Re: [PSES] Fwd: Re: [PSES] Lasers

[Regan Arndt]

Hello all,

The manufacturer of the end-use product must ALSO submit an application to
the CDRH (as a LASER PRODUCT) when they are incorporating an existing OEM
laser or laser system that has a CDRH accession # associated with it.
This manufacturer will then get a different accession # on this new
submittal & must also do an annual report submission.

You can obtain a guidance document directly from the CDRH at:
https://www.fda.gov/radiation-emitting-products/home-business-and-entertainment-products/laser-products-and-instruments

One of the definitions that are basic to the regulations are:
A LASER PRODUCT is any device that constitutes, incorporates, or is
intended to incorporate a laser or laser system [CFR 1040.10 (b) (21)]

The accession # that is given to the manufacturer of the LASER PRODUCT
system is merely just a tracking # (not a CDRH approval) for the end
product model it is being sold into the USA.

Hope that helps.
Regan Arndt

On Tue, Jun 18, 2024 at 2:47 PM Jim Bacher, WB8VSU 
wrote:

> Steve, both. The client has to file a yearly report as well. The client
> just refers to the OEMs FDA Accession number along with detailing labeling,
> manuals, etc.
>
>
> Jim Bacher, WB8VSU
> j.bac...@ieee.org or ja.bac...@outlook.com
> JBRC Consulting LLC
> Product EMC & Regulatory Consultant
> https://trc.guru/ email:j...@trc.guru
> IEEE Life Senior Member
>
>
> On June 18, 2024 5:39:08 PM sgbrody  wrote:
>
>> I have a client with a product that has a 3rd party Class 3B laser
>> embedded.
>>
>> Who needs an FDA Accession number - laser manufacturer or my client as an
>> end product containing an embedded laser?
>>
>> Thanks,
>>
>>
> --
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[PSES] Seeking volunteers to join the IEEE PSES RATC (Risk Assessment Technical Committee)

[Regan Arndt]

Greetings fellow members,


I am looking for any volunteers to join the IEEE PSES Risk Assessment
Technical Committee.

It would only take a few hours of your valuable time out of every month at
most.


One of the main functions of this Technical Committee is to promote
activities in our field and provide expert knowledge and assistance to:

-  Receive, generate, and review papers within our scope in cooperation
with the Transactions Editor and/or the Technical Papers Committee.

-  Organize and operate sessions at meetings of the IEEE at all levels and
at meetings of other organizations with which the Society is desirous of
cooperating, in accordance with the rules in effect at such   meetings.

-  Arrange through appropriate editors for publishing pertinent papers in
IEEE publications.

-  Evaluate "state of the art" in the area of Risk assessment.



The operation of each Technical Committee shall have at least one annual
meeting to formulate a report to be presented to the IEEE PSES Board of
Governors indicating the status of committee work.



In addition, if you are interested in becoming a speaker on a Risk
Assessment topic for next year’s IEEE ISPCE in Chicago, please let me know
as this would also be a great opportunity to us to meet in person and
develop a technical program for future IEEE ISPCE events and to meet with
the Board of Governors.

https://2024.psessymposium.org/


Please email me at regan.ar...@ieee.org or reganar...@gmail.com if you are
interested in joining.


Thank you in advance.

Regan Arndt

IEEE PSES RATC Chair

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[PSES] AI & Regulatory Compliance

[Regan Arndt]

Greetings fellow members,

Our industry will not be immune to this new era of AI technology and want
to bring up this topic again to obtain some more insight from the forum
into:

*"How do you think AI will play a future role in our Regulatory compliance
world?"*


I can see some real benefits to this when applying it to a risk assessment,
EMC redesign including change out of critical components, & possibly to
help support engineering judgments in lieu of testing (i.e. temperature
modeling), etc.…though I think we would have to include the usage of AI as
one of the potential risks in the risk assessment. lol

UL touched base on this topic during their UL Innovations summit held in
Fremont, CA yesterday.

I know there is the ISO/IEC DTR 5469 in development, but this appears, I
believe, to only address functional safety of the AI systems in question,
and not addressing AI in normal compliance assessments for products under
the category of laboratory, IT, audio, etc.

Also, is there someone out there that will be speaking to this during the
2024 ISPCE in Chicago next May? Perhaps there should be an IEEE PSES
technical committee created for this?

Side note: Nordcloud puts out a good summary blog on this:
https://nordcloud.com/blog/how-ai-can-help-you-obtain-regulatory-compliance/

There are other AI blogs out there in the ether but more tuned for the
financial sector and other industries….

Looking forward to the discussion.



P.S.

I am now the Chair for the IEEE PSES Risk assessment technical committee
and am looking for any volunteers to join our group. This topic will be one
to discuss soon within our group. Please email me at regan.ar...@ieee.org
or reganar...@gmail.com if you are interested in joining.

Cheers!

Regan Arndt

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[PSES] Looking for a Product Safety Engineer? - Here's your chance....

[Regan Arndt]

Dear fellow members,

Our PSES Santa Clara Valley Chapter is putting on a Virtual Networking
session on Wednesday, Oct. 13th @ 7 p.m. PDT.

One of the highlights in this session will be a panel of HR personnel &
Hiring managers from reputable companies to describe their product safety
needs and to advertise their open Product Safety Engineer positions.

If you or anyone in your company is looking for a Product Safety engineer
and would like to be part of this panel, please let John McBain or myself
know as soon as you can by replying to the email addresses below. Up to 5
panel members will spend ~5 minutes each making a presentation followed by
a few minutes of Q&A.

We have almost 50 members in our local Chapter, but our mailing list for
this event reaches over 500 guests, so you may get a good amount of
visibility and interest if you choose to participate. First come, first
served!

We look forward to hearing from you if you are interested.



Regan Arndt

IEEE PSES SCV Chapter Chair

regan.ar...@ieee.org



John McBain

IEEE PSES SCV Chapter Secretary

johnmcb...@ieee.org

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Re: [PSES] Job Opening: Clarion Safety Systems

[Regan Arndt]

Thanks Doug. I imagine they will not get many prospects because it mentions
the pay is $0.00/hr.lol

On Thu, Nov 19, 2020, 9:21 AM Doug Nix  wrote:

> Colleagues,
>
> I recently learned that Clarion Safety Systems is looking to fill the
> following position. I have nothing to do with the search, so please contact
> the Clarion contact shown below.
>
> Inquiries from interested parties should be sent to: Cherie (
> cgorm...@clarionsafety.com).
>
> *Director of Safety Assessment and Standards Leadership*
> Clarion Safety Systems, LLC
> Milford, PA 18337•Temporarily remote
>
> Qualifications
>
>- Bachelor's (Preferred)
>
>
> Full Job Description
>
> This position is responsible for taking the lead role in risk assessment
> consultations, proposals and engagements carried out under the auspices of
> Clarion Safety Systems. This team member will be responsible for
> recruiting, on-boarding and managing both internal and external
> professionals in the practice of risk assessment. In addition, this team
> member will network with other individuals and organizations to advance
> both Clarion’s and the client’s strategic objectives related to reducing
> risk and protecting people.
>
> *OVERALL RESPONSIBILITIES INCLUDE: *
>
>- Management of Clarion’s client risk assessment process from initial
>analysis through to corrective action recommendations.
>
>
>- The monitoring of standards development activities in this field in
>order to offer expert guidance to customers and write expertise-driven
>change proposals when standards are revised.
>
>
>- Membership and participation on one or more standards committees
>relevant to machine safety and risk assessment.
>
>
>- Interpretation of relevant standards to provide guidance to
>Clarion’s product development team to best meet client and industry needs.
>
>
>- Development of alliances with a variety of strategic stakeholders
>including industry trade groups and associations (e.g., ASSP, UL, NEMA,
>AEM) to reinforce Clarion’s expertise-driven leadership and build Clarion’s
>business.
>
>
>- Contributing to Clarion’s corporate strategy development.
>
> *ESSENTIAL QUALIFICATIONS: *
>
> To perform this position successfully, this individual must demonstrate
> the following:
>
>- Bachelor's degree in a relevant engineering discipline or equivalent
>applicable work experience. Master's degree desirable.
>
>
>- 5+ years of relevant work experience performing machinery risk
>assessments.
>
>
>- Extensive knowledge of A, B and C level machine safety standards
>(e.g., ANSI, ISO, IEC, UL, NFPA, OSHA, EN).
>
>
>- Experience with CE compliance.
>
>
>- The ability to interface with client engineers, analyze their
>drawings and reports, and effectively communicate recommendations.
>
>
>- A “customer-centric” understanding of business drivers related to
>machinery manufacturers and standards compliance (e.g., export market
>requirements, domestic liability reduction).
>
>
>- Excellent written, verbal and presentation skills.
>
>
>- The ability to comfortably interface with internal colleagues and
>external parties.
>
>
>- Strategic/creative thinking, negotiating and diplomacy skills.
>
>
>- Extremely well organized, capable of prioritizing, and ability to
>simultaneously manage multiple tasks.
>
>
>- Documented “credentials” such as relevant certification(s) by a
>recognized third-party authority a decided plus (e.g. TUV Rheinland, or
>similar entity).
>
>
>- Fluency in Microsoft Office programs.
>
>
>- Considerable travel may be required.
>
> Job Type: Full-time
>
> Pay: $0.00 per hour
>
> Benefits:
>
>- 401(k)
>- Dental insurance
>- Disability insurance
>- Flexible spending account
>- Health insurance
>- Life insurance
>- Paid time off
>- Vision insurance
>
> Schedule:
>
>- 8 hour shift
>
> Education:
>
>- Bachelor's (Preferred)
>
> Experience:
>
>- Machinery Risk: 5 years (Preferred)
>
> This Company Describes Its Culture as:
>
>- Detail-oriented -- quality and precision-focused
>- Outcome-oriented -- results-focused with strong performance culture
>- Team-oriented -- cooperative and collaborative
>
> Company's website:
>
>- www.clarionsafety.com
>
> Work Remotely:
>
>- Yes, temporarily due to COVID-19
>
>
>
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
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>
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> well-used formats), large files, etc.
>
> Website: http://www.ieee

Re: [PSES] Follow-Up Questions October IEEE PSES Virtual Chapter - OSHA NRTL

[Regan Arndt]

Thanks Kevin. Excellent webinar and great discussions.  Thank you again.
Can you please share your slides?
Also, I have not received the IEEE email yet for the recorded download, but
do you have a link to that yet?

Regan

On Tue, Oct 20, 2020 at 4:10 PM Kevin Robinson 
wrote:

> *Last week I had the honor of presenting to the IEEE PSES Virtual Chapter
> where I discussed OSHA's Nationally Recognized Testing Laboratory (NRTL)
> Program.  There were a number of questions that were asked that I was
> unable to get to, so I wanted to share the questions and answers below.*
>
>
> *A note - As I am posting this from my personal account and these answers
> have not been reviewed by OSHA Legal Counsel or agency leadership, these
> answers reflect my own personal opinion and do not necessarily reflect
> the opinion of OSHA.  For more official responses to these or any
> questions, please contact me at robinson.ke...@dol.gov
>  *
>
>
> *QUESTION:*
>
> This is a very good topic as our European colleagues understand CE marking
> but get confused with NRTL requirements.  Does OSHA feel CE is not enough
> and that the additional NRTL requirements are mandatory for the USA.  Any
> plans to harmonize with the EU on CE?
>
>
>
> *ANSWER:*
>
> OSHA Explored this in 2008 in the form of a Request for Information.  You
> can view the original request and comments from the public at:
> https://beta.regulations.gov/docket/OSHA-2008-0032/document
>
> OSHA’s final decision on this matter can be found at:
> https://beta.regulations.gov/document/OSHA-2008-0032-0099
>
>
>
> *QUESTION:*
>
> How does OSHA ensure competency to the older (non-IEC) UL standards
> overseas? For example, there was a lawsuit against [a NRTL] that they lost,
> where the expertise for the standards were present in the US, but not by
> those overseas that were actually doing the work. We have seen subpar work
> coming from overseas often. Does OSHA consider the current system
> sufficient in this regard to oversee these overseas efforts? How does OSHA
> determine competency when it is not using the standards itself and doesn't
> evaluate products?
>
>
>
> *ANSWER:*
>
> OSHA conducts regular assessments of NRTL locations around the world and
> as we increase staffing, we are increasing the number of assessments we do
> every year.  In addition, we regularly review complaints that come into the
> NRTL Program office as well as complaints and incidents that may be
> received by the NRTL.  If OSHA notes a deficiency during an assessment, the
> NRTL is given an opportunity to correct the deficiency.  In the rare
> instance that a NRTL is unable to adequately address the deficiency OSHA
> will take the necessary corrective action up to and including reduction in
> the NRTL’s scope of recognition to remove the sites(s) that present a
> problem or full revocation of NRTL recognition.  Thankfully this is very
> rare.
>
>
>
> *QUESTION:*
>
> What are the occupational safety provisions of the NEC? E.g., is it the
> whole document or just certain sections. If the latter, which ones?
>
>
>
> *ANSWER:*
>
> OSHA Regulations largely refer to NFPA 70E which applies directly to the
> workplace.  That said, many of the test standards recognized under the NRTL
> Program reference the NEC (NFPA 70) and as the NEC addresses electrical
> equipment and installations in the workplace it would apply.  Local AHJs
> largely enforce the NEC.
>
>
>
> *QUESTION:*
>
> There appears to be a misunderstanding by many that NRTL approval only
> applies to to AC powered equipment (110V). It applies to DC & low voltage
> AC as well, correct?
>
> *ANSWER:*
>
> OSHA regulations, specifically Subpart S of the Occupational Safety and
> Health Act https://www.osha.gov/laws-regs/regulations/standardnumber/1910
> applies to “Utilization Equipment”
> https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.302
> .  Utilization Equipment is defined as “Equipment that utilizes electric
> energy for electronic, electromechanical, chemical, heating, lighting, or
> similar purposes.”
> https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.399
> .  This is a very broad definition which does not limit the equipment based
> on voltage, current draw, or type of power source.
>
>
>
> *QUESTION:*
>
> For UL traditionally, the word Listed and unique mark relative to UL
> Recognition for components has been used. Local ordinances will often
> specify Listing (not certifications or approvals). Most NRTLs have the same
> marks for components and end products, without specifying Listing; does
> OSHA consider this acceptable? Also, native European certification bodies
> use certificates as the basis of certification, and the mark is not
> required to be on the product, but are still considered approved. It seems
> the presence of the Mark on the product, which has been the US way over the
> years has been changing with infusion of other NRTLs. Is the Mark on the
> product required to prove the produ

[PSES] High voltage versus High tension

[Regan Arndt]

Hi folks,

I never encountered this before but am curious if anyone had any problems
in using the European verbiage ‘High Tension’ in lieu of ‘High voltage’
during their 61010 assessment on their labels and documentation.

Unless I am mistaken on the Group & National differences, IEC 61010-1 does
not mention anything specific on allowing this alternative language.

I also want to know if ‘High tension’ would be a problem in the USA and
Canada during a Field evaluation or NRTL certification? (I only ask to
avoid having 2 labels/wording on a global product)

Thanks for sharing any experiences you had.


Regan Arndt

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[PSES] EMO versus EMS

[Regan Arndt]

Greetings everyone. Hope all is well and you are safe during these times.

Does anyone have a good article, whitepaper or anything that talks about
EMO and EMS (differences, etc.) other than what is in NFPA 79?
Specifically looking for a design guidance document of sort. Not much out
there on Google.

Thanks in advance for sharing what you have.

Regan Arndt
IEEE PSES SV Chapter Chair

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Re: [PSES] IEC 61010-1:2010 hazardous DC voltage

[Regan Arndt]

Rich & Pete. Thanks for your excellent explanation to this topic. Good
lesson. Much appreciated.
I can only speak for myself but I strongly believe that this
topic/understanding needs to be brought more into the spotlight based on my
previous discussions with some of my peers.
Any of you care to do a whitepaper on this?

Regan

On Wed, Feb 26, 2020 at 7:43 AM Pete Perkins  wrote:

> Regan et al,
>
>
>
>The basic electric shock info for the levels selected in
> the product standards come from IEC 60479 series, Effects of electric shock
> on the human body…  There are two sets of curves in IEC 60479-1 based upon
> the data collected and evaluated (from the literature).  One set of curves
> is for AC and the other is for DC.  These plot three body effects;
> startle-reaction, letgo-immobilization and Ventricular Fibrillation as a
> function of time.  The names for these effects primarily come from the
> effect of AC currents on the body.  The DC effects are not as well defined
> physiologically but are given the same names for consistency.  The product
> committees end up picking levels which seem appropriate for the application
> and the values are not fully consistent between product standards, in spite
> of the work of the IEC to make it so.
>
>A major difficulty is that the body effects are from the
> current while the product committees would like to specify voltage, which
> is easier to measure and verify compliance.
>
> The IEC long ago issued a simple 1201 Voltage Limits standard, aka 61201,
> which was updated using a more complete evaluation and had a myriad of
> curves for the various conditions based upon the choice of contact
> parameters selected.  This is so much more complicated than just selecting
> a fixed voltage for most conditions and is not generally used in product
> standards.
>
>So, in short, whether one picks 60Vdc or 70Vdc is not very
> relevant in the overall human body effect picture; nor is a change of 4Vdc
> around any of these values.
>
>Finally, as Rich stated, the DC value is not related to the
> AC value by the sqrt 2.  This works well for moving from AC to equivalent
> DC voltage for hi-pot testing purposes but provides no path to the human
> body effect which is different, as has been discussed here.
>
>
>
> :>) br,  Pete
>
>
>
> Peter E Perkins, PE
>
> Principal Product Safety & Regulatory Affairs Consultant
>
> PO Box 1067
>
> Albany, ORe  97321-0413
>
>
>
> 503/452-1201
>
>
>
> IEEE Life Fellow
>
> IEEE PSES 2020 Distinguished Lecturer
>
> p.perk...@ieee.org
>
>
>
> *From:* Regan Arndt 
> *Sent:* Tuesday, February 25, 2020 8:49 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] IEC 61010-1:2010 hazardous DC voltage
>
>
>
> Hi Rich.
>
> Thanks for your feedback.
>
>
>
> Correction/clarification. I was not trying to ‘convert’ to DC using 1.414
> (root 2).
>
> I merely used that ‘multiplication factor’ (1.414 & sometimes just 1.4)
> based on the widely used/misused?/abused? that is used in the industry when
> determining ‘equivalent’ DC values, just like one commonly does when
> calculating the hipot test values.
>
>
>
> See:
> https://electrical-engineering-portal.com/what-is-hipot-testing-dielectric-strength-test
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__electrical-2Dengineering-2Dportal.com_what-2Dis-2Dhipot-2Dtesting-2Ddielectric-2Dstrength-2Dtest&d=DwMFaQ&c=q6k2DsTcEGCcCb_WtVSz6hhIl8hvYssy7sH8ZwfbbKU&r=9-kTQUJB47k5_bHz_YekCwOWfoQDGgqgofVdnvpCXhM&m=X4OfXcJKn2LCMhQAhagkIEb6yDHp7Th9Mn0aSM9F6M4&s=57RvY_cM21TMTgAGuiIGMnZD0a7EcjWCvdfn0geu-kw&e=>,
> where Jignesh Parmar quotes in his article: “Therefore, if we use dc test
> voltage, we ensure that the dc *test voltage is under root 2 (or 1.414)
> times the ac test voltage, so the value of the dc voltage is equal to the
> ac voltage peaks.”*
>
>
>
> Another classic example comes from the 60950 standard for hipot values.
> 1500 VAC/2121 DC (calculation factor = 1.414)
>
>
>
> That being said, I look forward to hear a response from someone on TC66 on
> why they chose 70V.
>
>
>
> It would also be great if you could do a whitepaper (& speak) on the
> understanding of how the body reacts to AC & DC for this year’s PSES
> symposium in Chicago? 😉
>
>
>
> Regan
>
>
>
> On Tue, Feb 25, 2020 at 4:07 PM Richard Nute  wrote:
>
>
>
>
>
> Hi Regan:
>
>
>
> The “bump” occurred from 1st edition, 1990, to 2nd edition, 2001.  The 2nd,
> 2001, and 3rd, 2010, are the same.
>
>
>
> Be careful with y

Re: [PSES] IEC 61010-1:2010 hazardous DC voltage

[Regan Arndt]

Hi Rich.

Thanks for your feedback.



Correction/clarification. I was not trying to ‘convert’ to DC using 1.414
(root 2).

I merely used that ‘multiplication factor’ (1.414 & sometimes just 1.4)
based on the widely used/misused?/abused? that is used in the industry when
determining ‘equivalent’ DC values, just like one commonly does when
calculating the hipot test values.



See:
https://electrical-engineering-portal.com/what-is-hipot-testing-dielectric-strength-test
<https://urldefense.proofpoint.com/v2/url?u=https-3A__electrical-2Dengineering-2Dportal.com_what-2Dis-2Dhipot-2Dtesting-2Ddielectric-2Dstrength-2Dtest&d=DwMFaQ&c=q6k2DsTcEGCcCb_WtVSz6hhIl8hvYssy7sH8ZwfbbKU&r=9-kTQUJB47k5_bHz_YekCwOWfoQDGgqgofVdnvpCXhM&m=X4OfXcJKn2LCMhQAhagkIEb6yDHp7Th9Mn0aSM9F6M4&s=57RvY_cM21TMTgAGuiIGMnZD0a7EcjWCvdfn0geu-kw&e=>,
where Jignesh Parmar quotes in his article: “Therefore, if we use dc test
voltage, we ensure that the dc *test voltage is under root 2 (or 1.414)
times the ac test voltage, so the value of the dc voltage is equal to the
ac voltage peaks.”*



Another classic example comes from the 60950 standard for hipot values.
1500 VAC/2121 DC (calculation factor = 1.414)



That being said, I look forward to hear a response from someone on TC66 on
why they chose 70V.



It would also be great if you could do a whitepaper (& speak) on the
understanding of how the body reacts to AC & DC for this year’s PSES
symposium in Chicago? 😉



Regan

On Tue, Feb 25, 2020 at 4:07 PM Richard Nute  wrote:

>
>
>
>
> Hi Regan:
>
>
>
> The “bump” occurred from 1st edition, 1990, to 2nd edition, 2001.  The 2nd,
> 2001, and 3rd, 2010, are the same.
>
>
>
> Be careful with your math and DC interpretation.  The rms voltage limit is
> 33.  The ac peak is 1.414 x 33 = 46.7.  The DC is 70, which is unrelated to
> the AC voltages (which is because of how the body reacts to AC and DC).
>
>
>
> As to the rationale for the change from 1st to 2nd, I suggest you find a
> member of TC66 and ask for the documents preceding the 2nd.
>
>
>
> Touch voltages are specified in IEC TS 61201.  In this standard both 30
> and 33 volts rms are listed, with very little difference in body reaction.
> Same for 60 versus 70 volts DC.
>
>
>
> Best regards,
>
> Rich
>
>
>
>
>
>
>
> *From:* Regan Arndt 
> *Sent:* Tuesday, February 25, 2020 2:38 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] IEC 61010-1:2010 hazardous DC voltage
>
>
>
> Dear fellow members,
>
>
>
> I am trying to understand the 'rationale/history' of why TC66 bumped up
> the DC voltage by a mere 4 volts for hazardous voltages.
>
> As we know by simple math, 46.7 Vp x 1.414 = 66 VDC.where, why
> and how did the extra 4 volts come about?
>
> I need a history lesson here ;)
>
>
>
> Also, will these voltages also come back to normal in Ed 4? (i.e. 42.4 Vp,
> 60 VDC)
>
>
>
> Thanks for shedding any light on this?
>
>
>
> Regan Arndt
>
>
>
>
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including how to
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>
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[PSES] IEC 61010-1:2010 hazardous DC voltage

[Regan Arndt]

Dear fellow members,

I am trying to understand the 'rationale/history' of why TC66 bumped up the
DC voltage by a mere 4 volts for hazardous voltages.
As we know by simple math, 46.7 Vp x 1.414 = 66 VDC.where, why
and how did the extra 4 volts come about?
I need a history lesson here ;)

Also, will these voltages also come back to normal in Ed 4? (i.e. 42.4 Vp,
60 VDC)

Thanks for shedding any light on this?

Regan Arndt

-

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discussion list. To post a message to the list, send your e-mail to 


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Re: [PSES] Mandatory certification

[Regan Arndt]

Hi Rich.

If you are referring to clause (2):

*(2) With respect to an installation or equipment of a kind that no
nationally recognized testing laboratory accepts, certifies, lists, labels,
or determines to be safe, if it is inspected or tested by another Federal
agency, or by a State, municipal, or other local authority responsible for
enforcing occupational safety provisions of the National Electrical Code,
and found in compliance with the provisions of the National Electrical Code
as applied in this subpart; o*r

Correct me if I am wrong, "BUT ONLY" if that piece of equipment *cannot be
certified by the NRTL's*, which is almost rare nowadays when you look at
the extensive scope of accreditation of the NRTL's.

Regan

On Thu, Feb 20, 2020 at 10:58 AM Richard Nute  wrote:

>
>
> Hi Regan:
>
>
>
> While field inspection is not part of OSHA's NRTL program, OSHA rules
> allow another government (federal, state, local) organization to determine
> compliance with the NEC.  See:
>
>
>
> https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.399
>
>
>
> I would guess that such a government organization (not the manufacturer)
> would hire a NRTL to do a field inspection.
>
>
>
> Best regards,
>
> Rich
>
>
>
>
>
> *From:* Regan Arndt 
> *Sent:* Wednesday, February 19, 2020 10:46 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
>
>
>
> Hello Dave/Bernd.
>
>
>
> Just a comment/clarification. The field inspection/label program is not
> part of OSHA's NRTL program despite some NRTL's that conducted this
> service. I know it can seem confusing but there are also some non-NRTL's
> that conduct these field evaluations, all of which are under state
> jurisdiction.
>
>
>
> Some may think they are abiding by OSHA rules with obtaining a field
> evaluation by an NRTL. That is not the case.
>
>
>
> Regan
>
>
>

-

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Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[Regan Arndt]

Hello Dave/Bernd.

Just a comment/clarification. The field inspection/label program is not
part of OSHA's NRTL program despite some NRTL's that conducted this
service. I know it can seem confusing but there are also some non-NRTL's
that conduct these field evaluations, all of which are under state
jurisdiction.

Some may think they are abiding by OSHA rules with obtaining a field
evaluation by an NRTL. That is not the case.

Regan

On Wed, Feb 19, 2020 at 7:11 AM Nyffenegger, Dave <
dave.nyffeneg...@bhemail.com> wrote:

> Bernd,
>
>
>
> I don’t know any jurisdiction that would accept a manufacturer
> self-declaration if the jurisdiction is requiring a safety certification.
> An alternative to an NRTL listing is an NRTL field inspection/label which
> is unique to each product at each  installation.
>
>
>
> -Dave
>
>
>
> *From:* Dürrer Bernd [mailto:bernd.duer...@wilo.com]
> *Sent:* Wednesday, February 19, 2020 10:02 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] AW: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
>
>
>
> Hello Ted, hello Regan,
>
>
>
> Thank you for your clear statements on NRTL certification. Can you please
> provide some guidance on the interpretation of the National Electrical Code
> NFPA 70 (2020 edition), article 110.3, on the suitability of installation
> and use in conformity with the NEC? Informational note no. 2 explains, that
> this suitability “may” be evidenced by listing or labelling. Informative
> Annex A “provides a list of product safety standards used for product
> listing where that listing is required by the NEC.” This lists includes
> many product safety standards for consumer products like appliances that
> are typically plug connected. In the case that the NEC has been adopted by
> local jurisdiction and that the equipment is in the scope of a product
> safety standard listed in Annex A, is NRTL certification and listing then a
> mandatory requirement, or is there another option (e.g. self-declaration of
> the manufacturer that the product is suitable for installation and use in
> conformity with the NEC) that is accepted both by jurisdiction and the
> market?
>
>
>
> Thank you and kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* Regan Arndt 
> *Gesendet:* Dienstag, 18. Februar 2020 18:01
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
>
>
>
> OSHA & the related NRTL mandatory certification is only for the
> commercial/office/industrial workplace. OSHA has no jurisdiction in the
> consumer environment.
>
> The FCC is for both environments.
>
>
>
> Regan
>
>
>
> On Mon, Feb 17, 2020, 8:29 PM <06cee064502d-dmarc-requ...@ieee.org>
> wrote:
>
> Thank you Ted, Rich and Regan,
>
> The product is classified as IT and is sold to pro market. i.e it is used
> by professional and not consumer market. There two types of products. Class
> I as well as Class III. They are mainly used in corporation conference
> rooms.
>
>
>
> With that in mind, what are your thoughts about mandatory NRTL
> certification as well as FCC?
>
>
>
> Thanks
>
> Peter
>
> -Original Message-
> From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org>
> To: EMC-PSTC 
> Sent: Mon, Feb 17, 2020 6:16 pm
> Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
>
> Hello Peter,
>
>
>
> Let me add to Rich and Regan’s comments.
>
>
>
> The question for residential installations isn’t as clear as for the
> workplace. Most jurisdictions in the United States have adopted the
> National Electrical Code which requires many electrical and electronic
> products to either be Listed or to be investigated and approved by the
> local Authority Having Jurisdiction. In practice, this typically will apply
> to hard-wired products or products attached to building structure. The
> enforcement is typically through an electrical inspection which will often
> not cover plug-connected devices.
>
>
>
> In the workplace, any product that has a direct connection to the mains
> will need NRTL approval. At the other end of the spectrum, a product like a
> USB mouse or remote control using alkaline batteries likely won’t need NRTL
> approval. In theory, I believe an OSHA inspector could enforce the NRTL
> requirement on any electrical product, but that won’t necessarily be what
> happens in practice.
>
>
>
> That being said, you can choose not to get NRTL approval for your product.
> However, you need to understand the risks your product may pose. If you
> sell products to commercial customers, are you meeting their needs? Will
>

Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[Regan Arndt]

OSHA & the related NRTL mandatory certification is only for the
commercial/office/industrial workplace. OSHA has no jurisdiction in the
consumer environment.
The FCC is for both environments.

Regan


On Mon, Feb 17, 2020, 8:29 PM <06cee064502d-dmarc-requ...@ieee.org>
wrote:

> Thank you Ted, Rich and Regan,
>
> The product is classified as IT and is sold to pro market. i.e it is used
> by professional and not consumer market. There two types of products. Class
> I as well as Class III. They are mainly used in corporation conference
> rooms.
>
> With that in mind, what are your thoughts about mandatory NRTL
> certification as well as FCC?
>
> Thanks
> Peter
>
> -Original Message-
> From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org>
> To: EMC-PSTC 
> Sent: Mon, Feb 17, 2020 6:16 pm
> Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
>
> Hello Peter,
>
> Let me add to Rich and Regan’s comments.
>
> The question for residential installations isn’t as clear as for the
> workplace. Most jurisdictions in the United States have adopted the
> National Electrical Code which requires many electrical and electronic
> products to either be Listed or to be investigated and approved by the
> local Authority Having Jurisdiction. In practice, this typically will apply
> to hard-wired products or products attached to building structure. The
> enforcement is typically through an electrical inspection which will often
> not cover plug-connected devices.
>
> In the workplace, any product that has a direct connection to the mains
> will need NRTL approval. At the other end of the spectrum, a product like a
> USB mouse or remote control using alkaline batteries likely won’t need NRTL
> approval. In theory, I believe an OSHA inspector could enforce the NRTL
> requirement on any electrical product, but that won’t necessarily be what
> happens in practice.
>
> That being said, you can choose not to get NRTL approval for your product.
> However, you need to understand the risks your product may pose. If you
> sell products to commercial customers, are you meeting their needs? Will
> your products be acceptable to them? If you have a low-voltage device that
> isn’t mains connected, you will need to understand your customer’s needs
> before you make any determination about skipping NRTL approval.
>
> Let’s use the USB mouse example. If you sell a USB mouse that has no NRTL
> approval, you can state that you are selling a product to the general
> public for home use where NRTL approval for a mouse is clearly not
> required. You can then argue that any business that purchases it is making
> their own decision on whether to accept a non-NRTL product. However, it is
> up to you, your employer and your employer’s legal department on whether
> you should take this approach.
>
> Ted Eckert
> The opinions expressed do not necessarily reflect those of my employer,
> OSHA or the U.S. Department of Labor.
>
> *From:* Richard Nute 
> *Sent:* Monday, February 17, 2020 3:52 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [EXTERNAL] Re: [PSES] Mandatory certification
>
>
> Hi Peter:
>
> I can only speak to NRTL certification.
>
> If your product can be used in a workplace, then NRTL certification is
> mandatory.
>
> In most non-workplace locations, safety certification is mandatory.  A
> local authority specifies the acceptable certification houses.  Most local
> authorities specify the NRTL certification houses.
>
> Certification by a NRTL certification house is accepted almost universally
> in the USA.
>
> Best regards,
> Rich
>
>
> -
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
> 
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/
> 
> can be used for graphics (in well-used formats), large files, etc.
> Website: http://www.ieee-pses.org/
> 

Re: [PSES] Mandatory certification

[Regan Arndt]

Hi Peter.
Here is a very good link on NRTL and requirements by OSHA:
*https://www.osha.gov/dts/shib/shib021610.html
*

As for the FCC, see this link, specifically subpart B
https://www.ecfr.gov/cgi-bin/text-idx?SID=c7be03a4f7b02514cea89421fc363794&mc=true&tpl=/ecfrbrowse/Title47/47cfr15_main_02.tpl


Hope this helps.

Regan


On Mon, Feb 17, 2020 at 3:25 PM <06cee064502d-dmarc-requ...@ieee.org>
wrote:

> Hello colleagues,
>
> I have a simple question. For an IT product that falls under 60950-1 and
> CISPR 32, do FCC and NRTL certification mandatory? I have always been under
> the impression that the when it comes to EMI/EMC, testing and
> certification/validation is mandatory but when it comes to product safety
> it is not but I am not 100% sure about my assumption. The product is
> unintentional radiator.
>
> Thanks
> Peter
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including how to
> unsubscribe) 
> List rules: http://www.ieee-pses.org/listrules.html
>
> For help, send mail to the list administrators:
> Scott Douglas 
> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bacher 
> David Heald 
>

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Re: [PSES] CE marking quality manufacturing requirements

[Regan Arndt]

Perfect. Exactly what I was looking for. I guess I fell asleep again
reading this directive before I reached this clauselol

Thanks everyone for replying. Very good feedback/input from all of you.

Cheers!
Regan

On Wed, Jan 15, 2020 at 12:04 AM Charlie Blackham <
char...@sulisconsultants.com> wrote:

> Regan
>
>
>
> CE marking of course applies to all products manufactured on an ongoing
> basis, and the requirement you refer to is in the Directives
>
>
>
> Quoting from the LVD as an example (Annex III, Module A)
>
>
>
> *3. Manufacturing *
>
> The manufacturer shall take all measures necessary so that the
> manufacturing process and its monitoring ensure compliance of the
> manufactured electrical equipment with the technical documentation referred
> to in point 2 and with the requirements of this Directive that apply to it.
>
>
>
> To which the LVD guide adds
>
>
>
> The manufacturer has to ensure, that the manufacturing process permanently
> leads to compliant electrical equipment. One means to achieve this could be
> a supervised QM-System.
>
>
>
> You as the manufacturer need to decide what is prudent, for example:
>
>- NRTL audits generally concern themselves with safety critical
>components – which assists with safety, but doesn’t cover EMC
>- Alternative components may well meet all necessary safety standards
>and have equivalent electrical performance for EMC compliance, but what
>about RoHS?
>
>
>
> The manufacturing quote is similar in the EMC Directive: Annex II, Module
> A, section 4
>
>
>
> Regards
>
> Charlie
>
>
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: **https://sulisconsultants.com/* <https://sulisconsultants.com/>
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Regan Arndt 
> *Sent:* 15 January 2020 00:23
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] CE marking quality manufacturing requirements
>
>
>
> Greetings team members,
>
>
>
> I seem to recall somewhere either in a directive or the blue guide where
> it states (or implies) that part of the CE marking requirements entails
> that the manufacture must have a product quality system/production
> control..and this is where I need clarification: Does it imply that
> the quality system entail that *one must conduct an internal product
> safety audit (or the like) *to reassure themselves that there has been no
> deviation to the product design/documentation that originally supported
> their CE marking testing/declaration.
>
>
>
> *Note that I am not referring to the module conformity assessment protocol
> which involves a notified body, but just the simple self-declaration
> scheme. My search always seems to point me towards the notified body
> modules section, where they say that the 3rd party conducts factory audits,
> etc. but there is nothing that states this for the non-notified body
> involvement.*
>
>
>
> If there is no such production verification audit required, would it not
> be prudent to do this? ….just like the NRTL program? My experience
> indicates that most manufacturers do not conduct internal product audits
> relating to CE marking unless they forced to because they also have a
> certification mark on the product (i.e. NRTL program or other certification
> scheme via a Notified Body).
>
>
>
> Thanks for any help you can provide me with an official exact
> clause/text/excerpt from the OJ, guides and/or directives.
>
>
>
> Regan Arndt
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
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> emc-p...@ieee.org>
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[PSES] CE marking quality manufacturing requirements

[Regan Arndt]

Greetings team members,



I seem to recall somewhere either in a directive or the blue guide where it
states (or implies) that part of the CE marking requirements entails that
the manufacture must have a product quality system/production
control..and this is where I need clarification: Does it imply that
the quality system entail that *one must conduct an internal product safety
audit (or the like) *to reassure themselves that there has been no
deviation to the product design/documentation that originally supported
their CE marking testing/declaration.



*Note that I am not referring to the module conformity assessment protocol
which involves a notified body, but just the simple self-declaration
scheme. My search always seems to point me towards the notified body
modules section, where they say that the 3rd party conducts factory audits,
etc. but there is nothing that states this for the non-notified body
involvement.*



If there is no such production verification audit required, would it not be
prudent to do this? ….just like the NRTL program? My experience indicates
that most manufacturers do not conduct internal product audits relating to
CE marking unless they forced to because they also have a certification
mark on the product (i.e. NRTL program or other certification scheme via a
Notified Body).


Thanks for any help you can provide me with an official exact
clause/text/excerpt from the OJ, guides and/or directives.


Regan Arndt

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[PSES] Product Safety Engineer opportunity

[Regan Arndt]

Sending on behalf of Hunter Bisch of Danaher

Ensure Water Quality for the World: Sr. Safety Compliance Engineer

I am with talent acquisition at Danaher Corporation, a Fortune 200 science
and technology innovator (NYSE:DHR). I am reaching out to you due to your
association with the IEEE Product Safety Engineering Society. The Danaher
Water Quality platform is looking for a Product Safety Compliance Engineer
and I wanted to gauge your interest or to see if you knew anyone who may be
looking.



This role would work specifically with Danaher's water quality companies
who design and manufacture instrumentation such as Hach, Sea-Bird
Scientific, and Trojan Technologies. The position would be based at Hach
headquarters in Loveland, CO and relocation assistance would be provided.



We are looking for a skilled Compliance Engineer who can evaluate and
analyze instrumentation circuit designs in regards to regulatory standards
and directives. The ideal candidate would have experience with ATEX/Hazloc,
6.10.10, and 6.09.50. Experience in other areas of compliance such as
wireless, enclosure, environmental, and EMC would be major pluses.



I would love to share more details with you if interested, or would welcome
any recommendations you may have.



Sincerely,

Hunter Bisch

Talent Acquisition, Danaher

hunter.bi...@danaher.com

(618) 384-0557
-- 
Best regards,

Regan

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[PSES] IEC 1010 versus IEC 61010-1

[Regan Arndt]

Hello fellow members,

I am doing some research and was wondering if anyone has in their archives
a compiled list of the additional/more stricter requirements using the
latest 61010-1 version (2010:3rd edition) compared to the latest IEC 1010
version (I think the year was 1999 or 2000).

I don't need anything too much in detail, but only highlights.

Thanks for helping where you can.

Regan Arndt

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[PSES] GB or GC?....that is the question....

[Regan Arndt]

Hello members,

I tried to search my EMC-PSTC archives (to no avail) regarding a debate of
using either ground bond (let's assume 25A for this discussion) or ground
continuity (resistance measured < 0.1 ohm for this discussion) testing *during
production*.

Therefore, I would like to bring the topic up (again?) and get your
professional opinion on these tests.

(Side note: Omnia has put out a brochure recently promoting the use of
ground bond test in addition to ground continuity during production, but I
am a little skeptical.)


I am a proponent for the ground continuity test during production for
several reasons:

1.   It’s safe to conduct, especially for production staff

2.   Less harmful to the equipment

3.   Intent is to verify the ground path is ‘secure’.

And I am an opponent to the ground bond test during production for several
reasons:

1.   Dangerous to conduct. Need astute production personnel that know
what they are doing.

2.   I consider this a type test and ‘somewhat’
damaging/stressful….(Yes, can be debated)…


Yes, the ground bond test is useful and a good indicator for determining
the ampacity integrity of cables/connectors but, in my opinion, it should
be reserved for type testing only.

*I feel that there is no reason to do the ground bond test during
production if the manufacture controls their components in
purchasing/design via an ECO process, etc., thus the ground continuity test
is thereby sufficient*.

If one have no component control process, then, yes, GB is a good idea.


Note that IEC 61010-1 Annex F (Routine tests) also specifies the ground
continuity test (and not a ground bond test)... but also take note that
it does say the value for current is not specified.

*F.2 Protective earth*

*A continuity test is made between the earth pin of the appliance inlet or
the **MAINS **plug of plug-connected equipment, or the **PROTECTIVE
CONDUCTOR TERMINAL **of **PERMANENTLY CONNECTED EQUIPMENT **on the one
side, and all **ACCESSIBLE **conductive parts which are required by 6.5.2
to be connected to the **PROTECTIVE CONDUCTOR TERMINAL **on the other side.*

*NOTE No value is specified for the test current.*


Your reply is greatly appreciated.

Thanks in advance.

Regan Arndt

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Re: [PSES] Automated listserv error message

[Regan Arndt]

Hi Peter. Received same message. Weird.

On Wed, Apr 24, 2019, 8:32 AM Doug Powell  wrote:

> All,
>
> Yesterday I received what was called an automatic removal message from
> the listserv.  The subject line was "Your removal from the EMC-PSTC
> list".  And indeed, I was unsubscribed for the first time since 1997.
> I wondered if anyone else with a gmail account has this problem.
>
> I was advised to contact my email administrator and of course you can
> see I am on gmail.  Apparently there were three separate message
> rejections with error 5.0.0
>
> Best, Doug
>
> --
>
> Douglas E Powell
>
> doug...@gmail.com
> http://www.linkedin.com/in/dougp01
>
> -
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
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> well-used formats), large files, etc.
>
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>
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Re: [PSES] MD clarification of the DoC

[Regan Arndt]

Thanks Pete for that history lesson.

My confusion lies on the fact that 2 different people and addresses can be
on the MDoC. One for the DoC as a whole and one for the compiler. If I
understand you correctly, it seems that it will be easier for the EU courts
to fine/imprison someone in the EU (person that 'compiles' the technical
file) versus one outside the EU (i.e. one who can sign the MDoC (&
ultimately is the responsible person). That's how I read itdon't know
why the directive didn't just say the signer (responsible person) of the
MDoC must be on EU soil.

...oh, btw, I have yet to see an example of a MDoC with 2 names and 2
addresses though...despite seeing other multiple errors on these

On Tue, Dec 18, 2018 at 11:34 PM Pete Perkins <
0061f3f32d0c-dmarc-requ...@ieee.org> wrote:

> Regan,  A little ancient history:
>
> When the CE marking system was set up it was apparent by the early
> reactions that the developers of the system never envisioned that anyone
> but a European would sign the MDoC and be legally responsible for the
> equipment safety.  (I’ve always said they are looking for someone to arrest
> since there is legal criminal liability for signing the MDoC falsely.)
> Failing to set up the process the way they envisioned it, 2nd best is to
> have a European person available who can bear the responsibility; don’t be
> fooled that the Euro contact only has to provide the TF upon request.  That
> being said, any European asked would not accept the responsibility lightly
> and want legal, contractual assurances that the non-European company would
> provide needed legal and financial support to defend them and the company.
> Getting this done has been left to the Directives  and there is no uniform
> way applying it broadly to all Directives, MDoCs and products yet.  (I’m
> surprised that the EU bureaucrats haven’t worked this out yet; they did it
> for the CE marking.)  Moreover, non-Euro companies have been dragging their
> feet on meeting this requirement even when it is in a Directive, such as
> the MD you mentioned.  This avoids the initial cost of setting up a
> contracted representative,  any ongoing cost to maintain the representative
> and, minimizes the chances of being drawn into any expensive legal battle
> over challenges – either procedural or equipment incident related.  It is
> so easy to sell over the internet and ship the CE marked unit to the Euro
> customer and have the payment flow to the manufacturer.
>
> Remember your mother’s mantra: be careful what you ask
> for; you might just get it.
>
>
>
> :>) br,  Pete
>
>
>
> Peter E Perkins, PE
>
> Principal Product Safety & Regulatory Affairs Consultant
>
> PO Box 23427
>
> Tigard, ORe  97281-3427
>
>
>
> 503/452-1201
>
>
>
> IEEE Life Fellow
>
> p.perk...@ieee.org
>
>
>
> *From:* Nyffenegger, Dave 
> *Sent:* Tuesday, December 18, 2018 11:16 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] MD clarification of the DoC
>
>
>
> Regan, “So, a European must compile it but he can store it somewhere in
> i.e. Timbuktu. strange.”
>
>
>
> I don’t take ‘compile” too literally,  they are looking for a contact in
> the EU, one that can be easily contacted who can provide a copy of the
> technical file on request.  How the person gets it or where they get it
> from is not of concern.  This individual is distinctly different than one
> who signs the DoC and different than authorized representative, although it
> could be the same person as you have pointed out.  The Blue Guide probably
> has some words on this, it’s been a while since I’ve looked at it.
>   Technical file requirements vary across directives.
>
>
>
> -Dave
>
>
>
> *From:* Regan Arndt [mailto:reganar...@gmail.com ]
> *Sent:* Tuesday, December 18, 2018 1:44 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] MD clarification of the DoC
>
>
>
> Hello folks. Hope you are all enjoying the festive season thus far!
>
>
>
> I was wondering if any of you knew the rationale behind requirement #2 in
> the Machinery Directive and why the other directives do not have this? (as
> you can see, this is over & above the authorized rep (#10) signing the
> DoC).
>
>
>
> Excerpt below:
>
>
>
> *A. EC DECLARATION OF CONFORMITY OF THE MACHINERY*
>
>
>
> *2. name and address of the person authorised to compile the technical
> file, who must be established in the Community;*
>
>
>
> *10. the identity and signature of the person empowered to draw up the
> declaration on behalf of the manufacturer or his authorised representativ*
> e.
>
&g

Re: [PSES] MD clarification of the DoC

[Regan Arndt]

ok, but why for only the MD, and not the rest? - curious

On Tue, Dec 18, 2018 at 11:30 AM John Woodgate  wrote:

> I think it's because the compiler must be subject to EU law, or that of a
> Member State, but the digital document can be stored anywhere as long as it
> is reasonably accessible.
>
> Best wishes
> John Woodgate OOO-Own Opinions Only
> J M Woodgate and Associates www.woodjohn.uk
> Rayleigh, Essex UK
>
> On 2018-12-18 18:43, Regan Arndt wrote:
>
> Hello folks. Hope you are all enjoying the festive season thus far!
>
> I was wondering if any of you knew the rationale behind requirement #2 in
> the Machinery Directive and why the other directives do not have this? (as
> you can see, this is over & above the authorized rep (#10) signing the
> DoC).
>
> Excerpt below:
>
>
> *A. EC DECLARATION OF CONFORMITY OF THE MACHINERY *
>
>
> *2. name and address of the person authorised to compile the technical
> file, who must be established in the Community; *
>
> *10. the identity and signature of the person empowered to draw up the
> declaration on behalf of the manufacturer or his authorised representativ*
> e.
>
> It's odd because in Annex VII, in section 2, it states:
>
>
> *The technical file does not have to be located in the territory of the
> Community, nor does it have to be permanently available in material form.
> However, it must be capable of being assembled and made available within a
> period of time commensurate with its complexity by the person designated in
> the EC declaration of conformity.*
>
> So, a European must compile it but he can store it somewhere in i.e.
> Timbuktu. strange.
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
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> well-used formats), large files, etc.
>
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[PSES] MD clarification of the DoC

[Regan Arndt]

Hello folks. Hope you are all enjoying the festive season thus far!

I was wondering if any of you knew the rationale behind requirement #2 in
the Machinery Directive and why the other directives do not have this? (as
you can see, this is over & above the authorized rep (#10) signing the
DoC).

Excerpt below:


*A. EC DECLARATION OF CONFORMITY OF THE MACHINERY*


*2. name and address of the person authorised to compile the technical
file, who must be established in the Community;*

*10. the identity and signature of the person empowered to draw up the
declaration on behalf of the manufacturer or his authorised representativ*e.

It's odd because in Annex VII, in section 2, it states:


*The technical file does not have to be located in the territory of the
Community, nor does it have to be permanently available in material form.
However, it must be capable of being assembled and made available within a
period of time commensurate with its complexity by the person designated in
the EC declaration of conformity.*

So, a European must compile it but he can store it somewhere in i.e.
Timbuktu. strange.

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Re: [PSES] CE non-conformity statistics

[Regan Arndt]

Thanks everyone for your feedback and help. Greatly appreciated.
Perhaps someday AdCo, RAPEX and other surveillance authorities would have
their own blog and get some constructive feedback from the industry.
There is always room for improvement.

Regan

On Mon, Nov 5, 2018 at 8:06 AM Kunde, Brian  wrote:

> John,
>
>
>
> Exactly!!
>
>
>
> Even annex I of the Machinery Directive (EHSR) can only be applied to a
> product. Step 1 is for the manufacturer to make the determination of which
> sections of the EHSR apply to their product and which sections do not by
> means of the Risk Assessment. Only the manufacturer can make this
> determination, so how is a field inspector going to be able to evaluate a
> product without this information?  They just have to do the best they can
> and false non-compliances are going to be the result.
>
>
>
> The question is, are these false non-compliances making it into these
> annual reports?  If so, then the numbers may not be as meaningful as one
> might hope.
>
>
>
> *Brian Kunde*
>
> Manager • Compliance Engineering
>
> LECO Corp • Compliance Testing Center
>
>
>
> *From:* John Woodgate [mailto:j...@woodjohn.uk]
> *Sent:* Friday, November 02, 2018 5:43 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] CE non-conformity statistics
>
>
>
> There's more. The recommended format for EU DoCs, at least for electrical
> safety and EMC asserts conformity with Directives, not standards, and says
> it 'applies' standards, not conforms to them:
>
>
>
>
>
>
>
>
>
>
> *The object of the declaration described above is in conformity with the
> relevant Union harmonisation legislation: EMC Directive 2014/30/EU e.g. Low
> Voltage Directive (LVD) 2014/35/EU   The following harmonised standards and
> technical specifications have been applied:   Title, Date of
> standard/specification: e.g. EN 55014, aregearg + A1:2009 + A2:2011  *
>
> John Woodgate OOO-Own Opinions Only
>
> J M Woodgate and Associates www.woodjohn.uk
>
> Rayleigh, Essex UK
>
> On 2018-11-02 21:11, John Woodgate wrote:
>
> Your first paragraph states the problem, and 'technical violation - no
> action' is the way it's resolved.
>
> In a DoC, I wouldn't mention 'relevant' at all, particularly now the legal
> profession has got its hooks into the European compliance system. It really
> does look like a 'loophole creator', not only to a rabid regulator. The
> place to assert relevance/irrelevance is in the assessment document,
> whether for EMC or safety.
>
> John Woodgate OOO-Own Opinions Only
>
> J M Woodgate and Associates www.woodjohn.uk
>
> Rayleigh, Essex UK
>
> On 2018-11-02 20:38, Kunde, Brian wrote:
>
> John,
>
>
>
> I love your example of the Power Supply.  In this case, a “standard” says
> one thing, but the manufacturer did it a different way. The use of
> Standards to show compliance to a Directive is only voluntary.  In a Hazard
> Driven approach to safety, such a drop-dead requirement in a Standard
> should not be allowed unless you only look at standards as a guide to
> compliance, which they are.  In a Risk Assessment, if doing something one
> way over another would not cause an increase risk, then it would be
> considered compliant.
>
>
>
> But what about a Manufacturer’s Declaration of Compliance where they list
> standards? Do they have to abide by each of these standards to the letter
> to be compliant with the Directives? I don’t think so.  Many DoCs state
> this, “conforms with all relevant provisions of the following,” blah blah
> blah ….  to where a list of standards and technical specifications are
> listed.  But who is say what is relevant? The Manufacturer is given that
> authority in the NLF; not the inspector.
>
>
>
> This is all in fun and I’m not debating you on this.  The fact is, you can
> talk about “Hazard Driven” approach, or this or that, do lectures, write
> books, get your picture in CE Magazine, but what it all boils down to is
> making the inspectors happy.  Maybe we should call this “Inspector Driven”
> approach to Compliance.  Smile!!  Isn’t that what we do or try to do?
>
>
>
> The Other Brian
>
>
>
> *From:* John Woodgate [mailto:j...@woodjohn.uk ]
> *Sent:* Friday, November 02, 2018 2:53 PM
> *To:* Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] CE non-conformity statistics
>
>
>
> A typical technical non-compliance is incorrect marking of power supply
> data. Different standards have different requirements, and it's easy to
> mistakenly state, for example, the supply current when the standard
> requires the input power to be stated. Yes, the majority of reported
> violations are minor and require no action, except that the manufacturer
> has to fix the issue for future production.
>
> Another case, although I don't know if it would always be rated
> 'technical' is when the offending product is shown to have an unpredictable
> and random fault, which might well be caused by a component failure during
> early use, so that the product was probably complia

Re: [PSES] CE non-conformity statistics

[Regan Arndt]

Hi Pete. Yes, it's a sad state of affairs. Our profession needs to do more
or something different to turn this around.

I wish AdCo could release where these products originated from so we can
focus our attention on improvements in these regions.

Anybody know of some examples of penalties/fines that have occurred
recently?

I'm also surprised there was no cross-border market surveillance of just
LVD or Machinery.   It appears they are just cherry picking the high
profile products/categories.

On Thu, Nov 1, 2018 at 9:01 AM Pete Perkins  wrote:

> Regan,  Thanx for chasing down these statistics; very
> interesting.  For most of the folks on this forum the most interesting are
> the technical non-conformity issues.  The best/lowest is 14% for EMC and
> higher 24%/25% for safety/radio.  Doesn’t speak well for our profession and
> influence on industry.  Yes, there are many others but most of them are
> Technical File paperwork issues.
>
>
>
> :>) br,  Pete
>
>
>
> Peter E Perkins, PE
>
> Principal Product Safety & Regulatory Affairs Consultant
>
> PO Box 23427
>
> Tigard, ORe  97281-3427
>
>
>
> 503/452-1201
>
>
>
> IEEE Life Fellow
>
> p.perk...@ieee.org
>
>
>
> *From:* Regan Arndt 
> *Sent:* Wednesday, October 31, 2018 3:52 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] CE non-conformity statistics
>
>
>
> Thanks Charlie. I checked the latest on the RED. Below is an excerpt on
> the stats. Amazing. Wonder what the penalties were. h..
>
>
>
> ADCO RED report to TCAM WG on market surveillance statistics for 2016
>
>
>
> *2. Results for 2016 *
>
> Totally, 13,488 R&TTE equipment has been inspected by 25 market
> surveillance authorities in 2016: Austria, Cyprus, Denmark, Estonia,
> Finland, France, Germany, Greece, Hungary, Italy, Latvia, Lithuania,
> Luxembourg, Malta, Norway, Poland, Portugal, Romania, Slovakia, Slovenia,
> Spain, Sweden, Switzerland, The Netherlands and United Kingdom. About 10391
> equipment were been found non-compliant to the provisions of the R&TTE
> Directive. However, due to the fact that not all provisions were checked by
> all involved market surveillance authorities, the effective amount of non
> compliant equipment may be higher.
>
>
>
> *Summary of the results: **·** Overall : 10391 non compliant equipment
> (13488 inspected equipment)*
>
>- Declaration of conformity : 9372 non compliant DoC (13224 inspected
>equipment)
>- CE marking : 8307 non complaint CE marking (13371 inspected
>equipment)
>- Geographical area for use : 3773 not compliances (11750 inspected
>equipment)
>- Essential requirements : 579 technical non compliances (of 2131
>measured equipment)
>- Safety (art.3.1.a): 116 technical non compliances (of 488 measured
>equipment)
>- EMC (art 3.1.b.): 84 technical non compliances (of 583 measured
>equipment)
>- Radio (art.3.2.) : 434 technical non compliances (of 1755 measured
>equipment)
>- Technical documentation: 276 non compliances (of 651 inspected
>equipment)
>- Test reports: 236 non compliances (of 603 inspected equipment)
>- Drawings and explanations: 47 non compliances (of 212 inspected
>equipment)
>- Other elements: 79 non compliances (of 326 inspected equipment)
>
> Regan
>
>
>
> On Mon, Oct 29, 2018 at 4:47 PM Charlie Blackham <
> char...@sulisconsultants.com> wrote:
>
> Regan
>
>
>
> Market enforcement reports from the various “AdCos”, Administrative
> Cooperation Groups, can be found at
> http://ec.europa.eu/growth/single-market/goods/building-blocks/market-surveillance/organisation/administrative-cooperation-groups_en
> under the “Documents from the AdCo Groups)
>
>
>
> As well as a number of reports on EMC, you may wish to look at the
> R&TTE/RED ones as well
>
>
>
> Regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: **www.sulisconsultants.com*
> <https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f>
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Regan Arndt 
> *Sent:* 29 October 2018 23:34
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] CE non-conformity statistics
>
>
>
> Greetings fellow members,
>
>
>
> Out of curiosity, has anyone been privy to any recent EU statistics for
> those manufacturers who have been subjected to customs investigations
> pertaining to CE marking, penalties, sales ban

Re: [PSES] CE non-conformity statistics

[Regan Arndt]

Thanks Charlie. I checked the latest on the RED. Below is an excerpt on the
stats. Amazing. Wonder what the penalties were. h..

ADCO RED report to TCAM WG on market surveillance statistics for 2016

* 2. Results for 2016 *
Totally, 13,488 R&TTE equipment has been inspected by 25 market
surveillance authorities in 2016: Austria, Cyprus, Denmark, Estonia,
Finland, France, Germany, Greece, Hungary, Italy, Latvia, Lithuania,
Luxembourg, Malta, Norway, Poland, Portugal, Romania, Slovakia, Slovenia,
Spain, Sweden, Switzerland, The Netherlands and United Kingdom. About 10391
equipment were been found non-compliant to the provisions of the R&TTE
Directive. However, due to the fact that not all provisions were checked by
all involved market surveillance authorities, the effective amount of non
compliant equipment may be higher.

*Summary of the results:  Overall : 10391 non compliant equipment (13488
inspected equipment)*

   - Declaration of conformity : 9372 non compliant DoC (13224 inspected
   equipment)
   - CE marking : 8307 non complaint CE marking (13371 inspected equipment)
   - Geographical area for use : 3773 not compliances (11750 inspected
   equipment)
   - Essential requirements : 579 technical non compliances (of 2131
   measured equipment)
   - Safety (art.3.1.a): 116 technical non compliances (of 488 measured
   equipment)
   - EMC (art 3.1.b.): 84 technical non compliances (of 583 measured
   equipment)
   - Radio (art.3.2.) : 434 technical non compliances (of 1755 measured
   equipment)
   - Technical documentation: 276 non compliances (of 651 inspected
   equipment)
   - Test reports: 236 non compliances (of 603 inspected equipment)
   - Drawings and explanations: 47 non compliances (of 212 inspected
   equipment)
   - Other elements: 79 non compliances (of 326 inspected equipment)

Regan

On Mon, Oct 29, 2018 at 4:47 PM Charlie Blackham <
char...@sulisconsultants.com> wrote:

> Regan
>
>
>
> Market enforcement reports from the various “AdCos”, Administrative
> Cooperation Groups, can be found at
> http://ec.europa.eu/growth/single-market/goods/building-blocks/market-surveillance/organisation/administrative-cooperation-groups_en
> under the “Documents from the AdCo Groups)
>
>
>
> As well as a number of reports on EMC, you may wish to look at the
> R&TTE/RED ones as well
>
>
>
> Regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: **www.sulisconsultants.com*
> <https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f>
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Regan Arndt 
> *Sent:* 29 October 2018 23:34
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] CE non-conformity statistics
>
>
>
> Greetings fellow members,
>
>
>
> Out of curiosity, has anyone been privy to any recent EU statistics for
> those manufacturers who have been subjected to customs investigations
> pertaining to CE marking, penalties, sales bans, etc. due to, not only
> selling an unsafe product but, having no CE marking on product, no DoC,
> insufficient technical files, non-compliance to the directives, etc?
>
> The only thing I can find on the web that has something close is from
> Yvonne Halpaus of QNET, LLC where she recently published a guide on CE
> marking in 2015. An excerpt is below:
>
> *Findings in earlier reports show that 37,600 items of equipment tested in
> Switzerland showed 1,100 cases of CE Conformity problems. Of 3,962 items
> that were subjected to rigorous measurements, a high proportion of the
> devices were found defective (976 altogether) and that none of these met
> the EMC specified requirements. *
>
> *In 23 cases a sales ban was imposed and legal proceedings were launched.
> Two other Member States also revealed problems when testing against the EMC
> & Machinery Directive: 33% failed the EMC tests, 47% did not meet the
> Machinery Directive formal rules and 89% had technical non-conformities. *
>
> *These negative findings were not the result of regular surveillance
> mechanisms, 58% was based on examinations triggered by accidents, 33.3%
> following inspection of equipment installation, 8.5% based on complaints
> from competing manufacturers and 0.2% following visits to trade fairs*.
>
>
>
>  Thanks for sharing any information you have. I'm wanting to update my CE
> marking training slides with some good solid facts.
>
>  Regan Arndt
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-

[PSES] CE non-conformity statistics

[Regan Arndt]

Greetings fellow members,


Out of curiosity, has anyone been privy to any recent EU statistics for
those manufacturers who have been subjected to customs investigations
pertaining to CE marking, penalties, sales bans, etc. due to, not only
selling an unsafe product but, having no CE marking on product, no DoC,
insufficient technical files, non-compliance to the directives, etc?

The only thing I can find on the web that has something close is from
Yvonne Halpaus of QNET, LLC where she recently published a guide on CE
marking in 2015. An excerpt is below:

*Findings in earlier reports show that 37,600 items of equipment tested in
Switzerland showed 1,100 cases of CE Conformity problems. Of 3,962 items
that were subjected to rigorous measurements, a high proportion of the
devices were found defective (976 altogether) and that none of these met
the EMC specified requirements. *

*In 23 cases a sales ban was imposed and legal proceedings were launched.
Two other Member States also revealed problems when testing against the EMC
& Machinery Directive: 33% failed the EMC tests, 47% did not meet the
Machinery Directive formal rules and 89% had technical non-conformities. *

*These negative findings were not the result of regular surveillance
mechanisms, 58% was based on examinations triggered by accidents, 33.3%
following inspection of equipment installation, 8.5% based on complaints
from competing manufacturers and 0.2% following visits to trade fairs*.


 Thanks for sharing any information you have. I'm wanting to update my CE
marking training slides with some good solid facts.

 Regan Arndt

-

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discussion list. To post a message to the list, send your e-mail to 


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Re: [PSES] LVD votlage scope query

[Regan Arndt]

Thanks Scott. The last sentence makes it very clear.

*"For products with multiple voltage ratings, input or output, the products
are considered within the scope of this Directive as soon as one of the
ratings fall within the given voltage rating."*

Regan


On Fri, Aug 10, 2018 at 2:55 PM, Scott Aldous 
wrote:

> Hi Regan,
>
> See the LVD guidelines <http://ec.europa.eu/DocsRoom/documents/20341>,
> section 6. From the guide:
>
> "The Directive applies to all electrical equipment 8 designed for use with
> a voltage rating
> of between 50 and 1000 V for alternating current and between 75 and 1500 V
> for
> direct current. Voltage ratings refer to the voltage of the electrical
> input or output, not
> to voltages that may appear inside the equipment.
>
> Following discussions with Member States, the Commission has taken the
> position
> that the term “designed for use with a voltage range” shall be understood
> as
> equipment having either a rated input voltage or a rated output voltage
> inside this
> voltage range. Internally there may be higher voltages.
>
> For products with multiple voltage ratings, input or output, the products
> are considered
> within the scope of this Directive as soon as one of the ratings fall
> within the given
> voltage rating."
>
> On Fri, Aug 10, 2018 at 2:45 PM Regan Arndt  wrote:
>
>> Hi folks.
>>
>> It's been a while since I went on the europa website and I just saw this
>> (never noticed it before). The general europa webpage section of the LVD
>> has bolded the text " *input* *or* *output voltage* ". More
>> interestingly, the conjunction ‘*or*’. Some could now argue that their
>> HV power supply (120/240 VAC input, >1500 V output) or ESD test equipment
>> (4KV+), etc. is exempt from the LVD because they think they have an option
>> due to the interpretation (or misinterpretation) of the word 'OR'.
>> (Yes, I have already seen cases like this) …….perhaps the website should
>> have stated “*and/or*” rather than just “*or*” or word it differently.
>> Again, the key point here is the word 'or'.
>>
>> Also, when I was at the PSES symposium this year in San Jose, I asked a
>> similar question related to this and some seemed to think that this was
>> ‘input’ voltage only.
>>
>> Your comments, opinions & advice on this topic are greatly appreciated.
>>
>> Below are the excerpts:
>>
>> About the Low Voltage Directive (LVD)
>>
>> The LVD covers health and safety risks on electrical equipment operating
>> with an *input* *or* *output voltage* of between:
>>
>> ·50 and 1000 V for alternating current
>>
>> ·75 and 1500 V for direct current
>>
>> Excerpt obtained from: http://ec.europa.eu/growth/sectors/electrical-
>> engineering/lvd-directive_en
>>
>>
>> The directive itself does not specifically call out input or output per
>> se. It only states ‘rating’.
>>
>> *Chapter 1, Article 1:*
>>
>> *This Directive shall apply to electrical equipment designed for use with
>> a voltage rating of between 50 and 1 000 V for alternating current and
>> between 75 and 1 500 V for direct current, other than the equipment and
>> phenomena listed in Annex II.*
>>
>>
>>
>> Excerpt from the Directive obtained from: https://eur-lex.europa.eu/
>> legal-content/EN/TXT/?uri=CELEX:32014L0035
>>
>>
>> Regan Arndt
>> IEEE PSES SCV Chair
>> -
>> 
>>
>> This message is from the IEEE Product Safety Engineering Society emc-pstc
>> discussion list. To post a message to the list, send your e-mail to <
>> emc-p...@ieee.org>
>>
>> All emc-pstc postings are archived and searchable on the web at:
>> http://www.ieee-pses.org/emc-pstc.html
>>
>> Attachments are not permitted but the IEEE PSES Online Communities site
>> at http://product-compliance.oc.ieee.org/ can be used for graphics (in
>> well-used formats), large files, etc.
>>
>> Website: http://www.ieee-pses.org/
>> Instructions: http://www.ieee-pses.org/list.html (including how to
>> unsubscribe) <http://www.ieee-pses.org/list.html>
>> List rules: http://www.ieee-pses.org/listrules.html
>>
>> For help, send mail to the list administrators:
>> Scott Douglas <sdoug...@ieee.org>
>> Mike Cantwell <mcantw...@ieee.org>
>>
>> For policy questions, send mail to:
>> Jim Bacher <j.bac...@ieee.org>
>> David Heald <dhe...@gmail.com>
>>
>

[PSES] LVD votlage scope query

[Regan Arndt]

Hi folks.

It's been a while since I went on the europa website and I just saw this
(never noticed it before). The general europa webpage section of the LVD
has bolded the text " *input* *or* *output voltage* ". More interestingly,
the conjunction ‘*or*’. Some could now argue that their HV power supply
(120/240 VAC input, >1500 V output) or ESD test equipment (4KV+), etc. is
exempt from the LVD because they think they have an option due to the
interpretation (or misinterpretation) of the word 'OR'.
(Yes, I have already seen cases like this) …….perhaps the website should
have stated “*and/or*” rather than just “*or*” or word it differently.
Again, the key point here is the word 'or'.

Also, when I was at the PSES symposium this year in San Jose, I asked a
similar question related to this and some seemed to think that this was
‘input’ voltage only.

Your comments, opinions & advice on this topic are greatly appreciated.

Below are the excerpts:

About the Low Voltage Directive (LVD)

The LVD covers health and safety risks on electrical equipment operating
with an *input* *or* *output voltage* of between:

·50 and 1000 V for alternating current

·75 and 1500 V for direct current

Excerpt obtained from:
http://ec.europa.eu/growth/sectors/electrical-engineering/lvd-directive_en


The directive itself does not specifically call out input or output per se.
It only states ‘rating’.

*Chapter 1, Article 1:*

*This Directive shall apply to electrical equipment designed for use with a
voltage rating of between 50 and 1 000 V for alternating current and
between 75 and 1 500 V for direct current, other than the equipment and
phenomena listed in Annex II.*



Excerpt from the Directive obtained from:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0035


Regan Arndt
IEEE PSES SCV Chair

-

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discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
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Re: [PSES] Safety critical component part #'s and Agency approvals

[Regan Arndt]

rchase print is a type of contract between
>the supplier and the purchasing company.
>3. Our Compliance Department performs Production Audits (usually on an
>annual bases) on all families of products. During these audits, all safety
>critical components are verified that they are what they are supposed to be
>and verifies the certification markings.  The certification markings is
>also a type of contract or declaration from the manufacturer.
>
>
>
> Datasheets and pages from the manufacturer’s catalog that shows
> certification marks, symbols, or a list of standards are really meaningless
> and as others have already pointed out this information can change without
> warning.
>
>
>
> The Other Brian
>
>
>
> *From:* Regan Arndt [mailto:reganar...@gmail.com ]
> *Sent:* Thursday, September 21, 2017 4:39 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] Safety critical component part #'s and Agency approvals
>
>
>
> Greetings everyone,
>
>
>
> My experience in regulatory compliance dates back to 1994 where it was a
> foregone conclusion that most component manufacturers did not identify
> their agency certification as a unique identifier in their part number.
>
>
>
> I have seen some good progress over the years, but I also believe that the
> industry still continues to eliminate redundant certification (due to
> standards harmonization) or sometimes complete agency certification (for
> the sake of cost reduction) on components without changing their respective
> part number. Or even worse, continue to advertise that the component is
> approved but in reality, it is not.
>
>
>
> Has anyone experienced anything recently that they wish to share?
>
>
>
> P.S. I am updating my old safety presentation and need some good examples
> before I present again to our local IEEE chapter meeting.
>
>
>
> Thanks for sharing whatever you can. (privately or within this forum)
>
>
>
> Cheers!
>
> Regan
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including how to
> unsubscribe) <http://www.ieee-pses.org/list.html>
> List rules: http://www.ieee-pses.org/listrules.html
>
> For help, send mail to the list administrators:
> Scott Douglas 
> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bacher 
> David Heald 
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including how to
> unsubscribe) <http://www.ieee-pses.org/list.html>
> List rules: http://www.ieee-pses.org/listrules.html
>
> For help, send mail to the list administrators:
> Scott Douglas 
> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bacher 
> David Heald 
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including how to
> unsubscribe) <http://www.ieee-pses.org/list.html>
> List rules: http://www.ieee-pses.org/listrules.html
>
> For help, send m

Re: [PSES] Safety critical component part #'s and Agency approvals

[Regan Arndt]

LOL.great story! Thanks for sharing!
Damned if you.damned if you don't.

On Sep 22, 2017 12:13 PM, "Richard Nute"  wrote:



Back when I was working…



For each of our part numbers, we had a drawing (spec).  For purchased
parts, the drawing was a cut and paste of the part manufacturer’s spec.
This drawing equated our part number to the manufacturer’s part number.  If
the part was required to be certified, such was indicated on the drawing.
This drawing was used for purchasing the part.



Then, the company did away with incoming inspection.  The certification
houses had a fit, and threatened to appeal to the president of the
company.  I told the certification houses that I couldn’t justify setting
up an inspection process and hiring people to look for the certification
mark (for which we never had a failure).  (The certification houses had no
sympathy for our expenses.)  Instead, I invited the certification house
inspectors to the production line where they could look at the parts as
they were being installed in the product.  This worked.



(Some parts are bulk-marked, so the certification mark is on the package.
In one inspection, the package had been discarded to the compactor.  Our
manufacturing host climbed into the compactor and retrieved the package!)



We installed process measurement.  My process measurement was the number of
inspection deficiencies, any one of which threatened to shut down the
production line.  So, I instituted a periodic line inspection in
anticipation of a certification house inspection.  I was much more thorough
and detailed than the certification house inspectors.  I drove the
deficiencies to zero.  This infuriated the inspectors, so the certification
houses sent managers to see why their inspectors could find no
deficiencies.  Sigh.



Rich





*From:* Kunde, Brian [mailto:brian_ku...@lecotc.com]
*Sent:* Friday, September 22, 2017 5:44 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] Safety critical component part #'s and Agency
approvals



We address this possible issue in two ways.



   1. We list the certification markings that are on Safety Critical
   Components on our purchase print as “incoming inspection requirements”.
   When parts are received, our IQA department visually verifies that the
   certification markings on the parts match the print. If they are different,
   the parts are rejected until this issues has been resolved (possible the
   manufacturer changed the certification body, etc.).
   2. The purchase print also has a statement that says that the supplier
   must notify us in advance of any changes to the part including regulatory
   certifications and status. The purchase print is a type of contract between
   the supplier and the purchasing company.
   3. Our Compliance Department performs Production Audits (usually on an
   annual bases) on all families of products. During these audits, all safety
   critical components are verified that they are what they are supposed to be
   and verifies the certification markings.  The certification markings is
   also a type of contract or declaration from the manufacturer.



Datasheets and pages from the manufacturer’s catalog that shows
certification marks, symbols, or a list of standards are really meaningless
and as others have already pointed out this information can change without
warning.



The Other Brian



*From:* Regan Arndt [mailto:reganar...@gmail.com ]
*Sent:* Thursday, September 21, 2017 4:39 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] Safety critical component part #'s and Agency approvals



Greetings everyone,



My experience in regulatory compliance dates back to 1994 where it was a
foregone conclusion that most component manufacturers did not identify
their agency certification as a unique identifier in their part number.



I have seen some good progress over the years, but I also believe that the
industry still continues to eliminate redundant certification (due to
standards harmonization) or sometimes complete agency certification (for
the sake of cost reduction) on components without changing their respective
part number. Or even worse, continue to advertise that the component is
approved but in reality, it is not.



Has anyone experienced anything recently that they wish to share?



P.S. I am updating my old safety presentation and need some good examples
before I present again to our local IEEE chapter meeting.



Thanks for sharing whatever you can. (privately or within this forum)



Cheers!

Regan
-


This message is from the IEEE Product Safety Engineering Society emc-pstc
discussion list. To post a message to the list, send your e-mail to <
emc-p...@ieee.org>

All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at
http:/

Re: [PSES] [BULK] Re: [PSES] Safety critical component part #'s and Agency approvals

[Regan Arndt]

Thanks Brian, so you are telling me that they did not change their part #
when they changed the hipot value?

If so, that's another interesting scenario to keep tabs on.

On Sep 22, 2017 7:20 AM, "Kunde, Brian"  wrote:

Regan,



I do not recall a case where a manufacturer completely removed a
certification, but I have seen the following scenarios:



1.   Where a certification will change, such as from the separate UL
 and CSA marks to a joined cULus or cCSAus mark. I’ve also seen marks
change from one agency to another like TUV:SUD to VDE or TUV Rheinland,
etc..

2.   Suppliers will notify us of a change in the standard that a part
is evaluated to or the test levels in which a part is specified for. One
example I recall is an opto-isolator where the manufacturer re-specified
the dielectric strength of the part due to a change in the standard they
use.  This flagged our R&D department to re-evaluate the part in the
application.

3.   The most common and recent change we had to deal with is where a
supplier first claims their parts to be RoHS-EU compliant. This is usually
done without any change to the part number. For us, how do we separate old
stock (where RoHS is questionable) from new stock? We had to make sure we
used up old stock prior to our declarations of RoHS or purge old stock
parts to insure we are using RoHS compliant parts.



I hope this was helpful.



The Other Brian



*From:* Regan Arndt [mailto:reganar...@gmail.com]
*Sent:* Friday, September 22, 2017 9:48 AM
*To:* Kunde, Brian
*Cc:* EMC-PSTC@listserv.ieee.org
*Subject:* [BULK] Re: [PSES] Safety critical component part #'s and Agency
approvals
*Importance:* Low



Thanks Brian. That's great you do this.

Can you share any examples of where they have removed agencies but still
retained the same part #?





On Sep 22, 2017 5:43 AM, "Kunde, Brian"  wrote:

We address this possible issue in two ways.



1.   We list the certification markings that are on Safety Critical
Components on our purchase print as “incoming inspection requirements”.
When parts are received, our IQA department visually verifies that the
certification markings on the parts match the print. If they are different,
the parts are rejected until this issues has been resolved (possible the
manufacturer changed the certification body, etc.).

2.   The purchase print also has a statement that says that the
supplier must notify us in advance of any changes to the part including
regulatory certifications and status. The purchase print is a type of
contract between the supplier and the purchasing company.

3.   Our Compliance Department performs Production Audits (usually on
an annual bases) on all families of products. During these audits, all
safety critical components are verified that they are what they are
supposed to be and verifies the certification markings.  The certification
markings is also a type of contract or declaration from the manufacturer.



Datasheets and pages from the manufacturer’s catalog that shows
certification marks, symbols, or a list of standards are really meaningless
and as others have already pointed out this information can change without
warning.



The Other Brian



*From:* Regan Arndt [mailto:reganar...@gmail.com]
*Sent:* Thursday, September 21, 2017 4:39 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] Safety critical component part #'s and Agency approvals



Greetings everyone,



My experience in regulatory compliance dates back to 1994 where it was a
foregone conclusion that most component manufacturers did not identify
their agency certification as a unique identifier in their part number.



I have seen some good progress over the years, but I also believe that the
industry still continues to eliminate redundant certification (due to
standards harmonization) or sometimes complete agency certification (for
the sake of cost reduction) on components without changing their respective
part number. Or even worse, continue to advertise that the component is
approved but in reality, it is not.



Has anyone experienced anything recently that they wish to share?



P.S. I am updating my old safety presentation and need some good examples
before I present again to our local IEEE chapter meeting.



Thanks for sharing whatever you can. (privately or within this forum)



Cheers!

Regan

-


This message is from the IEEE Product Safety Engineering Society emc-pstc
discussion list. To post a message to the list, send your e-mail to <
emc-p...@ieee.org>

All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at
http://product-compliance.oc.ieee.org/ can be used for graphics (in
well-used formats), large files, etc.

Website: http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.

Re: [PSES] Safety critical component part #'s and Agency approvals

[Regan Arndt]

Thanks Brian. That's great you do this.
Can you share any examples of where they have removed agencies but still
retained the same part #?


On Sep 22, 2017 5:43 AM, "Kunde, Brian"  wrote:

We address this possible issue in two ways.



1.   We list the certification markings that are on Safety Critical
Components on our purchase print as “incoming inspection requirements”.
When parts are received, our IQA department visually verifies that the
certification markings on the parts match the print. If they are different,
the parts are rejected until this issues has been resolved (possible the
manufacturer changed the certification body, etc.).

2.   The purchase print also has a statement that says that the
supplier must notify us in advance of any changes to the part including
regulatory certifications and status. The purchase print is a type of
contract between the supplier and the purchasing company.

3.   Our Compliance Department performs Production Audits (usually on
an annual bases) on all families of products. During these audits, all
safety critical components are verified that they are what they are
supposed to be and verifies the certification markings.  The certification
markings is also a type of contract or declaration from the manufacturer.



Datasheets and pages from the manufacturer’s catalog that shows
certification marks, symbols, or a list of standards are really meaningless
and as others have already pointed out this information can change without
warning.



The Other Brian



*From:* Regan Arndt [mailto:reganar...@gmail.com]
*Sent:* Thursday, September 21, 2017 4:39 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] Safety critical component part #'s and Agency approvals



Greetings everyone,



My experience in regulatory compliance dates back to 1994 where it was a
foregone conclusion that most component manufacturers did not identify
their agency certification as a unique identifier in their part number.



I have seen some good progress over the years, but I also believe that the
industry still continues to eliminate redundant certification (due to
standards harmonization) or sometimes complete agency certification (for
the sake of cost reduction) on components without changing their respective
part number. Or even worse, continue to advertise that the component is
approved but in reality, it is not.



Has anyone experienced anything recently that they wish to share?



P.S. I am updating my old safety presentation and need some good examples
before I present again to our local IEEE chapter meeting.



Thanks for sharing whatever you can. (privately or within this forum)



Cheers!

Regan

-


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discussion list. To post a message to the list, send your e-mail to <
emc-p...@ieee.org>

All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at
http://product-compliance.oc.ieee.org/ can be used for graphics (in
well-used formats), large files, etc.

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-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send yo

[PSES] Safety critical component part #'s and Agency approvals

[Regan Arndt]

Greetings everyone,


My experience in regulatory compliance dates back to 1994 where it was a
foregone conclusion that most component manufacturers did not identify
their agency certification as a unique identifier in their part number.


I have seen some good progress over the years, but I also believe that the
industry still continues to eliminate redundant certification (due to
standards harmonization) or sometimes complete agency certification (for
the sake of cost reduction) on components without changing their respective
part number. Or even worse, continue to advertise that the component is
approved but in reality, it is not.


Has anyone experienced anything recently that they wish to share?


P.S. I am updating my old safety presentation and need some good examples
before I present again to our local IEEE chapter meeting.



Thanks for sharing whatever you can. (privately or within this forum)



Cheers!

Regan

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] EMC co-location distance question

[Regan Arndt]

Thanks to everyone who chimed in. Much appreciated!

From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, March 09, 2017 12:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC co-location distance question

Here is the problem with the ‘2 dB rule’.  If there are only two ports it 
simply makes more sense to cable the ports.  If the device passes, go no 
further.  If you only fill one port, then you have to still fill the remaining 
port to meet the 2dB rule, even if it passes.  So, why waste the time?
The 2dB rule is basically meant for those systems having many identical ports.

The same reasoning can be applied to adding identical modules.  If a host only 
has the capacity of two identical modules, you will need to put both modules in 
and test once.  If you use the 2dB rule for identical modules, you test one 
host with one module, then you must still add the second identical module to 
meet the 2dB rule.  Again, why waste the time – test both, get done.

The 2dB rule in both scenarios is still for those instances where many of the 
same identical modules or ports are used in a single host’; but then it appears 
no one defines what “many” means.  In that case, put one module in, then put 
the second.  If no more than 2dB is seen, test done; if more than 2dB put the 
third in.  If still more than 2dB keep going till all modules are in place or 
no more than 2dB increase seen.

​Thanks
Dennis Ward
This communication and its attachements contain information from PCTEST 
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or attachments(s) are free from computer virus or other defect.  Thank you.

From: Bill Stumpf [mailto:bstu...@dlsemc.com]
Sent: Thursday, March 9, 2017 11:26 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EMC co-location distance question

Right - ANSI C63.4 still makes reference to the "2dB rule"

Bill

From: Adam Dixon [mailto:lanterna.viri...@gmail.com]
Sent: Thursday, March 09, 2017 1:03 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EMC co-location distance question

It's been awhile, but at the time when wanting to understand modular test 
requirements, the 2dB asymptote/leveling off  was a reference in FCC Part 15 
Section 15.31 (a) (3)  pointing to ANSI C63.4-2003.
Regards,
Adam in Atlanta

On Thu, Mar 9, 2017 at 1:16 PM, Sundstrom, Mike 
mailto:mike.sundst...@garmin.com>> wrote:
Regan,
In regards to the daisy chaining:
Hook up equipment (daisy chaining) until such a time as you don’t get a 2 dB 
increase of any unwanted signals. I think this is in ANSI or CISPR?
Everyone,
What am I remembering partly here?


Thanks,

Michael Sundstrom
Garmin Compliance Engineer
2-2606
(913) 440-1540
KB5UKT

"We call it theory when we know much about something but nothing works,
and practice when everything works but nobody knows why."  -- Albert 
Einstein

From: Regan Arndt [mailto:re...@empowermicro.com<mailto:re...@empowermicro.com>]
Sent: Thursday, March 09, 2017 11:50 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EMC co-location distance question

Hi Bill. Thanks for this great info! Much appreciated.

The second part of my original email was merely philosophical discussion 
points. Let me clarify. I would love to hear what people think:


1. How many different types of ancillary equipment shall you test with your 
main EUT? i.e. PCs or laptops with HDMI & USB ports……the sky’s the limit as to 
the myriad of devices that now can be connected. Where does one ‘stop’?

a. Also, not all devices (that claim to be Class B) are noise free. I’ve 
personally experienced extremely noisy devices using a reputable brand name 
(yes, FCC logo on the device), but had to exchange it for their competitor to 
ensure no unintentional emissions, so my main EUT passes. (Moral of the 
story….don’t believe everything you read on the label – lol)


2. Another related question: what about identical devices that can be daisy 
chained? i.e. some devices allow a daisy chain of up to 12 or more. (i.e. 
telecom trunk card). Does one use the chamber table as the determination for 
the quantity of daisy chained samples to test? Or does one compile all the max 
# of daisy chained devices on the table despite the congestion of I/O & power 
cables (not recommended)? Or is there a rule of thumb that one shall prove that 
t

Re: [PSES] EMC co-location distance question

[Regan Arndt]

Hi Bill. Thanks for this great info! Much appreciated.

The second part of my original email was merely philosophical discussion 
points. Let me clarify. I would love to hear what people think:


1. How many different types of ancillary equipment shall you test with your 
main EUT? i.e. PCs or laptops with HDMI & USB ports..the sky's the limit as 
to the myriad of devices that now can be connected. Where does one 'stop'?

a. Also, not all devices (that claim to be Class B) are noise free. I've 
personally experienced extremely noisy devices using a reputable brand name 
(yes, FCC logo on the device), but had to exchange it for their competitor to 
ensure no unintentional emissions, so my main EUT passes. (Moral of the 
storydon't believe everything you read on the label - lol)


2. Another related question: what about identical devices that can be daisy 
chained? i.e. some devices allow a daisy chain of up to 12 or more. (i.e. 
telecom trunk card). Does one use the chamber table as the determination for 
the quantity of daisy chained samples to test? Or does one compile all the max 
# of daisy chained devices on the table despite the congestion of I/O & power 
cables (not recommended)? Or is there a rule of thumb that one shall prove that 
there will not be an increase in emissions past a certain number of devices? 
(The latter is my preference).

Thoughts?

From: Bill Stumpf [mailto:bstu...@dlsemc.com]
Sent: Thursday, March 09, 2017 6:54 AM
To: Regan Arndt ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: EMC co-location distance question

Regan,
I'm not sure I understand your question correctly, but I will try to provide an 
answer.  ANSI C63.4 is used when testing for FCC part 15 subpart B compliance 
for unintentional radiators. When testing a table-top system, the collocated 
equipment should be spaced at 10cm, unless this is not typical of normal 
operation. If so, then the EUT and its accessories/peripheral devices should be 
placed as they would be in typical applications.  It is important to read the 
text of the ANSI standard, as it goes into great detail on how to set up and 
select accessories for testing.  The drawings are for general reference only 
and the text always takes precedence. As for EN/CISPR standards, they mostly 
accept similar setup conditions to ANSI C63.4, but you will have to verify the 
specific requirements in each standard.   The <20cm you refer to was at one 
time unofficially (FCC) considered the distance for collocation of transmitter 
antennas, but this is no longer the case.  The FCC considers that two 
transmitters/antennas are collocated if they are in the same product / 
enclosure.  I hope this helps.

Bill

From: Regan Arndt [mailto:re...@empowermicro.com]
Sent: Wednesday, March 08, 2017 1:50 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] EMC co-location distance question

Greetings members,

Can anyone shed any light on what ANSI defines as the max distance/limit of a 
'co-located' piece of ancillary equipment or other support equipment (on the 
table) to the main EUT being tested for FCC Part 15 class B for 'unintentional 
radiators'. I seem to recall 20 cm but I think this was referring to 
'intentional' radiators.

Is there a similar requirement in the EMC directive and/or EN/CISPR standards? 
Or is this really dictated on your recommended set-up? Shall that device be 
removed from the test bed if typical installation indicates that it will be 
greater than 20cm from the main EUT?

I believe that the set-up in ANSI only showed the PC, printer, mouse, keyboard 
& monitor but that's it. There are so many other/different electronic devices 
that connect to a laptop/PC/other, etc. (i.e. smart phone) these days, it is 
not viable for anyone to test all devices/configurations. I understand that one 
must use good judgment and exercise due diligence but there must be a limit. 
Agree? Some of these electronic devices state compliance to Class B, it may 
still have interference with another closely co-located device because they did 
not test it fully to the myriad of other electronic devices out there that it 
could be connected to. There is no guarantee per se.

Can anyone comment? Thanks in advance.

Regan

-


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
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Website: http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including h

[PSES] EMC co-location distance question

[Regan Arndt]

Greetings members,

Can anyone shed any light on what ANSI defines as the max distance/limit of a 
'co-located' piece of ancillary equipment or other support equipment (on the 
table) to the main EUT being tested for FCC Part 15 class B for 'unintentional 
radiators'. I seem to recall 20 cm but I think this was referring to 
'intentional' radiators.

Is there a similar requirement in the EMC directive and/or EN/CISPR standards? 
Or is this really dictated on your recommended set-up? Shall that device be 
removed from the test bed if typical installation indicates that it will be 
greater than 20cm from the main EUT?

I believe that the set-up in ANSI only showed the PC, printer, mouse, keyboard 
& monitor but that's it. There are so many other/different electronic devices 
that connect to a laptop/PC/other, etc. (i.e. smart phone) these days, it is 
not viable for anyone to test all devices/configurations. I understand that one 
must use good judgment and exercise due diligence but there must be a limit. 
Agree? Some of these electronic devices state compliance to Class B, it may 
still have interference with another closely co-located device because they did 
not test it fully to the myriad of other electronic devices out there that it 
could be connected to. There is no guarantee per se.

Can anyone comment? Thanks in advance.

Regan


-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
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Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] RoHS and renewable energy

[Regan Arndt]

Very interesting Brian. Noted. Thanks. I wonder if any of these Import 
authorities actually read the directives?? :P
Perhaps they read itbut do they really understand it?! - I think they may 
likely have an algorithm cheat sheet at best..
Renewable energy products should have some relaxation as they are (in a sense) 
contributing to a greener world.

We definitely live in a bureaucratic world...
Regan

-Original Message-
From: Brian O'Connell [mailto:oconne...@tamuracorp.com] 
Sent: Tuesday, February 21, 2017 10:23 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS and renewable energy

Mr. Woodgate is offering a rational interpretation in the face of an 
inconsistent and confused bureaucracy. The problem is that the import 
authorities may or may not agree for all cases of related equipment. Depending 
on the particular state’s import authorities and the particular equipment being 
imported, they have previously disallowed the RoHS ‘exemption’ for inverters 
and/or combiner boxes; and one such rejected assembly had a combiner box that 
was attached to a PV Panel. 

Confused in an anomalous wet desert,
Brian


From: John Woodgate [mailto:jmw1...@btinternet.com]
Sent: Monday, February 20, 2017 1:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS and renewable energy

I agree with your interpretation. I don't think it means that only an inverter 
specified by type number by the manufacturer of the PV module is exempt. What 
would be the point of such a restriction (not that EU regulations necessarily 
have a point!)?

With best wishes DESIGN IT IN! OOO – Own Opinions Only www.jmwa.demon.co.uk J M 
Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

From: Regan Arndt [mailto:re...@empowermicro.com]
Sent: Monday, February 20, 2017 9:04 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS and renewable energy

Thanks Brian.
 
I cannot find an 'example of' or a 'definition' as to what constitutes 
'specifically designed' within the directive.
 
If I read the exemption clause below, it can be interpreted that 'equipment 
specifically designed' (i.e. micro inverter)..as 'part of another type of 
equipment' (i.e. PV module).
 
Note that a micro inverter (for all intents and purposes) can only be used with 
a PV module and cannot be used with any other device (i.e. computer 
peripheral), thus it could (or at least should) be classified as 'equipment 
specifically designed'. 
 
(c) equipment which is specifically designed, and is to be installed, as part 
of another type of equipment that is excluded or does not fall within the scope 
of this Directive, which can fulfil its function only if it is part of that 
equipment, and which can be replaced only by the same specifically designed 
equipment;
 
Any further help from you directly or from the EMC-PSTC team on obtaining a 
formal clarification is greatly appreciated.
 
Thanks in advance.
 
Regan
 
-Original Message-
From: Brian O'Connell [mailto:oconne...@tamuracorp.com]
Sent: Friday, February 17, 2017 2:44 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS and renewable energy
 
No. Only for panel materials used in the PV film, and is not a system-level 
exemption. By definition, substances and materials specified in the RoHS and 
REACH directives are considered harmful, so no exclusion for materials in other 
stuff.
 
Can you offer an 'acceptable' rationale in your D of C for the import 
authorities?
 
Brian
 
 
From: Regan Arndt [mailto:re...@empowermicro.com]
Sent: Friday, February 17, 2017 2:05 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RoHS and renewable energy
 
Greetings everyone, 
 
Regarding the RoHS recast directive; DIRECTIVE 2011/65/EU OF THE EUROPEAN 
PARLIAMENT AND OF THE COUNCIL of 8 June 2011, on the restriction of the use of 
certain hazardous substances in electrical and electronic equipment (recast) – 
see attached.
 
Article 2 states:
Scope
 
4. This Directive does not apply to:
 
(i)   photovoltaic panels intended to be used in a system that 
is designed, assembled and installed by professionals for permanent use at a 
defined location to produce energy from solar light for public, commercial, 
industrial and residential applications;
 
1.   Does anyone know if this includes micro-inverters?  I 
would assume so as the PV module then becomes an ‘AC PV module’ but maybe not 
….. as there are more RoHS concerning components in a micro-inverter than in a 
DC PV module. 
 
2.   Does this exemption include combiner boxes? Does the 
exemption include String inverters? Rest of the BOS? I would assume so as it 
also states:
 
(c) equipment which is specifically designed, and is to be installed, as part 
of another type of equipment that is excluded or does not fall within the scope 
of this Directive, which can fulfil its funct

Re: [PSES] RoHS and renewable energy

[Regan Arndt]

Thanks Brian.

I cannot find an 'example of' or a 'definition' as to what constitutes 
'specifically designed' within the directive.

If I read the exemption clause below, it can be interpreted that 'equipment 
specifically designed' (i.e. micro inverter)..as 'part of another type of 
equipment' (i.e. PV module).

Note that a micro inverter (for all intents and purposes) can only be used with 
a PV module and cannot be used with any other device (i.e. computer 
peripheral), thus it could (or at least should) be classified as 'equipment 
specifically designed'.

(c) equipment which is specifically designed, and is to be installed, as part 
of another type of equipment that is excluded or does not fall within the scope 
of this Directive, which can fulfil its function only if it is part of that 
equipment, and which can be replaced only by the same specifically designed 
equipment;

Any further help from you directly or from the EMC-PSTC team on obtaining a 
formal clarification is greatly appreciated.

Thanks in advance.

Regan

-Original Message-
From: Brian O'Connell [mailto:oconne...@tamuracorp.com]
Sent: Friday, February 17, 2017 2:44 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS and renewable energy

No. Only for panel materials used in the PV film, and is not a system-level 
exemption. By definition, substances and materials specified in the RoHS and 
REACH directives are considered harmful, so no exclusion for materials in other 
stuff.

Can you offer an 'acceptable' rationale in your D of C for the import 
authorities?

Brian


From: Regan Arndt [mailto:re...@empowermicro.com]
Sent: Friday, February 17, 2017 2:05 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] RoHS and renewable energy

Greetings everyone,

Regarding the RoHS recast directive; DIRECTIVE 2011/65/EU OF THE EUROPEAN 
PARLIAMENT AND OF THE COUNCIL of 8 June 2011, on the restriction of the use of 
certain hazardous substances in electrical and electronic equipment (recast) – 
see attached.

Article 2 states:
Scope

4. This Directive does not apply to:

(i)   photovoltaic panels intended to be used in a system that 
is designed, assembled and installed by professionals for permanent use at a 
defined location to produce energy from solar light for public, commercial, 
industrial and residential applications;

1.   Does anyone know if this includes micro-inverters?  I 
would assume so as the PV module then becomes an ‘AC PV module’ but maybe not 
….. as there are more RoHS concerning components in a micro-inverter than in a 
DC PV module.

2.   Does this exemption include combiner boxes? Does the 
exemption include String inverters? Rest of the BOS? I would assume so as it 
also states:

(c) equipment which is specifically designed, and is to be installed, as part 
of another type of equipment that is excluded or does not fall within the scope 
of this Directive, which can fulfil its function only if it is part of that 
equipment, and which can be replaced only by the same specifically designed 
equipment;

Most installations do not have such specific restrictions on the usage of which 
inverters are to be used for DC panels, etc.

The directive does mention the following:
(17) The development of renewable forms of energy is one of the Union’s key 
objectives, and the contribution made by renewable energy sources to 
environmental and climate objectives is crucial. Directive 2009/28/EC of the 
European Parliament and of the Council of 23 April 2009 on the promotion of the 
use of energy from renewable sources ( 4 ) recalls that there should be 
coherence between those objectives and other Union environmental legislation. 
Consequently, this Directive should not prevent the development of renewable 
energy technologies that have no negative impact on health and the environment 
and that are sustainable and economically viable.

Can someone interpret the bold underlined statement above? It leads to a vague 
interpretation me thinks.

Thanks in advance.

Regan Arndt

-

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[PSES] RoHS and renewable energy

[Regan Arndt]

Greetings everyone,

Regarding the RoHS recast directive; DIRECTIVE 2011/65/EU OF THE EUROPEAN 
PARLIAMENT AND OF THE COUNCIL of 8 June 2011, on the restriction of the use of 
certain hazardous substances in electrical and electronic equipment (recast) – 
see attached.


Article 2 states:
Scope

4. This Directive does not apply to:



(i)   photovoltaic panels intended to be used in a system that 
is designed, assembled and installed by professionals for permanent use at a 
defined location to produce energy from solar light for public, commercial, 
industrial and residential applications;


1.   Does anyone know if this includes micro-inverters?  I 
would assume so as the PV module then becomes an ‘AC PV module’ but maybe not 
….. as there are more RoHS concerning components in a micro-inverter than in a 
DC PV module.


2.   Does this exemption include combiner boxes? Does the 
exemption include String inverters? Rest of the BOS? I would assume so as it 
also states:

(c) equipment which is specifically designed, and is to be installed, as part 
of another type of equipment that is excluded or does not fall within the scope 
of this Directive, which can fulfil its function only if it is part of that 
equipment, and which can be replaced only by the same specifically designed 
equipment;

Most installations do not have such specific restrictions on the usage of which 
inverters are to be used for DC panels, etc.


The directive does mention the following:
(17) The development of renewable forms of energy is one of the Union’s key 
objectives, and the contribution made by renewable energy sources to 
environmental and climate objectives is crucial. Directive 2009/28/EC of the 
European Parliament and of the Council of 23 April 2009 on the promotion of the 
use of energy from renewable sources ( 4 ) recalls that there should be 
coherence between those objectives and other Union environmental legislation. 
Consequently, this Directive should not prevent the development of renewable 
energy technologies that have no negative impact on health and the environment 
and that are sustainable and economically viable.

Can someone interpret the bold underlined statement above? It leads to a vague 
interpretation me thinks.

Thanks in advance.

Regan Arndt


-

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Re: [PSES] [RFI] Part 15 isn't enough..

[Regan Arndt]

Check out this free download (google it): “Electronic Systems Failures & 
Anomalies Attributed to EMI” NASA Reference Publication 1374 issued in 1995.

You’d think we would have learned our lesson by now……

Regardless, it’s still all about the mighty dollar with no regard to human 
life. (unfortunately).

Check out section 2.3.3 – 6 deaths due to medical device EMI problems.



As for the New Jersey incident. It could have been prevented. It was just too 
costly…..until now.

http://www.cnn.com/2016/09/29/us/new-jersey-hoboken-train-safety/index.html



Regan Arndt

From: dward [mailto:dw...@pctestlab.com]
Sent: Thursday, September 29, 2016 4:15 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

As to John’s comment about the train wreck in the US, try looking at the so 
called safety record of train travel in the EU.  Wrecksin Spin killed 4 injured 
49, recent wrecks in Germany killed 30 injured many more.  Spain, France, UK, 
Germany, Italy, Netherlands on and on it goes.  So, John’s analogy of train 
wrecks and so called safety regulations simply does not hold water.


On Sep 29, 2016, at 3:19 PM, Ghery S. Pettit 
mailto:n6...@comcast.net>> wrote:

Immunity testing is required in the EU, South Korea and China.  Nowhere else in 
the world is it required for commercial products.  I’d say that the US is in 
the “real world”.

Ghery S. Pettit

From: Ken Javor [mailto:ken.ja...@emccompliance.com]
Sent: Thursday, September 29, 2016 3:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@listserv.ieee.org>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Without getting into the specifics of this particular argument, the idea that 
the “rest of the world” has dome something doesn’t necessarily imply that North 
America is “behind.”  In the same sense that if a train has derailed and the 
locomotive is headed over a cliff, we don’t say the caboose is behind and needs 
to catch up.

Ken Javor
Phone: (256) 650-5261



From: john Allen 
mailto:john_e_al...@blueyonder.co.uk>>
Reply-To: john Allen 
mailto:john_e_al...@blueyonder.co.uk>>
Date: Thu, 29 Sep 2016 22:44:48 +0100
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dennis

I really  do wonder what World you live in – but then, TBH, based on your 
previous comments of a similar nature, I did not expect anything else!

OK, Government “interference” is unwelcome in many cases but Brian O’Connell’s 
post is a  poignant “real world”  comment on what suppliers are facing, and 
what the Government should face up to and address – for the greater good of 
everyone in YOUR country.

Without getting trying to “personal”,  “get real”! - a lot of the rest of the 
“real world” has already adopted appropriate requirements to try to prevent 
undue interference problems and so N. America is behind on this issue.

John E Allen.
W. London, UK


From: dward [mailto:dw...@pctestlab.com]
Sent: 29 September 2016 22:28
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

The federal government already interferes with US citizens far too much as it 
is – we do not need, nor do most of us want more federal intrusion.  The feds 
are there to keep the wolves at bay and keep out of our lives.  Besides, the 
open market in the US seems to take care of itself in the interference area.  
Does not take long for the consumer to know what is trash and what works.
The only regulations dealing with the spectrum that is needed is the regulation 
to help stop interference to licensed services. That was the intent of the FCC 
to start and there is no reason to change it.



​
Dennis Ward
This communication and its attachements contain information from PCTEST 
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or attachments(s) are free from computer virus or other defect.  Thank you.


From: john Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Thursday, September 29, 2016 2:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dennis

And why not – seriously?

As was said many years ago – and often repeated! - “what’s right for the goose 
is right for the gander”.

In this case (and many others) In simple terms, that means that implies that 
electronic devices need to be approp

Re: [PSES] 10G base-T ethernet EMC test setup question

[Regan Arndt]

I remember taking a class from Professor Brian O'Connell. ;) (P.S. I sat in the 
front row). He said something of the following:

1. describe the end-use environment of your equipment.
2. specify the EMC standards that will be scoped for your equipment.
3. describe how the component or assembly will be used in your equipment.
4. describe how you will affect the transfer of large burritos and fine ale to 
helpful members of the tribe.

Regan

-Original Message-
From: Tesla [mailto:emc...@126.com] 
Sent: Friday, September 09, 2016 1:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 10G base-T ethernet EMC test setup question

Hi, EMC experts

We are doing 10G base-T ethernet reference design for the test chip. My first 
task is to do radiated emission test. 
I have two very basic questions for the setup:
1 How long CAT-6 ether net cable should be attached to the DUT when doing 
emission test? in the actual application, any length cable can be installed in 
the our ethernet device
2 What is the upper frequency of the radiated emission test? the on board clock 
is 156MHz, The upper frequency should be 2000MHz?

Thanks and Regards.

Tesla

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Re: [PSES] EMC & its role in reliability

[Regan Arndt]

Thanks Brian. Yes, correction/clarificationnot HALT per se, but 
'Reliability forecast' testing/calculations, etc. ...i.e. crystal ball.'How 
long will it last in the field?'
The 'HALT' acronym is commonly overused/misstated.my bad. ;)

-Original Message-
From: Brian O'Connell [mailto:oconne...@tamuracorp.com] 
Sent: Wednesday, August 24, 2016 4:50 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC & its role in reliability

'Pure' HALT is a different animal and not intended to be an MTTF or MTBF 
indicator or calculator, and has no affect to M-HB-217 calculations (although 
SR322 does allow HALT/HASS to affect the system-level number). The test method 
used is to enable one to rapidly find the most weak points in the design. HALT 
test conditions are relatively short and not necessarily related to life 
acceleration per the Arrhenius equation. HALT, as a name, is not correct in 
either intent or effect. A HALT-type test method used for EMC would be 
effective for rapidly finding the system's immunity limits for various 
well-defined operating conditions. 

Methinks what you may be looking for is the EMC functional equivalent of a 
thermal/humidity burn-in chamber; that is, continuous and long-term operations 
while subjecting the unit to its rated susceptibility limits. And do not know 
if hi EM radiation at the rated levels would actually stress most stuff if 
under ionizing level.

All engineers should be part of a HALT project at least once. Good Stuff.

Brian

From: Regan Arndt [mailto:re...@empowermicro.com]
Sent: Wednesday, August 24, 2016 4:03 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC & its role in reliability

Thanks Doug! Appreciate the offer!

Here’s some more thought provoking questions……….

If an electronic device that has currently passed its initial IEC radiated 
immunity testing, will it eventually fail over time if it is exposed to a 
longer timeframe with the same level of radiation?
My guess is yes. What would that timeframe look like? Hmmm…..
Then there is ESD, Surge, etc. to also look at.
Most HALT testing is environmental chamber based and perhaps there should be 
something similar developed for EMI?
Has any testing (i.e. test to failure) like this been done before?

Regan

From: Douglas Nix [mailto:d...@mac.com]
Sent: Wednesday, August 24, 2016 4:19 AM
To: Regan Arndt 
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC & its role in reliability

Regan,

There has been a lot of work going on at the IET in this topic, starting with 
the first Guide published a couple of years ago (happy to share a copy with 
anyone who wants one, it's free), and one to the new guide that is about to be 
published. 

This is a significant and important topic and needs discussion. I am definitely 
supportive of this idea!

Sent from my iPhone
Doug Nix

d...@mac.com
Mobile: (519) 729-5704

On Aug 23, 2016, at 19:38, Regan Arndt  wrote:
Greetings EMC-PSTC members..
 
I am trying to help decide if Electromagnetic Immunity/emissions could be a 
potential good topic of discussion at next year's NREL PV reliability 
conference.
Does anyone have any field data, whitepapers, research info (not just for PV 
modules/inverters, but anything) to show possible degradation of EMC 
components/performance over time?
 
Thanks in advance for sharing.
 
Best regards,
 
   Regan Arndt
   Sr. Compliance Engineer
   Empower Micro Systems, Inc.
   2989 Copper Road, Santa Clara 95051
   408-641-5688

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Re: [PSES] EMC & its role in reliability

[Regan Arndt]

Thanks Doug! Appreciate the offer!

Here’s some more thought provoking questions……….

If an electronic device that has currently passed its initial IEC radiated 
immunity testing, will it eventually fail over time if it is exposed to a 
longer timeframe with the same level of radiation?
My guess is yes. What would that timeframe look like? Hmmm…..
Then there is ESD, Surge, etc. to also look at.
Most HALT testing is environmental chamber based and perhaps there should be 
something similar developed for EMI?
Has any testing (i.e. test to failure) like this been done before?

Regan

From: Douglas Nix [mailto:d...@mac.com]
Sent: Wednesday, August 24, 2016 4:19 AM
To: Regan Arndt 
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC & its role in reliability

Regan,

There has been a lot of work going on at the IET in this topic, starting with 
the first Guide published a couple of years ago (happy to share a copy with 
anyone who wants one, it's free), and one to the new guide that is about to be 
published.

This is a significant and important topic and needs discussion. I am definitely 
supportive of this idea!

Sent from my iPhone
Doug Nix

d...@mac.com<mailto:d...@mac.com>
Mobile: (519) 729-5704

On Aug 23, 2016, at 19:38, Regan Arndt 
mailto:re...@empowermicro.com>> wrote:
Greetings EMC-PSTC members..

I am trying to help decide if Electromagnetic Immunity/emissions could be a 
potential good topic of discussion at next year's NREL PV reliability 
conference.
Does anyone have any field data, whitepapers, research info (not just for PV 
modules/inverters, but anything) to show possible degradation of EMC 
components/performance over time?

Thanks in advance for sharing.

Best regards,

   Regan Arndt
   Sr. Compliance Engineer
   Empower Micro Systems, Inc.
   2989 Copper Road, Santa Clara 95051
   408-641-5688



-


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[PSES] EMC & its role in reliability

[Regan Arndt]

Greetings EMC-PSTC members..

I am trying to help decide if Electromagnetic Immunity/emissions could be a 
potential good topic of discussion at next year's NREL PV reliability 
conference.
Does anyone have any field data, whitepapers, research info (not just for PV 
modules/inverters, but anything) to show possible degradation of EMC 
components/performance over time?

Thanks in advance for sharing.

Best regards,

   Regan Arndt
   Sr. Compliance Engineer
   Empower Micro Systems, Inc.
   2989 Copper Road, Santa Clara 95051
   408-641-5688




-

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Re: [PSES] CE-EMC on Submersible Product

[Regan Arndt]

Excerpt from Marine directive:
COMMISSION DECISION of 1 September 2010 on criteria and methodological 
standards on good environmental status of marine waters (notified under 
document C(2010) 5956) (Text with EEA relevance) (2010/477/EU)

Descriptor 11: Introduction of energy, including underwater noise, is at levels 
that do not adversely affect the marine
environment.
Together with underwater noise, which is highlighted throughout Directive 
2008/56/EC, other forms of energy input have
the potential to impact on components of marine ecosystems, such as thermal 
energy, electromagnetic fields and light.
Additional scientific and technical progress is still required to support the 
further development of criteria related to this
descriptor (22), including in relation to impacts of introduction of energy on 
marine life, relevant noise and frequency
levels (which may need to be adapted, where appropriate, subject to the 
requirement of regional cooperation). At the
current stage, the main orientations for the measurement of underwater noise 
have been identified as a first priority in
relation to assessment and monitoring (23), subject to further development, 
including in relation to mapping. Anthropogenic
sounds may be of short duration (e.g. impulsive such as from seismic surveys 
and piling for wind farms and
platforms, as well as explosions) or be long lasting (e.g. continuous such as 
dredging, shipping and energy installations)
affecting organisms in different ways. Most commercial activities entailing 
high level noise levels affecting relatively broad
areas are executed under regulated conditions subject to a license. This 
creates the opportunity for coordinating coherent
requirements for measuring such loud impulsive sounds.
11.1. Distribution in time and place of loud, low and mid frequency impulsive 
sounds
- Proportion of days and their distribution within a calendar year over areas 
of a determined surface, as well as
their spatial distribution, in which anthropogenic sound sources exceed levels 
that are likely to entail significant
impact on marine animals measured as Sound Exposure Level (in dB re 1μPa2.s) or 
as peak sound pressure level
(in dB re 1μPapeak) at one metre, measured over the frequency band 10 Hz to 10 
kHz (11.1.1)
11.2. Continuous low frequency sound
- Trends in the ambient noise level within the 1/3 octave bands 63 and 125 Hz 
(centre frequency) (re 1μΡa RMS;
average noise level in these octave bands over a year) measured by observation 
stations and/or with the use of
models if appropriate (11.2.1).

Hope this helps somewhat.

Regan Arndt

-Original Message-
From: T.Sato [mailto:vef00...@nifty.com]
Sent: Wednesday, May 18, 2016 3:47 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE-EMC on Submersible Product

On Wed, 18 May 2016 21:19:00 +,
  John Allen 
mailto:jral...@productsafetyinc.com>> wrote:

> I would like to get thoughts on if EMC testing is required for CE on a 
> product that does generate noise, but is installed 30 feet below the surface 
> of water.
>
> I'm guessing conducted radiation is still a concern, but what about radiated 
> and immunity??  Does it matter if it's 30 feet below or 3 feet??

If the attenuation data in

  http://file.scirp.org/pdf/JEMAA2011071_18390291.pdf
  Electromagnetic Wave Propagation into Fresh Water

is appicable, for 30 MHz, about -10 dB attenuation may be expected at
10 m, which may not enough to ignore radiated emissions and immunities.

In addition, some RF may propagate up/down through the cable.

I guess radiated emissions/immunities can still a matter.

Regards,
Tom

--
Tomonori Sato  mailto:vef00...@nifty.com>>
URL: http://t-sato.in.coocan.jp

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RE: Implanted IC in brain

[Regan Arndt]

I hope that this era falls into the category of medical equipment using IEC 
601.
I hate to see 950 get rearranged again.  I experienced enough grief with 225 
being assimilated into 950.  


Regan Arndt
ITE & Telecomm Safety Specialist



From: "Kazimier Gawrzyjal" 
Reply-To: "Kazimier Gawrzyjal" 
To: "'Mel Pedersen'" ,"'Barry Ma'" 
, EMC-PSTC 

Subject: RE: Implanted IC in brain
Date: Thu, 13 Jul 2000 13:55:55 -0400

Greetings,

Interesting topic

Personally if forced to choose, I'd place my money on the recent advances
announced by the genetics community to get my great-grand kids to the
"enhanced" state of humanity as opposed to a chip set in the old
noodlemy thoughts will continue to be my own and not accessible by the
crackers of tomorrow via the wireless web concept.

Seems some form of operating system would be required to get the web
interface runninganyone have that much faith in the existing options
today as to load up some software in your noggin??  Hopefully airline 
pilots
will be excluded from this vision of the future else face at least one 
crash

per week.Can you go to "Bob's Headshop" for some aftermarket knock-off
parts?

Does UL 1950 cl. 1.1.2 and 1.1.3 allow for added abnormals?

My 2 Cents and not those of my current employer.
Kaz Gawrzyjal
Safety Guy
nortel networks
k...@nortelnetworks.com
k...@hotmail.com

-Original Message-
From: Mel Pedersen [mailto:mpeder...@midcom-inc.com]
Sent: Thursday, July 13, 2000 10:54 AM
To: 'Barry Ma'; EMC-PSTC
Subject: RE: Implanted IC in brain



Hello:

I believe we should consider what precedents the Medical Equipment 
community

has laid out hereat least as a startIEC 60601, FDA regs, etc

these address safety concerns for implanted.

Just my humble thoughts on the matter.

- Mel

-Original Message-
From: Barry Ma [mailto:barry...@altavista.com]
Sent: Wednesday, July 12, 2000 7:14 PM
To: EMC-PSTC
Subject: Implanted IC in brain



Hi,

It seems not a pure friction to implant intelligent IC into human brains.
Some people made prediction about this new breed of human being. Some are
talking about downloading certain virtual sense from Internet. ... Let's 
put

aside the feasibility and focus only on related EMC/Safety concerns.

1. If there going to be a wireless access from human brain to Internet, do
we have the same Safety concern as cellular phone?
2. It would also be possible to directly communicate each other via brain
ICs. We don't have to exchange thoughts by means of any language (spoken 
and

written) or eye contact. ...  Should we have EMC standards to regulate the
emission level of brain waves and immunity capability for brain ICs?

Thanks.
Best Regards,
Barry Ma
ANRITSUwww.anritsu.com
Morgan Hill, CA 95037
Tel. 408-778-2000 x 4465
___

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Thanks!

[Regan Arndt]

  Thanks!  1/14/97

I would like to thank everyone for their comments for the question below.
It was quite a discussion.
I never got around to voice my biased opinion however, so.

Coming on board with regulatory department @ NORTEL was an eye opener with 
respect to the vast amount of information & experience one needed to 
successfully maintain the role of a regulatory compliance tech or engineer.
Therefore the answer to my own question is YES.  If the technical institute 
that I attended offered any instruction involving regulatory compliance, it 
would have made my grueling first two months in the department a little easier, 
thus benefiting my employer as well.

Once again, thanks!
Regan
--
List-Post: emc-pstc@listserv.ieee.org
Date: 12/20/96 8:04 AM
To:
From: Regan Arndt
I would like to ask everyone's opinion on the following subject:

Do you believe that there is a need for students, who are in technical 
institutions & Universities, to participate,  in a course designed towards 
achieving a good working knowledge of regulatory compliance standards as part 
of their cirriculum.
i.e:
Safety (i.e IEC 950, EN60950, etc.),
EMC (CISPR 22, AS/NZS 3548, etc.), &
Network Protection (FCC part 68, IC CS03,etc.)


RVSP

Thanks in advance

Regan Arndt
Safety technologist
NORTEL

Re: EZU Contacts

[Regan Arndt]

  RE>>EZU Contacts 11/20/96

If all else fails try:
Mr. Jan Sedlacek, he is the Director of the Czech
 Telecommunication Office.  42-2-7992-419 fax number 42-2-7936-709
Regan
--
List-Post: emc-pstc@listserv.ieee.org
Date: 11/19/96 7:10 PM
To: Regan Arndt
From: Kathy Toy
   - E X T E R N A L L Y  O R I G I N A T E D  M E S S A G E -

George,

Here is what I have:

CZECH Republic - EZU (Elktrotechnicky zkusebni ustav)
Electrotechnical Testing Institute
Pod lisem 129
171 02 Praha 8 -Traja
Czech Republic

Contact:  Tomas Stary, Technical Director

Tel: +42 2 688 00 71
FAX: +42 2 688 00 37 or 688 00 70


Slovak Republic - EVPU (Elktrotechnicky Vyskumny A Projektovy Ustav
Elektrotechnical Research and Testing Institue
Trencianska 19
018 51 Nava Dubnica
Slovenska Republika

Contact:  Milan Gajdosik (Slovak Testing Centre - SKtC 101)

Tel:  +42 (0)827/247 24
FAX:  +42 (0)827/247 50

Good Luck,
-kt

- Begin Included Message -

>From owner-emc-p...@mail.ieee.org Tue Nov 19 09:08 PST 1996
To: emc-pstc 
From: George Sparacino/UB Networks 
List-Post: emc-pstc@listserv.ieee.org
Date: 19 Nov 96 10:41:43 EDT
Subject: EZU Contacts
Mime-Version: 1.0
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Does anyone have a name & phone/fax # for an english speaking contact at the
EZU in the Czech Republic ?


Thanks,
George Sparacino - PSE



- End Included Message -



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Re: Up-to-date standards

[Regan Arndt]

  RE>>Up-to-date standards 11/15/96

Thanks for the price correction.  I accidently slipped an exta zero on the 
price tag.
Sorry for the mis-conception.
Regan
--
List-Post: emc-pstc@listserv.ieee.org
Date: 11/14/96 3:29 PM
To: Regan Arndt
From: Egon H. Varju
   - E X T E R N A L L Y  O R I G I N A T E D  M E S S A G E -

Regan,

> One pitfall though.  The cost of the CD & it's updates on a quarterly
> basis is approx. $20,000/year. (This includes all the CSA standards)

Actually, the initial purchase cost is only CDN$1,900 (approx US$1,375),
including one year's worth of updates.  Subsequent renewal is CDN$1,295/yr
(approx US$950/yr).  You could easily spend more than that on paper copies, if
you need several standards.

Yes, the CD includes all CSA standards, including Part I (Canadian Electrical
Code), II and III, plus all related bulletins, notices, etc.  A complete printed
set would cost around $11,000.

> I think just getting the paper copy of the ammendaments would be one of a
> less financial strain.

I guess this is a business decision, depending in part on how many standards you
need to access.  If you only use one or two standards, it may be difficult to
justify the cost.  Mind you, I personally REALLY like the search capabilities.
As all these standards get bigger and bigger, it's very nice to be able to
quickly zero in on key words.  I'm so hooked now that I carry the CD with me
everywhere.  :-)

If you're using several standards, you should also consider the hidden costs.
It can take many hours of unproductive work to dig out standards, replace pages,
attachments, etc.  If the number of standards you use is large, it may require a
full-time librarian to keep things up to date (we employ several, in order to
keep up with all the CSA/UL/IEC/ISO and other publications).

By the way, the above prices are for single user.  A network version will be
more expensive, of course, but nowhere near $20,000.  I don't have exact prices
here with me, but I believe a 2 - 5 user version is around CDN$4,200 and a 11 -
20 user version is around CDN$9,500.  Plase note that by "5 user" we mean 5
people accessing the CD simultaneously.

As I mentioned before, you should contact our Standards Sales department for
exact prices.  I've managed to dig up some numbers:

Phone:  1-800-463-6727
Fax:  (416) 747-2475

The CD expert is Mr. Steve Dove:  (416) 747-2635

My apologies to the forum if I've exceeded propriety by blatant advertising, but
this is a REALLY NEAT product, that can save product safety professionals a lot
of time and costs.

__

 Egon H. Varju, P.Eng.  Thursday, 14 November 1996 @ 10:41 AM
 CSA Pacific Region
 Tel:   1-604-244-6640   HAVE MODEM  -  WILL TRAVEL
 Fax:   1-604-244-6600
 E-mail:73132.2...@compuserve.com
var...@csa.ca
__


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Date: 14 Nov 96 14:26:47 EST
From: "Egon H. Varju" <73132.2...@compuserve.com>
To: Regan Arndt 
Cc: Steve Dove , IEEE 
Subject: Re: Up-to-date standards
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Re: Up-to-date standards

[Regan Arndt]

  RE>>Up-to-date standards 11/14/96

One pitfall though.  The cost of the CD & it's updates on a quarterly basis is 
approx. $20,000/year. (This includes all the CSA standards)  I think just 
getting the paper copy of the ammendaments would be one of a less financial 
strain.
Just my 2 cents worth.
Regan Arndt
Safety technologist
Nortel
--
List-Post: emc-pstc@listserv.ieee.org
Date: 11/13/96 8:54 PM
To: Regan Arndt
From: Egon H. Varju
   - E X T E R N A L L Y  O R I G I N A T E D  M E S S A G E -

As far as CSA standards are concerned, it is really easy to make sure your copy
of the latest standards is complete.  All you have to do is to subscribe to the
"CSA E-Code" CD.  The CD includes ALL standards, bulletins, notices, etc.  Every
3 months a complete new, updated CD is sent to you.  No need to waste hours
updating paper copies.  The CD is available as a stand-alone, or network
version.

Nice features include word search capabilities, hypertext, ability to print hard
copies.

Sorry, I don't have the phone numbers handy here with me, but all you have to do
in order to get more details and prices is to phone the nearest CSA office or
agency and ask for "Standards Sales."

Or try CSA's URL:  

Regards,
Egon Varju


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Date: 13 Nov 96 13:35:49 EST
From: "Egon H. Varju" <73132.2...@compuserve.com>
To: "Farnsworth,Heber" 
Cc: IEEE 
Subject: Re: Up-to-date standards
Message-ID: <961113183548_73132._iho9...@compuserve.com>
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Re: standard requirements

[Regan Arndt]

  RE>>standard requirements11/13/96

I have previously contacted the Institute of Telecommunications, (Mr. Tomasz 
Niewodniczanski) & they referred me to Adam Borowski, who is directly involved 
with ITE standards & development @ the "Laboratory of Type Approvals" in 
Warsaw.  Their standard dates from 1993 & is under development @ this time.  
Please call Adam  @ 48 22 128325 or his secretary @ 128323, fax: 128146 for the 
latest updates.
Also note: If you don't speak french or polish, & try to call the Institute of 
Telecommunications, (Mr. Tomasz Niewodniczanski), ask to speak to "Sega" who is 
their translator.
Hope this helps.
Regan Arndt
Safety technologist
Nortel
--
List-Post: emc-pstc@listserv.ieee.org
Date: 11/12/96 6:44 PM
To: Regan Arndt
From: tania.gr...@octel.com
   - E X T E R N A L L Y  O R I G I N A T E D  M E S S A G E -

 Sandy,

 Recent TREG and emc-p...@ieee.org mail shows the following:

 Author:  par...@bangate.compaq.com at P_Internet_mail
 Date:7/25/96  7:57 PM
 Priority: Normal
 BCC: Tania Grant at P_BSD
 TO:  at P_Internet_Mail
 CC:  at P_Internet_Mail
 CC:  at P_Internet_Mail
 Subject: re: Poland and Hungary, Regulatory Requirements
 --- Message Contents
 ---
 Hello Ron,

 Please let me answer at least some of your questions concerning
 Safety, EMC and PTT regulatory requirements in Poland and Hungary.

 1. POLAND
 a) Polish Safety Standard: PN-93/T-42107 [IEC 950 (1991) + Amds. with
minor deviations]. An outside CB Test Report will be accepted, but
samples are required.
Contact: Laboratorium Elektrotechniczne PCBC
Mr. Wiktor Greviennikow
ul. Klobucka 23A
02-699 Warszawa, Poland
Phone: +48 22 47 99 16
Fax: +48 22 47 12 22

 b) Polish EMC/RFI Standard: PN 89/E-06251. EMC/RFI test reports are  
only accepted from a PCBC accredited EMC lab.
Contact: Laboratorium Badawcze ELTEST
 ul. Ratuszowa 11, Room No. 136
 Warszawa, Poland
 Phone: +48 22 19 39 66 (Mr. Marek Jewtuch) or
 Phone: +48 22 18 99 92 (Mr. Edward Rudalski)

 c) Polish PTT approval:
Contact: Institute of Telecommunications
 Mr. Tomasz Niewodniczanski
 ul. Kopernika 11
 51-622 Wroclaw, Poland
 Phone: +48 71 72 88 12
 Fax: +48 71 72 88 78
 
 Author:  "Ray Russell"  at P_Internet_mail
 Date:10/9/96  8:08 AM
 Priority: Normal
 BCC: Tania Grant at P_BSD
 TO: emc-p...@ieee.org at P_Internet_Mail
 TO: Brent Taira <72642.3...@compuserve.com> at P_Internet_Mail
 Subject: Re: Poland Certification
  Message Contents-
  Dear Brent,

  As a former Compliance Engineer for a PC manufacturer, we found 
  that Poland would accept EMI and a CB test report from NEMKO. If
  interested, you might contact:

  Morten Smith
  Phone 47 22 96 03 30
  FAX   47 22 69 86 36.

  I hope this helps,

  Ray Russell

 I hope this helps you, Sandy.  Please note that the ul. abreviation in
 the addresses does not stand for downsized UL but for 'ulitza', meaning
 'street'.

  Tania Grant, Octel Communications Corporation
  tania.gr...@octel.com

__ Reply Separator _
Subject: standard requirements
Author:  "Sandy Florence-ESF003"  at 
P_Internet_mail
List-Post: emc-pstc@listserv.ieee.org
Date:11/12/96 10:27 AM


Does anyone know the ITE test standard requirements for Poland ?

Thanks.

Sandy

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Re: Up-to-date standards

[Regan Arndt]

  RE>Up-to-date standards  11/13/96

Try the Bill Holz seminars.
His e-mail is: 72163.2...@compuserve.com  & phone number is (612) 639-0775.
>From what I hear, his seminars have THE latest up to date info with respect to 
>standards & doesn't try to SELL you any service or product & is constantly 
>presenting seminars on a quarterly basis.
Regan Arndt
Safety technologist
Nortel
--
List-Post: emc-pstc@listserv.ieee.org
Date: 11/13/96 2:25 AM
To: Regan Arndt
From: Farnsworth,Heber
   - E X T E R N A L L Y  O R I G I N A T E D  M E S S A G E -

I am having difficulty keeping track of present and future standards,
and would like people+s ideas. Some of my questions are:

1.  We want to produce a written procedure indicating how we will know
that standards we use are up-to-date and that we have all that are
required. There are some subscription services which take a list of
standards and provide updates as needed. Any other ideas? Anyone know
some good web sites? (some have been mentioned, but not having web
access at the time I didn+t save them.)

Global Engineering has a World-Wide Standards Index, with a program to
compare your list of standards and identify updates. ILI has a similar
product (whoever they are.)

St. Lucie Press, 561-274-9906, has a subscription service for European
Directives which sounds pretty good. For US $95.00 per directive (or
sometimes group of related directives) they+ll send you the current
directive and place you on an order list for revisions. When a revision
is made they send it to you and bill you $95.00.

2.  The above will work for published standards.  Any thoughts on how to
identify/get drafts standards? I used to be on several standards writing
committees, and word got around. I no longer have that access.

3.  With many design engineers, one paper copy of each standard is very
restrictive. Multiple copies are expensive. Electronic copies come in a
bewildering variety of formats. Any suggestions concerning standards
access?

I+m primarily interested in:
  AAMI (medical equipment)
  CSA
  EC directives
  EMC (CISPR, EN, IEC)
  IEC/EN/ISO
  MIL
  UL

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From: "Farnsworth,Heber" 
To: Post News 
Cc: "Ross,Marilyn" 
Subject: Up-to-date standards
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Spectrum Analyzers for Emis

[Regan Arndt]

Reply to:   Spectrum Analyzers for Emissions & Immunity

Rich & anyone else?
Would anyone out there know of a good "big bang for the buck" spectrum analyzer 
meant to interface with an Emscan unit, version 2.2 (Near field planar PCP 
emissions scanning device meant for isolating frequencies & EMI problem areas). 
 Emscan Corporation  has several HP models (HP8560 & HP8590 series) that 
support the EMSCAN 2.2.
We would use the Emscan to test a PCP with the spectrum analyzer on the bench & 
also use the spectrum analyzer to evaluate test components/systems inside an 
anechoic chamber for emission pre-scans to FCC & CISPR for equipment and 
systems with clock rates less than 50MHz.
We would also like it to be compatible with 'EMCO' near field probes.
Regards,
Regan Arndt
Safety Technologist
NORTEL

Re: Routine Hipot testing

[Regan Arndt]

  RE>>Routine Hipot testing5/6/96

Be aware that when doing manufacturing floor testing, the 1 second test is for 
levels 20% higher (AC or DC).  IEC 950 also states 3000VAC + 20% for 
re-inforced. ( 1sec)
Regan Arndt
Safety Technologist
Nortel, Calgary
--
List-Post: emc-pstc@listserv.ieee.org
Date: 5/6/96 3:50 PM
To: Regan Arndt
From: Kazimier Gawrzyjal
   - E X T E R N A L L Y  O R I G I N A T E D  M E S S A G E -

  RE>>Routine Hipot testing   5/6/96
   Kaz-ESN 765-4805

Egon,
You may have a point.
However, Note 1 of UL 1950 ed. 3, cl. 5.3.2  merely reads:  "For production 
test purposes, it is permitted to reduce the duration of the electric strength 
test to 1 s.  Alternative methods of production test are under consideration."  
The above sub-clause note, in no way details manufacturing and production test 
requirements, unlike UL 1459 (cl.6.3).
Hence, there is much implied in the above note while not much is stated 
regarding production testing requirements.  This is likely due to the complete 
reliance of such requirements being stated in the report as opposed to being a 
specified standard requirement.


 Cheers,
Kaz Gawrzyjal
Safety Eng-Nortel
0307...@nt.com

--
List-Post: emc-pstc@listserv.ieee.org
Date: 5/6/96 12:12 PM
To: Kazimier Gawrzyjal
From: Egon H. Varju
   - E X T E R N A L L Y  O R I G I N A T E D  M E S S A G E -

Kaz,

On 1996.5.5 you wrote:

>I believe that the harmonized, 3rd edition of UL 1950/ CSA C22.2 N0. 950 
>has pulled the requirement for 100 % hi-pot testing out of the standard. 
>Not to say that this is no longer a requirement.  A comment from a UL
>rep. was that such factory testing is included in the Certification
>reports (or Follow Up Service Agreements) as a requirement and so the
>text has been removed from the bi-national standard.  Nevertheless, it
>must still be performed.

Actually, the requirement has not been removed from the bi-national standard.
See Sub-Clause 5.3.2, Note 1.

:-)
Egon Varju




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Date: 6 May 1996 13:12:41 -0400
From: Kazimier Gawrzyjal 
Subject: Re: Routine Hipot testing
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