that UL will accept the results. By the way, the gallon of mineral spirits I have at home is also labeled petroleum spirit. If you are doubtful of this test result, you may want to have an agency such as UL do the test for you or use an approved label system. In my experience I have found mineral spirit to be a more harsh chemical than Isopropyl Alcohol. The alcohol test is performed on labels that are used in medical environments per IEC 60601. Ed From: Massey, Doug C. masse...@lxe.com Reply-To: Massey, Doug C. masse...@lxe.com To: 'IEEE Forum' emc-p...@majordomo.ieee.org Subject: Label Rub test per IEC60950 Date: Fri, 6 Oct 2000 10:22:27 -0400 Does anyone know what the trade name for the chemical used for the rub test in 60950 clause 1.7.15 is ? The standard calls it petroleum spirit, then describes an aliphatic solvent hexane, with several properties, none of which are a chemical formula. Is it common mineral spirits available at most hardware stores? Also, is Isopropyl Alcohol a more harsh solvent than the petroleum spirits? Thanks Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org _ Get Your Private, Free E-mail from MSN Hotmail at http://www.hotmail.com. Share information about yourself, create your own public profile at http://profiles.msn.com. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher
Label Rub test per IEC60950
Does anyone know what the trade name for the chemical used for the rub test in 60950 clause 1.7.15 is ? The standard calls it petroleum spirit, then describes an aliphatic solvent hexane, with several properties, none of which are a chemical formula. Is it common mineral spirits available at most hardware stores? Also, is Isopropyl Alcohol a more harsh solvent than the petroleum spirits? Thanks Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
Thanks for all the advice
Thanks to all who responded to my UL1950 desparate cry for help regarding interpretation of the clauses under 4.4. To summarize : (Rich) : Sub-clauses 4.4.3.2 through 4.4.3.6 are specific requirements for parts inside a fire enclosure, invoked by the compliance statement of 4.4.3.1. (Sub-clauses 4.4.3.2 through 4.4.3.6 do not have individual compliance statements; therefore, the sub-clauses define requirements for compliance to 4.4.3.1!) - Everybody agreed with this interpretation (except for the test house ! ). (Kaz) Is it possible that the exemptions under 1950, 3rd, cl. 4.4.3.2 .7th hyphenated item dealing with abnormal testing per 5.4.6 to prove in no issues could be applied? - Sorry Kaz, 5.4.6 applies to electrical components, not foam. Good try though. (George) box within a box - good logic. It is actually a box connected to a box - the LPS sources are extenal to this enclosure. Several folks mentioned the small parts criteria - unfortunately it wasn't THAT small. And finally, thanks to Rich again for putting it so succinctly.. Remember, you ALWAYS have the alternative of testing! Incidentally, the agency allowed it under engineering judgement, pending verification of LPS power sources. (Insert iron-clad disclaimer here that excuses my employer from any liability now and forever due to my personal opinions) Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
Desperate for help on a UL1950 interpretation
Hello All - I desperately need some opinions on an interpretation of a particular clause in UL1950. The background: I have an investigation underway to UL1950 of a portable handheld computer, powered by battery and other power options, all of which meet the requirements for inherently LPS. Clause 4.4.3.1 states, Components inside a FIRE ENCLOSURE, and continues into flammability requirements of materials and components. Clause 4.4.5.2 addresses components not requiring a fire enclosure, and states, -components in a SECONDARY CIRCUIT supplied by a limited power source complying with 2.11, provided that The product in question absolutely meets the requirements of clause 4.4.5.2, which I interpret to mean that a fire enclosure is not required. However, the test house performing the evaluation is applying all of the criteria of clause 4.4.3.2. Unfortunately, I have a relatively small foam spacer inside that does not meet the flammability class HF-2 or better as specified in 4.4.3.2. The test house tells me that yes, the product meets the requirements for the exemption allowed in 4.4.5.2, but that I cannot literally interpret the statement in 4.4.3.1 to mean that the substance of clause 4.4.3 regards only component and material flammability ratings inside a fire enclosure. I guess I'm a literal type guy - I can't see any other way to interpret the standard. Can anyone shed some light on this interpretation so that I can read between the lines and understand the real requirements? I'm not trying to make an enclosure of gasoline-impregnated paper, and with the exception of a small (but critical) piece of foam, everything else meets the requirements without the exclusion allowed by 4.4.5.2. HELP !?!? Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
