Re: [PSES] Safety standards versus safety engineering

[John Allen]

Isn't the guy at the top supposed to set Risk Tolerance??


Best Regards,


John


John Allen

USA


From: John Allen john_e_al...@blueyonder.co.uk
Sent: Friday, March 6, 2015 2:35 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

And I’ve just thought of “another BIG one” myself that we must all have 
encountered at some time:

-  The “guy in the middle” does not think that the “guy at the top” 
would “like” the possible outcomes of a risk assessment,  what it could do to 
his own “prospects”, and/or “I do what I’m told, and so it’s not my 
responsibility because nobody told me to do it”.

Ring some bells?

John Allen
W.London, UK

From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: 06 March 2015 20:18
To: 'Ken Javor'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Safety standards versus safety engineering

And the BIG ones just keep coming – bring ’em on!

From: Ken Javor [mailto:ken.ja...@emccompliance.com]
Sent: 06 March 2015 20:08
Tor: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

A key contributor to the Columbia disaster was the method they used to attach 
the insulating foam to the External Tank. They had changed it from the original 
method (which worked well) because it was not “green” enough. The new technique 
satisfied the arbiters “greenness” but it didn't work as well.  The work of the 
safety engineers has to be measured against external forces like that.

Ken Javor
Phone: (256) 650-5261

From: Cortland Richmond k...@earthlink.netmailto:k...@earthlink.net
Reply-To: Cortland Richmond k...@earthlink.netmailto:k...@earthlink.net
Date: Fri, 6 Mar 2015 14:54:04 -0500
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering


I forwarded Dr Feynman's appendix to the Rogers Commission report to someone 
involved in processes that would, if followed, rein in this kind of thing.

I am not an optimist.

Cortland Richmond
-Original Message-
From: msherma...@comcast.netmailto:msherma...@comcast.net
Sent: Mar 6, 2015 12:16 PM
To: k...@earthlink.netmailto:k...@earthlink.net
Cc: EMC-PSTC
Subject: Re: [PSES] Safety standards versus safety engineering

Re ...and dismissal of identifiable risks deemed conveniently unlikely to 
occur.

This is a real issue in organizations, and was a key contributor to the 
Columbia space shuttle disaster.

NASA's Columbia Accident Investigation Board's final report explores this 
contributor a lot. The report is easy to find on the web. ...
-


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Re: [PSES] Safety standards versus safety engineering

[John Allen]

Does the guy at the top know what risk tolerance means in terms of safety?


 

Personally I doubt that more than a very small proportion of them do
because, to most of them, risk is measured in financial impacts, and thus
the most important to them are meeting, or not, targets for sales and
profitability (and not going under!).

 

John Allen

W.London, UK

 

From: John Allen [mailto:jral...@productsafetyinc.com] 
Sent: 06 March 2015 20:43
To: EMC-PSTC@LISTSERV.IEEE.ORG; John Allen
Subject: Re: [PSES] Safety standards versus safety engineering

 

Isn't the guy at the top supposed to set Risk Tolerance??

 

Best Regards,

 

John

 

John Allen

USA

  _  

From: John Allen john_e_al...@blueyonder.co.uk
Sent: Friday, March 6, 2015 2:35 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering 

 

And I've just thought of another BIG one myself that we must all have
encountered at some time: 

-  The guy in the middle does not think that the guy at the top
would like the possible outcomes of a risk assessment,  what it could do
to his own prospects, and/or I do what I'm told, and so it's not my
responsibility because nobody told me to do it.

 

Ring some bells?

 

John Allen

W.London, UK

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 06 March 2015 20:18
To: 'Ken Javor'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Safety standards versus safety engineering

 

And the BIG ones just keep coming - bring 'em on!

 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: 06 March 2015 20:08
Tor: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

 

A key contributor to the Columbia disaster was the method they used to
attach the insulating foam to the External Tank. They had changed it from
the original method (which worked well) because it was not green enough.
The new technique satisfied the arbiters greenness but it didn't work as
well.  The work of the safety engineers has to be measured against external
forces like that. 

Ken Javor
Phone: (256) 650-5261

  _  

From: Cortland Richmond k...@earthlink.net
Reply-To: Cortland Richmond k...@earthlink.net
Date: Fri, 6 Mar 2015 14:54:04 -0500
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering


I forwarded Dr Feynman's appendix to the Rogers Commission report to someone
involved in processes that would, if followed, rein in this kind of thing. 

I am not an optimist.

Cortland Richmond

-Original Message- 
From: msherma...@comcast.net 
Sent: Mar 6, 2015 12:16 PM 
To: k...@earthlink.net 
Cc: EMC-PSTC 
Subject: Re: [PSES] Safety standards versus safety engineering 

Re ...and dismissal of identifiable risks deemed conveniently unlikely to
occur.

This is a real issue in organizations, and was a key contributor to the
Columbia space shuttle disaster.

NASA's Columbia Accident Investigation Board's final report explores this
contributor a lot. The report is easy to find on the web. ...

-


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discussion list. To post a message to the list, send your e-mail to
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David Heald dhe...@gmail.com 

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Re: [PSES] Safety standards versus safety engineering

[John Allen]

And I've just thought of another BIG one myself that we must all have
encountered at some time: 

-  The guy in the middle does not think that the guy at the top
would like the possible outcomes of a risk assessment,  what it could do
to his own prospects, and/or I do what I'm told, and so it's not my
responsibility because nobody told me to do it.

 

Ring some bells?

 

John Allen

W.London, UK

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 06 March 2015 20:18
To: 'Ken Javor'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Safety standards versus safety engineering

 

And the BIG ones just keep coming - bring 'em on!

 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: 06 March 2015 20:08
Tor: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

 

A key contributor to the Columbia disaster was the method they used to
attach the insulating foam to the External Tank. They had changed it from
the original method (which worked well) because it was not green enough.
The new technique satisfied the arbiters greenness but it didn't work as
well.  The work of the safety engineers has to be measured against external
forces like that. 

Ken Javor
Phone: (256) 650-5261

  _  

From: Cortland Richmond k...@earthlink.net
Reply-To: Cortland Richmond k...@earthlink.net
Date: Fri, 6 Mar 2015 14:54:04 -0500
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering


I forwarded Dr Feynman's appendix to the Rogers Commission report to someone
involved in processes that would, if followed, rein in this kind of thing. 

I am not an optimist.

Cortland Richmond

-Original Message- 
From: msherma...@comcast.net 
Sent: Mar 6, 2015 12:16 PM 
To: k...@earthlink.net 
Cc: EMC-PSTC 
Subject: Re: [PSES] Safety standards versus safety engineering 

Re ...and dismissal of identifiable risks deemed conveniently unlikely to
occur.

This is a real issue in organizations, and was a key contributor to the
Columbia space shuttle disaster.

NASA's Columbia Accident Investigation Board's final report explores this
contributor a lot. The report is easy to find on the web. ...

-


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:
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David Heald dhe...@gmail.com 

-


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David Heald

Re: [PSES] Safety standards versus safety engineering

[John Allen]

And not so cordially either!

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 06 March 2015 21:47
To: 'Bonsen, Robert'
Subject: RE: [PSES] Safety standards versus safety engineering

 

Robert

 

You have obviously been there!

 

I sympathise, completely - I have too!

 

John Allen

W. London, UK

 

From: Bonsen, Robert [mailto:robert.bon...@hp.com] 
Sent: 06 March 2015 21:21
To: John Allen
Subject: RE: [PSES] Safety standards versus safety engineering

 

Good points, all, especially this one. Those not involved with larger
companies often miss that safety is only a part of the bigger picture,
unfortunately. Thus, the decision makers are rarely sufficiently educated,
experienced or even interested in championing safety.

 

That is left to the guys at the bottom, who, when accused of making
pro-safety calls against bigger business goals, are typically cordially
invited to find employ elsewhere. 

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Friday, March 06, 2015 2:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

 

Does the guy at the top know what risk tolerance means in terms of safety?


 

Personally I doubt that more than a very small proportion of them do
because, to most of them, risk is measured in financial impacts, and thus
the most important to them are meeting, or not, targets for sales and
profitability (and not going under!).

 

John Allen

W.London, UK

 

From: John Allen [mailto:jral...@productsafetyinc.com] 
Sent: 06 March 2015 20:43
To: EMC-PSTC@LISTSERV.IEEE.ORG; John Allen
Subject: Re: [PSES] Safety standards versus safety engineering

 

Isn't the guy at the top supposed to set Risk Tolerance??

 

Best Regards,

 

John

 

John Allen

USA

  _  

From: John Allen john_e_al...@blueyonder.co.uk
Sent: Friday, March 6, 2015 2:35 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering 

 

And I've just thought of another BIG one myself that we must all have
encountered at some time: 

-  The guy in the middle does not think that the guy at the top
would like the possible outcomes of a risk assessment,  what it could do
to his own prospects, and/or I do what I'm told, and so it's not my
responsibility because nobody told me to do it.

 

Ring some bells?

 

John Allen

W.London, UK

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 06 March 2015 20:18
To: 'Ken Javor'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Safety standards versus safety engineering

 

And the BIG ones just keep coming - bring 'em on!

 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: 06 March 2015 20:08
Tor: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

 

A key contributor to the Columbia disaster was the method they used to
attach the insulating foam to the External Tank. They had changed it from
the original method (which worked well) because it was not green enough.
The new technique satisfied the arbiters greenness but it didn't work as
well.  The work of the safety engineers has to be measured against external
forces like that. 

Ken Javor
Phone: (256) 650-5261

  _  

From: Cortland Richmond k...@earthlink.net
Reply-To: Cortland Richmond k...@earthlink.net
Date: Fri, 6 Mar 2015 14:54:04 -0500
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering


I forwarded Dr Feynman's appendix to the Rogers Commission report to someone
involved in processes that would, if followed, rein in this kind of thing. 

I am not an optimist.

Cortland Richmond

-Original Message- 
From: msherma...@comcast.net 
Sent: Mar 6, 2015 12:16 PM 
To: k...@earthlink.net 
Cc: EMC-PSTC 
Subject: Re: [PSES] Safety standards versus safety engineering 

Re ...and dismissal of identifiable risks deemed conveniently unlikely to
occur.

This is a real issue in organizations, and was a key contributor to the
Columbia space shuttle disaster.

NASA's Columbia Accident Investigation Board's final report explores this
contributor a lot. The report is easy to find on the web. ...

-


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
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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
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For help, send mail to the list

Re: [PSES] Safety standards versus safety engineering

[John Allen]

Rich

 

And I do have to disagree with you on this one. 

 

The top decision-makers set the company goals, but they also set and oversee
the overall company culture, and the guys the middle follow their leads.


 

So, if you get - and you do! - middle management and/project managers who
will do what they think the bosses want - and those bosses are not
safety-minded in at least some small fashion -, and/or what they think they
can get away with not doing in order to save time/money or give them a leg
up the corporate ladder, then corners will be cut wherever it suits them. 

 

Therefore as safety and regs compliance are often seen as unnecessary
cost/time/manpower burdens, and which don't contribute to the on-time 
to-budget delivery of projects, then they are thus obvious targets for
doing as little, and as cheaply, as possible.

 

This is not idle gossip or speculation - I have seen various aspects of the
above in a wide range of companies (including some that I worked both before
and after, I think, our mutual time at HP - and at HP itself for that
matter, which is one of the reasons why I myself left!)

 

John Allen.

W.London, UK

 

 

From: Richard Nute [mailto:ri...@ieee.org] 
Sent: 06 March 2015 23:16
To: 'John Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Safety standards versus safety engineering

 

 

 

I disagree.

 

The decision-makers leave the safety as well as the specific design to the
experts.  The decision-makers look at the bigger picture as to the features
of the product, how it fits into the product mix, and other high-level
stuff.  They don't engage in the specific design and they don't engage in
the safety aspects.

 

Trying to raise safety to a decision-maker level is futile, and expecting
them to champion safety is also futile.  Safety and EMC are things that must
be applied to a product.  The decision-makers know and expect that.  The
only thing that matters is if either causes a schedule delay.  

 

 

Best regards,

Rich

 

 

 

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Friday, March 06, 2015 1:50 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

 

And not so cordially either!

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 06 March 2015 21:47
To: 'Bonsen, Robert'
Subject: RE: [PSES] Safety standards versus safety engineering

 

Robert

 

You have obviously been there!

 

I sympathise, completely - I have too!

 

John Allen

W. London, UK

 

From: Bonsen, Robert [mailto:robert.bon...@hp.com] 
Sent: 06 March 2015 21:21
To: John Allen
Subject: RE: [PSES] Safety standards versus safety engineering

 

Good points, all, especially this one. Those not involved with larger
companies often miss that safety is only a part of the bigger picture,
unfortunately. Thus, the decision makers are rarely sufficiently educated,
experienced or even interested in championing safety.

 

That is left to the guys at the bottom, who, when accused of making
pro-safety calls against bigger business goals, are typically cordially
invited to find employ elsewhere. 

 


-

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

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Re: [PSES] Safety standards versus safety engineering

[John Allen]

John T

 

Your last line is what,  I think, most of us have said or implied!

 

So what do the rest of the viewers think, and where do you think the
world is globally?

 

John Allen

W.London, UK

 

From: Tyra, John [mailto:john_t...@bose.com] 
Sent: 07 March 2015 21:35
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

 

With all due respect I think this is a generalization as when I worked at
TUV I assisted companies who were very safety conscience and it came down
from the top. I am also lucky to currently work for a company where the
upper management is very supportive of product safety.

 

That being said I also worked with companies when at TUV who wanted to do
the minimum and in some cases argued against compliance with the standards
or  who I felt tried to hide noncompliance's from me.

 

IMHO it really depends on the company and the culture of that company.

 

 

 

From: Richard Nute [mailto:ri...@ieee.org] 
Sent: Friday, March 06, 2015 6:16 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

 

 

 

I disagree.

 

The decision-makers leave the safety as well as the specific design to the
experts.  The decision-makers look at the bigger picture as to the features
of the product, how it fits into the product mix, and other high-level
stuff.  They don't engage in the specific design and they don't engage in
the safety aspects.

 

Trying to raise safety to a decision-maker level is futile, and expecting
them to champion safety is also futile.  Safety and EMC are things that must
be applied to a product.  The decision-makers know and expect that.  The
only thing that matters is if either causes a schedule delay.  

 

 

Best regards,

Rich

 

 

 

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Friday, March 06, 2015 1:50 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

 

And not so cordially either!

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 06 March 2015 21:47
To: 'Bonsen, Robert'
Subject: RE: [PSES] Safety standards versus safety engineering

 

Robert

 

You have obviously been there!

 

I sympathise, completely - I have too!

 

John Allen

W. London, UK

 

From: Bonsen, Robert [mailto:robert.bon...@hp.com] 
Sent: 06 March 2015 21:21
To: John Allen
Subject: RE: [PSES] Safety standards versus safety engineering

 

Good points, all, especially this one. Those not involved with larger
companies often miss that safety is only a part of the bigger picture,
unfortunately. Thus, the decision makers are rarely sufficiently educated,
experienced or even interested in championing safety.

 

That is left to the guys at the bottom, who, when accused of making
pro-safety calls against bigger business goals, are typically cordially
invited to find employ elsewhere. 

 

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Re: [PSES] Safety standards versus safety engineering

[John Allen]

I agree with John T.  The world's companies are a mixed bag of safety cultures. 
 I've had the opportunity to work with some great companies in which safety is 
priority, always taking the high road.  In these companies the culture started 
at the top.  Even had the CEO for one of them often sit in our safety meetings. 
 Of course these companies are all about brand name protection, but regardless, 
safety is a priority.  Unfortunately I've also seen the polar opposite.  Just 
had the Chief Technical Officer of a client hand me an interconnecting cord 
for under cabinet lighting with male terminals on both ends.  When I rolled my 
eyes at him, he asked what the problem was.  Even after I asked him to hold one 
end while I plug in the other, he asked if there were any NRTL's that would 
accept it.

We have a tough job as compliance engineers if the client, or boss, does not 
make safety a priority.  Often it's like talking to the wall.  But we keep 
doing our part so we can sleep at night.

I know ANSI and others have a group reaching out to CEO's to try to get safety 
built into company cultures.  And showing them why it makes financial sense to 
do so.  Joe Bhatia from ANSI spoke at a past ISPCE symposium about it.  If your 
company  does not have safety as a priority, maybe reach out to Mr. Bhatia and 
have him send your boss some information.

The 2015 ISPCE also has a new track called Compliance 101.  The idea is to help 
designers and newbies to compliance understand the general requirements so 
they can build safety into the design, as they're designing. Some of the 
presentations can be a great way to show your boss the basics, even if it falls 
on deaf ears.

And maybe with these activities, along with HBSE and Risk Assessments being 
incorporated into our Standards, there will be a day when safety takes priority 
for everyone.



On Mar 7, 2015, at 3:56 PM, John Allen 
john_e_al...@blueyonder.co.ukmailto:john_e_al...@blueyonder.co.uk wrote:

John T

Your last line is what,  I think, most of us have said or implied!

So what do the rest of the “viewers” think, and where do you think the “world” 
is globally?

John Allen
W.London, UK

From: Tyra, John [mailto:john_t...@bose.com]
Sent: 07 March 2015 21:35
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

With all due respect I think this is a generalization as when I worked at TUV I 
assisted companies who were very safety conscience and it came down from the 
top. I am also lucky to currently work for a company where the upper management 
is very supportive of product safety.

That being said I also worked with companies when at TUV who wanted to do the 
minimum and in some cases argued against compliance with the standards or  who 
I felt tried to hide noncompliance’s from me.

IMHO it really depends on the company and the culture of that company.



From: Richard Nute [mailto:ri...@ieee.org]
Sent: Friday, March 06, 2015 6:16 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering



I disagree.

The decision-makers leave the safety as well as the specific design to the 
experts.  The decision-makers look at the bigger picture as to the features of 
the product, how it fits into the product mix, and other high-level stuff.  
They don’t engage in the specific design and they don’t engage in the safety 
aspects.

Trying to raise safety to a decision-maker level is futile, and expecting them 
to champion safety is also futile.  Safety and EMC are things that must be 
applied to a product.  The decision-makers know and expect that.  The only 
thing that matters is if either causes a schedule delay.


Best regards,
Rich




From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Friday, March 06, 2015 1:50 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

And not so cordially either!

From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: 06 March 2015 21:47
To: 'Bonsen, Robert'
Subject: RE: [PSES] Safety standards versus safety engineering

Robert

You have obviously “been there”!

I sympathise, completely – I have too!

John Allen
W. London, UK

From: Bonsen, Robert [mailto:robert.bon...@hp.com]
Sent: 06 March 2015 21:21
To: John Allen
Subject: RE: [PSES] Safety standards versus safety engineering

Good points, all, especially this one. Those not involved with larger companies 
often miss that safety is only a part of the bigger picture, unfortunately. 
Thus, the decision makers are rarely sufficiently educated, experienced or even 
interested in championing safety.

That is left to the guys at the bottom, who, when accused of making pro-safety 
calls against bigger business goals, are typically cordially invited to find 
employ elsewhere

Re: [PSES] Safety standards versus safety engineering

[John Allen]

Good morning

W.r.t. my post yesterday morning, I should have clarified my comment about
H and P, and made it clear that it referred to the behaviour of some of
the managers where I worked at the time - and not to the company's overall
approach to compliance with regulations and standards, which was very good.

John Allen
W.London.

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 07 March 2015 10:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

In message 
!!AAAYAGfd0ZsQVUREqttMnk+fShfigAAAECy+EXCYlFJPsxoGw
gF+As0BAA==@blueyonder.co.uk, dated Sat, 7 Mar 2015, 

And I do have to disagree with you on this one.

I agree. Rich is describing an ideal company, and those are very rare, 
mostly started-up by a technical person, whose management role has not 
been taken over by suits.

Can you imagine H and P not being standards-conscious?
-- 

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Re: [PSES] USB Mains Outlet sockets

[John Allen]

John, Richard

 

I had forgotten about Annex II, and so I think that, between you, you have
probably identified the two main reasons why the suppliers of these products
appear to have decided not to apply the CE mark.

 

However, one thing then occurs to me: 

 

Assuming that Richard is correct in saying Maybe the socket importers wish
to claim that their sockets are fixed installations and therefore
excluded,  under the EMC Directive, from the need for conformance to
Standards and from CE marking! then does that mean that your average
domestic user who installs one of these outlets, then need to create a
Technical File to demonstrate that his house complies the EMCD?

(Whilst I am well aware of the responsibilities placed on
commercial/industrial premises operators for EMCD compliance, but I had
never really considered the question of domestic properties)

 

Oh, and BTW, what would happen if someone, as they probably will, fits
these outlets to mobile homes/caravans which otherwise have no
electrical/electronic circuitry in them  are they turning an essentially
EMC-passive mobile installations (within the scope of the EMCD) into
active ones, that would then need EMCD assessment?

 

Stupid questions? Maybe, but would be interesting to hear your thoughts?

 

John  Allen

W. London, UK

 

 

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 13 March 2015 18:51
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] USB Mains Outlet sockets

 

In message


mailto:04cab9802ba27a409548dd47de1da7ef8d8c128...@slomailprd01.polycom.com
04cab9802ba27a409548dd47de1da7ef8d8c128...@slomailprd01.polycom.com,

dated Fri, 13 Mar 2015, Pearson, John  mailto:john.pear...@polycom.com
john.pear...@polycom.com

writes:

 

Any more thoughts?  Concur?

 

No. There is no standard that applies to these products. You cannot
'cherry-pick' inapplicable standards to argue that they should not be
marketed.

 

Plug and socket outlets for domestic use are exempt from the LVD (Annex II),
so it is not allowed to apply the CE mark.

--

OOO - Own Opinions Only. With best wishes. See
http://www.jmwa.demon.co.uk www.jmwa.demon.co.uk When I turn my back on
the sun, it's to look for a rainbow John Woodgate, J M Woodgate and
Associates, Rayleigh, Essex UK

 

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Re: [PSES] USB Mains Outlet sockets

[John Allen]

John 

Leaving aside the LVD in/out issues, since a small USB charger is almost
inherently not EMC benign, then surely it must be subject to the EMCD -
unless you firmly play the installations card - ?

If it IS subject to the EMCD, then the essential requirements of that
apply - regardless of whether there are directly-applicable harmonised
Standards - , CE marking is required and the overall CE marking requirements
apply, and that would then throw the RoHS II requirements into play as well.

So, I think the installations issue could probably be the critical one.

John Allen
W. London, UK

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 14 March 2015 10:15
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] USB Mains Outlet sockets

In message FCA549BE3ECF9D4CB8CB8576837EA48920ACD5@ZEUS.cetest.local,
dated Sat, 14 Mar 2015, ce-test, qualified testing bv - Gert Gremmen 
g.grem...@cetest.nl writes:

As this outlet sockets are a mixed function product, I would just 
assume (backed up by many documents/conventions) that both regulations 
for wall outlets as well as those for power supplies are applicable.
Both categories are adequately covered by suitable standards.

But the standards for wall outlets are not harmonized, so I think they are
not really 'covered' in the sense of Directives. I think a 'notified body'
procedure would at least be wise, if not essential.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I
turn my back on the sun, it's to look for a rainbow John Woodgate, J M
Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] USB Mains Outlet sockets

[John Allen]

It's interesting to note that both the genuine and the counterfeit items
are marked as complying with BS5733, which is the catch all (and uniquely
British!) BS safety standard for electrical installation accessories which
don't fit into the scope any other particular safety standard - so that
might be a rationale for claiming compliance with the UK regs requirements
for installation accessories.

 

However, that certainly begs the question of compliance with the EMCD and
the energy-efficiency Directive requirements (and RoHS II for that matter) -
which rationally I think that they should.

 

John Allen

W. London, UK

From: Pearson, John [mailto:john.pear...@polycom.com] 
Sent: 13 March 2015 13:51
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] USB Mains Outlet sockets

 

Here is a Friday discussion topic for you guys.

 

In the UK we are seeing a plethora of aftermarket 250v AC mains outlet
sockets which are supplied for installation, it seems by the homeowner,
(this has been a traditional practice over here.  In the US I understand
that this happens less).  The advantage of these sockets is that they also
give you 2 USB charging ports in the wall as well as two socket outlets.  I
see large distributors (Screwfix, Amazon.co.uk and Ebuyer for e.g.) selling
several https://www.google.co.uk/search?q=lap+mains+socket
https://www.google.co.uk/search?q=lap+mains+socketsourceid=ie7rls=com.mic
rosoft:en-GB:IE-Addressie=oe=gfe_rd=crei=edoCVauNDquD8Qekq4HgBQgws_rd=s
sl#rls=com.microsoft:en-GB:IE-Addresstbm=shopq=usb+mains+power+socket+outl
et
sourceid=ie7rls=com.microsoft:en-GB:IE-Addressie=oe=gfe_rd=crei=edoCVa
uNDquD8Qekq4HgBQgws_rd=ssl#rls=com.microsoft:en-GB:IE-Addresstbm=shopq=us
b+mains+power+socket+outlet

.  Look out for an explosion of these items is my suspicion as the idea of
getting rid of plug in USB chargers is very appealing, even to me!

 

 

Questions from the compliance side

 

Energy Efficiency

Single rail PSU's are subject to mandatory Energy Efficiency marking and
performance.  All the units I have seen thus far do not mark or declare any
performance figures.  The PSU being wired into the mains does not to my mind
preclude these products from compliance with the Eco-design Directive and
278/2009 specifically, or am I missing something?

 

Safety of USB port

All of the devices I have seen are stamped with EN 60950-1 on the back thus
appear to be purporting compliance this std.  Not seen any DoC's.  I do not
understand how they can meet the Disconnect Device requirements of CL 3.4 by
design unless the mains switches are the disconnect device.  I see however
that the switches only turn off the mains to the traditional BS1363 sockets.
Any thoughts?

 

Certification

Several of these items claim ASTA certification.  I wonder what ASTA
certified them to.  I suspect not EN 60950-1.  Is that not misleading?

 

Insulation test

At least one of these devices states Do not Megger the device.  Apparently
the USB charge circuitry cannot stand high voltage and would likely or
possibly fail.  As it is recommend in the UK that home wiring be regularly
checked for insulation issues is this product fit for purpose ?

 

CE marking

Several of these are not CE marked.  See this
http://www.amazon.co.uk/Connekt-Gear-Power-Socket-Charging-white/dp/B00KO1KD
N4

 

Rather bizarrely one supplier with a seemingly non CE marked product issued
this http://www.groupgear.co.uk/catalogue/27-2000-Counterfeit-warning.pdf

 

Does outlet sockets require CE marking by the placer on the market and if
they also incorporate a PSU for charging ITE product doesn't it become an
ITE product itself subject to EMCD and LVD and thus require CE marking for
that purpose also?

 

 

 

All this said it seems that they are getting great reviews but likely from
the user benefit rather than the above

 

Look forward to interesting responses.

 

John

 

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Re: [PSES] USB Mains Outlet sockets

[John Allen]

PS: another part of the question, for the items that ARE CE marked, is: are
they claiming compliance with LVD by reference to the essential protection
requirements of Annex I, and thus claiming that the combination of 60950-1
and BS5733 compliance does ensure compliance with the Directive?

 

More questions than answers so far (as is often the case J)!

 

John Allen

W. London, UK.

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 13 March 2015 15:31
To: 'Pearson, John'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] USB Mains Outlet sockets

 

It's interesting to note that both the genuine and the counterfeit items
are marked as complying with BS5733, which is the catch all (and uniquely
British!) BS safety standard for electrical installation accessories which
don't fit into the scope any other particular safety standard - so that
might be a rationale for claiming compliance with the UK regs requirements
for installation accessories.

 

However, that certainly begs the question of compliance with the EMCD and
the energy-efficiency Directive requirements (and RoHS II for that matter) -
which rationally I think that they should.

 

John Allen

W. London, UK

From: Pearson, John [mailto:john.pear...@polycom.com] 
Sent: 13 March 2015 13:51
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] USB Mains Outlet sockets

 

Here is a Friday discussion topic for you guys.

 

In the UK we are seeing a plethora of aftermarket 250v AC mains outlet
sockets which are supplied for installation, it seems by the homeowner,
(this has been a traditional practice over here.  In the US I understand
that this happens less).  The advantage of these sockets is that they also
give you 2 USB charging ports in the wall as well as two socket outlets.  I
see large distributors (Screwfix, Amazon.co.uk and Ebuyer for e.g.) selling
several https://www.google.co.uk/search?q=lap+mains+socket
https://www.google.co.uk/search?q=lap+mains+socketsourceid=ie7rls=com.mic
rosoft:en-GB:IE-Addressie=oe=gfe_rd=crei=edoCVauNDquD8Qekq4HgBQgws_rd=s
sl#rls=com.microsoft:en-GB:IE-Addresstbm=shopq=usb+mains+power+socket+outl
et
sourceid=ie7rls=com.microsoft:en-GB:IE-Addressie=oe=gfe_rd=crei=edoCVa
uNDquD8Qekq4HgBQgws_rd=ssl#rls=com.microsoft:en-GB:IE-Addresstbm=shopq=us
b+mains+power+socket+outlet

.  Look out for an explosion of these items is my suspicion as the idea of
getting rid of plug in USB chargers is very appealing, even to me!

 

 

Questions from the compliance side

 

Energy Efficiency

Single rail PSU's are subject to mandatory Energy Efficiency marking and
performance.  All the units I have seen thus far do not mark or declare any
performance figures.  The PSU being wired into the mains does not to my mind
preclude these products from compliance with the Eco-design Directive and
278/2009 specifically, or am I missing something?

 

Safety of USB port

All of the devices I have seen are stamped with EN 60950-1 on the back thus
appear to be purporting compliance this std.  Not seen any DoC's.  I do not
understand how they can meet the Disconnect Device requirements of CL 3.4 by
design unless the mains switches are the disconnect device.  I see however
that the switches only turn off the mains to the traditional BS1363 sockets.
Any thoughts?

 

Certification

Several of these items claim ASTA certification.  I wonder what ASTA
certified them to.  I suspect not EN 60950-1.  Is that not misleading?

 

Insulation test

At least one of these devices states Do not Megger the device.  Apparently
the USB charge circuitry cannot stand high voltage and would likely or
possibly fail.  As it is recommend in the UK that home wiring be regularly
checked for insulation issues is this product fit for purpose ?

 

CE marking

Several of these are not CE marked.  See this
http://www.amazon.co.uk/Connekt-Gear-Power-Socket-Charging-white/dp/B00KO1KD
N4

 

Rather bizarrely one supplier with a seemingly non CE marked product issued
this http://www.groupgear.co.uk/catalogue/27-2000-Counterfeit-warning.pdf

 

Does outlet sockets require CE marking by the placer on the market and if
they also incorporate a PSU for charging ITE product doesn't it become an
ITE product itself subject to EMCD and LVD and thus require CE marking for
that purpose also?

 

 

 

All this said it seems that they are getting great reviews but likely from
the user benefit rather than the above

 

Look forward to interesting responses.

 

John

 

-


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Website

Re: [PSES] Basic instruction in EMC and safety requirements for the non-professional

[John Allen]

John

 

And so what has actually changed with today's get rich quick senior
managers of both types in the last 50 years? 

 

Often, unfortunately not very much! L

 

John Allen 

W.London, UK

 

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 31 March 2015 22:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Basic instruction in EMC and safety requirements for the
non-professional

 

In message

!!AAAYAEGjmYsMtGZAuvo7rFLQ++figAAAEGclIn6IPpdMlDLZ1

 mailto:GnjPVEBAA==@blueyonder.co.uk
GnjPVEBAA==@blueyonder.co.uk, dated Tue, 31 Mar 2015, John Allen 
mailto:john_e_al...@blueyonder.co.uk john_e_al...@blueyonder.co.uk
writes:

 

- unfortunately, the  cost without a sale argument is prevalent,

 

But since the cost is necessary for market entry, the real point is 'no sale
without this cost'.

 

and not only amongst the marketing men but also amongst some of the 

senior technical management because of their conviction that the 

technical superiority of their products will overcome any minor

legal issues with problems in selling those products!

 

That attitude was 'dinosaur-like' 50 years ago.

--

OOO - Own Opinions Only. With best wishes. See
http://www.jmwa.demon.co.uk www.jmwa.demon.co.uk When I turn my back on
the sun, it's to look for a rainbow John Woodgate, J M Woodgate and
Associates, Rayleigh, Essex UK

 

-



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Re: [PSES] Basic instruction in EMC and safety requirements for the non-professional

[John Allen]

Ken

In one respect you are quite right, but you still really do have to
understand the minds of the people you need to convince/convert, and thus
you need to understand and rationalise how you will present those primers to
the audience that you hope will take it all in - and that means really
understanding your likely audience, and then to pitch the presentations in
terms that they will quickly absorb.

John Allen
W.London, UK.



-Original Message-
From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: 31 March 2015 21:50
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Basic instruction in EMC and safety requirements for the
non-professional

There appear to be some serious attitude cases subscribed to this forum. I
am truly looking for primer type info for the non-engineer. Not trying to
persuade recalcitrant mangers, just trying to round up some basic info on
the subject.

Ken Javor
Phone: (256) 650-5261


 From: Brian Oconnell oconne...@tamuracorp.com
 Reply-To: Brian Oconnell oconne...@tamuracorp.com
 Date: Tue, 31 Mar 2015 20:31:27 +
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Conversation: [PSES] Basic instruction in EMC and safety requirements 
 for the non-professional
 Subject: Re: [PSES] Basic instruction in EMC and safety requirements 
 for the non-professional
 
 Mr. Nute,
 
 As this is probably for management, respectfully suggest that the 
 premier exposition for PHBs is none other than a reference to some 
 Wile E. Coyote videos. This is well within the MBA attention span and 
 their required level of understanding for product performance and
conformity.
 
 Brian
 
 
 From: Richard Nute [mailto:ri...@ieee.org]
 Sent: Tuesday, March 31, 2015 12:57 PM
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] Basic instruction in EMC and safety requirements 
 for the non-professional
 
 Hi Ken:
 
 Oh, boy.  EMC and safety requirements are a cost without a sale.  That 
 is what a VP of marketing told me.   For the most part, management 
 would prefer to keep the costs at a minimum.
 
 EMC, ROHS, and safety requirements are rules that the products must 
 comply with in order to sell in various countries.
 
 1)  The requirements must be included in the design of the product.
 
 2)  Tests verify that the product complies with the requirements 
 and determine whether the product can bear certification marks.
 
 3)  Marks applied to the product attest to compliance with the 
 requirements.
 
 4)  For some countries, documents accompanying the product attest 
 to compliance with the requirements.
 
 5)  Some countries and certification houses require factory 
 inspection as a condition for marking the product.
 
 6)  Some certification houses require periodic factory surveillance.
 
 7)  The cost of compliance at our company is.  The number of 
 full-time employees in this activity is.
 
 I'm sure that you can amplify on any of these points if asked.
 
 
 Good luck, and best regards,
 Rich
 
 From: Ken Javor [mailto:ken.ja...@emccompliance.com]
 Sent: Tuesday, March 31, 2015 10:39 AM
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: [PSES] Basic instruction in EMC and safety requirements for 
 the non-professional
 
 Can anyone out there suggest either some texts or urls covering the 
 subject matter for management at a higher level not interested in 
 details?  Especially as to impact on selling equipment outside a country's
own borders.
 
 Thank you,
 
 Ken Javor
 Phone: (256) 650-5261
 
 -
 
 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 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

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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
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well-used formats), large files, etc.

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

Re: [PSES] Basic instruction in EMC and safety requirements for the non-professional

[John Allen]

Ken

 

OK, I do understand, and so make sure that what you pass on, to the managers
asking for the info, the other half of the equation in terms that they
themselves understand for the audience that they need to reach - and not
just pass on the info

 

John Allen

W.London, UK

 

-Original Message-
From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: 31 March 2015 22:49
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Basic instruction in EMC and safety requirements for the
non-professional

 

I'm not making a persuasive pitch. I was asked to provide primer type
material for someone who wanted an overview of the topic without getting
into engineering details. I started off with enclosures for rotating fans
and the UL finger, but I figured there would be much more comprehensive
backgrounds available from the cognoscenti who subscribe to this forum.

 

Ken Javor

Phone: (256) 650-5261

 

 

 From: John Allen  mailto:john_e_al...@blueyonder.co.uk
john_e_al...@blueyonder.co.uk

 Date: Tue, 31 Mar 2015 22:33:40 +0100

 To: 'Ken Javor'  mailto:ken.ja...@emccompliance.com
ken.ja...@emccompliance.com

 Cc:  mailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG

 Subject: RE: [PSES] Basic instruction in EMC and safety requirements 

 for the non-professional

 

 Ken

 

 In one respect you are quite right, but you still really do have to 

 understand the minds of the people you need to convince/convert, and 

 thus you need to understand and rationalise how you will present those 

 primers to the audience that you hope will take it all in - and that 

 means really understanding your likely audience, and then to pitch the 

 presentations in terms that they will quickly absorb.

 

 John Allen

 W.London, UK.

 

 

 

 -Original Message-

 From: Ken Javor [ mailto:ken.ja...@emccompliance.com
mailto:ken.ja...@emccompliance.com]

 Sent: 31 March 2015 21:50

 To:  mailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG

 Subject: Re: [PSES] Basic instruction in EMC and safety requirements 

 for the non-professional

 

 There appear to be some serious attitude cases subscribed to this 

 forum. I am truly looking for primer type info for the non-engineer. 

 Not trying to persuade recalcitrant mangers, just trying to round up 

 some basic info on the subject.

 

 Ken Javor

 Phone: (256) 650-5261

 

 

 From: Brian Oconnell  mailto:oconne...@tamuracorp.com
oconne...@tamuracorp.com

 Reply-To: Brian Oconnell  mailto:oconne...@tamuracorp.com
oconne...@tamuracorp.com

 Date: Tue, 31 Mar 2015 20:31:27 +

 To:  mailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG

 Conversation: [PSES] Basic instruction in EMC and safety requirements 

 for the non-professional

 Subject: Re: [PSES] Basic instruction in EMC and safety requirements 

 for the non-professional

 

 Mr. Nute,

 

 As this is probably for management, respectfully suggest that the 

 premier exposition for PHBs is none other than a reference to some 

 Wile E. Coyote videos. This is well within the MBA attention span and 

 their required level of understanding for product performance and

 conformity.

 

 Brian

 

 

 From: Richard Nute [ mailto:ri...@ieee.org mailto:ri...@ieee.org]

 Sent: Tuesday, March 31, 2015 12:57 PM

 To:  mailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG

 Subject: Re: [PSES] Basic instruction in EMC and safety requirements 

 for the non-professional

 

 Hi Ken:

 

 Oh, boy.  EMC and safety requirements are a cost without a sale.  

 That is what a VP of marketing told me.   For the most part, 

 management would prefer to keep the costs at a minimum.

 

 EMC, ROHS, and safety requirements are rules that the products must 

 comply with in order to sell in various countries.

 

 1)  The requirements must be included in the design of the product.

 

 2)  Tests verify that the product complies with the requirements 

 and determine whether the product can bear certification marks.

 

 3)  Marks applied to the product attest to compliance with the 

 requirements.

 

 4)  For some countries, documents accompanying the product attest 

 to compliance with the requirements.

 

 5)  Some countries and certification houses require factory 

 inspection as a condition for marking the product.

 

 6)  Some certification houses require periodic factory surveillance.

 

 7)  The cost of compliance at our company is.  The number of 

 full-time employees in this activity is.

 

 I'm sure that you can amplify on any of these points if asked.

 

 

 Good luck, and best regards,

 Rich

 

 From: Ken Javor [ mailto:ken.ja...@emccompliance.com
mailto:ken.ja...@emccompliance.com]

 Sent: Tuesday, March 31, 2015 10:39 AM

 To:  mailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG

 Subject: [PSES] Basic instruction in EMC and safety requirements for 

 the non-professional

 

 Can anyone out there suggest either some texts

Re: [PSES] Basic instruction in EMC and safety requirements for the non-professional

[John Allen]

Brian  friends

 

Your comment about W.E.C. is undoubtedly true in many cases as I have seen
on many occasions - unfortunately, the  cost without a sale argument is
prevalent, and not only amongst the marketing men but also amongst some of
the senior technical management because of their conviction that the
technical superiority of their products will overcome any minor legal
issues with problems in selling those products! 

 

Unfortunately, again, they often then hit the real World and find out
otherwise - which is why you need to convince both of those groups of the
need for compliance, and so the pitch needs to be targeted at both of them. 

 

And, in the case of the techies, that means that you probably need to
outline, sometimes over a long period of time, what the technical issues
are, and then what the potential implications are - possibly by emphasising
the non-compliant aspects of a design and the potential risks to both life
and to being hit with the relevant legal penalties in terms criminality,
fines (both to the company and to them personally), and in terms of company
reputation/public perception.

 

John Allen

W.London, UK.

 

-Original Message-
From: Brian Oconnell [mailto:oconne...@tamuracorp.com] 
Sent: 31 March 2015 21:31
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Basic instruction in EMC and safety requirements for the
non-professional

 

Mr. Nute,

 

As this is probably for management, respectfully suggest that the premier
exposition for PHBs is none other than a reference to some Wile E. Coyote
videos. This is well within the MBA attention span and their required level
of understanding for product performance and conformity.

 

Brian

 

 

From: Richard Nute [ mailto:ri...@ieee.org mailto:ri...@ieee.org]

Sent: Tuesday, March 31, 2015 12:57 PM

To:  mailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] Basic instruction in EMC and safety requirements for the
non-professional

 

Hi Ken:

 

Oh, boy.  EMC and safety requirements are a cost without a sale.  That is
what a VP of marketing told me.   For the most part, management would prefer
to keep the costs at a minimum.

 

EMC, ROHS, and safety requirements are rules that the products must comply
with in order to sell in various countries.  

 

1)  The requirements must be included in the design of the product.

 

2)  Tests verify that the product complies with the requirements and
determine whether the product can bear certification marks.

 

3)  Marks applied to the product attest to compliance with the
requirements.

 

4)  For some countries, documents accompanying the product attest to
compliance with the requirements.

 

5)  Some countries and certification houses require factory inspection
as a condition for marking the product.

 

6)  Some certification houses require periodic factory surveillance.

 

7)  The cost of compliance at our company is.  The number of full-time
employees in this activity is.

 

I'm sure that you can amplify on any of these points if asked.

 

 

Good luck, and best regards,

Rich

 

From: Ken Javor [ mailto:ken.ja...@emccompliance.com
mailto:ken.ja...@emccompliance.com]

Sent: Tuesday, March 31, 2015 10:39 AM

To:  mailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG

Subject: [PSES] Basic instruction in EMC and safety requirements for the
non-professional

 

Can anyone out there suggest either some texts or urls covering the subject
matter for management at a higher level not interested in details?
Especially as to impact on selling equipment outside a country's own
borders.

 

Thank you,

 

Ken Javor

Phone: (256) 650-5261

 

-



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

 

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http://www.ieee-pses.org/emc-pstc.html

 

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http://product-compliance.oc.ieee.org/
http://product-compliance.oc.ieee.org/ can be used for graphics (in
well-used formats), large files, etc.

 

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

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David Heald:  mailto:dhe...@gmail.com dhe...@gmail.com

Re: [PSES] standards-driven product safety

[John Allen]

No need to say much, except that I fully agree with both Rich and John W!

John Allen
W.London, UK

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 22 February 2015 08:04
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] standards-driven product safety

In message 54e90ce3.9030...@bendbroadband.com, dated Sat, 21 Feb 2015,
Richard Nute ri...@bendbroadband.com writes:

 No-one will try to write a standard for a product that does not yet 
 exist, so standards development must always lag innovation.

The question I ask is:  Can you make a safe product without a safety 
standard?

Yes. 'Safe' products (perhaps not by the current criteria) preceded, for
example, BS 415 (an ancestor of IEC/EN 60065), which originally applied to
'battery eliminators' (mains power packs for battery radios, 120 V DC at
about 60 mA).

If the principles of product safety are known, they can be applied to 
an innovative product technology as well as existing product 
technology.
No safety standard is required.

Agreed. The EU system allows that.

The three-block model can tell when safeguards are required.  For most 
products, both a basic safeguard and a supplementary safeguard provide 
sufficient safety.  Such safeguards provide protection under normal 
conditions and under single fault (e.g., failure of the basic
safeguard)
conditions.

Agreed.

Such is engineering and science driven safety, not standards driven 
safety.

Well, they are not opposites. Standards are necessary to support regulation
intended to eliminate unsafe product from the market. Those standards should
be 'engineering and science driven', not arbitrarily prescriptive.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I
turn my back on the sun, it's to look for a rainbow John Woodgate, J M
Woodgate and Associates, Rayleigh, Essex UK

-

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-

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Attachments are not permitted but the IEEE PSES Online Communities site at 
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Website:  http://www.ieee-pses.org/
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Re: [PSES] Machinery requirements for Japan market

[John Allen]

Bit like the voluntary nature of VCCI EMC certification, then!:DSent from my FonepadChris 0133def26cf0-dmarc-requ...@ieee.org wrote:Pete,Very true'voluntary' definition.Big name Japanese customers will not buy your product without these labels/certifications.I always recommend the certification route to our management and spend the extra funds to get VCCI report,regardsChristopherFrom: Pete Perkins 0061f3f32d0c-dmarc-requ...@ieee.org To: EMC-PSTC@LISTSERV.IEEE.ORG  Sent: Monday, February 23, 2015 11:52 AM Subject: Re: [PSES] Machinery requirements for Japan market   Mike, Dave et al, Just a reminder, 'voluntary' has a different definition in Japan.  We tried to play thecard when I worked at the bigelectronics company but our Japanese distributor remended us that they hadvolunteered to meet the requirement so it wasn't voluntary for the designand manufacturing company. :)   br,   Pete Peter E Perkins, PEPrincipal Product Safety EngineerPO Box 23427Tigard, ORe 97281-3427 503/452-1201   fone/faxp.perk...@ieee.org  __ _ _ _Hi Dave,From what I understand, the "Electrical Appliance and Material Safety Law"under the Ministry of Economy Trade and Industry has lists of "SpecifiedElectrical Appliances and Materials (Category A and B)" which determine theelectrical safety requirements for certain products.http://www.meti.go.jp/english/policy/economy/consumer/pse/02.htmhttp://www.meti.go.jp/english/policy/economy/consumer/pse/03.htmEMC is voluntary under the Voluntary Control Council for Interference(VCCI). https://www.vcci.jp/vcci_e/Mike VioletteWashington Laboratories  American Certification Body mi...@wll.com+1 240 401 1388On Feb 23, 2015, at 10:20 AM, Nyffenegger, Dave wrote: Hi Folks,  Can anyone tell me if there are any national requirements forcertifications of light machinery used commercially in the officeenvironment in Japan or point me to where I can learn about that? i.e.Safety and/or EMC etc.  thanks  David P. Nyffenegger, PMP, SM-IEEE Product Development Manager Bell and Howell
-

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Re: [PSES] Google Earth Pro Now Free - the Licence Key!

[John Allen]

Went to load GEP this afternoon but could not open the link to get the free
Licence Key.

 

Bit of searching elsewhere took me to this page, and it turns out that a lot
of people are having the same problem:

http://techcrunch.com/2015/01/31/once-399-a-year-google-earth-pro-is-now-fre
e/#tmhmdj:U0B

 

Some way down, Owen E Dismuke gives this info “

“Sign up page now has a link at the top stating Sign up is no longer
required for Google Earth Pro. Click here to download Earth Pro, then sign
in using your email address and the License Key GEPFREE.

 

More realistically now, download and install GPE, and then enter the email
address and License Key as above. OTOH, if you don’t want to give your email
address, then put any sort of User Name and it lets you run the program
anyway (that’s what I did accidently)!

 

Enjoy 

 

John

From: Ed Price [mailto:edpr...@cox.net] 
Sent: 03 February 2015 01:03
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Google Earth Pro Now Free

 

FYI:

 

Google has now made their Google Earth Pro available for free (it used to
cost $400 for a 1 year license, but demand is so low that it looks like they
gave up trying to squeeze some money out of this version). 

Here’s what the Pro can do that the non-Pro version can’t:

*   Print images at 4800×3200; non-Pro is capped at 1000×1000.
*   Automatically import a few thousand addresses at once to be pinned
on a map. You can create a club membership maps or special interest maps,
like show every Wal-Mart in Manitoba.
*   Capture HD videos of what’s on screen.
*   Measure distances/areas using lines, paths, polygons, circles, and
more. Non-pro can only handle lines/paths. This is really handy if you want
to measure real estate or estimate construction projects.

All you have to do is go to https://geoauth.google.com/gev0/free_trial.html
and fill out the registration form. Ignore anything about costs and buying
and free trials. After filling out the form, Google will send you your key
by email.

 

Then, go to http://www.google.com/earth/download/gep/agree.html to start the
INSTALL. Google Earth Pro will install onto your machine (if you have Google
Earth already, it will preserve your preferences and locations) and
automatically remove the old Google Earth. Totally painless and quick
installation.

 

Ed Price
WB6WSN
Chula Vista, CA USA
1961 Amphicar 770
2001 Fleetwood Storm 31W
2008 Ford Explorer

 

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Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?

[John Allen]

Good point - didn't know that (:-)), but it's another example of where the EU 
approach is more pragmatic.

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 21 February 2015 22:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone 
terminal equipment?

In message
!!AAAYAEGjmYsMtGZAuvo7rFLQ++figAAAEDf9dud5KeJHuCKyK
rUnaccBAA==@blueyonder.co.uk, dated Sat, 21 Feb 2015, John Allen 
john_e_al...@blueyonder.co.uk writes:

OTOH, the EU approach is more encompassing because the prime 
requirement is to comply with the essential protection requirements of 
the relevant Directive(s). As such you do NOT need to comply with all 
the detailed requirements of a standard, but if you claim compliance 
with a Harmonized Standard but you don’t comply with some of its 
specific requirements then you DO have to identify where you have 
deviated and how you still hold that you comply with the essential 
requirements of the Directive in question.

There is an important principle here, and it almost certainly applies to PV 
products, which use relatively new technology that is still being improved.

No-one will try to write a standard for a product that does not yet exist, so 
standards development must always lag innovation. If it lags as little as 
possible, it can hamper product improvement, because it's written around a 
'Mark 1' version of the new technology. If it lags a lot, badly-designed 
products can appear on the market, and the lagging standard's provisions may be 
influenced by them - governments and manufacturers will not generally allow 
standards to drive existing products from the market.

The EU system attempts to resolve this dilemma - swift standardisation is 
encouraged. Product improvement is permitted, but controlled by the requirement 
to state and justify a deviation from the applicable standard.

A historical example. LED lamps were illegal on British bicycles for some years 
after they became practicable, because the (very elderly) regulations specified 
'incandescent lamps', with the intention of disallowing acetylene ('carbide') 
lamps.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

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Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?

[John Allen]

Good morning (London time!)

 

W.r.t. the OSHA survey – things have changed a bit in the EU since 2008 – for 
both good and bad! 

 

I think there is more general awareness of the hazards of electrical and other 
goods – and certainly there are more product recalls than there ever were in 
earlier days, and the supply chain is more aware of its responsibilities to 
ensure that only “safe” items are supplied. You only have to look at the number 
of high-profile product recalls that now routinely occur!

 

OTOH, the ranges of goods on offer, and the variety of sources from which they 
come, have expanded enormously – and that, unfortunately, has lead to more 
“holes in the systems” for trying to ensure that only “safe” items are put on 
the market.

 

However, I think that there are several common factors which are tending to 
reinforce the overall trend towards safer products across the World, and thus 
in both N.America and Europe, such as:

 

1) More and more products are being developed for worldwide, as opposed to 
national, markets, and that means that the designers and manufacturers have to 
take all the market requirements into account – and, with the welcome rise in 
the importance of truly international safety standards, that means that those 
suppliers do more closely try to meet them (or then either fail to get their 
products into the big markets, or else get widely taken to account for 
supplying unsafe products)

 

The NTRL approach in N. America and the EU CE marking requirements over here 
have both substantially contributed to that  both directly in their own 
marketplaces and more globally as the less economically-developed countries 
(even the big ones like China!) pragmatically adopt the similar standards and 
regulatory controls on the basis that “if it works in the big countries then it 
should work for us as well” (and as well as encouraging and helping their own 
manufacturers to meet those same standards in order to have much wider export 
markets – or at least not to lose them!).

 

2) Intelligence gathering and dissemination of information on unsafe 
products is now much more worldwide – and so knowledge of those products 
quickly gets to both the regulators and the general public, and the latter are 
in a much better position to put pressure on the former to get the suppliers to 
get the problems fixed! 

 

Gone are the days when a supplier in one country could be reasonably sure that 
faults in products on one side of the World would not become public knowledge 
elsewhere – or that a local supplier could claim that a product was OK and a 
particular safety problem had never been known about in his marketplace, even 
though it was well known to the suppliers and regulators in another.

 

National product-alert/recall regimes are much more established in both of the 
big markets – the legally-enforced systems such CPSC/OHSA in the US and RAPEX 
in the EU have more clout than they did before. Even if many of the individual 
regulators are short of funds to enforce the rules, the combined effects of all 
of them help collectively

 

So where do I think that leaves us?  Well, collectively a lot better than we 
were in 2008, and with a general way forward to better, safer products. 

 

Is the NTRL system in the US still necessary? Yes, because that is how the 
State regulators and the public expect/require it to be at present – but in 
another 10-20 years, maybe it will become a fond memory from the past! J

 

John Allen

W.London, UK

 

From: Kevin Robinson [mailto:kevinrobinso...@gmail.com] 
Sent: 21 February 2015 03:21
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone 
terminal equipment?

 

OSHA Conducted a Request for Information (RFI) back in 2008 that compared the 
effectiveness and overall costs of SDoC vs 3rd Party Conformity assessment, the 
full summary report can be found here 
http://www.regulations.gov/#!documentDetail;D=OSHA-2008-0032-0099 .  While 
there was no clean data (products that were purely SDoC vs products that were 
purely 3rd party) available to draw firm conclusions, some of the findings were 
interesting:

 

*   Recorded injuries from electrical equipment were double (per 100,000 
workers) in the EU vs the US
*   A European study found that 58% of extension cords that were available 
for sale in the EU were sufficiently unsafe to justify a sales ban/product 
recall
*   In the 2008 RFI, OSHA estimated that implementing an SDoC system in the 
U.S. could cost the Agency approximately $360 million annually. In contrast, 
the current budget associated with operating the NRTL Program is approximately 
$1 million per year. Based on this estimate, operating an effective SDoC 
program would require OSHA to incur substantial additional costs. OSHA's 
current budget for all of its operations is about $558 million. Thus, based on 
OSHA's estimate, adopting an SDoC system would

Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?

[John Allen]

Brian

Not arguing at all with your comments - generally I think I generally agree 
with them in the specific issue of strict compliance with the standards.

But why do I think that that the standards are not the whole answer?

Why? Because the burden on small (and even on bigger) companies of complying 
with the complex requirements of many standards can be (generally IS) very 
heavy - just think how much time/money it takes to comply with the ones you 
know well - and then think how much more is required for a company that does 
not?

And, in that respect, the NRTL approach is very prescriptive - deviations from 
the standards is hard, if not impossible, for them to permit.

OTOH, the EU approach is more encompassing because the prime requirement is to 
comply with the essential protection requirements of the relevant Directive(s). 
As such you do NOT need to comply with all the detailed requirements of a 
standard, but if you claim compliance with a Harmonized Standard but you don’t 
comply with some of its specific requirements then you DO have to identify 
where you have deviated and how you still hold that you comply with the 
essential requirements of the Directive in question.

That's not to excuse companies that ignore the above statement of the 
requirements, but to explain why it is perfectly possible for the situations 
you describe could arise in the EU and yet still be compliant with the legal 
(and hopefully ethical) requirements in this area of the world. OTOH, in the US 
the situation is more black and white and with less room for flexibility - 
which also means a rather blinkered  approach IMHO!

John Allen
West London, UK
-Original Message-
From: Brian Oconnell [mailto:oconne...@tamuracorp.com] 
Sent: 21 February 2015 20:21
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone 
terminal equipment?

Non sequitur? The survey indicated injury rates, not recalled products 
(actually preferable to injuries).

A small example from my edge of the desert. With exception of the U.K. and 
Germany, all of the PV stuff that has been reviewed by self that was built in 
the EU required some significant fixes - did not conform to EN62109-1 much less 
UL1741/1703. Methinks the industry attitude of many southern EU states needs 
some adjustment.

The only thing that OSHA and SCC should fix is the mess that is the (lack of) 
mutual recognition among accredited labs. If one NRTL thinks another NRTL's 
work cannot be accepted, then make a regulatory framework where they are 
required to be doing the same thing or the offending NRTL's VP of engineering 
goes to jail.

Brian


From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Saturday, February 21, 2015 1:46 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone 
terminal equipment?

Good morning (London time!)

W.r.t. the OSHA survey – things have changed a bit in the EU since 2008 – for 
both good and bad! 

I think there is more general awareness of the hazards of electrical and other 
goods – and certainly there are more product recalls than there ever were in 
earlier days, and the supply chain is more aware of its responsibilities to 
ensure that only “safe” items are supplied. You only have to look at the number 
of high-profile product recalls that now routinely occur!

OTOH, the ranges of goods on offer, and the variety of sources from which they 
come, have expanded enormously – and that, unfortunately, has lead to more 
“holes in the systems” for trying to ensure that only “safe” items are put on 
the market.

However, I think that there are several common factors which are tending to 
reinforce the overall trend towards safer products across the World, and thus 
in both N.America and Europe, such as:

1) More and more products are being developed for worldwide, as opposed to 
national, markets, and that means that the designers and manufacturers have to 
take all the market requirements into account – and, with the welcome rise in 
the importance of truly international safety standards, that means that those 
suppliers do more closely try to meet them (or then either fail to get their 
products into the big markets, or else get widely taken to account for 
supplying unsafe products)

The NTRL approach in N. America and the EU CE marking requirements over here 
have both substantially contributed to that  both directly in their own 
marketplaces and more globally as the less economically-developed countries 
(even the big ones like China!) pragmatically adopt the similar standards and 
regulatory controls on the basis that “if it works in the big countries then it 
should work for us as well” (and as well as encouraging and helping their own 
manufacturers to meet those same standards in order to have much wider export 
markets – or at least not to lose them!).

2) Intelligence gathering and dissemination of information

Re: [PSES] Safety standards versus safety engineering

[John Allen]

Brian

I'm not sure I quite understand your post, but I think I agree with you! 

However, my experience indicates that many companies - and even some very
big ones! - DON'T always have adequate control of their sub-contract
suppliers!

Again, I'm not sure, but I think a lot of the issues come down to
inadequacies in:
 
a) How much understanding the sub-contract supplier has of the required
technology, regulatory requirements and design/manufacturing controls for a
particular product;

b) How much understanding the company that lets a contract to that
sub-contract company REALLY has of a) above, and thus what IT itself then
needs to specify, and to do, in order to ensure those requirements can and
are, on an ongoing basis, met;

c) How much time/effort and money is then put in by both sides in adequately
documenting the requirements specifications, and in policing of the
on-going manufacturing and delivery processes, to ensure that what the
design team specified is correct, and is what the customer actually gets!

(and the above is all predicated by the assumption that all the parties are
honest in what they do - which, as we all know, is not always the case :-(
)

Unfortunately, over the years, I have seen many notable examples of how a),
b, and/or c) have not been done correctly, or, in some cases, not at all -
and we all have a pretty good idea of where that sort of thing is likely to
lead!

John Allen
W.London, UK



-Original Message-
From: Brian Ceresney [mailto:bceres...@delta-q.com] 
Sent: 05 March 2015 22:52
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

I tend to disagree. 
For example, for a company who uses contract manufacturing, the Supply,
Quality, and Manufacturing teams have a significant amount of responsibility
for Safety, which can be quite separate from the Design team. 
The management must keep good control over all of the groups involved in the
process, to ensure that safety is built-in to each and every product.
Best Regards,
Brian C.

Brian Ceresney
Regulatory Lead
Delta-Q Technologies Corp.

Phone: +1.604.566.8827
E-mail: bceres...@delta-q.com  

This is my own opinion, and does not reflect that of Delta-Q Technologies. 


Confidentiality Notice: This email message, including any attachments, is
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and privileged information. Any unauthorized review, use, disclosure or
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contact the sender by reply e-mail and destroy all copies of the original
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-Original Message-
From: Richard Nute [mailto:ri...@ieee.org]
Sent: March-05-15 2:37 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

 ... the management of the company has to own the safety of the 
 product. They control the
resources
 needed to ensure that the products are designed,
and
 manufactured to be safe.

Cop-out.

For every product, there is a development team.
The product safety engineer is a member of that team, overtly or not, and
owns the safety of the product.


Best regards,
Rich

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Re: [PSES] Safety standards versus safety engineering

[John Allen]

Charlie

 

That sort of wording is written into most of the existing, and all the NLF
version, of the major Directives. 

 

Unfortunately, many senior people in many companies are concerned only
with the so designed bit in order to get the DoC signed and the product
onto the market, and then choose to ignore the and manufactured bit -
until, maybe, then the company then gets bitten by the repercussions of a
unsafe product being on the market. 

 

However, it is possible that by the time the latter happens, the original
miscreants have moved on or moved out, and can't easily be pinpointed as
major causes of the problems, and new people have moved into the same
positions without understanding what has happened and what they need to do
to fix it, and to stop it happening again - and so the circle of musical
chairs goes on!

 

And, yes, I'm a cynic - but one who has often been tasked/involved with the
clean-up work to try and put things right, and, unfortunately more rarely,
in trying to stop it happening in the first place. L

 

John Allen 

W.London, UK

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 06 March 2015 08:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

 

This is clearly written into the LVD:

 

ANNEX I

Principal Elements of the Safety Objectives for Electrical Equipment
Designed For Use within Certain Voltage Limits

1. General conditions

d) The electrical equipment should be so designed and manufactured as to
ensure that protection against the hazards set out in points 2 and 3 of this
Annex is assured, providing that the equipment is used in applications for
which it was made and is adequately maintained.

 

Designing one item in development and assessing it is somewhat pointless if
you can't make the ones that you actually sell safe.

 

Regards

Charlie

 

-Original Message-
From: Brian Ceresney [mailto:bceres...@delta-q.com] 
Sent: 05 March 2015 22:52
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

 

I tend to disagree. 

For example, for a company who uses contract manufacturing, the Supply,
Quality, and Manufacturing teams have a significant amount of responsibility
for Safety, which can be quite separate from the Design team. 

The management must keep good control over all of the groups involved in the
process, to ensure that safety is built-in to each and every product.

Best Regards,

Brian C.

 

Brian Ceresney

Regulatory Lead

Delta-Q Technologies Corp.

 

Phone: +1.604.566.8827

E-mail:  mailto:bceres...@delta-q.com bceres...@delta-q.com  

 

This is my own opinion, and does not reflect that of Delta-Q Technologies. 



 

Confidentiality Notice: This email message, including any attachments, is
for the sole use of the intended recipient(s) and may contain confidential
and privileged information. Any unauthorized review, use, disclosure or
distribution is prohibited. If you are not the intended recipient, please
contact the sender by reply e-mail and destroy all copies of the original
message.

 

 

 

 

-Original Message-

From: Richard Nute [ mailto:ri...@ieee.org mailto:ri...@ieee.org]

Sent: March-05-15 2:37 PM

To:  mailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] Safety standards versus safety engineering

 

 ... the management of the company has to own the safety of the 

 product. They control the

resources

 needed to ensure that the products are designed,

and

 manufactured to be safe.

 

Cop-out.

 

For every product, there is a development team.

The product safety engineer is a member of that team, overtly or not, and
owns the safety of the product.

 

 

Best regards,

Rich

 

-



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Re: [PSES] SV: [PSES] Germanwings crash

[John Allen]

Are we not in danger of losing the plot here?

 

All the solutions posed here (including some of mine) are becoming more
and more complex, and difficult to introduce right across the World in under
a few years (and VERY expensive) - and far more so than the basic solution
required in the US and elsewhere, i.e. that two people must be in the
cockpit and all times, and thus when one leaves then another one must enter.

 

Essentially, this is the low cost and simple KISS solution which can be
implemented immediately and without the need for technological changes in
either the aircraft or the world communications systems. The only area where
it would not work would be in small, single crew (i.e. just the pilot!)
aircraft used for feeder services, etc., - but, in those, the risk has
always been there that a rogue pilot could crash his plane deliberately,
and there always will be until all flights are totally remotely controlled
and automated (but then remember the Terminator!)

 

Also, remember that the more complex a system is then the more likely it is
to have hidden fault conditions which are not identified for some time, and
which could then be exploited as backdoors to the system by the wrong
people if they find out before the airlines (etc.) do - just like the s/w
on your PC can be, which is why you hope you're A/V s/w and firewall do what
they claim to be able to do.

 

From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: 02 April 2015 05:24
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] SV: [PSES] Germanwings crash

 

Since its not difficult to map all the world on a single USB card (including
height information)

the plane itself  might have enough information to simply refuse to be led
to ground under uncontrolled

circumstances.

Drones (even below 1000 USD) do autonomously return to their point of
departure if control is lost.

If Google can operate a car from NY to LA without a driver,  it cannot be a
huge challenge

to methodically prevent a plane from diving at full speed below 3000 feet,
or even hurt a sky scraper

or fly over certain zones (Ukraine ?).

Soon pilots will be not needed anymore, but for waving to the ground crew.

 

Gert

 

 

 

Van: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Verzonden: woensdag 1 april 2015 23:02
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] SV: [PSES] Germanwings crash

 

John

 

Military drones analogy? - I don't think so!

 

In those cases you have dedicated (at least) two-man teams flying 1 drone
each on a specific operation.

 

In the real-life civil aviation industry, you have thousands of simultaneous
flights from here to there  controlled by hundreds of ground controllers
in different countries /time zones /cultures /languages, where no single
third-party team is in constant communication with any single aircraft for
the whole of its flight (handovers, sometimes many times, happen on any
flight) - and you think they could conceivably operate consistent and
reliable  systems whereby a pilot says I need a cr*p, please open the
cockpit door in 30s, and someone, somewhere, has to say  OK, and do
that?

 

And then do it again when the pilot, who is NOT now in the cockpit wants to
get back into the cockpit? 

 

Works no better than the system on the Germanwings flight because the
co-pilot (in that case) is the one who IS in communication with the
someone, somewhere, and he/she is the weak link in your argument
because he simply needs not to pass on the pilot's request!

 

Maybe it would be possible in a few years' time when all aircraft are flown
remotely, but then there will be no need for aircrew flying the planes
anyway - and then the emphasis will be on the ground controllers AND their
computer systems. Terminator, Judgement Day here we come! L

 

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 01 April 2015 21:30
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Germanwings crash

 

In message

!!AAAYAEGjmYsMtGZAuvo7rFLQ++figAAAEFC36QsFDqtAlNsc1

 mailto:kQ8nscBAA==@blueyonder.co.uk
kQ8nscBAA==@blueyonder.co.uk, dated Wed, 1 Apr 2015, John Allen 
mailto:john_e_al...@blueyonder.co.uk john_e_al...@blueyonder.co.uk
writes:

 

Not realistic for a huge raft of reasons: air-to-ground-to-air 

time-delays, comms issues, EMI issues, language issues, situational 

awareness issues - need I go on? !! L

 

Those factors may be taken into account. Since is possible to fly and
control military drones in complex manoeuvres in combat conditions, it seems
that reliably opening a door by remote control might not be quite
impossible.

--

OOO - Own Opinions Only. With best wishes. See
http://www.jmwa.demon.co.uk www.jmwa.demon.co.uk When I turn my back on
the sun, it's to look for a rainbow John Woodgate, J M Woodgate and
Associates, Rayleigh, Essex UK

Re: [PSES] SV: [PSES] Germanwings crash

[John Allen]

Gert

That's fine when there are two people in the cockpit - but what happens when
one has left to answer the call of nature?

Presumably the door cannot then be closed or opened - so it has to stay
open, which breaks the major post 9/11 rule that the door has to be kept
closed and locked at all times except when a crew person is legitimately
leaving / entering.



-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: 02 April 2015 05:15
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Germanwings crash

Or lockout should be impossible unless there are two officers on the
flight deck (two security codes needed, not a toggle switch!).

That would be simple: to momentary switches to be actuated at the same time
with enough physical distance between them

Gert Gremmen


-Oorspronkelijk bericht-
Van: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Verzonden: woensdag 1 april 2015 21:34
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] SV: [PSES] Germanwings crash

In message 01d06ca9$c89b05e0$59d111a0$@westin-emission.no, dated Wed,
1 Apr 2015, Amund Westin am...@westin-emission.no writes:

Doors should be opened by ground control officers via radio.

Or lockout should be impossible unless there are two officers on the flight
deck (two security codes needed, not a toggle switch!).
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I
turn my back on the sun, it's to look for a rainbow John Woodgate, J M
Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] SV: [PSES] Germanwings crash

[John Allen]

OK, and so another member of the crew has the code. 

This rapidly becomes common knowledge amongst the bad guys, and one of
them manages to get on the plane and grabs a member of the cabin crew and
threatens them - he won't even need a knife if he is strong and the cabin
crew member is not, and so could threaten to strangle that person (or a
passenger) - and forces the code to be revealed = the door is opened, and we
are back to square 1!

I don't there is any definitive solution to the problem (except that no
aircraft ever fly), and so there will always be risks of aircraft being
crashed deliberately.

All the ideas have their merits and demerits, and so it's a matter of
balancing the risks against the complexity, costs and fallibilities of the
possible solutions - I think we will have to wait and see just what develops
over time, when, maybe, the powers that be decide which, if any, of these
(or other) solutions are adopted, but be vigilant in the meantime. Sh*t
happens and it always will.

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 02 April 2015 08:45
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Germanwings crash

In message
!!AAAYAEGjmYsMtGZAuvo7rFLQ++figAAAEH78Bib0uHFGn7Ud/
R43nIoBAA==@blueyonder.co.uk, dated Thu, 2 Apr 2015, John Allen
john_e_al...@blueyonder.co.uk writes:

That's fine when there are two people in the cockpit - but what happens 
when one has left to answer the call of nature?

Presumably the door cannot then be closed or opened - so it has to stay 
open, which breaks the major post 9/11 rule that the door has to be 
kept closed and locked at all times except when a crew person is 
legitimately leaving / entering.

No: the door would be closed and in 'normal' mode, so it can be opened by an
officer from outside by entering a security code, as at present. 
The point is that the officer inside can't unilaterally set 'lockout' 
mode.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I
turn my back on the sun, it's to look for a rainbow John Woodgate, J M
Woodgate and Associates, Rayleigh, Essex UK

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[PSES] Consultant for UL498 and UL67

[John Allen]

Hi,


We're in need of a consultant with experience in UL489 and UL67.  A client has 
new IP that the NRTL's haven't seen yet.


Please respond to me directly.


John

jral...@productsafetyinc.com

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Re: [PSES] Wire Questions

[John Allen]

Brian 

 

Can’t respond w.r.t. you para 1 question, but w.r.t. para 2:

-   IEC/EN 60799:1998  “Electrical accessories — Cord sets and
interconnection cord sets” (1998 edition is still valid AFAIK) is a good
guide to cordset ratings, and Table 1 allows ratings under 1 sq mm
(generally 0.75 sq mm) for cordsets rated up to 10A provided the length does
not exceed 2m, and 1 sq mm for cordsets rated at 16A (but 1.5 sq mm for
cordsets longer than 2m).

(must admit that I thought for a long time that 16A-rated cordsets needed to
be 1.5 sq mm regardless of length, but “found out” in a rather embarrassing
way that they do not!)

 

Regards

 

John Allen

W.London, UK

 

 

From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: 06 May 2015 17:09
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Wire Questions

 

Didn’t I hear there was some kind of agreement where UL/CSA approved power
cordage was allowed to be used in Europe as long as the conductor size met
requirements?  If so, what is the official document which describes this
agreement?  

 

Doesn’t Europe have a minimum conductor size for detachable power cords of
1mm²?  I believe the IEC 60320 allows conductor size of 0.75mm² if the
overall cord length is less than 2 meter (or at least is was years ago).   

 

18AWG conductors on UL/CSA power cords for North America does not meet the
1mm² requirement so that is why we try to use 16AWG or 14AWG cord sets even
if they cannot be used outside of North America. 

 

In the real world, it is common for the plug to be cut off the power cord
and replaced with something local. In those cases, we want to be sure the
cordage is large enough to meet any local electrical codes. 

 

The Other Brian

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Tuesday, May 05, 2015 2:09 PM
To: Kunde, Brian
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Wire Questions

 

Brian

 

Grounding Conductor size

 

An interesting question with respect to internal grounding conductors, and
one which made me refer to a very old copy of CSA Technical Note TN-017
“Bonding and Grounding of Electrical Equipment (Protective Grounding)”,
dated January 13, 1993, which I have – don’t know if there is a newer
version, but I suspect there is (if so, does anyone have a copy of this or
of whatever has replaced it?) so the following comments may well be
out-of-date!

 

TN-017 refers to CSA C22.0.4, which I don’t think I have, as the basic
requirements for grounding of equipment, so obviously not sure what that
currently states.

 

However: 

 

Page 2 of TN-017, under “Grounded (Class I) Equipment” states that 

“IEC standards require the ground path impedance to be less than or equal to
0.1 ohm. Although it is a satisfactory criteria for evaluating a path to
ground where overcurrent protection is rated or set at 15A and 20A, this
approach fails to provide proper protection when overcurrent devices are
rated or set at 30A or higher”

 

Page 6, Under “National Electric Code (NEC)” states:

“Article 250 of NEC defines grounding and bonding requirements for
installations of electrical equipment in the United States. Articles250-60,
250-95 and 250-155 also define min size of ground conductor required. Also
see Articles 250-42, 250-45, 250-59, 250-113 and 250-114.

 

NEC requires the following in particular.

 

(a)   Ground conductor must not be smaller than specified in Table 250-95
with the exceptions that the ground conductor:

i.  Must not be smaller than 18A AWG copper and not smaller than
circuit conductors.

ii. Need not be larger than the AC circuit conductors.

 

This means that the min cord size permitted is No 18 AWG, and min size of
ground conductor shall be No 18 AWG.

 

(b)   Ground conductor may be without insulation but if insulation is
provided, it shall be coloured green or green with one or more yellow
stripes.

(c)All non-current carrying metal parts of fixed, portable and mobile
equipment shall be grounded. Grounding conductors not part of cable assembly
must not be smaller that No 6 AWG.”

 

NB: w.r.t. (c) above, there are exceptions elsewhere for double-insulated
(etc.) equipment!

 

Can’t find any definitive statement in TN-017 as to the required internal
grounding conductor sizes, but, from the above, it seems to me that the
issue you mention relates to a combination of the following:

-   The IEC continuity test at 25A is only adequate at supply currents
which would be protected by a 15A/20A external breaker, which is probably
why 61010-1 states different – see below;

-   the potential AWG size of the external supply cord – and that the
grounding conductor needs to be  the size of the current-carrying
conductors; 

-   the current rating of the protection in the installation – and if
the latter is 15A/20A, then the internal conductor would have to be larger
than 18AWG.

 

Since you were using a 16AWG power cord in some cases, then that would mean

Re: [PSES] Trade Description Act 1968 Consumer Protection Act 1987

[John Allen]

Scott

You can search for any UK legislation on this site:

http://www.legislation.gov.uk/search

As far as I can see from a quick look, the Trades Descriptions Act has not
undergone much change but the Consumer Protection Act has undergone
considerable updating.

Please understand most UK ACTS are often then modified and enhanced by
subsidiary REGULATIONS published later - and that has certainly happened to
a great extent w.r.t. the CPA in order to improve consumer protection !

Regards

John Allen
W.London, UK

-Original Message-
From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 08 May 2015 18:03
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Trade Description Act 1968  Consumer Protection Act 1987

Hello All,

Are these two Acts still valid or have been replaced by others after EU was
established?

Thanks and regards,

Scott

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Re: [PSES] Trade Description Act 1968 Consumer Protection Act 1987

[John Allen]

Scott

If you check the Explanatory Note that you will find at the back of each
Regulation, you will generally be able to see any references to relevant EU
legislation.

John Allen
W.London, UK

-Original Message-
From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 11 May 2015 00:07
To: John Allen
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Trade Description Act 1968  Consumer Protection Act
1987

John,

Yes, those should not be UK only and for all consumers in EU.  Hope to find
out the corresponding EU directives/regulations.  Thanks for your guidance.

Scott


 On 10 May, 2015, at 2:48 pm, John Allen john_e_al...@blueyonder.co.uk
wrote:
 
 Scott
 
 The TDA is mainly UK, but I expect most of the other EU countries to 
 have parallel requirements.
 
 However, whilst the CPA is basically UK-specific, it now incorporates 
 a lot of EU-based requirements, especially w.r.t. distance selling 
 and warrantee-type requirements because of cross-border internet sales 
 and so on, as well as those related to generally beefing up consumer
protection.
 
 John Allen
 W.London, UK
 
 -Original Message-
 From: Scott Xe [mailto:scott...@gmail.com]
 Sent: 10 May 2015 06:41
 To: John Allen
 Cc: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] Trade Description Act 1968  Consumer Protection 
 Act
 1987
 
 Hi John,
 
 Thanks for your direction.  I found what you described.  Thanks!
 
 Are they national requirements only not EU requirements?  Is there any 
 place we can verify?
 
 Regards,
 
 Scott
 
 
 On 9 May, 2015, at 1:21 am, John Allen 
 john_e_al...@blueyonder.co.uk
 wrote:
 
 Scott
 
 You can search for any UK legislation on this site:
 
 http://www.legislation.gov.uk/search
 
 As far as I can see from a quick look, the Trades Descriptions Act 
 has not undergone much change but the Consumer Protection Act has 
 undergone considerable updating.
 
 Please understand most UK ACTS are often then modified and enhanced 
 by subsidiary REGULATIONS published later - and that has certainly 
 happened to a great extent w.r.t. the CPA in order to improve 
 consumer
 protection !
 
 Regards
 
 John Allen
 W.London, UK
 
 -Original Message-
 From: Scott Xe [mailto:scott...@gmail.com]
 Sent: 08 May 2015 18:03
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: [PSES] Trade Description Act 1968  Consumer Protection Act
 1987
 
 Hello All,
 
 Are these two Acts still valid or have been replaced by others after 
 EU was established?
 
 Thanks and regards,
 
 Scott
 
 -
 
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 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.
 
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 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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 David Heald: dhe...@gmail.com
 
 
 

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Re: [PSES] Wire Questions

[John Allen]

 company to incorporate in their own
equipment), then it's probably doubtful if the use of US/CSA-certified mains
supply cords would be picked up by most of the end-user community. As long
as the plug was the correct one, and the conductor insulation colours were
also correct if an unterminated power cord was supplied, for those countries
then most of those people would probably not look much further! Not to say
that this is right/ legal, but taking a pragmatic view of the actual
situation in most countries. J

 

Therefore, in the circumstances, it may well be better (as you appear to do)
to leave the supply of appropriate power cords to the European installers!

 

John Allen

W.London, UK

 

From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: 05 May 2015 16:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Wire Questions

 

Rick,

 

Are you talking strictly about power cordage or internal hookup wire? 

 

We had a CSA inspector reject one of our products because the internal PE
Conductor (hookup wire) was a smaller gauge (18awg) than what was on the
power cord (16awg). He said in Canada, the PE Conductor inside our product
had to be the same gauge or larger than the PE conductor in the power cord
regardless of the protection device or the current rating of the wire. In
our case, we were using a 16 awg detachable power cord with an IEC 60320
connector. Inside our instrument, from the IEC connector to our chassis
ground we used an 18 awg green/yellow hookup wire which can handle way more
fault current than the 16 awg power cord. So as a general rule, we always
use 14 awg hookup wire on IEC connectors just to be on the safe size; As
such power cords can come in 18, 16, and 14 awg sizes.

 

Our power cords for North America always have UL and CSA, but no CE or
harmonized (at least it is not required to have this). When products are
shipped to Europe I understood that UL/CSA cordage was acceptable (you still
have to change the plug) as long as the conductor size met the requirements.
That is why we don't use 18 awg power cords anymore.  I really don't know
the details because this is handled by our installers during the customer
installation.

 

Hope this was helpful.

The Other Brian

 

From: Rick Busche [mailto:rick.bus...@qnergy.com] 
Sent: Tuesday, May 05, 2015 10:08 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Wire Questions

 

We manufacture a product that is intended for both the US and Canadian
markets in addition to the European community. Our wiring is currently
UL/CSA and harmonized.  Looking at the various wire vendors there are
UL/CSA  CE certifications and certifications  that are UL/CSA, CE and
Harmonized. Is it acceptable to have  wiring with just UL/CSA and CE? 

 

Also, I remember years ago a document or standard that stated that a
grounding wire could be smaller than the load wires. The argument was that
it doesn't have to support the load but just fault  the input current.  Does
this sound familiar to anyone?

 

Thanks

 

Rick

 

 

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Re: [PSES] CSA/cUL Certification

[John Allen]

It will be important to check the extent to which you have, or have not,
incorporated all the components and materials which are normally required to
be CSA Accepted/UL Recognized because, if you have not, then you could face
very high initial component approval, and then on-going follow-up services,
costs - for example: using plastic materials (e.g. the case  the PWBs)
that meet the Flammability requirements of 62368-1/60065 but which are not
UL/CSA is going to cost you a lot in both the short and the long terms,
as well as potentially delaying your CSAus/cUL Listing!

 

This sort of problem has been the undoing of many attempts to get products
into N.America over the years!

 

John Allen

W.London, UK

 

 

 

From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 05 May 2015 08:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] CSA/cUL Certification

 

Product: Multimedia (audio/video) powered by 12V battery or AC/DC adapter.

 

Before even start making an approach towards CSA and UL, are there any
important technical issues that should be addressed before getting on?

I mean, the product is finished developed (for Europe market) and maybe a
kind of quick check will point out if CSA/cUL Certification is possible at
all .

 

Thanks.

 

Best regards

Amund

 

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Re: [PSES] Wire Questions

[John Allen]

Brian


Thanks 

Grounding Conductors - what you have identified in C22.2 No 0.4 seems to 
largely confirm and expand on what I surmised from TN-017 and the related 
references.

Regards

John Allen
W.London, UK

-Original Message-
From: Brian Oconnell [mailto:oconne...@tamuracorp.com] 
Sent: 05 May 2015 19:40
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Wire Questions

CSA-C22.2 No 0.4 (Bonding of Electrical Equipment) has this

3.4.3.2
The fault capacity of a bond shall be adequate if the bond complies with one of 
the following
requirements:
(a) the bond is made from a suitably terminated conductor not smaller than the 
specified minimum size of bonding conductors in Table 16 of Part I of the CEC;
Note: When equipment contains two or more motors connected to a circuit in the 
equipment that does not have overcurrent protection, the bonding conductor size 
is selected by assuming that the branch circuit protection is equal to three 
times the full load current of the largest motor plus the current required by 
the other loads.
(b) in cord-connected equipment, the bond is made from a suitably terminated 
conductor not smaller than the bonding conductor in the supply cord;
(c) the bond is made from a copper conductor not smaller than the applicable 
minimum size specified in Table 1 and meets the test requirements specified in 
Clause 4.1;
(d) the bond is made from a conductor smaller than that required in Item (b) or 
(c), or smaller than required in Item (a) for overcurrent protection rated 40 A 
or more, and meets the test requirements specified in Clauses 4.1 and 4.3; or
(e) the bond is made from a conductive element, other than a conductive element 
specified in Items (a) to (d), that meets the test requirements specified in 
Clauses 4.1 and 4.3

And table 1 indicates:

Rating of branch circuitMinimum bonding 
conductor size, AWG
required for equipment, A
15  20
20  18
30  14

Note that the 20gauge wire contradicts some stuff in NEC article 250(NFPA70), 
and CEC Part II (CSA C22.2 No 0-M9).

Brian

From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Tuesday, May 05, 2015 11:09 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Wire Questions

Brian

Grounding Conductor size

An interesting question with respect to internal grounding conductors, and one 
which made me refer to a very old copy of CSA Technical Note TN-017 “Bonding 
and Grounding of Electrical Equipment (Protective Grounding)”, dated January 
13, 1993, which I have – don’t know if there is a newer version, but I suspect 
there is (if so, does anyone have a copy of this or of whatever has replaced 
it?) so the following comments may well be out-of-date!

TN-017 refers to CSA C22.0.4, which I don’t think I have, as the basic 
requirements for grounding of equipment, so obviously not sure what that 
currently states.

However: 

Page 2 of TN-017, under “Grounded (Class I) Equipment” states that “IEC 
standards require the ground path impedance to be less than or equal to 0.1 
ohm. Although it is a satisfactory criteria for evaluating a path to ground 
where overcurrent protection is rated or set at 15A and 20A, this approach 
fails to provide proper protection when overcurrent devices are rated or set at 
30A or higher”

Page 6, Under “National Electric Code (NEC)” states:
“Article 250 of NEC defines grounding and bonding requirements for 
installations of electrical equipment in the United States. Articles250-60, 
250-95 and 250-155 also define min size of ground conductor required. Also see 
Articles 250-42, 250-45, 250-59, 250-113 and 250-114.

NEC requires the following in particular.

(a) Ground conductor must not be smaller than specified in Table 250-95 with 
the exceptions that the ground conductor:
i. Must not be smaller than 18A AWG copper and not smaller than circuit 
conductors.
ii. Need not be larger than the AC circuit conductors.

This means that the min cord size permitted is No 18 AWG, and min size of 
ground conductor shall be No 18 AWG.

(b) Ground conductor may be without insulation but if insulation is provided, 
it shall be coloured green or green with one or more yellow stripes.
(c) All non-current carrying metal parts of fixed, portable and mobile 
equipment shall be grounded. Grounding conductors not part of cable assembly 
must not be smaller that No 6 AWG.”

NB: w.r.t. (c) above, there are exceptions elsewhere for double-insulated 
(etc.) equipment!

Can’t find any definitive statement in TN-017 as to the required internal 
grounding conductor sizes, but, from the above, it seems to me that the issue 
you mention relates to a combination of the following:
- The IEC continuity test at 25A is only adequate at supply currents which 
would be protected by a 15A/20A external breaker, which is probably

Re: [PSES] Trade Description Act 1968 Consumer Protection Act 1987

[John Allen]

Scott

The TDA is mainly UK, but I expect most of the other EU countries to have
parallel requirements.

However, whilst the CPA is basically UK-specific, it now incorporates a lot
of EU-based requirements, especially w.r.t. distance selling and
warrantee-type requirements because of cross-border internet sales and so
on, as well as those related to generally beefing up consumer protection.

John Allen
W.London, UK

-Original Message-
From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 10 May 2015 06:41
To: John Allen
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Trade Description Act 1968  Consumer Protection Act
1987

Hi John,

Thanks for your direction.  I found what you described.  Thanks!

Are they national requirements only not EU requirements?  Is there any place
we can verify?

Regards,

Scott


 On 9 May, 2015, at 1:21 am, John Allen john_e_al...@blueyonder.co.uk
wrote:
 
 Scott
 
 You can search for any UK legislation on this site:
 
 http://www.legislation.gov.uk/search
 
 As far as I can see from a quick look, the Trades Descriptions Act has 
 not undergone much change but the Consumer Protection Act has 
 undergone considerable updating.
 
 Please understand most UK ACTS are often then modified and enhanced by 
 subsidiary REGULATIONS published later - and that has certainly 
 happened to a great extent w.r.t. the CPA in order to improve consumer
protection !
 
 Regards
 
 John Allen
 W.London, UK
 
 -Original Message-
 From: Scott Xe [mailto:scott...@gmail.com]
 Sent: 08 May 2015 18:03
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: [PSES] Trade Description Act 1968  Consumer Protection Act 
 1987
 
 Hello All,
 
 Are these two Acts still valid or have been replaced by others after 
 EU was established?
 
 Thanks and regards,
 
 Scott
 
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Re: [PSES] SV: [PSES] Germanwings crash

[John Allen]

Mixed-sex flightcrew? :D
Sent from my Fonepad
Gary Tornquist <gary...@microsoft.com> wrote:>Chamber pots!  
>
>One has to wait years to legitimately reference chamber pots in conversation :)
>
>Cheers,
>Gary Tornquist
>
>-Original Message-
>From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
>Sent: Thursday, April 2, 2015 12:12 AM
>To: EMC-PSTC@LISTSERV.IEEE.ORG
>Subject: Re: [PSES] SV: [PSES] Germanwings crash
>
>Gert
>
>That's fine when there are two people in the cockpit - but what happens when one has left to answer the call of nature?
>
>Presumably the door cannot then be closed or opened - so it has to stay open, which breaks the major post 9/11 rule that the door has to be kept closed and locked at all times except when a crew person is legitimately leaving / entering.
>
>
>
>-Original Message-
>From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl]
>Sent: 02 April 2015 05:15
>To: EMC-PSTC@LISTSERV.IEEE.ORG
>Subject: Re: [PSES] SV: [PSES] Germanwings crash
>
>>Or lockout should be impossible unless there are two officers on the
>flight deck (two security codes needed, not a toggle switch!).
>
>That would be simple: to momentary switches to be actuated at the same time with enough physical distance between them
>
>Gert Gremmen
>
>
>-Oorspronkelijk bericht-
>Van: John Woodgate [mailto:j...@jmwa.demon.co.uk]
>Verzonden: woensdag 1 april 2015 21:34
>Aan: EMC-PSTC@LISTSERV.IEEE.ORG
>Onderwerp: Re: [PSES] SV: [PSES] Germanwings crash
>
>In message <01d06ca9$c89b05e0$59d111a0$@westin-emission.no>, dated Wed,
>1 Apr 2015, Amund Westin <am...@westin-emission.no> writes:
>
>>Doors should be opened by ground control officers via radio.
>
>Or lockout should be impossible unless there are two officers on the flight deck (two security codes needed, not a toggle switch!).
>--
>OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
>
>-
>
>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:
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>-
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Re: [PSES] SV: [PSES] Germanwings crash

[John Allen]

John

You do have a point - but, actually, there is  a much wider one that IACO
could consider: that is, in such cases, could those in the cabin area be
provided with a system whereby, in cases where the cockpit gets taken
over, it could allow them to communicate with the someone somewhere to
alert them of the problems - but it would still not prevent the person still
remaining in the locked cockpit to do whatever they want, unless a remote
unlocking facility is incorporated. Again, maybe in the future, and then
again subject to all the communications-related issues mentioned in my first
post on this subject.

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 01 April 2015 22:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Germanwings crash

In message
!!AAAYAEGjmYsMtGZAuvo7rFLQ++figAAAEIikrBPlu6RNlut8A
ucpoOcBAA==@blueyonder.co.uk, dated Wed, 1 Apr 2015, John Allen
john_e_al...@blueyonder.co.uk writes:

you think they could conceivably operate consistent and reliable 
systems whereby a pilot says I need a cr*p, please open the cockpit 
door in 30s, and someone, somewhere, has to say  OK, and do that?

I'm sure that isn't what was meant. The ground control would operate only in
exactly the Germanwings emergency case - lockout of an officer due to the
other officer being mentally disturbed or having, for example, fainted and
fallen on the switch.

It does require the locked-out officer to be able to send a suitable Mayday,
but that's not so difficult.

Even so, I think my proposal for lockout being invoked only by both officers
is simpler and possibly more reliable.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I
turn my back on the sun, it's to look for a rainbow John Woodgate, J M
Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] SV: [PSES] Germanwings crash

[John Allen]

John

 

Military drones analogy? - I don't think so!

 

In those cases you have dedicated (at least) two-man teams flying 1 drone
each on a specific operation.

 

In the real-life civil aviation industry, you have thousands of simultaneous
flights from here to there  controlled by hundreds of ground controllers
in different countries /time zones /cultures /languages, where no single
third-party team is in constant communication with any single aircraft for
the whole of its flight (handovers, sometimes many times, happen on any
flight) - and you think they could conceivably operate consistent and
reliable  systems whereby a pilot says I need a cr*p, please open the
cockpit door in 30s, and someone, somewhere, has to say  OK, and do
that?

 

And then do it again when the pilot, who is NOT now in the cockpit wants to
get back into the cockpit? 

 

Works no better than the system on the Germanwings flight because the
co-pilot (in that case) is the one who IS in communication with the
someone, somewhere, and he/she is the weak link in your argument
because he simply needs not to pass on the pilot's request!

 

Maybe it would be possible in a few years' time when all aircraft are flown
remotely, but then there will be no need for aircrew flying the planes
anyway - and then the emphasis will be on the ground controllers AND their
computer systems. Terminator, Judgement Day here we come! L

 

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 01 April 2015 21:30
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Germanwings crash

 

In message

!!AAAYAEGjmYsMtGZAuvo7rFLQ++figAAAEFC36QsFDqtAlNsc1

 mailto:kQ8nscBAA==@blueyonder.co.uk
kQ8nscBAA==@blueyonder.co.uk, dated Wed, 1 Apr 2015, John Allen 
mailto:john_e_al...@blueyonder.co.uk john_e_al...@blueyonder.co.uk
writes:

 

Not realistic for a huge raft of reasons: air-to-ground-to-air 

time-delays, comms issues, EMI issues, language issues, situational 

awareness issues - need I go on? !! L

 

Those factors may be taken into account. Since is possible to fly and
control military drones in complex manoeuvres in combat conditions, it seems
that reliably opening a door by remote control might not be quite
impossible.

--

OOO - Own Opinions Only. With best wishes. See
http://www.jmwa.demon.co.uk www.jmwa.demon.co.uk When I turn my back on
the sun, it's to look for a rainbow John Woodgate, J M Woodgate and
Associates, Rayleigh, Essex UK

 

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Re: [PSES] SV: [PSES] Germanwings crash

[John Allen]

Not realistic for a huge raft of reasons: air-to-ground-to-air time-delays,
comms issues, EMI issues, language issues, situational awareness issues -
need I go on? !! L

 

-Original Message-
From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 01 April 2015 19:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] SV: [PSES] Germanwings crash

 

Doors should be opened by ground control officers via radio.

 

 

 

-Opprinnelig melding-

Fra: Ken Javor [ mailto:ken.ja...@emccompliance.com
mailto:ken.ja...@emccompliance.com]

Sendt: 1. april 2015 18:38

Til:  mailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG

Emne: Re: [PSES] Germanwings crash

 

These type doors became mandatory after 9/11. Boeing was sued after 9/11
because these type doors had not been installed.

 

What is the manufacturer to do?

 

Ken Javor

Phone: (256) 650-5261

 

 

 From: John Woodgate  mailto:j...@jmwa.demon.co.uk j...@jmwa.demon.co.uk

 Reply-To: John Woodgate  mailto:j...@jmwa.demon.co.uk
j...@jmwa.demon.co.uk

 Date: Wed, 1 Apr 2015 17:08:07 +0100

 To:  mailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG

 Subject: [PSES] Germanwings crash

 

 There is a general safety lesson to be learned, which needs to be 

 applied to every risk analysis. An irrecoverable situation (flight 

 deck door locked from inside and opening denied) cannot be accepted 

 even if the probability of a bad result appears vanishingly small.

 

 This post is not meant to start an argument, which would be 

 inappropriate in the context of a tragedy.

 --

 OOO - Own Opinions Only. With best wishes. See
http://www.jmwa.demon.co.uk www.jmwa.demon.co.uk 

 When I turn my back on the sun, it's to look for a rainbow John 

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

 

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[PSES] Production Line testing for UL60950

[John Allen]

Can someone point me in the right direction (i.e.; what clause number can I 
find it??) regarding production line testing in UL60950-1.


Thanks,


John

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[PSES] Compliance Engineer needed

[John Allen]

Hi,


We're looking to hire an experienced compliance engineer.  Contact me at 
jral...@productsafetyinc.com if you're interested or know of anyone.


Best Regards,


John


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Re: [PSES] Production Line testing for UL60950

[John Allen]

Hi Rich,


I did not see it in UL60950 2nd or 3rd edition either.  If I remember correctly 
it was in UL478 and still is required in many other Standards.  Any thoughts on 
why it was not carried into the new Standards and/or why ground continuity 
wouldn't be required as a routine test??


I would love to see 108-570, thank you!


Best Regards,


John

jral...@productsafetyinc.com



From: Richard Nute ri...@ieee.org
Sent: Tuesday, June 23, 2015 6:34 PM
To: John Allen
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Production Line testing for UL60950






Hi John:





Yes, UL 60950-1 does not have a routine ground continuity test.  In fact, see 
1.4.2:



Type tests

Except where otherwise stated, the tests specified in this standard are type 
tests.



In IEC product safety standards, tests can only be type tests.  But, this 
principle is not universally followed.  (UL 60950-1 was based on IEC 60950-1, 
but not identical.)



Not only that, TC108 is publishing a routine test standard, IEC 62911 (aka 
108-570).  It is likely that UL will pick up on this and publish a routine 
test standard that can apply to a number of their standards.





Best regards,

Rich





(I can send you a copy of 108-570 if you would like.)





From: John Allen [mailto:jral...@productsafetyinc.com]
Sent: Tuesday, June 23, 2015 3:21 PM
To: ri...@ieee.org
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Production Line testing for UL60950



Thank you everyone!!  Forgot about, but found routine tests.  What's odd to 
me is it doesn't seem ground continuity is required as a routine test.

Best Regards,



John



John Allen

Product Safety Consulting, Inc

www.productsafetyinc.comhttp://www.productsafetyinc.com



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Re: [PSES] Production Line testing for UL60950

[John Allen]

Thank you everyone!!  Forgot about, but found routine tests.  What's odd to 
me is it doesn't seem ground continuity is required as a routine test.

Best Regards,

John

John Allen
Product Safety Consulting, Inc
www.productsafetyinc.comhttp://www.productsafetyinc.com

On Jun 23, 2015, at 5:18 PM, Richard Nute 
ri...@ieee.orgmailto:ri...@ieee.org wrote:



Hi John:


In UL 60950-1, the term routine tests is used for production-line testing.  
See:

1.2.13.3
Table 2K
Table 2M
2.10.5.4
2.10.5.11
2.10.5.13
2.10.6.2
Table 2R
5.2.2
Table G.2
Table R.1
Table R.2
U.3.1

See also the index under routine.

ROUTINE TEST  1.2.13.3*
coated printed board
2.10.6.2, 2.10.6.4 (Table 2R), R.1 (Table R.1)
electric strength test voltage and duration
5.2.2
reduced CLEARANCE requiring ROUTINE TESTS
2.10.3.3 (Table 2K), 2.10.3.4, (Table 2M),
2.10.7, G.6 (Table G.2), R.2 (Table R.2)
semiconductor devices 2.10.5.4
solvent-based enamel  2.10.5.13
winding wireU.3.1
wound component   2.10.5.11

These references may be incorrect as I am using a Word version of Ed. 2.


Best regards,
Rich



From: John Allen [mailto:jral...@productsafetyinc.com]
Sent: Tuesday, June 23, 2015 2:37 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Production Line testing for UL60950


Can someone point me in the right direction (i.e.; what clause number can I 
find it??) regarding production line testing in UL60950-1.



Thanks,



John

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[PSES] HazLoc Consultant

[John Allen]

Hi,


I'm looking for an experienced HazLoc consultant.  Please respond separately to 
my email - jral...@productsafetyinc.com.


Best Regards,


John

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Re: [PSES] EU Customs and EMC test report

[John Allen]

Dave,

 

Whilst not an EU countries issue, some non-EU countries which require CE
marking (notably Turkey!) may require the Technical Files (which would
probably include the lab reports) to be presented to the Customs or other
regulatory body at the time of product entry if there is any doubt as to the
accuracy of the DoC.

 

John Allen

W.London, UK

 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: 15 June 2015 20:19
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU Customs and EMC test report

 

Chuck,

 

I would expect only to see the applicable standards listed in the lab test
report that they tested to.  I don't see directives listed in my lab test
reports.  The DoC should identify the applicable directives and the
standards used to support compliance with the directives. An EU Customs
official wouldn't normally be looking at your test reports unless there is a
formal request for the technical file.   The lab test reports shouldn't
accompany the product shipment/paper work.

 

-Dave

 

From: Chuck McDowell [mailto:chu...@meyersound.com] 
Sent: Monday, June 15, 2015 3:03 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU Customs and EMC test report

 

Dear Compliance Professionals,

 

Does a EMC test report issued by a accredited testing laboratory need to
also reference the current EMC Directive 2004/108/EC?

 

My belief is that the EMC Directive needs to noted on the product
Declaration of Conformity, and not in the EMC test report. Is this correct?

A EU Customs official stop a shipment because the EMC Directive noted in the
EMC test report was out-of-date. I would like to remove EMC Directive dated
notations from future reports.

 

Thank you in advance for your comments,

 

Chuck McDowell

Compliance Specialist 

Meyer Sound Laboratories Inc.

2832 San Pablo Ave.

Berkeley, CA 94702-2204

Phone 510-486-1166 Ext. 270

Fax 510-486-8356

Email cmcdow...@meyersound.com

 

 

 



NOTICE: This email may contain confidential information. Please see
http://www.meyersound.com/confidential/ for our complete policy.   --  

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Re: [PSES] FCC label - stick-on / permanently affixed ....

[John Allen]

Morning

 

Following on from Charlie’s points below, if you have a NTRL listing, then
(generally?) that NRTL will make sure that the rating label is physically
suitable for the intended use and environment (UL would require a suitably
Recognized labelling system label for a separate label) and therefore I
would have thought that that would be adequate grounds for claiming that it
would also meet the FCC requirements in question by default.

 

John Allen

W.London, UK

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 13 August 2015 08:15
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC label - stick-on / permanently affixed 

 

Amund

 

The FCC don’t routinely check labels in the same way that some NRTLs do, so
there’s no “approved label”. 

 

The FCC label should be as well affixed as your rating label and other
compliance marks - many products integrate them onto the same label or
silk-screen them onto the product

 

Regards

Charlie

 

From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 13 August 2015 07:45
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] FCC label - stick-on / permanently affixed 

 


FCC CFR 47 §15.19   Labelling requirements: The label shall not be a
stick-on, paper label. The label on these products shall be permanently
affixed to the product and shall be readily visible to the purchaser at the
time of purchase, as described in §2.925(d) of this chapter. “Permanently
affixed” means that the label is etched, engraved, stamped, silkscreened,
indelibly printed, or otherwise permanently marked on a permanently attached
part of the equipment or on a nameplate of metal, plastic, or other material
fastened to the equipment by welding, riveting, or a permanent adhesive. The
label must be designed to last the expected lifetime of the equipment in the
environment in which the equipment may be operated and must not be readily
detachable.


 

 

My interpretation:

Stick-on, paper label is a label with paper surface. Such type of label can
be damaged when exposed to humidity, water, etc.

I have a lot of devices (here at the office) with FCC label and many of them
have stick-on labels. But, they have plastic, vinyl, etc surface. Such a
label will be more resistant than a paper label. But still it’s a stick-on
label.

In my opinion, it will be good enough to use a stick-on plastic label with
permanent adhesive. The last question can be «what is permanent adhesive?».

 

Any comments?

 

Best regards

Amund

 

 

 

 

 

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Re: [PSES] FCC label - stick-on / permanently affixed ....

[John Allen]

Dave


That’s the sort of information source to which I was alluding – so it’s
probably what Amund should refer to.

 

John Allen

W.London, UK

 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: 13 August 2015 13:06
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC label - stick-on / permanently affixed 

 

You can also refer to UL 969 for requirements of adhesive-attached labels
for use as permanent nameplates.

 

-Dave

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, August 13, 2015 3:34 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC label - stick-on / permanently affixed 

 

Morning

 

Following on from Charlie’s points below, if you have a NTRL listing, then
(generally?) that NRTL will make sure that the rating label is physically
suitable for the intended use and environment (UL would require a suitably
Recognized labelling system label for a separate label) and therefore I
would have thought that that would be adequate grounds for claiming that it
would also meet the FCC requirements in question by default.

 

John Allen

W.London, UK

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 13 August 2015 08:15
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC label - stick-on / permanently affixed 

 

Amund

 

The FCC don’t routinely check labels in the same way that some NRTLs do, so
there’s no “approved label”. 

 

The FCC label should be as well affixed as your rating label and other
compliance marks - many products integrate them onto the same label or
silk-screen them onto the product

 

Regards

Charlie

 

From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 13 August 2015 07:45
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] FCC label - stick-on / permanently affixed 

 


FCC CFR 47 §15.19   Labelling requirements: The label shall not be a
stick-on, paper label. The label on these products shall be permanently
affixed to the product and shall be readily visible to the purchaser at the
time of purchase, as described in §2.925(d) of this chapter. “Permanently
affixed” means that the label is etched, engraved, stamped, silkscreened,
indelibly printed, or otherwise permanently marked on a permanently attached
part of the equipment or on a nameplate of metal, plastic, or other material
fastened to the equipment by welding, riveting, or a permanent adhesive. The
label must be designed to last the expected lifetime of the equipment in the
environment in which the equipment may be operated and must not be readily
detachable.


 

 

My interpretation:

Stick-on, paper label is a label with paper surface. Such type of label can
be damaged when exposed to humidity, water, etc.

I have a lot of devices (here at the office) with FCC label and many of them
have stick-on labels. But, they have plastic, vinyl, etc surface. Such a
label will be more resistant than a paper label. But still it’s a stick-on
label.

In my opinion, it will be good enough to use a stick-on plastic label with
permanent adhesive. The last question can be «what is permanent adhesive?».

 

Any comments?

 

Best regards

Amund

 

 

 

 

 

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[PSES] PSES Symposium 2016 - Compliance 101 Track

[John Allen]

Hi guys,


I'm heading up the Compliance 101 Track for the 2016 Symposium in Anaheim, CA.  
The Track was very well received last year and I'm hoping to do it again this 
year with 6 or 7 presentations on high level compliance issues, tips and 
teachings.


The audience for the Track are those new to compliance and designers who don't 
have the time to get their hands around compliance.  Believe it or not, some 
people that attended the Track last year still thought UL was a government 
agency.


I believe we have a huge opportunity to grow the Symposium, and membership in 
the PSES by teaching newbies and designers how to do what we do.  For the 
consultants out there I know this sounds like you're giving away free 
consulting, and you are, but as one of you I can say it is worth it - a 
knowledgeable client is our best client!!


The Symposium is not until May 16-18, 2016 but we need to get organized as the 
TPC is already meeting monthly.


Please consider doing a presentation and reach out to me if your interested.  
If you'd like to see the Compliance 101 presentations to get a flavor for what 
they looked like let me know.  Not 100% sure if I can pass them on if you 
didn't attend the symposium, but can certainly pass along something similar to 
the one I did.


Best Regards,


John


John Allen

President

Product Safety Consulting, Inc.

http://www.productsafetyinc.com

630-238-0188

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Re: [PSES] FW: [PSES] PSES Symposium 2016 - Compliance 101 Track

[John Allen]

Thanks Pete, that'd be great, even without the demonstration.  If anyone can 
find that video Kevin referred to, send it along.

The Call for Submissions is here - 
http://2016.psessymposium.org/sites/2016.psessymposium.org/files/call-for-papers/ISPCE_2016_CFP_v10-web.pdf

The first deadline is December 6, 2015.

Best Regards,

John

John Allen
President
Product Safety Consulting, Inc.
http://www.productsafetyinc.com
630-238-0188


Product Safety Consulting
Product Safety Consulting provides product developers and manufacturers with 
expert advice and testing services, so they can secure product safety and
Read more...



From: Kevin Robinson kevinrobinso...@gmail.com
Sent: Monday, August 24, 2015 11:30 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] PSES Symposium 2016 - Compliance 101 Track

About 10-15 years ago, there was an advertising video for a Bapco Safety 
Analyzer that was making the rounds. As I recall the President of the company 
said he had all of his sales engineers experience what high leakage current 
felt like by having them hold on to the bare conductors of a circuit he 
designed and he walked through sensing the current, experiencing pain, and let 
go current.

I would love to see that video again.

Kevin Robinson

 On Aug 24, 2015, at 11:32 AM, Pete Perkins 
 0061f3f32d0c-dmarc-requ...@ieee.org wrote:

 John, et al,

Well, no demonstration... Looked into it several years ago and the
 IEEE didn't want to cover the liability for such.  Too, bad, I've always
 felt that EE product folks should always know what allowable electric shock
 feels like.  But I do get to describe my own reaction to electric shock (bus
 not as satisfying for the audience).

 :) br, Pete

 Peter E Perkins, PE
 Principal Product Safety Engineer
 PO Box 23427
 Tigard, ORe  97281-3427

 503/452-1201 fone/fax
 p.perk...@ieee.org


 -Original Message-
 From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
 Sent: Sunday, August 23, 2015 11:14 PM
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] PSES Symposium 2016 - Compliance 101 Track

 In message 001801d0de2a$ab67e590$0237b0b0$@cs.com, dated Sun, 23 Aug 2015,
 Pete Perkins 0061f3f32d0c-dmarc-requ...@ieee.org writes:

I did the Electric Shock for Dummies pitch last year and had a great
 group attending.  I?m willing to do it again this year, building on
 last years session with some improvements.

 With demonstrations? (;-)
 --
 OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I
 turn my back on the sun, it's to look for a rainbow John Woodgate, J M
 Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Dual polarity DC electric strength test

[John Allen]

Just a couple of thoughts:

 

-   The quoted rationale from 62368-2, which I don’t have, is very “bland” 
and appears to pose more questions than it answers – so is more explanation 
and/or examples then given (there or elsewhere)?

 

-   Many (too many!) years ago I came across a product with a transformer 
with a fabricated, not moulded, bobbin which had very poor Creepage and 
clearance to Ground at one end of the primary wdg – so it would pass DC Hipot 
with one polarity to Ground but would fail disastrously if the polarity was 
reversed.

 

That sort of construction would (or at least “should”) not happen today, but in 
these cost-cutting times I can see why a production test might be considered 
necessary to weed out faulty manufacture, especially in sub-contractor supplied 
assemblies - but I am sure that no right-minded Compliance/Approvals Engineer 
would ever allow such construction through his type tests or allow it to be 
submitted to an agency for testing!

 

John Allen

W.London, UK

 

 

From: Wm Barry [mailto:05b89252cb83-dmarc-requ...@ieee.org] 
Sent: 05 August 2015 16:38
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Dual polarity DC electric strength test

 

The IEC 62368-2 Rationale document (under 5.4.9) states::

 

The dc voltage test with a test voltage equal to the peak value of the ac 
voltage is not fully equivalent to the ac voltage test due to different 
withstand characteristics of solid insulation for these types of voltages. 
However in case of a pure dc voltage stress, the dc voltage test is 
appropriate. To address this situation the dc test is made with both 
polarities.

 

This might make sense for type testing where insulation is being qualified 
especially when the test is conducted as verification that no damage to 
insulation occurred as a result of a another test.

 

For routine testing, my opinion has always been that this is done to catch 
damage to insulation that could occur during the manufacture/assembly of the 
product. Wouldn't such damage likely be caught by a dc test voltage at either 
polarity? 

 

Also note, that reversing the tester leads (for a tester that cannot produce 
negative dc voltage) on a Class 1 product with a metal enclosure will result in 
increased risk of shock to the test operator especially if the product 
enclosure is large. I think in most cases, the tester's return lead is bonded 
to the tester's earth connection making the EUT's enclosure safe to touch even 
during testing.

 

If routine testing is done to satisfy safety certification requirements, it 
might be worth having the discussion with the certifier to see how they 
interpret this requirement. 

 

I haven't heard of any cases where a product was shipped with damaged 
insulation because the dc hipot was only tested at positive polarity.

 

William Barry

 

(yes - the content contained in this email is of my own opinion and does not 
represent in any way the opinion of any former, current, or future employer)

 

 

On Wednesday, August 5, 2015 7:24 AM, Charlie Blackham 
char...@sulisconsultants.com wrote:

 

Rich

 

 The standard is incorrect in requiring tests of both polarity d.c.  There is 
 no physical rationale for both polarities. 

 

Go on, I’ll bite J

What’s this requirement doing in the standard then?

 

Regards

Charlie

 

 

From: Richard Nute [mailto:ri...@ieee.org] 
Sent: 04 August 2015 19:09
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Dual polarity DC electric strength test

 

 

 

Hi Greg:

 

 

The standard is incorrect in requiring tests of both polarity d.c.  There is no 
physical rationale for both polarities.  But, at this time, if you opt for d.c. 
testing, you must test with both polarities.  I would advise testing with a.c. 
to avoid capital expense of a new d.c. tester.  

 

 

Best regards,

Rich

 

 

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Re: [PSES] Friday night conundrum

[John Allen]

A few weeks ago, there was an interesting presentation on this very subject
at the TUV Sud Customer Day at Brooklands - so maybe someone from TUV Sud
might like to comment? :-D

 

John Allen

W.London, UK

 

-Original Message-
From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org] 
Sent: 14 August 2015 20:09
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Friday night conundrum

 

John,

 

Thinking of all of this only in EMI terms seems way too
limiting.

There are examples of all kinds of electromechanical devices which interact
readily with the body which could harbor unsuspecting hazards.  There are
already artificial limbs that are computer driven (even from brain waves or
other nerve signals}.  A cochlear implant doesn't have to be solely driven
by audio. How about an augmented reality set of glasses (and the computing
horsepower that drives it, all wearable).  What about a driven exoskeleton
that provides movement to someone severely handicapped or adds super power
for lifting or jumping.  Wearables are just coming into their own and we do
not yet see the full range of possibilities or the issues that they will
raise.  Some will be regulated medical devices (by whatever mechanism draws
them into that category) others will be commercial products and only covered
by the usual sets of requirements we normally deal with. 

 

It appears that the fun is just beginning.  Do you, John,
want to leave all the fun up to the young guys?  

 

:) br, Pete

Peter E Perkins, PE

Principal Product Safety Engineer

PO Box 23427

Tigard, ORe  97281-3427

503/452-1201 fone/fax

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

 

-Original Message-

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

Sent: Friday, August 14, 2015 11:24 AM

To:  mailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] Friday night conundrum

 

In message  mailto:001401d0d6bd$33ff5980$9bfe0c80$@cs.com
001401d0d6bd$33ff5980$9bfe0c80$@cs.com, dated Fri, 14 Aug 2015, Pete
Perkins  mailto:0061f3f32d0c-dmarc-requ...@ieee.org
0061f3f32d0c-dmarc-requ...@ieee.org writes:

 

   Is the 'brite line' of separation because of the power supply (I 

think not) or at some other defined 'interface'.

 

The question ought to be whether the product is a *conceivable* EMI threat
or needs regulatory control of its immunity. But note 'ought'. 

Some decisions seem to be made for undisclosed reasons.

--

OOO - Own Opinions Only. With best wishes. See
http://www.jmwa.demon.co.uk www.jmwa.demon.co.uk When I turn my back on
the sun, it's to look for a rainbow John Woodgate, J M Woodgate and
Associates, Rayleigh, Essex UK

 

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Re: [PSES] Calculating Reflection Angles on OATS/SAC

[John Allen]

IIRC 

 

IIRC, most of the basic principles were explained, with illustrations, in
Albert Smith’s early IEE papers published in the 1980s. 

 

I only had a paper copy of those when I started experimenting with his
swept-frequency site calibration methods in the late 80’s (at HP) and I
assume that the principles have been expounded and expanded many times over
the years – so can anyone point to some decent downloadable documents which
illustrate the issues?

 

John Allen

W.London, UK

 

From: Pawson, James [mailto:james.paw...@echostar.com] 
Sent: 10 August 2015 09:56
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Calculating Reflection Angles on OATS/SAC

 

Very helpful, thanks Brent!

 

From: Brent DeWitt [mailto:bdew...@ix.netcom.com] 
Sent: 08 August 2015 01:19
To: Pawson, James; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Calculating Reflection Angles on OATS/SAC

 

Hi James,

 

The image concept again is useful.  By definition, the  ground reference
plane is at zero potential.  For that to be true, charges on the real
antenna and its image must be equal and opposite.  Put a plus on one end of
a dipole and a minus on the other and look at them.  If they are vertical,
and the bottom of the real dipole has the minus sign, the top of the image
must be plus for the charges to cancel.  For the horizontal example, if the
left end is plus the same end of the image must be minus for the same
reason.

 

In the extreme thought experiment, if you lowered the vertical dipole so its
center point were at the ground plane (now a monopole), its image would
complete the dipole.  The same extreme applied to the horizontal dipole
would have the two cancelling each other out entirely.  We can see this in
reality, since the vertical polarization with the antenna at one meter
height is usually the strongest emission at low frequencies where the path
length in wavelengths is small.  The first maximum from the horizontal
dipole occurs when there is a 180 degree path length difference between the
real antenna and its image.

 

Does that help any?

Brent

 

From: Pawson, James [mailto:james.paw...@echostar.com] 
Sent: Thursday, August 06, 2015 5:13 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Calculating Reflection Angles on OATS/SAC

 

Many thanks for all of the replies on this topic. The conceptual key I
lacked was the “image” of the receiver below the ground plane which made the
calculations a lot simpler and I’ve now got an up and running spreadsheet.
I’ve also been introduced to things like cotangents and arctangents which
are new to me.

 

The only thing I still remain confused about is the phase of the reflection
from the ground plane.

 

 Gert wrote: “Note that vertical waves invert in polarity on reflection
with the ground plane, where horizontal polarized waves do not.”

 

 Brent wrote: “…and take the difference for phase, remembering that the
horizontally polarized image is 180 degrees out of phase to start with while
the vertical image is in phase.”

 

I might be misunderstanding but these statements seem to contradict each
other. I can kind of see how a vertically polarised wave would be reflected
inverted. If this was the case, could this be compensated for by subtracting
180° from the reflected ground ray to ensure the phases added/subtracted
correctly at the RX antenna?

 

Thanks again

James

 

 

 

_
From: Pawson, James 
Sent: 31 July 2015 15:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Calculating Reflection Angles on OATS/SAC

 

 

Hi,

 

I’m trying to calculate the distances/angles at which a maximum (in phase)
or minimum (anti-phase) signal would occur on an OATS/SAC.

 

I can do this simply when the TX and RX antennae are the same height above
the reflecting surface as the point of reflection lies halfway between the
two antennae, Distance_tx = Distance_rx. The direct and reflected paths can
be calculated using simple geometry and the wavelength is given by lambda =
c / f.

 

However when the height of the RX antenna is different to the height of the
TX antenna then the horizontal distance to the reflection point is no longer
equidistant. I can see that the ratio Height_tx / Distance_tx = Height_rx /
Distance_rx remains the same because the angle of reflection is the same.
But I’m left with two unknown Distance terms in the equation.

 

Is there a standard equation for calculating the reflection angle on an
OATS/SAC with a varying height antenna? Or can someone give me some pointers
to help me figure it out myself? I was so distracted thinking about this
that I missed my turnoff whilst cycling home the other day.

 

I’ve tried Googling but maybe I’m not putting in the right search term.

 

Any assistance gratefully received.

Thanks and regards,

James

 

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Re: [PSES] [BULK] Re: [PSES] PSES Symposium 2016 - Compliance 101 Track

[John Allen]

Those are great suggestions!!  If either of you - Ted and The Other Brian - or 
anyone else can put together either presentation they'd both be great for 
Compliance 101.  Any takers??


Only one comment in that there's no ketchup on Chicago style hot dogs!!


Best Regards,


John


John Allen

President

Product Safety Consulting, Inc.

http://www.productsafetyinc.com

630-238-0188


From: Ted Eckert ted.eck...@microsoft.com
Sent: Monday, August 24, 2015 4:53 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [BULK] Re: [PSES] PSES Symposium 2016 - Compliance 101 Track


Hotdogs can be used for demonstrations of pinch points. (I recommend not using 
Chicago style 
dogshttps://en.wikipedia.org/wiki/Chicago-style_hot_dog#/media/File:Chicago-style_hot_dog_2.jpg.
 The ketchup and mustard are bad enough, but that neon green relish makes a 
real mess during testing.) But seriously, raw hotdogs work for showing how 
different situations could cut the skin on a finger.



Another potential demonstration is to show how the K factor of a fan relates to 
injury. My hypothetical test would be to use a set fans with varying K factors. 
You could use the aforementioned hotdog or people who have signed a waiver. I 
wouldn’t recommend allowing participants to test any fan with a K factor more 
than 25% of the finger safe limit. That should be sufficient to give an idea of 
what the K factor means. It may be interesting to take a fan with a K factor 
just within the finger-safe limit and stick a hotdog in it to show what happens.



More than a decade ago, I took an HBSE course from UL that included leakage 
current video. It appeared to be from the 1950s and it started with a notice 
that the video was in the public domain. However, I’ve never been able to find 
a copy on the web. In the video, the person giving the demonstration cuts the 
ground plug off of a metal power drill and holds it in his hand. (This was long 
before double insulated power tools.) The person than put a metal cuff around 
their forearm just below the elbow. An assistant adjusted the current flowing 
through the presenters arm from the cuff to the drill. increasing it in steps 
to 8 mA with the presenter explaining what he feels. At 8 mA, the presenter was 
losing control of the musculature of the forearm, but he was still able to 
stand up and clearly describe the situation.



I don’t know if UL still has this video. If so, it is another question whether 
they would present it again or share it. Personally, I would rather not create 
a modernized version. I’ve experienced 3.5 mA between two fingers on one hand 
and that is more than enough of a test for me.



The opinions expressed are my own and do not necessarily reflect those of my 
employer. Do not try this at home, and consult your corporate attorney before 
even considering any demonstrations using humanb subjects. I am proposing 
hypotheitical demonstrations and I am not specifically endorsing the use of 
human subjects.



Ted Eckert



From: Kunde, Brian [mailto:brian_ku...@lecotc.com]
Sent: Monday, August 24, 2015 1:37 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [BULK] Re: [PSES] PSES Symposium 2016 - Compliance 101 Track



I would love to see a similar demonstration on determining minor to moderate 
mechanical hazards; pinch, crush, shear, etc.  How to measure force, determine 
contact area, calculating contact pressure, and ultimately determining the 
“Ouch Factor”. What protective measure can be use in different cases to “lower 
the risk to an accessible level”? How bad of boo boo are you willing to let 
your Users have access too?  At some point, someone is going to have to stick 
their finger in there and see how bad it hurts. I’m thinking about using one of 
those pain charts they use at the hospital.



I’d go to a demonstration like that.



The Other Brian



From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org]
Sent: Monday, August 24, 2015 1:07 AM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [BULK] Re: [PSES] PSES Symposium 2016 - Compliance 101 Track
Importance: Low



John,



Thanx for speaking up; the symposium is always awsome.



I did the Electric Shock for Dummies pitch last year and had a 
great group attending.  I’m willing to do it again this year, building on last 
years session with some improvements.



:) br, Pete



Peter E Perkins, PE

Principal Product Safety Engineer

PO Box 23427

Tigard, ORe  97281-3427



503/452-1201 fone/fax

p.perk...@ieee.orgmailto:p.perk...@ieee.org



From: John Allen [mailto:jral...@productsafetyinc.com]
Sent: Sunday, August 23, 2015 4:40 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] PSES Symposium 2016 - Compliance 101 Track



Hi guys,



I'm heading up the Compliance 101 Track for the 2016 Symposium in Anaheim, CA.  
The Track was very well received last year

Re: [PSES] Cd exemption for art material

[John Allen]

Brian 

 

Having now read the eur-lex text, I would have thought that the most likely
people to be affected by the cadmium in paints would be the artists who use
those paints -is that what you are alluding to below?

 

If so, then, again, I would have thought that the Swedish proposal should
then have been drafted to address that issue - Thus if "history" then showed
that artists and their direct associates do/do not appear not to have
suffered any long term effects from cadmium in their materials, then that
would be a good reason for accepting/rejecting that proposal.

 

By contrast the actual Swedish proposal took a tortuous route to actually
achieving very little - and presumably at some actual cost for the
investigations and reports etc.

 

Relatively good to see that the REACH bodies do take a risk assessment
approach where the material in question is a minor contributor to an
environmental issue, and not just the "definitive" "if it can then it will
cause a real problem" approach.

 

Might be a pity that the powers-that-be behind ROHS/ROHS2 did not take a
similar approach?

 

John Allen

W. London, UK.

 

-Original Message-
From: Brian O'Connell [mailto:oconne...@tamuracorp.com] 
Sent: 05 November 2015 17:51
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Cd exemption for art material

 

 
<http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52015XC1028(0
1)=EN>
http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52015XC1028(01
)=EN

 

The chemical principle of local concentration vs equilibria, and likelihood
for direct exposure to users, seems to have been ignored.

 

 

Brian

Sr Janitorial Assistant For the Vulcan Science Academy

 

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Re: [PSES] EMC in Canada

[John Allen]

FWIW, as we all know, the overall EM environment has changed greatly in the
last 25 yrs, and, surely, that Canadian document should be updated -
although it probably won't!

Therefore, suppliers really do need to consider the immunity aspect very
seriously - even if it is only from the "customer satisfaction" ( or "not"!)
perspective - so the EU requirements are a "legal" step in that direction
and should be a real consideration for any supplier, especially if they want
to sell "everywhere" in the World.

W.r.t. Amund's  original post: my comments above might well be a good
objective to keep in mind - poor immunity can be a real problem in the
"real" World (been there, seen it!) where poor immunity can lead to lots of
"unexplained" field failures and tortuous "fixes" which don't really address
the underlying design problems. Thus, even where there are no legal
requirements, comply with general legal requirements elsewhere as a starting
point - and don't dismiss them as an irrelevance for that particular market!

John Allen
W.London, UK

-Original Message-
From: Bill Stumpf [mailto:bstu...@dlsemc.com] 
Sent: 06 October 2015 20:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC in Canada

Amund,
Industry Canada has a couple of immunity Advisory bulletins published: 

https://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/emcab1.pdf/$FILE/emcab1.pdf

http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf01005.html


EMCAB-1 is no longer found listed on their website, but the link still
works.  Although over 21 years old they may be of some value.


Bill Stumpf - Lab / Technical Manager
D.L.S. Electronic Systems, Inc.
166 South Carter Street
Genoa City WI 53128
Ph: 262-279-0210






-Original Message-
From: Brian O'Connell [mailto:oconne...@tamuracorp.com]
Sent: Tuesday, October 06, 2015 11:42 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC in Canada

Cannot make 'blanket' statement that there are "no immunity requirements in
Canada". Some ISM stuff does have immunity/susceptibility requirements,
where (at least) the generic immunity standards are referenced. But there is
no CAN/CSA 61326-1, and there is no CAN/CSA CISPR24, and there is no CAN/CSA
CISPR14-2.

But they do try to speak French in Quebec, but cannot know effects of
Canadian French on product immunity. Eh.

Brian

-Original Message-
From: Amund Westin [mailto:am...@westin-emission.no]
Sent: Monday, October 05, 2015 10:23 PM
To: Brian O'Connell; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: SV: [PSES] EMC in Canada

It's a video and audio recorder.
Yes, we make use of EN55103-2 for CE marking.

But generally, still no immunity requirements in Canada?


#Amund
  


-Opprinnelig melding-
Fra: Brian O'Connell [mailto:oconne...@tamuracorp.com]
Sendt: 5. oktober 2015 22:15
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] EMC in Canada

'Professional' stuff would reference 55103-2, but not a Canada requirement.
Do not know what your box does, but note that for A/V stuff for use with
medical equipment, CSA 60601-1-2 does reference 55103-2.

Brian

From: Amund Westin [mailto:am...@westin-emission.no]
Sent: Monday, October 05, 2015 12:00 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EMC in Canada

Emission testing ITE: ICES-003
Immunity testing ITE: No requirements

Is it the same approach for professional A/V products? Only emission
testing?

Best regards
Amund

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Re: [PSES] OSHA and UL60974-1 Engine Driven Arc Welders

[John Allen]

Hi Kevin,


Thank you for the detailed clarification!!


Best Regards,


John



From: Kevin Robinson <kevinrobinso...@gmail.com>
Sent: Thursday, October 8, 2015 2:27 PM
To: John Allen
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] OSHA and UL60974-1 Engine Driven Arc Welders

Hi John,

My name is Kevin Robinson, and I am the Director of the office that administers 
the NRTL Program for OSHA.  While this response is not an "official" response 
from OSHA (as I am sending it from my personal account), I would say the same 
thing if you were to contact me at work 
(robinson.ke...@dol.gov<mailto:robinson.ke...@dol.gov>).

Before I answer your question, I would like to help set the stage a bit.  The 
NRTL Program was created by OSHA and for OSHA.  OSHA NRTL Approval requirements 
while adopted by many state and local AHJs do not officially travel down to 
that level.  Whether an AHJ would accept a certification is really up to that 
AHJ.  Additionally, only certain types of equipment 
(http://www.osha.gov/dts/otpca/nrtl/prodcatg.html) are required by OSHA 
regulations to be "acceptable" (certified by an  NRTL).  You will notice that 
engine driven arc welders do not appear on the list of products requiring NRTL 
approval, therefore, NRTL approval is not required to satisfy OSHA (but your 
local AHJ may require some independent certification).

With that said, any organization recognized by OSHA as an NRTL can evaluate, 
test and certify equipment that is not on their NRTL scope and issue a 
certification, however, if the standard is not in their NRTL scope of 
recognition (http://www.osha.gov/dts/otpca/nrtl/nrtllist.html) then they may 
not represent themselves as an NRTL (either in the quotation, contracts, but 
most importantly, on the certification mark that they authorize you to apply to 
your product.  If an organization recognized by OSHA as an NRTL were to test 
and certify a product outside their NRTL scope that would be fine.  An AHJ may 
accept that certification, but the certification would NOT be acceptable to 
OSHA (assuming NRTL certification was even required).

If you have any additional questions, feel free to contact me directly.

Kevin Robinson
202-693-1911
robinson.ke...@dol.gov<mailto:robinson.ke...@dol.gov>



On Thu, Oct 8, 2015 at 2:54 PM, John Allen 
<jral...@productsafetyinc.com<mailto:jral...@productsafetyinc.com>> wrote:

Hi guys,


Question on the subject -

UL60974-1 (Engine Driven Arc Welders) is not on the OSHA list of "Appropriate 
Test Standards".  UL551 (Transformer Arc Welders) is on the list.  No NRTLs 
have UL60974-1 coverage by OSHA.  Can we still use UL60974-1 for USA 
Certification?

Our issue is that UL551 does not cover our product - an Engine Driven Arc 
Welder.

Stated another way, if a Standard is not on the "Appropriate Test Standard" 
list, and no NRTLs have OSHA coverage for it, can we still Certify to it and 
have it be accepted by OSHA or any AHJ?

Thanks,

John
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[PSES] OSHA and UL60974-1 Engine Driven Arc Welders

[John Allen]

Hi guys,


Question on the subject -

UL60974-1 (Engine Driven Arc Welders) is not on the OSHA list of "Appropriate 
Test Standards".  UL551 (Transformer Arc Welders) is on the list.  No NRTLs 
have UL60974-1 coverage by OSHA.  Can we still use UL60974-1 for USA 
Certification?

Our issue is that UL551 does not cover our product - an Engine Driven Arc 
Welder.

Stated another way, if a Standard is not on the "Appropriate Test Standard" 
list, and no NRTLs have OSHA coverage for it, can we still Certify to it and 
have it be accepted by OSHA or any AHJ?

Thanks,

John

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Re: [PSES] CE Marking on Packaging of Assembly Components

[John Allen]

Carl

Personally, I would:

- Decide what is the most major part of the product which has a visible
external surface which be carrying all the other product identification
marking, and then put the  CE marking on that part;
- Make sure that the product documentation going to the customers clearly
states that the product will only be compliant with all relevant CE
Directives and the DoC when assembled and installed according to the
detailed instructions you provide.
- Before making the final decisions, take a look at the recently updated
Commission Blue Guide - and particularly Chp 2 Section 2.1 Product
Coverage and the para beginning A combination of products... on Page 18
and Chp 4 Section 4.2.2.3 Identification element on Page 49.

John Allen
W.London, UK
 
-Original Message-
From: Chuck McDowell [mailto:chu...@meyersound.com] 
Sent: 27 August 2015 17:52
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE Marking on Packaging of Assembly Components

I can across this European Commission document on spare parts this week. It
maybe of interest.
I believe it states that for EMC Directive OEM parts do not require a DoC
ergo no CE mark.
 Google APPLICATION OF EMC DIRECTIVE AND/OR EMC VEHICLE DIRECTIVE TO
AFTERMARKET EQUIPMENT

http://www.google.com/url?sa=trct=jq=esrc=ssource=webcd=1cad=rjauact=
8ved=0CB4QFjAAahUKEwjfy73C2MnHAhUQRYgKHWphDz4url=http%3A%2F%2Fec.europa.eu
%2FDocsRoom%2Fdocuments%2F4543%2Fattachments%2F1%2Ftranslations%2Fen%2Frendi
tions%2Fnativeei=7zvfVZ-YL5CKoQTqwr3wAwusg=AFQjCNHmvmnYBItTKhMu7bZUXyC2ols
YGA

See if category B applies to you sub-assemblies?


Chuck McDowell
Compliance Specialist 
Meyer Sound Laboratories Inc.


-Original Message-
From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Thursday, August 27, 2015 8:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE Marking on Packaging of Assembly Components

It depends on which directives apply to the product/components.  The
Machinery Direct is clear that partly complete machinery is not to carry a
CE mark to avoid confusion when it's integrated with the complete system.
Partly completed machinery should be accompanied by a DoI.However if
your items are not machinery but instead fall under the LVD for example and
you are going to provide a separate DoC for those items then it would make
sense that they be marked.   If you are not providing a separate DoC/DoI for
these items because they have not been assessed as individual products then
perhaps provide documentation/statement that they are part of the larger
system to be integrated and provide a copy of the DoC of the complete system
but do not CE mark the items/shipping container itself.  I wouldn't put a CE
mark on a component that falls under MD or LVD without having a DoC/DoI and
technical file to back it up.

-Dave

-Original Message-
From: Carl Newton [mailto:emcl...@gmail.com]
Sent: Thursday, August 27, 2015 8:39 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] CE Marking on Packaging of Assembly Components

Group,

I'm dealing with a scenario in which a storage assembly that includes some
electronic functionality is assembled on-site by end-users.  Various  
elements of this storage product are shipped from different factories.   
One package may include the electronic subassembly that has the product
label attached.  Another package may include plastic panels with no inherent
standalone function (RoHS does not apply at this time).  The set of
component packages that comprise the product are imported into the EU  from
the USA.  The UK distributor has asked that all packages have the CE Marking
on the box.  I'm reluctant to sign-up to this procedure in view of the fact
that the CE Marking should not be applied to most sub-assemblies.


I've reviewed the 2014 Blue Guide, Regulation (EC) No 765/2008, and
768/2008/E seeking guidance on this scenario but find nothing.  Is anybody
within the group aware of some form of legal guidance that applies?

Thanks,

Carl

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This message

Re: [PSES] FW: [PSES] [BULK] Re: [PSES] PSES Symposium 2016 - Compliance 101 Track

[John Allen]

Thanks Rich!  The video was great!


Best Regards,


John


John Allen

President

Product Safety Consulting, Inc.

http://www.productsafetyinc.com

630-238-0188

[http://www.productsafetyinc.com/assets/product-safety-consulting.png]http://www.productsafetyinc.com/

Product Safety Consulting
Product Safety Consulting provides product developers and manufacturers with 
expert advice and testing services, so they can secure product safety and
Read more...http://www.productsafetyinc.com/




From: Pete Perkins 0061f3f32d0c-dmarc-requ...@ieee.org
Sent: Monday, August 24, 2015 7:49 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] FW: [PSES] [BULK] Re: [PSES] PSES Symposium 2016 - Compliance 
101 Track


Rich,



Thanx for chasing the video's.



My kids saw Hagagrd's live demo in the 70's and I met him 
briefly when I picked them up.



We'll have to see how to fit some of this in...



:) br, Pete



Peter E Perkins, PE

Principal Product Safety Engineer

PO Box 23427

Tigard, ORe  97281-3427



503/452-1201 fone/fax

p.perk...@ieee.org



From: Richard Nute [mailto:ri...@ieee.org]
Sent: Monday, August 24, 2015 4:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [BULK] Re: [PSES] PSES Symposium 2016 - Compliance 101 Track







Hi Ted:





You can download the video here:



https://dl.dropboxusercontent.com/u/69937717/ubc/20041102-045126.mpg



The gentleman is Claude Haggard.  I think he lived in Medford, Oregon.  This 
was from a TV show (back in the days of BW TV) he did for Pacific Power to 
alert rural folks to the hazards of electricity.  Mr. Haggard would take his 
show throughout the US, primarily for school children.  I saw him do his show 
in person, probably in the Midwest.



Here is a very brief announcement of his presentation at SOC, March 25, 1955.



http://www.newspapers.com/newspage/96844225/



You can also see a record of Mr. Haggard presenting to an NFPA committee 
(Chicago) in 1958:



http://www.nfpa.org/Assets/files/AboutTheCodes/70/NEC-Proceedings-1958.pdf



Here is another article and picture about one of his presentations, (Seattle, 
November, 1971):



http://providencearchives.contentdm.oclc.org/cdm/ref/collection/p15352coll31/id/163





Enjoy!

Rich



ps:  I used carrots to determine if mechanical impacts would hurt.





-


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Re: [PSES] [BULK] Re: [PSES] PSES Symposium 2016 - Compliance 101 Track

[John Allen]

Thanks Dan,


Pretty funny guy!!  Not sure if PSES would allow live demos.


Best Regards,


John


John Allen

President

Product Safety Consulting, Inc.

http://www.productsafetyinc.com

630-238-0188

[http://www.productsafetyinc.com/assets/product-safety-consulting.png]<http://www.productsafetyinc.com/>

Product Safety Consulting
Product Safety Consulting provides product developers and manufacturers with 
expert advice and testing services, so they can secure product safety and
Read more...<http://www.productsafetyinc.com/>




From: Dan Roman <danp...@verizon.net>
Sent: Monday, August 31, 2015 9:17 PM
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG; 'Pete Perkins'; ri...@ieee.org
Subject: RE: [PSES] [BULK] Re: [PSES] PSES Symposium 2016 - Compliance 101 Track


This guy appears to be doing a lot of demos, perhaps you can get him…here is a 
sample of his work.



https://youtu.be/MMzU66IHe-k



__
Dan Roman, N.C.E.

Senior Member

IEEE Product Safety Engineering Society

mailto:dan.ro...@ieee.org








From: John Allen [mailto:jral...@productsafetyinc.com]
Sent: Monday, August 24, 2015 6:32 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [BULK] Re: [PSES] PSES Symposium 2016 - Compliance 101 Track



Those are great suggestions!!  If either of you - Ted and The Other Brian - or 
anyone else can put together either presentation they'd both be great for 
Compliance 101.  Any takers??



Only one comment in that there's no ketchup on Chicago style hot dogs!!



Best Regards,



John



John Allen

President

Product Safety Consulting, Inc.

http://www.productsafetyinc.com

630-238-0188





From: Ted Eckert <ted.eck...@microsoft.com<mailto:ted.eck...@microsoft.com>>
Sent: Monday, August 24, 2015 4:53 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [BULK] Re: [PSES] PSES Symposium 2016 - Compliance 101 Track



Hotdogs can be used for demonstrations of pinch points. (I recommend not using 
Chicago style 
dogs<https://en.wikipedia.org/wiki/Chicago-style_hot_dog#/media/File:Chicago-style_hot_dog_2.jpg>.
 The ketchup and mustard are bad enough, but that neon green relish makes a 
real mess during testing.) But seriously, raw hotdogs work for showing how 
different situations could cut the skin on a finger.



Another potential demonstration is to show how the K factor of a fan relates to 
injury. My hypothetical test would be to use a set fans with varying K factors. 
You could use the aforementioned hotdog or people who have signed a waiver. I 
wouldn’t recommend allowing participants to test any fan with a K factor more 
than 25% of the finger safe limit. That should be sufficient to give an idea of 
what the K factor means. It may be interesting to take a fan with a K factor 
just within the finger-safe limit and stick a hotdog in it to show what happens.



More than a decade ago, I took an HBSE course from UL that included leakage 
current video. It appeared to be from the 1950s and it started with a notice 
that the video was in the public domain. However, I’ve never been able to find 
a copy on the web. In the video, the person giving the demonstration cuts the 
ground plug off of a metal power drill and holds it in his hand. (This was long 
before double insulated power tools.) The person than put a metal cuff around 
their forearm just below the elbow. An assistant adjusted the current flowing 
through the presenters arm from the cuff to the drill. increasing it in steps 
to 8 mA with the presenter explaining what he feels. At 8 mA, the presenter was 
losing control of the musculature of the forearm, but he was still able to 
stand up and clearly describe the situation.



I don’t know if UL still has this video. If so, it is another question whether 
they would present it again or share it. Personally, I would rather not create 
a modernized version. I’ve experienced 3.5 mA between two fingers on one hand 
and that is more than enough of a test for me.



The opinions expressed are my own and do not necessarily reflect those of my 
employer. Do not try this at home, and consult your corporate attorney before 
even considering any demonstrations using humanb subjects. I am proposing 
hypotheitical demonstrations and I am not specifically endorsing the use of 
human subjects.



Ted Eckert



From: Kunde, Brian [mailto:brian_ku...@lecotc.com]
Sent: Monday, August 24, 2015 1:37 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [BULK] Re: [PSES] PSES Symposium 2016 - Compliance 101 Track



I would love to see a similar demonstration on determining minor to moderate 
mechanical hazards; pinch, crush, shear, etc.  How to measure force, determine 
contact area, calculating contact pressure, and ultimately determining the 
“Ouch Factor”. What protective measure c

Re: [PSES] PSES Symposium 2016 - Compliance 101 Track demo

[John Allen]

When he was at HP many (about 40 IIRC) years ago, Al Kanode ran some demos
(participated myself, and it was "interesting!) like that - anyone have any
film (before the days of home videos!) of one of those ?

On my side, I helped to design and install the electrical side of an exhibit
at the London Science Museum in 2004/2005 to demonstrate that you can't see
electrical energy but it really does exist. It consisted (briefly!) of a
tall metal column connected to a shock source (a low-power electric fence
energiser with external ballasting to reduce the shock current to a much
lower level than the max in most standards) - people touched it with the
fingers, and when they did they got a slight shock and there was a loud
noise from the associated sound system.

See this video of it for a laugh https://vimeo.com/31445076.

The critical part of the design that I added was the shock circuit was only
between the inner core of the centre section and the fairly closely packed
metal rods surrounding it -  and you could only insert a couple of fingers
at a time, and thus you would get the shock between the fingers on one hand.
OTOH, in the original design (before I got involved!), you got the shock
between the cylinder - which had no centre section at that time - and the
floor, and that, coupled with the use of a much more powerful fence
energizer, meant a MUCH bigger "belt" which no-body in their right mind
would want in a public place like that.

Literally thousands of people (including lots of kids!) played with this
thing - sometimes for protracted periods - and, AFAIK, no-one got even
mildly hurt!

Surely something like that could be demonstrated, with the well-publicised
warning that that the higher the shock current then the "bigger" the effect
would be?

John Allen
W.London, UK

-Original Message-
From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org] 
Sent: 02 September 2015 17:12
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] PSES Symposium 2016 - Compliance 101 Track demo

Dan et al,

A flamboyant demonstration; not sure that a person needs to
shock his tongue - an organ with lots of sensors built-in.  Seems like
something left over from a horror movie (or real life experience in some
cultures since the introduction of electricity 100 years ago or so).  

There is a lot of good technical information available on
electric shock - starting from the 1930s (Whittaker) thru the 1950s
(especially Dalziel) and more recently (e.g. 1983 & 1986 ES symposiums).
This technical material is summarized in IEC 60479 series of Basic Safety
standards which are to be used by equipment committees.  I have given a
number of electric shock presentations at the IEEE PSES/ISPCE meetings since
the first meeting of this group.  

I have been involved in electric shock demonstrations both
as a subject (see my PSES08 presentation on body impedance calculations) and
as a demonstrator with hundreds of participants over the years.   The demo
allows the participant to feel the startle-reaction current (0.5mArms) and
just short of the letgo-immobilization current (3.5mArms demo) as defined in
the technical standards we commonly deal with; the distributions of current
between these two levels is widespread, as shown in my papers.  

Nute & I have sought permission from the IEEE to give a demo
at the meetings and it was refused because of the liability issues.  The
PSES management committee is familiar with the effort.  

Watching a video is interesting (and, as has been pointed
out, you can watch it on YouTube).  Watching a person get a live shock is
more interesting (hopefully not some prurient interest here).  Participating
in a safe electric shock demo is revealing and qualitative, leaving a
lasting impression on most participants.  

My compliance 101 demo has not used a  video or a demo;
there is a lot more important technical information to present in the short
time allotted.  

If folks want to watch YouTube videos we could set up a
table in the exhibit hall and let them run non-stop.  

C'mon down and I'll give the scoop on electric shock (jra
consenting) including dealing with modern switching supplies and the issues
introduced at the product level which must be measured and remain in
compliance to the long-standing requirements.  

There's more here than meets the eye.  

:>) br, Pete
 
Peter E Perkins, PE
Principal Product Safety Engineer
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201 fone/fax
p.perk...@ieee.org

_ _ _ _ _

Thanks Dan,

Pretty funny guy!!  Not sure if PSES would allow live demos.

Best Regards,

John

John Allen
President
Product Safety Consulting, Inc.
http://www.productsafetyinc.com
630-238-0188

-
--

Re: [PSES] RF Common Mode Immunity Test Question

[John Allen]

FWIW, 27MHz sounds more like a CB station rather than an “real” Amateur station 
which (IIRC) would be using the 28MHz band – and CB operators (especially in 
some countries! ) may use illegal amps (“boosters”) to raise the transmit power 
beyond the legal limits!


John Allen

W.London, UK

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 12 September 2015 20:00
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

I agree -an amateur could not and would not use a call sign other than his or 
her designated licensed call sign. No blue leader, no quacking duck, nothing 
but respective number licensed to him or her.

 

 

 

 

 

Sent from my Verizon Wireless 4G LTE smartphone

 Original message 

From: "ce-test, qualified testing bv - Gert Gremmen" <g.grem...@cetest.nl> 

Date: 9/12/2015 11:25 AM (GMT-08:00) 

To: EMC-PSTC@LISTSERV.IEEE.ORG 

Subject: Re: [PSES] RF Common Mode Immunity Test Question 

 

A Ham never can be a source of interference, by definition (if they
respect their limits- in more than one way).

To me an amateur is not a HAM, but that is a matter of language I
suppose.



My example showed a (spiced up) example of lack of immunity in a
professional audio installation , that due pragmatic testing, too cables
with average screening properties

and a substantial power output in a "room" with  may-i-say very specific
acoustic properties, lead to an extremely interfering situation.



Gert Gremmen



Van: Ed Price [mailto:edpr...@cox.net] 
Verzonden: zaterdag 12 september 2015 20:09
Aan: ce-test, qualified testing bv - Gert Gremmen
Onderwerp: RE: [PSES] RF Common Mode Immunity Test Question



Gert:



Allow me to fine tune your story for accuracy. In the late 1950's, the
USA FCC re-allocated the 27 MHz region (called 11 meter band) from
amateur use to a new "citizens" band. (I don't know how many other
countries followed that example.) This was created from the existing
amateur 10-meter band, making amateurs rather unhappy. This 11-meter
Citizens Band eventually degenerated into unregulated technical and
operational chaos. If you had a device exhibiting a susceptible response
of a "blue angel calling a red devil" and not something like "WB6WSN
calling..." then the source was not an amateur but an unregulated CB'er.
Please, hams are sensitive about being the assumed source of
interference.



Ed Price
WB6WSN
Chula Vista, CA USA



-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: Saturday, September 12, 2015 10:18 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question



This is a typical standards clause included in a standard by non-emc
"experts".



What  is a metal enclosure, and when is it not enclosure ?

Metalized plastic:  is not metal but might be as good Painted metal:
complies but may have substantial potential difference between parts



If heavy interference exists, 4 braid connection points are not enough,
and inferior braided coax and signal cables is all over the market.



This is an example of economic drive  "fast  cheap & pragmatic testing"

and this  exemption clause

is a recipe for problems in the field.



I remember a customer of mine building PA systems for a church
application ( = 55103-2) Final testing was ok, and the system worked
like a charm.

The first Sunday in real use, the vicar got an unexpected reply on its
questions to the mighty when a local 27 MHz radio amateur switched on
its transmitter and "preached"  : "blue angel calling red devil "







Gert Gremmen

ce-test qualified testing bv





-Oorspronkelijk bericht-

Van: John Woodgate [mailto:j...@jmwa.demon.co.uk 
<mailto:j...@jmwa.demon.co.uk%0b%3cmailto:j...@jmwa.demon.co.uk%3e%20> 
<mailto:j...@jmwa.demon.co.uk> ]

Verzonden: vrijdag 11 september 2015 16:48

Aan: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 

Onderwerp: Re: [PSES] RF Common Mode Immunity Test Question



In message

<6165069ea399fe46b1a5148bcb1a75ebd...@ex-ukha-01.ad.s-a-m.com 
<mailto:6165069ea399fe46b1a5148bcb1a75ebd...@ex-ukha-01.ad.s-a-m.com%0b%3cmailto:6165069ea399fe46b1a5148bcb1a75ebd...@ex-ukha-01.ad.s-a-m.com>
 
<mailto:6165069ea399fe46b1a5148bcb1a75ebd...@ex-ukha-01.ad.s-a-m.com> >,
dated Fri, 11 Sep 2015, Robert Dunkerley <robert.dunker...@s-a-m.com 
<mailto:robert.dunker...@s-a-m.com%0b%3cmailto:robert.dunker...@s-a-m.com> 
<mailto:robert.dunker...@s-a-m.com> > writes:



>Would this not imply that nearly all types of signal cables (most are 

>screened this way?) would be exempt from this test, or is my 

>understanding totally wrong? (probably the case!)



Not all products have a metal case. Not all ports meet the definition of
'screened port'. Not all cables have br

Re: [PSES] RF Common Mode Immunity Test Question

[John Allen]

Ed

 

Hopefully (?) at least some of the kit sold in the US is also elsewhere in
the World where there ARE EM immunity requirements, and so the relevant
design precautions are effectively in place anyway (unless/until the bean
counters get their way to make the US-market products cheaper!)

 

John Allen

W.London, UK

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: 12 September 2015 21:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

John:

 

Unfortunately, American consumer electronics has no E-field immunity
requirement. The only help a consumer gets is that little paragraph of
legalese that advises you to re-orient your device and move further away
from emitters. OTOH, most consumer equipment design which takes emission
compliance into account will also yield reasonable immunity levels. My
personal experience indicates that most immunity problems with consumer
electronics is not a design problem but a reliability problem. As an
example, last year a friend asked me to repair his semi-pro mixer board
(used in a church environment); he had problems "everywhere" with
distortion, low gain and external RF susceptibility. However, the mixer
board was fine; it was his patch cords that were horribly abused and leaky.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Saturday, September 12, 2015 11:47 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

In message <
<mailto:FCA549BE3ECF9D4CB8CB8576837EA48920AF42@ZEUS.cetest.local>
FCA549BE3ECF9D4CB8CB8576837EA48920AF42@ZEUS.cetest.local>,

dated Sat, 12 Sep 2015, "ce-test, qualified testing bv - Gert Gremmen" 

< <mailto:g.grem...@cetest.nl> g.grem...@cetest.nl> writes:

 

>A Ham never can be a source of interference, by definition (if they 

>respect their limits- in more than one way).

 

It is clearly not true, given the unlimited lack of immunity exhibited by
some products. Immunity isn't even controlled in the Americas.

> 

>To me an amateur is not a HAM, but that is a matter of language I 

>suppose.

 

Yes. 'Amateur' is the larval form. (;-)

> 

>My example showed a (spiced up) example of lack of immunity in a 

>professional audio installation , that due pragmatic testing, too 

>cables with average screening properties

 

Was it definitely due to cables? Much professional PA equipment is none too
good on immunity. And there are far too many installations that don't
exclusively use balanced lines.

> 

 

--

OOO - Own Opinions Only. With best wishes. See
<http://www.jmwa.demon.co.uk> www.jmwa.demon.co.uk When I turn my back on
the sun, it's to look for a rainbow John Woodgate, J M Woodgate and
Associates, Rayleigh, Essex UK

 

-



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well-used formats), large files, etc.

 

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Re: [PSES] RF Common Mode Immunity Test Question

[John Allen]

“Lazyboy”

 

You may not have, and, as a licenced Amateur, I am sure you would not because 
you know that you should not, and that there are better and more challenging 
ways to talk to your faraway friends – but I don’t think that some CB operators 
are as “conscientious” J.

 

John Allen

W.London, UK

 

From: Scott Douglas [mailto:sdouglas...@gmail.com] 
Sent: 12 September 2015 23:13
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

Well, I never hooked up a 1 kW linear amp to my 5 W CB radio to talk to South 
America. And woke the neighbors on Sunday morning so they could listen to me on 
their turned-off console radio receiver...

So says
Lazyboy
KDT-8165

On 9/12/2015 12:37 PM, John Allen wrote:

FWIW, 27MHz sounds more like a CB station rather than an “real” Amateur station 
which (IIRC) would be using the 28MHz band – and CB operators (especially in 
some countries! ) may use illegal amps (“boosters”) to raise the transmit power 
beyond the legal limits!


John Allen

W.London, UK

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 12 September 2015 20:00
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

I agree -an amateur could not and would not use a call sign other than his or 
her designated licensed call sign. No blue leader, no quacking duck, nothing 
but respective number licensed to him or her.

 

 

 

 

 

Sent from my Verizon Wireless 4G LTE smartphone

 Original message 

From: "ce-test, qualified testing bv - Gert Gremmen" <g.grem...@cetest.nl> 

Date: 9/12/2015 11:25 AM (GMT-08:00) 

To: EMC-PSTC@LISTSERV.IEEE.ORG 

Subject: Re: [PSES] RF Common Mode Immunity Test Question 

 

A Ham never can be a source of interference, by definition (if they
respect their limits- in more than one way).

To me an amateur is not a HAM, but that is a matter of language I
suppose.



My example showed a (spiced up) example of lack of immunity in a
professional audio installation , that due pragmatic testing, too cables
with average screening properties

and a substantial power output in a "room" with  may-i-say very specific
acoustic properties, lead to an extremely interfering situation.



Gert Gremmen



Van: Ed Price [mailto:edpr...@cox.net] 
Verzonden: zaterdag 12 september 2015 20:09
Aan: ce-test, qualified testing bv - Gert Gremmen
Onderwerp: RE: [PSES] RF Common Mode Immunity Test Question



Gert:



Allow me to fine tune your story for accuracy. In the late 1950's, the
USA FCC re-allocated the 27 MHz region (called 11 meter band) from
amateur use to a new "citizens" band. (I don't know how many other
countries followed that example.) This was created from the existing
amateur 10-meter band, making amateurs rather unhappy. This 11-meter
Citizens Band eventually degenerated into unregulated technical and
operational chaos. If you had a device exhibiting a susceptible response
of a "blue angel calling a red devil" and not something like "WB6WSN
calling..." then the source was not an amateur but an unregulated CB'er.
Please, hams are sensitive about being the assumed source of
interference.



Ed Price
WB6WSN
Chula Vista, CA USA



-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: Saturday, September 12, 2015 10:18 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question



This is a typical standards clause included in a standard by non-emc
"experts".



What  is a metal enclosure, and when is it not enclosure ?

Metalized plastic:  is not metal but might be as good Painted metal:
complies but may have substantial potential difference between parts



If heavy interference exists, 4 braid connection points are not enough,
and inferior braided coax and signal cables is all over the market.



This is an example of economic drive  "fast  cheap & pragmatic testing"

and this  exemption clause

is a recipe for problems in the field.



I remember a customer of mine building PA systems for a church
application ( = 55103-2) Final testing was ok, and the system worked
like a charm.

The first Sunday in real use, the vicar got an unexpected reply on its
questions to the mighty when a local 27 MHz radio amateur switched on
its transmitter and "preached"  : "blue angel calling red devil "







Gert Gremmen

ce-test qualified testing bv





-Oorspronkelijk bericht-

Van: John Woodgate [mailto:j...@jmwa.demon.co.uk 
<mailto:j...@jmwa.demon.co.uk%0b%3cmailto:j...@jmwa.demon.co.uk%3e%20> 
<mailto:j...@jmwa.demon.co.uk> ]

Verzonden: vrijdag 11 september 2015 16:48

Aan: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 

Onderwerp: Re: [PSES] RF Common Mode Immunity Test Question



In message

<6165069ea399fe46b1a51

Re: [PSES] RF Common Mode Immunity Test Question

[John Allen]

Scott

 

I think I need to apologise for the tone of my earlier email – a bit OTT w.r.t. 
yourself on reflection !

 

John Allen

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 13 September 2015 08:51
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

“Lazyboy”

 

You may not have, and, as a licenced Amateur, I am sure you would not because 
you know that you should not, and that there are better and more challenging 
ways to talk to your faraway friends – but I don’t think that some CB operators 
are as “conscientious” J.

 

John Allen

W.London, UK

 

From: Scott Douglas [mailto:sdouglas...@gmail.com] 
Sent: 12 September 2015 23:13
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

Well, I never hooked up a 1 kW linear amp to my 5 W CB radio to talk to South 
America. And woke the neighbors on Sunday morning so they could listen to me on 
their turned-off console radio receiver...

So says
Lazyboy
KDT-8165

On 9/12/2015 12:37 PM, John Allen wrote:

FWIW, 27MHz sounds more like a CB station rather than an “real” Amateur station 
which (IIRC) would be using the 28MHz band – and CB operators (especially in 
some countries! ) may use illegal amps (“boosters”) to raise the transmit power 
beyond the legal limits!


John Allen

W.London, UK

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 12 September 2015 20:00
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

I agree -an amateur could not and would not use a call sign other than his or 
her designated licensed call sign. No blue leader, no quacking duck, nothing 
but respective number licensed to him or her.

 

 

 

 

 

Sent from my Verizon Wireless 4G LTE smartphone

 Original message 

From: "ce-test, qualified testing bv - Gert Gremmen" <g.grem...@cetest.nl> 

Date: 9/12/2015 11:25 AM (GMT-08:00) 

To: EMC-PSTC@LISTSERV.IEEE.ORG 

Subject: Re: [PSES] RF Common Mode Immunity Test Question 

 

A Ham never can be a source of interference, by definition (if they
respect their limits- in more than one way).

To me an amateur is not a HAM, but that is a matter of language I
suppose.



My example showed a (spiced up) example of lack of immunity in a
professional audio installation , that due pragmatic testing, too cables
with average screening properties

and a substantial power output in a "room" with  may-i-say very specific
acoustic properties, lead to an extremely interfering situation.



Gert Gremmen



Van: Ed Price [mailto:edpr...@cox.net] 
Verzonden: zaterdag 12 september 2015 20:09
Aan: ce-test, qualified testing bv - Gert Gremmen
Onderwerp: RE: [PSES] RF Common Mode Immunity Test Question



Gert:



Allow me to fine tune your story for accuracy. In the late 1950's, the
USA FCC re-allocated the 27 MHz region (called 11 meter band) from
amateur use to a new "citizens" band. (I don't know how many other
countries followed that example.) This was created from the existing
amateur 10-meter band, making amateurs rather unhappy. This 11-meter
Citizens Band eventually degenerated into unregulated technical and
operational chaos. If you had a device exhibiting a susceptible response
of a "blue angel calling a red devil" and not something like "WB6WSN
calling..." then the source was not an amateur but an unregulated CB'er.
Please, hams are sensitive about being the assumed source of
interference.



Ed Price
WB6WSN
Chula Vista, CA USA



-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: Saturday, September 12, 2015 10:18 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question



This is a typical standards clause included in a standard by non-emc
"experts".



What  is a metal enclosure, and when is it not enclosure ?

Metalized plastic:  is not metal but might be as good Painted metal:
complies but may have substantial potential difference between parts



If heavy interference exists, 4 braid connection points are not enough,
and inferior braided coax and signal cables is all over the market.



This is an example of economic drive  "fast  cheap & pragmatic testing"

and this  exemption clause

is a recipe for problems in the field.



I remember a customer of mine building PA systems for a church
application ( = 55103-2) Final testing was ok, and the system worked
like a charm.

The first Sunday in real use, the vicar got an unexpected reply on its
questions to the mighty when a local 27 MHz radio amateur switched on
its transmitter and "preached"  : "blue angel calling red devil "







Gert Gremmen

ce-test qualified testing bv





-Oorspronkelijk bericht-

Van: John Woodgate [mailto:j...@jmwa.demon.co.uk 
<mailto:j...@jmwa.demon.co.uk%0b%3cmailto:j...@jmw

Re: [PSES] RF Common Mode Immunity Test Question

[John Allen]

Seconded!

 

Anyway, what would one of  your “average” US customers say if, for example, one 
of their sophisticated modern consumer appliances (e.g. a robotic lawnmower/ 
vacuum cleaner/ “internet of things” kitchen appliance / “domestic robot” 
[already almost here!)  – need I go on?) went haywire and ran them/their kids 
over in the garden/house or set fire to the house whilst everyone was in bed 
because their neighbour switched on their perfectly legally EM 
emissions-compliant CB set, TV, washing machine (etc.),  but their own 
equipment was very susceptible to those EM emissions?

 

Sue the perfectly innocent neighbour or else the manufacturer, the distributor 
etc? Maybe, if the first person (people) ever got out of hospital!  Some may 
think I’m exaggerating but the same sort of thing has happened in the past in 
the US and elsewhere. 

 

The responsible approach is like many countries to legally require a reasonable 
level of EM immunity for consumer and industrial products (and the medical and 
some other sectors are even more stringent) – and since so many such countries 
already have the requirements in place, then why does the US government not 
take the “easy path” and introduce similar requirements? (same reasons, I 
suppose, as the opposition to gun-control and so on L).

 

The bean counters might want to rely on their product liability insurance – but 
that only works once or twice and then a company will find it difficult to get 
that anymore, and the resulting publicity can be horrendous.

 

Prevention is better than punishment!

 

Not politics on my part, just what I consider to be ethical common sense.

 

John Allen

W.London, UK

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: 14 September 2015 17:10
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

Dennis:

 

The rationale that you don’t need consumer electronics with a modicum of 
immunity works only for you, because you are what I would call an expert 
customer. You have the knowledge to ameliorate immunity problems, but most of 
the population does not have this capability.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

From: dward [mailto:dw...@pctestlab.com] 
Sent: Monday, September 14, 2015 8:20 AM
To: 'Ed Price'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] RF Common Mode Immunity Test Question

 

I for one would never want the US to get into this arena.  Too much regulation 
in the US as it is.  Don’t need more and don’t want more.  I’ll decide what is 
best for me, not the government.

 

 

​

Dennis Ward

This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
it from your computer system.  Usage of PCTEST email addresses for non-business 
related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: Saturday, September 12, 2015 1:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

John:

 

Unfortunately, American consumer electronics has no E-field immunity 
requirement. The only help a consumer gets is that little paragraph of legalese 
that advises you to re-orient your device and move further away from emitters. 
OTOH, most consumer equipment design which takes emission compliance into 
account will also yield reasonable immunity levels. My personal experience 
indicates that most immunity problems with consumer electronics is not a design 
problem but a reliability problem. As an example, last year a friend asked me 
to repair his semi-pro mixer board (used in a church environment); he had 
problems “everywhere” with distortion, low gain and external RF susceptibility. 
However, the mixer board was fine; it was his patch cords that were horribly 
abused and leaky.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Saturday, September 12, 2015 11:47 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

In message < <mailto:FCA549BE3ECF9D4CB8CB8576837EA48920AF42@ZEUS.cetest.local> 
FCA549BE3ECF9D4CB8CB8576837EA48920AF42@ZEUS.cetest.local>,

dated Sat, 12 Sep 2015, "ce-test, qualified testing bv - Gert Gremmen" 

< <mailto:g.grem...@cetest.nl> g.grem...@cetest.nl> writes:

 

>A Ham never can be a source of interference, by definition (if they 

>respect their limits- in more than one way).

 

It is clearly not tr

Re: [PSES] RF Common Mode Immunity Test Question

[John Allen]

Ravinder

 

W.r.t. your 2nd para, the 1st  sentence is roughly what I said in an earlier
post - but the 2nd sentence could be a misleading assumption because of what
you said in the 1st para (and what I also said in my earlier post about bean
counting for the US market!) L

 

John Allen

W.London, UK

 

-Original Message-
From: Ravinder Ajmani [mailto:ravinder.ajm...@hgst.com] 
Sent: 15 September 2015 18:51
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

Pardon my skepticism, but I have very little faith on the US industries
self-enforcing any kind of regulations.  When Wall Street analysts expect
public companies to show higher profits quarter after quarter, lowering the
cost becomes the key driver.

 

However most US companies ship their products overseas, and almost all of
these countries have some form of immunity requirements, similar to the EU
regulations.  Hence one can assume that the products built in US are
designed to meet these requirements. 

 

The sad thing is that in until the eighties US was leading the world on EMC
requirements, but now has fallen behind.

 

My personal view.

 

Regards

 

Ravinder Ajmani

HGST, a Western Digital company

 <mailto:ravinder.ajm...@hgst.com> ravinder.ajm...@hgst.com

 

 

5601 Great Oaks Parkway

San Jose, CA 95119

 <http://www.hgst.com> www.hgst.com

 

-Original Message-

From: Gary McInturff [ <mailto:gary.mcintu...@esterline.com>
mailto:gary.mcintu...@esterline.com]

Sent: Tuesday, September 15, 2015 9:16 AM

To:  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

Well not really John - ANSI has no regulatory authority but money does. A
business isn't likely to simply add either NRE cost or cost per unit without
justification - poor product performance, competitive advantage, regulation.
Poor performance isn't even a clean definition - if I have one failure out
of 10,000 because of ESD for example - just ship them another one etc.

 

My personal opinion is that proper operation in the field is as important as
any other functional specification but whether it's done through
self-enforcement or governmental regulation is a thorny question.

 

-Original Message-

From: John Woodgate [ <mailto:j...@jmwa.demon.co.uk>
mailto:j...@jmwa.demon.co.uk]

Sent: Monday, September 14, 2015 11:38 PM

To:  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

In message < <mailto:009601d0ef5d$3dc51eb0$b94f5c10$@cox.net>
009601d0ef5d$3dc51eb0$b94f5c10$@cox.net>, dated Mon, 14 Sep 2015, Ed Price <
<mailto:edpr...@cox.net> edpr...@cox.net> writes:

 

>True, the FCC is essentially still following the Communications Act of

>1934 in its scope. However, telegraph rates aren?t so important 

>anymore, while the issue of consumer electronics immunity certainly is.

>We expect our laws and regulations to evolve to address the important 

>issues of the day, junking the obsolete and helping with new conflicts.

 

It is interesting that the US (ANSI) participates fully in the IEC
committees on immunity, having four experts on each and holding the
Convenership of one.

 

Immunity is for other people, right?just

--

OOO - Own Opinions Only. With best wishes. See
<http://www.jmwa.demon.co.uk> www.jmwa.demon.co.uk When I turn my back on
the sun, it's to look for a rainbow John Woodgate, J M Woodgate and
Associates, Rayleigh, Essex UK

 

-



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1iAx-glaOgP

Re: [PSES] RF Common Mode Immunity Test Question

[John Allen]

I think it's also interesting and significant that many industries - and
certainly many sections of the telecomms and IT industries - have to specify
their own immunity requirements to ensure that the kit will work correctly
in the end-use environments, but that probably leads to
duplications/variations in those requirements (as is also true in the
various regional/national Defence EMC requirements - but even that is slowly
changing towards common requirements throughout NATO) , and is something
which I find quite astonishing for such a large and technologically-advanced
country. 

 

That in turn probably leads to higher overall costs, whereas, were there to
be common mandatory requirements, then fewer tests would be required i.e.
"one size fits all" as is pretty much the case in the EU and other regions
with common technical requirements - OTOH, maybe this is a crafty "hidden
barrier to trade" which does not break the WTO rules and helps knowledgeable
US manufacturers in their own backyards!

 

John Allen

W.London, UK

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: 15 September 2015 03:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

Gary:

 

True, the FCC is essentially still following the Communications Act of 1934
in its scope. However, telegraph rates aren't so important anymore, while
the issue of consumer electronics immunity certainly is. We expect our laws
and regulations to evolve to address the important issues of the day,
junking the obsolete and helping with new conflicts.

 

Immunity problems may manifest themselves as product quality issues (fitness
for use, truth in advertising) or safety issues (inadvertant activation,
erratic reliability, failure to respond), so maybe the FCC shouldn't be the
lead agency. OTOH, immunity control is technically so closely related with
established FCC emission regulations (and our industry that helps enforce
them) that I don't see it making any sense to get another authority
involved. Agency cooperation isn't unheard of; for example, the FCC and FAA
share requirements for radio tower marking, lighting and location.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

-Original Message-
From: Gary McInturff [mailto:gary.mcintu...@esterline.com] 
Sent: Monday, September 14, 2015 11:30 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

IMO - The FCC was commissioned with protecting the public airways only - a
far different scenario than in the EU. As such they worry about emissions
coming from any unintentional or intentional radiator that would be
detrimental to the public airways recivers or transmitting equipment. They
were never set up or intended to protect the general public - even the CB
and Ham radio stuff was to protect the public communications and not our
neighbors TV. Although proper design, frequency allocation and usage would
cut down on that type of interference. They do mention immunity but only in
so much as to let you know that properly operating public communications
equipment could cause problems - and the consumer should deal with it
because the FCC has no authority to mandate it for non- public
telecommunications equipment. 

 

Whether it should be granted that power or not is the discussion of the
minute I suppose.

 

 

-Original Message-

From: John Woodgate [ <mailto:j...@jmwa.demon.co.uk>
mailto:j...@jmwa.demon.co.uk]

Sent: Monday, September 14, 2015 10:45 AM

To:  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] RF Common Mode Immunity Test Question

 

In message

<sn1pr12mb07357121e3850ada9346ec6380...@sn1pr12mb0735.namprd12.prod.outlo

ok.com>, dated Mon, 14 Sep 2015, Rodney Davis <
<mailto:rodney.da...@mitel.com> rodney.da...@mitel.com>

writes:

 

>Hi guys, in simple English.. the  FCC does state in section

>15.17 Susceptibility to interference..., you are responsible for 

>reducing the susceptibility for receiving harmful interference.

 

Who is 'you', and how does anyone know what level of immunity is 'enough'
without immunity standards?

--

OOO - Own Opinions Only. With best wishes. See
<http://www.jmwa.demon.co.uk> www.jmwa.demon.co.uk When I turn my back on
the sun, it's to look for a rainbow John Woodgate, J M Woodgate and
Associates, Rayleigh, Essex UK

 

-


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

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Website: http://www.ieee-ps

Re: [PSES] UL CSDS website

[John Allen]

been on and off ul.com and my home all day, no issues.





From: Nyffenegger, Dave 
Sent: Wednesday, September 16, 2015 1:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UL CSDS website


Are you referring to UL.com (MyHome @UL)?  What sort of trouble?  I tried to 
log in yesterday from my Win 7 machine and it kept giving me Authentication 
errors.  I then tried to log in from my WIN XP VM with the some login ID and 
password and have no problem.  Same thing today.  Go figure.



If you're referring to the UL SCCL website, ulstandards.com, I'm not having any 
issues logging into that one.  And no problem accessing the online 
certifications dir either.



-Dave





From: McDiarmid, Ralph [mailto:ralph.mcdiar...@schneider-electric.com]
Sent: Wednesday, September 16, 2015 1:45 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UL CSDS website



Anyone having trouble logging into that site today?
___

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

-


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Re: [PSES] Getting 2 emails for many posts on the forum - is it just me?

[John Allen]

PS: just noticed that the 1st post is addressed to "John Allen
<john_e_al...@blueyonder.co.uk>; EMC-PSTC@LISTSERV.IEEE.ORG" whereas the 2nd
is just to "EMC-PSTC@LISTSERV.IEEE.ORG"

-Original Message-
From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 14 September 2015 19:23
To: 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: Getting 2 emails for many posts on the forum - is it just me?

Evening

I started noticing this happening a few days ago, and it has been consistent
all today for posts from US contributors, but there seems to be about a 2
minute gap between the 1st post and the 2nd post  - but that does not seem
to be happening from UK/European contributors, where I am getting only 1
post.

Anyone have any idea why?

John Allen
W.London, UK

-

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[PSES] Getting 2 emails for many posts on the forum - is it just me?

[John Allen]

Evening

I started noticing this happening a few days ago, and it has been consistent
all today for posts from US contributors, but there seems to be about a 2
minute gap between the 1st post and the 2nd post  - but that does not seem
to be happening from UK/European contributors, where I am getting only 1
post.

Anyone have any idea why?

John Allen
W.London, UK

-

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:
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Re: [PSES] EN55032 definition of residential environment

[John Allen]

Rich

 

Might that be a result of a classic case of the FCC/IC position of
specifying emissions but not immunity limits (presumably the Yachtboy is/was
aimed at the European market which does have immunity requirements?

 

John Allen

W.London, UK

 

From: Richard Nute [mailto:ri...@ieee.org] 
Sent: 08 December 2015 20:23
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN55032 definition of residential environment

 

 

 

Hmm.

 

“The Class B requirements are intended to offer adequate protection to
broadcast services within the residential environment.”

 

I live about ¼ mile from 8 transmitter TV, FM, etc., towers.  Only the best
of radios, e.g., Grundig Yachtboy, can properly tune both AM and FM, but the
digital TVs are unaffected (as near as I can tell).

 

What about protection of my radios from the broadcast services?  J  

 

 

Rich

 

 

 

 

From: Ronald Pickard [mailto:ronald.pick...@compoundphotonics.com] 
Sent: Tuesday, December 08, 2015 11:32 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN55032 definition of residential environment

 

Hi Ian,

The “residential” environment is generally understood to be the
household/domestic environments where humans typically “reside”. With that
said and further into EN 55032 clause 4, there is a subtle and a bit of a
loose Class B definition: “The Class B requirements are intended to offer
adequate protection to broadcast services within the residential
environment.” Such residential broadcast services would typically include
radio and television for personal consumption, and possibly including Wi-Fi
now-a days. And, I’m not sure what “adequate protection” actually means in
this case, but given Ghery’s statement below, I doubt that it will get any
more definitive.

 

Best regards,

 

Ron Pickard
Regulatory Compliance Engineer
Compound Photonics 
D | +1 (602) 883-8039

 

From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: Tuesday, December 08, 2015 12:00 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN55032 definition of residential environment

 

Disclaimer – While I am the Vice Chairman of CISPR I, the following is my
personal opinion and does not necessarily reflect the opinions of the
Chairman or other members of CISPR I, its working groups, national
committees or IEC HQ.

 

That said…

 

I don’t recall seeing Gert at CISPR I meetings, nor CISPR I WG2 (emissions)
or CISPR I WG4 (immunity) meetings (he isn’t a member of either WG).  If he
were present, he would know that the reason such regulatory statements are
not in CISPR standards such as CISPR 22, 24 or 32 is that CISPR standards
may not contain regulatory statements.  Defining which products must meet
Class A or Class B limits is up to regulators.  There as even been
discussion about the “legality” of the Class A warning label in CISPR 22 and
32.  CISPR 32 does have language that gives guidance to help the user of the
standard properly apply it, but a regulator is free to ignore or change this
at their discretion.  So, to say that CISPR I has been “notorious” is a bit
of a stretch, in my opinion.

 

There has been no serious work done to have two different immunity levels in
CISPR 24 or 35 as it has not been felt to be needed.  Join your national
committee (or contact it) and make a proposal if you feel that such
additional test levels would be warranted.  A persuasive argument would be
given a fair hearing.  Be aware that any new requirements will take years to
incorporate into a standard.  Remember, CISPR I has been trying to get CISPR
35 published for nearly 15 years as it is, but feel free to make a proposal
for an amendment to add different test levels for Class A products.  Just
remember, we’ve gotten along well with single limits in CISPR 24 since it
was originally published in 1997, so a convincing argument will be needed.

 

Ghery S. Pettit

Vice Chairman, CISPR SC I

 

From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: Tuesday, December 08, 2015 9:55 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN55032 definition of residential environment

 

1.

Independent of the standards, the EMC directive requires marking on
typeplate and/or documentation if an equipment is non-residential.

 

2.

Unwilling standards committees have been “reluctant” in including  the
definitions in written in their standards. 

CISPR I has been notorious in these for years, by not even defining Class A
for immunity (CISPR 24).

There are ample standards and EC documents giving an appropriate
definitions, in general something

like:

 

If it is predominantly used for households or is connected to a
residentially used power newtwork

the equipment will be residential or often said “Class B”. 

If connected to a private power network then it should be Industrial or
“Class A”.

 

One standard that comes to mind that gives a good description including
examples is EN 61326-1:2013.

An EC document TC210/Sec0515/INF from 2007

Re: [PSES] EN55032 definition of residential environment

[John Allen]

Oh, and one other thing, I sometimes ponder is whether some of the immunity
withstand limits (especially for radiated and conducted RF) for Class B
equipment are higher enough for the "modern world" ,because:

-  Modern dwellings, especially in Europe and the Far East, are much
smaller and more closely crowded together than they were 30-40 years ago,
and so emission/immunity limits based on 10m  (33 ft!) distances are now
often totally unrealistic (many people live in dwellings where 10m is the
distance to the next but one dwelling - not the next)!

-  There are vastly larger numbers of electronic products in many
urban environments than there were then, and thus the cumulative electronic
noise levels must be much higher now than then;

-  The frequency spectra of those devices is much wider now (all the
way up to 5GHz+ - and rising!) than it was then!

 

"Informed" opinions on the above would be interesting!

John  Allen

W.London, UK

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 08 December 2015 22:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN55032 definition of residential environment

 

On the issue of the "residential" environment, I think that whole issue is
now becoming very blurred in reality with the (at least in the UK) trend to
using former industrial buildings for residential use - as well as the more
general diffusion of the physical barriers between residential and
industrial premises, because what can now really be defined as one or the
other now that businesses are being located in what would generally be
considered as "residential locations" (at least in the "developed"
countries)?

 

Personally, I think that only equipment specifically intended for "totally
heavy industrial machinery/installations" should be Class A - and
"everything else" should be Class B.

 

John Allen

W.London, UK

 

From: Ronald Pickard [mailto:ronald.pick...@compoundphotonics.com] 
Sent: 08 December 2015 19:32
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN55032 definition of residential environment

 

Hi Ian,

The "residential" environment is generally understood to be the
household/domestic environments where humans typically "reside". With that
said and further into EN 55032 clause 4, there is a subtle and a bit of a
loose Class B definition: "The Class B requirements are intended to offer
adequate protection to broadcast services within the residential
environment." Such residential broadcast services would typically include
radio and television for personal consumption, and possibly including Wi-Fi
now-a days. And, I'm not sure what "adequate protection" actually means in
this case, but given Ghery's statement below, I doubt that it will get any
more definitive.

 

Best regards,

 

Ron Pickard
Regulatory Compliance Engineer
Compound Photonics 
D | +1 (602) 883-8039

 

From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: Tuesday, December 08, 2015 12:00 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN55032 definition of residential environment

 

Disclaimer - While I am the Vice Chairman of CISPR I, the following is my
personal opinion and does not necessarily reflect the opinions of the
Chairman or other members of CISPR I, its working groups, national
committees or IEC HQ.

 

That said.

 

I don't recall seeing Gert at CISPR I meetings, nor CISPR I WG2 (emissions)
or CISPR I WG4 (immunity) meetings (he isn't a member of either WG).  If he
were present, he would know that the reason such regulatory statements are
not in CISPR standards such as CISPR 22, 24 or 32 is that CISPR standards
may not contain regulatory statements.  Defining which products must meet
Class A or Class B limits is up to regulators.  There as even been
discussion about the "legality" of the Class A warning label in CISPR 22 and
32.  CISPR 32 does have language that gives guidance to help the user of the
standard properly apply it, but a regulator is free to ignore or change this
at their discretion.  So, to say that CISPR I has been "notorious" is a bit
of a stretch, in my opinion.

 

There has been no serious work done to have two different immunity levels in
CISPR 24 or 35 as it has not been felt to be needed.  Join your national
committee (or contact it) and make a proposal if you feel that such
additional test levels would be warranted.  A persuasive argument would be
given a fair hearing.  Be aware that any new requirements will take years to
incorporate into a standard.  Remember, CISPR I has been trying to get CISPR
35 published for nearly 15 years as it is, but feel free to make a proposal
for an amendment to add different test levels for Class A products.  Just
remember, we've gotten along well with single limits in CISPR 24 since it
was originally published in 1997, so a convincing argument will be needed.

 

Gh

Re: [PSES] EN55032 definition of residential environment

[John Allen]

On the issue of the "residential" environment, I think that whole issue is
now becoming very blurred in reality with the (at least in the UK) trend to
using former industrial buildings for residential use - as well as the more
general diffusion of the physical barriers between residential and
industrial premises, because what can now really be defined as one or the
other now that businesses are being located in what would generally be
considered as "residential locations" (at least in the "developed"
countries)?

 

Personally, I think that only equipment specifically intended for "totally
heavy industrial machinery/installations" should be Class A - and
"everything else" should be Class B.

 

John Allen

W.London, UK

 

From: Ronald Pickard [mailto:ronald.pick...@compoundphotonics.com] 
Sent: 08 December 2015 19:32
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN55032 definition of residential environment

 

Hi Ian,

The "residential" environment is generally understood to be the
household/domestic environments where humans typically "reside". With that
said and further into EN 55032 clause 4, there is a subtle and a bit of a
loose Class B definition: "The Class B requirements are intended to offer
adequate protection to broadcast services within the residential
environment." Such residential broadcast services would typically include
radio and television for personal consumption, and possibly including Wi-Fi
now-a days. And, I'm not sure what "adequate protection" actually means in
this case, but given Ghery's statement below, I doubt that it will get any
more definitive.

 

Best regards,

 

Ron Pickard
Regulatory Compliance Engineer
Compound Photonics 
D | +1 (602) 883-8039

 

From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: Tuesday, December 08, 2015 12:00 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN55032 definition of residential environment

 

Disclaimer - While I am the Vice Chairman of CISPR I, the following is my
personal opinion and does not necessarily reflect the opinions of the
Chairman or other members of CISPR I, its working groups, national
committees or IEC HQ.

 

That said.

 

I don't recall seeing Gert at CISPR I meetings, nor CISPR I WG2 (emissions)
or CISPR I WG4 (immunity) meetings (he isn't a member of either WG).  If he
were present, he would know that the reason such regulatory statements are
not in CISPR standards such as CISPR 22, 24 or 32 is that CISPR standards
may not contain regulatory statements.  Defining which products must meet
Class A or Class B limits is up to regulators.  There as even been
discussion about the "legality" of the Class A warning label in CISPR 22 and
32.  CISPR 32 does have language that gives guidance to help the user of the
standard properly apply it, but a regulator is free to ignore or change this
at their discretion.  So, to say that CISPR I has been "notorious" is a bit
of a stretch, in my opinion.

 

There has been no serious work done to have two different immunity levels in
CISPR 24 or 35 as it has not been felt to be needed.  Join your national
committee (or contact it) and make a proposal if you feel that such
additional test levels would be warranted.  A persuasive argument would be
given a fair hearing.  Be aware that any new requirements will take years to
incorporate into a standard.  Remember, CISPR I has been trying to get CISPR
35 published for nearly 15 years as it is, but feel free to make a proposal
for an amendment to add different test levels for Class A products.  Just
remember, we've gotten along well with single limits in CISPR 24 since it
was originally published in 1997, so a convincing argument will be needed.

 

Ghery S. Pettit

Vice Chairman, CISPR SC I

 

From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: Tuesday, December 08, 2015 9:55 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN55032 definition of residential environment

 

1.

Independent of the standards, the EMC directive requires marking on
typeplate and/or documentation if an equipment is non-residential.

 

2.

Unwilling standards committees have been "reluctant" in including  the
definitions in written in their standards. 

CISPR I has been notorious in these for years, by not even defining Class A
for immunity (CISPR 24).

There are ample standards and EC documents giving an appropriate
definitions, in general something

like:

 

If it is predominantly used for households or is connected to a
residentially used power newtwork

the equipment will be residential or often said "Class B". 

If connected to a private power network then it should be Industrial or
"Class A".

 

One standard that comes to mind that gives a good description including
examples is EN 61326-1:2013.

An EC document TC210/Sec0515/INF from 2007 addresses the topi

Re: [PSES] EN55032 definition of residential environment

[John Allen]

Gert 

 

>From my perspective, most of what you say below supports the position that
only equipment specifically intended for "totally heavy industrial
machinery/installations" should be Class A - and "everything else" should be
Class B.

 

Just a great pity that most of the regulators (across the World?) don't seem
agree with, or even understand, that approach, and thus get swayed by the
industry interest groups that you allude to below L.

 

"Industry" will often do the very least that it can get away with in order
to market their products, and that's why - in reality - Brian Kunde's
comments about many companies doing more than is required is only - at best
- partially true as a large proportion of them just plain don't.

 

I suspect that some are large organisations, even though most are probably
SMEs which simply don't have the financial leeway to do more than is legally
necessary (even if they would want to) in order to compete with the large
ones - therefore it must be up to the regulators to tighten the regulations
appropriately.

 

BTW, as for the medical installation to which you refer below, if that is in
the EU (which I assume that it is) then 2004/108/EC, and thereafter, require
installation owners to do appropriate EMC assessments, or to get appropriate
EMC "experts" to do those assessments if they themselves don't have the
relevant expertise - and the forthcoming presence of Class A ITE in a
"sensitive" installation should then have rang "alarm bells" even before it
was operated. Therefore the hospital management failed to meet their legal
EMCD requirements, as well as a failure of a general duty-of-care to their
patients!

 

John Allen

W.London, UK

 

 

 

From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: 09 December 2015 18:50
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN55032 definition of residential environment

 

Hi Ghery, (and all other members of this group)

 

I do not think that one needs to be member of CISPR I WG2 or WG4 in any form
to be able to discuss this topic.

Ample documentation is available within the national committees, to get a
clear image of the discussions in CISPR I

and several of my close EMC friends have been participating.

 

A simple division in Classes A and B (or Industrial versus residential or
Domestic) cannot be seen as a regulatory statement. Division in classes is a
common thing within all standards and has nothing to do with regulatory
aspects. Different  test levels are defined for  different types of
equipment taking in consideration their targeted environment (being not
industrial or residential) . 

 

The European Commission's opinion on this subject is clear. EN standards
should create a separate set of limits for 2 classes

as described. The infamous Class A statement in CISPR22 actually encourages
manufacturers to test and mark their products to industrial test levels and
market them in residential environments. That actually is a regulatory
aspect IMHO, as it overrules the requirements from the EC and the mandates
given to CENELEC in creating harmonized standards. 

 

This unlevel playing field  creates a tremendous amount of extra work for
manufacturers that integrate ITE OEM product in for example  (most)  medical
equipment, or radio equipment or laboratory equipment, that do not allow or
for any Class A emissions.

Just Integrate a touchscreen in a lab equipment and you will see what I
mean. Many industrial sectors this way pay for the profits of the
IT-industry that successfully "lobbied" their way into the IT standard. (not
that lobby is illegal of course, it's just a way of defending ones industry
sector)

 

So this is how it happens that I (it actually happened) encounter 30 inch EN
55022 Class A LCD monitor in a local university hospital surgeons room that
was intentionally shielded to allow  sensitive correlation type of  ECG
equipment to function correctly. Well , it did interfere. (I also found a
100 mW Wi-Fi transceiver on the ceiling, but the frequency of that carrier
is simply too high to interfere with the ECG stuff) . It makes very clear
how unaware even (medical electronics) professionals  are when it comes to
the risks of EMC.

This is why we have the EMCD, why we have CISPR and EMC standards, to
recognise that EMC is not like dust, one cannot see when it's dirty.

 

 

Gert Gremmen

ce-test, qualified testing bv

 

 

Van: Ghery S. Pettit [mailto:n6...@comcast.net] 
Verzonden: dinsdag 8 december 2015 20:00
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] EN55032 definition of residential environment

 

Disclaimer - While I am the Vice Chairman of CISPR I, the following is my
personal opinion and does not necessarily reflect the opinions of the
Chairman or other members of CISPR I, its working groups, national
committees or IEC HQ.

 

That said.

 

I don't recall seeing Gert at CISPR I

Re: [PSES] Outdoor Bluetooth speakers

[John Allen]

Charlie

 

That would be my reaction as well - which is why I would expect AV
specialists to question its application to their kit, and why the 62368-1
Scope needs clarification.

 

John Allen

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 22 December 2015 17:58
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Outdoor Bluetooth speakers

 

I think EN 60905-22 is overkill for occasional use outdoors.

 

1 Scope

1.1 Equipment covered

This part of IEC 60950 applies to information technology equipment intended
to be installed in an OUTDOOR LOCATION.

 

The requirements for OUTDOOR EQUIPMENT also apply, where relevant, to empty
OUTDOOR ENCLOSURES supplied for housing information technology equipment to
be installed in an OUTDOOR LOCATION

 

3 Terms and definitions

For the purposes of this document, the terms and definitions given in IEC
60950-1 and the following apply.

3.1

OUTDOOR LOCATION

location for equipment where protection from the weather and other outdoor
influences provided by a building or other structure is limited or
non-existent

3.2

OUTDOOR EQUIPMENT 

equipment specified by the manufacturer to be installed where exposed wholly
or partly to the conditions in an OUTDOOR LOCATION

 

The product is designed to be used indoors, with occasional, portable, use
outdoors, then 60950-22 is not appropriate.

 

That said, you may want to make the equipment splash/drip proof, but that
would be more for functional / customer experience.

 

Regards

Charlie

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 22 December 2015 17:34
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Outdoor Bluetooth speakers

 

Good evening

 

I had the same idea as Ken re 60950-22 - and then got to thinking about
62368-1 which is replacing both 60065 & 60950, and the likelihood of  a
"Part XX" to that standard.?

 

Did a quick search on "62368 outdoor equipment" and no "Part XX" was flagged
up, but amongst the results was a link to this CSA page
http://shop.csa.ca/en/canada/it-telecom-and-audio-video-equipment/cancsa-c22
2-no-62368-1-14-/invt/27033302014

 

About 2/3rds of the way down that page it states the following:

 

"Additional requirements for information and communication technology
equipment intended for outdoor installation are given in CSA/UL 60950-22.
Additional requirements for audio/video equipment intended for outdoor
installation are given in the relevant requirements in CAN/CSA C22.2 No.
60065 or UL 60065." - so N.America is certainly "covered".

 

Presumably, however, the IEC Committees will (or should be!) working on a
suitable "Part XX" to 62368 - so does anyone have leads on that?

 

John Allen

W.London, UK

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 22 December 2015 17:13
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Outdoor Bluetooth speakers

 

Hi Ken,

 

Thanks for your suggestion on 60950-22.  I did not know or have this
standard but had some search on internet and note that the standard is for
equipment intended for outdoors.  I doubt it is too tough for my said
equipment.  That is reason why I believe there may be different levels for
outdoor use equipment.

 

Regards,

 

Scott

 

 

On 23 Dec, 2015, at 12:40 am, IBM Ken <ibm...@gmail.com> wrote:

 

Hi Scott, I don't have any experience in this area but have you looked at
60950-22?

 

On Tue, Dec 22, 2015 at 11:21 AM, Scott Xe <scott...@gmail.com> wrote:

It is my first time to test an audio product for outdoor use.  The product
is powered by rechargeable lithium batteries and primarily used indoors but
can be used occasionally for outdoor picnics and/or parties.  Traditionally,
we use EN 60065 for safety evaluation.  Is there any specific safety
standard covering the said operating conditions?  For outdoor use product,
are there any defined levels of outdoor condition as this is not a product
to be used outdoor permanently?

Thanks and regards,

Scott

-

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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For policy questions, send mail to:
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Re: [PSES] Outdoor Bluetooth speakers

[John Allen]

Good evening

 

I had the same idea as Ken re 60950-22 - and then got to thinking about
62368-1 which is replacing both 60065 & 60950, and the likelihood of  a
"Part XX" to that standard.?

 

Did a quick search on "62368 outdoor equipment" and no "Part XX" was flagged
up, but amongst the results was a link to this CSA page
http://shop.csa.ca/en/canada/it-telecom-and-audio-video-equipment/cancsa-c22
2-no-62368-1-14-/invt/27033302014

 

About 2/3rds of the way down that page it states the following:

 

"Additional requirements for information and communication technology
equipment intended for outdoor installation are given in CSA/UL 60950-22.
Additional requirements for audio/video equipment intended for outdoor
installation are given in the relevant requirements in CAN/CSA C22.2 No.
60065 or UL 60065." - so N.America is certainly "covered".

 

Presumably, however, the IEC Committees will (or should be!) working on a
suitable "Part XX" to 62368 - so does anyone have leads on that?

 

John Allen

W.London, UK

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 22 December 2015 17:13
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Outdoor Bluetooth speakers

 

Hi Ken,

 

Thanks for your suggestion on 60950-22.  I did not know or have this
standard but had some search on internet and note that the standard is for
equipment intended for outdoors.  I doubt it is too tough for my said
equipment.  That is reason why I believe there may be different levels for
outdoor use equipment.

 

Regards,

 

Scott

 

 

On 23 Dec, 2015, at 12:40 am, IBM Ken <ibm...@gmail.com> wrote:

 

Hi Scott, I don't have any experience in this area but have you looked at
60950-22?

 

On Tue, Dec 22, 2015 at 11:21 AM, Scott Xe <scott...@gmail.com> wrote:

It is my first time to test an audio product for outdoor use.  The product
is powered by rechargeable lithium batteries and primarily used indoors but
can be used occasionally for outdoor picnics and/or parties.  Traditionally,
we use EN 60065 for safety evaluation.  Is there any specific safety
standard covering the said operating conditions?  For outdoor use product,
are there any defined levels of outdoor condition as this is not a product
to be used outdoor permanently?

Thanks and regards,

Scott

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Re: [PSES] 3 phase 408V in EU and Emissions Classification

[John Allen]

The answer regarding 408V - which is a N.American standard voltage ) - is
"possible but doubtful" on any predictable basis because the defined voltage
is 2301Ph / 400V 3Ph with a  tolerance of +/-10%,  and has been for decades,
but the actual voltage will vary from country to country - so the UK is
generally on the high side of the 230/400V numbers for historical reasons
(we were 240/415) but most of the other EU countries were 220/380 and so
they may well be on the low side,

 

EU public mains supply voltage characteristics are defined in EN 50160: 2010
- and there is more detail in the "Application guide to the European
Standard EN 50160 on voltage  characteristics of Electricity supplied by
public distribution systems" issued by EUROELECTRIC - the Union of the
Electricity Industry (doc no 23002Ren9530).


Regards

 

John Allen

W.London, UK

(PS: whilst not part of the regulatory setup, I wrote and revised BSI's
Guide to Voltages across the World and have kept an eye of the subject ever
since J.)

 

-Original Message-
From: Carl Newton [mailto:emcl...@gmail.com] 
Sent: 19 November 2015 15:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 3 phase 408V in EU and Emissions Classification

 

Group,

 

Please forgive my ignorance, but I would appreciate some education
concerning 3 phase power in the EU generally.  I'm looking at a water
handling system that is to employ 408 V ac, 3 phase in the EU.  It would be
used with HVAC systems and I'm told that it can be used in apartment
complexes, among other types.  So I'm being told that for that reason it may
be attached to the public AC mains, which means that it should be Class B.

 

Can somebody here explain whether any of the various EU nations can provide
408 3 phase from the public AC mains?  Or am I looking at a Class A device?

 

Same for Australia.

 

Thanks very much,

 

Carl

 

--

 

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Re: [PSES] 3 phase 408V in EU and Emissions Classification

[John Allen]

I fully agree with Doug on the need for Class B compliance (certainly on 
emissions) because the use of “industrial” equipment (especially motorised) in 
residential and “light commercial” premises can be a notably source of 
interference to equipment in surrounding rooms as most of that will be Class B 
immunity, and thus quite a bit more susceptible than any Class A immunity stuff 
 – electrically powered lifts have been highlighted as a notable source of such 
interference in these locations, and any water-handling system  could be just 
as bad/worse because of its more distributed nature throughout a building.

 

John Allen

W.London, UK

 

From: Doug Nix [mailto:d...@ieee.org] 
Sent: 19 November 2015 16:28
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 3 phase 408V in EU and Emissions Classification

 

Carl,

 

An apartment complex is a shared low-voltage distribution network, and would be 
viewed as Class B.

 

The concern is that conducted emissions from one user will affect equipment in 
another user’s premises, since there is no attenuation by the substation 
equipment and the intervening MV distribution network as would occur between 
two large factories, for example.

 

So your gear will definitely need to meet Class B limits, or only be installed 
by special permission of the local authority having jurisdiction.

 

Doug Nix
d...@ieee.org
+1 (519) 729-5704

 

On 19-Nov-15, at 11:24, Carl Newton <emcl...@gmail.com> wrote:

 

Doug,

 

Excellent response.  So if I'm understanding you correctly, the 408 V ac 
supplied to an apartment complex can be via the low-voltage public AC mains. 

 

Thanks very much,

 

Carl

 

On Thu, 19 Nov 2015 11:13:00 -0500, Douglas Nix <d...@mac.com> wrote:





Carl,

 

Standard AC mains voltage in the EU is 400V +10%, -5%, 3P. This accommodates 
everything from 380 V nominal legacy systems through 440 V nominal legacy 
systems. The same is done for 1P systems: 230V +10%, -5%, so the 408 V nominal 
that your customer is asking for is accommodated within the standard mains 
voltages.

 

None of this has bearing on the EMC Class used for the equipment. The Generic 
EMC Standards, IEC 61000-6-1, -2, -3, -4 deal with the specific emissions and 
immunity requirements for equipment in these classes where no product family 
standard exists. Class A environments are “Industrial”, as defined by the way 
power is supplied to the facility. Class B is “Commercial / Residential”. 
Reading from EN 55011 (CISPR 11):

 

4.2 Division into classes

Class A equipment is equipment suitable for use in

all establishments other than domestic and those

directly connected to a low voltage power supply

network which supplies buildings used for domestic

purposes.

 

Class A equipment shall meet class A limits.

 

NOTE 1 Operation of equipment which does not meet the

class A limits but does not result in unacceptable degradation of

radio services may be sanctioned on a case-by-case basis by the

competent national authority.

 

NOTE 2 Aithough class A limits have been derived for

industrial and commercial establishments, administrations may

allow, with whatever additional measures are necessary, the

installation and use of class A ISM equipment in

a domestic establishment or in an establishment connected

directly to domestic electricity power supplies.

 

Class B equipment is equipment suitable for use in

domestic establishments and in establishments

directly connected to a low voltage power supply

network which supplies buildings used for domestic

purposes.

 

Class B equipment shall meet class B limits.

 

The key words are: “...other than domestic and those directly connected to a 
low voltage power supply network which supplies buildings used for domestic 
purposes.” Industrial establishments have a direct connection to the medium 
voltage transmission grid, i.e. a private substation, that supplies power to 
that establishment only. This is a Class A environment. If the equipment is 
connected to a shared low-voltage network, i.e. where power distribution from a 
single substation occurs at 1 kVac / 1500 Vdc or less, and this distribution 
network supplies a number of independent users, then it is a 
commercial/residential application, therefore a Class B environment.

 

In theory, Class A equipment can be installed in Class B environment by special 
permission of the local authority.





Doug Nix

d...@mac.com
+1 (519) 729-5704

 

On 19-Nov-15, at 10:43, Carl Newton <emcl...@gmail.com> wrote:

 

Group,

Please forgive my ignorance, but I would appreciate some education concerning 3 
phase power in the EU generally.  I'm looking at a water handling system that 
is to employ 408 V ac, 3 phase in the EU.  It would be used with HVAC systems 
and I'm told that it can be used in apartment complexes, among other types.  So 
I'm being told that for that reason it may be attached to the public AC mains, 
which means that it should be Clas

Re: [PSES] For Your Information NRTL Directive Draft and Comment

[John Allen]

Thanks Kevin!!




John Allen | President | Product Safety Consulting, Inc.

Your Outsourced Compliance Department®

http://www.productsafetyinc.com

630-238-0188


From: Kevin Robinson <kevinrobinso...@gmail.com>
Sent: Thursday, June 9, 2016 4:09 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] For Your Information NRTL Directive Draft and Comment

Hello All,

I wanted to advise you that the Draft NRTL Program Directive has been published 
on the OSHA website for public comment.  We encourage you all to review the 
draft directive and to submit any questions, comments, revisions or concerns 
you may have to OSHA.

In previous communications OSHA indicated that the Directive would be published 
in the Federal Register for comments.  Due to some complications in that 
process, and in the interest in sharing the draft Directive with you as soon as 
possible, we will not be publishing the Directive in or seeking comments 
through the Federal Register.

Please submit your comments no later than 11:59pm Eastern Time  Tuesday August 
9, 2016

To submit via email, send comments to 
nrtlprog...@dol.gov<mailto:nrtlprog...@dol.gov?subject=NRTL%20Directive%20Comment>
  Please title your submissions as "NRTL Directive Comment" .

To submit in hard copy, please use the following address:

OSHA
NRTL Program
Office of Technical Programs and Coordination Activities
200 Constitution Avenue NW, Room N3653
Washington, DC 20210

*** Please note, comments sent via U.S. Mail may take an additional ten days to 
be received due to security screening procedures.***

To submit comments via fax, please send comments to 
202-693-1644.


Draft NRTL Directive: 
http://www.osha.gov/dts/otpca/nrtl/nrtl_draftdirective_public_comment.pdf

Additional information, including a list of Frequently Asked Questions may be 
found at: http://www.osha.gov/dts/otpca/nrtl/nrtlnews.html
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[PSES] Multiple Listee for CE

[John Allen]

Hi,


Some may be familiar with Multiple Listee's regarding NRTLs where one company 
gets the Listing/Certification in their name and another company's name.


How would this work for CE?


Company A designs, tests, builds a Technical File and makes Declaration to the 
appropriate Directives.  If company B wants company A to put their name on it 
and company B places the product on the market, do they need their own 
Technical File?  Do they put something in the file from company A that the 
company B's model number is exactly the same as their model?


Thanks,


John




John Allen | President | Product Safety Consulting, Inc.

Your Outsourced Compliance Department®

http://www.productsafetyinc.com

630-238-0188

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Re: [PSES] Multiple Listee for CE

[John Allen]

That works perfectly, thanks!!  I still would want so see company A's Technical 
File.




John Allen | President | Product Safety Consulting, Inc.

Your Outsourced Compliance Department®

http://www.productsafetyinc.com

630-238-0188

[http://www.productsafetyinc.com/assets/product-safety-consulting.png=3]<http://www.productsafetyinc.com/>

Product Safety Consulting
Product Safety Consulting provides product developers and manufacturers with 
expert advice and testing services, so they can secure product safety and
Read more...<http://www.productsafetyinc.com/>




From: Steven Brody <sgbr...@comcast.net>
Sent: Wednesday, May 25, 2016 3:06 PM
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Multiple Listee for CE


·   Company A issues a DoC in their name as the manufacturer and uses the 
company B name and model number they mark the product with.

·   Company B creates their own TCF using the DoC from company A along with 
any additional manuals or instructional information they provide when they sell 
it.

·   Company B issues a DoC as the manufacturer using the model and part 
number that is on the product, and matches the information on the DoC from 
company A.  They will also need to use their own Authorised Representative 
unless A and B agree to use the Company A AR.



That allows for the EU folks to contact B if needed and B in turn contacts A 
for whatever assistance is needed.



Steve Brody

sgbr...@comcast.net



From: John Allen [mailto:jral...@productsafetyinc.com]
Sent: Wednesday, May 25, 2016 3:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Multiple Listee for CE



Hi,



Some may be familiar with Multiple Listee's regarding NRTLs where one company 
gets the Listing/Certification in their name and another company's name.



How would this work for CE?



Company A designs, tests, builds a Technical File and makes Declaration to the 
appropriate Directives.  If company B wants company A to put their name on it 
and company B places the product on the market, do they need their own 
Technical File?  Do they put something in the file from company A that the 
company B's model number is exactly the same as their model?



Thanks,



John







John Allen | President | Product Safety Consulting, Inc.

Your Outsourced Compliance Department®

http://www.productsafetyinc.com

630-238-0188

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[PSES] AMA Warns of Harm from LED Streetlights’ Blue Light

[John Allen]

Just had a routine info email from the ECM Web highlighting an interesting 
American Medical Association (AMA) article on the potential harmful effects of 
LED streetlights - see here:

http://electricalmarketing.com/blog/ama-warns-harm-led-streetlights-blue-light?NL=ECM-07
 

 
=ECM-07_20160622_ECM-07_825=42=article_1_b_rid=CPG0400025478_campaign=8880_medium=email=0cf944f7f4f14ecbb045b2dbb57fc4de

I wonder what the effects could be in the future – and if anyone else, 
anywhere, has already picked up/investigated this subject?


John E Allen

W.London, UK


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Re: [PSES] AMA Warns of Harm from LED Streetlights’ Blue Light

[John Allen]

Brian

About 40yrs ago, I joined a company here where all the overhead lighting was by 
unbaffled fluorescent tubes,- and fairly soon I was having a lot of eyestrain 
problems - only solved for me when I got my first pair of photochromic/ 
"transitions" type lenses. 

We then had the same issue at home much more recently when I fitted the first 
set of halogen lights with the "cool white" or  "daylight" colour temperatures 
(around 4000-6000K colour temperature), and so had to change them for the "warm 
white" sort which is somewhat yellower (lower colour temperature - around 
2700K- 3000K).

I also suffer quite badly in bright sunlight if I wear anything but 
photochromic lenses, and so I'm one of those who is very sensitive in this 
respect, and I think there may be many others like me ) - and thus I am worried 
if this issue becomes more widespread over here.

John E Allen
W.London, UK

-Original Message-
From: Brian O'Connell [mailto:oconne...@tamuracorp.com] 
Sent: 22 June 2016 18:51
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] AMA Warns of Harm from LED Streetlights’ Blue Light

Found the AMA release here:
www.ama-assn.org/ama/pub/news/news/2016/2016-06-14-community-guidance-street-lighting.page

Almost ten years ago, saw an article that AMA says color over 3000 K not good. 
And much external LED stuff seems to be 4000 K or more. Am still waiting for 
data indicating actual disruption of circadian rhythm and/or decreasing visual 
acuity in humans. LED magazine was talking about this over five years past, and 
the IES published this in 2010: 
http://www.ies.org/PDF/PositionStatements/PS-03-10.pdf

Suspect LED implementations will see a period where humans learn to accept a 
new norm. Those that cannot adapt will be submitted to the Klingon High Command 
for disposition. My professional recommendation is to not stare at the street 
lamp. Anecdotally, we had a few complaints about blue hue of new office 
lighting for a few weeks, but all are now happy as a gopher in soft dirt, and 
have become decidedly compliant with all corporate edicts. But most 
importantly, LED lighting, when done correctly, reduces wide-spectrum light 
pollution, so for sake of my desert trips, all must use LEDs.

But, have noted that some of the LED drivers are serious noise problems (both 
RE and CE).

Brian


From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Wednesday, June 22, 2016 10:09 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] AMA Warns of Harm from LED Streetlights’ Blue Light

Just had a routine info email from the ECM Web highlighting an interesting 
American Medical Association (AMA) article on the potential harmful effects of 
LED streetlights - see here:
http://electricalmarketing.com/blog/ama-warns-harm-led-streetlights-blue-light?NL=ECM-07=ECM-07_20160622_ECM-07_825=42=article_1_b_rid=CPG0400025478_campaign=8880_medium=email=0cf944f7f4f14ecbb045b2dbb57fc4de
I wonder what the effects could be in the future – and if anyone else, 
anywhere, has already picked up/investigated this subject?

John E Allen
W.London, UK

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Re: [PSES] FW: [PSES] AMA Warns of Harm from LED Streetlights’ Blue Light

[John Allen]

J!!

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: 22 June 2016 20:13
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] AMA Warns of Harm from LED Streetlights’ Blue 
Light

 

John said: “There have been lots of press reports of medics advising not to use 
computers late at night because the blue light from the display can cause 
insomnia.”

 

Wait, isn’t the monitor being able to keep you awake a positive effect? I mean, 
who among us has never had to delete 856 pages of the letter “c” that you find 
attached to the end of your latest status report?

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

 


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Re: [PSES] AMA Warns of Harm from LED Streetlights’ Blue Light

[John Allen]

Doug

 

Historically, France – of which Monaco is effectively a part for technical 
requirements – used to mandate yellow/amber headlight (we had to fit coloured 
adapters if we went to France at that time) but I think that has now changed.

 

Also, there is another factor to consider – age. As we get older, our eyes lose 
the accommodation to deal with objects at different distances (certainly true 
for me) and we often begin to suffer from eye defects like cataracts,  which 
cause blurred vision, and those factors cause problems in either very high or 
low levels. So, at night, rapidly varying light levels cause (at least me) a 
lot of problems when driving that I never suffered when younger.

 

Finally, different peoples’ eyes vary quite a lot.  I actually have pretty 
reasonable vision in very, very low light levels in which my wife can see 
nothing at all – so my sight sensitivity must be basically quite high, but it 
means I can’t cope with very high levels (be that the Sun or very bright car 
headlights). All these factors make the problems difficult to solve, and 
anything that makes the situation more extreme also makes them even worse.

 

John E Allen

W.London, UK

 

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: 22 June 2016 20:18
To: John Allen
Cc: EMC-PSTC
Subject: Re: [PSES] AMA Warns of Harm from LED Streetlights’ Blue Light

 

John,

​​

I have to wonder about the "blue rich" automotive headlights, for me they are a 
strong irritant and very distracting.  Amazingly, I actually heard some people 
say the blue are better because you can see further at night and in fog.

 

Years ago I once heard that in Morocco, the preferred color for car headlamps 
is amber.  Never did verify if that was true.

 

-Doug

 

 

Douglas E Powell

Laporte, Colorado USA

 <mailto:doug...@gmail.com> doug...@gmail.com

 <http://www.linkedin.com/in/dougp01> http://www.linkedin.com/in/dougp01

 

 

 

On Wed, Jun 22, 2016 at 11:08 AM, John Allen <john_e_al...@blueyonder.co.uk> 
wrote:

Just had a routine info email from the ECM Web highlighting an interesting 
American Medical Association (AMA) article on the potential harmful effects of 
LED streetlights - see here:

http://electricalmarketing.com/blog/ama-warns-harm-led-streetlights-blue-light?NL=ECM-07
 
<http://electricalmarketing.com/blog/ama-warns-harm-led-streetlights-blue-light?NL=ECM-07=ECM-07_20160622_ECM-07_825=42=article_1_b_rid=CPG0400025478_campaign=8880_medium=email=0cf944f7f4f14ecbb045b2dbb57fc4de>
 
=ECM-07_20160622_ECM-07_825=42=article_1_b_rid=CPG0400025478_campaign=8880_medium=email=0cf944f7f4f14ecbb045b2dbb57fc4de

I wonder what the effects could be in the future – and if anyone else, 
anywhere, has already picked up/investigated this subject?


John E Allen

W.London, UK

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-- 

 

Douglas E Powell

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


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Re: [PSES] insulated wires

[John Allen]

Rich

 

Your first para is effectively what I was trying to say (obviously not 
effectively!)  because, as you said, the internal wiring then need only be able 
to cope with the normal-condition current and any overcurrents from internal 
faults (such as a short to ground in Class I equipment) would be prevented by 
the fuse(s) rupturing before there is any damage to the wiring or other 
components.

 

Also, it might be worth reminding folks that single-pole fusing is OK for 
defined-polarity mains supply systems (e.g. the UK, and some N.American 
systems) if it is in the Line/Live/”Hot” conductor, but not in 
undefined-polarity systems as found on the European Continent and many other 
regions/countries – those need double-pole fusing or else there is the risk 
that the unfused lines will have to carry the full mains-supply prospective 
fault current in the event of a similar fault condition with a 
reversed-polarity connection. If the latter configuration can apply, then you 
cannot reduce in the wiring size unless the equipment is Class II Double 
Insulated.

 

All this is outlined in 60950 and other standards.

 

John E Allen

W.London, UK

 

 

From: Richard Nute [mailto:ri...@ieee.org] 
Sent: 23 June 2016 18:47
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] insulated wires

 

 

AFAIK, that requirement does not apply if a correctly fused appliance inlet is 
used  because that should allow smaller gauge wiring from its outlet terminals 
– and that is quite common (or at least it was) for 60950 equipment.

 

Wire rating (in 60950 equipment) is based on normal-condition current, not 
fault-condition current.  (Think conductor size in wall-warts.)

 

Wire rating based on fuse rating would imply that wire ratings would be based 
on fault-condition current.  

 

 

Rich

 

 

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Re: [PSES] insulated wires

[John Allen]

Mike


AFAIK, that requirement does not apply if a correctly fused appliance inlet is 
used  because that should allow smaller gauge wiring from its outlet terminals 
– and that is quite common (or at least it was) for 60950 equipment.

 

Whilst I am here, I would suggest that because the appropriate UL Recognized 
wiring generally meets all the same technical requirements (as far as this 
standard is concerned) that apply for non-US certifications, I would always 
advocate that it is used where the equipment is going to be widely certified 
and sold around the World. It is a GOOD IDEA to use UL-Recognized wiring even 
if you sell mainly outside N.America but eventually want to enter that market, 
as otherwise it would mean re-specing all the wire in the equipment to get 
through the relevant certifications/Listings (unless you want to get involved 
in paying a lot of upfront and on-going fees to the Listing Agency to use 
something else – from bitter personal experience with equipment which was 
“dropped on me”, that is NOT a good idea!)

 

John E Allen

W.London, UK

 

From: Mike Sherman - Original Message - [mailto:msherma...@comcast.net] 
Sent: 23 June 2016 16:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] insulated wires

 

Also be aware that there is a minimum wire gage size for the incoming mains 
wire inside the equipment. 

Sent from Xfinity Connect Mobile App


-- Original Message --

From: Brian Kunde
To: EMC-PSTC@LISTSERV.IEEE.ORG
Sent: June 23, 2016 at 8:49 AM
Subject: Re: [PSES] insulated wires

Try the US National Electric Code table 310-17 for single conductor insulated 
wire in free air at 30ºC ambient (hook up wire). Keep in mind that you have to 
de-rate the values in this chart for bundling (NEC table 310-15-(b)(2)(a)) and 
temperatures (NEC table 690-31(c))above 30ºC.

The Other Brian

-Original Message-
From: Amund Westin [mailto:am...@westin-emission.no]
Sent: Thursday, June 23, 2016 8:46 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] insulated wires

Looking for requirements for single insulated wires (UL, IEC, etc.) used inside 
an IEC60950-1 product (230VAC).
Any tips where I should start looking?

B.regards
Amund

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[PSES] Class 1 Div 1 Small Motor

[John Allen]

Hi,


Does anyone know who has small motors that can pass Class 1 Div 1??


Current motor is 12Vdc, 8Amp


Thanks,


John

jral...@productsafetyinc.com

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Re: [PSES] Is your company doing enough to ensure adequate EMC complain nce?

[John Allen]

I agree w.r.t. to the definitions of the terms “compliance” & “conformity”, but 
Ed’s post does throw me a bit because there are many areas where non-compliance 
would just be totally stupid, e.g. such as driving on the wrong side of the 
road or ignoring traffic light signals – that’s not restraint of trade (but you 
can get terminally bored on long straight roads like US Interstates, so maybe 
that driving on the wrong side on those would “liven things up” and make for 
“more competitive” traffic situations? J ).

 

The same goes for not producing compliant products, but there, I think, the 
European product safety Directives may have the edge over US legislation/NRTL 
standards approach because the former do not demand “strict compliance” with 
Harmonised Standards if you can demonstrate that the products do meet the 
Essential/Particular safety requirements of those Directives, whereas as the US 
approach seems to positively encourage/require strict compliance to the 
relevant stds. Maybe that’s why they might be considered stultifying and/or a 
restraint of trade?

 

John Allen

W.London, UK 

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: 17 January 2016 16:20
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

 

OTOH, I was always uneasy with the term “compliance” because to me, compliance 
is a coercive, one-way street. You are expected to comply, without any 
negotiation; comply or suffer the consequences. You comply, but there is no 
business incentive to excel. This is not a free market, not capitalism as it 
should be. 

 

I’m not saying that Compliance is pure evil, just that over-emphasis on 
compliance can yield stultification, restraint of trade and terminal boredom.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: Saturday, January 16, 2016 10:54 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

 

In generic terms Compliance is indeed nothing more than adherence to a set of 
rules. I once debated legal council at a company who wanted exclusive use of 
the term. I pointed out how this term is used in finance, medical, 
transportation, product safety, EMC and legal circles. Given a bit more time 
I'm certain I could come up with a list nearly as long as your arm. This one 
reason why I personally prefer the term Compliance Engineer. It is unique to 
this business sector. Among my peers, I like to be more specific and mention 
product safety engineer or EMC engineer.  

 

All the best, Doug

 

 

Douglas E Powell

doug...@gmail.com 

‎https://www.linkedin.com/in/dougp01

 

 

‎ 

 

 

 


From: Brian Gregory

Sent: Saturday, January 16, 2016 11:24 PM

To: EMC-PSTC@LISTSERV.IEEE.ORG

Reply To: Brian Gregory

Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

 

 

Ah yes, I recall a conversation with a bright one from Garrad Hassan about a 
mutual customer.  He was establishing their compliance with GH's established 
financial qualifications for an undisclosed analysis.  I picked on the 
distinction rather quickly and had to clarify to him what compliance meant to 
me, representing an NRTL.

 

Colorado Brian 



-- Original Message --
From: Scott Aldous <0220f70c299a-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?
Date: Fri, 15 Jan 2016 10:11:52 -0800

As is made somewhat more clear in this article 
<http://www.fcpablog.com/blog/2015/11/9/sec-we-protect-compliance-officers-except-when-we-prosecute.html>
  (linked to by the original), this has nothing to do with technical product 
compliance but is about securities compliance 
<https://en.wikipedia.org/wiki/Securities_regulation_in_the_United_States> .  

 

Sloppy use of the term "compliance" with no explanation of the specific meaning.

 

Scott (am I the "other" Scott?) just made a similar point... I will post anyway.

 

On Fri, Jan 15, 2016 at 9:52 AM, Brian Gregory <brian_greg...@netzero.net> 
wrote:

 

 If you read the article (and others) it can be read either way.  The blog's 
purpose is to give Compliance Officers tools, reference information and 
background as to what is going on. 

 

That the SEC is getting involved in Compliance investigations indicates to me 
increased scrutiny of companies' compliance issues.  As a technical issue, this 
appears to me to be bureaucratic overreach at the least, since SEC and DOJ 
aren't safety organizations like OSHA.  I think out-of-compliance issues should 
be (1) safety based and (2) customer sourced.  SEC or DOJ get involved when 
there's a user-related problem or clear malfeasance (altering of documentation, 
unsubstantiated claims, etc.), which are covered under existing laws.

 

As I see IEC 

Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[John Allen]

And I should have added that I, for one, am quite glad that “compliance” is now 
a far more widespread discipline than it used to be as it may mean that we get 
fewer financial and other scandals that might have been avoided if the relevant 
regs and rules had been followed and enforced over the last 10 years or so – 
they affected me, and many others like some of you guys.

 

John Allen

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 17 January 2016 08:28
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

 

Morning all from a slightly snowy Southern England

 

Over the years I’ve received a number of approaches from financial services 
recruitment companies about jobs in that industry sector – and had to outline 
the Compliance Engineer role to them because they were not aware of there being 
compliance people outside their sector!

 

John Allen

W.London, UK

 

 

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: 17 January 2016 06:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

 

In generic terms Compliance is indeed nothing more than adherence to a set of 
rules. I once debated legal council at a company who wanted exclusive use of 
the term. I pointed out how this term is used in finance, medical, 
transportation, product safety, EMC and legal circles. Given a bit more time 
I'm certain I could come up with a list nearly as long as your arm. This one 
reason why I personally prefer the term Compliance Engineer. It is unique to 
this business sector. Among my peers, I like to be more specific and mention 
product safety engineer or EMC engineer.  

 

All the best, Doug

 

 

Douglas E Powell

doug...@gmail.com 

‎https://www.linkedin.com/in/dougp01

 

 

‎ 

 

 

 


From: Brian Gregory

Sent: Saturday, January 16, 2016 11:24 PM

To: EMC-PSTC@LISTSERV.IEEE.ORG

Reply To: Brian Gregory

Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

 

 

Ah yes, I recall a conversation with a bright one from Garrad Hassan about a 
mutual customer.  He was establishing their compliance with GH's established 
financial qualifications for an undisclosed analysis.  I picked on the 
distinction rather quickly and had to clarify to him what compliance meant to 
me, representing an NRTL.

 

Colorado Brian 



-- Original Message --
From: Scott Aldous <0220f70c299a-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?
Date: Fri, 15 Jan 2016 10:11:52 -0800

As is made somewhat more clear in this article 
<http://www.fcpablog.com/blog/2015/11/9/sec-we-protect-compliance-officers-except-when-we-prosecute.html>
  (linked to by the original), this has nothing to do with technical product 
compliance but is about securities compliance 
<https://en.wikipedia.org/wiki/Securities_regulation_in_the_United_States> .  

 

Sloppy use of the term "compliance" with no explanation of the specific meaning.

 

Scott (am I the "other" Scott?) just made a similar point... I will post anyway.

 

On Fri, Jan 15, 2016 at 9:52 AM, Brian Gregory <brian_greg...@netzero.net> 
wrote:

 

 If you read the article (and others) it can be read either way.  The blog's 
purpose is to give Compliance Officers tools, reference information and 
background as to what is going on. 

 

That the SEC is getting involved in Compliance investigations indicates to me 
increased scrutiny of companies' compliance issues.  As a technical issue, this 
appears to me to be bureaucratic overreach at the least, since SEC and DOJ 
aren't safety organizations like OSHA.  I think out-of-compliance issues should 
be (1) safety based and (2) customer sourced.  SEC or DOJ get involved when 
there's a user-related problem or clear malfeasance (altering of documentation, 
unsubstantiated claims, etc.), which are covered under existing laws.

 

As I see IEC regulations leaning more towards risk management/aversion, I get 
the feeling that standards organizations are also contributing to this 
overreach by trying to solve problems, via regulation/standardization that 
haven't been proven yet to be problems in the actual marketplace of people, 
customers and products.  If you've been involved in any STP's, it's hard to 
avoid the feeling that there are some making hay out of increased regulatory 
oversight, including many ways that help consultants more than end users.

 

 

Colorado Brian 

-- Original Message --
From: "gdstuyvenb...@yahoo.com"  
<058ee1229c70-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?
Date: Fri, 15 Jan 2016 13:29:10 +

Ken, wasn't suggesting increased governme

Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[John Allen]

Morning all from a slightly snowy Southern England

 

Over the years I’ve received a number of approaches from financial services 
recruitment companies about jobs in that industry sector – and had to outline 
the Compliance Engineer role to them because they were not aware of there being 
compliance people outside their sector!

 

John Allen

W.London, UK

 

 

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: 17 January 2016 06:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

 

In generic terms Compliance is indeed nothing more than adherence to a set of 
rules. I once debated legal council at a company who wanted exclusive use of 
the term. I pointed out how this term is used in finance, medical, 
transportation, product safety, EMC and legal circles. Given a bit more time 
I'm certain I could come up with a list nearly as long as your arm. This one 
reason why I personally prefer the term Compliance Engineer. It is unique to 
this business sector. Among my peers, I like to be more specific and mention 
product safety engineer or EMC engineer.  

 

All the best, Doug

 

 

Douglas E Powell

doug...@gmail.com 



‎https://www.linkedin.com/in/dougp01

 

 

‎ 









 


From: Brian Gregory

Sent: Saturday, January 16, 2016 11:24 PM

To: EMC-PSTC@LISTSERV.IEEE.ORG

Reply To: Brian Gregory

Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

 

 

Ah yes, I recall a conversation with a bright one from Garrad Hassan about a 
mutual customer.  He was establishing their compliance with GH's established 
financial qualifications for an undisclosed analysis.  I picked on the 
distinction rather quickly and had to clarify to him what compliance meant to 
me, representing an NRTL.

 

Colorado Brian 



-- Original Message --
From: Scott Aldous <0220f70c299a-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?
Date: Fri, 15 Jan 2016 10:11:52 -0800

As is made somewhat more clear in this article 
<http://www.fcpablog.com/blog/2015/11/9/sec-we-protect-compliance-officers-except-when-we-prosecute.html>
  (linked to by the original), this has nothing to do with technical product 
compliance but is about securities compliance 
<https://en.wikipedia.org/wiki/Securities_regulation_in_the_United_States> .  

 

Sloppy use of the term "compliance" with no explanation of the specific meaning.

 

Scott (am I the "other" Scott?) just made a similar point... I will post anyway.

 

On Fri, Jan 15, 2016 at 9:52 AM, Brian Gregory <brian_greg...@netzero.net> 
wrote:

 

 If you read the article (and others) it can be read either way.  The blog's 
purpose is to give Compliance Officers tools, reference information and 
background as to what is going on. 

 

That the SEC is getting involved in Compliance investigations indicates to me 
increased scrutiny of companies' compliance issues.  As a technical issue, this 
appears to me to be bureaucratic overreach at the least, since SEC and DOJ 
aren't safety organizations like OSHA.  I think out-of-compliance issues should 
be (1) safety based and (2) customer sourced.  SEC or DOJ get involved when 
there's a user-related problem or clear malfeasance (altering of documentation, 
unsubstantiated claims, etc.), which are covered under existing laws.

 

As I see IEC regulations leaning more towards risk management/aversion, I get 
the feeling that standards organizations are also contributing to this 
overreach by trying to solve problems, via regulation/standardization that 
haven't been proven yet to be problems in the actual marketplace of people, 
customers and products.  If you've been involved in any STP's, it's hard to 
avoid the feeling that there are some making hay out of increased regulatory 
oversight, including many ways that help consultants more than end users.

 

 

Colorado Brian 

-- Original Message --
From: "gdstuyvenb...@yahoo.com"  
<058ee1229c70-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?
Date: Fri, 15 Jan 2016 13:29:10 +

Ken, wasn't suggesting increased government regulation, rather useful tips for 
our own consideration.  

 

Gary Stuyvenberg

Thompson Consulting

 

  _  

From: Ken Javor <ken.ja...@emccompliance.com>
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Sent: Thursday, January 14, 2016 10:59 PM
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?

 

“Last week was a good one for the compliance profession. “

Could not disagree more.  This is big brother, or socialism, call it what you 
will.  A product either meets requirements, or it doesn't. The gov’t 
instructing the private sector on how to get there is w

[PSES] US CPSC "Consumer Products Safety Robot"

[John Allen]

Hi


People on LinkedIn may have seen this, but others may not and so I'm posting
a link here:

 

http://consumerproductlaw.com/lawyer/2016/01/15/CPSC/Here-Comes-The-Consumer
-Product-Safety-Robot_bl23096.htm

 

It's not actually a "robot" but is a piece of free s/w to, as it states in
the 2nd paragraph on the page, "assist companies and others in navigating
the complex and confusing maze of federal regulatory requirements that apply
to consumer products. It provides businesses with necessary compliance
information specific to their own products. "


It's accessible via the CPSC's website at https://business.cpsc.gov/robot/

 

 

Might help non-consumer product suppliers as well, but I don't know as I
have not checked it out myself as yet - comments from interested people
would be useful.

 

John  Allen

W.London, UK


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Re: [PSES] Is your company doing enough to ensure adequate EMC compliance?

[John Allen]

FWIW, I wasn't actually pointing to the financial sector, and/or the US ones
in particular, because I have no particular expertise in that  area -
especially w.r.t. the US, but some of the UK & European banks were either
complicit and/or just as bad/worse anyway!

 

What I actually said was  "financial and other scandals"   - which includes
many other and different areas from fake or "non-compliant" materials
/products (consumer electronics ring any bells?)  to deliberate misuse of
substandard materials in life changing/threatening applications (such as the
breast plants made from normal industrial materials instead of specialist
medical grade ones).

 

Therefore, In that respect, I do agree that EMC compliance is, in the
majority but certainly not all, of products/cases a relatively "low level"
compliance issue by comparison. 

 

However, it is, and it should be, a sub-set of a company's legal and ethical
approach to do no harm and improve the lot of its customers. Having worked
for many (too many!) companies over the years, I have encountered some
senior management "real cowboys" -  and "walked away" in at least one case
-, plus many middle managers and senior engineers, who did not care a s***
for making sure the products were as reasonably compliant as possible to
whatever regs/stds applied. Unfortunately that mindset then influences those
who work for them (and/or know no better), and that in turn can lead to
many, and worse, things being done/not done.

 

It was therefore a great relief to work for the "old HP" for a few years
because of the "HP Way" approach to products and product compliance - and
that certainly included EMI (no immunity requirements at that time) stds &
regs. Unfortunately very few of the companies I worked for after that were
as ethical or diligent. L

 

John Allen

W.London, UK

 

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: 17 January 2016 16:10
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC
complia nce?

 

We are getting off-topic here, but I can't let this one go without comment.
The "financial melt-down" in the USA back in 2008/2009 was initiated by the
very US government which is now in a lily-white, holier-than-thou mode
enforcing all sorts of rules-of-conduct to make sure, as Mr. Allen says,
that this doesn't happen again. USG had been forcing banks into making
mortgage loans that were not backed by adequate security.  Meaning, they
were legally forced to make loans to people who shouldn't have been
qualified. They did this to avoid accusations of various sorts of
discrimination that had become illegal.  Faced with massive amount of bad
debt, bankers attempted to off-load that bad debt by selling mortgage-backed
securities, which were worthless, but people didn't know it. It was like a
game of "Old Maid," with the holder of the "Old Maid" trying to dump it on
someone else.

The USG by forcing bankers to take on bad debt converted the banking
industry from one fundamentally based on truth and integrity (as perceived
by the public) into a group of con artists. But they became con-artists in
response tot the government stimulus of forcing them to make bad loans. 

People refer to the bad actors in the banking/mortgage industry without
referencing that it wasn't always like that, and it was the USG that
transformed that industry from a reputable one into a disaster.

Ken Javor
Phone: (256) 650-5261



  _  

From: John Allen <john_e_al...@blueyonder.co.uk>
Reply-To: John Allen <john_e_al...@blueyonder.co.uk>
Date: Sun, 17 Jan 2016 09:13:02 -
To: <EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC
complia nce?

And I should have added that I, for one, am quite glad that "compliance" is
now a far more widespread discipline than it used to be as it may mean that
we get fewer financial and other scandals that might have been avoided if
the relevant regs and rules had been followed and enforced over the last 10
years or so - they affected me, and many others like some of you guys.
 
John Allen
 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 17 January 2016 08:28
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC
complia nce?

Morning all from a slightly snowy Southern England
 
Over the years I've received a number of approaches from financial services
recruitment companies about jobs in that industry sector - and had to
outline the Compliance Engineer role to them because they were not aware of
there being compliance people outside their sector!
 
John Allen
W.London, UK
 
 

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: 17 January 2016 06:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequ

[PSES] Software Safety to UL1998

[John Allen]

Hi,


We're looking for a software safety engineer that knows UL1998.  Please respond 
to me directly, and quickly :-).


Thanks,


John




John Allen | President | Product Safety Consulting, Inc.

Your Outsourced Compliance Department®

http://www.productsafetyinc.com

630-238-0188

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Re: [PSES] Brexit and the European Compliance Complex

[John Allen]

Don't think so - but there might be a "Yuck" marking from some Europhobics
J.

 

From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org] 
Sent: 27 June 2016 19:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit and the European Compliance Complex

 

John et al,

 

  Anyone  betting on a CEuk marking
yet?  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

  p.perk...@ieee.org

 

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Sunday, June 26, 2016 1:05 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit and the European Compliance Complex

 

I can't see any reason to invalidate the CE mark. The former 'BEAB' mark was
demoted to voluntary after the general agreement in Europe to move away from
3rd-party certification, mostly due to legal liability issues - the test
houses were being asked to declare safe products whose contents were not
anywhere near sufficiently under their control.

 

With best wishes DESIGN IT IN! OOO - Own Opinions Only

  www.jmwa.demon.co.uk J M Woodgate and
Associates Rayleigh England

We live in exiting times

 

From: Richard Nute [mailto:ri...@ieee.org] 
Sent: Sunday, June 26, 2016 8:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit and the European Compliance Complex

 

 

Will the CE mark continue to be accepted in the U.K.?  Or, will the old U.K.
marks be resurrected?

 

 

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Re: [PSES] Brexit and the European Compliance Complex

[John Allen]

Ed

 

I seriously doubt that our technical regulatory requirements (at least in
the compliance area in question) will change that much as they have always
been prepared and applied with a "soft touch" approach.

 

We trade with both Europe and the RoW, and the technical standards of most
countries (except notably for those which have followed traditional
US/Canadian requirements and standards) are mostly IEC-based and so it would
make no sense for the UK to do anything else. Anyway, we will hopefully join
the EEA and those countries have to apply the same overall requirements and
standards as the EU. For example, as John Woodgate said in another thread,
about the EMCD, it would make no sense for the UK to loosen its EMC
requirements - especially in today's World where poor EMC control is a
threat to many areas of commerce, industry and the domestic environment. 

 

The military-side standards are nowadays heavily driven by the need to buy
equipment from whichever  countries and suppliers can provide it - and a
single platform may incorporate items from multiple suppliers. 

 

There have been, and are, ongoing efforts to "harmonise" MIL-STD-461 and DEF
STAN 59-411 (and the parallel standards of a number of other European
countries) - do a search on the "Allied Environmental Conditions And Test
Publications" (AECTP) and you will find a number of NATO standards which
could be relevant, notably AECTP 500 "Electromagnetic Environmental Effects
Test and Verification" (January 2011)

 

I expect that to continue - but there are likely to be continuing
differences in specific areas as no two defence organisations have exactly
the same technical requirements and expectations as their fields of ops may
differ (think of the differences between the requirements naval carrier ops
for top-side and below-decks equipment, or between airforce aerial platforms
and land-based equipment).

 

As for the overall "burden" of regulations, I think that the tech regs
requirements are not really the problem area - it's more those
business-operations and finance (etc) regs where the burden is most keenly
felt, especially, it is said, by SMEs. Other areas which cause particular
concerns to some regions of the UK are those related to the environment and
energy, off-shore fishing quotas, and especially immigration & border
controls - where the UK (or what is eventually left of it if, e.g. Scotland
decides to hold another independence referendum and then leaves) is at odds
with many other EU Member States and the Brussels central governing
organisation on what it is allowed to do, or not.

 

John E Allen

W.London, UK


PS: I voted to Remain - but let's not get into another of those discussions
are they are interminable and get a lot of people very annoyed (been there,
done that, over the last couple of days L)

 

 

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: 26 June 2016 12:11
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Brexit and the European Compliance Complex

 

Now that the UK has voted to withdraw from the European Union, how will this
affect the regulatory compliance landscape of the UK market? I have heard
that trade into the EU represents about 6% of the UK's GDP (is that true).
If that is so, then will the UK assert its own national compliance
structure? Will the UK simply copy the existing EU compliance Directives,
Norms and Standards (as they were already published in UK versions), or will
the UK feel it necessary to have a complete new system? (I recall that the
British MoD decided on this second option, essentially rewriting the US
MIL-STD-461 as their own DEF-STAN 59-41 and then 59-411.)

 

Is there a sense within the UK that having to follow the numerous, complex
and opaque EU regulations (sorry to have to say that, but that seems to be
>80% of all our conversations now) has become onerous and that a move to UK
national regulations would be a chance to simplify and eliminate burdens?

 

The current UK government was not enthusiastic about Brexit, so are there
any predictions about how happily and efficiently it will move to complete
the withdrawal (I understand that they have 2 years maximum). However,
assuming that the current government does move ahead to comply with the will
of their nation, what are the first significant changes that will affect
both UK companies and foreign companies trading with the UK?

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

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Re: [PSES] Brexit and the European Compliance Complex

[John Allen]

Rich

 

(Almost!) Everyone here knows the marking, and some of them actually know
what it means and how to apply it (many still don't), and it is in all the
relevant legislation - and that is almost certainly how it will remain as I
can't see anyone wanting another change, especially the legislature and
enforcement agencies.

 

John E Allen

W.London, UK

 

From: Richard Nute [mailto:ri...@ieee.org] 
Sent: 26 June 2016 20:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brexit and the European Compliance Complex

 

 

Will the CE mark continue to be accepted in the U.K.?  Or, will the old U.K.
marks be resurrected?

 

 

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Re: [PSES] EMO vs EPO

[John Allen]

Evening

 

Getting a bit out-of-date in this area, but there is quite a lot in Clause 9 
“Control circuits and control functions” of 60204-1; 2006 as amended, and that 
also refers to the safety-related aspects of control functions given in ISO 
13849-1, ISO 13849-2 and IEC 6206 (none of which I have access to)

 

However, Clause 9.2 of Clause 9 defines 3 categories of stop functions:

– stop category 0: stopping by immediate removal of power to the machine 
actuators

(i.e. an uncontrolled stop – see 3.56);

– stop category 1: a controlled stop (see 3.11) with power available to the 
machine

actuators to achieve the stop and then removal of power when the

stop is achieved;

– stop category 2: a controlled stop with power left available to the machine 
actuators.

 

Clause 9 then goes on to outline the above in more detail.

 

Maybe the latest edition of NFPA 79, which very much mirrors 60204-1, has 
similar or more info?  Otherwise you might need to refer to the other ISO/IEC 
standards mentioned above.

 

 

Joh E Allen

W.London, UK

 

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: 27 June 2016 19:50
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EMO vs EPO

 

All,

 

Is there an official fine point distinction between Emergency Off (EMO), 
Emergency Power Off (EPO) and Emergency Stop or are they all equivalent and 
interchangeable terms?

 

To my thinking, if there is a distinction, it would seem that Emergency Stop is 
related to mechanical hazards or moving parts, EPO is related to electrical 
hazards and EMO would be a general "catch all" acronym for any type of hazard 
whether mechanical, electrical, radiation, chemical, etc.  

 

Thanks!  Doug

 

 

 

-- 

 

Douglas E Powell

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

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Re: [PSES] NRTL invoices

[John Allen]

Morning

 

"Someone" really should have reported at least the first 2  of those
incidents to the relevant NTRL or to OSHA because that totally devalues the
FUS concept and is effectively fraud and could lead to dangerous products on
the US market L. OTOH, I doubt that anyone in the actual factories would
have worried much - anything for an "quiet life"!

 

Some of the others display a chronic lack of technical training and/or
expertise on the parts of the auditors in question, and could also lead to
cases where auditors don't spot safety-related discrepancies, and don't
issue stop shipment/variation notices, where they should have - and they
reflect very badly on the NTRLs which employ them. So what "qualifications"
(etc.) are the NRTLs required to ensure that their auditors have?

 

John Allen

W.London, UK

 

-Original Message-
From: Brian O'Connell [mailto:oconne...@tamuracorp.com] 
Sent: 11 February 2016 23:05
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] NRTL invoices

 

Refusal to pay for any audit services rendered that the NRTL deems necessary
will result in suspension of right to apply their mark to any products.

 

Stuff seen during various NRTL FUS audits:

- Asia sites - auditor arrives 0830, reads papers and drinks coffee until
1100, returns at 1300 with papers for QA to sign.

- Latin America site - auditor arrives 1030, asks what is in production,
logs times of 0800-1500 on audit form, then leaves about 1100.

- U.S. customer site - auditor arrives 0930, inspects units that do not bear
his agency's marks (and have never been assessed by any NRTL), writes
variation notice, then leaves about 1100.

- Canada customer site - auditor arrives 0730 goes directly to receiving
inspection and goes through files and component records then abruptly walks
out at 1600 with the audit report taped to the QA office door.

- Asia site - auditor writes variation notice because hi-pot test level is
too high. Their agency required 2500V, another wanted 3kV.

- Asia site - auditor writes variation notice because product is being
hi-potted twice during production process, and because one test level is a
bit higher than the report.

- Latin America site - auditor issues variation notice because cord sets
were bulk-packed in a separate box. 

- Latin America site - auditor issues variation notice because no ground
bond test is being done on a class II construction (auditor previously saw
it being done on a class I product). And there was no requirement in the
construction report.

 

Brian

 

-Original Message-

From: Richard Nute [ <mailto:ri...@ieee.org> mailto:ri...@ieee.org]

Sent: Thursday, February 11, 2016 2:27 PM

To: Brian O'Connell;  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
EMC-PSTC@LISTSERV.IEEE.ORG

Subject: RE: [PSES] NRTL invoices

 

When I was hosting the FUS, I had a rule that inspection would not interrupt
or disrupt production.  I insisted that the inspector identify the products
to be inspected, the construction, and the components before we went to the
factory floor.  If the product was not in production that day, then it could
not be inspected.  I determined when it would be in production, and the
inspector could return on that date.  (Never happened.)  I refused to pay
for a non-inspection. 

 

I set a goal of zero variances from an inspection.

I did my own inspection in advance of when the unannounced inspection would
take place.

(Inspections at that time were quarterly; I could anticipate a window in
which the inspection would

occur.)  I found and corrected either the construction or the report.  The
certification house couldn't believe we could go so long -- two years --
without a variance, so they sent managers to oversee the inspections.  Zero
variances.

 

Rich

 

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