Re: [PSES] EN 55032 Testing on Wired Network Port

[John Woodgate]

Very good. In fact, this answer applies to practically EVERY question 
'Do we need to test'? Re 'testing to find out if we need to test' and ' 
to see the effect',  we can use cheaper and quicker 'pre-compliance' 
testing. If the results are in doubt, that indicates in itself a need to 
fully test.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-04-27 11:45, Matthew Wilson wrote:


You ask for opinions so I’ll give mine, based on the device needing to 
meet the EU EMC directive as you mention EN 55032.  It’s up to you but 
the decision if the debug port must be tested is part of the risk 
analysis and assessment required by the EU EMC directive. This is 
including foreseeable misuse.   That risk based decision whether to 
test or not will then be part of your technical file for the product 
supporting the declaration of conformity and CE mark.


I would think leaving the wired network port attached is quite a 
reasonable foreseeable misuse and so it could be expected to test to 
see the effect of that operating mode.


But like all these sort of questions the answer is ‘it depends’.  We 
don’t know from your post what the device is, the environment in which 
it is used, the class of end user (skilled, unskilled?) and nor do we 
know all the circumstances that make up the factors to the ‘it 
depends’.  All this can really only be untangled for the product with 
a risk exercise.


See an article here re EMC risk analysis:

https://www.element.com/nucleus/2017/08/17/13/42/what-is-an-emc-risk-analysis

Then only you can decide based on your risk outcomes whether to test 
the port or not and have good supporting evidence as to the decision 
for or against test.


Hope that helps.

Matthew Wilson,

Technical Director,

GB Electronics (UK) Ltd.

*From:*itl-emc user group [mailto:itl...@itl.co.il]
*Sent:* 24 April 2018 11:19
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] EN 55032 Testing on Wired Network Port

A device has a wired network port used for de-bugging only.

The port is not used during normal operation of the device.

Any opinions on whether or not this port should be tested?

*Regards,***

*David Shidlowsky***| Technical Reviewer

*Address*1 Bat-Sheva St. LOD 7120101 Israel

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

*Mail*: dav...@itlglobal.org <mailto:dav...@itlglobal.org>

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Matthew Wilson
Technical Director



GBE <https://gbelectronics.uk>
https://gbelectronics.uk

T: +44 (0)1903 244500
F: +44 (0)1903 700715



Ascot House // Mulberry Close // Woods Way
Goring-by-Sea // West Sussex // BN12 4QY // UK




Electronics Design // Manufacturing // Component Distribution

ISO 9001 | ISO 14001 <https://gbelectronics.uk/quality/standards>

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VAT Registration No: GB 925 1744 25



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Re: [PSES] EN 55032 Testing on Wired Network Port

[Matthew Wilson]

You ask for opinions so I’ll give mine, based on the device needing to meet the 
EU EMC directive as you mention EN 55032.  It’s up to you but the decision if 
the debug port must be tested is part of the risk analysis and assessment 
required by the EU EMC directive. This is including foreseeable misuse.   That 
risk based decision whether to test or not will then be part of your technical 
file for the product supporting the declaration of conformity and CE mark.

I would think leaving the wired network port attached is quite a reasonable 
foreseeable misuse and so it could be expected to test to see the effect of 
that operating mode.

But like all these sort of questions the answer is ‘it depends’.  We don’t know 
from your post what the device is, the environment in which it is used, the 
class of end user (skilled, unskilled?) and nor do we know all the 
circumstances that make up the factors to the ‘it depends’.  All this can 
really only be untangled for the product with a risk exercise.

See an article here re EMC risk analysis:

https://www.element.com/nucleus/2017/08/17/13/42/what-is-an-emc-risk-analysis

Then only you can decide based on your risk outcomes whether to test the port 
or not and have good supporting evidence as to the decision for or against test.

Hope that helps.

Matthew Wilson,
Technical Director,
GB Electronics (UK) Ltd.

From: itl-emc user group [mailto:itl...@itl.co.il]
Sent: 24 April 2018 11:19
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EN 55032 Testing on Wired Network Port

A device has a wired network port used for de-bugging only.
The port is not used during normal operation of the device.
Any opinions on whether or not this port should be tested?


Regards,
David Shidlowsky | Technical Reviewer
Address 1 Bat-Sheva St. LOD 7120101 Israel
Tel 972-8-9186113 Fax 972-8-9153101
Mail : dav...@itlglobal.org<mailto:dav...@itlglobal.org>

This e-mail message may contain privileged or confidential information.
If you are not the intended recipient, you may not disclose, use, disseminate, 
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Matthew Wilson
Technical Director


[GBE]<https://gbelectronics.uk>
https://gbelectronics.uk


T: +44 (0)1903 244500
F: +44 (0)1903 700715


Ascot House // Mulberry Close // Woods Way
Goring-by-Sea // West Sussex // BN12 4QY // UK



Electronics Design // Manufacturing // Component Distribution
[ISO 9001 | ISO 14001] <https://gbelectronics.uk/quality/standards>

Want to send us a file? https://www.mailbigfile.com/gbelectronics





GB Electronics (UK) Limited is a company registered in England and Wales
Company Registration No: 06210991
VAT Registration No: GB 925 1744 25


Registered Office:
Ascot House, Mulberry Close, Woods Way
Goring by Sea, West Sussex, BN12 4QY


Disclaimer: This email and any files transmitted with it are confidential and 
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W

Re: [PSES] EN 55032 Testing on Wired Network Port

[Pete Perkins]

All,  Been some good discussion her about the EMC issues and why or
when to test or not test.  I especially liked John Woodgate's comment that
if the emissions are well away from the limit then why bother to test; but
this does raise the issue to how would you know? And if you had to test to
know why wouldn't you run the test and include the data in your Technical
File (which amounts to running the tests anyway and showing compliance).  

 

Additionally, it needs to be pointed out that if the Wired
Network Port is using a standard connector (RJ-45, USB etc) then it has to
be shown that the port meets the appropriate safety requirements for the
usual Network.  There have been some safety requirements in 60950 for years
but these are now being updated and upgraded in 62368-3 at the insistence of
IEC ACOS to show that the port will not damage any network equipment
attached to it nor will be damaged by connecting to the standard network.
These ports are being upgraded to handle power over these communication
lines and are all moving to 100 Watts; for instance, can a person plug their
phone into your port expecting it to charge but not damage your system?.
Evaluating the ports for safety will be a requirement no matter what type of
equipment they will be used on.  

 

Expect this to be applied broadly moving ahead.  

 

:>) 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

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: Gert Gremmen; ce-test  
Sent: Tuesday, April 24, 2018 4:23 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 55032 Testing on Wired Network Port

 

EMC testing is like speeding by car. Did you ever try convince an officer
that you drove too fast for only a few minutes by year if caught
over-speeding?  And what did he say ?

Ports do not need testing only if inoperable at all. And even than, from a
technical point of view it may generate interference. In my opinion, testing
requirements end completely when a port is not accessible to the end-user.

And the criterion is not troublesome emissions, the requirement is
over-the-limit emissions.

Like speeding by car, driving beyond speed-limits does not need to be
troublesome (by the absence of other cars for example, or by night).
Nevertheless, any speeding limit is enforced even if not troublesome.

But at the end, it is the manufacturer who decides if creating emissions
over the limit is acceptable or not. But do not complain if you get caught.

 

Gert Gremmen

 

On 24-4-2018 12:52, John Woodgate wrote:

 Do you even need to justify not testing, if it doesn't produces troublesome
emissions? The only justification I can see might be that it is used only
for periods of a few minutes a few times a year. 

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2018-04-24 11:18, itl-emc user group wrote:

A device has a wired network port used for de-bugging only.

The port is not used during normal operation of the device.

Any opinions on whether or not this port should be tested?

 

 

Regards,

David Shidlowsky| Technical Reviewer

Address 1 Bat-Sheva St. LOD 7120101 Israel

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

Mail :  <mailto:dav...@itlglobal.org> dav...@itlglobal.org 

 

This e-mail message may contain privileged or confidential information. 

If you are not the intended recipient, you may not disclose, use,
disseminate, distribute, copy or rely upon this message or attachment in any
way. If you received this e-mail message in error, please return by
forwarding the message and its attachments to the sender.

 

 

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This message is from the IEEE Product Safety Engineering Socie

Re: [PSES] EN 55032 Testing on Wired Network Port

[Paolo Roncone]

Hello,

according to EN55032/CISPR32, the port you describe is not a wired network
port (sec.3.1.32), rather a signal/control port. (sec.3.1.30).
In Annex A of the standard I don't see tests required on such a port.

Best regards,
Paolo

On Tue, Apr 24, 2018 at 12:18 PM, itl-emc user group 
wrote:

> A device has a wired network port used for de-bugging only.
>
> The port is not used during normal operation of the device.
>
> Any opinions on whether or not this port should be tested?
>
>
>
>
>
> *Regards,*
>
> *David Shidlowsky* | Technical Reviewer
>
> *Address* 1 Bat-Sheva St. LOD
> 
> 7120101 Israel
>
> *Tel* 972-8-9186113 *Fax* 972-8-9153101
>
> *Mail* : dav...@itlglobal.org
>
>
>
> This e-mail message may contain privileged or confidential information.
>
> If you are not the intended recipient, you may not disclose, use,
> disseminate, distribute, copy or rely upon this message or attachment in
> any way. If you received this e-mail message in error, please return by
> forwarding the message and its attachments to the sender.
>
>
>
>
> -
> 
>
> 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
>
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> Scott Douglas 
> Mike Cantwell 
>
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> David Heald 
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Re: [PSES] EN 55032 Testing on Wired Network Port

[John Woodgate]

By 'troublesome' I meant 'emissions over, or too close to, the limit, 
that can't be easily reduced.' If the emissions are low enough or can be 
made so, why bother to ask about need to test?


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-04-24 12:23, Gert Gremmen; ce-test wrote:


EMC testing is like speeding by car. Did you ever try convince an 
officer that you drove too fast for only a few minutes by year if 
caught over-speeding?  And what did he say ?


Ports do not need testing only if inoperable at all. And even than, 
from a technical point of view it may generate interference. In my 
opinion, testing requirements end completely when a port is not 
accessible to the end-user.


And the criterion is not _troublesome_ emissions, the requirement is 
_over-the-limit_ emissions.


Like speeding by car, driving beyond speed-limits does not need to be 
troublesome (by the absence of other cars for example, or by night). 
Nevertheless, any speeding limit is enforced even if not troublesome.


But at the end, it is the manufacturer who decides if creating 
emissions over the limit is acceptable or not. But do not complain if 
you get caught.



Gert Gremmen


On 24-4-2018 12:52, John Woodgate wrote:


 Do you even need to justify not testing,if it doesn't produces 
troublesome emissions? The only justification I can see might be that 
it is used only for periods of a few minutes a few times a year.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2018-04-24 11:18, itl-emc user group wrote:


A device has a wired network port used for de-bugging only.

The port is not used during normal operation of the device.

Any opinions on whether or not this port should be tested?

*Regards,***

*David Shidlowsky***| Technical Reviewer

*Address*1 Bat-Sheva St. LOD 7120101 Israel

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

*Mail*: dav...@itlglobal.org 

This e-mail message may contain privileged or confidential information.

If you are not the intended recipient, you may not disclose, use, 
disseminate, distribute, copy or rely upon this message or 
attachment in any way. If you received this e-mail message in error, 
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sender.


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Re: [PSES] EN 55032 Testing on Wired Network Port

[Gert Gremmen; ce-test]

EMC testing is like speeding by car. Did you ever try convince an 
officer that you drove too fast for only a few minutes by year if caught 
over-speeding?  And what did he say ?


Ports do not need testing only if inoperable at all. And even than, from 
a technical point of view it may generate interference. In my opinion, 
testing requirements end completely when a port is not accessible to the 
end-user.


And the criterion is not _troublesome_ emissions, the requirement is 
_over-the-limit_ emissions.


Like speeding by car, driving beyond speed-limits does not need to be 
troublesome (by the absence of other cars for example, or by night). 
Nevertheless, any speeding limit is enforced even if not troublesome.


But at the end, it is the manufacturer who decides if creating emissions 
over the limit is acceptable or not. But do not complain if you get caught.



Gert Gremmen


On 24-4-2018 12:52, John Woodgate wrote:


 Do you even need to justify not testing,if it doesn't produces 
troublesome emissions? The only justification I can see might be that 
it is used only for periods of a few minutes a few times a year.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2018-04-24 11:18, itl-emc user group wrote:


A device has a wired network port used for de-bugging only.

The port is not used during normal operation of the device.

Any opinions on whether or not this port should be tested?

*Regards,***

*David Shidlowsky***| Technical Reviewer

*Address*1 Bat-Sheva St. LOD 7120101 Israel

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

*Mail*: dav...@itlglobal.org 

This e-mail message may contain privileged or confidential information.

If you are not the intended recipient, you may not disclose, use, 
disseminate, distribute, copy or rely upon this message or attachment 
in any way. If you received this e-mail message in error, please 
return by forwarding the message and its attachments to the sender.


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Re: [PSES] EN 55032 Testing on Wired Network Port

[Charlie Blackham]

David

It is for the manufacturer to determine applicable ports for the lab to test

8 Applicability
Measurements shall be performed on the relevant ports of the EUT according to 
the appropriate tables given in Annex A.
Where a manufacturer determines from the electrical characteristics and 
intended usage of the EUT that one or more measurements are unnecessary, the 
decision and justification not to perform these measurements shall be recorded 
in the test report.

Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
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From: itl-emc user group 
Sent: 24 April 2018 11:19
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EN 55032 Testing on Wired Network Port

A device has a wired network port used for de-bugging only.
The port is not used during normal operation of the device.
Any opinions on whether or not this port should be tested?


Regards,
David Shidlowsky | Technical Reviewer
Address 1 Bat-Sheva St. LOD 7120101 Israel
Tel 972-8-9186113 Fax 972-8-9153101
Mail : dav...@itlglobal.org<mailto:dav...@itlglobal.org>

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Re: [PSES] EN 55032 Testing on Wired Network Port

[John Woodgate]

 Do you even need to justify not testing,if it doesn't produces 
troublesome emissions? The only justification I can see might be that it 
is used only for periods of a few minutes a few times a year.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-04-24 11:18, itl-emc user group wrote:


A device has a wired network port used for de-bugging only.

The port is not used during normal operation of the device.

Any opinions on whether or not this port should be tested?

*Regards,***

*David Shidlowsky***| Technical Reviewer

*Address*1 Bat-Sheva St. LOD 7120101 Israel

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

*Mail*: dav...@itlglobal.org 

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[PSES] EN 55032 Testing on Wired Network Port

[itl-emc user group]

A device has a wired network port used for de-bugging only.
The port is not used during normal operation of the device.
Any opinions on whether or not this port should be tested?


Regards,
David Shidlowsky | Technical Reviewer
Address 1 Bat-Sheva St. LOD 7120101 Israel
Tel 972-8-9186113 Fax 972-8-9153101
Mail : dav...@itlglobal.org

This e-mail message may contain privileged or confidential information.
If you are not the intended recipient, you may not disclose, use, disseminate, 
distribute, copy or rely upon this message or attachment in any way. If you 
received this e-mail message in error, please return by forwarding the message 
and its attachments to the sender.



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