Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

2012-11-14 Thread Brian Oconnell
http://style.org/strouhalflight/

Have also used Strouhal number to calc air flow in non-circular plenum.
Physics works.

Brian 

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Wiseman,
Joshua E
Sent: Wednesday, November 14, 2012 1:57 PM
To: Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

Is that an European or African swallow?

Josh

-Original Message-
From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: Wednesday, November 14, 2012 2:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

Yes, but what is the airspeed of an unladen swallow?

The Other Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Brian
Oconnell
Sent: Wednesday, November 14, 2012 3:30 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

Excellent point. And it (not the elderberry smell) was used at a PSES
symposium session as one of the reasons to fire the conformity assessment
body.

There may be a time when the assessor is intractable and will offer only
vague hand waves in lieu of any rationale. But first talk to a technical
authority at the agency to verify that the requirement is capricious.

"Your mother was a hamster and your father smelt of elderberries."
  -- Monty Python and the Holy Grail

Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Peter Tarver
Sent: Wednesday, November 14, 2012 12:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

> From: Brian Oconnell
> Sent: Tuesday, November 13, 2012 15:28
>
> OHSA allows the recognized lab use of 'engineering judgment' and 
> reference to corporate policy for acceptance or rejection of 
> construction. And various instances of adjudication have allowed 
> internal lab 'policy' that would be in addition to, or in lieu of, a 
> normative reference from an ANSI safety standard.

None of this effects the need for explanation, even if it's, "you're father
smells of elderberries."

There has to be a rationale even for a policy.  Denial of sound engineering
rationale casts a pall on the reputation of an NRTL and would be reason to
move on.

If the product is not intended exclusively for the workplace, OSHA's opinion
is of no account.

During prior employment, I applied similar to the stated OSHA position to a
coffee percolator.  The device would not heat up enough to allow normal
operation (or to even warm water).  The customer was told that the
certification service would not be forthcoming, but I had to explain why.

Whether it's considered a matter of fairness or a response to contracted
services, some explanation is needed.


Peter Tarver

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Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

2012-11-14 Thread Wiseman, Joshua E
Is that an European or African swallow?

Josh

-Original Message-
From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: Wednesday, November 14, 2012 2:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

Yes, but what is the airspeed of an unladen swallow?

The Other Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Brian Oconnell
Sent: Wednesday, November 14, 2012 3:30 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

Excellent point. And it (not the elderberry smell) was used at a PSES symposium 
session as one of the reasons to fire the conformity assessment body.

There may be a time when the assessor is intractable and will offer only vague 
hand waves in lieu of any rationale. But first talk to a technical authority at 
the agency to verify that the requirement is capricious.

"Your mother was a hamster and your father smelt of elderberries."
  -- Monty Python and the Holy Grail

Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Peter Tarver
Sent: Wednesday, November 14, 2012 12:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

> From: Brian Oconnell
> Sent: Tuesday, November 13, 2012 15:28
>
> OHSA allows the recognized lab use of 'engineering judgment' and 
> reference to corporate policy for acceptance or rejection of 
> construction. And various instances of adjudication have allowed 
> internal lab 'policy' that would be in addition to, or in lieu of, a 
> normative reference from an ANSI safety standard.

None of this effects the need for explanation, even if it's, "you're father 
smells of elderberries."

There has to be a rationale even for a policy.  Denial of sound engineering 
rationale casts a pall on the reputation of an NRTL and would be reason to move 
on.

If the product is not intended exclusively for the workplace, OSHA's opinion is 
of no account.

During prior employment, I applied similar to the stated OSHA position to a 
coffee percolator.  The device would not heat up enough to allow normal 
operation (or to even warm water).  The customer was told that the 
certification service would not be forthcoming, but I had to explain why.

Whether it's considered a matter of fairness or a response to contracted 
services, some explanation is needed.


Peter Tarver

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Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

2012-11-14 Thread Kunde, Brian
Yes, but what is the airspeed of an unladen swallow?

The Other Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Brian Oconnell
Sent: Wednesday, November 14, 2012 3:30 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

Excellent point. And it (not the elderberry smell) was used at a PSES symposium 
session as one of the reasons to fire the conformity assessment body.

There may be a time when the assessor is intractable and will offer only vague 
hand waves in lieu of any rationale. But first talk to a technical authority at 
the agency to verify that the requirement is capricious.

"Your mother was a hamster and your father smelt of elderberries."
  -- Monty Python and the Holy Grail

Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Peter Tarver
Sent: Wednesday, November 14, 2012 12:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

> From: Brian Oconnell
> Sent: Tuesday, November 13, 2012 15:28
>
> OHSA allows the recognized lab use of 'engineering judgment' and
> reference to corporate policy for acceptance or rejection of
> construction. And various instances of adjudication have allowed
> internal lab 'policy' that would be in addition to, or in lieu of, a
> normative reference from an ANSI safety standard.

None of this effects the need for explanation, even if it's, "you're father 
smells of elderberries."

There has to be a rationale even for a policy.  Denial of sound engineering 
rationale casts a pall on the reputation of an NRTL and would be reason to move 
on.

If the product is not intended exclusively for the workplace, OSHA's opinion is 
of no account.

During prior employment, I applied similar to the stated OSHA position to a 
coffee percolator.  The device would not heat up enough to allow normal 
operation (or to even warm water).  The customer was told that the 
certification service would not be forthcoming, but I had to explain why.

Whether it's considered a matter of fairness or a response to contracted 
services, some explanation is needed.


Peter Tarver

-

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mistake, please destroy it and notify us of the error. Thank you.

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Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

2012-11-14 Thread Brian Oconnell
Excellent point. And it (not the elderberry smell) was used at a PSES
symposium session as one of the reasons to fire the conformity assessment
body.

There may be a time when the assessor is intractable and will offer only
vague hand waves in lieu of any rationale. But first talk to a technical
authority at the agency to verify that the requirement is capricious.

"Your mother was a hamster and your father smelt of elderberries."
  -- Monty Python and the Holy Grail

Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Peter
Tarver
Sent: Wednesday, November 14, 2012 12:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

> From: Brian Oconnell
> Sent: Tuesday, November 13, 2012 15:28
>
> OHSA allows the recognized lab use of 'engineering
> judgment' and reference to corporate policy for
> acceptance or rejection of construction. And various
> instances of adjudication have allowed internal lab
> 'policy' that would be in addition to, or in lieu of, a
> normative reference from an ANSI safety standard.

None of this effects the need for explanation, even if it's, "you're father
smells of elderberries."

There has to be a rationale even for a policy.  Denial of sound engineering
rationale casts a pall on the reputation of an NRTL and would be reason to
move on.

If the product is not intended exclusively for the workplace, OSHA's opinion
is of no account.

During prior employment, I applied similar to the stated OSHA position to a
coffee percolator.  The device would not heat up enough to allow normal
operation (or to even warm water).  The customer was told that the
certification service would not be forthcoming, but I had to explain why.

Whether it's considered a matter of fairness or a response to contracted
services, some explanation is needed.


Peter Tarver

-

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Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

2012-11-14 Thread Peter Tarver
> From: Brian Oconnell
> Sent: Tuesday, November 13, 2012 15:28
>
> OHSA allows the recognized lab use of 'engineering
> judgment' and reference to corporate policy for
> acceptance or rejection of construction. And various
> instances of adjudication have allowed internal lab
> 'policy' that would be in addition to, or in lieu of, a
> normative reference from an ANSI safety standard.

None of this effects the need for explanation, even if it's, "you're father
smells of elderberries."

There has to be a rationale even for a policy.  Denial of sound engineering
rationale casts a pall on the reputation of an NRTL and would be reason to
move on.

If the product is not intended exclusively for the workplace, OSHA's opinion
is of no account.

During prior employment, I applied similar to the stated OSHA position to a
coffee percolator.  The device would not heat up enough to allow normal
operation (or to even warm water).  The customer was told that the
certification service would not be forthcoming, but I had to explain why.

Whether it's considered a matter of fairness or a response to contracted
services, some explanation is needed.


Peter Tarver


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Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

2012-11-13 Thread Richard Pittenger
Hello Brian and Group,

As a follow-up to my original posting a couple of weeks ago, the agency has 
backed down and agreed to accept the VTM-2 film as submitted.

Thanks to all who provided comment.

Good evening,
Richard Pittenger
Hobart


From: Brian Oconnell [oconne...@tamuracorp.com]
Sent: Tuesday, November 13, 2012 6:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

"In either case, the NRTL owes you an engineering rationale for their claim of 
noncompliance.  Because Mama said so doesn’t fly."

OHSA allows the recognized lab use of 'engineering judgment' and reference to 
corporate policy for acceptance or rejection of construction. And various 
instances of adjudication have allowed internal lab 'policy' that would be in 
addition to, or in lieu of, a normative reference from an ANSI safety standard.

Brian

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Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

2012-11-13 Thread Brian Oconnell
"In either case, the NRTL owes you an engineering rationale for their claim of 
noncompliance.  Because Mama said so doesn’t fly."

OHSA allows the recognized lab use of 'engineering judgment' and reference to 
corporate policy for acceptance or rejection of construction. And various 
instances of adjudication have allowed internal lab 'policy' that would be in 
addition to, or in lieu of, a normative reference from an ANSI safety standard.

Brian

-

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Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

2012-11-13 Thread Peter Tarver
Richard –



I’ve run into similar issues with NRTLs before.  Much depends on the
standard being applied.



If UL 746C is being applied (by reference from the end-product standard),
Table 6.1 outlines the requirements for a barrier or liner and the flame
rating will determine some of the other material properties that apply
(insulator requirements are independent of flame rating).



There’s also a gotcha in UL 746C that a barrier or liner needs to be ≥ 0.71
mm thick to ignore a clearance altogether, or as thin as 0.33 mm to halve
the otherwise required clearance.



Thinner materials require a “separate evaluation.”  This might be where
your issue lies.



On the other hand, if UL 746C is not being used, the requirements fall out
from the end-product standard.



In either case, the NRTL owes you an engineering rationale for their claim
of noncompliance.  Because Mama said so doesn’t fly.





Peter Tarver



*From:* Richard Pittenger [mailto:richard.pitten...@hobartcorp.com]
*Sent:* Friday, November 02, 2012 11:21



Esteemed Colleagues,



I have a product submitted to NRTL “E” that uses a Mylar electrical barrier
between line-voltage (120 V ac), uninsulated live parts on a circuit board
and the aluminum electrical enclosure. The ‘through-air’ spacing would be a
little short without this barrier in place. The barrier material has a UL
94 VTM-2 flame rating and has been accepted in other similar products for
many years in similar applications by NRTL “U”.



NRTL “E” is objecting to use of this material for this application but so
far has not provided a reason. Can any of you think of a reason why a
plastic film with a VTM-2 flame rating shouldn’t be used as an electrical
barrier?



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Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

2012-11-02 Thread Richard Nute

Hi Richard:


Unfortunately, this situation mixes two, independent
requirements:  1) electrical insulation requirements, 
and 2) anti-fire requirements.

If the clearance (air insulation) is insufficient for
basic insulation, then a solid insulation may be used 
in place of the clearance.  

If the metal enclosure is grounded, then the insulation
must be basic insulation, and no requirements for the
thickness of the solid insulation.  If the metal 
enclosure is not grounded, then the solid insulation 
comprises supplementary insulation and must be at least
0.4 mm thick.  (Typically, no other electrical 
properties apply to the solid insulation.)

Without knowing anything further about the construction,
the material will need to be rated at least HB for
anti-fire.  The applicable standard will specify the
required flammability rating.  In some cases, all 
material within the power supply must be at least V2
(equivalently VTM2).  

Don’t let the certification house mix up the two
requirements.  As others have advised, insist the 
cert house show you the written requirements!


Best regards,
Rich


-Original Message- 
From: Richard Pittenger 
Sent: Friday, November 02, 2012 11:21 AM 
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: VTM-2 Rated Film - Proper Electrical Barrier 



Esteemed Colleagues,



I have a product submitted to NRTL “E” that uses a Mylar electrical barrier 
between line-voltage (120 V ac), uninsulated live parts on a circuit board and 
the aluminum electrical enclosure. The ‘through-air’ spacing would be a little 
short without this barrier in place. The barrier material has a UL 94 VTM-2 
flame rating and has been accepted in other similar products for many years in 
similar applications by NRTL “U”. 



NRTL “E” is objecting to use of this material for this application but so far 
has not provided a reason. Can any of you think of a reason why a plastic film 
with a VTM-2 flame rating shouldn’t be used as an electrical barrier? 



Thanks for any and all comments. 



Regards,

Richard Pittenger

Agency Approval Engineer

Food Machines Engineering

Hobart/Berkel


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Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

2012-11-02 Thread Ralph . McDiarmid
And some standards will provide only a reduction in clearance if an 
insulator is used, it won't necessarily replace the need for a clearance. 
(as silly as that may sound)
___ 


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




From:
"jral...@productsafetyinc.com" 
To:
EMC-PSTC@LISTSERV.IEEE.ORG, 
Date:
11/02/2012 12:54 PM
Subject:
Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier



Flame rating doesn’t mean it’s an insulator.  Is it an insulator?  What 
are the Dielectric properties?  Insulators depend on the Standard.  Most 
I’ve worked in require insulators to be 0.7mm thick, minimum.  They also 
may be concerned that a sharp solder point or component pins can pierce 
the insulation.  We’ve used mica and fish paper without issues.  Also, the 
orange insulator (Kapton) I think is either GE or EI Dupont and we’ve used 
it many times in the past.  For NRTL E – make him point to the clause in 
the Standard
 
From: Richard Pittenger [mailto:richard.pitten...@hobartcorp.com] 
Sent: Friday, November 02, 2012 1:21 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] VTM-2 Rated Film - Proper Electrical Barrier
 
Esteemed Colleagues,
 
I have a product submitted to NRTL “E” that uses a Mylar electrical 
barrier between line-voltage (120 V ac), uninsulated live parts on a 
circuit board and the aluminum electrical enclosure. The ‘through-air’ 
spacing would be a little short without this barrier in place. The barrier 
material has a UL 94 VTM-2 flame rating and has been accepted in other 
similar products for many years in similar applications by NRTL “U”. 
 
NRTL “E” is objecting to use of this material for this application but so 
far has not provided a reason. Can any of you think of a reason why a 
plastic film with a VTM-2 flame rating shouldn’t be used as an electrical 
barrier? 
 
Thanks for any and all comments. 
 
Regards,
Richard Pittenger
Agency Approval Engineer
Food Machines Engineering
Hobart/Berkel
 

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Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

2012-11-02 Thread jral...@productsafetyinc.com
Flame rating doesn't mean it's an insulator.  Is it an insulator?  What are the 
Dielectric properties?  Insulators depend on the Standard.  Most I've worked in 
require insulators to be 0.7mm thick, minimum.  They also may be concerned that 
a sharp solder point or component pins can pierce the insulation.  We've used 
mica and fish paper without issues.  Also, the orange insulator (Kapton) I 
think is either GE or EI Dupont and we've used it many times in the past.  For 
NRTL E - make him point to the clause in the Standard

From: Richard Pittenger [mailto:richard.pitten...@hobartcorp.com]
Sent: Friday, November 02, 2012 1:21 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

Esteemed Colleagues,

I have a product submitted to NRTL "E" that uses a Mylar electrical barrier 
between line-voltage (120 V ac), uninsulated live parts on a circuit board and 
the aluminum electrical enclosure. The 'through-air' spacing would be a little 
short without this barrier in place. The barrier material has a UL 94 VTM-2 
flame rating and has been accepted in other similar products for many years in 
similar applications by NRTL "U".

NRTL "E" is objecting to use of this material for this application but so far 
has not provided a reason. Can any of you think of a reason why a plastic film 
with a VTM-2 flame rating shouldn't be used as an electrical barrier?

Thanks for any and all comments.

Regards,
Richard Pittenger
Agency Approval Engineer
Food Machines Engineering
Hobart/Berkel


Disclaimer - This email and any files transmitted with it are confidential and 
contain privileged or copyrighted information. You must not present this 
message to another party without first gaining permission from the sender. If 
you are not the intended recipient, you must not copy, print, distribute or use 
this email or the information contained in it for any purpose other than to 
notify us.

If you received this email in error, please notify the sender immediately and 
delete this email from your system. We do not guarantee that this email is free 
from viruses or any other defects although due care has been taken to minimize 
the risk.
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Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

2012-11-02 Thread John Woodgate
In message 
<99280a01673ff44180f15babb58896ca091b2ae...@troyex2.itwfeg.biz>, dated 
Fri, 2 Nov 2012, Richard Pittenger  
writes:


NRTL ?E? is objecting to use of this material for this application but 
so far has not provided a reason. Can any of you think of a reason why 
a plastic film with a VTM-2 flame rating shouldn?t be used as an 
electrical barrier?


Surely it's up to the NRTL to say why they object. It might be because 
the part could be removed during servicing and not replaced.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] VTM-2 Rated Film - Proper Electrical Barrier

2012-11-02 Thread Brian Oconnell
The NRTL assessment engineer must provide specific requirements via
normative clauses of the scoped standard, or a formal corporate policy that
has been published. If this person will not or cannot, immediately contact
the agency's technical authority for the scope of your equipment. The OSHA
NRTL program does allow a certain latitude per 'engineering judgment'.

The material shall be rated for your intended use and conditions of
acceptability.

Creepage and Clearance are defined and specified in all ANSI safety
standards.

I will address these type of agency issues at the PSES symposium.

Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Richard
Pittenger
Sent: Friday, November 02, 2012 11:21 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: VTM-2 Rated Film - Proper Electrical Barrier

Esteemed Colleagues,
 
I have a product submitted to NRTL "E" that uses a Mylar electrical barrier
between line-voltage (120 V ac), uninsulated live parts on a circuit board
and the aluminum electrical enclosure. The 'through-air' spacing would be a
little short without this barrier in place. The barrier material has a UL 94
VTM-2 flame rating and has been accepted in other similar products for many
years in similar applications by NRTL "U". 
 
NRTL "E" is objecting to use of this material for this application but so
far has not provided a reason. Can any of you think of a reason why a
plastic film with a VTM-2 flame rating shouldn't be used as an electrical
barrier? 
 
Thanks for any and all comments. 
 
Regards,
Richard Pittenger
Agency Approval Engineer
Food Machines Engineering
Hobart/Berkel



Disclaimer - This email and any files transmitted with it are confidential
and contain privileged or copyrighted information. You must not present this
message to another party without first gaining permission from the sender.
If you are not the intended recipient, you must not copy, print, distribute
or use this email or the information contained in it for any purpose other
than to notify us.

If you received this email in error, please notify the sender immediately
and delete this email from your system. We do not guarantee that this email
is free from viruses or any other defects although due care has been taken
to minimize the risk.
-


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