Re: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

[Michael Derby]

The RE Directive is ‘into force’ for the member states to begin transitioning 
into their national law.   That has not happened yet.

Also, there are no harmonised standards or Notified Bodies for the RED, so it’s 
unusable from a practical point of view.

 

The relevant stakeholders have until 12 June 2016 to prepare and we must be 
able to use the RED by 12 June 2016.

The RTTE Directive will be repealed on 12 June 2016.

 

 

But yes, as Lauren says, under the RED the Alert Symbol will no longer be part 
of the labelling requirements.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] 
Sent: 31 July 2014 20:24
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

 

The RTTE is replaced, in part by the RED (Radio Equipment Directive – 
2014/53/EU) which covers the ‘use of spectrum’ topic and no longer calls for 
the alert symbol. 

 

From RED …

“Article 50 

Repeal 

Directive 1999/5/EC is repealed with effect from 13 June 2016. 

References to the repealed Directive shall be construed as references to this 
Directive and shall be read in accordance with the correlation table in Annex 
VIII. 

 

Article 51 

Entry into force 

This Directive shall enter into force on the twentieth day following that of 
its publication in the Official Journal of the European Union. [i.e. early 
June, 2014]”

 

I think the above means the RED is in transition and you may chose to follow it 
vs. the RTTED. Thus an alert symbol might not be required. 

 

 

Regards,

Lauren 

KLA-Tencor

 

From: Dave Heald [mailto:emcp...@gmail.com] 
Sent: Thursday, July 31, 2014 12:38 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

 

Hi all,

  I know the 2.4 GHz band for WiFi no longer requires the Alert sign as the 
last restriction on use fell out in 2012, but I have a question on the 5GHz 
bands:

 

Specifically, if there is an EU-wide restriction on use (indoor use with power 
limits based on sub-band), is the Alert symbol still required?  

 

If it is not, what is the rationale for excluding it?  

 

 Note that I have been operating under the assumption that the Alert sign is 
required, but I haven't had to make the decision on whether or not to apply the 
Alert sign since 2011 when the 2.4GHz band still required it, so I want to 
check  be sure.

 

Thanks,

-Dave Heald

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Re: [PSES] New EU Directives

[Michael Derby]

Hi Scott,

I think that two important points to consider for anyone re-branding a
product is this:

The new Radio Equipment Directive states:

The manufacturer, having detailed knowledge of the design and production
process, is best placed to carry out the conformity assessment procedure.
Conformity assessment should therefore remain solely the obligation of the
manufacturer. 

It then states:

Any economic operator that either places radio equipment on the market
under his own name or trade mark or modifies radio equipment in such a way
that compliance with this Directive may be affected should be considered to
be the manufacturer and should assume the obligations of the manufacturer. 


The Directive effectively also states that any importer who has concerns
about the compliance of the device they import, should get it tested.

When deemed appropriate with regard to the risks presented by radio
equipment, importers shall, to protect the health and safety of end-users,
carry out sample testing of radio equipment made available on the market,
investigate, and, if necessary, keep a register of complaints, of
non-conforming radio equipment and radio equipment recalls, and shall keep
distributors informed of any such monitoring.

Importers who consider or have reason to believe that radio equipment which
they have placed on the market is not in conformity with this Directive
shall immediately take the corrective measures necessary to bring that radio
equipment into conformity, to withdraw it or recall it, if appropriate.
Furthermore, where the radio equipment presents a risk, importers shall
immediately inform the competent national authorities of the Member  states
in which they made the radio equipment available on the market to that
effect, giving details, in particular, of the non-compliance and of any
corrective measures taken. 


Thanks,   Michael.



Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 06 June 2014 16:20
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New EU Directives

Thanks!  What is the major impact on own brand labelers?

Regards,

Scott


On 6/6/14 5:53 am, T.Sato vef00...@nifty.ne.jp wrote:

 On Fri, 6 Jun 2014 00:49:58 +0800,
   Scott Xe scott...@gmail.com wrote:
 
 Is there any reason behind to have LVD, EMC and RTTE directives 
 updated in similar time?
 
 To align them with NLF, all the new approach directives which were not 
 aligned with NLF were/will be updated even if no other changes were 
 necessary.
 
 For some directives such as RTTED (RED), other significant changes 
 were also made.
 
 NLF itself have big impact, and I guess own brand labelers who 
 supplied completed product from OEMs may have hard time.
 
 Regards,
 Tom
 
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Re: [PSES] New EU Directives

[Michael Derby]

Hello,

Yes, the RED is just like the RTTED in that sense.

Presently:   If a device has a radio in it (such as a laptop with WiFi, or
other digital device with Bluetooth, etc.), then the RTTE Directive applies
to that device.   The RTTE Directive includes EMC and Safety, so the EMC
and Safety (LV) Directives do not apply to that device.

Similarly with the RED, it includes EMC and Safety, so the EMC Directive and
the Safety Directive will continue not to apply to radio products.

However, the EMC and Safety requirements within the RTTE and RE Directives
are equivalent to the requirements of the EMC and Safety Directives, with a
few noteworthy exceptions.   (For example, there is no minimum voltage limit
for radio equipment, so all battery powered equipment would need a safety
assessment)


Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 09 June 2014 10:07
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New EU Directives

In message 20af01cf83c0$8988ff10$9c9afd30$@acbcert.com, dated Mon, 9 Jun
2014, Michael Derby micha...@acbcert.com writes:


When deemed appropriate with regard to the risks presented by radio 
equipment, importers shall, to protect the health and safety of 
end-users,

So the RED, unlike the EMCD, includes provisions for electrical safety?
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid
faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] List of Harmonised standards for RED

[Michael Derby]

OJ for RED?

 

11:59pm on 11th June 2016 ?

 

J

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 08 June 2014 20:32
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] List of Harmonised standards for RED

 

David

 

It's unlikely to be any time soon.

 

The scope of the RED is different to the RTTE, so there will be products
transitioning between RTTE/RED and the EMC and LV Directives - this will
take a bit of time to coordinate.

 

The Commission is planning a workshop on the RED is late November - I don't
expect much to happen until sometime after that

 

Regards 

Charlie

 

From: itl-emc user group [mailto:itl...@itl.co.il] 
Sent: 08 June 2014 04:50
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] List of Harmonised standards for RED

 

Hi

Does anyone know of a target date for a list of harmonised standards for the
RED.

I just checked the web site and the list for RTTE still appears but no RED.

 

Regards,

David Shidlowsky | Technical Writer

Address 1 Bat-Sheva St. POB 87, LOD 71100 Israel

Tel 972-8-9186113 Fax 972-8-9153101

Mail e...@itl.co.il/dav...@itl.co.il  Web  http://www.itl.co.il/
www.itl.co.il

 

 http://app.sqm.co.il/SitePages/Questionnaire.aspx Fill out Customer
Satisfaction Survey

Global Certifications You Can Trust 

 

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Re: [PSES] New EU Directives

[Michael Derby]

The EMC and LV Directives are 're-casts', so there should not be much in the
way of technical changes.

 

For the RTTE Directive, that is being phased out and replaced with the
Radio Equipment Directive which was published last week.

There should be plenty of changes for radio products, including:

. Which devices are in or out of scope.

. Frequency range applicable.

. Assessment procedure and use of Notified Bodies.

. Notified Body actions and responsibilities.

. Labelling and user manuals.

. Declaration of Conformity.

. Responsible parties.

. Market surveillance.

. Process for Class 2 devices.

 

..to name but a few.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Jim Hulbert [mailto:jim.hulb...@pb.com] 
Sent: 23 May 2014 18:24
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] New EU Directives

 

I will of course investigate on my own.  But is anything shockingly changed
in the new EMC, LVD, and RTTE Directives?  Or for most of us will it simply
mean updating our Declarations of Conformity?

 

Jim Hulbert

Pitney Bowes

 

 

  _  

 

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Re: [PSES] Concerning FCC classification of digital devices

[Michael Derby]

Hello Niels,

 

Sorry to disappoint your customer but this is a computer peripheral.

 

They would connect it to their computer for updating software, etc.
Regardless of how rarely they do it… the fact is, they do it.

It’s like a mobile phone, or a GPS Sat Nav., or a camera, etc.   It is not
normally used while connected to a laptop, but connection to a laptop (or
computer) is one of its modes.

So, yes, it is a computer peripheral.

 

If they wish to DoC as a computer peripheral;  it needs to be tested at a
lab which is accredited and also has its details shown on the ‘accredited’
section of the FCC’s website.

https://apps.fcc.gov/oetcf/eas/reports/TestFirmSearch.cfm

(Search ‘accredited’, not ‘2.948 listed’)

They would then need a DoC and that FCC Logo.

 

Alternatively, if their lab is not on that ‘accredited’ list, then they can
get a certification with a TCB using equipment class JBP.

 

 

Thanks,   Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Niels Hougaard [mailto:n...@bolls.dk] 
Sent: 14 March 2014 14:05
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Concerning FCC classification of digital devices

 

Dear list members,

 

Being an independent testing facility, we have received a question from a
costumer regarding FCC classification. 

The consumer’s product is a small portable device for use with a musical
instrument. When the product is used normally, it is attached to the
instrument by audio Jack cables. The product is battery powered, but can be
powered by a general purpose adaptor. The product has a build-in
microprocessor and therefore clock frequencies that requires a
classification with regards to FCC (47 cfr part 15, §15.101).

For software update, programming purpose , and under these circumstances
also sometimes powering, the product has a MINI-B USB connector – depending
on variant, the product can either be supplied with or without the USB cable
in the shipping box.

 

Question is

– Is this product considered a “Class B Computer Peripheral” – which require
a DoC, and an accredited test report from an NVLAP accredited test lab and
appropriate FCC logo markings (DoC or certification procedure) ?

or 

– is the product considered  “Other Class B digital device - - “ – which
require only a verification and no FCC logo marking (Verification procedure)
?

 

Our costumer states that in their point of view the users only operates the
device with a computer connected, when they are putting the device into
operation initially or for reconfiguration, software upgrade or similar.
Therefore they claims it should not be considered Computer Peripheral since
the use of the product is very different from the use of typical computer
Peripherals like keyboard, mouse or printer.

 

Is having a USB connector enough to classify the product as a “Class B
Computer Peripheral”? Or is the use of the USB connector of importance+

 

Does anyone in here have experience from similar cases?

 

Regards,

Niels

Niels Hougaard

Bolls ApS

Ved Gadekæret 11F

DK-3660 Stenløse

Denmark

 

T: +45 48 18 35 66

F: +45 48 18 35 30

 mailto:n...@bolls.dk n...@bolls.dk

 http://www.bolls.dk/ www.bolls.dk

 

 

 

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Re: [PSES] Concerning FCC classification of digital devices

[Michael Derby]

That's correct Cortland.   If the USB is only used for charging (not data
transfer), then it does not count as a 'peripheral' and therefore
Verification as Digital Device can be used.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: CR [mailto:k...@earthlink.net] 
Sent: 14 March 2014 18:38
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Concerning FCC classification of digital devices

 

An on-board header is much less an issue; connecting only the power pins on
a micro-USB connector eliminates data transfer as a defining capability.

Cortland Richmond

On 3/14/2014 12:08 PM, Dward wrote:

 The simple fact that it can, at any time, connect to a PC and download
software makes this a Computer Peripheral.  It does not matter how often it
can be done, nor how many times it is actually done, the fact that it can be
done and that it is a consumer device makes

 

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Re: [PSES] RFID - USA

[Michael Derby]

Hello Mel,

 

For the RFID devices at 13.56 MHz, these come under FCC Part 15.225.

(For Industry Canada, it would be RSS-210 section A2.6)

 

RFID at 900 MHz is typically certified to FCC Part 15.247 as a DSS device.

 

For lower frequency RFID, such as 125 kHz, etc., people typically use the
general emissions limits of 15.209 and certify to Part 15C.

 

 

Thanks,   Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: mel soliven [mailto:mel_soli...@yahoo.com] 
Sent: 07 March 2014 03:11
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RFID - USA

 

Dear Experts,

 

Would appreciate if anyone can provide on RFID requirements in America?

Not sure if FCC will suffice this requirements.

The RFID has an operating frequency of 13.56MHz. 

 

Many Thanks

Mel

 

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Re: [PSES] FCC draft comments on WiFi operation in channels 12 and 13

[Michael Derby]

Hello Curt,

 

It has always been possible to use channels 12 and 13 in the USA because
they are perfectly in band channels.   However, it is very difficult for a
WLAN device to pass the FCC tests on those channels, so most manufacturers
simply choose to disable them.   Some manufacturers choose to reduce the
power on those channels.   Of course, if the whole device has sufficiently
low power, then it might pass channels 12 and 13 (or just 12) without
additional power reduction.

 

This means that most WLAN devices use only channels 1 to 11 but some do use
1 to 12 or 1 to 13.   (12 is easier to get passing than 13, since the tricky
test is a band edge issue)

 

It has always been the case that if you only test and certify your device up
to channel 11, then you cannot sell a device which could transmit on
channels 12 or 13.

 

In the past, manufacturers have asked the FCC if their devices can passive
scan on 12 and 13, even if their device is only certified up to channel 11.

Of course the answer was yes, you can passive scan because passive
scanning does not include transmission.

Of course, the assumption then should be that if the client device sees a
working access point on channel 12 or 13, it must not actually form a link
and transmit!

 

You can imagine that as a TCB, if we see an application which states that a
device transmits on channels 1 to 11 and can also passive scan on channels
12 and 13; it looks perfectly reasonable.   Many did not realise the need to
ask:  Please confirm that it cannot transmit on channels 12 or 13 if
instructed to do so by the access point.

 

It seems that some manufacturers did not make that final step.   I am not
going to say if this was a misunderstanding or avoidance of the rules by the
manufacturer or lack of explanation by the FCC; this is not my comment to
make and I'm sure there is a variety of answers.

 

So, last summer 2013, the FCC clarified the point that you can passive scan
on those channels but you cannot transmit on those channels if you are not
certified to use them, even if instructed to do so by an access point.

(Remember that the access point could be using channels 12 and 13 by
implementing power reduction, or could simply be breaking the rules!)

 

This 'clarification' came as a surprise to some manufacturers (but not all).

 

Due to this 'surprise', the FCC gave a 6 month amnesty where they would
not actively enforce/investigate this issue.   I don't like to call it a
transition period because nothing has actually changed.   It is a
clarification/explanation of the existing rules, it is not a change in the
rules.

 

I believe the amnesty expires next month.

 

 

I hope this helps.

 

 

Michael.

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Curtis Mc Namara [mailto:mcnam...@umn.edu] 
Sent: 30 January 2014 23:48
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] FCC draft comments on WiFi operation in channels 12 and 13

 

FCC Draft KDB 594280 Software Configuration Control DR04-41649:
https://apps.fcc.gov/eas/comments/GetPublishedDocument.html?id=352
https://apps.fcc.gov/eas/comments/GetPublishedDocument.html?id=352tn=40250
1 tn=402501

This draft says that operation on channels 12 and 13 in the US cannot rely
on passive scanning alone. However, at this point it is a draft, and the
introductory paragraph says to follow previous guidance.

Has a anyone here evaluated this? I have a customer with products in the
field which use passive scanning, and they are curious whether there will be
a transition time, and whether it is still permissible and practical to ship
devices with passive scanning.

Thanks!

Curt

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Re: [PSES] Risk Assessments and mitigation for EMC chambers

[Michael Derby]

If they make microwaves to look more like the carry cases you take a cat to the 
vet in, then it becomes almost impossible to get the cat to go in there.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: IBM Ken [mailto:ibm...@gmail.com] 
Sent: 10 January 2014 16:30
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Risk Assessments and mitigation for EMC chambers

 

I call for flashing hazard lights (and 'silent' dog whistles) to be added to 
all microwaves.

 

On Fri, Jan 10, 2014 at 11:26 AM, McInturff, Gary 
gary.mcintu...@esterline.com wrote:

Yea I can hardly get more than 4 cats on one of them. J

 

Gary

No animals were hurt in writing this email.

From: IBM Ken [mailto:ibm...@gmail.com] 
Sent: Friday, January 10, 2014 7:36 AM


To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Risk Assessments and mitigation for EMC chambers

 

My guess is because a microwave is a much smaller volume; not likely to have a 
human inside it when activated.

 

On Fri, Jan 10, 2014 at 9:13 AM, Sundstrom, Michael 
michael_sundst...@overheaddoor.com wrote:

From a RF Health and Safety point of view, why is a microwave oven allowed 
with just an interlock on the door and not allowed for a RF enclosure for EMC?
 Human Exposure Limit will not apply if no human is in RF chamber when RF is on.

 Michael Sundstrom
OHD TREQ Dallas
Electronic Lab Analyst EMC Lead
(214) 579 6312 tel:%28214%29%20579%206312   office
(940) 390 3644 tel:%28940%29%20390%203644   cell
マイク
KB5UKT


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]

Sent: Thursday, January 09, 2014 3:49 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Risk Assessments and mitigation for EMC chambers

In message da4b81107b2a4296adcb45d026290...@thhste15d1be4.hs20.net,
dated Thu, 9 Jan 2014, Charlie Blackham char...@sulisconsultants.com
writes:

Anyone have any documents or stories to share as to how they have
satisfied/pacified/dismissed enthusiastic Health  Safety officers who
still want to ?do something??

A safety briefing won't help if a 400 lb EUT slips off the turntable on to your 
foot. I think emergency stops are not only reasonable but would be required by 
law in some jurisdictions, and I don't see any EMC issues. Flashing lights are 
another matter; EMC issues exist and implementation is not as easy as for 
emergency stops.

Can you show that the applicable human exposure limits cannot anywhere be 
exceeded with the max amplifier and antenna?
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Nondum ex 
silvis sumus John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Website: http

Re: [PSES] TCBs FCC Shut Down

[Michael Derby]

Hello,

 

A Grant of certification may be sent to you by the TCB but it comes from the
FCC and their website.   It is an FCC Grant, not a TCB Grant.

The FCC website is down, so nothing can be granted or certified; not by any
TCB.

 

You can submit an application to a TCB and most likely they will perform the
review for you.   I know we are still reviewing applications and working
with manufacturers, despite the shutdown.

You can proceed to work with the TCB to resolve any issues with your
application.

If your application requires a KDB enquiry or a PBA, it will not be possible
to complete that stage because that requires the FCC website.

It will also not be possible to complete the certification.

 

The TCB cannot give you an It's ok to ship voucher.   That would not be a
good thing.

 

C2PCs are an application process also.Again, if you wish to have a C2PC
done, the TCB can help to review it but it cannot be completed or
'authorised'.

 

Yes, many have been affected by this, especially the TCBs of course, but
also the test labs, manufacturers and employees of the FCC.

 

All TCBs are in the same boat on this.   None of us can certify but all of
us could help to do the initial review.   So, I think the shopping around
idea is no different now, to how it was before.

 

I hope this helps,

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: FW Miller [mailto:f_w_mil...@yahoo.com] 
Sent: 02 October 2013 19:32
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] TCBs  FCC Shut Down

 

I need some advice and information, please.  

What constitutes a grant of certification from a TCB? 

1. Posting on the FCC web site, which is now shut down, until it isn't..

2. Technical evaluation review completed, with something in writing
indicating it's OK to ship.

3. Any other method? Chapter  verse of the source would be appreciated.

4. Following the certification, there's a C2PC for co-location that's
required. 

 

We, as with many many others have been affected by the shut down  are
looking for solutions. Are the TCBs acting in unison on this one, or should
we be shopping around?

 

Many thanks in advance for your support.

 

 

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Re: [PSES] USA Canada rf emission test standards

[Michael Derby]

Hello,

 

For the FCC, their rules do state ANSI C63.4-2003 only.   

However, their website confirms you can use either 2003 and 2009.

I can confirm that it is ok to use 2009.

 

http://transition.fcc.gov/oet/ea/eameasurements.html

 

Changing the FCC rules is not a quick process.   There is an FCC rule change
proposal in place, to insert the 2009 version and remove the 2003 version.

 

So, in summary, ANSI C63.4-2009 is ok for FCC and Industry Canada.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Ian McBurney [mailto:ian.mcbur...@allen-heath.com] 
Sent: 17 September 2013 16:35
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] USA  Canada rf emission test standards

 

Dear Colleagues;

 

I am trying to combine FCC 47 CFR part 15 and Canadian ICES-003:2012
radiated rf emission testing for a digital device that is an unintentional
radiator.

However; looking into the test standards for each country I am getting
perplexed.

 

It appears that for 47 CFR part 15 sub part B, the test standard for
compliance is ANSI UL C63.4 2003 whereas for Canada it is the latest edition
that is acceptable which I believe is the ANSI UL C63.4 2009.

Similarly; if I was to apply the CISPR 22 method then CFR47 part 15
recognises the third edition of CISPR 22 and Canada applies the 6 edition
2008.

 

Is there a common set of standards that can be applied for radiated 
conducted rf emission measurements that is acceptable in both the USA 
Canada?

 

I am carrying out measurements from 30MHz to 2GHz to class B limits.

 

Many thanks in advance.

 

Ian McBurney

Design  Compliance Engineer.

 

Allen  Heath Ltd.

Kernick Industrial Estate,

Penryn, Cornwall. TR10 9LU. UK

T: 01326 372070

E: ian.mcbur...@allen-heath.com

 

 

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Re: [PSES] Using existing WiFi FCC data for new FCCID - Yes or No?

[Michael Derby]

Hi Charles,

 

Sorry for the late reply.I'm just back from vacation and it's possible
you may already have your answer.

 

I think there's the engineering aspect and also the legislative aspect.

 

Firstly, if the WiFi part is a fully certified module, then you should not
need to repeat all those WiFi tests.   The module should have been certified
for any host and should therefore not require re-testing for a change in
host.   (Accepting that the host must be re-tested for its own emissions).

If the WiFi part is a Limited Modular Approval, then it may need to be
partially re-tested, to allow use in this newly designed host, if the
changes are significant.

(For example, you might need to consider if the module has a voltage
regulator and if the voltage to the module has changed.

 

Now, based on your question, I am going to guess that the WiFi part does not
actually have a certification or an FCC ID of its own.

So,  you would be taking test results from one unit and applying them to
another unit.

 

As an engineer, I can see that it would most likely not be a problem.   Most
likely, the majority of test results may remain unchanged.   Of course, I
have no idea about the voltage supply to your WiFi transmitter section, or
the temperature change around the WiFi part, etc., etc., all of which can
affect transmitter performance.   (Notice the excessive use of most likely
and may in there).

 

From an admin point of view though, you need to be careful that you're not
calling the WiFi  a reference design, whereby you have certified a device
once and then assume the same design will always comply in other hosts,
environments and circumstances.   There is not (yet?) a place for this in
the FCC rules.

Also, your old device and your new device would have different FCC IDs but
they would have identical test report values for the WiFi sections.

When the FCC are searching for faked test reports, this is one of their
search criteria (two separate certified devices with identical output
powers, for example).

In their search, your two devices would show up as having identical output
powers.   Further investigations would show that all the test results are
identical in the reports for two separate products.

This could be flagged as a faked test report!   At the very, very least, I
suspect it would be called in for audit testing.

 

So, I would say that if you do want to use your old WiFi test results for
your new product, then you should not just include the results and forget
about it.   Instead, you will need to provide very clear and thorough
explanations/justifications to your TCB, for upload to the FCC website.

You may need to do some partial testing to justify it.

 

The FCC's modular approvals (and limited modular approvals) process exists
to allow this sort of data re-use.   Certification of a design within a
device, to be copied by other devices, is not a permitted route.

 

If in doubt, I would recommend a re-test.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Grasso, Charles [mailto:charles.gra...@echostar.com] 
Sent: 30 August 2013 17:20
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Using existing WiFi FCC data for new FCCID - Yes or No?

 

Hello,

 

Given: A  product that has a front panel and a main board. The front panel
(along with USB and other electronics) also includes
the WiFI circuitry and antenna connectors. The main board also integrates
(on board)  a RF4CE radio for remote functionality.

 

Scenario: As the result of a cost reduction effort, the main board has been
redesigned and a new cheaper RF4CE radio circuit  included - however  there
are *NO*

changes to the front panel.  Of course the  RF4CE radio will be tested to
ensure compliance to FCC regulations, however as the WiFi radio has not
changed - 

there is a desire NOT to repeat the extensive WiFi testing that has already
been previously done. A  query was made to a TCB as to whether the previous
WiFi
data could be used in addition with the new RF4CE data to apply for a new
FCCID. 

 

Question:  Does anyone know why this approach would not be acceptable??

 

Best Regards

Charles Grasso

Compliance Engineer

Echostar Communications

(w) 303-706-5467

(c) 303-204-2974

(t) 3032042...@vtext.com

(e) charles.gra...@echostar.com

(e2) chasgra...@gmail.com

 

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Re: [PSES] Lists Of Harmonised Standards

[Michael Derby]

Hello,

 

I'll start by saying I don't know when the next version of the Official
Journal (harmonised standards) for the EMC and R%TTE Directives is due out.

 

For the EMC and RTTE  Directives, the last release was 23 October 2012, so
I would expect to see a new version released soon.   (Within 2013, I would
assume, but that's a guess)

 

As for the proposed Radio Equipment Directive (to replace the RTTE
Directive), the 'proposed' timeline is:

 

RE-D draft text was proposed on 17 October 2012.
EU Parliament discussions from Q1 of 2013.   Discussions estimated to take
approximately 1 year.
Final text expected in Q1 of 2014.
Transition period of 18 months expected, so the old RTTE approach should
finally be replaced by the end of 2015.

 

 

Of course, that was just the plan.   When do things ever really happen
early, or even on time?   J

I suspect that schedule has already slipped.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: itl-emc user group [mailto:itl...@itl.co.il] 
Sent: 22 August 2013 05:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Lists Of Harmonised Standards

 

Hi,

Does anyone have any leads as to when a new list of harmonized standards to
the EMC, Medical Devices, and RTTE Directives will be published.

I recall reading in some previous posts that the RTTE Directive is going to
be discontinued and a Directive concerning radio only will be published.

 

Regards,

David Shidlowsky | Technical Writer

Address 1 Bat-Sheva St. POB 87, LOD 71100 Israel

Tel 972-8-9186113 Fax 972-8-9153101

Mail e...@itl.co.il/dav...@itl.co.il  Web  http://www.itl.co.il/
www.itl.co.il

 

 http://app.sqm.co.il/SitePages/Questionnaire.aspx Fill out Customer
Satisfaction Survey

Global Certifications You Can Trust 

 

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Re: [PSES] Verification under FCC rules and our Digital Class A product for industrial use only

[Michael Derby]

Hello  all,

 

I agree with Tom that it only applies to Class B computer peripherals.

 

However, I thought I'd share an interesting recent experience with you, for
your information.

 

I sent a KDB to the FCC about a boat (luxury yacht) that had a USB port on
the dashboard (I'm not sure if boat users employ the terminology
'dashboard'?   I guess I mean the place where the 'driver' stands, to guide
the 'pointy end' of the boat).   J

 

The USB port on the dashboard was there to allow a person to use a laptop,
to update the software to the boat's GPS and navigation systems.

 

The FCC confirmed that the GPS etc. within the boat's dashboard would
require a DoC, because it becomes a Class B computer peripheral when you
take a laptop onto the boat and plug it into the dashboard.

 

I suspect this probably comes from the history of the Class B or A decision,
with regard to proximity to television receivers.

Being a luxury yacht, it had many television receivers. 

 

I confess, I was surprised.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Thomas Cokenias [mailto:t...@tncokenias.org] 
Sent: 22 August 2013 21:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Verification under FCC rules and our Digital Class A
product for industrial use only

 

Hi Binayak

 

Your product is used and sold  for use in the non-residential/industrial
environment only, so your product is class A and requires verification only,
even though it could be connected to a class B computer as a peripheral

 

best regards

 

Tom Cokenias

 

On Aug 22, 2013, at 11:48 AM, Binayak Marahatta wrote:





Dear experts,

We wanted to do Verification under FCC rules and We have Digital Class A
product ( touch display for industrial application only). Test required for
verification process is OK (No harmful interference at Industrial
environment). This device has been tested and found to comply with the
limits for a Class A digital device. These limits provide reasonable
protection against harmful interference when equipment is operated in a
commercial environment.


*

I know the following from FCC:

Verification: allows you to use an FCC listed lab or you can use your own
lab. 

 

*   Both require you to maintain test records in a format specified in
the rules: 

Verification:- Retention of Records are in 2.955 of the rules.

1. No additional description of measurement facilities is required if using
a FCC listed lab under 2.948 (1 ) (ii) 

2. If using your own lab then in additional to records defined in 2.955 a
description of measurement facilities is require under 2.948 (1).

*Both the DoC and Verification are called self-declaration
procedures (i.e. the Commission does not formally approve) , but does
require you to produce records of testing if the commission request it:




Additional questions:


If   device has a USB 2.0 port for sharing data or installing new software
from  computer, RJ-45 Ethernet connector, DVI-D, protective conductor
connection, Connection for 24 V DC supply,Serial interface etc, then does it
classified as a computer peripheral and would it  need either
Certification or DoC for that function??

Do you think we just needs Verification for this industrial Class A device?

 

Please advise.


Thank you for your help.

Best regards,

Bin





KEB products are Control Technology,Inverters, Converters, Servo
systems,Frequency generators,Communication, EMC, Magnetic Technology, Motor
and Gears, Elevator Technology, Medical Technology, Material Technology,
Automotive etc.







This e-mail, and any attachment to it, contains confidential information
that may be legally privileged and which is intended only for the
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This message is from the IEEE Product Safety Engineering Society emc

Re: [PSES] Grandfathered requirements for ETSI

[Michael Derby]

Hello,

 

In general, no.   The standards change to keep up with changes in
interference level, spectrum planning, problems seen, etc.

As I think John Woodgate already said..  You can sit on the standards
committee and influence it.

I used to be on the group for writing EN 300 328 and EN 301 893 (I am not
anymore, I should add!   V1.8.1 was not me!  J ) and the group was mostly
made up of manufacturers protecting the interests of their companies, and
regulators protecting their spectrum.

 

Can I ask exactly what the problem is?   Is it the Medium Access Protocol
issue?   Are you concerned that your device may choose to change channel
mid-operation, or something?

Actually, I'm guessing that (spectrum sharing) cannot be the issue because
that aspect of V1.8.1 became mandatory on 23rd October 2012.

Is it the new power measurements?

 

I'm curious because maybe there is a solution, after all.

 

If that fails, I have the ETSI group chairman's e-mail address, if you want
it.   J

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Mark Tucker [mailto:mtuc...@murata.com] 
Sent: 07 August 2013 18:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Grandfathered requirements for ETSI

 

Hi, 

My company makes 2.4 GHz proprietary wireless products for European use (not
WiFi, BT or ZB). These units are qualified under EN 300 328. We understand
that EN 300328 v1.8.1 will become law the 1st of 2015. 

We've been selling wireless products for many years in the EU and the
installed base is in the 10s of thousands of units. However, the changes
dictated by v1.8.1 will break our radio protocol and destroy the
compatibility between new units (that must be v1.8.1 compliant) and those
already installed in the field. This is a huge issue for us and any other
vendor that may have the misfortune of having a large installed base of
pre-existing products. 

Is there any provision in ETSI rules that allows for backwards compatibility
with preexisting products? I have a hard time believing that they wouldn't
have made some sort of provision for this. 

Any help or advice would be greatly appreciated. 

Mark 
















Mark Tucker
Director of Hardware Engineering
RFM
3079 Premiere Parkway, Suite 140
Duluth GA 30097
mtuc...@murata.com 

- Forwarded by Mark Tucker/US/MuRata on 08/07/2013 12:57 PM - 

From:IEEE LISTSERV Server (16.0) lists...@ieee.org 
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Subject:Welcome to the emc-pstc email list 

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Re: [PSES] Grandfathered ETSI standards for CE Marking?

[Michael Derby]

You are correct Carl.   The device always needs to be 'assessed' to the
latest 'requirements'.

 

...and the easiest way to do this, is to 'test' to the latest 'standard'.

 

If they are following the harmonised standard route, then they will need to
show compliance with EN 300 328 V1.8.1 before December 2014.   (Some tests
will need re-testing)

 

If they do not wish to do that, then they will need to go to a Notified Body
for an opinion because they will no longer have the luxury of presumption
of conformity because the standard listed on their DoC will no longer be
the harmonised one (from December 2014).

 

Of course, if they do go to a Notified Body with their old results (V1.7.1)
and ask for an opinion to the new requirements (V1.8.1), then the Notified
Body should ask for some justification.   You don't need to test to
harmonised standards when you go to a Notified Body, but the Notified Body
should be asking for some justification for compliance, which is typically
equivalent to the latest harmonised standards.

Most likely, the Notified Body would ask them to demonstrate how it would
meet the V1.8.1 requirements.   J

 

You're right that there's no certification for Europe on RTTE equipment.
It's all DoC, to the latest requirements.

 

So, I think you are right.   The lab and manufacturer seem like they are
wrong.

 

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Carl Newton [mailto:emcl...@gmail.com] 
Sent: 15 July 2013 17:02
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Grandfathered ETSI standards for CE Marking?

 

Group,

 

I'm in a debate with a lab and a manufacturer that insist that a RTTE
device doesn't need to be re-evaluated against a new revision standard when
the previous is withdrawn.

 

ETSI EN 300 228 V1.7.1 loses the presumption of conformity in 2014 (December
I think).  Customer is installing a ZigBee component within his ITE device
and wishes to apply the ZigBee transceiver compliance to his device.   I've
argued that revision V1.8.1 which is listed in the OJ must be applied after
the DoW.  Both the ZigBee component manufacturer and the test lab involved
argue that once a device is certified that retesting is not necessary.  

 

I've double-checked the Blue Guide and I believe that their interpretation
is not correct and that after the DoW the current revision listed in the OJ
must be stated on the DoC.   Safety in numbers, looking for a sanity check
here.

 

Thanks,

 

Carl

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Re: [PSES] Pager and EMC in US

[Michael Derby]

Hello Niels,

 

It can all depend on what is happening within the ‘other parts’ of the
device.

 

Firstly, I assume that the pager has a transceiver within it.   Perhaps a
WLAN transceiver, based on your testing and authorisation to 15.247.

 

Now, as you say, the “ordinary EMC” needs to be done on the non-transmitter
parts of the device.   (Probably testing to 15.109 and maybe also 15.107).
It can really depend on what the rest of the device is doing……

 

For example, if the pager has a USB port for sharing data or installing new
software from your computer, then it would be classified as a “computer
peripheral” and would need either Certification or DoC for that function.

If it does not operate as a computer peripheral and if it is basically just
“some electronics”, then most likely it just needs Verification.

 

DoC testing must be done at a recognised, accredited, test lab.   That means
a lab which is accredited but also registered on the FCC’s website for DoC
testing.

 

Verification and Certification testing does not require the lab to be
accredited.

However…..   although Verification and Certification testing does not
require an accredited test laboratory company; it is important to note that
any radiated measurements for Part 15 must be made on a test site that is
‘listed’ with the FCC.

 

So, let’s take Verification for example……

If you were doing Verification on the non-transmitter parts; then you don’t
need to use an accredited company but your Part 15.109 measurements (and
Part 15.209) tests must be performed on a listed test site.

 

https://apps.fcc.gov/oetcf/eas/reports/TestFirmSearch.cfm

 

 

I hope this helps?

 

 

Michael.

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Niels Hougaard [mailto:n...@bolls.dk] 
Sent: 14 May 2013 07:38
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Pager and EMC in US

 

Dear list members

 

A pager (small, portable) is tested according to FCC 47 CFR part 15, §15.247
and is getting a FCC grant authorization.

 

Must the ordinary EMC emission testing on such a product be performed by a
FCC accredited test lab, for a certification, or is verification acceptable
to FCC?

 

Best regards,

Niels Hougaard

Niels Hougaard

Bolls ApS

Ved Gadekæret 11F

DK-3660 Stenløse

Denmark

 

T: +45 48 18 35 66

F: +45 48 18 35 30

n...@bolls.dk

www.bolls.dk http://www.bolls.dk/ 

 

 

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Re: [PSES] EN 60065 A12 - Sound Pressure Restriction

[Michael Derby]

Hello,

I'm not really giving an opinion here, I'm just sharing some observations.

There have been a lot of conversations in Notified Body groups about this topic.

It's important to remember that the Directives (either the LVD or the RTTED) 
require that a device is safe and will not cause harm.   That's the basic 
requirement.   The Directives are more important than the standards.
The standards are there to help you demonstrate that.   Though, they do provide 
'presumption of conformity'.

I think the history of the scope of this document comes from a study that 
personal portable music players present a safety risk.   Therefore, the 
standard was created and references those devices.

As for other devices which put sound into your ear?   Well, that's the debate.
You still need to ensure that the device is not going to cause harm.

Some people say that the standard only covers portable music players and 
therefore something like a laptop or tablet does not need to worry about it.
Other people say that it's easy to sit at your desk for 8 hours and listen to 
music while you work, so therefore those devices should be assessed too.
Some say that a portable music player is a greater risk because you could walk 
away from your desk and still be listening.
Some say that a laptop/tablet is a greater risk because many people sit at 
their desk for longer than they walk around.

Ultimately, the standards are written based on a need that has been proposed to 
(for example) CENELEC.

Regardless of what you think poses the greatest risk; if you sell a device that 
allows people to listen to music, you are still responsible for being confident 
that there are no safety risks; regardless of whether this standard applies to 
your device or not.
That said, you may agree with the standard that a device outside the scope of 
A12 does not present a safety risk.

As ever, the Directives are more important than the standards.


Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 06 February 2013 14:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 60065 A12 - Sound Pressure Restriction

Hi Ted,

Appreciate your valid points.  Where does the standard specify to use the 
device while walking?  We can easily find people to watch the film or play the 
game with mobile phones and/or tablets in public transport.  To avoid dispute 
on this point, let us focus on CD players (all DVD players are backward 
compatible to CD players).  Lots of ads are showing that youngsters are holding 
the player by one hand.  Does the standard restrict that the device must be put 
into the pocket as a qualified unit?  The player can be placed in hand bag.  
Samsung Note 2 and other tablets are considered not as portable units?  However 
lots of people are holding such items on the go.

If a CD player is qualified as an exemption, does the supplier need to update 
the original LVD report to include this A12 although it is not required to 
comply with any requirements in A12?

Thanks and regards,

Scott


On 6/2/13 12:08 AM, Ted Eckert ted.eck...@microsoft.com wrote:

 Hi Scott,

 The people who sit on CENELEC committees are humans and they are prone 
 to human errors. They write standards in plain language that is easy 
 to understand. The problem comes when these standards are adopted into 
 law. Laws that are very precise are easy to interpret, but are very 
 complicated. Take the Low Voltage Directive as an example. It tells us 
 that products must be safe, but doesn't give much more detail. If that 
 were the only regulation in place, we would need armies of lawyers to 
 argue whether specific products are acceptably safe or have 
 unreasonable hazards. We are given the option of complying with standards 
 that give us more detail on one route to compliance.
 If you have an IT product that meets EN 60950-1, you have met one 
 legal interpretation of acceptably safe.

 In addition, standards are written by committee. The words need to be 
 acceptable to a specified majority of the committee before the 
 standard can be adopted. Precise language can be harder to pass 
 sometimes because some committee members may object to one particular 
 item. The whole committee may agree on the general intent of the 
 standard but not every specific item. A more general wording can be easier to 
 pass.

 The CENELEC audio requirements have three tests to determine if a 
 product is within the scope. The product is within the scope if:
 − is designed to allow the user to listen to recorded or broadcast 
 sound or video; and − primarily uses headphones or earphones that can 
 be worn in or on or around the ears; and − allows the user to walk 
 around while in use.

 Let's take the example of a portable DVD player. It meets the first 
 clause as playing recorded video is its primary function. Many meet 
 the second clause having headphone jacks, and often multiple headphone

Re: [PSES] Retesting to latest standards

[Michael Derby]

Hello,

 

If the latest version of the standard is 'harmonised' (on the Official
Journal) and if the old version has been removed from the Official Journal,
then you are recommended and encouraged to make sure your device complies
with the new version (so that  you can show you meet the latest harmonised
standards).   This is to make sure that devices which stay on the market for
a long time, keep up with the changing requirements.

 

If you look at the old standard and the new standard, then decide that none
of the changes really affect your device or your test results, then you
could say that your device meets the new standard without a need to re-test.
You can confidently put the new standard on your DoC in your TCF, having
performed the assessment.

 

If you find some new tests have been added that your device has not been
tested for, then you should test to those new tests.

 

Typically if a product is on the market for years and years, then it may
need to have a few reassessments to new standards, to make sure it's kept up
to date.

If a product is only on the market for a year or two, then typically it
would not require any re-assessments during its lifetime.

 

And yes, this is a volatile topic on this e-mail forum.   J

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Mcburney, Ian [mailto:ian.mcbur...@dmh-global.com] 
Sent: 05 February 2013 09:50
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Retesting to latest standards

 

Dear Colleagues;

 

I know this question has been ask before so please humour me.

We have an old product that was tested to the 1996 version of EN 55103 parts
1  2.

The latest versions are dated 2009 with some changes to testing.

Am I required to retest the product to the new version even though there
have been no changes to it since its original introduction.

 

Many thanks in advance

 

Ian McBurney

Design Engineer

 

Allen  Heath Ltd

Kernick Industrial Estate

Penryn, Cornwall

TR10 9LU

United Kingdom

 

+44 (0)1326 370121


ian.mcbur...@dmh-global.com

www.allen-heath.com http://www.allen-heath.com/ 
 http://www.dmh-global.com/ A DMH Pro Company.

 

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Re: [PSES] FCC IC and Product Information

[Michael Derby]

Hello,

 

You cannot get confidentiality or even short term confidentiality on a test
report.   You can't keep the results private, sorry.

 

David is correct in his summary below.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: itl-emc user group [mailto:itl...@itl.co.il] 
Sent: 30 January 2013 05:15
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC  IC and Product Information

 

In my experience, TCB's don't charge extra for confidentiality unlike the
FCC.

I have not heard of short term confidentiality for a test report.

Internal photos can be kept confidential only under certain circumstances
such as the device being filled and sealed with epoxy. Permanent
confidentiality request for schematics, block diagram and parts list is
given without any problem. 

 

Regards,

David Shidlowsky | Technical Writer

Address 1 Bat-Sheva St. POB 87, LOD 71100 Israel

Tel 972-8-9186113 Fax 972-8-9153101

Mail e...@itl.co.il/dav...@itl.co.il  Web  http://www.itl.co.il/
www.itl.co.il

 

 http://app.sqm.co.il/SitePages/Questionnaire.aspx Fill out Customer
Satisfaction Survey

Global Certifications You Can Trust 

 

 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Mark Gandler
Sent: Tuesday, January 29, 2013 9:50 PM
To: emc-pstc@listserv.ieee.org
Subject: RE: [PSES] FCC  IC and Product Information

 

You can submit 180 days Short term request for confidentiality pretty much
on most of the  information (phots, manuals, test setup) and later on ask
for 90 days extension.

The longer the request higher the fee

 

There is also an option for permanent confidentiality request on some of the
more critical info: block diagram, schematics. There is also a fee for that.


 

Mark

  _  

From: edpr...@cox.net
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] FCC  IC and Product Information
Date: Mon, 28 Jan 2013 21:27:46 -0800

Bill:

 

Wow, I never knew about this source. This will keep me up all night!

 

Ed Price

WB6WSN

Chula Vista, CA  USA

 

From: Bill Owsley [mailto:wdows...@yahoo.com] 
Sent: Monday, January 28, 2013 8:40 PM
To: Ed Price
Subject: Re: [PSES] FCC  IC and Product Information

 

http://transition.fcc.gov/oet/ea/fccid/
and explore from there...

 


  _  


From: Ed Price edpr...@cox.net
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Sent: Monday, January 28, 2013 10:05 PM
Subject: RE: [PSES] FCC  IC and Product Information


I didn't realize that the FCC releases any information to the public, other
than cross-referencing to your approval status. Do you mean something like
the information in your FRN (FCC Registration Number) that you have in order
to do business with the FCC?

BTW, I think it would be really great if I could access the test data
submitted to the FCC for things like Part 15 compliance. For one thing, as a
consumer, I could use that as a component of my purchasing decision. For
instance, if I were buying a DC to AC inverter, I could look at several and
be able to choose which one had the lowest emission signature, which is a
lot better than just the assurance that they all passed the limit.

Ed Price
WB6WSN
Chula Vista, CA  USA


-Original Message-
From: Peter Merguerian [mailto:pmerguerian2...@yahoo.com] 
Sent: Monday, January 28, 2013 6:47 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] FCC  IC and Product Information

Dear Members

How long can we prevent the FCC or IC from releasing any testing/product
information to the public?

Peter

Sent from my iPhone

Peter S. Merguerian
pe...@goglobalcompliance.com
Go Global Compliance Inc.
www.goglobalcompliance.com http://www.goglobalcompliance.com/ 
(408) 931-3303

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Re: [PSES] One DoC per manufactured Unit?!

[Michael Derby]

I think that's part of the history, John.

I believe one of the situations that arises from the NLF is that the 
requirements of each Directive are being harmonised.
This often means looking at all the Directives, finding the 'most strict 
requirement' and then applying it to all the others.

So, you couldn't have this requirement for the Toy Safety Directive and then 
say that it doesn't apply to other Directives, because that would not be in 
line with the Directive harmonisation and NLF.
The alternative would be to remove the requirement from the Toy Safety 
Directive, which obviously it not what they want to do.

I witnessed similar conversations with regard to the 5mm height of the CE Mark. 
  Some Directives don't (didn't) worry too much about CE Mark height but they 
will need to, to align through the NLF.

My glasses/spectacles have thin little stems of about 2.5mm thickness, so the 
CE Mark on the stem is about 2mm high.
I'm not sure how they could fit a 5mm CE Mark onto a 2.5mm stem.

Of course, I need to take my glasses off to see the CE Mark.   But without my 
glasses on, I cannot see a 2mm CE Mark.
So, maybe I just don't care.   Ignorance is bliss.


Michael.



Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: John Cotman [mailto:john.cot...@conformance.co.uk] 
Sent: 14 January 2013 16:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] One DoC per manufactured Unit?!

The Toy Safety Directive already has the picture requirement on the D of C.

John C

-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl]
Sent: 14 January 2013 14:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] One DoC per manufactured Unit?!

You can make fun of it, but all these things have been introduced with the goal 
of creating a better level playing field, thus making possible to find, an 
pursue those manufacturers that spoil the market by selling untested, possible 
unsafe cheap rubbish.


Customs are better able to simply stop products with false DoC, this way.

Imagine the poor customs guy, having to tell if these little green pieces of 
plastic with copper screws on it really are the KML032-1234-s-XX as the DoC 
states ?? 
If they are, they may withold the product and dupe the honest manufacturer, if 
they assume it's ok, another batch of unsafe rubbish may dupe the consumer (in 
the end).


If you look at it like that, the costs for even (if it were required) a serial 
number and a hologram and color image and a fully operating miniature  model 
with each DoC are a bargain compared to the increased benefit that goes with 
increased sales.;))  if you are not on the side of the cheaters. 


And of course, it also brings the cheating to a higher level, so expect
even more stringent measures in the future... it's an everlasting battle
between the GOOD and the BAD

Regards,

Ing.  Gert Gremmen, BSc



g.grem...@cetest.nl
www.cetest.nl

Kiotoweg 363
3047 BG Rotterdam
T 31(0)104152426
F 31(0)104154953

P Before printing, think about the environment. 



-Oorspronkelijk bericht-
Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens John Woodgate
Verzonden: Monday, January 14, 2013 3:00 PM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: One DoC per manufactured Unit?!

In message
64D32EE8B9CBDD44963ACB076A5F6ABB0262C6D0@Mailbox-Tech.lecotech.local,
dated Mon, 14 Jan 2013, Kunde, Brian brian_ku...@lecotc.com writes:

As far as the color picture, well, that?s just stupid. Why not ask for 
a hologram of the product?

A fully working full-size model would be even better. But for some suppliers, 
that would be too difficult.(;-)

Our DOC is included in our manual and we are not going to add color for 
a single picture.

I?m not sure where we would put a picture anyway. Our DOC is a full 
page now. It would most likely have to be very small or on a separate 
page.

Does the manual have a picture of the product on the front cover already?
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a 
point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] iPhone 5 TxRx frequencies on 4g

[Michael Derby]

Hello Derek,

 

I guess like most people have answered, this could be a two part question.

 

Are you interested in which bands are supported by your carrier?   Or are
you interested in which bands your iPhone 5 is technically capable of?

 

What's the FCC ID of your phone?

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Derek Walton [mailto:lfresea...@aol.com] 
Sent: 06 January 2013 17:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] iPhone 5 TxRx frequencies on 4g

 

HI folks, can anyone tell me what transmit and receive frequencies my iPhone
5 uses here on the US 4G network please. 

 

Thanks,


Derek.

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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

[Michael Derby]

Hello,

 

I think that in the past, there was always the general understanding that a
full copy of the DoC must be supplied with each device sold.

 

However, more and more people are simply adding a statement to their user
manual to state something like:   This device complies with the relevant
provisions of Directive 1999/5/EC  and then making sure that their full DoC
is available online, or something like that.

If you're going to do that, it's recommended to make sure the statement is
in every language, or at least in the language of the country it's arriving
into.

 

This document is very useful..

http://ec.europa.eu/enterprise/sectors/rtte/files/guidance/guidance_en.pdf

 

I have known people to have their product stopped at customs because the
package did not include the full DoC in, for example, Polish.   However, the
manufacturer quickly got one translated and supplied, so their product was
allowed in.

 

I know that some people still insist that the full DoC must be supplied with
each device but I think it's generally considered acceptable to just make
sure the 'statement of compliance' is provided and that the full DoC is at
least available.   Online is good.

I believe that the proposed new RTTE Directive text should officially allow
this approach, I hope.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 03 December 2012 08:25
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Language Translations for EU Declarations of Conformity
(DOCs)

 

 

It's covered in the Europa Interpretation of the RTTE Directive:

http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e
n.htm#h2-23 

 

regards

Charlie

 

 

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 30 November 2012 19:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Language Translations for EU Declarations of Conformity
(DOCs)

 

In message  mailto:3a33c563-1637-4755-b1ef-8247792e6...@conformance.co.uk
3a33c563-1637-4755-b1ef-8247792e6...@conformance.co.uk,

dated Thu, 29 Nov 2012, Nick Williams 
mailto:nick.willi...@conformance.co.uk nick.willi...@conformance.co.uk

writes:

 

AIUI, the R+TTE Directive also requires this, and there are others 

which do the same.

 

Article 6 3. of the RTTED says:

 

  3. Member States shall ensure that the manufacturer or the person
responsible for placing the apparatus on the market provides information for
the user on the intended use of the apparatus, together with the declaration
of conformity to the essential requirements.

 

Nowhere that I can find does it say a DoC has to accompany every unit.

--

OOO - Own Opinions Only. See  http://www.jmwa.demon.co.uk
www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it
proves to be.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

 

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For help, send mail to the list administrators:

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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Michael Derby]

I agree with Charlie that it is not saying you must test to V1.8.1.   It is
saying that you must have spectrum sharing mechanisms (we know that, it's in
V1.7.1) but we don't necessarily know what that means.   It gives examples,
followed by an idea of where to find tests if you want them.

 

 

Imagine the text from the OJ:

This version of the standard gives presumption of conformity with the
requirements of Article 3(2) of Directive 1999/5/EC under the following

condition: The equipment shall implement an adequate spectrum sharing
mechanism, e.g. LBT (Listen Before Talk), DAA (Detect And Avoid), etc., in

order to comply with the requirement specified in clause 4.3.5 of this
version. Such a mechanism shall facilitate sharing between the various

technologies and applications which currently exist and in case of
congestion, users will be ensured equal access (and as a consequence a
graceful

degradation of service to all users). The efficiency of the various sharing
mechanisms can be assessed using the appropriate clauses of EN 300328

version 1.8.1.

 

Now imagine a conversation between an industry person (let's call him IP)
and the OJ itself.   For the OJ, I shall use only the text above..

 

OJ:   This version of the standard gives presumption of conformity with the
requirements of Article 3(2) of Directive 1999/5/EC under the following

condition: The equipment shall implement an adequate spectrum sharing
mechanism,

 

IP:   What is a spectrum sharing mechanism?

 

OJ:e.g. LBT (Listen Before Talk), DAA (Detect And Avoid), etc., in order
to comply with the requirement specified in clause 4.3.5 of this version. 

 

IP:   Oh, I see that, but what is it for?   If you explain it, maybe I can
use some other way to meet that requirement.

 

OJ:   Such a mechanism shall facilitate sharing between the various
technologies and applications which currently exist and in case of
congestion, users will be ensured equal access (and as a consequence a
graceful degradation of service to all users). 

 

IP:   I see.   That would be really easy if I had a WLAN or Bluetooth device
but I don't, I have this cool new technology I invented.   Are there any
tests I can follow?

 

OJ:   The efficiency of the various sharing mechanisms can be assessed using
the appropriate clauses of EN 300328 version 1.8.1.

 

IP:   Thank you, you've been very helpful.

 

 

 

Honestly, I don't actually hear these voices in my head.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 29 November 2012 08:31
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

 

Mark

 

Harmonised Standards don't always contain all the requirements - Spectrum
Requirements also apply and these are regulated by the various national
radio interface regulations and not in the standards.

The base for the use of the 2400-2483.5 MHz frequency band may be found in
Annex 3 of ERC/REC 70-03.

http://www.erodocdb.dk/Docs/doc98/official/pdf/REC7003e.pdf . This is the
latest, October 2012 version, but the previous February 2011 version
contained the following note: The equipment shall implement an adequate
spectrum sharing mechanism in order to facilitate sharing between the
various technologies and applications covered by this annex 3. 

 

In other words  an adequate spectrum sharing requirement has been needed
for some time.

 

The wording in the OJ has changed (evolved) from, if you like, pointing to
where ways for assessing this requirement could be found, to telling you
where they can be found. It does not say that the Spectrum Sharing
requirements of V1.8.1 must be followed, it says can be found.

 

In my opinion, the note in the OJ referring to V1.8.1 is not mandatory.
Demonstration with requirement could be made through consideration of
sharing requirements already built in though conformity with relevant 802.11
requirements of WiFI or BT standards. But whatever you choose, you should be
prepared to justify it to a Spectrum Authority if required.

 

The manufacturer must fully apply the relevant Harmonised Standard if they
want to apply the CE mark without the use of a Notified Body and the
Spectrum Requirements must also be followed before the device is put into
service.

 

The requirement hasn't actually changed when applying V1.7.1 it's just that
the guidance has been improved as it has been found to be not as clear as it
might have been. Though whether it's completely clear now . . . . J

 

Regards

Charlie

 

 

 

From: Mark Gandler [mailto:markgand...@hotmail.com] 
Sent: 28 November 2012 19:51
To: Charlie Blackham; j...@jmwa.demon.co.uk; emc-pstc@listserv.ieee.org
Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

 

Charlie,

current mandatory version is 1.7.1. Future (2015) is 1.8.1. Both harmonized.


 

There is an application note in question which describes

Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Michael Derby]

I blame too much time between the helmholz coils!!!

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Nick Williams [mailto:nick.willi...@conformance.co.uk] 
Sent: 29 November 2012 21:32
To: Michael Derby
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

 

You would not be alone if you did, Michael...

 

 

 

On 29 Nov 2012, at 20:01, Michael Derby micha...@acbcert.com wrote:





 

 

Honestly, I don't actually hear these voices in my head.

 

 

 


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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Michael Derby]

If he had a kind of high pitched, squeaky voice, yes.

I do recall I did get a headache every time I put the surge generator
through the coils but perhaps that's to be expected.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: don_borow...@selinc.com [mailto:don_borow...@selinc.com] 
Sent: 29 November 2012 22:05
To: Michael Derby
Cc: emc-p...@ieee.org; 'Nick Williams'
Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

So do you hear the voice of Helmholtz?

Donald Borowski
EMC Compliance Engineer
Schweitzer Engineering Labs
Pullman, Washington, USA



From:   Michael Derby micha...@acbcert.com
To: 'Nick Williams' nick.willi...@conformance.co.uk
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Date:   11/29/2012 01:56 PM
Subject:RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment 
requirements
Sent by:emc-p...@ieee.org



I blame too much time between the helmholz coils!!!
 
 
Michael Derby
Regulatory Engineer
ACB Europe
 
From: Nick Williams [mailto:nick.willi...@conformance.co.uk]
Sent: 29 November 2012 21:32
To: Michael Derby
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
 
You would not be alone if you did, Michael...
 
 
 
On 29 Nov 2012, at 20:01, Michael Derby micha...@acbcert.com wrote:


 
 
Honestly, I don?t actually hear these voices in my head.
 
 
 
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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Michael Derby]

Hello all,

A mandatory requirement to have a Medium Access Protocol has existed in EN
300 328 since V1.7.1, which was published in 2006, first introduced onto the
Official Journal sometime soon after that.   (the oldest OJ I have on record
is 2008 and it's on there).

There were a lot of complaints that the section on Medium Access Protocol
was not clear enough and people did not know what it meant.   Or, they knew
what it meant but didn't know how thorough it needed to be.   We knew that
IEEE 802.11 had it and we knew that Bluetooth hopped away from trouble.
Zigbee was listed in the scope of the standard so we all felt happy about
IEEE 802.15.4.   But what about everything else?

Industry called out for a better explanation and more clarification, which
is summarised as the text we are discussing below.
So, it is simply a clarification of an existing requirement.   It's not some
sudden new requirement.

EN 300 328 V1.8.1 makes it even more clear and removes the requirement for
clarifications in the OJ.

As a final comment, yes, there are manufacturers involved in the ETSI group
for EN 300 328. :-) 


Thanks,   Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 27 November 2012 13:25
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

In message
3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.net,
dated Tue, 27 Nov 2012, Charlie Blackham char...@sulisconsultants.com
writes:

The reference has been in public domain for some years, and whilst the 
ETSI website is not always the easiest thing to navigate, draft 
standards are available, free of charge.

Even to non-members? I tried to get a draft document and couldn't.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to
make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Possible Counterfeit EMC Components?

[Michael Derby]

I was chatting with a power supply manufacturer who told me he had worked
hard to design his power supply and get it through all the necessary
regulations.   When complete, he sent the design and instructions out to the
manufacturing company.

After many of them had been made and sold, he realised the components in the
power supply were all cheaper imitations of the components he had instructed
the manufacturer to use.

D'oh.



Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: 30 October 2012 20:42
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Possible Counterfeit EMC Components?

I recently preformed a safety evaluation of a product made in the far east
which contained a suspicious looking rf line filter. Instead of the nice
silkscreened markings showing the company name, numbers and a schematic of
the filter components, it just had a basic printed label. When I removed the
filter and turned it over I found that the case was not soldered but just
spot welded in four spots.

Are line filter companies cutting corners to save money or might this filter
be a counterfeit?

The filter manufacturer's website doesn't show this model filter (anymore?)
but you can buy them from several online electronic component companies.

Has anyone run across counterfeit components and is this something we need
to keep an eye out for? My biggest concern is with safety certified
components which smaller companies like ours have to purchase through
distributors who get them from who knows where.

Is this a real concern or am I just being paranoid?

Thanks,
The Other Brian




LECO Corporation Notice: This communication may contain confidential
information intended for the named recipient(s) only. If you received this
by mistake, please destroy it and notify us of the error. Thank you.

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Re: [PSES] CE+CE ...

[Michael Derby]

In addition to Charlie's words..

Although you may choose to 'carry forward' some of the radio transmitter
test results from the module; you are not actually carrying forward the
equipment authorisation and this does not mean you are any less
responsible for the radio performance of the end product.

The end product supplier is still responsible.
(It's not like FCC or IC modular approval, where the module manufacturer
retains some responsibility).

So, yes, you can carry forward (trust?) the radio test results from the
module if you choose, if you trust them and you think they're applicable to
your application.


Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 12 October 2012 13:19
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE+CE ...

Amund

There's guidance on integrating assessed radio modules into products at
http://www.rtteca.com/TGN01Rev5.pdf 

Basically, you may well be able to carry forward the RF spectrum
compliance of the module, subject to meeting some criteria, but you will
need to assess the finished product for EMC and safety

Regards
Charlie

-Original Message-
From: amund [mailto:am...@westin-emission.no] 
Sent: 12 October 2012 12:24
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] CE+CE ...

Consider a radio system under development (radiomodule, SMPS, hard disk,
main board, etc) All parts in the system are COST (and CE marked) and the
main work is now an engineering job and make some SW. 

When system is functioning and ready for putting it on the marked, the
complete RTTE approval must be carried out, even though that all modules are
CE marked. 

No other outcome, agree?

#Amund

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Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

[Michael Derby]

I confess to a hint of British irony in my e-mail.   J

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Peter Tarver [mailto:ptar...@enphaseenergy.com] 
Sent: 09 August 2012 23:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

 

I've watched BBC News rebroadcast in the US.  One thing BBC absolutely is
not is politically unbiased.

 

Peter Tarver

 

From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Thursday, August 09, 2012 00:45
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

 

Hello,

 

I am enjoying this conversation.

 

It's worth pointing out to the non-BBC watchers that there are no
commercials/adverts on the BBC.   They get their money through the license
fee.

So, basically, we are paying for the privilege/opportunity to watch
television without any commercials or advert breaks.   It's nice for films,
where there isn't an interruption every 20 minutes (unless you need the
toilet, of course).

 

We also have the opportunity to complain about BBC services, since we're
paying for them.   It also helps keep them politically neutral, since they
don't have sponsors to worry about.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 
 
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Re: [PSES] France no longer having restriction on WIFI ?‏

[Michael Derby]

Hello Jasmine,

 

The most official and ‘legal’ document is this one.

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:289:0019:002
0:EN:PDF

It was written in 2009 and shows that the French restriction expires from
1st July 2012.

 

As additional guidance, the European Commission post this page on ‘Class 1’
devices.

http://ec.europa.eu/enterprise/sectors/rtte/files/rtte_subclass_july2012_en.
pdf

You can see sub-class 22 is for WLAN devices.

In June, it said  “2400-2454 MHz”   Now, from July, it says  “2400-2483.5
MHz”

 

I hope this helps,

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: jasmine tan [mailto:jastan...@hotmail.com] 
Sent: 10 August 2012 09:03
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] France no longer having restriction on WIFI ?‏
Importance: High

 

Dear Folks,
I had heard that as of July 1, 2012, France removed the 100 mW indoor use
requirement . Thus the Alert Symbol (!),is no longer required.
Does any one has the officail documents to verify this rumour. Please share
with me,
Thanks in advance.
 
 
Best  Regards,
jasmine

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Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

[Michael Derby]

Thanks Ed,

 

I was thinking back to my days of living in the USA.   Maybe I should have
said  relatively  neutral.J

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: 10 August 2012 13:57
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

 

Michael:

 

The BBC's sponsor is the UK government, so I suppose they still have
somebody looking over their shoulder.

 

Ed Price

El Cajon, CA

USA

 

 

From: Peter Tarver [mailto:ptar...@enphaseenergy.com] 
Sent: Thursday, August 09, 2012 3:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

 

I've watched BBC News rebroadcast in the US.  One thing BBC absolutely is
not is politically unbiased.

 

Peter Tarver

 

From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Thursday, August 09, 2012 00:45
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

 

Hello,

 

We also have the opportunity to complain about BBC services, since we're
paying for them.   It also helps keep them politically neutral, since they
don't have sponsors to worry about.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

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Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

[Michael Derby]

Renewed annually.

I don't recall if a dog license is cheaper if you have a black and white
dog.



Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: 08 August 2012 21:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

Is the TV License a onetime deal or to you have to renew it on an annual
bases like a dog license?


-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John
Woodgate
Sent: Wednesday, August 08, 2012 4:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

In message FCA549BE3ECF9D4CB8CB8576837EA489140853@ZEUS.cetest.local,
dated Wed, 8 Aug 2012, ce-test, qualified testing bv - Gert Gremmen
g.grem...@cetest.nl writes:

If they want people to pay for it than have it scrambled.

That, of course, is possible now, but wasn't in the past. Who will buy
everyone a new TV (or 4 or 5 new TVs) with a descrambler?

The UK want you to pay but do not provide a License, and there is no 
delivery clause either,

Oh, you get a licence. It's the size of two A5 sheets joined at the short
sides and printed in black and a pretty green colour. A bargain at
£145.(;-)
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
Instead of saying that the government is doing too little, too late or too
much, too early, say they've got is exactly right, thus throwing them into
total confusion.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

[Michael Derby]

Hello,

 

I am enjoying this conversation.

 

It's worth pointing out to the non-BBC watchers that there are no
commercials/adverts on the BBC.   They get their money through the license
fee.

So, basically, we are paying for the privilege/opportunity to watch
television without any commercials or advert breaks.   It's nice for films,
where there isn't an interruption every 20 minutes (unless you need the
toilet, of course).

 

We also have the opportunity to complain about BBC services, since we're
paying for them.   It also helps keep them politically neutral, since they
don't have sponsors to worry about.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: 08 August 2012 19:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

 

Subscribing suggest a written consent, and a received license in return, so
a contract.

Receiving BBC is possible without that, so it is stupid to require citizen
to pay for that.

If they want people to pay for it than have it scrambled.

The UK want you to pay but do not provide a License, and there is no
delivery clause either,

It's a one-way benefit system, it's theft. Like making people paying for
books in the store

they never intent to buy nor read.

 

 

Gert gremmen

 

Van: ralph.mcdiar...@schneider-electric.com
[mailto:ralph.mcdiar...@schneider-electric.com] 
Verzonden: woensdag 8 augustus 2012 20:34
Aan: ce-test, qualified testing bv - Gert Gremmen
CC: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

 


I like the idea about the right to receive anything.  However, if you're
watching BBC, then you are in effect subscribing to it, and so I can see the
rationale for a license to receive.  (just as there is a subscription to
satellite radio) 

Some folks also think it's their right to transmit without an license.
Fortunately they are few and far between, but there are some who insist it's
a right, not a privilege to use the radio spectrum.  I've got my license and
I use it sparingly and at lowest power necessary to make a QSO.

___ 

Ralph McDiarmid  |   Schneider Electric   |  Solar Business  |   CANADA  |
Regulatory Compliance Engineering 


From: 

ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl 


To: 

EMC-PSTC@LISTSERV.IEEE.ORG 


Date: 

08/07/2012 11:13 PM 


Subject: 

[PSES] FW: [PSES] EU sets EMC limits for London Olympics

 

  _  




In the Netherlands the right to receive  is very well defended, to the
extent that speed radar detection systems cannot be prohibited.

The right to receive is seen in the same way as the right to speak , which
is not so odd because having the right to speak when no one listens makes no
sense ;)

This is not the same all over Europe, in spite of trying to harmonise
legislaton.

Regards,

Ing.  Gert Gremmen, BSc



g.grem...@cetest.nl
www.cetest.nl

Kiotoweg 363
3047 BG Rotterdam
T 31(0)104152426
F 31(0)104154953

P Before printing, think about the environment. 



-Oorspronkelijk bericht-
Van: emc-p...@ieee.org [ mailto:emc-p...@ieee.org
mailto:emc-p...@ieee.org] Namens John Woodgate
Verzonden: Wednesday, August 08, 2012 6:44 AM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] EU sets EMC limits for London Olympics

In message 006801cd74e6$a5614d90$f023e8b0$@cox.net, dated Tue, 7 Aug 2012,
Ed Price edpr...@cox.net writes:

The British apparently never had the mindset of public ownership of the 
spectrum, so its government had no precedent to keep it from realizing 
yet another revenue stream. John  Chris, do you agree with that?

Yes: the GPO owned the spectrum.
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
Instead of saying that the government is doing too little, too late or too
much, too early, say they've got is exactly right, thus throwing them into
total confusion.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] SAR standards

[Michael Derby]

Hello Bob,

 

It's the basic RF Exposure assessment standards that are harmonised, such as
EN 50360, EN 62479, EN 62311.

 

EN 62209-1 and EN 62209-2 are more like the test procedure standards.

 

For example, EN 62311 is a standard for assessing a device to RF Exposure
requirements.   If you follow EN 62311 through and realise that you need to
do a SAR test, then you will find the requirements match EN 62209-1.   EN
62209-1 and EN 62209-2 would be good test procedure standards to use for SAR
testing to demonstrate compliance.

EN 62311 does list EN 62209-1 as a reference document.

 

I hope this helps,

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Robert Heller [mailto:rehel...@mmm.com] 
Sent: 23 July 2012 12:07
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] SAR standards

 

Are SAR standards (EN 62209-1 for example) harmonized to any Directive for
Europe? I don't see them listed in the standards harmonized to the RTTE
Directive? 

Bob Heller
St. Paul, MN 55107-1208
Tel: 651-778-6336
Fax: 651-778-6252

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Re: [PSES] ANSI C63.4: 2009

[Michael Derby]

Hi,

 

I assume you're asking when they will formally write it into their rules,
rather than when it is acceptable.

 

I can't imagine how long it takes the FCC to change the text of their rules,
but certainly not overnight.

 

Luckily though, the 2009 version is acceptable now.   It's not written in
the rules yet but it is an acceptable standard to use.

 

http://transition.fcc.gov/oet/ea/eameasurements.html

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: itl-emc user group [mailto:itl...@itl.co.il] 
Sent: 15 July 2012 04:48
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] ANSI C63.4: 2009

 

Hello

Does anyone know when the FCC is planning to replace ANSI 63.4: 2003 with
ANSI 63.4: 2009 if at all?

 

Regards,

David Shidlowsky | Technical Writer

Address 1 Bat-Sheva St. POB 87, LOD 71100 Israel

Tel 972-8-9186113 Fax 972-8-9153101

Mail e...@itl.co.i/dav...@itl.co.ill  Web  http://www.itl.co.il
www.itl.co.il

 

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Re: [PSES] Two Notified Body numbers on a product

[Michael Derby]

Notice that although the RTTE Directive does not mention NB number height
directly... the Commission's RTTE Guidance document states (advises?) that
the NB number should be the same height as the CE Mark.

 

I think Charlie's suggestion makes good sense but be warned that an
enthusiastic surveillance authority could ask questions.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 06 June 2012 09:19
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Two Notified Body numbers on a product

 

Amund

 

Yes - put two NB numbers next to the CE mark - this can be done by placing
the two number on top of each other next to the CE mark such that their
total height is same as that of CE mark

 

Regards

Charlie

 

From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 06 June 2012 04:46
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Two Notified Body numbers on a product

 

A product has to fulfill the EU directives RTTE and CPR. Two different
Notified Bodies are involved for the directives.

Are we talking about double NB numbering on the CE label?

 

So far, I have not seen any product with two NB identification numbers ...

 

#Amund

 

 

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Re: [PSES] Compliance costs too much.

[Michael Derby]

I guess to measure the cost of compliance; you certainly need to understand
the cost of non-compliance.

Safety, with regard to reputation, conscience, law suits, sleeping well at
night, jail time, etc.
EMC and Radio, with regard to quality, reputation, harmony within society,
etc.

In the USA, Canada and Europe, I see very real examples of how poor
compliance rates do lead to a tightening in the requirements.
So, you could also consider it an investment.

Just a thought.   :-)

Michael.



Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Richard Nute [mailto:ri...@ieee.org] 
Sent: 30 March 2012 12:24
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Compliance costs too much.

I once worked with an EMC engineer who measured the performance of himself
and his time by the cost of the components that were used in the equipment
solely for the purpose of EMC control.

His objective was to reduce the cost of compliance by advising designers of
careful layout so as to minimize the need for EMC components.

Safety is a bit different because many safety components are also functional
components.
Nevertheless, a ground wire can be eliminated if double-insulation is
employed.  In this example, a cost trade-off between the power cord and the
extra insulation.  But, these days, most primary circuit designs are indeed
double-insulated as transformers simply don't use internal shields.

Enclosures... only needed for primary circuits and secondary circuits
exceeding 30 V.  (Yes, you still want an enclosure, but not for safety!)

Etc.  So, compliance should not cost too much.

I look forward to your comments on compliance costing too much.


Rich
  

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Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity (DOCs)

[Michael Derby]

Yes, I think you're thinking of the RTTE Directive Monrad.

For the RTTE Directive, the lack of a harmonised standard would require a
Notified Body opinion.
For the EMC Directive, the use of a Notified Body is optional.

Remember that if the RTTE Directive applies to your device, then the EMC
Directive does not apply.   You don't apply them both.

Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 12 March 2012 20:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

Monrad

My understanding is that unless the DOC cites the current harmonized 
standards, then a company must go to a notified body to get an 
exception and cite that finding/exception in the DOC

That is not required - the use of a NB is completely voluntary under the EMC
Directive as per Article 7. You can put whatever standards you choose on
your DoC.

Regards
Charlie

-Original Message-
From: Monrad Monsen [mailto:monrad.mon...@oracle.com]
Sent: 12 March 2012 18:44
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

John,
Regarding the question Are you implying that a notified body would freely
support a product not updating to comply with new revisions of the
harmonized standards?, you wrote:
  Yes: It's possible. For example, an update might well require   emission
testing above 1 GHz. If the product clearly has no   possibility of
producing such emissions, since previous tests   have shown no significant
emissions above 100 MHz, it does   not need to be tested. But the
manufacturer can justify that   in his EMC assessment, it is not necessary
to involve a   Notified Body.
The declaration of conformity (DOC) must be signed by the manufacturer using
the harmonized standards.  Your example is inadequate.  Avoiding even
testing the new radiated emissions testing above 1GHz for based on whether
there is significant emissions above 100 MHz is very risky.
In fact, the emissions standard (EN55022:2006+A1:2007) states product must
be tested if the product has a clock/oscillator over 108MHz.  More likely,
the product will be sold also in USA and Canada, so the product is already
tested above 1GHz even if there was a slightly different test methodology.
My e-mail was addressing the case if a hardware change is required to meet
the new requirement.

Are you saying that a manufacturer can justify in his EMC assessment
to avoid having to complying with the new 4dB tighter limits given in the
1-3GHz range and implementing a known hardware change?

My understanding is that unless the DOC cites the current harmonized
standards, then a company must go to a notified body to get an exception and
cite that finding/exception in the DOC.  To do any less would invite some
regulator to take time to investigate your product documentation with a risk
of either stopping a product in customs or demanding a recall of any
products that did get through to customers.

You also state:
  Again, no Notified Body need be involved. Revised standards apply   in
Europe only after a (normally) 3 year transition period. For   some types
of product, that is short compared with the normal   product replacement
cycle, but surely it isn't for ITE. Your   preference is thus often
achievable.
Might be true for laptops, but I normally deal with professional products
like servers and massed storage products that  have a sales life going as
long as  4-8 years with minor updates (drop-in CPU updates or drop-in
replacements with faster disk or tape drives).  Even beyond the period of
new product sales, there is also a market for used product sales that could
bring products to Europe from outside years later.  As you know, the
directives apply to all products (new or used) at the time when it is
placed on the market and/or put into service which impacts used product
sales when it first enters the European market.

By the way, the Europe Commission issued Decision 2010/571/EU on 24 Sep
2010 that announced expiration dates for several RoHS exemptions that were
within a year of the decision.  Fortunately, the more frequently used RoHS
exemptions 7(c)-III and 11(b) expiration dates were given two years notice.
Hence, even your hopeful 3 year transition period is not rigorously
followed by Europe.

Note:  All opinions expressed in this e-mail are my own only and do not
necessarily reflect the opinions of any company I work for or have ever
worked for.   In fact, my opinions may change in the progress of this
discussion.

Monrad

On 3/12/2012 10:18 AM, John Woodgate wrote:
 In message 4f5e1878.2000...@oracle.com, dated Mon, 12 Mar 2012, 
 Monrad Monsen monrad.mon...@oracle.com writes:

 You made a very interesting statement ... especially for someone 
 whose e-mail address indicates that you are in Europe.  You said:
 You have also complicated the issue

Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity (DOCs)

[Michael Derby]

Then it's an RTTE Device.

 

If you have a piece of apparatus that has no radio or telecoms
(wirelessless?), you would normally apply the EMC and Safety Directives.
Then you add a radio device to it and it becomes an RTTE Directive device.

The RTTE Directive includes EMC (article 3.1b) and Safety (article 3.1a)
and states that once you apply the RTTE Directive, you no longer apply the
EMC and Safety Directives.

 

Now, you might say.. But my device is complex and the harmonised standards
I apply are in the EMC OJ and the Safety OJ, not the RTTE OJ!

..well, that's ok, you can use standards from the EMC OJ and the Safety OJ
to demonstrate compliance with articles 3.1b and 3.1a of the RTTE Directive
but that doesn't mean you're applying the EMC or Safety Directives.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 13 March 2012 12:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

 

 Or a laptop (EMC) with a wireless mouse (RTTE)?

 

Presumably there'd be some wireless in the laptop as well J

 

Regards

Charlie

 

From: Robert Heller [mailto:rehel...@mmm.com] 
Sent: 13 March 2012 11:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

 

What if your equipment is multi-functional? Say a passport reader that has a
RFID mode (RTTE) as well as a functional mode to read UV inks or
invisible data (EMC). Or a laptop (EMC) with a wireless mouse (RTTE)? 

Bob Heller
St. Paul, MN 55107-1208
Tel: 651-778-6336
Fax: 651-778-6252
=




From:Michael Derby micha...@acbcert.com 
To:'Charlie Blackham' char...@sulisconsultants.com,
EMC-PSTC@LISTSERV.IEEE.ORG 
Date:03/13/2012 04:33 AM 
Subject:RE: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs) 
Sent by:emc-p...@ieee.org 

  _  




Yes, I think you're thinking of the RTTE Directive Monrad.

For the RTTE Directive, the lack of a harmonised standard would require a
Notified Body opinion.
For the EMC Directive, the use of a Notified Body is optional.

Remember that if the RTTE Directive applies to your device, then the EMC
Directive does not apply.   You don't apply them both.

Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Charlie Blackham [ mailto:char...@sulisconsultants.com
mailto:char...@sulisconsultants.com] 
Sent: 12 March 2012 20:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

Monrad

My understanding is that unless the DOC cites the current harmonized 
standards, then a company must go to a notified body to get an 
exception and cite that finding/exception in the DOC

That is not required - the use of a NB is completely voluntary under the EMC
Directive as per Article 7. You can put whatever standards you choose on
your DoC.

Regards
Charlie

-Original Message-
From: Monrad Monsen [ mailto:monrad.mon...@oracle.com
mailto:monrad.mon...@oracle.com]
Sent: 12 March 2012 18:44
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

John,
Regarding the question Are you implying that a notified body would freely
support a product not updating to comply with new revisions of the
harmonized standards?, you wrote:
 Yes: It's possible. For example, an update might well require   emission
testing above 1 GHz. If the product clearly has no   possibility of
producing such emissions, since previous tests   have shown no significant
emissions above 100 MHz, it does   not need to be tested. But the
manufacturer can justify that   in his EMC assessment, it is not necessary
to involve a   Notified Body.
The declaration of conformity (DOC) must be signed by the manufacturer using
the harmonized standards.  Your example is inadequate.  Avoiding even
testing the new radiated emissions testing above 1GHz for based on whether
there is significant emissions above 100 MHz is very risky.
In fact, the emissions standard (EN55022:2006+A1:2007) states product must
be tested if the product has a clock/oscillator over 108MHz.  More likely,
the product will be sold also in USA and Canada, so the product is already
tested above 1GHz even if there was a slightly different test methodology.
My e-mail was addressing the case if a hardware change is required to meet
the new requirement.

Are you saying that a manufacturer can justify in his EMC assessment
to avoid having to complying with the new 4dB tighter limits given in the
1-3GHz range and implementing a known hardware change?

My understanding is that unless the DOC cites the current harmonized
standards, then a company must go to a notified body to get an exception and
cite that finding/exception in the DOC.  To do any less would

Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)

[Michael Derby]

I think there are two things to consider here.   Firstly, the word 'opinion'
is important, specifically with regard to the fact that it's not
'certification'.   J

 

Secondly, I think it could depend on the circumstances of this apparent
problem.

 

For example, you could easily test to all harmonised standards and pass, yet
still experience an interference problem in the real world.   It's very
possible and has happened on many occasions.

The answer to this is that these harmonised standards give a good
presumption of conformity but never give a guarantee of conformity.

 

Even if you meet all the harmonised standards tests.. If your device causes
a problem in the real world, you'll need to work to fix it.

 

Similarly, if a Notified Body assesses some partial testing of a device,
that too would help give you confidence and assist in your presumptions to
sign your DoC.

However, much like the folks at ETSI and CENELEC, the Notified Body cannot
see into the future and therefore cannot know every eventuality.

 

Now, with the Notified Body aspect, it could come down to their whole
approach to the situation..

 

Let's say that the Notified Body did a good job of assessing the device and
its environment but, just like with the harmonised standard approach,
something unforeseen happens and interference exists.   I think in that case
the Notified Body's opinion may still have been ok; just like you could say
a harmonised standard is assumed to be ok.   However, everyone learned a
lesson and the manufacturer must fix the problem.

 

However, if the Notified Body completely missed something,  or allowed
testing to completely the wrong limits, or forgot to consider the other
devices using the band, or perhaps assessed the transmit parameters but
ignored receiver parameters, etc. etc. etc. and the interference was a
direct result of this omission.   Well, then I suspect the Notified Body
would need to answer to their accreditation body or the commission.

...just like Gert Gremmen said in his reply.

 

If you ask two Notified Bodies for their opinions and they give different
opinions, that's ok, that can happen.   If you decide to sell that device,
you must put both the Notified Body numbers on the product of course.
Again, this is because it's not certification, it's an opinion.   Even if
the Notified Body says no, you can sell the device with their NB number on
it.   If the device has a problem in the real world and a regulator contacts
the Notified Body, the Notified Body can say sure, we gave our opinion, we
said no.

 

 

Some people like the freedom of a DoC system.   Some don't like the
responsibility.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: John Cotman [mailto:john.cot...@conformance.co.uk] 
Sent: 08 March 2012 10:04
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)

 

Notified Body opinion is supposed to be authoritative.

Legally, standards are voluntary, compliance with the Directive is
mandatory.  So, if the NB says it meets the Directive, then you've been told
that you meet the law, and you have good evidence to support due
diligence.  If the NB turn out to be wrong, they should have plenty of
insurance cover in place.

However:

1) Your customers may want to see a test cert with a nice pass to a
standard, and not really like an NB statement.

2) What happens when 2 different NBs come to a different conclusion
about the legal compliance of an item, always fun in court?

 

John C

 

  _  

From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: 08 March 2012 09:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)

 

The NOBO will have a serious problem ;)

 

No without joking, that is possible, especially

if the TCF route chosen was because the device absolutely cannot

meet a standard for physical, or design reasons.

 

If the NOBO overlooked something evident, such as spurious

emission limits without any necessity, they will have a problem

with their accreditations (if they are).

 

For the product it makes no difference, their opinion has been made.

 

But as the manufacturer remains liable for compliance, they better

know what they risk. 

 

 

Regards,

Ing.  Gert Gremmen, BSc

 

 

 

g.grem...@cetest.nl

www.cetest.nl


Kiotoweg 363

3047 BG Rotterdam

T 31(0)104152426
F 31(0)104154953

 

Before printing, think about the environment. 

 

 

Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens Anthony Thomson
Verzonden: Thursday, March 08, 2012 10:31 AM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Notified Body Opinion vs. Harmonised Standards (RTTED)

 

What should happen if a Notified Body has given a positive opinion that a
wireless device complies with the RTTE Directive (Articles 3.1a, 3.1b, 
3.2) based on limited testing results (not to Harmonised Standards

Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)

[Michael Derby]

Hello,

I guess one example might be the (relatively) recent issue with weather radar 
and 5 GHz WLAN devices.   Products were tested and complied with harmonised 
standards.   As it happened, the devices were unable to detect weather radar 
and an interference potential existed.   It's just something that wasn't really 
considered during the writing of the standard and it wasn't expected.
Products met the harmonised standard but did not meet the Directive!
I don't know if any/many products were recalled or asked to switch off but I do 
know that manufacturers needed to find a way to detect and avoid weather radars 
(basically, fix the problem).   Otherwise, if they did not, they could be 
failing to meet the Directive (even though they met the harmonised standard).
Of course, it wasn't long before a new Official Journal was released with notes 
to supplement the harmonised standard and instruct the manufacturer that they 
needed to do more than just meet the standard.

It could happen at any time and the text even leans towards it a little.   If 
you look at the early commission decisions for devices like UWB, they include 
text that really imply things along the lines of  We'll give this a go and 
see.   If there's any interference, we'll re-think it
It helps to get harmonised standards out there and get the technology moving, 
without having to wait until the perfect standard exists.

I think the situation you're leaning towards below is if two devices interfere 
with each other and one is the villain and one is not.   In that instance, I'm 
not saying the 'good guy' would necessarily need to switch off.

That said... imagine a licensed device and an unlicensed device having a battle 
of interference.   (Particularly somewhere like the USA).   One transmitter has 
paid a lot of money for the license and the other has not.   Who do you think 
will get to stay switched on?   :-)

Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Macy [mailto:m...@basicisp.net] 
Sent: 08 March 2012 17:15
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)

--- micha...@acbcert.com wrote:

From: Michael Derby micha...@acbcert.com
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)
Date: Thu, 8 Mar 2012 14:44:30 +

...snip...

Even if you meet all the harmonised standards tests…. If your device causes a 
problem in the real world, you’ll need to work to fix it.

...snip...

Michael,

Would you clarify. 

When does the responsibility for a product's susceptibility fall back onto THAT 
Product's manufacturer?

Especially when the only way to stop bothering the 'poorly made' product is to 
NOT operate your 'well made' product?

Regards,

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Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)

[Michael Derby]

exactly John, hence the 2-part FCC statement on the label of the
unlicensed device.   :-)


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 08 March 2012 17:52
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)

In message 1b7f01ccfd51$64d7e2f0$2e87a8d0$@acbcert.com, dated Thu, 8 Mar
2012, Michael Derby micha...@acbcert.com writes:

That said... imagine a licensed device and an unlicensed device having 
a battle of interference.   (Particularly somewhere like the USA). 
One transmitter has paid a lot of money for the license and the other 
has not.   Who do you think will get to stay switched on? :-)

That isn't arbitrary: unlicensed devices are normally allowed on condition
that they have no redress against legal emissions.
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John
Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK If 'QWERTY' is an
English keyboard, what language is 'WYSIWYG' for?

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Re: [PSES] RTTE compliance test reports

[Michael Derby]

Hello,

 

Not quite Scott, I think what Thomas and Charlie were (correctly) saying,
was..

 

With harmonized and published standard, we do not need to use accredited
laboratory for the test.  

...in fact, regardless of whether you use a harmonised standard or not, the
lab does not need to be accredited.

 

If a laboratory is not accredited, how does a client know if the laboratory
is capable of doing the required tests.

..that's a very good question and it explains why so many accredited labs
(with their extra overheads) are still in business.   You somehow need to
trust your lab.   There's no certification for the RTTE or EMC Directives,
so all the responsibility is on the person signing the DoC.   Good idea to
find a good lab!   That's why people use an accredited lab or one that they
really trust.

 

The capability includes equipment and its calibration, knowledge of standard
interpretation and skill set of actual testing.

.Yes.   You could look at the capability of the lab, how they calibrate
their equipment, chat to them about the standards and the staff, visit their
lab, etc.

 

 

Michael

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 29 February 2012 12:02
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RTTE compliance test reports

 

Hi Thomas,

Thanks for your advice.  With harmonized and published standard, we do not
need to use accredited laboratory for the test.  If a laboratory is not
accredited, how does a client know if the laboratory is capable of doing the
required tests.  The capability includes equipment and its calibration,
knowledge of standard interpretation and skill set of actual testing.

Regards,

Scott


On 29/2/12 6:45 AM, Thomas Cokenias t...@tncokenias.org wrote:

Hi Scott,

Not sure if this answers your question,   but you MUST use a Notified Body
if you test to a standard that has not been harmonized as evidenced by being
published in the Official Journal of the EU.

If you do  test to a standard that is indeed harmonized and published in the
OJ, then you are not required to get a NB expert opinion, and as others have
posted, you do not need to use an accredited test lab for your tests either,
as long as you use test methods called out by the standards and your
equipment and procedures can meet the measurement  uncertainty limits
published therein.  This means you can do tests at your location if you
already have the equipment.

best regards

Tom Cokenias
T.N. Cokenias Consulting
P.O. Box 1086
El Granada CA 94018


On Feb 28, 2012, at 8:07 AM, Scott Xe wrote:

RTTE compliance test reports 

I notice that some compliance reports of RTTE are reviewed by a notified
body while some are issued by an accredited laboratory only.  Can someone
advise if they have different purposes or requirements.

Thanks and regards,

Scott

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Attachments

Re: [PSES] GPS Receivers

[Michael Derby]

Hello Steve,

 

It's not a broadcast receiver and therefore the RTTE Directive does apply.

 

I've seen people use all sorts of standards in the past but the basic
requirement is really going to be to check the receiver emissions (article
3.2 of the Directive) and also check it has good EMC performance (article
3.1b of the Directive).   Of course, safety too (article 3.1a)

 

Most people recommend use of simply EN 300 440 (assuming it's a 1.5 GHz
device) and then do the EMC testing to EN 301 489-3.   (I'm not sure if
Space is really 'short range' but the tests will do)

 

At the RTTECA (RTTE Notified Body group) we wrote the following guidance..

http://rtteca.com/TGN16.pdf

I hope it's useful.

 

For the EN 300 440 tests, most people just test the radiated emissions of
the receiver.   (For example, the sat-nav in a car or on a phone).

The only other thing to note is that if you happen to claim your GPS
receiver is part of a critical lifesaving system that relies on the GPS
working, then you could start considering it to be a different Class of
receiver within EN 300 440.

 

As a receive only device, it's Class 1.   (No Alert Symbol. unless of course
there's a Class 2 transmitter in with it)

 

As for multi-radio equipment.. It's likely that the GPS will be on during
tests of other features, so you may be able to save time and effort by
monitoring/exercising both.

 

I hope this helps,

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Steve O'Steen [mailto:steve.ost...@acstestlab.com] 
Sent: 28 February 2012 14:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] GPS Receivers

 

All,

 

I would be interested in all opinions regarding the compliance requirements
for a GPS receiver.  Annex I, Item 4 excludes all sound and TV broadcast
receivers from the RTTE Directive.

 

 

Assuming the RTTE Directive applies, which one of the Product Specific
Standards would be most applicable?  

 

If the GPS receiver were part of a multi-radio equipment, would that affect
the selection of the Product Specific Standard focused on the GPS?

 

Are there other exclusions to the RTTE Directive I'm not aware of that
would default GPS to the EMC Directive or at least to the EN55022/E55024,
which is harmonized in the RTTE Directive as well?

 

Best regards, 

 

 

Steve O'Steen

EMC Director

Advanced Compliance Solutions, Inc.

sost...@acstestlab.com

770-831-8048 ext. 210

www.acstestlab.com http://www.acstestlab.com/ 

 

ATLANTA, GA   -   MELBOURNE, FL   -   BOCA RATON, FL

 

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Re: [PSES] GPS Receivers

[Michael Derby]

Hi Steve,

 

If it's a GPS Receiver that is also located with (for example) a Bluetooth
transmitter, then you could still assess the Bluetooth transmitter to EN 300
328 and EN 301 489-17, then the GPS receiver to EN 300 440 and EN 301 489-3.

 

The comment in TGN 16 comes from the type of GPS equipment which also has a
satellite transmitter included.   In such a case, you might consider using
something like EN 300 441 and EN 401 489-19.

 

I hope that makes sense?

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Steve O'Steen [mailto:steve.ost...@acstestlab.com] 
Sent: 28 February 2012 16:04
To: Michael Derby; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] GPS Receivers

 

Michael,

 

After reviewing the TGN16 a little closer, I noticed the statement below:

 

This Guidance applies to receive-only equipment.  Where GPS/GNSS or other 

receivers are combined with other radio equipment, different principles may
apply.

 

So, back to my question regarding multi-radio devices, is there another
guide to address that equipment or could TGN16 still be applied?

 

Best regards,

 

Steve O'Steen

EMC Director

Advanced Compliance Solutions, Inc.

sost...@acstestlab.com

770-831-8048 ext. 210

www.acstestlab.com http://www.acstestlab.com/ 

 

ATLANTA, GA   -   MELBOURNE, FL   -   BOCA RATON, FL

 

CONFIDENTIAL  

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From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Tuesday, February 28, 2012 10:15 AM
To: Steve O'Steen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] GPS Receivers

 

Hello Steve,

 

It's not a broadcast receiver and therefore the RTTE Directive does apply.

 

I've seen people use all sorts of standards in the past but the basic
requirement is really going to be to check the receiver emissions (article
3.2 of the Directive) and also check it has good EMC performance (article
3.1b of the Directive).   Of course, safety too (article 3.1a)

 

Most people recommend use of simply EN 300 440 (assuming it's a 1.5 GHz
device) and then do the EMC testing to EN 301 489-3.   (I'm not sure if
Space is really 'short range' but the tests will do)

 

At the RTTECA (RTTE Notified Body group) we wrote the following guidance..

http://rtteca.com/TGN16.pdf

I hope it's useful.

 

For the EN 300 440 tests, most people just test the radiated emissions of
the receiver.   (For example, the sat-nav in a car or on a phone).

The only other thing to note is that if you happen to claim your GPS
receiver is part of a critical lifesaving system that relies on the GPS
working, then you could start considering it to be a different Class of
receiver within EN 300 440.

 

As a receive only device, it's Class 1.   (No Alert Symbol. unless of course
there's a Class 2 transmitter in with it)

 

As for multi-radio equipment.. It's likely that the GPS will be on during
tests of other features, so you may be able to save time and effort by
monitoring/exercising both.

 

I hope this helps,

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Steve O'Steen [mailto:steve.ost...@acstestlab.com] 
Sent: 28 February 2012 14:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] GPS Receivers

 

All,

 

I would be interested in all opinions regarding the compliance requirements
for a GPS receiver.  Annex I, Item 4 excludes all sound and TV broadcast
receivers from the RTTE Directive.

 

 

Assuming the RTTE Directive applies, which one of the Product Specific
Standards would be most applicable?  

 

If the GPS receiver were part of a multi-radio equipment, would that affect
the selection of the Product Specific Standard focused on the GPS?

 

Are there other exclusions to the RTTE Directive I'm not aware of that
would default GPS to the EMC Directive or at least to the EN55022/E55024,
which is harmonized in the RTTE Directive as well?

 

Best regards, 

 

 

Steve O'Steen

EMC Director

Advanced Compliance Solutions, Inc.

sost...@acstestlab.com

770-831-8048 ext. 210

www.acstestlab.com http://www.acstestlab.com/ 

 

ATLANTA, GA   -   MELBOURNE, FL   -   BOCA RATON, FL

 

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responsible for delivering

Re: [PSES] RTTE compliance test reports

[Michael Derby]

If the tests are all done to a harmonised standard (standard fully applied,
and passes), then there's no need to go to a Notified Body.

(You can, if you wish to, but there's no need to)

 

If you can't or don't fully apply a harmonised standard, then you must go to
a Notified Body for their opinion.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 28 February 2012 16:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RTTE compliance test reports

 

I notice that some compliance reports of RTTE are reviewed by a notified
body while some are issued by an accredited laboratory only.  Can someone
advise if they have different purposes or requirements.

Thanks and regards,

Scott

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Re: [PSES] RTTE compliance test reports

[Michael Derby]

Hello Amund.

 

No, there's no requirement for a Notified Body to be associated with a test
laboratory.

 

Presently, there's no requirement for a Notified Body to be accredited under
the RTTE Directive.. Although each nation typically does have an
accreditation requirement before submitting Notified Body applications to
the European Commission.   I hope that makes sense.

For example, a company in the USA wishing to act as a Notified Body would
have to apply through NIST, who would then assess their ability to do it
through accreditation etc., even though the Directive does not mandate it.

 

Under the NLF re-cast, this will change and I suspect the accreditation for
a Notified Body would be to something like Guide 65.

 

The RTTE Directive is due to be included in the NLF changes but it's not
being grouped in the 'omnibus re-cast list' of Directives because the RTTE
Directive is also actually being re-written for technical changes.

 

Directives like the EMC Directive are just being 're-cast' for the NLF and
should therefore not include any technical changes; whereas the RTTE
Directive is actually being re-written and will certainly contain some
technical and administrative changes.

 

I'm sure I'll get corrected on some of my political terminology details here
but I hope the general idea makes sense.

 

Michael.

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 28 February 2012 17:11
To: Michael Derby; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: SV: [PSES] RTTE compliance test reports

 

My input on this issue:

 

. Notified Body = Appointed by authorities for testing /
certification according to an EU directive

. Accredited laboratory = Fulfil ISO/IEC 17025 Laboratory
Accreditation (criteria for laboratories to demonstrate the technical
competence to carry out specific test methods)

 

I assume that a Notified body must also be an Accredited laboratory, but not
visa versa.

 

Best regards

Amund

 

 

Fra: Michael Derby [mailto:micha...@acbcert.com] 
Sendt: 28. februar 2012 17:27
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] RTTE compliance test reports

 

If the tests are all done to a harmonised standard (standard fully applied,
and passes), then there's no need to go to a Notified Body.

(You can, if you wish to, but there's no need to)

 

If you can't or don't fully apply a harmonised standard, then you must go to
a Notified Body for their opinion.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 28 February 2012 16:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RTTE compliance test reports

 

I notice that some compliance reports of RTTE are reviewed by a notified
body while some are issued by an accredited laboratory only.  Can someone
advise if they have different purposes or requirements.

Thanks and regards,

Scott

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Re: [PSES] Is this common knowledge - Electrical Ratings

[Michael Derby]

Labelling is an interesting topic, though also a source of great frustration
it seems.   In response to a couple of the comments below..


 As a consumer, why do I need to know the meaning of EMC and Radio
markings?
 As a consumer, I only need to know efficiency ratings at the time I
choose the appliance/equipment.

I wonder how many people understand the Alert Symbol (!) of the RTTE
Directive.   When you see the Alert Symbol on your radio product (such as on
most mobile phones, wireless internet, UWB devices, etc.), it is often there
to alert the user that there is a restriction of use for the product.
The user then knows (???) to go to the user manual and read the restrictions
of their device before they power it on.
.right?   :-)


 Such ratings need not be a permanent part of the equipment, but can be
on a disposable tag.  There is no post-purchase need for such data.

One word. e-bay
:-)
Do we all buy our products new, from the original supplier?


Just to stir the pot,

Michael.



Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Richard Nute [mailto:ri...@ieee.org] 
Sent: 28 January 2012 20:39
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is this common knowledge - Electrical Ratings

Hi Peter:


 I believe rating markings, energy efficiency ratings, EMC and Radio 
 markings should be harmonized worldwide and governments/regulators 
 should be involved to train consumers the meaning these markings.

As a consumer, why do I need to know the meaning of EMC and Radio markings?

As a consumer, I only need to know efficiency ratings at the time I choose
the appliance/equipment.
Such ratings need not be a permanent part of the equipment, but can be on a
disposable tag.  There is no post-purchase need for such data.

As a consumer, I simply plug the equipment into the wall outlet.  The
equipment is pre-configured for voltage and is provided with the proper plug
for my house.  I don't need to know voltage, current, watts, or frequency
ratings of the equipment.

If a house circuit-breaker trips when I turn on my equipment, I may need to
know the current or power rating of my equipment in order to balance the
load on the circuit.

So, who are the rating markings for?  The certifiers and regulators.  The
ratings could just as well be in the accompanying documents.


Best regards,
Rich
;-)

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Re: [PSES] FCC requirements for Inductive Chargers

[Michael Derby]

Hello,

Please note that not all of these wireless chargers would be Part 15
(47CFR15, as stated).   Some might be Part 18, depending on the operation.

I think you'd need to look at the operation of the charger and see if any
form of 'handshaking' is taking place; even if it's just a recognition
signal.
If it is, you could say that's data or communication and Part 15 could
apply.
If not, this could be a Part 18 device.

It's a little like the European debate of  Does the EMC Directive or RTTE
Directive apply?
You need to ask yourself if it is just using RF for a process, or if there
is some form of communication taking place.


Thanks,   Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Brian Oconnell [mailto:oconne...@tamuracorp.com] 
Sent: 25 January 2012 19:03
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC requirements for Inductive Chargers

ICNIRP
29CFR1926
29CFR1910
ANSI C95.x
47CFR15
CISPR 11,12,14,22

When human exposure mentioned, I think about Star Trek's 'subnucleonic
radiation' - will CISPR32 address these limits?

Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Moshe Henig
Sent: Wednesday, January 25, 2012 10:19 AM
To: emc-pstc-requ...@listserv.ieee.org; emc-p...@ieee.org;
EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: FCC requirements for Inductive Chargers

Thanks group,
But what are the FCC requirements for wireless chargers that does not comply
with WPC?
Thanks
Moshe

2012/1/23 Moshe Henig moshe.he...@gmail.com

Dear Group,

What are FCC requirements for Mobile Phone Battery Inductive Charger and
what are the conditions?

Thanks

Moshe Henig Dipl. Ing.
NCE SMIEEE
iNarte Certified EMC engineer
EMC and Safety consultant
Mobile +972 52 8951449
Skype mhenig
he...@bezeqint.net

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Re: [PSES] FCC requirements for Inductive Chargers

[Michael Derby]

 

This makes me realise how boring my reply was.

 

I'm sorry.

 

I'll try harder next time.

 

 

I don't want to be one of those guys in the red shirt who only turns up for
one episode and you know he's going to get killed.

 

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Bob Richards [mailto:b...@toprudder.com] 
Sent: 25 January 2012 19:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC requirements for Inductive Chargers

 


Is that the same gallium alloy used in the turbo entabulator? ;-)



--- On Wed, 1/25/12, John Woodgate j...@jmwa.demon.co.uk wrote:


From: John Woodgate j...@jmwa.demon.co.uk
Subject: Re: FCC requirements for Inductive Chargers
To: EMC-PSTC@LISTSERV.IEEE.ORG
Date: Wednesday, January 25, 2012, 2:18 PM

In message b4c40db49fd3404c80870094ce1b0...@tamuracorp.com
http://us.mc1616.mail.yahoo.com/mc/compose?to=B4C40DB49FD3404C80870094CE1B0
e...@tamuracorp.com , dated Wed, 25 Jan 2012, Brian Oconnell
oconne...@tamuracorp.com
http://us.mc1616.mail.yahoo.com/mc/compose?to=oconne...@tamuracorp.com 
writes:

 When human exposure mentioned, I think about Star Trek's 'subnucleonic
radiation' - will CISPR32 address these limits?

Yes, in the 6th edition, published in 2042. I've already commissioned a
supply of gallium foil helmets to screen against the Higgs field.
-- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
Some people who are peeling the finch of the financial crisis are thinking
of
biting a rook.

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Re: [PSES] RTTE - Alert Calss 2 identifier

[Michael Derby]

Hello,

 

I'm not aware of any requirement for it to be on the DoC.   Just the
equipment, the packaging and the user manual.

 

I find this labelling guidance document very useful:

 

http://ec.europa.eu/enterprise/sectors/rtte/files/guidance/guidance_en.pdf

 

 

Michael.

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 17 January 2012 09:12
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RTTE - Alert Calss 2 identifier

 

For Class 2 RTTE equipment, the Alert symbol shall be affixed to the
equipment as part of the CE marking.

 

I can't find any requirements that the Alert symbol should be included in
the Declaration of Conformity document.

Shall it be included in the DoC or not?

Best regards

Amund  

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Re: [PSES] Radiated Emissions Testing of Intentional Radiators - Practicalities?

[Michael Derby]

Hi James,

 

You can try putting the support access point down on the floor, outside the
beam of your site's measurement antenna.   Covering it with a little spare
anechoic material helps too.

 

If you're just worried about the main fundamental signal (2.4 GHz, etc.)
from your support access point, you can ensure the antenna from it is not in
line with your site's measuring antenna.   If possible, you could even
remove the support access point's regular (omni) antenna and fit a more
directional horn to it.   This would allow you to point the support access
point's antenna at your 'EUT' and not at your site's receiving antenna.

 

If you're worried about the general broader emissions from your supporting
access point, and if the floor location with anechoic tent isn't helping,
maybe you could locate it outside your chamber and have an RF cable through
a waveguide to the supporting access point antenna.

 

I hope this helps a little.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Pawson, James [mailto:james.paw...@echostar.com] 
Sent: 10 January 2012 16:13
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Radiated Emissions Testing of Intentional Radiators -
Practicalities?

 

 

Hello list members,

 

We are wanting to test one of our products, which contains a WiFi interface,
in our anechoic chamber. To ensure the WiFi is active we would need to set
up antennae in the anechoic chamber itself - the irony of introducing radio
into a radio-quiet environment is not lost on me.

 

I'm concerned about separating out the emissions from the WiFi access point
and the emissions of the equipment under test. Does anyone have any
practical pointers / hints / tips / experience / pitfalls of doing this?

 

Thanks in advance

James

 

James Pawson

Leading Hardware Engineer - EMC

EchoStar Europe

 

 

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Re: [PSES] Experts and Wisdom

[Michael Derby]

It’s an old one but it still makes me smile…….   Regarding the difference 
between wisdom and knowledge…….

 

 

Knowledge is knowing that a tomato is a fruit.

Wisdom is knowing not to put it in a fruit salad.

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Pettit, Ghery
Sent: 03 January 2012 20:57
To: McInturff, Gary; 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: RE: Experts and Wisdom

 

Could well have been.

 

Ghery S. Pettit

 

From: McInturff, Gary [mailto:gary.mcintu...@esterline.com] 
Sent: Tuesday, January 03, 2012 12:57 PM
To: Pettit, Ghery; 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: RE: Experts and Wisdom

 

Probably right after the battle of Gettysburg

 

Gary

 

From: Pettit, Ghery [mailto:ghery.pet...@intel.com] 
Sent: Tuesday, January 03, 2012 12:23 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Experts and Wisdom

 

“Judgment comes from experience.  Experience comes from poor judgment.”   
Robert E. Lee

 

Ghery S. Pettit

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Doug Powell
Sent: Tuesday, January 03, 2012 10:44 AM
To: EMC-PSTC
Subject: Experts and Wisdom

 

 

 

All,

 

With some folks retiring and others I know are changing careers (recently 
termed “retooling”), I had some pensive thoughts about losing many folks who 
are experts in the field or those with great wisdom.  So it occurs to me, I 
would like to hear your favorite quotes on Wisdom and Experts.  I’ll prime the 
pump with a few I know.

*   Wisdom is the “stuff” you get immediately after you need it most. 
*   An expert is one who has already made all of the necessary mistakes. 
*   ex·pert/ˈekspərt/  Noun: compound word  “ex + spurt”.  EX meaning “has 
been”, SPURT meaning a “drip under pressure”, therefore a “Has been drip under 
pressure!”

thanks, –doug  

Douglas E Powell

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

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